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3SGI0N VII!
INDUSTRIAL
PRETREATMENT PROGRAM
Draft
NGYME3 1334
INSPECTION
MANUAL
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Gore Illustration by Hathanial Miullo
Cavmr Daaign by Unda J. Pataraon
Aagion VIII
0.5. Bwicenaantal Protection kg*ney
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INDUSTRIAL PRETREATMENT PROGRAM
INSPECTION MANUAL
DRAFT
Max H. Dcdson
Director, Water Management Division
U.S. Environmental Protection Agency
Region VIII
Marshall P. Fischer - Industrial Pretreatsnent Coordinator
Lisa Luebke - Associate Industrial Pretreatnent Coordinator
Linda J. Peterson - Pretreatment Program Specialist
EPA 908/3-84-004
November 1984
Ccmpliance Branch
Water Management Division
Region VIII
U.S. Environmental Protection Agency
I860 Lincoln Street
Denver, Colorado 80295-0699
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TABLE OF CONTENTS
CHAPTER
1
INTRODUCTION AND BACKGROUND
CHAPTER
2
PREPARING FOR AN INDUSTRIAL USER INSPECTION
CHAPTER
3
GENERAL PRINCIPLES OF SAFETY
CHAPTER
4
QUESTIONS FOR INDUSTRIAL FACILITIES INSPECTIONS
CHAPTER
5
SAMPLING INDUSTRIAL USER WASTEWATERS
CHAPTER
6
SAMPLE CONTROL & CHAIN-OF-CUSTODY PROCEDURES
CHAPTER
7
FOLLOW-UP COMPLIANCE ACTIVITIES
CHAPTER
8
BASELINE MONITORING REPORTS (BMRs)
APPENDICES
A Finding Federal Regulations A Requirements
B Priority Pollutants & Effluent Limitation Parameters
C Sample Preservation Guidance
D Example of an Investigation Form
E Example of a Baseline Monitoring Report (8MR) Form
F Comparison of RCRA 5 Pretreatment Regulations
G List of Region VIII POTW Contacts for Pretreatment
H Abbreviated Standard Industrial Code (SIC) Listings
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CHAPTER 1
INTRODUCTION AND BACKGROUND
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o For new sources, achievement of Pretreatment Standards for
New Sources (PSNS) upon commencement of facility operations
The General Pretreatment Program Regulations provide that a POTW
which receives waste from industrial users, may develop and implement
an industrial pretreatment program in lieu of that of the
Environmental Protection Agency. The POTVi's program must assure that
all applicable federal pretreatment standards are properly applied and
enforced. Further, the POTW's program must be adequate to effectively
manage the types of industrial waste that it receives to protect
against any adverse impact to the plant and/or the environment.
Purpose of this Manual
This manual is intended to assist the POTW in its implementation
of an industrial pretreatment program by providing some guidance on
the maintenance of an effective industrial inspection program. This
document contains sections on site review, sample collection,
questions which will assist in evaluating the adequacy of a facilities
envrionmental controls, chain-of-custody, and general safety knowledge
for on-site evaluations.
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CHAPTER 1
INTRODUCTION
BACKGROUND
The Clean Water Act
Under the Clean Water Act (the Federal Water Pollution Control Act
Amendments of 1972. and amended as the Clean Water Act in 1977), the
Environmental Protection Agency (EPA) is charged with the
responsibility to restore and maintain the chemical, physical, and
biological integrety of the Nation's Waters. The Act established the
National Pollutant Discharge Elimination System (NPDES) permit program
to regulate point source discharges of wastewater to rivers and
streams. In addition, the Act required EPA to develop regulations to
control indirect users (industrial facilities) of Publicly Owned
Treatment Works (POTWs) to prevent these indirect users from
discharging pollutants that are not compatable or interfer with the
operation of the POTW.
EPA was unable to promulgate many of the regulations by the dates
contained in the 1972 Act and in 1976, was sued by several
environmental groups. In settlement of this lawsuit, EPA and the
plaintiffs executed a Settlement Agreement which was approved by the
Court. This Agreement required EPA to develop a program and adhere to
a schedule for promulgating effluent limitation guidelines for
Industries involved fn 21 major industrial categories. The Clean
Water Act of 1977 incorporated the terms of the"Settlement Agreement.
The Pretreatment Program
On June 28, 1978, EPA promulgated the General Pretreatment Program
regulations at 40 CFR 403. These regulations outline the
administrative framework of the National Pretreatment Program and
detail the basic responsiblities of any industrial user of a POTW. In
addition, for those industrial sources which fall into one of the 21
(subsequently expanded to over 30) categories of industrial operations
which had been identified as having a high potential for the discharge
of toxic substances, technology-based pretreatment standards must be
met as follows:
o For existing sources, acheivement within three years of the
promulgation of Pretreatment Standards for Existing Sources
(PSE5), and
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CHAPTER 2
PREPARING FOR AN INDUSTRIAL USER INSPECTION
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CHAPTER 2
PREPARING FOR AN INDUSTRIAL USER INSPECTION
Prior to going into the field, the Pretreatment Program inspector
must take the necessary time to prepare for the Inspection. This
includes a review of the appropriate files, lining up the laboratory
facilities to analyze samples to be taken, checking out the equipment
to be used, etc. The checklist which begins on page 2 should be a
valuable tool for the inspector.
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INDUSTRIAL PRETREATMENT PROGRAM
INSPECTION
PROCEDURES CHECKLIST
PREPARATION FOR THE INSPECTION
1. Determine the purpose for and the scope of the
Inspection for the given industry.
2. Determine if the industrial user has processes which are
subject to Federal Categorical Pretreatment Standards.
If so, check the following:
o Have Federal Categorical Pretreatment Standards
been either proposed or promulgated for the process
of that industrial user?
o If the Federal Categorical Pretreatment Standards
have been promulgated, what is the deadline for
submission of the industries Baseline Monitoring
Report (BMR) and the deadline for final compliance
with the Federal Categorical Pretreatment Standards.
o Has the Industrial user submitted a category
determination request to the Pretreatment Program
Approval Authority (i.e., EPA or the Pretreatment
delegated NPDES state)?
o Did the Industrial user develop a compliance
schedule for the installation of technology
required to meet the applicable Pretreatment
standards.
o Is there any information which shows that the POTW
has standards on that industry which are more
stringent than those established by the Federal
Categorical Pretreatment Standards?
3. Determine 1f the Industrial user is located in a POTW
with an approved Industrial Pretreatment Program. If
so, is the legal authority (e.g., municipal ordinance,
contract, etc.) used by that POTVf to implement the
Program available for review? Does the legal authority
contain requirements more stringent than the Federal
Categorical Pretreatment Standards?
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INDUSTRIAL PRETREATMENT PROGRAM
INSPECTION CHECKLIST page -2-
4. Oetermine 1f 1t is appropriate to Invite the POTW
representative to accompany (or assist) with the
inspection of the industrial user. Representatives from
POTWs with approved Pretreatment Programs should always
be invited to participate in routine inspections of
industrial users. A listing of representatives from
approved POTW programs should be maintained by the
inspectors.
5. Review the Pretreatment file information which may be
available for that industrial facility. Existing
Information such as plant layouts or process flow
diagrams should be copied and taken as reference
materials during the inspection and for verification of
their accuracy.
6. Review the Pretreatment files for POTWs with approved
Pretreatment Programs particularly with regard to the
annual reports filed by the POTW.
7. Review the appropriate regulations. Oetermine if the
facility has a RCRA TSD permit and, if so, review
conditions of that permit which might be applicable to
the on-site inspection.
8. Review available literature about unfamiliar industrial
process which may be encountered. Prepare specific
questions to be asked about industrial processes to be
encountered.
9. As appropriate, contact the industrial user to establish
a convenient date and time to perform the inspection.
In some cases, no advance notice should be given.
10. Prepare safety equipment, sampling equipment, and
sampling containers if monitoring activities may be
performed.
11. Carry a copy of the applicable portions of the Clean
Water Act and Pretreatment Program regulations with you.
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INDUSTRIAL PRETREATMENT PROGRAM
INSPECTION CHECKLIST page -3-
B. THE ON-SITE INSPECTION
1. Establish contact with the chief executive officer,
plant manager of engineer or another person 1n similar
authority.
2. Conduct a peripheral examination of the industrial
user. Note the size of the Industry, additional
buildings» outside chemical storage, and location of the
sanitary sewer. Look for evidence of any direct
discharges either into storm drains or adjacent drainage
areas.
3. Observe the physical characteristics of wastestream In
the sanitary sewer which 1s emanating from the
Industrial user, if access 1s available. Obtain samples
if appropriate.
4. Request a pre-inspection meeting/discussion with the
industry representative(s) to:
o Explain the purpose of the visit/Inspection.
o Emphasize that any process Information necessary
for the inspection report which the industry feels
is proprietary can be handled as confidential
information. However, advise the Industry that
effluent data is public information subject to
public access through appropriate means.
o Describe the information you wish to collect during
the inspection. Offer the industry official an
opportunity to review the inspection report form
that you Intend to complete.
o Provide the industry with any written information
about the Pretreatment Program, if available.
o Answer any other questions for the industry
representatives about the purpose of the visit or
about the Pretreatment Program. Advise the
Industrial user who to contact for those questions
you are either unable or unqualified to answer
yourself. (Don't assume any information:)
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CHAPTER 3
GENERAL PRINCIPLES OP SAFETY
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CHAPTER 3
GENERAL PRINCIPLES OF SAFETY
Introduction
This chapter of the manual discusses the basic principles of
safety and is intended as an introduction to various types of
physical, chemical, biological, and radiological hazards. Through an
understanding of the principles of safety, an industrial inspector
will be better prepared to recognize, handle, and avoid most safety
hazards that might be encounterd during a facility inspection.
Any discussion of safety must address accidents and accident
prevention. An accident may be the result of an unsafe act—such as
standing up in a small boat or not wearing a respirator properly—or
an ""safe condition—such as a leaking boat or toxic atmosphere.
These situations can be related since one individual's unsafe act can
result in an unsafe condition for someone else.
Accidents can be reduced or prevented by taking steps to:
1. Eliminate the unsafe condition.
2. Reduce unsafe acts.
A person must be on the offense for actions within one's own
control and on the defense against hazards that others may create.
Safety awareness is an integral part of industrial inspections.
Safety Programs
The goal of a safety and health program should be to improve the
safety and health of the work environment. Elements of a quality
safety and health program include:
Standard Operating Procedures
Standard operating procedures should be a written step-by-step set
of instructions for performing a task in a safe manner. Written
procedures make it easier for new employees to learn and for
supervisors to answer questions.
Work Practices
Work practices must be evaluated to verify the effectiveness of
the safety program. Safe work habits must be encouraged and unsafe
work habits eliminated.
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Environmental Monitoring
The monitoring of environmental conditions is important in
determining what procedures should be followed.
Personal Monitoring
While environmental monitoring gives airborne concentrations of
chemicals at different locations at a site, it does not necessarily
indicate what the worker is actually exposed to. That information
comes from sampling devices that the worker wears through the work
shift. These devices can be badges, electronic monitors, or pumps
pulling air through sampling media.
Personal Protective Equipment
Personal protective equipment may be necessary in the actual or
potential presence of toxic quantities of chemicals. Appropriate
equipment must be selected and all users properly trained in its use.
Engineered Safeguards
In general industry, engineered safeguards, such as ventilation
systems, are used frequently to control exposure to hazards. Because
of the limited use of engineered controls, the proper selection and
use of personal protective equipment may become very important.
Medical Surveillance
Medical surveillance is important in two ways. First, if
inspectors are handling any materials that could damage their bodies,
they must be checked to determine if any damage 1s occurring. There
are medical tests for determining if a worker has too much of a
chemical in his system. For example, blood tests can detect lead and
carbon monoxide; urine tests can aetect arsenic; and there are tests
to determine if the liver is functioning properly. Workers showing an
abnormal amount of a chemical in their systems should be removed from
their assignments or have their operating procedures reevaluated.
The second reason for medical surveillance is to ensure the worker
is capable of doing the job. Using respiratory protection strains the
pulmonary system. OSHA General Inaustry Standards require that:
"Persons should not be assigned to tasks requiring use of respirators
unless it has been determined that they are physically able to perform
the work and use the equipment."
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Education and Training
A safety program can be an effective means of reducing the rjsks
at hazardous material responses, but only if everyone knows the
program and follows it. This requires education, training, monitoring
of activities, feedback, and retraining. Employees have to learn the
proper procedures for the job. If the procedures require use of
particular equipment, then the workers should have "hands on" training
until they are familiar with It. Refresher courses in first aid,
safety,and procedures that are not used frequently are a good idea.
Safety Hazards
Hazard recognition is necessary as the first step to safe working
practices. This section discusses a number of categories of safety
hazards. A convenient system for characterizing hazards is the
Abnormal Energy Exchange concept. Injuries are produced when a
harmful amount of energy ts transferred from outside sources to the
human body. These sources are classified by the type of energy
transferred:
1. Physical Hazards:
A. Kinetic/Mechanical
B. Thermal
C. Electrical
0. Acoustic: explosions, loud machinery
2. Chemical Hazards: local effects, such as from corrosives,
and internal or systemic effects from toxic chemicals
3. Biological Hazards: poisonous plants and animals, disease
producing organisms
4. Radiological Hazards: ionizing and nonionizing radiation
Physical Hazards
Kinetic/Mechanical
This category includes hazards associated with movement (walking,
climbing), tools and machinery operation, and the transfer of
materials.
Walking: The first consideration in touring an industrial
facility is the appropriate footgear to be worn to prevent injury.
Generally, flat, closed shoes are recommended. However, if a
construction site or a site where heavy equipment is being used will
be visited, steel toe shoes are often recommended.
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When walking, an inspector must take care to be conscious of his
surroundings, above, around, and beneath him. Walking cautiously at a
facility will prevent the inspector from tripping or engaging himself
in a hazardous situation.
Extra precautions must be taken when walking on raised walkways if
guarorails or railings are absent. The precautions sometimes include
the use of a safety belt with a lifeline. There are two types of
safety belts:
1. Emergency (designed to safely stop a person who is fallina)
and
2. Normal use (support a person who is working, e.g., a window
washer's belt or help hoist).
Safety belts may also be necessary for inspectors climbing fixed
laaders that lack a cage or a ladder safety device. A ladder cage is
a structure that encloses a fixed ladder and 1s so narrow that a
person cannot fall down the ladder but is caught inside the cage. A
ladder safety device is a special rail and safety belt attachment
which allows an inspector to move freely up or down a fixed ladder,
but locks in place if there is a sudden movement downward.
Another hazard which the inspector must be aware of is hazards
from above. People working above ground are not always careful with
the placement of their tools. Consequently, the use of hardbats is
required in certain areas to prevent head injuries in the event a tool
or other material is dropped.
Inspectors can also be struck by vehicles (bulldozers, backhoes,
tractors, and trucks) used at a facility. Such vehicles are equipped
with a backup alarm to warn persons in the area that the vehicles are
moving in reverse.
Material Handling: Accidents in the manual handling of materials
are primarily the result of unsafe working habits. The following
paragraphs discuss those situations which most probably will be
encountered by the inspector:
A battery-charging area for battery powered trucks must be posted
with "NO SMOKING" signs due to the hydrogen gas emitted during
charging. Protective equipment (gloves, goggles, etc.) should be
worn when handling acids or corrosive materials.
Any driver operated equipment (truck, tractor) used on site with
uneven terrain must have some form of rollover protection to
prevent damage to its cargo.
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Compressed gas cylinders can present a physical hazard. The
cylinder can be overpressured and explode if heated or can become
a missile if its valve is broken off, releasing the compressed
gas. When any cylinder is not in use, the cap must be in place.
In addition, the cylinder must be chained upright or placed in a
horizontal position so that it cannot fall and break the valve.
Tool and Machinery Operation: Guarding is important in protecting
persons from the hazards associated with operating machinery. Even
wel1-coordinated and highly trained people may at times perform unsafe
acts which could lead to Injury and death.
The most common methods of guarding that might be used by response
personnel are:
Fixed enclosures which prevent access to dangerous parts.
Interlocking devices which automatically stop a machine if a
barrier is removed, a door to the operating part is opened, or
any part of the machine operator's body contacts the barrier.
Thermal
Thermal hazards generally come from fires and explosions. There
can also be a problem from heat stress due to weather conditions.
Fires and explosions: The two primary methods of preventing
thermal injury from fire or explosions are to prevent their
occurrence, or if they should happen, to be at a safe distance.
Prevention of fire or explosion involves recognizing the hazard and
taking the appropriate steps. This includes using equipment to detect
an explosive or flammable atmosphere (e.g., L£L meters) and using
equipment (e.g., explosion-proof instruments and non-sparking bronze,
brass, or aluminum tools) that will not cause ignition of flammable
materials.
In areas where flammable liquids are stored, handled, used,
dispensed, or transferred, smoking and the carrying of lighters,
matches, and other spark producing devices should b€ prohibited. Even
a spark generated by static electricity can have sufficient energy to
ignite some flammable or explosive materials. Fire risks can also be
reduced by using approved equipment such as safety cans equipped with
spring loaded covers for storing flammable liquids.
If a fire starts, the fire department should be contacted
irrmediately. It will dispatch properly trained and equipped personnel
to handle the situation. If the fire is small, persons may attempt to
handle it by using the proper portable fire extinguisher:
Portable fire extinguishers should be available around electrical
equipment and where'any flammable liquids are stored or dispensed.
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Portable fire extinguishers are classified by the National Fire
Protection Association according to the types of burning materials
they are designed to extinguish:
Class A: Ordinary combustibles, such as wood, paper,
textiles*
Class B: Flammable liquids, such as oil, grease, paint.
Class C: Fires involving electrical wiring and equipment
where safety requires the use of electrically
nonconductive extinguishing media. This class is
based on fire location and not burning material.
Thus, an extinguisher will not be marked only for
Class C, but will be AC, BC, or ABC and should be
selected accordingly.
Class 0: Combustible metals, such as magnesium, sodium,
zinc, powdered aluminum.
Heat Stress: The htsnan body is designed to function at a certain
internal temperature. When metabolism or external sources (fire,a hot
summer day) cause the body temperature to rise, the body seeks to
protect itself by triggering cooling mechanisms. Excess heat is
dissipated by either changes in blood flow to dissipate heat by
convection (causing "flushing" or reddening of the skin) or
perspiration. The use of protective clothing generally increases heat
stress problems.
The major disorders resulting from heat stress are:
Heat cramps: Painful spasms which occur in the skeletal muscles
or persons who sweat profusely in the heat and drink large
quantities of water, but fail to replace the body's lost salts or
electrolytes. Drinking water while continuing to lose salt tends
to dilute the boay's extracellular fluids. Soon water seeps by
osmosis Into active muscles and causes pain.
Heat exhaustion: Extreme weakness or fatigue, diz2ines, nausea,
ano neadache. In serious cases, a person may vomit or lose
consciousness. The skin may be clammy and moist, the complexion
pale or flushed, and body temperature normal or slightly higher
than normal. The treatment is rest in a cool place and
replacement of body water lost by perspiratiuon.
Heat stroke: A very serious condition caused by the breakdown of
tne Doays heat regulating mechanism. The skin is very dry and
hot with a red, mottled or bluish appearance, unconsciousness,
mental confusion, or convulsions may occur. As first aid
treatment, the person should be moved to a cool place. Body heat
should be reduced artificially, but not too rapidly, by soaking
the person's clothes with water and fanning them.
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The steps that can be taken to reduce heat stress are:
1. Acclimatize the body. Allow a period of adjustment to make
further heat exposure endurable.
2. Drink more liquids to replace body water lost during sweating.
3. Rest frequently.
4. Increase salt consumption. Sweat is mostly water with
smaller amounts of sodium than potassium salts. Replacement
fluids should be similar in composition. Thus, table salts
usually are not necessary and can be harmful.
5. Wear cotton long underwear under heavy chemical protective
clothing. The cotton will absorb perspiration and will hold
it close to the skin. This will provide the body with the
maximum cooling available from the limited evaporation that
takes place beneath chemical resistant clothing.
