DRAFT MANUAL OF PRACTICE

IDENTIFICATION OF

ILLICIT CONNECTIONS
U.S. ENVIRONMENTAL PROTECTION AGENCY
PERMITS DIVISION  (EN-336)
September 1990

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     TABLE OF CONTENTS


     Section                                            Page

1.    INTRODUCTION 	      1

2.    MANUAL APPROACH 	      3

3.    SYSTEM EVALUATION 	      4

     Step 1 - Mapping Effort 	      4
          Land Use 	      5
          Drainage Topography 	      6
          Aerial Photographs 	      6
          Sewers 	      7
          Summary 	      7
     Step 2 - Walking Tour 	      8
          Inaccessible Outfalls 	      8
          Accessible Outfalls 	      8
          Physical Characteristics 	      9
               Odor	      9
               Color 	      9
               Turbidity 	     10
               Floatables 	     10
               Residues 	     11
               Vegetation 	     11
               Structural Damage 	     12
     Step 3 - Discharge Analysis	     12
               pH 	     13
               Total Dissolved Solids 	     14
               Conductivity  	     14
     Summary	     15

 4.   IDENTIFICATION OF POTENTIAL INDUSTRIAL SOURCES      16

     Step 1 - Evaluate Flow  Pattern	     17
               Continuous Dry Weather Flow	     17
               Intermittent  Dry Weather Flow	     17
     Step 2 - Analysis of Data 	     19
     Step 3 - Correlation to Possible Industrial Sources 19
               Industrial Sources of Non-Storm Water     20
               Chemical and  Physical Properties  ....     20
               Waste  Characterization 	     20
          Correlation Process  	     27
          Age of Facilities  	     28

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     TABLE OF CONTENTS (cont.)


     Section                                            Page

5.    INDUSTRIAL WATER USE AND SPILL POTENTIAL 	     30

          Non-Contact Cooling Water 	     30
          Rinse Water 	;	     31
          Process Water 	     32
          Process Line Discharge 	     32
          Batch Dumps 	     33
          Slowdown 	     33
          Industrial Spills 	     34

6.    ON-SITE INDUSTRIAL INVESTIGATION 	     36

     Step 1 - Data Collection 	     36
          Mapping Information 	     36
               Plant Layout Drawings 	     37
               Sewer System Maps	     37
               Topographic Maps 	     39
               Summary 	     39
          Spill History	     41
     Step 2 - Preliminary Evaluation of Water Use ..     42
     Step 3 - On-Site Investigation	     43
          Outdoor Inspection  	     43
          Indoor Inspection 	     44
     Step 4 - Confirmatory Analysis 	     45
          Dry Weather Discharge Examination 	     45
               Procedure 	     46
               Summary 	     48
          Pipeline Examination 	     48
               Dye Tracer Tests 	•. • • •     49
               Internal Pipe  Investigations 	     49

7.   FIELD SURVEY TECHNIQUES  	     51

     Necessary Equipment and  Materials  	     51
          Field Test Kit 	     51
          pH and Conductivity Meters 	     53
          Automatic Sampler   	     53
          Instant Camera and  Film	     53
          Collecting  Samples  	     55
          Recordkeeping  	     55

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     TABLE OF CONTENTS (cont.)
     Section                                            Pagt

7.   FIELD SURVEY TECHNIQUES (cont.)

          Outfall Identification 	     56
          Manhole Observation Equipment 	     56
          Pipeline Examination  	     57
          Inspector Safety 	     57
     Personnel Requirements 	     58
          Phase I - Screening of Storm Water Outfalls    58
          Phase II - Industrial On-Site Investigation    58
          Personnel Training 	     58
     Timeline	     60
     Organizational Ideas 	     61
          Outfall Analysis Data 	     61
          Laboratory Analysis 	     61
          Process Data:  Direct Discharge 	     61
          Process Data:  Indirect Discharge 	     62
          Spill History 	     62
          Spill Potential 	     62
          Facility Runoff 	     62
          Correlation of Data 	     62

8.   SUMMARY  	     63
     TABLES
1    Sources of Non-Storm Water Discharge
       Related to Industry                               21
2    Chemical and Physical Properties                    23
3    Field Equipment and Materials                       52
4    Considerations for Automatic Sampler                54

     FIGURES

1    Typical Plant Layout and Sewer Overview             38
2    Storm and Sanitary Sewers Diagram                   40

     APPENICES

A    Waste Characterization
B    Cost Estimates
C    Data Inventory Forms

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   Section 1
   INTRODUCTION

The 1972 amendments to the Federal Water Pollution Control Act (FWPCA,
also referred to as the Clean Water Act or CWA),  prohibited the
discharge of any pollutant to navigable waters from a point source
unless the discharge is authorized by a National Pollutant Discharge
Elimination System (NPDES) permit.  Efforts to improve water quality
under the NPDES program have focused traditionally on reducing
pollutants in discharges of industrial process waste water and from
municipal sewage treatment plants.  In response to concerns about more
diffuse sources of pollutants, the Water Quality Act (WQA) of 1987 added
section 402(p) to the CWA to provide a comprehensive framework for the
United States Environmental Protection Agency (EPA) to address storm
water discharges.