6. There are instruments that measure air temperature, radiant
heat, and humidity to give a heat index. The National
Institute for Occupational Safety and Health (NIOSH), the
ftnerican Conference of Governmental Industrial Hygienists
(ACGIH), and other groups use this index in their guidelines
on heat stress. However, these guidelinses are usually valid
only for acclimatized personnel wearing light summer clothing
and not chemical resistant protective gear.
Cold temperatures can also cause problems. The severe effects are:
Frostbite is a common injury generally affecting the extremities
of tne body. The signs of frostbite are:
The skin turns white or grayish-yellow.
Pain is sometimes felt early but subsides later. Often there
is no pain.
The affected part feels intensely cold and numb.
Hypothermia is characterized by shivering, numbness, drowsiness,
muscular weakness, and a low internal body temperature when the
boay feels warm externally. With both frostbite and hypothermia,
the affected areas need to be wanned Quickly. This is best done
by immersing in warm, not hot, water. In all cases, seek medical
assistance.
To prevent these effects from occurring, persons working in the
cold should wear aoequate clothing and reduce the time spent in the
cold area.
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Electrical
Shock is the primary hazard from electrical tools. Although,
electrical shock may not cause death, it can cause burns or falls that
lead to injury.
Ways for protecting personnel from shock are:
1. Grounding equipment
2. Using double-insultated tools
3. Using overcurrent devices such as fuses {which interrupt
current by melting a fusible metal strip) or circuit breakers
(which operate by temperature change or magnetic difference).
Additionally, tools and flexible cords should be inspected for damage
that could lead to shock. For more detailed information check the
National Electrical Code.
Acoustic
Excessive noise can destroy the ability to hear and may also put
stress on other parts of the body, including the heart. There is no
cure for most effects of noise; therefore, prevention is the only way
to avoid physical damage. The damage depends mainly on the intensity
and length of exposure. The frequency or pitch can also have some
effect, high-pitched sounds being more damaging than low-pitched ones.
Noise may fatigue the inner ear, causing hearing loss. After a
period of time off, hearing may be restored. Under some
circumstances, the damage may become permanent because cells in the
inner ear have been aestroyed and can never be replaced or repaired.
Permanent damage can be caused by long-term exposure to loud noise, or
in some cases, by brief exposure to very loud noises (explosions,
shock waves).
Noise can also put stress on other parts of the body causing the
abnormal secretion of hormones and tensing of muscles. Workers
exposed to noise sometimes complain of nervousness, sleeplessness, and
fatigue. Excessive exposure to loud noises can also reduce job
performance and may cause high rates of absenteeism.
OSHA regulations limit a worker's noise exposure to 90 Decibels
(dBA) for an 8 hour exposure. Time limits are shorter for higher
r.oise levels (Table 5-1). Instruments generally are designed'to use a
scale that correlates to the way the human ear responds to different
sound frequencies.
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Table S-I
LIMITS FOR HUMAN EXPOSURE TO NOISE
Sound level
bBA
Hours of exposure per day
80*
83*
85
87
90
92
95
97
100
102
105
110
115
120
130
32
21
16
12
8
6
4
0.5
0.25
0.125
0.03
3
2
1.5
~Sound levels below 85 dBA in themselves are not considered a
problem. However, levels between 80 and 85 do contribute to the total
exposure and, thus, are used in calculations. Source: Table 6-16a,
Appendix A. 29 CFR 1910.95, Occupational Safety and Health
Administration General Industry Standards, 1981.
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Vihen daily noise exposure is composed of two or more periods of
different noise levels, their combined effect should be considered,
rather than the individual effect of each.
If the combined effect exceeds the allowable limits, the employer
must use "engineering controls" (changes in the physical environment
like noise enclosures, mufflers, quieter tools) or "administrative
controls" law. While such controls are being implemented, workers
must be provided with personal protective equipment—usually ear-muffs
or earplugs— to protect their hearing. Hearing protectors are
assigned a Noise Reduction Rating (NRR) developed by EPA. The NRR for
each device 1s provided on its packaging.
Recent rulemaking by OSHA requires a continued, effective hearing
conservation program whenever worker noise exposures equal or exceed
an 8-hour time-weighted average sound level (TWA) of 85 decibels.
The main elements of the hearing conservation program is a
monitoring of workers' exposures:
1. An audiometric testing program for those exposed above an 85
dBA TWA. This requires a "baseline" audiogram for comparison
and annual retesting to see 1f there is any hearing loss.
2. Hearing protection available for those exposed to above 85
dBA TWA. If the TWA is above 90 d8A, or if it is above 85
dBA and the worker shows a permanent significant hearing
loss, then hearing protection is required to be worn.
3. Informing exposed workers about noise hazards (or effects)
and the elements of a hearing conservation program.
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Chemical Hazards
Industrial inspectors may be exposed to a variety of chemical
compounos ana potential chemical hazards. The inspector should be
aware of the following types of chemical reactions which might pose
some risk:
1. Heat generation (e.g., acid and water)
2. Fire (e.g., hydrogen sulfide and calcium hypochlorite)
3. Explosion (e.g., picric acid and sodium hydroxide)
4. Toxic gas or vapor (sulfuric acid and plastic)
5. Flammable gas or vapor product (e.g., acid and metal)
6. Synergistic toxicity (e.g., chlorine and ammonia)
7. Formation of shock sensitive compounds
8. Pressurization of closed vessels
9. Solubilization of toxic substances (e.g., hydrochloric acid
and chromium)
10. Oispersal of toxic mists or dusts
11. Violent polymerization (e.g., ammonia and acrylonitrile)
Fire Hazards
Combustibility: Materials that are readily ignited and continue
burning are considered combustible. Fuel, oxygen, and heat must all
be present in order for combustion to occur. The concentration of the
fuel and the oxygen must be high enough to allow ignition and maintain
the burning process.
Heat might either be supplied from the ignition source and then
maintained by combustion, or supplied from an external source. V/hen a
material by itself generates enough heat to self-ignite ana combust,
spontaneous combustion occurs, either as a fire or an explosion.
F1ammability: FTammability is the ability of a material (liquid
or gas) to generate a sufficient concentration of combustible vaoors
under normal conditions to be ignited and produce a flame. A proper
fuel to air ratio is necessary for combustion to occur. Each material
has a flammable range of fuel concentrations in air that are optimal
for ignition and to sustain combustion. The lowest concentration of
fuel in this range is called the Lower Flamnable Limit (LFL) and the
highest concentration is called the Upper Flammable Limit (UFL).
Concentrations below the LEL lack fuel to cause combustion. However,
concentrations above the UFL should be considered extremely dangerous
because, eventually, there is a zone where fuel concentrations are
within the flammable range.
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Toxic Hazards
Toxic materials cause local or systemic detrimental effects in an
organism. Types of toxic hazards can be categorized by the
physiological effect they have on the organism. A material may induce
more than one physiological response.
Systemic Poisons: Systemic poisons are chemical agents which act
on a specmc target organ or organ system. A subgroup of systemic
poisons is anesthetics and narcotics, which may not necessarily cause
irreversible harm, but do depress the central nervous system and cause
a loss of sensation or stupor.
Asphyxiants: Asphyxiants are agents which deprive the tissues of
oxygen (a conoition calleo anoxia). Simple asphyxiants dilute or
displace atmospheric oxygen. Chemical asphyxiants will either prevent
oxygen uptake in the blood or block oxygen transfer from the blood to
the tissue. Some extremely toxic compounds are both simple and
chemical asphyxiants.
Irritants: Irritants are materials that cause inflammation of
membranes. The mechanism of irritation is either by corrosive or
drying action and may effect the eyes, skin, respiratory membranes, or
gastrointestinal tract. The irritant must come in direct contact with
the tissue to cause a reaction.
Allergic Sensitizers: A sensitization to a chemical Involves
immune meonanisms, wnen a foreign substance called an antigen enters
body tissue, it triggers the production of antibodies which react with
the antigen to make it innocuous. Upon first exposyre to a specific
chemical, there are no antibodies in the body. After subsequent
exposures, the concentration of antibodies increase until a threshold
is reached. At this point, the antibody level is high enough that
upon exposure to the chemical the antigen-antibody reaction, also
called an allergic reaction, is severe enough to manifest itself as
one or more symptoms. The body has become "sensitized" to that
chemical.
Mutagens. Teratogens, and Carcinogens: An agent that can cause
cancer in an organism is called a carcinogen. This differs from a
mutagen, which changes a gene in a sperm or egg cell of the parent.
The parent is not affected but the offspring suffer the consequences.
Teratogenesis is also manifested in offspring but differs from
mutagenesis in that it results from exposure of the embryo or fetus to
the agent itself. While some teratogens and carcinogens have been
identified, 1t is not possible to accurately pinpoint mutagens because
of the difficulty in observing mutagenic action in cells.
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Corrosive Hazards
A corrosive agent is a reactive compound or element that produces
a destructive chemical change in the material upon which it is
acting. Upon contact, a corrosive material may destroy body tissue,
metals, plastics, and other materials. Common corrosives are the
halogens, acids, and bases. Skin irritation and burns are typical
results when the body contacts an acidic or basic material.
Chemical Reactivity Hazards
A reactive material is one that can undergo a chemical reaction
under certain specified conditions. Generally, the term reactive
hazard is used to refer to a substance that undergoes an abnormal or
violent reaction in the presence of water or under normal atmospheric
conditions.
Biological Hazards
The biological hazards that inspectors may encounter are usually
limited to animal bites or stings and contact with plants that can be
handled by first aid treatments. However, some exposure to microbes
may also be possible.
Microbial Hazards
Microbial hazards can occur when the materials the workers are
handling have biological as well as chemical contamination. This may
particularly be a problem if a chemical spill is into or mixed with
sewage. However, most bacteria that affect humans prefer a neutral
environment (pH 7). Thus, an extremely acid or alkaline environment
would destory or inhibit bacterial growth.
Radiological Hazards
Radioactive emissions can be dangerous to living organisms because
their energy ionizes molecules in the cells. The ionization may cause
cellular dysfunction or death. An industrial pretreatment inspector
should be aware of the three types of radioactive emissions that can
be encounterd:
1. alpha particles (positively charged),
2. beta particles (a negatively charged electron), and
3. gamna waves (pure electromagnetic energy).
The alpha and beta particles both have mass and can only travel short
distances in material, losing much of their energy. Thus, the outer
layer of the skin and clothing generally protect against these
particles. Alpha and beta particles are dangerous when they enter the
body through inhalation or ingestion. Gainra waves pass through all
materials to some degree; and thus, high levels must be avoided.
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Personal Protective Eauioment
Face and Eye Protection
Face shields are designed to protect the face from flying
particles and sprays of hazardous liquids and, 1n addition, to provide
antiglare protection when needed. Face shields should be worn over
appropriate goggles for protection against heavy flying objects, for
welding and curring, or against intense radiant energy.
In sane designs, a face shield can be attached to a bardhat. The
best combination is one that leaves no gap between the shield and the
brim of the hat and prevents overhead splashes from running down
inside the face shield. In areas or during operations where a harahat
face-shield combination would not provide adequate protection against
a hazardous chemical splash, a hood may be necessary.
The use of safety glasses, goggles, and face shields must meet the
requirements of the American National Standard Institute (ANSI) and
QSHA standards. Eye protection is available in three styles and is
designed mainly for protection against flying particles:
1. Spectacles with impact resistant lenses are patterned after
conventional correction eyeglasses, but are of more
substantial construction and may have sideshields. Clip-on
sideshields may also be available to add side protection.
Corrective tempered safety lenses can be mounted in
spectacles with safety frames.
2. Flexible or cushion-fitting goggles have a lens in either a
flexible frame or a rigid frame with a cushioned surface
where they contact the face and are usually ventilated to
prevent fogging. These goggles protect against fine dust,
fumes, liquids, splashes, mists, and sprays.
3. Eyecup goggles have lenses which can readily be removed
and/or replaced. Each eyecup has a lens retainer bearing
evenly on the lens with enough pressure to retain fragments
if a lens breaks. Many flexible or cushion-fitting goggles
and some eyecup goggles will fit over corrective spectacles.
Head Protection
Hardhats are designed to protect the wearer's head from impact
from flying or falling objects, splashes of liquids, electric shock,
or any combination of these. The hardhat must meet the ANSI
specifications for safety helmets as follows:
Class A: LIMITED VOLTAGE resistance for general service
3-14
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Class B:
HIGH VOLTAGE resistance
Class C: NO VOLTAGE protection
Class D: Limited protection for FIRE-FIGHTING
Manufacturers have adapted hardhats so that ear protection and
face shields may be easily attached. Liners, for use in cold weather,
and a ciiin strap may also be useful.
Foot Protection
Footwear is intended to protect against impact and/or liquid
hazardous chemicals and must meet ANSI specifications. For impact,
safety footwear generally has a metal cap or box built into the toe.
They may have other built-in features for specific needs such as
conductive soles to drain off static charges, no fasteners for quick
removal if splashed by molten metal, reinforced soles to protect from
nails or other sharp objects, Instep protection, or woodsoles for work
in wet areas.
Hand Protection
Hand protection may be needed in corrosive environments or around
certain toxic chemicals which can be adsorbed through the skin.
Gloves that are used for hand protection must consider the chemical
reactivity and resistance to materials being handled, resistance to
puncturing or tearing, as well as their allowance for the dexterity
necessary to accomplish the required task. Leather gloves tend to
quickly adsorb organic chemicals.
Protective Clothing
There are a variety of materials from which protective outer
garments are made. Normally, an inoustrial pretreatment inspector
will only require minimal protection. Disposable Tyvek or Nomex suits
can be used to protect work clothes when additional protection is
necessary. Occassionally, a splash suit (e.g., PVC) might be needed
if the inspector is in an area where there is a possibility of direct
contact with an acid or base.
Respiratory Protective Devices
Respiratory protective devices may be necessary to protect the
industrial inspector from oxygen deficiency, aerosol contaminants, or
gaseous contaminants. Respiratory apparatus are be divided into two
general categories:
1. Air purifying (respirators) and
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2. atmosphere-supplying (hose or airline masks, escape devices,
SCSAs).
Air purifying devices are only used if the atmosphere has at least
19.5% oxygen and there are no contaminants in excess of a contaminant
concentration published as Immediately Qangerous to Life or Health
(IDLH). An IOLH concentration is that concentration of a specific
contaminant at which an unprotected individual exposed for 30 minutes
or more suffers irreversable damage or dies.
Atmosphere-supplying respirators provide from 5 minutes to several
hours of breathing air. Special training is needed prior to using a
full Self Contained Breathing Apparatus (SCSA). However, self-rescue
units are often located in areas where sudden changes in the
atmospheric conditions of the workplace (e.g., around chemical storage
tanks) could take place. In no case can a self-rescue device be usea
to enter into a hazardous atmoshpere.
Confined Spaces
Confined spaces are areas which have limited openings for entry
and exit; unfavorable natural ventilation which could contain or
produce dangerous air contaminants, and which is not intended for
continuous employee occupancy. Confined spaces include storage tanks,
compartments of ships, process vessels, pits, silos, vats, degreasers,
reaction vessels, boilers, ventilation and exhaust ducts, sewers,
tunnels, underground utility vaults, and pipelines.
Because of poor ventilation, high concentrations of gases or
vapors are more certain to exist in a confined space than at an open
site. Also, certain confined spaces may contain hazardous materials.
For example, organic materials in an enclosed space can combine with
oxygen in the surrounding air to proauce an oxygen deficient
atmosphere.
Besides the problem with possible high concentration of gases or
vapors, confined spaces also present an entrance and exit problem.
Spaces with only small openings for entry and exit can cause
interference with the use of equipment 1 ike SCBAs. An airline
respirator may have to be used in place of an SCBA. Because of this
problem, and in case a worker is injured, a lifeline is often attached
to the worker to aid in pulling him out. That way, rescuers do not
have to enter the space. A lifeline is especially important in spaces
where access is through an opening in the top of the space.
The basic requirements for entry into a confined space are to:
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1. Test the atmosphere prior to entry far oxygen and toxic and
combustible levels of gases or vapors. If the oxygen content
is less than 19.5 percent, personnel will have to wear .
atmosphere-supplying respirators while in the area. If toxic
levels of chemicals are present, appropriate respirator
protection will be necessary. If ccnfcustible gas levels are
above 10 percent of the lower explosion limit, entry should
be delayed until the level falls below 10 percent. Forced
ventilation can be used to lower the concentration of toxic
or combustible gases and raise the oxygen content. However,
what chemicals will be removed from the space and where they
will go should be evaluated before starting ventilation.
2. Establish a system to mark a confined space unsafe should
tests indicate it is unsafe to enter. Markings are to remain
in place until tests indicate entry is safe.
3. Lockout, block, or otherwise deactivate all mechanical,
electrical, liquid, and gas systems relating to the confined
space that may create a hazard during entry if they are put
in motion or otherwise activated.
4. Develop emergency procedures for rescue inside the confined
space. This includes a person on standby outside the
confined space to observe the worker and provide help in an
emergency. Any rescue personnel entering the confined space
will need, as a minimum, the same protective equipment that
the person inside is using.
Lockout
Lockout, blocking, or equivalent measures may be needed when
someone is working on or around equipment that could cause injury if
it is accidentally turned on. The general procedure is to turn off
the equipment at a point where it can be locked so that the equipment
cannot be turned on. In some cases, there may be several workers,
each using a different lock on a switch so that all locks have to be
removed before equipment can be used.
First Aid
OSHA Construction Industry Standard 29 CFR 1926.50 - Medical
Services and First Aid requires that:
Prior to start of the project, provisions must be made for prompt
medical attention in case of serious injury. The telephone
numbers of the physicians, hospitals, or ambulances must be
conspicuously posted. Proper equipment must be provided for
prompt transportation of an injured person to a physician or
hospital, or a communication system for contacting necessary
ambulance service.
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Medical personnel are to be available for advice and consultation
on matters of occupational health.
At least one and preferably more persons at the worksite must be
trained in first aid. The American Red Cross, some insurance
carriers, local safety councils, and other organizations provide
acceptable training.
First aid supplies approved by a consulting physician must be
readily available. The supplies should be in sanitary and
weatherproof containers with Individually sealed packages for
material such as gauze, bandages, and dressings that must be
sterile.
It is important to remember that first aid is inmedlate temporary
treatment given in the event of accident or illness before the doctor
arrives. Some states have laws establishing limits on first aid given
by the lay person. Trained employees should understand where first
aid ends and professional medical treatment begins.
Additionaly, OSHA's Medical Services and First Aid Standards for
general industry require that areas where workers may be exposed to
splashes of corrosive materials should have facilities for flushing
the chemicals out of eyes and from the body. If a decontamination
line has been set up, it may provide the protection needed.
Otherwise, additional facilities will be needed.
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CHAPTER 4
QUESTIONS FOR INDUSTRIAL USER INSPECTIONS
-------
CHAPTER 4
QUESTIONS FOR INDUSTRIAL FACILITIES INSPECTIONS
This chapter of the inspection manual provides a variety of
Questions that are normally of concern at the different types of
industries visited by the industrial pretreatment inspector. However,
these questions do not encompass all possible questions that may
relevant to a specific facility within an industry in a listed
category. These questions are intended to be a guide for the
inspector and not to subsitute for using technical experts when the
need for such expertise arises. Further, the industrial Inspector
should research background material available on a given Industry and
formulate any additional questions before initiating the inspection.
The first group of questions deals with general items that may be
asked at most any facility. These items include chemicals, cooling
waters, solvents, boiler discharges, discharge locations, and sampling
points. The question which follow deal with specific industries. The
general questions should also be included, where applicable, during
inspections of the different industries.
4-1
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industry s.i.c. page
Adhesives and Sealants 2891 6
Aluminum Forming 3353 - 3471 5
Auto Body Repair & Paint Shops 7531-35 7
Auto Parts & Supplies: Retail 5531 7
Auto Engine & Transmission Work 7538 - 7439 7
Aito Wash 542 8
Bakeries 5462 8
Battery Manufacturing 3691-92 9
Beverages 2082-87 9
Blueprinting & Photocopying 7332 9
Canned & Preserved Fruits & Vegetables 2032-38,2099 9
Coil Coating (including canmaking) 3479-97 10
Copper Forming 3351 11
Dairy Industry 202X 11
Eating Establishments 5812 12
Electric Services 4911-31 12
Electronic Components 3671-79 13
Electroplating & Metal Finishing 3471 and 3479 13
Explosives 2892 14
Fiberglass Insulation 3296 15
Fuel Oil dealers 5983 15
Funeral Services 7261 15
Gasoline Service Stations 5541 16
Gum and Wood Products 2821, 2861 16
Hospitals 8062-69 17
Inorganic Chemicals 281X 17
Laundries 7211-19 17
Leather Tanning & Finishing 3111 18
Lumber & Building Materials, Retail 5211 19
Lumber and Wood Products 2411-99 19
Machine & Sheet Metal Shops 3599 19
Meat Products/Poultry Products 2011-17 20
Metal Fabrication (e.g. Sheet Metal) 3411-69 20
Metal Refineries and Foundries 3312-99 21
Nursing Care Facilities 8051-59 21
Organic Chemicals 2861-69 21
Paint & Ink Formulation 2851, 2893-99, 3951-55 22
Paper and Paper Products 2611-61 23
Paving & Roofing 2951-52 23
Pesticides 2869 and 2879 24
Petroleum Refining 2911 24
Pharmaceuticals 2831-34 25
Photographic Processing and Supplies 7395, 3861 26
Plastic & Synthetic Materials Manuf. 282X, 3079 26
Porcelain Enameling 3631-39 27
Printing and allied Products 2711-95 27
Rubber /Synthetic Rubber Processing 3011 - 3069, 2822 28
Schools and Universities 8211-22 29
Scrap Materials 30
Soap & Detergent Manufacturing 2841-44 31
Steam Supply & Non-Contact Cooling 33
Sugar Processing 2061-63 31
Textile Mills 2211-99 ,2311-99 32
Veterinary Services 0741-42 33
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GENERAL QUESTIONS
A. USAGE OF CHEMICALS, CLEANERS, AND LOCATION OF DRAINS
1. Check the proximity of any chemical storage areas to floor
drains. What kind of chemicals arestored? Chemicals might
include paint, thinner, solvents, etc.
* 2. Check the floor washdown procedures (frequency, water usage,
detergents). What is the frequency (daily, periodically,
etc.)? Are high pressure sprays used? Are any detergents used?
How is the wash water disposed?
3. Check for the usage of detergents and chemical cleaners for
equipment washdown. Acids (e.g. muriatic, sulfuric, phosphoric,
and acetic), surfactants, caustic soda, soda ash, and phosphates
are commonly used as cleaners. How are these materials stored?
B. COOLING WATERS
1. Are there any sources of uncontaminated cooling water in the
plant? Are there any sources of recirculated or once-through
cooling waters? What is the disposal method of the cooling water?
2. If contact cooling water is used, is it treated in any way before
discharge? What contaminants would be in the water?
3. Is there any water cooled machinery used by the facility? What
contaminants would be in the water? What is the volume and how
is the cooling water disposed of?
C. SOLVENTS
1. Does the facility use any solvents or degreasing agents?
2. Are any solvent wastes handled seperately from the other cleaning
solution wastes?
3. Is there any batch pretreatment prior to discharge?
4. How are any residual materials, sludges at the bottom of the tank
disposed of?
5. Is there a solvents managment plan to reduce solvent waste at the
facility?
6. If solvent is used, is it redistilled on-site? Does this
generate uncontaminated cooling water? Where is it discharged?
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GENERAL QUE5TI0NS (continued)
D. BOILER DISCHARGES
1. Check the frequency and volume of any boiler blowdown. Check on
the usage of additives to the boiler make-up waters? Oo the
additives contain any metals or priority pollutants?
2. What type of boiler pretreatment is used (e.g., ion exhanae,
chemical addition, etc.)? Are there any boiler wastes generated?
3. What is the frequency and volume of boiler blowdown?
4. Are there air pollution control devices which use water? How is
this water disposed of?
E. DISCHARGE LOCATIONS & SAMPLING POINTS
1. Are the facility's domestic and process wastewaters segregated?
2. Does the facility have a sampling point available which is
representative of the process wastewaters discharged?
F. FOOD PROCESSING
1 What are the products processed at this facility? What is the
production rate?
2. Does the facility use flow equalization prior to discharging into
the sewer? Does the facility have any provisions to respond to a
product spill into the wastewater system?
3. Does the facility generate any byproducts which have associated
wastewaters?
4. Is there any coloring added to the product? Is there any
treatment for removal of the color?
5. Check for the usage of chemical cleaners for equipment washdcwn.
Acids (e.g. muriatic, sulfuric, phosphoric, and acetic),
surfactants, caustic soda, soda ash, and phosphates are commonly
used as cleaners. How are these materials stored?
6. Check the floor washdown procedures. Are equipment and floors
washed down with water?
7. What is the water consumption rate of the operation (total
gallons per day and by number of pounds of product or pounds of
material processed)? How much water is generated by or
incorporated into the product?
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GENERAL QUESTIONS (continued)
8. What percent of water use is recycled? Does this include any
uncontaminated water {for refrigeration, machinery, etc.)?
9. What kind of containers does the facility use to package the
product? Are containers mace an site? Are they washed or
steri Hied?
G. PRETREATMENT
1. What kind of treatment systems does the facitity have in place
for each of the various types of process wastewaters discharged.
2. Are any of the process wastewaters subject to National
Categorical Pretreatment Standards?
3. Does the facility combine its waste from the various sources
prior to treatment or discharge? Is the combined waste stream
formula applicable?
H* SOLIDS DISPOSAL
1. How much sludge material is generated? How is the sludge
disposed? How much waste is stored on site?
2. Is the sludge either a listed RCRA waste or characteristic of a
hazardous waste (i.e., ingnitable, reactive, corrosive, or EP
Toxic)? Does this facility manifest the waste? Who handles the
waste transport/disposal?
I. RADIOACTIVE MATERIALS
1. Quantify the maximum quantity of each radionuclide used, stored,
and discharged at the facility.
1. How are liquid and solid radioactive wastes being disposed?
3. Are they being hauled away? If so, what is the name of the
hauler and what is the destination of the waste?
4. Are they being discharged to the sanitary sewer? If so, how
often and what are the maximum concentrations in Curies?
5. Obtain a copy of radioactive user licenses.
6. Obtain a copy of any protocols for handling radioactive materials
at the facility.
7. Obtain a copy of any logs pertaining to radioactive discharges.
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AOHESIVES AND SEALANTS
1. What is the product that is manufactured at this facility? .Are
the adhesives water base or organic solvent base materials? What
Icind of binder material is used?
2. Are there any product washing operations? Are reactor vessels
washed down between batches? Is water or a solvent used? Would
these wastes be discharged to the sewer?
3. Check the general questions on solvents.
4. Check the usage of cooling waters. See general questions.
ALUMINUM FORMING
1. What is the production rate of this facility in terms of mass of
aluminum or aluminum alloy processed per year?
2. What forming processes are used at the facility?
3. What kind of metal forming lubricating compounds are used?
4. How often are the lubricant-wastewater emulsions changed and
discharged?
5. Is there a continuous overflow from auenching water baths? What
is the disposal method for the quench waters?
6. Is any casting done on site? If yes, see questions under Metal
Refineries and Foundries.
7. Are any solvents used as part of the cleaning processes? Refer
to the general questions on solvents and cleaning agents.
8. Are wastewaters from desmutting and deoxidizing pretreated before
discharge to the sewers? What volume is discharged?
9. Are there any metal finishing processes (anodizing, chemical
conversion coatings, coloring, dyeing, chemical sealing, chemical
or electrochemical brightening, or etching) done on site? If
yes, see questions under Electroplating and Metal Finishing.
4-6
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AUTO BODY REPAIR & PAINT SHOPS (7531, 7535}
1. Oo the paint booths use a water curtain?
2. Check the paint spray-gun cleaning procedures and the method of
disposal of any cleanings.
* 3. How does the facility dispose of old or unwanted paint?
4. Is there any other disposal of any chemicals at this site? What
is the disposal method?
AUTO PARTS & SUPPLIES: WHOLESALE & RETAIL (5013, 5531)
1. If floor drains are present, is there any storage of oils, paint,
anti-freeze, transmission and brake fluids, or any other fluids
within the proximity of the drains? What is quantity of fluids
stored?
2. Check the location and manner of storage of batteries and battery
acid-.
3. Check for used crankcase oil return facilities.
4. Check for any machining or repair (see auto repair questions).
AUTO REPAIR (MECHANICAL) - ENGINE & TRANSMISSION WORK (7538, 7539)
1. Look for drains under service bays. What is the destination of
the drain.
2. Identify the location of any gas/oil interceptors or separators.
What kind of unit is it and what is the general operating
conoition of the unit?
3. Check on the use of solvents and parts degreasers? Check the
general questions on solvents.
4. Check for the storage of fluids such as oil, transmission, brake,
anti-freeze?
5. Check on the quantity ana method of waste oil storage and the
manner and location in which it is disposed.
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AUTO WASH (7542)
1. Check for any system for water reuse or reclamation such as. a
settling tank.
2. If a settling tank exists, check how the sludge from it is
handled and by whom. What is the ultimate disposal method?
3. Check what types of cleaners are used. Do any specialty cleaners
such as tire cleaners contain solvents? Do waxes contain
solvents? Check the general questions on solvents.
4. Check for an oil and grease separator on the discharge line.
5. Check for the storage of any liquids near the floor drains.
6. Check and Identify the water consumption level.
7. Can the facility handle trucks? If so, what kind of materials
might be contained by the trucks and what is the washwater
contamination from those materials.
RETAIL BAKERIES (5462)
1. Check the washdown and cleanup procedures.
a. Note washdown procedures (sequency of steps).
b. Note number of washdowns per day.
c. Note types of detergents used.
d. Note the location and number of floor drains.
2. Check the storage of cleaning agents.
3. Check the storage of baking ingredients.
4. Check the quantity of deep fry grease generated. Note how it is
disposed.
5. Check for the presence of any grease interceptor. Describe the
size and general condition of the unit. How often and by whom 1s
it serviced? How is grease disposed?
4-8
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BATTERY MANUFACTURING
1. What is the production rate of this facility? (number of units
manufactured, amper hour output, etc.)
2. What is the primary reactive anode material (cadmium, calcium,
lead, Leclanche, lithium, magnesium, nuclear, zinc) used for the
batteries produced by the facility?
3. What volume of wastewater from electrodeposition rinses, scrubber
bleed off and caustic removal is discharged to the sewers?
4. Are depolarizers used in the manufacturing process? What type?
What is the final disposal method of these materials?
5. What kind of electrolytes does the facility use? Check the
questions on chemical storage.
BEVERA6ES
1. Check the general questions for Food Products.
BLUEPRINTING & PHOTOCOPYING (7332)
1. Check to see if they do any offset printing (relateo questions).
2. What type of blueprinting machines are being used? With some,
the total amnonia is totally consumed while others will have
spent ammonia solution to dispose.
3. Is there a significant amount of ammonia stored? Check the floor
drains.
4. Check the usage of other cleaning agents and solvents. Are any
chemicals of concern?
CANNED & PRESERVEO FRUITS & VEGETABLES (2099, 2032, 2033, 2034, 2035,
1. Check what detergents and techniques are used in washing the
fruits and vegetables before rinsing.
2. In addition to checking the water usage for washing, rinsing, and
cooling, check to see if water is also used for conveyance.
3. Is peeling done chemically (i.e., caustic soda, surfactants to
soften the cortex)? Is there any discharge from the peeling
operation?
4. Check the floor washaown procedures. Are equipment and floors
washed down with water?
4-9
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5. Does the facility have a grease & solIds recovery system? Is
there any other pretreatment before discharge? Oescribe the
system.
6. Are there any processing brines used by the facility? How are
these brines disposed of? Check the kind of treatment given the
. brines prior to discharge to the sewer.
7. How are the larger remains of processed waste fruit and
vegetables disposed of (ground up and sewered, used as
byproducts, etc.)?
8. Check the refrigeration system for possible leaks.
9. Are there any fungicides or other similar chemicals used in the
processing?
10. Check the general questions on Food Processing.
COIL COATING (CAN WAKING)
1. What is the average square footage of metal sheeting processed at
the facility? (either on a daily or annual basis)
2. What is the base metal processed? (Aluminum, galvanized steel,
and/or steel)
3. Check the questions on cleaning solvents and cleaning solutions.
4. What sort of conversion coating is used at the facility?
(Chromating, phosphating, complex oxides)
5. What solvents are used to control viscosity?
6. Is there a continuous overflow from quenching water baths? What
is the disposal method for the quench waters?
CAMMAKING (1n addition to questions above)
1. What kind of metal forming lubricants does the facility use?
2. What is the volume of rinse waters discharged to the sewers?
Have the wastewaters been characterized?
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COPPER FORMING
1. What is the Quantity of copper and/or copper alloy processed by
the facility in terms of pounds, kilograms or tons per day?
2. What copper forming processes are employed at the facility?
. 3. What kind of metal forming lubricants does the facility use? How
often are spent lubricants from hot and cold rolling drawing
processes discharged?
4. What acid is used in the pickling process? Are any additional
chemicals added to the rinse tanks? How often are acids
changed? How is acid disposed? Are rinse tanks continuous
overflow?
5. Are any bright dip tanks used? Type? How often are solutions
changed? Refer to the questions for metal finishers.
6. Refer to the questions on solvent and cleaner usage.
7. Is any hydrostatic testing done on-site? Volume of water? What
pollutants are associated with the discharge?
8. Is any casting done on site? (See Metal Refineries and
Foundries.)
DAIRY INDUSTRY (All ,202l Numbers)
1. What products are processed at this plant?
2. What is the production rate of the facility (in pounds of raw
milk processed and/or pounds of product produced)?
3. Are any by-products (e.g., buttermilk, whey, etc.) produced?
4. How does the facility dispose of any spoiled materials?
5. Check on the use of cooling waters. See general questions.
6. What is the daily average water consumption? How much water is
incorporated into the product?
7. Does the facility utilize any pretreatment units such as settling
or grease traps, filtering devices, or flocculating tanks? Does
the facility have any flow equalization prior to discharging to
the sewer?
8. Check the general questions under Food Processing.
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EATING ESTABLISHMENTS (RESTAURANTS) (5812)
1. Check for the presence of any grease interceptor. Describe, the
size and general condition of the unit. How often and by whom is
it serviced? How is the grease disposed?
2. How does the facility dispose of any spent cooking grease?
9
3. How does the facility dispose of its edible garbage material?
4. Check what types of janitorial cleaners are used. How are they
stored?
5. Does the facility use an automatic dishwasher? Approximately how
many hours per day does it operate? What is the discharge
temperature and the water consumption rate? Is the dishwasher
connected to grease interceptors?
6. How many sinks does the facility have and how are they used?
7. How are any grill cleaning residuals disposed?
ELECTRIC SERVICES (4911, 4931)
Steam Electric Power Generation
1. Are plants coal, oil, or gas fired?
2. What is the source of condenser cooling water (e.g., city, river,
wells)? Are there any water treatment chemicals added by the
facility? How is the cooling water disposed of?
3. What is done with waste oils?
PEPCO Substations
1. Check the location of any floor drains.
2. Is there any contact cooling water discharge?
3. Look for signs of leaking transformer oil and to where it would
go if leakage occured. Look for a label on the transformer for
the identification of PCBs. What percentage of PCS is in the
oil?
4-12
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ELECTRONIC COMPONENTS
1 What is the product that is manufactured at this facility?
2. Does the facility use any solvents or degreasing agents? Check
the general questions on solvents.
. 3. Does the facility use any cooling water? Check the general
questions for cooling including machine cooling.
4. Does the facility have a clean air room for which it must scrub
the air? Are any chemical waste generated from the scruber? How
is the waste disposed?
5. Does the facility conduct any electroplating activities? Check
the questions on electroplating and metal finishing.
6. Is there any water recycle/reuse within the plant? Does the
plant employ any pretreatment for the recycle streams?
7. Does the facility employ any photographic processes?
8. Check the general questions on Solids Disposal.
ELECTROPLATING & METAL FINISHING (All '347' Numbers)
1. Try to determine the quantity of plating done by the facility in
terms of surface area (sq. ft., etc.) plated?
2. How often does the facility change its cleaning solutions, both
acidic and alkaline cleaners? What is the volume for each change
and how is the old material disposed of? Is there any batch
pretreatment prior to discharge? How are any residual materials,
sludges, at the bottom of the tank disposed of?
3. Does the facility use any solvents or degreasing agents? Check
the general questions on solvents.
4. Does the facility use any cooling water? Check the general
questions for cooling including machine cooling.
5. What types of chemicals make up plating baths? Is cyanide used
in the plating operation? Is there any chromium used? Is there
any aumonium persulfate used in an etching process?
6. How often are plating (concentrated) bath solutions changed?
What 1s the volume for each change and how is the old material
disposed? Is there any batch pretreatment prior to discharge?
How are any residual materials at the bottom of the tank disposed?
4-13
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7. Is there any water recycle/reuse within the plant? Does the
plant employ any pretreatment for the recycle streams?
8. If masking is employed, are photographic processes Involved
(circuit boards)?
9. Are there metal finishing operations (e.g., machining, grinding,
coloring, brightening, etc.) associated with the plating
operations?
10. If metal coloring is present, are organic dyes used?
11. Check the plumbing of the process wastewater from the plating
room to the pretreatment system or sewers. Are floor drains in
the plating room directed to the pretreatment units? Are floors
washed down regularly?
12. Does the facility use running water systems for rinsing? Are the
units set up for countercurrent flow? Are any still or dead
rinses used? Check if the rinsewaters are pretreated prior to
being discharged?
13. Has the facility been checked against any interconnections to
public water supply and processing (cross connections)? Are
there backflow preventers in place?
14. Check the general questions for Solids Disposal.
EXPLOSIVES
1 What are the products manufactured at this facility?
2. Does the facility blend these products into end-use products?
3. Is amnonlum nitrate used in the product and if so, how is it
monitored for 1n the wastewater?
4. Does the facility have a disposal area for obsolete, off-grade,
contaminated, or unsafe explosives and propellants?
i
5. Are the products produced for private sector usage or military
usage? Are there any security clearances necessary to go on site?
6. Check the general questions on Solids Disposal.
4-14
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FIBERGLASS INSULATION (3296)
I*. What methods are used to bind and cool the glass after it has
been drawn into fibers? What wastes are generated from this
phase? Are these wastes sewered and pretreated prior to
discharge?
2. What method is employed for collecting the glass fibers? (i.e.,
wire mesh conveyors, flight conveyors, etc.) What methods are
used to clean the conveyors of any glass fibers? Is this process
shut down or in service while cleaned? What type of cleaning
agent is used? Is the wastewater sewerea?
3. Are wet air scrubbers used? Is wastewater sewered or pretreated
first (i.e., sedimentation for particulate matter)?
4. How are any backings applied (heat, adhesives, etc.)?
FUEL OIL DEALERS (5983)
1. Record storage capacity (above or underground).
2. Are the above-ground storage and the loading areas diked? Is
there any leakage or spillage access to storm or sanitary sewer?
3. Are any oils or fuels stored inside the building? Note the
proximity to floor drains.
4. What type of absorbent is used for spills? How much is stored
for immediate availability? Note the proximity of the material
to any floor drains.
5. Does the facility have a Spill Prevention and Correction Control
(SPCC) plan?
FUNERAL SERVICES (7261)
1. Check what kind of chemicals are used and how they are stored.
What is the storage proximity to the floor drains?
2. Check how much formalin is used for embalming. What percentage
of usage is discharged into the sewer? How much blood is
discharged per day? Are there any other chemicals involved in
the embalming process?
3. Check the washing and cleaning procedures at the embalming
table. What kind of detergents and disinfectants are used?
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GASOLINE SERVICE STATIONS (5541)
1. Check the location of any floor drains. Look for drains under
service bays. What is the destination of the drain?
2. Identify the location of any gas/oil interceptors or separators.
What kind of unit is it and what 1s the general operating
condition of the unit?
3. Check what kind of chemicals are used and how they are stored.
Chemicals might include fluids such as oil, transmission, brake,
anti-freeze, or other solvents. What is the storage proximity to
the floor drains?
4. Check on the quantity and method of waste oil storage and the
manner and location 1n which 1t is disposed. Is there a waste
oil receptacle (drum or tank)?
5. Check on the disposal method used for radiator flushing.
GUM AND WOOD CHEMICALS MANUFACTURING
1. What volume of product is produced on a yearly basis?
2. If gum rosin is produced, what is the volume of crude gum wash
wastewater, still condensate, and dehydration brine discharged to
the sewers?
3. If wood rosin, turpentine, and pine oil are produced, what is the
volume of process wastewater from stripping, vacuum jet stream
condensates, and unit washdown?
4. If tall oil rosin, pitch, and fatty acids are produced, what is
the volume of wastewater from the acid treatment system, overflow
from evaporative cooling system, process washdowns and quality
control lab wastes?
5. Check the questions on cooling water usage.
6. If essential oils are produced what is the volume of contaminated
condensate that is discharged from the batch extraction of ail of
cedarwood?
7. If rosin derivatives are produced, what is the volume of
wastewater from the water of reaction; sparge stream, if used;
and the vacuum jet stream?
4-16
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HOSPITALS (8062, 8063, 8069)
1. Note the general layout of the facility (e.g., types of labs,
X-ray equipment, morgue, laundry, food services, etc.).
2. Check what kind of chemicals are used and how they are stored.
Mat is the storage proximity to the floor drains?
3. Any special procedures for handling hazardous or infectious
wastes, names of any haulers picking up such wastes.
4. Cleaning Procedures - types and quantities of cleaners and
germicides utilized.
5. See "Radioactive Materials" for further questions.
INORGANIC CHEMICALS
1 What is the product that is manufactured at this facility?
2. Are any brine muds generated by the facility's production of
inorganic compounds? Oo these brines contain any known heavy
metals? How are these brines muds disposed?
3 Does the facility generate any air scrubber wastewater? What is
the chemical quality of this water and how is it disposed?
4. Are any cyanide (CN) compounds generated by the facility? Are
the CN wastes treats segragated and/or pretreated prior to
discharge?
5. Check the questions for cooling waters.
6. Check the general questions on Solids Oisposal.
LAUNORIES (7211, 7213, 7214, 7215, 7216, 7219)
1. Is dry cleaning done? If so, what is the solvent?
2. Is sludge generated? Disposal?
3. If solvent is used, is it redistilled on-site? Ooes this
generate uncontaminated cooling water? Where is it discharged?
4. Do washers have lint traps, settling pits?
5. What is the temperature of the effluent? Is a heat exchange
system used?
6. Are printers rags, shop rags, or other industrial materials
cleaned?
4-17
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7. What types of detergents and additives are used? What is the pH
of the effluent?
8. Are laundry trucks maintained and washed on-site? If so, how are
waste oils, etc,, handled? Are there any floor drains leading
to the sewer in the vicinity of vehicles?
9. Is there any loss of water as a result of evaporation? What is
the estimated volume of the loss?
10. What is the water consumption at the facility? What is the
source of water used by the facility?
LEATHER TANNING & FINISHING (3111)
1. What method was used to preserve the received hides? (Note:
Hides preserved with salt will result in a high dissolved solids
count in the effluent.)
?. What types of skins and/or hides are tanned? (Note: If
sheepskins or goatskins are tanned, there will be a separate
solvent or detergent degreasing operation.)
3. Is hair saved or pulped (i.e., chemically dissolved). (Note: In
a save hair operation with good recovery of hair, the
contribution to the effluent strength is substantially lower than
in the pulp hair operation.)
4. Is deliming accomplished by treating with mild acids or by
bating. What is the destination of these wastes?
5. What types of tannin are used? (Note: Chrome and vegetable
tannins are the most coitmon. A combination of tannins may also
be used.)
6. Are chemicals stored near floor drains? (This is a very
appropriate question to ask since many liquid chemicals are used
in the leather tanning industry.)
7. Are tannins recycled and/or chemically recovered?
8. Any pretreatment units employed?
9. If sludge is generated, how is it disposed?
10. Check the general questions for machine cooling waters.
4-18
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LIMBER & BUILDING MATERIALS: RETAIL (5211)
1. Check for the storage of paint, thinner and other solvents,,
adhesives (glue), roofing materials (tar).
2. Does the facility mix paint? Is the paint mixing dry or does it
involve water? Check the near by sinks for ecidence of water
usage. How is the waste paint disposed?
3. Are cutting oils used and are they water soluble?
4. Are hydraulic oils used?
5. Would any of these oils ever be discharged to the sewer?
MACHINE & SHEET METAL SHOPS (3599, 3444)
1. What type of product is manufactured?
2. What kind of material is machined?
3. Are cutting oils used and are they water soluble?
4. Are hydraulic oils used?
5. Would any of these oils ever be discharged to the sewer?
6. Are any degreasing solvents or cleaners used? What are the
chemical make-up and/or brand names of the degreasers and how are
they used? How are the spent degreasing chemicals or sludges
disposed? Is degreasing rinse water discharged to the sewer?
7. Is there any water cooled equipment such as a vapor degreaser or
air compressor? What is it discharge frequency and volume?
8. Is any painting done on the premises? How are waste thinners or
paints disposed of? Is a water curtain used for control of
solvents entering the air and is contaminated water discharged?
9. Is any type of metal finishing done, such as anodizing,
chromating, application of a black oxide coating or an organic
dye? What are the chemicals used, volumes consumed, and
destinations of the finishing chemicals?
10. What is the water consumption?
11. Are there any pretreatment units, traps, etc.?
4-19
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MEAT PRODUCTS/POULTRY PRODUCTS (2011, 2013, 2016, 2017, 2077)
1. What types of livestock are slaughtered and/or processed?
2. What are the principal processes employed?
3. What methods are used to dehair? Is the hair recovered from the
wastewater stream?
4. Does the facility cure hides. What brine solution is used
specifically (i.e., sodium chlorine)? Are hides cured in vats?
Are vats ever discharge to the sewer? What is the frequency ana
volume of such a discharge?
5. What are the by-product processes?
6. Is rendering practiced at the plant? How (i.e., catch basins,
grease traps, air flotation, etc.)? How often are the systems
cleaned out?
7. What methods are used for clean-up operations? What detergents
are used (i.e, caustic, alkaline, etc.)?
8. Which waste waterstreams, if any, (i.e., uncontaminated water)
bypass all treatment and discharge directly to a receiving water
or municipal plant?
9. If poultry, how are feathers removed? Disposal? How are
chickens parts (innards) disposed? Blood?
METAL HEAT TREATING SHOPS (3398)
1. What kinds of metal are heat treated?
2. What fluids are used for quenching metals? Are these ever
changed and discharged to the sewer?
3. Are sludges ever removed from the quenching tanks? How are the
sludges disposed of?
4. Is any of the metal cleaned before or after heat treating? Are
any degreasing solvent or cleaners used and how are they usea?
5. Are there any water cooled quenching baths, vapor degreasers, or
other equipment? Discharge to? Volume?
6. What is the water consumption?
4-20
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METAL REFINERIES
1 What is the product that is manufactured at this facility?
2. Does the facility use any solvents or degreasing agents? Check
the general questions on solvents.
, 3* Ooes the facility use any cooling water? Check the general
questions for cooling including machine cooling.
4. Is there any water recycle/reuse within the plant? Does the
plant employ any pretreatment for the recycle streams?
5. Does the facility have a spill prevention and counter control
{SPCC) plan developed? Does the SPCC plan include spills to the
sewer of highly acidic or caustic materials?
6. Check the general questions on Solids Disposal.
NURSING CARE FACILITIES (8051, 8059)
1. Food service (see restaurant questions).
2. Any chemical usage (lab facility).
3. Janitorial chemicals - usage, destination and storage of
germicides and disinfectants.
ORGANIC CHEMICALS (2S65, 2869)
1. Are processes batch or continuous?
2. If batch processes are used, how frequent is clean-up and what is
aone with wastes?
3. Are waste disposal service or scavengers used? If so, for what
wastes? Are they licensed?
4. What types of solvents are stored in bulk?
5. Check the points for the discharge for cooling waters. See
general questions on cooling waters.
6. Check the general questions for any boiler waters generated.
7. Is there water in contact with catalysts used - in cleaning
catalyst beds, for example?
8. List all products and raw materials.
4-21
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9. Are there laboratories for research and for product testing? How
are laboratory wastes disposed of?
10. Is the water used in boiler feed or in processing pre-created?
If so, how? What wastes are generated?
11. Are storage areas near drains leading to the sewer?
•
12. Are there any chemical reaction or purification techniques, such
as crystallization, filtration, or centrifugation, which produce
wastewater and/or sludge wastes? What is the destination of
these wastestreams?
13. Are there any pretreatment units at the facility?
14. Is delonized water used, how is it generated (on-site)? Are
columns regenerated on-site? Does the facility use acids or
caustics? Is there a discharge from the deionization process?
Where does the discharge go?
15. Is a water tower used? What is the frequency and volume of the
aicharge? Where is the discharge to? Are any additives such as
chromates used by the facility?
PAINT & INK FORMULATION (2851, 2893, 2899, 3951, 3952, 3955)
1. Are oil-base or water-base inks manufactured?
2. What types of inks are made?
3. What type of paints are manufactured? Water or solvent based?
4. What are the pigments made of?
5. Are extenders used?
6. Are any solvents used? Check the general questions on solvents.
7. What are the resin types?
8. What other ingredients are used in formulating the product?
9. Is there any discharge to the sewer system (washdown and/or bad
batches)? Are any chemicals used to clean product equipment?
10. Are there any floor drains in chemical storage and mixing areas?
4-22
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11. Is there a scavenger service? If so, for what wastes?
12. Is there on-site disposal of solids by burial?
13. Check the general questions for machine cooling waters.
PAPER MILLS (2611, 2621, 2631, 2641, 2642, 2645, 2654)
i
1. What are the products manufactured at the plant?
2. Which specific chemicals are used in the process?
3. Is pulp bleached? If so, what is the process and what chemicals
are employed?
4. Are any chemicals manufactured on-site (chlorine dioxide,
hyprochlorites, etc.)? - any discharged from these operations?
5. Any recovery systems (white water recycle, cooking liquor
regeneration, cooling water reuse, etc.)?
6. Where 1s cooling water used in the plant (condensers, vacuum
pumps, compressors)? Where is it discharged?
7. Describe the types of size, fillers, coatings, finishes, etc., in
paper making.
8. What happens to bad batches or liquids in case of equipment
failure? (To the sewer or treatment plant?)
9. How much water is consumed, on the average? Source of water?
PAVING & RQOFINS (2951, 2952, 3996)
Tar & Asphalt
1. Does wastewater from wet air scrubbers used on the oxidizing
tower discharge directly to the sewer? Is it treated and
recycled?
2. What method(s) are used to control the temperature of the
oxidizing tower (i.e., water)? Is this waster discharged or
recycled?
3. What treatment methods are used to remove suspended solids or oil
from the water (i.e., catch basins, grease trps, sedimentation,
oil skimmers)?
4-23
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4. Is water or air used to cool asphalt products? If water, is it
contact or noncontact? If contact, 1s this water discharged
directly to sewer (Note: Mist spray used alone causes the
largest amount of solids present in wastewater).
5. Check the general questions for machine cooling waters.
• 6. Are any solvents used? Check the general questions on solvents.
PESTICIDES
1. Does the facility manufacture or blend pesticides at this
location.
2. What pesticides are manufactured or formulated at the facility?
What volume of product is produced on a yearly basis?
3. Check the chemical storage areas.
4 How are chemical containers rinsed? Is the rinse water
discharged to the sewer?
5. What is the volume of wastewater from the final synthesis
reaction or the dilution water step used directly in the process?
6. Check the procedures for floor and/or equipment washdown.
7. Check the general questions on Solids Disposal.
PETROLEUM REFINING
1. What are the processes employed by the facility and what is the
throughput (in barrels per day) of each of the following
processes:
a. Topping The term includes basic distillation
processes.
b. Cracking The term cracking includes hydrocracking,
fluid catalytic cracking, and moving bed
catalytic cracking processes.
c. Petrochemical This includes the production of of second
generation petrochemicals (i.e., alcohols,
ketones, cumene, styrene, ect.), first
generation petrochemicals, and Isomeriazation
prooucts (I.e., BTX, olefins, cyclohexanes,
etc.).
e. Lube This term includes hydrofining, white oil
manufacturing, propane-dewaxing, solvent
extractions and dewaxing, naphtenic lubes,
phenol extraction, SO2 extraction, etc.
4-24
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2. Identify the location of any oil Interceptors or separators.
What kind of unit is it and what is the general operating
condition of the unit?
3. Does the facility employ any biological treatment prior to
discharging into the sewer?
4. Are there any controls in place for phenols, sulfides, hexavalent
chrome, and/or ammonia? How does the facility dispose of any
spent caustic which it might generate?
5. Is storm runoff isolated from the sewer discharge? How is the
contaminated storm runoff disposed? Does the facility have an
NPDES permit issued by the State Health Department or EPA?
6. Check the questions for cooling waters.
7. Check the general questions on Sludge Disposal.
PHARMACEUTICALS MANUFACTURING {2831, 2833, 2834)
1. What type of processes are used to manufacture product(s)?
{fermentation, biological and natural extraction, chemical
synthesis, mixing/compounding and formulation).
2. If processes include fermentation and/or chemical synthesis, are
these continuous or batch-type operations?
3. If chemical synthesis is involved, what processing steps
(crystallization, distillation, filtration, centrifugation,
vacuum filtration, solvent extration, etc.) produce wastewaters?
Are these wastewaters discharged to the sewer system?
4. What types of solvents are used? Check the general questions on
solvents.
5. Is raw water intake purified? If yes, by what method - ion
exchange, reverse osmosis, water softening, etc.? What types ana
volumes of wastes are generated? Frequency of discharge?
6. What is done with the spent beer generated by fermentation?
7. Check the general questions on use of cleaners and location of
drains.
8. Is there any chance of spills or batch discharges?
9. Check the usage of cooling waters. See general questions.
10. Is there a research lab in the plant? What are the wastes
generated in the facility? How controlled?
4-25
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PHOTOGRAPHIC PROCESS (7395)
It is important to determine what type of chemistry is used-
because some of the chemicals may be toxic while others are not.
1. What types of films are developed? Are prints made? Give an
estimate of how much total processing is done per day? How many
automatic processors are utilized and how long are they in
operation per day?
2. What chemical brands are used: Kodak, 3M, GAP, etc.? What type
of process chemistry is used: C-41, E-6, CP-30, etc.? What are
the names of each chemical used in each process? What are the
volumes used? Which chemicals discharge to the sewer? Do any of
tfte chemicals used contain cyanide?
3. What is the square footage of the material being processed?
4. Is silver recovery practiced? Is bleach regeneration practiced
and if so, Is it done within the lab? What are the processes and
wastes involved?
5. What is the wastewater flow from each of the photographic
processing operations? Does the rinse water on the processors
run continuously or does it shut off when film is not being
processed? How often are the processors cleaned and the
chemicals changed? What chemicals, if any, are used to clean the
processor rollers and trays? Are there any floor drains where
the chemicals are mixed or stored?
6. Is there any type of pretreatment or pH control?
7. What is the water consumption?
PLASTIC & SYNTHETIC MATERIALS MANUFACTURING (2821, 2823, 2824, 3079)
1. What is the product that is being manufactured?
2. What are the raw material used including any accelerators and
inhibitors? Are there any known toxics (such as cyanide, cadmium
or mercury) utilized in manufacturing the product?
3. What type of polymerization process is employed? Does the
process use a water of solvent suspension? What are the wastes
generated from the process; what are the possible contaminants;
how are the wastes disposed?
4. Are there any product washing operations? Are reactor vessels
washed down between batches? Is water or a solvent used? Would
these wastes be discharged to the sewer?
5. Check the usage of cooling waters. See general Questions.
4-2S
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PORCELAIN ENAMELING
1. What 1s square footage of material enameled at the facility on an
annual basis.the annual ?
2. How is the basis metal prepared for enameling?
. 3. Is any electroplating done on site? If so, see the questions for
Electroplating and Metal Finishing.
4. What coating application method is used?
5. Check the questions on usage of chemicals and clean-up.
PRIMING (All '27* Numbers)
Some of the following questions may apply while others may not;
experience will be the best judge. The SIC number for offset and
silkscreen printing is 2732 and letterpress is 2751. Other types
of printing are listed in the 27XX group.
1. Note what kind of printing is done (i.e., offset, letterpress,
silkscreen, or other types of printing).
2. If offset printing is done, is film processing and plate
developing done in the shop?
3. If film processing is done, is an automatic film processor used
or are trays used? Ooes the processor's rinse water run
continuously or does it shut off after processing is completed?
How often are the processor's chemical tanks cleaned out and what
volume is discharged to the sewer? How much developer, fixer,
and stop batch (if applicable) are used and are these discharged
to the sewer? Is silver reclamation practiced? Is cyanide used
at all for further reducing negatives? Are phototypesitors used;
and if so, what chemicals are discharged?
4. If plate developing is done, what type of plates are used? If
they are aluminum plates, are they developed with a subtractive
color key additive developer? What are the names of the
developers and what quantities are used? Is the developer washed
off the plates to the sewer or wiped-off with a rag? How many
plates are developed.
5. If paper plates are used, what type of processor is employed and
what are the names, volumes, and destination of the chemicals
used? If a silver process is used, is silver reclamation
practiced?
4-27
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6. In the press room, what type of fountain solution is used and
would this ever be discharged during normal use or cleanup
operation? What type of solvent is used to clean the presser and
how is this applied? Would this solvent ever be discharged or
aoes it become associated with rags? Are these rags washed on
the premises or are they picked up by a commercial laundry? What
is the name of the laundry? Are there any floor drains where the
solvent or ink is stored? Are any of the presser waters cooled?
Are there any waste oils from the presser.
7. If letter press printing is done, is old lead type smelted in the
shop and if so, are the molds water cooled? What type of solvent
is used to clean the presser and type? Check the general
questions on solvents.
8. Is silkscreen printing done? What kind of photosensitive
coating and what volume is used? What kind of developer is used
and is it discharged? Is a solvent or other cleaner used to
clean the screen after printing? Check the general Questions for
solvents. Are the screens used over again for making new
stencils or are they thrown away?
9. If a different type of printing is done, what kind is it and what
are the names and volumes of the chemicals used? Are these
discharged to the sewer? Are the screens used over again for
making new stencils or are they thrown away?
10. Check the general questions for machine cooling waters.
RUBBER PROCESSING (2822, 2891, 3011, 3021, 3031, 3041, 3069, 3293)
Synthetic or Natural
1. What are the products manufactured?
2. Is the rubber natural or synthetic? If synthetic rubber is used,
is it polmerized on-site and would it be a water or solvent
suspension? Is there a discharge associated with the process?
3. What are the ingredients of the rubber, including all additives?
What kind of anti-tack agents are used? Are any known toxics
used in the plant?
4. Are there any waste oils from rubber mixers or other processes
which require disposal; and if so, how are they disposed of?
4-28
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5. What type of forming process is used? Is cooling water used?
Check the cooling water general questions.
6. Is there any wastewater associated with the curing process, e.g.,
steam condensate; and what would the contaminants be in the water?
7. Is rubber reclaimed; and if so, what type of process is used?
Are any chemical agents used and how are these disposed when
spent?
8. Are any final coatings applied to the rubber, paint, plastics,
etc.? Are there any wastes or wastewater associated with the
process and how would they be disposed?
9. Does the plant have air pollution control equipment? Does it use
water as a scrubbing medium and would this be discharged?
10. Check the general questions for machine cooling waters.
SCHOOLS -UNIVERSITIES (8211, 8221)
General
1. Cafeteria (see restaurants).
2. Janitorial chemicals - usage, destination, storage.
Junior High and High Schools - additional
1. Labs - chemical usage and disposal practices.
2. Art department - note any agents disposed of to the sewer
(amounts) - paint, thinner.
3. Wood/Metal shop - refer to questions for woodworking shops.
4. For vocational departments, refer to other applicable sections of
this document.
Universities
1. Is a map of the campus available to inspectors?
2. Can a master list of chemicals used on campus be provided? Which
chemicals are used most?
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3. Is there an organized waste chemicals pickup program? How many
pickups/year? How many gallons picked up/year? Who is
scavengers)? Licensed? Frequency of scavenger pickups? .
Central storage location(s) for water chemicals that have been
picked up?
4. Are radioactive materials handled on campus? If yes, in what
capacity? Are any wastes generated? If yes, how are these
wastes disposed of?
5. Any photo developing facilities on campus? Any printing
facilities?
6. Any prototype PC board work in the electronics labs on campus?
7. How are pathogenic organisms disposed of?
8. Any pretreatment facilities (marble chip acid traps, dilution
pits, etc.)?
9. Has a study beer done to account for all water uses (cooling
water, laboratory wastewaters, cooling tower and boiler
blowdowns, evaporation and drift from cooling towers, lawn
irrigation, etc.)? Which, and how many of each, of the following
units (that usually discharge uncontaminated water to the sewer)
does the university have in operation at various times: stills,
cold rooms, diffusion pumps, centrifuges, electron microscopes,
X-ray diffraction units, electrophoresis units, air compressors,
ice machines, fermentors. What is the total campus population,
including employees? How many reside on campus?
10. Are there floor drains near liquid chemical storage areas (such
as Building & Grounds, chemical "supermarkets", waste chemical
storage area(s), fuel oil tanks)?
SCRAP & WASTE MATERIALS (5093)
1. Any processing of the material - welding or smelting of metals?
2. Check the general questions for machine cooling waters.
3. Oil storage - describe including capacity.
4. Any other liquid storage or reclamation?
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SOAP & DETERGENT MANUFACTURING (2841)
General
1. Are only soaps manufactured, detergents, or both? Classify the
plant. J
• 2. Is there any cooling water used? Refer to general questions on
cooling water.
3. How are liquid materials stored? Floor drains nearby leadinq to
sewer? 3
4. Are air scrubbers used? Do these use water? Caustics?
5. In product purification steps, how are filter backwashes handled?
Soap
1. What is the basic process employed for manufacturing soap: batch
kettles? Fatty acid neutralization? Other?
2. Is process batch or continuous? If batch, what is the frequency
and volume of reactor cleanout?
3. Is waste soap from processing sewered?
4. Are perfumes and additives used? If so, what are they?
Detergent
1. What are the additives used in the product?
2. How are spray drying towers cleaned?
SUGAR PROCESSING (2061, 2062)
1. Are both liquid and crystalline sugar produced?
2. What type of system exists in the plant for "sweet water"
recovery?
3. Are ion exchange systems used? If so, what are the backwashing
systems likely to produce as wastes? How frequent is backwash?
4. Are trucks or other heavy equipment maintained? Washed? Any
floor drains leading to sewers? Any traps?
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5. What bulk chemicals are stored and how? (Examples are acids used
in liquid sugar production).
6. What happens to filter sludges in the plant? What type of filter
aids are used?
7. Is cooling water used? Refer to the general questions on cooling
waters.
8. From the cleaning of equipment, what wastes are sewered and what
wastes are recycled through the plant - examples are filters,
evaporation pans, screens, etc.
TEXTILE MILLS (All '22' and *23' Numbers)
1. What are the products manufactured in the mill? What is the
approximate production of the mill?
2. What types of fibers are used in the fabric?
3. Does the raw fiber require cleaning before spinning and weaving?
4. Are the fibers or fabrics scored, mercerized, fulled, carbonized
or bleached? What chemicals and rinsing operations are used and
what is the destination of these wastes?
5. Is any kind of sizing applied; and if so what Kind is it?
6. Is desizing practiced and what are the chemicals used? Are these
chemicals discharged to the sewer?
7. Is dye applied to fabrics? What are the types and chemical
constituents of the dyes and are the spent dye solutions and
rinse waters discharged to the sewer?
8. Are any antistatic agents applied to synthetic fibers before
spinning and weaving operations? Would these be removed from the
fabric and subsequently enter the wastewater discharged to the
sewer?
9. Are any further finishing operations practices such as printing
or application of various coatings?
10. What is the volume of wastewater generated by each chemical
process?
11. Are there any methods of pretreatment employed before discharge
of wastewater to the sewer?
12. Check the general questions for machine cooling waters.
13. Any liquids stored near floor drains leading to sewer?
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VETERINARY SERVICES (0741, 0742)
1. Check on chemical (including alcohol, germicides, pesticides,
cleaners, medicines) usage and storage. Refer to the general
questions.
2. . Are detergents used and discharged for animal washing baths? Are
there any hair clogging problems?
3. What is done with excretia material for any animals boarded?
4. Are there any special procedures taken for infectious wastes?
WOODWORKING SHOPS (243X)
1. Chemical usage - look for solvents, thinners, paints, stains,
cutting oils, adhesives, etc. Check the general questions for
solvents.
2. Check the general questions for chemical usage and proximity to
drains.
3. How are brushes cleaned? Are any spray guns used - how are they
cleaned?
4. Are cutting oils discharged?
5. Is any cooling water used? Check the general questions.
STEAM SUPPLY & NON-CONTACT COOLING (No SIC)
Steam Supply
1. Is system high or low pressure steam?
2. Check the general questions on boiler waters.
3. Is major cleaning and maintenance done? How often?
4. Are ion exchange systems used for boiler feed water? If so, what
types of wastes are generated?
Non-Contact Cooling Water
1. Are cooling towers used? If so, what are the additives?
2. How frequently are towers blown down? Where does blowdown go?
3. Are closed systems ever by-passed?
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CHAPTER 5
SAMPLING INDUSTRIAL USER WASTEWATERS
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CHAPTER 5
SAMPLING INDUSTRIAL USER WASTEWATERS
INTRODUCTION
* Industrial wastewaters may vary significantly in pollution
characteristics. This chapter discusses general guidelines and
considerations relating to sampling of industrial wastestreams.
Coupled with experience and common sense, this discussion should
assist the regulatory agency (federal, state, or local) in the
establishment of an effective sampling program for industrial users of
publicly owned treatment works (POTWs).
POSSIBLE OBJECTIVES OF THE SAMPLING PROGRAM
Regulatory
The primary objective of most sampling programs is. to determine
compliance with applicable laws and regulations. For compliance
sampling, the regulated parameters, the location of sampling points,
frequency of sampling, and the appropriate sample type are generally
specified in the discharge permit issued by the POTW to the industrial
user, sewer use ordinance, or the applicable federal regulation.
Process Control
In addition, sampling might be performed within an industrial user's
plant to monitor Individual wastestreams as a check on the process
efficiencies and to compute material and/or flow balances. Often
process control sampling involves only single indicator pollutants
which provide a relative benchmark for the concentration of othe
pollutant parameters. An example of an indicator pollutant would be
pH as a process control guide to effective precipitation of heavy
metals.
Research and Development
Sampling may be conducted as a part of a Research and Development
Project (or any type of study). The special needs of a the project
will dictate the sampling program. Examples of projects might include
studies to:
1. examine the impacts from a process modification and/or study
the economics of a possible change.
2. explore potential recovery from a given department or unit
process.
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3. define factors influencing character of wastes from a given
department or unit process.
4. investigate and demonstrate variations in the character and
concentration of combined wastes.
5. establish a sound basis for the treatment of residual wastes.
6. determine if the industrial user's waste has the potential to
impact the POTW's wastewater treatment systems.
LOCATION OF SAMPLING POINTS
Effluent Monitoring
Regulatory permits generally establish the effluent monitoring points
within an industrial user's facility. The permit may specify that
either the total plant discharge flow is to monitored or a specific
discharge from a certain operation must be monitored separately.
Consult permits for these locations, or use the following principles
for determining the representative sample point:
1. National Pretreatment Program Categorical Pretreatment
Regulations apply to the discharges from each specific
process wastestream. If two or more wastestreams are
combined prior to treatment, a combined wastestream formula
can be used and the discharge sampled after the combined
treatment.
2. Samples should normally be taken at representative sites of
the individual wastestreams.
3. The sampler should consider critical locations which have the
potential for displaying impacts to the POTW collection
system, evedience of short circuiting in the pretreatment
system employed by the industrial user, etc.
4. Samples should be taken at locations where flow measurements
can be measured or estimated.
5. Sampling locations must be convenient, accessable, and
practicable. However, above all other factors, the location
must produce a sample that is representative of the nature
and volume of the discharge to the POTW.
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In-Plant Locations
To achieve process control or to design and implement in-plant
pollution control programs, selection of proper in-plant sample
location is important. Use the following procedures to determine the
sampling locations:
1. Become familiar with the plant processes and sources and
characteristics of wastes from unit operations.
2. Ascertain the sewer layout of the plant. If a sewer plan
exists thoroughly review the sewer plan and examine each
sewer to determine its course ana destination. Where a sewer
plan is not available, the only practical way to determine
the sewer layout is by dye-tracing.
3. Determine the exact source and the point at which each
wastestream enters the sewer.
4. Sample each wastestream and plant outfall. By doing sof
which wastestream is characterized and the outfall
characterizes the total plant effluent.
5. Sample each batch discharge.
6. If a point of upset exists within the plant, establishment of
a sampling station or monitoring equipment at that point will
allow early detection.
7. If data on different wastestreams is available from past
records, use statistical techniques to aid in establishing
the critical sampling locations within the plant.
FREQUENCY ANO NUMBER OF SAMPLES
Determine the number of samples that should be taken of the industrial
user's discharge from the following:
1. The regulatory requirements (i.e., the permit, ordinance, or
federal regulation).
2. Where a number of samples is not specified:
a. Apply statistical methods to data from a preliminary
survey.
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b. Consider the nature of the waste generation and the
reliablity of the treatment system employed by the
industrial user. If the waste is highly variable, more
sampling would be necessary to accurately characterize
it. Conversely, the more consistant the waste quantity
and quality, the less sampling needed.
c. To first characterize a wastestream, it is suggested
that no less that three operating day composite samples
are necessary to effectively determine the concentration
and types of pollutants being discharged.
3. Where the frequency of samples is not specified, the
following factors must be considered:
a. Seasonal operations of the industrial user,
b. If the industrial user employs less than a 24 hour per
day operation,
c. Special times during the day, week, or month set aside
for the industrial user to cleanup production lines and
the impact to the wastestreams from such cleanup,
d. The reliability of the wastewater pretreatment systems
and processes used by the industrial user to treat its
wastewater,
e. The potential for upsets and spills at the industrial
user's site,
f. The compliance history of the industrial user, or
g. Any combination of the above factors.
4. As a general rule, monitoring of industrial users should be
conducted during normal working shifts in the season of
productive operation.
TYPE OF SAMPLE
The permit or sewer ordinance should specify the type of sample, grab,
or composite, for effluent monitoring. After careful analysis of the
treatment process, select the appropriate type of sample to be
collected. Collect proportional composite samples to determine the
average amount of pollutant or collect grab samples if:
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1. The Industrial user employs a batch discharge,
2. The flow is homogeneous and continuous with relatively
constant waste characteristics so a grab sample is
representative of the wastewater stream (e.g., there is flow
equalization prior to the sewer discharge),
3. It is necessary to characterize the extremes of flow and
wastewater quality,
4. A sample is needed for a parameter requiring that the entire
sample be used for analysis with no interior tranfers of
containers, (e.g., oil and grease),
5. When sampling for parameters which change character rapidly
(e.g., dissolved gases) or those which cannot be held for a
long length of time before analyses (e.g., bacteria counts,
chlorine, dissolved oxygen, and sulfide).
If the composite sampling interval is not specified by regulation,
ordinance, or permit requirement, the composite sampling interval
should be one hour or less.
METHOD OF SAMPLING
Choose manual or automatic sampling depending upon which method is
best for the specific sampling program. Only trained personnel should
be entrusted the task of sample collection. If an automatic sample is
to be used, the actual type of sampler is determined by the
constitutents in the wastewater.
FLOW MEASUREMENT
Flow measurement techniques adopted should be In relation to the
sampling location, type of flow, and other similar characteristics.
Primary and secondary devices should be calibrated prior to taking
flow measurements. If the variability of the wastewater is not known
or is large, use a sampler containing a multiplex feature, which
permits the collection of a composite sample in a single container
while collecting one or several discrete samples during a preset time
interval. Once the needed features have been established, the sampler
which best matches these features can be selected. Available samplers
may need adaptation. It is imperative that the stream be well mixed
at the sampling proint to avoid problems when using automatic samplers
in streams with a high solids content.
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VOLUME OF SAMPLE ANO CONTAINER TYPE
The volume of sample to be taken is determined by the number of
analyses to be performed on the sample. If this has not been
determined, a grab sample volume, a minimum of 7.57L (2 gallons) and
an individual composite volume of 100 milliliters (0.21 pints) should
be taken. The container type 1s also contingent upon the analysis to
•be run.
FIELD PROCEDURES
It is critical that inspectors be trained and use proper field
operations and procedures. Lack of care in field procedures will
undermine the entire sampling program despite adequate planning,
analytical facilities, and personnel. The key to the success of a
field sampling program lies in good housekeeping, collection of
representative samples, proper handling and preservation of samples,
and appropriate chain of custody procedures.
Field Analysis and Procedures
The sampling program should specify the various analyses to be
performed in the field and the corresponding analytical methods.
Field laboratories must also have standard procedures and methods for
handling and analyzing samples such that identification, integrity,
and representativeness of the samples are maintained at all times.
Sood Housekeeping
1. Written instructions on field sampling procedures should be
maintained in a written form to assure understanding of and
consistency with the procedures.
2. Prior to their use, sampling equipment must be checked to
insure good operating conditions and cleanliness. The
equipment must be kept in ready operating condition. After
the sampling has been completed, all the equipment must be
cleaned and stored in a neat environment. Manufacturer's
specifications for equipment maintenance must be fully
carried through.
3. The primary (e.g., flume) and secondary (e.g.,
recorder/transmitter) flow devices must be checked for the
following:
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a. Locations
(1) At the appropriate place as defined in sampling
program.
(2) Upstream and downstream conditions meet the
requirement of specific Installation of primary and
secondary devices.
b. Dimensions of primary devices such a flumes, weirs, and
still wells to be determine if they are within tolerance
limits.
c. General conditions of channel, primary and secondary
devices, and stilling wells. Note any unusual wear,
debris in channel, or distortion of chart paper.
d. Calibration of primary and secondary devices before
actual measurements of flow are taken.
4. All sample bottles must be checked to assure against possible
contamination.
5. In the laboratory, clean the sample intake tubing by flushing
with hot water and then rinsing with distilled water. In the
field, rinse several times with sample water.
6. Record of breakdowns in the sampling opeations and any
problems encountered with different equipment and how such
problems were resolved must be maintained* This information
indicates the reliability of the equipment, the problem areas
that need to be brought to the manufacturer's attention, and
considerations for future procurements.
7. Hold training sessions for field sampling teams (include
refresher training sessions as well).
Guidelines for Representative Sample
These guidelines will assist in obtaining representative samples of
industrial wastewaters sampled:
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Collect the sample where water is well mixed, that is near a
Parshall flume or at a point of hydraulic turbulence such as
downstream of hydraulic jump. Certain types of weirs and
flumes tend to enhance the settling of solids upstream and
accumulate floating solids and oil downstream, therefore such
locations should be avoided as a sample source* For low
level turbulence, mechanical or air mixing should be used to
induce turbulence except when dissolved gases or volatile
materials are being sampled.
If possible, collected the sample in the center of the
channel at 0.4 to 0.6 of the depth from the bottom where the
velocity of flow is average or higher than average and
chances of solids settling is minimum. This depth avoids
bottom bed loads and top floating materials such as oil and
grease.
In a wide channel, divide the channel cross section into
different vertical sections so that each section is equal
width. Take a representative sample in each vertical section.
When manual sampling with jars, place the mouth of the
collecting container below the water surface and facing flow
to avoid an excess of floating material. Keep the hand away
from the mouth of the jar as far as possible.
Additinal guidelines for manual sampling:
a. Sample facing upstream to avoid contamination.
b. Force sampling vessel through the entire cross seclton
of the stream wherever possible.
c. Drop an inverted bucket and jerk line just before impact
with the water surface.
d. Be certain that the sampler closes and opens at the
proper time when sampling with a depth integrating
sampler; with a point sampler, be certain that sampler
opens at a proper depth. If a doubt exists, discard the
sample and re-sample.
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6. When sampling, it is necessary to fill the bottles completely
if the samples are to be analyzed for volatile organics,
®2» CO2, NH3, H?S, free chlorine, pH, hardness,
SO2.NH4.FE**, oil and grease, acidity, or alkalinity.
When sampling for bacteria or suspended solids, it is
necessary to leave an airspace in the sample container to
allow mixing before subsampling.
7. Collect sufficient volume to allow duplicate analyses and
quality assurance testing (split or spiked samples). The
required sample volume is a summation of that required for
each parameter of interest. Refer to US EPA's Methods for
Chemical Analyses for Water and Wastewater, 1979, EPA
600/4-79-0202 (or any update to that document) for the volume
required for analysis fo a specific parameter, or the
laboratory director for minimum volumes to be collected.
8. Maintain an up-to-date log book which notes possible
interferences, environmental conditions and problem areas.
9. Since mathematical relationship between volumetric flow and
height (or depth") of flow is nonlinear, composite the flow
proportional samples in relation to the total volume of flow
as opposed to gauge height or raw measurement of a secondary
device.
10. If samples are taken from closed conduit via a valve or
faucet arrangement, allow sufficient flushing time to insure
that the sample is representative of the supply, taking into
account the diameter, length of the pipe to be flushed and
the velocity of the flow.
Sample Preservation, Handling and Chain of Custody Procedures
When immediate analysis of the collected sample is not possible, take
precautions so that the sample characteristics are not altered.
Follow these guidelines for sample handling and preservation:
1. Minimize the number of people handling the sample.
2. Follow the guidelines given on chain of custody procedures
and sampling handling.
3. Store the sample in a manner which insures that the
parameters to be analyzed are not altered, and use the
preservation methods and holding times pertinent to those
parameters, (see Appendix C for general guidlines)
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4. Insure that the container material does not interfere with
the analysis of the specific parameters. Refer to EPA's
Methods for Chemcial Analyses for Water and Wastewaters,
1979, EPA 600/4-79-020.
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CHAPTER 6
SAMPLE CONTROL AOT CHAIN-OF-OJSTODY PROCEDURES
-------
CHAPTER 6
SAMPLE CONTROL PROCEDURES
AND
CHAIN-OF-CUSTODY
INTRODUCTION
Successful implementation of an industrial monitoring program
depends on the regulatory agency's (federal, state, or local)
capability to produce reliable sampling data and to demonstrate the
precautions taken to assure the validity of that information. In
addition to proper sample collection, preservation, storace, and
handling procedures, sample identification and the establishment of a
chain-of-custody are absolutely essential to assure the data's
validity. The procedures specified in this chapter are those
currently used by the Environmental Protection Agency for its NPQES
discharge permit sampling. However, improvements may result in
changes being made in EPA's procedures and the reader is advisad to
keep abreast of official uniform procedures.
A sample is physical evidence collected from an industrial
facility to document if the facility is discharging within the
applicable pretreatanent standards. This evidence might be an
essential part of an enforcement investigation and might ultimately be
used in an administrative or judical enforcement proceeding. The
inspector taking an industrial facility discharge sample might be
called upon to testify as to the integrity of the evidence presented.
To assur* that the integrity will be sustained, the following sample
identification and chain-of-custody procedures are recommenced for
every sample taken by the industrial pratreatment inspector.
SAMPLE IDENTIFICATION
The method of identification of a sample depends on the type of
measurement or analyses performed. When in situ measurements (e.g.,
flow, pH, conductivity, or temperature) are maae, the oata must be
recorded directly in a logbook or Field Oata Record kept by the
industrial pretreatment Inspector. The fallowing information is
necessary:
1. Project Code A number assigned by the Inspection
Supervisor.
2. Station Number A number assigned for a given industrial
facility by the PQ7W and listed in the
permit if used for permit inpsections.
3. Time A four digit number indicating the
military time that the sample'was
collected.
4. Date The date of the day the sample is
collected.
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5. Samplers Identification of the person that took the
sample and any witness(es) to the sampling
done.
6. Station Location The sampling location as specified by the
permit or that can easily be located by
the Identification listed on the tag.
7. Field Observations and any pertinent remarks.
Samples other than in situ measurements must be identified by a
sample tag or other appropriate identification. These samples are
transported from the sample location to a laboratory or other location
for analysis. As a sample must often be separated into different
portions for the different analyses to be performed, it is essential
that each portion is properly preserved in accordance with applicable
procedures and that this be noted on the sample tag. Sample tags must
be completed for each sample using waterproof ink unless prohibited by
weather conditions. For example, a logbook notation would explain
that a pencil was necessary to fill out the sample tag because a
ballpoint pen would not function in freezing weather. The information
recorded on the sample tag 1s the same as that listed above for in
situ samples and includes:
1. Project Code
2. Station Number
3. Time
4. Oats
5. Samplers
6. Station Location
7. Field Observations and any pertinent remarks.
Sample tags used for water samples (also soil, sediment, biotic
sarples) must identify if the sample was a grab or a composite, the
parameters to be analyzed for, and any preservatives which might have
been used. The sample tags are attached to or folded around each
sample.
If the composite or grab sample is to be split, 1t must be
aliquoted Into similar sample containers. Identical sample tags must
be completed and attached to each of the split samples. The tag must
indicate with whom the samples are being split and must be signed by
both the sampler and the recipient. If either party refuses to split
a sample, this must also be noted and signed by both parties. In a
similar fashion, all tags on blank or duplicate samples will be marked
•Blank", or "Duplicate11 respectively.
After collection, separation, identification, and preservation,
the sample should always be maintained unoer uniform chain-of-custody
procedures as discussed below.
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CHAIN-OF-CUSTCOY PROCEDURES
Due to the evidentiary nature of samples collected during
enforcement investigations, possession must be traceable frcm the time
the samples are collected until they are introduced as evidence in any
legal proceedings. Because a routine sample might reveal information
which later could be used as enforcement evidence, the
chain-of-custody procedure should become standard operating procedures.
Sample Custody
A sample is under custody 1f:
1. It is in your possession, or
2. It 1s in your view, after being in ycur possession, or
3. It was in your possession and then you locked it up to
prevent tampering, or
4. It 1s 1n a designated secure area.
Field Custody Procedures
1. In collecting samples for evidence, collect only that number
which provides a good representation of the media being
sampled. To the extent possible, the quantity ana types of
samples and sample locations are determined prior to the
actual field work. As few people as possible should handle
samples.
2. The field sampler is personally responsible for the care and
custody of the samples collected until they are transferred
or dispatched properly.
3. The inspection coordinator for the PGTW determines whether
proper custody procedures were followed during the field work
and decides if additional samples are required.
Transfer of Custody and Shipment
1. Samples must be accompanied by a chain-of-custody record.
When transferring the possession of samples, the individuals
relinquishing and receiving will sign, date and note the time
on the record. This record documents sample custody transfer
from the sampler, often through another person (e.g., the
laboratory sample custodian), to the laboratory analyst.
2. Samples must be properly packaged for shipment to the
laboratory for analysis. Separate custody records must
accompany each shipment. Shipping containers must be
padlocked or sealed during shipment to the laboratory. The
method of shipment, courier name(s) and other pertinent
information are entered in the "Remarks" box.
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3. The custody record should contain a statement that the
samples were delievera to the designated loacation at the
designated time.
4. All shipments will be accompanied by the Chain-of-Custody
record identifying its contents. The origninal record will
accompany the shipment, and a copu will be retained by the
project officer.
FIELD FORMS
Appropriate field sheets must be completed at the time of sample
collection.
In addition to sample tags and field sheets, a bound field
notebook must be maintained by the inspector to provide a daily record
of significant events. Keep the notebook as a permanent record. In a
legal proceeding, notes, if referred to, are subject to
cross-examination and admissible as evidence.
Examples of field forms and Chain-of-Custody records can be found in
Appendix C of this manual.
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CHAPTER 7
FOLLOW-UP COMPLIANCE ACTIVITIES
-------
CHAPTER 7
FOLLOW-UP COMPLIANCE ACTIVITIES
When all the inspection information has been evaluated, the final
conclusion in the inspection report should indicate whether or not the
industrial user is in compliance with the applicable Pretreatment standards
and/or whether any further action is needed by the POTW at this time.
Recommendations with regard to future monitoring might included the following:
o if the monitoring visit results show problems with Pretreatment
facilities, chemical handling, or other violations, then the POTW may
want to increase the monitoring frequency; modify the indutrial
discharge permit; request additional information from the industrial
user; etc.
o conversely, if the industrial user has been consistently in
compliance and has had no major problems, then the monitoring
frequency might be reduced or abbreviated.
If the industrial user inspection or sampling results identify problems or
violations, the appropriate POTW staff must be notified and copies of the
report made available to them. A POTW staff person should be assigned to
follow through with the problem/violation until it is satisfactorily
resolved. The POTW should do one or more of the following:
o notify the industrial user of the problem/violation (i.e., issuance
of a written violation),
o establish or require the development of a compliance schedule,
o bring enforcement proceedings taken against the industrial user,
and/or
o ensure that remedial actions have been taken by the industrial user,
POTW managment must be kept informed of the status of any compliance
and/or enforcement actions. A final report should be made to the file once
all the necessary corrective actions have been completed.
Finally, all reports, communications, data, etc. on each industrial user
should be filed in a manner so the information is readily avaliable to the
appropriate POTW staff.
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CHAPTER 8
BASELINE MONITORING REPORTS (BMRs)
-------
CHAPTER 8
BASELINE MONITORING REPORTS (BMRs)
The General Pretreatment Regulations require that, within 180 days
following the Issuance of a final National Categorical Pretreatment
Standard for a industrial category, existing Industrial users (within
that category) of a POTW must submit a Baseline Monitoring Report
(BMR) to EPA or the approved POTW that is administering the
Pretreatment Program in lieu of EPA. The requirements for a 0MR are
contained at 40 CFR Section 403.12. Page 2 and 3 contain a baseline
monitoring checklist listing the specific type of information required.
The baseline monitoring report provides general facility
Information on the Industrial user, a brief discussion of its waste
characteristics, and an assessment of its current compliance with the
applicable National Categorical Pretreatment Standard. If not
currently 1n compliance, the industrial user must include a compliance
schedule listing the actions that need to be taken and the timing for
the industrial source to achieve full compliance. Although there
currently is no specific Baseline Monitoring Report Form that is
required by EPA, an example Baseline Monitoring Form is included in
Appendix E.
8-1
-------
BASELINE MONITORING REPORT CHECKLIST
40 CFR 403.12(b) and 40 CFR 402.12(c)
Industrial
User
•
PQVk
Categorical Pretreatment
Standard ________
Subcategories)
Date BMR
Que
Date BMR
Received _______________________
(1) Identifying Information Yes No
Name and address of the facility
Name and address of operator and
owners
(2) Permits
Listing of any environmental
control permits held by or for
the facility
(3) Description of Operations
Nature of operation
Average rate of production
SIC code(s)
Schematic process diagram
indicating points of discharge
to the POTVJ from the regulated
processes
(4) Flow Measurement
Average daily and maximum daily
flow, in gallons/day to the
POTU for: (Based on historical
Regulated process wastestreams
Other streams as necessary to
allow use of the combined
wastestream formula
data ( ))
8-2
-------
BASELINE MONITORING REPORT CHECKLIST (continued)
Yes No
(5) Measurements of Pollutants
Identification of applicable
Pre treatment Standards __
Adequate sampling and analysis
of each regulated process
wastestream:
(Based on historical data ( )) __
Sample Type
Flow-proportioned composite _
Grab
Number of Samples Collected
Location of sample _
Combined wastes tream _
Non-regulated wastestreams —_
Sampling and analysis done in
accordance with 40 CFR 136
Time, date and place of sampling
and methods of analysis, and
certification that such sampling
and analysis is representative of
normal work cycles and expected
pollutant discharges to the PQTW __ ___
(6) Certification
Reviewed by authorized representative
of the Industrial User and certified
by a qualified professional
Industrial user certified:
Compliance ( )/Noncompliance ( ) with Standards
Additional Operation and Maintenance needed ( )
Additional Pretreatment needed ( )
NOTE: Ttie Industrial Users's compliance determination is
" suoject to verification sy tne control Autnorny.
8-3
-------
BASELINE MONITORING REPORT CHECXtlST (continued)
(7) Compliance Schedule (If applicable)
Completion of final plans
Commence construction
Complete construction ___
Increments between milestones
. not greater than 9 months
I have reviewed this submission in detail and have
determined the Baseline Monitoring Report to be:
( ) Complete ( ) Incomplete
Date: ¦ Reviewed by:
8-4
-------
APPENDIX A
FINDING FEDERAL REGULATIONS AND REQUIREMENTS
-------
APPENDIX A
FINOING YOUR WAY TO REGULATIONS
ANO
EPA TECHNICAL PUBLICATIONS
INTRODUCTION
One of the seemingly most difficult aspects of the industrial
pretreatment program is keeping abreast of the mass of regulations,
technical publications of the federal government, and other related
materials being constantly generated. While the sheer numbers of
publications and requirements is indeed overwhelming, the ability to
effectively use this Information merely requires one to become
familiar with the informational systems through which they appear.
The purpose of this chapter is to review the basic statutory,
regulatory, and technical informational systems available readily
available to the general public. A subscription to the services
mentioned would further facilitate usage of the availble information.
ENVIRONMENTAL STATUTES
Most of the environmental programs being administered by the
Environmental Protection Agency were established through environmental
legislation enacted by Congress. Statutes such as the Clean Water
Act; the Clean Air Act; the Resource Conservation and Recovery Act;
the Comprehensive Environmental Response, Compensation, and Liablity
Act; etc. set forth the fundamental requirements of each program and
the authority of the Agency to enact and enforce administrative
requirements (regulations) to implement that program. State
administered programs generally mirror the federal programs and often
reference significant portions of the federal requirements as
requirements of the state program. Copies of the federal statutes and
their legislative history are available in most of the respective
program offices and in the EPA Regional Office Libraries. These
libraries should also have state laws and rules.
FEDERAL REGISTER
In 1935, Congress passed The Federal Register Act to establish a
uniform system for handling agency regulations. The Act established
the Federal Register as the official publication of the Federal
Government for reguiations, notices, and Presidential documents.
Publication of these documents in the Federal Register has the
following effects:
1. It provides official notice of the existence of the document;
2. It indicates that the copy contained in the Federal Register
is a true copy of the document; and,
3. It provides "prima facie" evidence in a court of law.
A-l
-------
CODE OF FEDERAL REGULATIONS
Annually, the final regulatory requirements are compiled and
published in the Code of Federal Regulations (CFR). The preamble to
the regulation is not induced in the CFR. However, the CFR provides
a reference to the Federal Register where the regulation was published
as a final rule. If background information on the regulation is
needed, the Federal Register document can then be accessed.
The CFR is divided into 50 titles according to subject matter.
Each Federal Agency is assigned a specific title of the CFR 1n which
its regulations will be published. Title 40 of the CFR entitled "The
Environment" contains the regulations of the Environmental Protection
Agency and 1s subdivided into chapters relating to air, water, and
solid waste environmental requirements. Title 40 is updated July 1 of
each year.
PRIVATE REGULATION SERVICES
In addition to the federal publications described above, there are
private regulation services available. An example of a private
publication is the Environment Reporter which is published by the
Bureau of National Affairs (BNA is a private corporation). 8NA
provides a weekly update of new regulations, copies of all pieces of
major environmental legislation (both State and Federal), and other
related materials. Information services like Inside EPA and Air and
Water Pollution Reports provide updates as to the most significant
environmental statutory and regulatory changes.
TECHNICAL PUBLICATIONS
EPA publishes or sponsors the publication of literally thousands
of technical documents per year. In the past, EPA distributed most of
these publications at no charge. Unfortunately, the cost of printing
this information has escalated to a point where the Federal Government
can no longer provide this free service. Therefore, essentially all
technical publications sponsored by the government, including EPA, are
now made available to the public through the U. S. (Department of
Commerce's National Technical Information Service (NTIS).
The Service prints up the "EPA Publication Bibliography Quarterly
Abstract Bulletin" providing a cumulative listing of EPA documents
published during the calendar year. This bibliography provides an
abstract of the listed Agency publications and a cross index of EPA
and NTIS publication numbers. Individual technical documents can be
purchased from NTIS either in paper or microfiche (substantially less
costly than paper). The address for NTIS is as follows:
National Technical Information Service
U. S. Department of Commerce
Springfield, Va. 22161
(703) 487-4650 TELEX 89-9405
A-2
-------
GOVERNMENT DEPOSITORY LIBRARIES
Nearly 1,400 libraries across the country serve as government
depositories providing at least a partial inventory of government
publications. In addition, many have exchange or loan arrangements
with other governmental depositories to obtain documents which are not
currently in their inventory. Pursuant to the requirements at 44
U.S.C. 1911, depositories must provide free public access to their
government publications. Table 1 1s a listing of the government
depository libraries within EPA's Region VIII.
EPA REGIONAL LIBRARY
The Denver Regional Office of the EPA maintains most of the EPA
technical information either in paper or microfiche. Library staff
are also available to provide any assistance which may be needed in
locating these documents or on the use of the library.
A-3
-------
TAB I- £ 1
Colorado
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-------
APPENDIX B
PRIORITY POLLUTANTS & EFFLUENT LIMITATION PARAMETERS
-------
APPENDIX B
TABLE B-I
MATRIX OF PRIORITY POLLUTANTS POTENTIALLY
DISCHARGED FROM INDUSTRIAL CATEGORIES
Table B-I lists Cha 25 categorical industries and the potential
priority pollutants that can occur in significant amounts in the
wastewater discharged from each group. This does not mean that every
facility within a specific group discharges that pollutant; it docs
mean that there is a high probability that it will be discharged,
based on a national survey of the Industries conducted by USEPA. In
addition, it does not mean that other priority pollutants will not be
£ound in significant quantities, but that, in general, the manufacturing
process and raw materials involved do not lead to the discharge of these
pollutants.
NOTE? The Information in the table was developed from Industry
Summaries prepared by the USEPA dated March, 1979 from the published
development documents for effluent limitations from Industrial point
source categories. This information is subject to change, and, as
shown in Tables B-I and B-II some industry groups may not be regulated.
8-1
-------
TABLE 5-1
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MATRIX OF PRIORITY POLLUTANTS
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B-5
-------
MATRIX OF PRIORITY POLLUTANTS
POTENTIALLY DISCHARGED FROM
INDUSTRIAL CATEGORIES
POLLUTANT FOUND IN
SIGNIFICANT QUANTITY
PRIORITY POLLUTANTS
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B-6
-------
MATRIX OF PRIORITY POLLUTANTS
POTENTIALLY DISCHARGED FROM
INDUSTRIAL CATEGORIES
POLLUTANT FOUND IN
SIGNIFICANT QUANTITY
PRIORITY POLLUTANTS
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B-7
-------
TABLE B-II
STATUS REPORT OF CATEGORIES TOTALLY OR PARTIALLY
EXCLUDED FROM PRETHEAIMEOT REGULATION
44 en
Mre_
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wamriM (;w Jmitray OaalC, aaca* Au«uac It, I9«l. TM» LaCorxulan -J auajaac M «Han«a.
B-8
-------
TABLE B-lII EFFLUENT L1H1TM10H PARAMETERS M INDUSTRY
TMfirilyn llukiriM I ' I I
im • i iif xsiiii I I a a a a a « a a a a a i ¦
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a a
-------
TABLE B—III (continued)
iMl
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«
-------
APPENDIX C
SAMPLE PRESERVATION GUIDANCE
-------
APPENDIX C
SAMPLE PRESERVATION
Various manuals and handbooks exist that outline procedures for the pre-
servation of industrial wastewater samples. The Intent of these procedures is
to delay any changes (either chemical or biological) that may occur once the
sample is taken from the wastestream. Preservation insures a sample repre-
sentative of the wastestream at the time of collection. For example, heavy
metal cations may absorb onto the sample container surface and some organic
pollutants are easily oxidized by free chlorine. Correct preservation
techniques would keep metal ions in a sample.
On December 3, 1979, EPA proposed to amend 40 CFR Part 136 with the
addition of sample preservation procedures and maximum holding times as
requirements for all pollutant parameters (Including toxic organlcs). Thus
the use of these preservation techniques would be mandatory whenever the
analysis of wastewater is required under the Glean Water Act (i.e., pretreat-
ment program compliance monitoring)• These sample preservation procedures and
holding times were selected because (1) they would retard significant sample
degradation, and (2) the procedures would minimize monitoring costs by
extending the holding times when possible. Table I shows the recommended
preservatives and holding times, as stated In the regulations. It Is recom-
mended that POTW personnel adopt these procedures in their monitoring program.
The EPA also recommends that the preservation procedures "be used at the
start of sample collection in the field and not after sample compositing is
complete or when samples are received in the laboratory for analysis.
Allquots of composite samples, which would require multiple preservatives,
should be preserved only by maintaining ac 4*C until compositing and sample
splitting are completed."^
1Guidelines Establishing Test Procedures for the Analysis of Pollutants;
Proposed Regulations. 40 CFR Part 136, December 3, 1979.
C-l
-------
C0MTA1N&BS, rKfiSKKVATlOM,
M b
Heasureaent Container
1 Acidity r.C
2 Alkalinity t.Q
3 taonli f,C
¦ACTKRIA
4-7 Collfora, facal P,G
tad total
I Fecal streptococci P,C
9 Blochenlcal oiygM 4mu4 P,G
10 Blochealcal oxygen p,C
deund carbonaceous
11 Broalde t,G
12 Cti«alcal oxygen deauuid P,C
II Chloride P,C
14 Chlorinated organic C, taflon-lined
compounds cap
15 Chlorine, total realdual P,C
16 Color P,C
17-18 Cyanide, total and P,C
anenabla to cklorlnatlon P.G
19 Dlaaolwul oxygen
Probe G bottle A top
Winkler C buttle 4 top
HOUtlNC Tixes
Preservative
Maxima .
Holding Tlaa
Cool, 4*C
Cool, 4*C
Cool, 4*C
UjBO^ to pU<2
14 daya
14 daya
2S days
Cool, 4*C .
0.0081 lUjfljOj
Cool, 4*C
0.008X **2820j
6 houre
i hours
Cool, 4*C
Cool, 4*C
48 houra
41 hours
Nona required
Cool, 4*C
U2S04 to pU<2
Nona required
Cool, 4*C
0.008X Na 8,0,
2 2)
Datenlne onalta
Cool, 4*C
Cool 4*C
NaOU to plOI2
0.008X MaSOj
28 days
28 daya
28 daya
1 daya (until extraction)
30 daya (after entractloo)
2 houra
48 hours
14 daya
Determine onslte
Fl> onalta
1 hour
i houra
-------
CONTAINERS, PUE8E8VATI0N, AND HOLDING T1H2S
• be Ma*Ui» 4
Measurement Container friunttlvt Holding Tine
20 Fluoride P Nona Icqul rad 28 daya
21 Hardoeae r.C HttO} to ptt<2 6 nontha
22 Hydrogen loa (pH) P,C tetania* oneIts 2 hours
21*92 Kjcldahl and organic nitrogen t,G Cool, 4*C 21 daya
«2S04 to f>H<2
METAI.S'
40-41 Chroalua VI f,G Cool, 4'C 41 hours
S8-90 Harcury P,0 HNO] to f>U<2 21 dayf
O.OSZ KjCTj0/
24-87 Metala escapt above P,6 HNOj to pU<2 i aontha
M Nit rata P.G Cool, 4*C 48 hours
68(a)' Hitrate-nltrlte P,6 Cool, 4*C 26 days
NjSO^ to pH<2
•9 Nitrlta p,6 Cool, 4*C 46 hours
90 Oil and graaaa 0 Cool, 4*C t 26 daya
H}S04 to pU<2
91 Organic Carbon P,G Cool, 4*C 28 days
HjSO^ CO pU<2
91-206 ORGANIC COMPOUNDS*
Extractables (Including 0, taflon-llnad Cool, 4*C . 1 daya (until amtractlon)
pUthalatee, altroaaalnaa cap 0.006Z Na.S.O. 10 daya (aftar extraction
organochlorlna pestlcldas,
PCB's, nltroaroaatlcs,
laopborona, polynuclear arnaatlc
hydrocarbona, heloethera,
chlorinated hydrocarbona and TCDO)
-------
CONTAINERS, PRESERVATION, AND HOLDING TIMES
Neaaureaent*
Container
Preservative'
Mulwn .
Holding Tina
Extractablas (phenol*)
C, taflon-lined
Cool, 4*C
T days (until extraction)
cap
U2S04 to pll<2
0.008* H«282°3>>
30 daya (after extraction)
Purgeablss (Ualocarbona and
Aroaatlca)
0, taflon-llnad
upturn
Cool 4*C .
0.008* 1Uj8j0j
14 daya
Purgeablas (Acrolein and
Acryloaltrlte)
e, teflon-lined
•eptua
Cool 4*C .
0.008* IUjSjOj
) daya
207
Or t liophoephats
r.c
Filter ooalta
Cool, 4*C
48 hours
208
rtntlcldu
0, teflon-llned
cap
Cool, 4*C .
0.008* NajSjOj
7 days (until ••traction)
30 daya (after extraction)
209
fluiuoli
P,6
Cool, 4*C
H2S0^ to pUC2
28 days
210
Hioaphorua (eleaental)
C
Cool, 4*C
48 hours
211
rhoaphoriM, total
f.c
Cool, 4*C
UaS04 to pH<2
28 days
HAOIOLOCICAL
212-216
Alpha, beta, and radlun
r.o
UNOj to pll<2
6 aontlis
217
Reeldue, total
r.c
Cool 4*C
14 days
2J8
Realdua, filterable
f.a
Coal 4*C
14 days
219
keeldue, nonfllterable
f.a
Cool 4*C
7 daya
220
teaidue, MttluUa
f,G
Cool 4*C
7 days
221
ItaUnc, volatile
r.c
Cool 4*C
7 daya
¦»%
-------
TABLE I. (Continued)
CONTAINERS, PRESERVATION, AND HOLDINC TIKES
be Haul mm
Measurement Container Preservative Holding Tlae
222
Specific conductance
P,G
Cool 4*C
28 daya
223
Sulfate
P.C
Cool 4*C
28 daya
224
Sulfide
P.6
Cool 4"C
Zinc Acetate
28 daya
225
Sulfite
P.6
Cool, 4*C
48 hours
226
Surfactanta
*.G
Cool 4*C
48 houra
227
Teaperatura
r.o
Determine onalta
laaedlately
228
Turbidity
r,6
Cool. 4*C
houra
i
* A
I . Parameter nuabere refer to Llat of Approved Procedures In AO CFR, part 136.
Polyethylene (P) or Glaaa (C).
Sample preservation ehould ba performed Immediately upon aample collection.
For compoalte aaaplaa each aliquot ahould be preaerved at the tlae of
collection. When uae of an automatic aaapler makes It Impossible to preaerve
each aliquot, then eaaplea My ba preserved by maintaining at 4*C until
j compositing and aaapla apllttlng la completed.
Saaplea ahould be analyced aa aoon aa poaalble after collection. The tlmea
llated are the maximum tlaea that aaaplaa aay ba held before analyala and
atlll conaldered valid. Saaplaa My be held for longer perloda only If tha
permittee, or monitoring laboratory, haa data on file to abow that the
specific typea of aaaplaa under atudy are atable for the longer tine.
Some aaaplaa aay not be atabla for the aaxlaua tlaa period given In the table.
A permittee, or aonltorlng laboratory, la obligated to hold the aaapla for a
shorter tlae If knowledge exists to show till a la neceaaary to Maintain aaapla
stability.
Saaplea should be filtered laaedlately onalta before adding preservative for
j dissolved aetala.
Guidance applies to saaplea to be analyced by CC, LC, or CC/HS for apeclflc
organic coapounda.
* Tills paraaeter aot listed In Tsble I.
. Should only be uaed In the presence of residual chlorine.
Not available In 40 CFI, Part 136.
Source I Culdellnea Eatabllehlng Teat Procedures for the Analysis of Pollutants;
Proposed Regulations. 40 CPR, Part 136, Deceaber 18, 1979.
-------
(Sample of Field Data Record)
FIELD DATA RECORD
ST1MI
umi
NMU
MHO*
eauena
TIM |M&|
_ *
TXBTfMnSf
twu l*WU
rwt ucii*u
:
- 1
1
1
"
1
C-6
-------
(Sample Tag)
ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
8UILDINS 53, BOX 25227-, DENVER FEDERAL CENTER
DENVER, COLORADO 80225 ( O
?roj«et Cod«
Station Ho*
Mo./Day/Tr.
Tin*
Designate:
Con?. Grab
Scaclaa Location
Saiaplara: (Slgaacara)
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-------
DETAILS OF SAMPLING
0
1
00
ruiMim •(
Sm*U
**»•
l«fb
fctahtf
•1
laylli
fl«M mr
Uk
la»l<
r«luM
rnumtlM
IImi
taUftlcal
IblMl
CklU •!
FlMtiM*
-------
(Chain of Custody Record)
toj> NOi
frojcct Nam
No,
of
con-
tainer a
////// -
Sanpierat(Signature)
Sti. No*
Pats
Tiaie
Ceap.
.0
IS
0
Station Location
/
//
Iclinqu tailed byi
(Signature)
Date/Tine
Received byi
(Signature)
Relinqulaliet
(Signature)
byt
T
Received by
(Signature)
Kellnqulelied byi
(Signature)
Date/Tine
1
Received byi
(Signature)
Reiinquialied byi
(Signature)
...
Date/Tine
1
Received by
(Signature)
llellnqulahed byi
((Signature)
Date/Time
Received for Laboratory byi
(Signature)
Date/Tine Rewar
1
kfl
-------
APPENDIX 0
EXAMPLE OF AN INVESTIGATION FORM
-------
APPENDIX D
INDUSTRIAL INVESTIGATION REPORT
»*•«« mm.
A0MI8; 1 M0 |
cawtrrv. »•»««t»«««t
1 / I
wr^kacK
eonncs*
AOOHSSS: e,T,r
¦ (TATI
SI*
•TNCBT HUMS* It
smvies
•TtlfT
A00RC2S.
rfATt
MO
SIP
ttLLINQ
AOOMUS:
•TATI
X»»
C3MTACT 1:
¦Ml
»*•••««
t 1
TITUS
ITACT2:
KAMI
pmmmm
( )
TITU.
MIUAtV ue
SIC M
ate ••
lie <«
mc ••
WATW
Acer •«
fWNCi
IIKVIU TTH
StWfft
acct n
UMVIU TT»«
ACCOUNT
INFORMATION:
ACCT ••
•MVIU TTH
mtimiv
mmctim
WMM1W
•cn«t t*H*urru •*
SAT ft
A AT I
»«*•«¦ •*
•*t a iirfoV
M |WIM »••• I
D-l
-------
JNOUSTiHAL INVESTIGATION REPORT
•««* * •*
movr*T
-------
industrial investigation report
WATffl SOURCE
(¦POI
WATER USAGI
¥tui«l !••• •» «•
~umummk .
~ NCXVIUi __
Cgww i i
c iACirkS* RW«VBMT1*M ••Vie*-
MMITAHT.
KIM—
eiMIUMCO •« MIWUCT.
MtrrMfATMCNT
csoc
MICHIfltN
COSC
•iinimax
CwfMiCAL STORAGt
i UNIT* . »J»MT V*W. '
NaaiMitv tb g»wi
I
8HLL CONTROL PlANS.'RROCgOURgl
AIR POLLUTION control iwtnm RtMttM)
MKIIK.
|IHC*III.
SAMPLING POINTS AVAILAILC
•CSCRIM * MM *W»»T kA T«UT:
•CSCRIM<
iui» ram a
ANALYTICAL rcsults availaili
D-3
-------
ttQUSTOIAL INVESTIGATION REPORT
>*OCZS CHEMICALS AMD WASTISTJEAMS
>«•« • o»
tratMTRv mummmm
D-4
-------
industrial investigation report
PROCESS FLOW DIAGRAM/FACILITY LAYOUT/RELATES INFORMATION
mm > mm
INOUMTI** MUMIK
D-5
-------
DEFICIENCY NOTICE
NATIONAL POLLUTANT BIS CHARGE
ELIMINATION SYSTEM (NPDBS)
(Read instruction* on back oi last pari Mor* aomplating)
*C*MITTCE (fmilUr) nam* ano aoomcss
PERMITTEE HEPNESENTATIVE fXaeeiMMg iMa Nattaa)*title .
. the deficiencies noted below were found.
During the compliance inspection carried out on (datvl
Additional areas of deficiency may be brought to your attention following a complete review of the Inspection Report and other in-
formation on file with the REGULATORY AUTHORITY administering your NPDES PERMIT.
MONITORING LOCATION (Qfttif)
ruow MKASuntMINT (Daaartaa)
SAMPLE collection/holoino TIME (.
sample phescnvatiom
OTHER SELr-MONITORINO DEFICIENCIES
ADDITIONAL COMMENTS
JUOUISTEO ACTION. Vow Mteniio« to tftccmMthm of the MWneto (Mid above It requeued. Xeeeipt of a dncriethm at Me corrective action*
Ukm will I* considered in Ike determination of the need fot furl tin Administrative or Legal Action. Your response Is to he (iMoeeter Km out Ineow*
Wete reaponeo mottod!: tl Hnciwiii with yamr aaat NPOES OiaeMargr Monitonnt Jtcporr (DA1R) or (3) mUmUfl as dfcvelM to Me ftiipwron 0«»
•ion* regarding possible Mkransp actio* ean fee awswarcd by the REGULATORY AUTHOKITY to wbicli yoor OMKi an tuamiUt* «ad wkicfc adiatM^
"3PCCTOR'* S4GMATUKK
'"I'lCO* a PRINTED NAME
INSPECTOR'S AOORESS/PMONE NO.
doncaa
OATS
V^A Farm UMO-t (2-M>
-------
APPENDIX E
EXAMPLE OF A BASELINE MONITOmG REPORT FORM
-------
INSTRUCTIONS FOR OPTIONAL BASELINE MONITORING REPORT FORM
general
Both the facility name and address and the owner or
operator name and address should be given. The name and
address o£ the POTW receiving the wastewater from the facility
should also be given.
The applicable Categorical Pretreatment Standard should be
indicated along with the applicable subcategories of that
Standard.
Questions
1.1. If "yes" is answered to this question, attach a copy
of the material submitted to the form.
1.2. See instructions for Question 1.
11.1. Briefly describe the nature of business or service
performed at this facility. This description should
include all manufacturing processes including those
not related to the categorical industry (use
additional sheets if necessary).
11.2. Give the production rate of this facility (usually
given as an annual average production or a monthly
average).
11.3. Provide the appropriate Standard Industrial
Classification (SIC) code(s) for this facility as
indicated in the Standard Industrial Classification
Manual published by the Office of Management and
Budget. This manual should be available at most
public libraries.
11.4. Self-explanatory.
11.5. Provide average and maximum waste flows from all
regulated process streams. If process wastestreams
are combined either with other process wastestreams or
non-process (sanitary, cooling water, etc.)
wastestreams, individual flowrates for the non-process
wastestreams should be given.
11.6. Each industrial user will sample, analyse and report
on all regulated pollutants specific to each process
(refer to appropriate subcategory in regulations for
specific pollutants). An attachment should be
provided indicating the types of samples (i.e., grab,
composite, flow proportioned), the frequency and
number of samples, time, date and locations of the
-------
sampling events, and certification that the method of
analysis meets the regulatory requirements (See
40 CPR 136). The facility must ascertain whether it
can meet the 30-day average, calculated average, daily
maximum or calculated maximum limit.
All pretreatment standards are process related and a
facility must comply with the standard at the end of
each regulated process. However, EPA recognizes that
many facilities combine their wastewater process
lines, cooling water and sanitary wastes prior to
treatment or discharge to municipal sewers.
Consequently, a facility can sample at a combined
point, but will need to adjust the categorical limit
by employing the Combined Wastestream Formula which is
contained in 40 CFR 403.6(e) of the General
Pretreatment Regulations. Zf this is the case with
your facility, you must employ the formula and provide
all additional data used for calculations. For
further explanation, please refer to 40 CFR 403.6.
Se1f-explanatory.
Zf the answer was "yes," skip Question 9, and go on to
Question 10.
An explanation is needed describing how the facility
intends to meet the Categorical Standards. Zf
additional pretreatment and/or operations and
maintenance are required, then an attachment must be
provided, describing the proposed system and a
schedule of dates for commencement and completion of
events leading to the construction and operation of
the system.
Any other environmental control permits (e.g., HPDES,
hazardous material, etc.) held by this facility must
be listed.
-------
wew|yoime mats
Facility Host ______ Omt/Optrtteri
MdrtMi ¦ Mdttui
Xccairiaq JOT** j
Udiuti
Cataforieal fnttMCMt Standard* ______
tfpllsaUi faboata^ory ( 1m) of that Standard*
X. Information JUraady Sataaittad
1) laa a baaalina report containing all tto iaforaatloo liatad toloa alxaady Dmb aobaittad
Cos thla facility?
L-J ®. L-J *0 Xf •yaa,* pi mm provide tto data ot aubaiaaion and tto mm and
addraaa of tto aqancy to which it waa aobaittad
2) «a» jaw fira aoppliad all ®* tto iaforaatloo raquaatad balow to tto WW la raapoaaa to
an indaatrial wast* i«m conductad by tto MXW aa pact of lta pratroatarat pro«raa?
L-J L-J » U "y*a,* atata tto data at yoor autoiaaxon aad tto mm and
toareaa of tto aganoy to wfticft it m> aobaittad
14 tfca anawar ia *yoa" to aittoc or totfe of tto qaMtioaa ataw. tton you aay not Mod to
followlnf qnMtioM. If your pravioualy aatoittad iaforaatloa providoa
•U tto iaforaatloa raquoatad balow, plaaaa attach a copy of ttot autoittal to this Coca
aad autoit oopiaa of tto fora, with a alqnod oartifioation ataeaaant (m aifnatara
bloofc) to tto spa aad tto Km.
XX. BaMliaa Monitoria« Kaport XaforMtlon
1) Briafly daaorlto tto produeta produced aad tto aaaofaetaring proaaasM aaployad by yoor
<*w»tloa. riM «a en
•Patolioly amd traataant vorka, aoaioipal vaatawatar traataoat plant or ayataa or aaaitary
diatriot.
-------
fage 2 of 3
2) traduction Utti (aaecifT unltal
3) SXC Code
hegolated »rocoea Bally Antaft Daily Mwf or
_motL_ ttttfllT) tfrt/HTl Meaaured tm
latiaatad (S)
Non-aegulated Proeaee Daily Average Daily Maaiaua or
H22Si <«al/dav) flf)
4) Naaauraaanta of follataatat Attack tbe aoat racont reaulta frsa tbe aaapliag aad
analyaia conducted dating aeraal mklnt bones of all rtfolattd procoaa atreaaa. Itn
aaaplea takan aoat ba representative of noraal «uk eyelaa and tbe atpacted pollutant
diacbargee to tba yon*, let eaeb saaple identified, include tba Collovia« iaforaatioa.
itatiia
Tba aaaplaa takan aoat bo representative of noraal votk eyelaa aad tba expected pollutaat
diacbargee to tba m»s race 4fl cm 4fla.iatbitsn
a. Saaple typo (i.e., flow proportioned, ccapoaite, scab)
b. frequency of aaaplea
o. Viae, data aad location of aaapliag mat
d. Matbod of analyaia
a. Comparison of roaalta vitb applicable pratraataaat standarda
f. Sf alternate liaita (i.e., eeabinad waateatreaa foraola*) aca calculated, iaolada
tba liait aad all supporting data.
7) baaidaal Frodnetat Does you* facility generate aay solid waate aateriala ia any of tba
regulated praoaaaaa liatad in Quaation S above?
/ / Tit / / MO Zf "yea,* please provide, on a separata attaebaeat, a liatiag of tba
type of vaata aatarial generated, tbe approaiaate quantities pec aontb and tba aetbod of
diapoaal of tbe liatad aatarial.
I) Certification Are betb tbe National Categorical Fretreataeat Standarda fee year
indaatry and otbar loeal pratraataaat ataadarda beiat aet on a consistent baala at tbia
jjjg Bi^n|^^lj^yes,Jfrgo*ci to Qaaatioa I. Xf •*>•, identify tbe ataadard(a)
9) It tbe answer to Oeeatloa 7 ia "no," will additional pretreataent and/or operation aad
aaintenanee be remixed for tbia facility to aeet either tbe Motional Categorical
pretreataent Standarda ox other loeal POT* ataadarda? raee 40 cr» 403.13(c)(H and (21)
J / n / / 10 zf *no," five tbe season for noncqapiiancai
•Xf uaing tbe oaabiaed waataatreaa foraula.
-------
1 o( ]
If •yaa," attaeb a doaoription of tha raquirad pratraataant aad/oc oparaeion and
aaintananca to aehiara eoapiianea, and includa tJsa aftortaat aeaadula of data* fee tba
ooaaonoaaont and eoaplation of tha major avanta loading to tha eonatruction and opatation
of tbaaa additional pratraataant ayataaa. Tba avanta lisead should ineluda aucb itaaa as
dovalopaant of praliainary piano, final daaign of tba ayataa, axacuting eontcaeta fos
purchaaa of aquipmnt- and or oonatraction, ooaaaneaaant of oonatruetion, coaplation of
conatruetion, and full oparational a&atua. tba period batvaan liaead eoapiianea dataa
auat not axcaad aim (9) aontha.
10) tiat any otber anwiromaetal ooatxol paraita (idantifying tba aqancy iaauioq tba parait)
bald by tbia faoilityi «aa 40 cm 403.12tb>(31)
vmrmit Trtm a »ia>«t HMfT
X bava paraonally axaainad and aa faaillar with tba inforaation anbaitttad on tbia fora and
attachaanta. Baaad on ay inquiry of tbeaa individnala iaaadiaealy raaponaibla for obtaining tba
inforaation roportad harain, i ballava tbat tba aubaittad inforaation ia trua, aeenrata and
eeaplata. X aa awara tbat tbora ara aignificant panaltiaa for aubaittinq falaa inforaation, aa
dietaead by 40 CF* 403.13(a). I»>a 40 CT* 403.12(b)(61)
Slgnatwr* or ocsiexax Data
Saa 40 cm 403.13 of tba Qanaral Pcatraataant rcoqsaa lagulationa for additional inforaation.
-------
APPENDIX F
COMPARISON OF RCRA AND PRETREATMENT REGULATIONS
-------
appendix f
i. Pretreatment
Types of Pollutants
• The Clean Water Act distinguishes between three types of pollu-
tants, Including (1) conventional pollutants, which comprise BOD,
TSS, fecal collforn, pB, and oil and grease, (2) toxic pollutants,
which comprise 126 ratals and organlcs, and (3) non-conventional
pollutants, which include all remaining pollutants.
• Pollutants Regulated by Categorical Standards - The pretreatment
program regulates pollutants contained in industrial wastewater
discharged to a POTW. Categorical standards (PSES) focus primarily
on the control of the 126 metal and organic toxic pollutants.
Conventional pollutants, such as.BOD and TSS, typically receive
adequate treatment at POTWs, and therefore are not regulated under
pretreatment standards (except pH, which is the subject of a
prohibited discharge standard). Moreover, Effluent Guidelines
Division has not yet conducted extensive sampling of some indus-
trial process wastestreaas (e.g., organic chemicals) for non-
conventional pollutants, precluding the development of PSES for the
control of non-conventional pollutants discharged by these indus-
tries. Regulation of these substances has been reserved for future
BAT/PSES rulemaking efforts.
• Pollutants Regulated bv Prohibited Discharge Standards/Local Limits
- Pretreatment regulations [40 CFR 403.5(c)J also require the
establishment of a local limit for any pollutant which can cause
interference (i.e., process upset, sludge contamination) or pass
through (i.e., water quality violation) at a POTW. The general
pretreatment regulations contain specific prohibitions against the
discharge of pollutants which will cause the following hazards at a
POTW:
- Fire and explosion
- Corrosion (pH less than five)
- Obstruction
- Interference
- Beat.
General prohibitions also preclude discharges which can cause POTW
Interference or pass through.
F-1
-------
2. RC2A
• Definition of Hazardous Wasca - Under RCSA Saceioa 3001, a hazard-
ous waste is dafload as a solid waste which say "causa, or signif-
icantly concribuca Co an inereaae in mortality or an incraasa in
sarlous irreversible, or incapacitating reversible illness; or pose
a substantial prasanc or potential hazard to human health or tha
environment whan improperly treated, stored, transported, disposed
of, or otherwise managed*" Solid waste Is daflnad broadly to
include solid, semi-solid, liquid and gaseous waste materials.
• Two Types of Hazardous Waste - There ara two types of hazardous
wastes: characteristic wastes and listed wastes*
- Characteristic Waste* A material may ba classified as a
hazardous waste where tha material, because it exhibits a
certain characteristic (a.g*, corrosivity), is capable of
causing tha hara cited in tha RCSA Section 3001 "Hazardous
Waste" definition* Currently, there ara four characteristics
which qualify a material aa a hazardous waste, including
lgnitabllity (40 C7& 261.21], corrosivity [40 CFR 261.22],
reactivity (40 CFR 261*23] and E? toxicity (40 CFR 261*24]* Zn
each Instance, tha characteristic must ba demonstrabla as
measured by a feasible standardized test method, or as detected
through a generator's knowledge of tha solid waste* The EP
toxicity testing procedura is designed to identify wastes likely
to leak toxic conseituanta into groundwater in a landfill
environment*
- Listed Waste* Second, the Administrator may list claaaas or
types of solid waste as hazardous wasta whare tha Administrator
has raason to balleve that individual wastes, within tha class
or type of wasta, ara typically or frequently hazardous* Tha
Administrator may list characteristic waatas, wastaa which ara
damonatratad to ba highly toxic [called Acuta Hazardous Waste]
and waatas containing ona or mora hazardous constltuants
enumerated in Appendix VIZI of 40 CFR Part 261 [called Toxic
Waste]* A substance is included in Appendix VIZI if it is shown
in scientific studies to have toxic, carcinogenic, mutagenic or
teratogenic effects on humans or other life forms* There ara
approximately 375 hazardoua constituents identified in Appendix
VIII. The Administrator has listed numerous hazardous wastes
from both non-specific sources (e.g., electroplating operations)
and specific sources (e.g., tank bottoms from tha petroleum
refining industry) in 40 CPR Part 261, Subpart 0*
F-2
-------
A COMPARISON OP MAJOR COMPONENTS OP TUB RCRA ANl) PKETREATMENT PROGRAM
PROGRAM AREA
PRETREATMENT
RCRA
COMMENTS
PARTIES
REGULATED
I
u
POLLUTANTS/
MATERIALS
REGULATED
CONTROL
AUTHORITIES
• •*14,000 Categorical Industries
(covering 22 Industrial
categories)
• Unknown nuaber of non-categorical
industrial uaers
• *1700 POTUs (comprising
National POTU flow)
SOX of
• 126 Priority Pollutants (Metals
and Tonic OrgaAics)
• Pollutants Regulated lay
Prohibited Discharge Standards
which nay cause:
- Pire or exploaion
- Corrosion (fit <5)
- Obstruction
- Interference
- Heat
- Pass through
• EPA IK)
• EPA Regions
• 19 States have approved programs
(36 NPDES States)
• *49,000 IN) Generators
(generators <100 Icg/ao. exempted)
• % 12,000 MU Transportera
• *7500 HU Treataent, Storage, and
Disposal Pacilitiee (TSOFs)
• Characteristic Uastea which
exhibit either!
- Ignltability
- Corrosivity
- Reactivity
- EP Tonicity
• Listed Hastes - covering
Characteristic Wastes, Acute
Hazardous Wsstes, and Toxic
llastes (Pollutants covered
include App. VIII 375 hazardous
constituents)
e EPA IM}
• EPA Regions
• 19 Stacea have either lnteria or
Pinal Authorisation
Unknown how aany Industries
discharging to POTUs are al
U1I generatora or TSOFs
Over 100 pollutants are on
both the priority pollutant
list and Appendix VIII
RCRA places no reliance on
aunlcipalitiea for regulstl
IIU.
e 440 POTUs hsve approved prograas
(1691 eventually)
-------
TYPE OF
STANDARDS
EHPLOYED
PERMITTING
MECHANISMS
RECORDKEEPING/
REPORTING
REQUIREMENTS
• Categorical Standards:
- Numerical limits for •elected
"I2b" pollutants
- Technology-based
- Mass*- or concent rst ion- based
• Local Limits:
- Numerical and absolute
prohibitions
• Ills discharging to 1700
Pretreatseat POTUs controlled by
"peralt, contract, ordre or
similar Mans"
• Other IUs say be permitted by
8tates or BPA although no
explicit regs currently exist
• POTUs regulated- by Federal or
State NFDES perklts
e POTUsl
- Industrtsl Waste Survey - to
identify 10s, pollutants, name,
address
- Discharge Monitoring Reports -
a MPDES reporting requirement
- POTW Annual Report - annual
summary of prutroatment
activities
Standards for Generators snd
Transporters are principally
concerned with handling waste
analysia and manifesting
TSDPs are subject to vsriety of
operational and design standards
RCRA contslns very few
discharge standards, relying
instesd on regulatory
provialons under CUA for UW
released to POTUs*
TSDFs regulated by two phase
permitting system - Part A and
Part 1 permits
Permits-by-rule for certain
disposal practices including UU
discharges to POTUs
Fretreatment permits optional;
but strongly encouraged for
large POTUs.
Generatorst
- EPA Notification - to obtain
l.D. No.
- Waste Analysis Records
Maintenance
- Maintenance of Manifests for 3
years
- Biennial Report - covering
generating activities
- Exceptions Report - when
manifest not received
Fretreatment program requires!
more frequent, periodic
reporting by Industries. RCH
relies more on records
maintenance.
-------
ucMDieeeetM/
REPORTING
REQUIREMENTS
(CONT'D)
IUst
- 1US Reaponae
- Permit Application .
- ImsUm Monitoring Report
(w/in 180 days of Cat. Std.
effective date)
- Compliance Date Report (w/in
90 days of coapllance date for
Cat. Std.)
-Self-Monitoring Reports
- Slug Load Notifications
INSPECTIONS AND • Federal/State Inspections*
SAMPLING
- Compliance Sampling Inspections
- Compliance Evaluation
Inspections
- Compliance Biomoijltoring
Inspections
- Performance AuUlt Inspections
- Pretreatment Program Audita
- NFDES Self-Monitoring
e P0T1I Compliance Monitoring
- Routine Industrial Demand
Monitoring
- Compliance Monitoring
- Ill Self-Monitoring
• Federal/State 1U Monitoring
(back-up compliance sampling of
10s)
Transporterst
- EPA Notification for I.D. No.
Compliance with Manifesting
Regs.
RCKA programmatic data pro-
vides little dsta on sewered
III# discharges. Pretreatment
programmatic data focuses
largely on toxic pollutants.
TSOFst
- EPA Notification for l.D. No.
- Compliance u/Manifestlng Regs.
- Maintenance of Usste Analysis
Records
- Maintenance of Operating
Records
- Biennial Report on wastes
received, generators, methods
of treatment, storage, etc.
Federal Inspections - primsry
agent for RCRA enforcement
State Inspections - compliance
evaluation program
Greater Federal primacy in
RCRA then in FT
-------
ENFORCKHENT
• Federal Authority:
- Civil r«oaUiei up to
$10,000/day
- Criainal Fine* up Co
$2St000/d
-------
APPENDIX G
LIST OF REGION VIII POTW CONTACTS FOR PRETREATMENT
-------
LIST OF POTVI PRETREATMENT PROGRAM CONTACTS
NAME OF THE POTW
NAME OF CONTACT
TELEPHONE NUMBER
COLORADO
City of Boulder
P 0 Box 791
Boulder, CO 80306
City of Broonrfleld
#6 Garden Office Center
Broomfleld, CO 80020
Centennial Water &
Sanitation District
62 West Plaza Drive
Highlands Ranch, CO 80126
City of Colorado Springs
18 South Nevada Avenue
P 0 Box 1103
Colorado Springs, CO. 80947
City of Craig
300 W. 4th Street
Craig, CO 81625
City of Delta
4th and Main
P 0 Box 19
Delta, CO 81416
Mr. Floyd Bebler
Mr. Thomas Huston
Mr. Jake Nielson
Mr. John Svlhllk
Mr. Donald Cooper
Mr. Frank Dicamlllo
City and County of Denver Mr. George Rupert
Wastewater Management Division
3840-G York Street
Denver, CO 80205
Eastern Fremont County
Sewage Disposal District
P 0 Box 405
Florence, CO 81226-0405
Cities of Englewood/Llttleton
(Bi-Cities Treatment Plant)
c/o City of Englewood
3400 South E1at1
Englewood, CO 80110
Mr. Thomas Doyle
Mr. William Owen
(303) 441-3131
(303) 466-5185
(303) 791-0436
(303) 636-5811
(303) 824-8151
(303) 874-7566
(303) 295-1451
(303) 784-6335
(303) 761-1140
G-l
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LIST Of PQV4 PRETREATMENT PROGRAM CONTACTS
NAME OF THE POTW
City of Fort Collins
Water Utilities Division
P 0 Box 580
Fort Collins, CO 80522
City of Fort Morgan
P 0 Box 100
Fort Morgan, CO 80701
City of Grand Junction
250 North Fifth Street
Grand Junction, CO 81501
City of Greeley
Greeley C1v1c Center
Greeley, CO 80631
City of La Junta
Municipal Building
P 0 Box 489
La Junta, CO 81050
City of Longnont
Water/Sewer Utilities 01v
1110 South Sherman
Longmont, CO 80501
City of Louisville
749 Main Street
Louisville, CO 80027
City of Loveland
Water and Wastewater Dept.
446 North Garfield Ave.
Loveland, CO 80537
Metropolitan Denver Sewage
Disposal 01st. Number
6450 York Street
Denver, CO 80229-7499
City of Montrose
P 0 Box 790
Montrose, CO 81401
City of Northglenn
2350 W 112th Aveenue
Northglenn, CO 80234
NAME OF CONTACT
Or. Keith Elnund
Mr. Michael Gay
Mr. J. Patterson, Jr.
Mr. Dan Hawkins
Mr. Cary Sarlo
Ms. Lynn Folsom
Mr. Karl Kasch
Mr. Todd Rogers
Mr. Steve Pearlman
Mr. Charles Liquln
Mr. Kip Scott
TELEPHONE NUMBER
(303) 221-6681
(303) 867-3001
(303) 224-1577
(303) 353-6123
(303) 384-2578
(303) 776-6050
(303) 666-6565
(303) 667-6130
(303) 289-5941
(303) 249-4534
(303) 451-1289
G-2
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LIST OF rom PRETREATMENT PROGRAM CONTACTS
NAME OF THE POTW
NAME OF CONTACT TELEPHONE NUMBER
City of Pueblo
P 0 Box 1427
Pueblo, Colorado 81002
Mr. Tom Cvar
(303) 544-4747
South Adams County
Mr. Larry L. Ford
Water and San. District
6595 East 70th Avenue
Commerce City, CO 80022
South Fort Collins
Mr. Michael DiTullio (303) 226-3104
Water & Sanitation Dist
4700 S College Avenue
Fort Collins, CO 80525
- City of Sterling Mr. Marvin McElwain (303) 522-9700
Centennial Square
Sterling, Colorado 80751
- Upper Eagle Sanitation 01st Mr. James Collins
& Vail Water & Sanitation
District
c/o Upper Eagle Valley
Sanitation District
P 0 Box 5130
Avon, CO 81620
- City of Westminster Ms. Pam Mulhall (303) 429-1546
3031 West 76th Avenue
Westminster, CO 80030
MONTANA
City of Billings
Public Utilities Dept
P 0 Box 30958
Billings, MT 59111
Mr. Gerald Underwood (406) 657-8305
City of Bozeman
P 0 Box 640
Bozeman, MT 59715
Mr. Richard Holmes
City of Great Falls
P 0 Box 5021
Great Falls, MT 59403
Mr. Lyle Meeks
(406) 727-5881
G-3
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LIST OF PQTW PRETREATMENT PROGRAM CONTACTS
NAME OF THE POTW
City of Helena
316 North Park Avenue
Helena, MT 59623
City of Missoula
201 West Spruce
Missoula, MT 59802
NAME OF CONTACT
Ms. Carol Ham
Mr. Joe Aide gar ie
TELEPHONE NUMBER
(406) 442-9920
Silver Bow Sanitation
District #1
800 Centennial Ave
Butte, MT 59701
Mr. William E. Pascoe
NORTH DAKOTA
- City of Bismarck
Dept of Public Works
P 0 Box 1578
Bismarck, N.D. 58502
- City of Fargo
Utilities Div - City Hall
Fargo, N.D. 58102
- City of Grand Forks
P 0 Box 1518
Grand Forks, N.D. 58201
Mr. Robert E. Gausvik (701) 222-6431
Mr. Ken Ruby
(701) 241-1300
Mr. J. Keith Johnson (701) 755-8103
SOUTH DAKOTA
- City of Rapid City Mr. John Healy (605) 399-4174
Wastewater Department
22 Main Street
Rapid City, S.D. 57701
- City of Sioux Falls Dr. Lyle D. Johnson (605) 339-7088
Water Reclamation Department
224 West 9th Street
Sioux Falls, S.D. 57102
6-4
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LIST OF POTW PRETREATMENT PROGRAM CONTACTS
NAME OF THE POTW
NAME OF CONTACT
TELEPHONE NUMBER
UTAH
Central Davis County
Sewer District
1234 South Main Street
Kaysville, UT 84037
Central Valley Water
Reclamation Facility Board
2589 South Main, Suite 120
South Salt Lake, UT 84115
Central Weber Sewer
Improvement District
2618 West Pioneer Road
Ogden, UT 84404
City of Logan
61 West 100 North
Logan, UT 84321
Moroni City Corporation
P 0 Box 467
Moroni, UT 84646
North Davis County
Sewer District
2200 South 4252 West
Syracuse, UT 84041
City of Orem
56 North State
Orem, UT 84057
City of Provo
351 West Center Street
P 0 Box 1849
Provo, UT 84603
Salt Lake City Corporation
1530 South West Temple
Salt Lake City, UT 84115
South Davis County
Sewer Improvement District
1800 West 1200 North
West Bountiful, UT 84087
Mr. Dean 0. Brand
Mr. Rodney L. Dahl
(801) 867-2190
(801) 487-4625
Mr. Marland L. Davidson (801) 731-3011
Mr. Ray C. Hugie
Mr. Paul Stevens
(801) 752-3060
(801) 436-8264
Mr. Allen Wheelwright (801) 825-0712
Mr. Keith Scott
Mr. Jesse Robinson
Mr. Sam Hong
(801) 224-7000
(801) 375-1822
(801) 535-7671
Mr. John Wheelwright (801) 295-3469
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LIST OF PQ-TO PRETREATMENT PROGRAM CONTACTS
NAME OF THE POTW
South Valley Water
Reclamation Facility
P 0 Box 277
Midvale, UT 84047
NAME OF CONTACT
Mr. Jack Petersen
TELEPHONE NUMBER
(801) 566-7711
Sprlngville City Corporation
50 South Main
Springville, UT 84663
Timpanogos Special
Service District
6400 North 5050 West
P 0 Box 515
Pleasant Grove, UT 84062
Mr. J. Brent Haymond (801) 489-5121
Mr. Garland J. Mayne (801) 756-5231
WYOMING
- City of Casper Mr. Punda Pai (307) 235-8213
200 North David Street
Casper, WY 82601
- City of Cheyenne Mr. Carroll Aamold (307) 637-6460
Water and Sewer Dept
2100 Pioneer Ave
Cheyenne, WY 82003
G-6
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APPENDIX H
ABBREVIATED STANDARD INDUSTRIAL CODE (SIC) LISTINGS
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APPENDIX H
STANDARD INDUSTRIAL CODE (SIC)
Standard Industlal Codes are as a means of Identifying the
activities that are conducted at Industrial facilities. The
appropriate Standard Industrial Classification (SIC) code(s) for this
facility as Indicated in the Standard Industrial Classification Manual
published by the Office of Management and Budget. This manual is
available at most public libraries.
Following is an abbreviated SIC listing:
S.I.C. INDUSTRY
0741 through 0742
2011 through 2017
202X
2032 through 2038
2061 through 2063
2076
2077
2082 through 2087
2091 through 2092
2099
2211 through 2299
2311 through 2399
2411 through 2499
2611 through 2661
2711 through 2795
281X
2821, 2861
282X
2822
2831 through 2834
2841 through 2844
2851
2861 through 2869
2869 and 2879
2873 through 2879
2891
2892
2893 through 2899
2911
2951 through 2952
3011 through 3069
3079
Veterinary Services
Meat Products/Poultry Products
Dairy Industry
Canned & Preserved Fruits & Vegetables
Sugar Processing
Vegetable Oils Processing
Animal Fats Processing
Meat Products/Poultry Products
Beverages
Seafood Processing Industry
Canned & Preserved Fruits & Vegetables
Textile Mills
Fabricated Textile Products
Lumber and Wood Products
Paper and Paper Products
Printing and allied Products
Inorganic Chemicals
Gum and Wood Products
Plastic & Synthetic Materials Manuf.
Synthetic Rubber Processing
Pharmaceuticals
Soap & Detergent Manufacturing
Paint & Ink Formulation
Organic Chemicals
Pesticides
Agricultural Chemicals
Adheslves and Sealants
Explosives
Paint & Ink Formulation
Petroleum Refining
Paving & Roofing
Rubber Processing
Plastic & Synthetic Materials Manuf.
H-l
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S.I.C.
3111
3296
3312 through 3399
3351
3353 through 3471
3411 through 3469
3471 and 3479
3479 through 3497
3599
3631 through 3639
3671 through 3679
3691 through 3692
3861
3951 through 3955
3996
4911 through 4931
5013 through 5099
5211
5462
5531
5541
5812
5983
7211 through 7219
7261
7332
7395
7531 through 7535
7538 through 7439
7542
8051 through 8059
8062 through 8069
8211 through 8222
SIC REFERENCE (continued)
INOUSTRY
Leather Tanning & Finishing
Fiberglass Insulation
Metal Refineries and Foundries
Copper Forming
Aluminum Forming
Metal Fabrication (e.a. Sheet Metal Shops)
Electroplating & Metal Finishing
Coil Coating (including canmaking)
Machine & Sheet Metal Shops
Porcelain Enameling
Electronic Components
Battery Manufacturing
Photographic Supplies
Paint & Ink Formulation
Flooring Materials
Electric Services
Wholesale Trade
Lumber & Building Materials, Retail
Bakeries
Auto Parts & Supplies: Retail
Gasoline Service Stations
Eating Establishments
Fuel 011 dealers
Laundries
Funeral Services
Blueprinting & Photocopying
Photographic Processing
Auto Body Repair & Paint Shops
Engine & Transmission Work
Auto Wash
Nursing Care Facilities
Hospitals
Schools and Universities
H-2
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BIBLIOGRAPHIC DATA K N°- 2.
SHEET EPA 908/3-84—004
3. Recipient's Accession No.
4. Title and Subtitle
Industrial Pretreatment Program Inspection Manual
5. Report Date
November 1984
6.
7. Author(s)
Compliance Branch, Water Management Division, Region VIII
8. Performing Organization Rept.
No.
9. Performing Organization Name and Address
Compliance Branch
Water Management Division
1860 Lincoln Street
Denver. Colorado 80295-0699
10. Project/Task/Work Unit No.
11. Contract/Gram No.
12. Sponsoring Organization Name and Address
U. S. Environmental Protection Agency
1860 Lincoln Street
Denver, Colorado 80295-0699
13. Type of Repon & Period
Covered
14.
15. Supplementary Notes
16. Abstracts
The manual is Intended to provide assistance to Publicly Owned Treatment
Works (POTWs) in their implementation of an industrial pretreatment program. The
document outlines many of the basic principles of an inspection/sampling program
including site review, sample collection, specific items of interest at various
types of industrial installations, chain-of-custody, and general principles of
safety.
17. Key Words and Document Analysis. 17a. Descriptors
Pretreatment
Inspections
Wastewater
Industrial Waste
Pollution Control
17b. Identifiers/Open-Ended Terma
17c. COSAT1 Field 'Group
19. Security Class (This
Report)
ISS1I
21. No. of Pages
190
IB. Availability Statement
Release to Public
^CLASSIFIED
22. Price
reMM MTI»» imkv. I0-T») ENDORSED BV ANSI AND UNESCO.
THIS FORM MAY BE REPRODUCED
uaeoMM.DC ta»<»7
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