EPA is in the process of developing and implementing comprehensive
national strategies to coordinate NPDES permitting efforts for storm
water discharges.  An important component of these control strategies is
the reduction of pollutants from industrial and commercial sites
discharged to separate and drainage systems.

Storm water drainage systems can be in the form of open ditches, swales,
channels, brooks, and subterranean routes, or closed pipes.  Separate
storm sewers are designed to convey only storm water, surface runoff,
street wash waters and drainage [40 CFR 35.2005(b) (47) ].

However, recent research  efforts have shown that sources  of non-storm
water from industrial facilities, commercial facilities,  and sanitary
sewage can contribute significant amounts of pollutants to separate
storm drainage systems and ultimately to surface waters.  Illicit
connections are point source discharges of pollutants to  separate  storm
drainage systems which are not composed entirely of  storm water  and  are
not authorized by an NPDES permit.  There are two  categories of  illicit

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connections - pronounced and subtle.  Pronounced connections are from
direct hook-ups to storm drainage systems.  Subtle connections are
indirect, intermittent, and usually do not involve piping.

Both pronounced and subtle illicit connections to separate storm sewers
may adversely affect the quality of receiving waters.  The removal and
prevention of such discharges can result in improvements in the quality
of receiving waters.  Nationwide studies have shown that illicit
connections can be prominent in commercial and industrial sites.  The
type of materials that are illegally discharged through separate storm
water sewers to surface waters varies considerably.  Distinct physical
and chemical characteristics can be used to identify non-storm water
from storm water discharge.

The purpose of this manual is to present a procedure for the
identification of illicit connections into storm drainage systems.  The
manual takes two perspectives: 1) that of evaluating which industrial
facility discharges non-storm water to a separate storm sewer system
serving multiple facilities; and 2) that of evaluating a targeted
facility for non-storm discharges to separate storm sewers.  The goal is
to ensure that storm drainage systems do not receive non-storm water or
other non-permitted discharges.  The methodology presented has been
designed to be flexible so as to accommodate both industrial and
commercial facilities.  In an effort to simplify the text, the word
"industrial" has been used to connote both industrial and commercial
facilities.

The methodology of this manual has been organized as a step-by-step
procedure to follow and implement.  These procedures are guidelines for
use with reasonable judgement on a case-by-case basis.

The intended use  for this manual is by regulatory or industrial
personnel.  It  is  important  to note that  this document has been written
for a non-technical audience.

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     Section 2

     MANUAL APPROACH
This manual takes a two phased approach to evaluating illicit
connections to separate storm sewers.  The first phase involves
the screening of storm sewer systems which drain multiple
facilities for indications of possible contamination from non-
storm water discharges from industrial and commercial sources.
The second phase is the investigation of the industrial or
commercial facility for identification of actual illicit
connections into the storm drainage system.

Both of these phases are divided into a number of sub-sections as
shown below which are described in more detail in the following
sections.

     System Evaluation

               Mapping Effort
               Walking Tour
               Outfall Analysis

     On-Site Industrial Evaluation
               Data Collection
               Preliminary Evaluation of Water Use and Other
               Discharges
               On-Site Investigation
               Confirmatory Analysis

In  addition, the final section is a discussion of the field
survey techniques essential for both phases.  This section
provides  organizational ideas for field testing  procedures.
General estimates regarding personnel and  time requirements
necessary to carry out field surveys as well  as  equipment cost

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     Section 3

     SYSTEM EVALUATION
This section provides a brief overview of procedures for
identification of non-storm water flows in storm water systems
which serve a number of facilities.

This initial phase of the procedures consists of three steps.
The first step is a mapping effort during which outfalls with a
potential for illicit connections.  The second step involves
conducting field surveys in order to screen priority outfalls for
actual signs of contaimination associated with illicit
connections.  In the third step, storm water outfalls (or other
suitable locations) are observed for signs of possible
contamination from illicit connections, physical characteristics
are observed, elementary chemical analyses are performed, flow
patterns are established, field tests are made, samples are
collected for comprehensive laboratory analyses, and relevant
information is documented.

Actual field testing procedures are discussed in detail in
Section 7 of this manual.
STEP 1 - MAPPING  EFFORT

The purpose  of  the mapping  effort  is to identify all storm water
outfalls with potential  for contamination from  illicit
connections, and  to  identify industrial facilities that
potentially  may be sources  of non-storm water to these outfalls.
This process involves the acquisition  and study of land-use,
drainage  (topographic),  and sewer  maps for  the  area under
investigation.

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Once the industrial outfalls have been located and the
contributing area delineated, they can be classified as having
either high or low potential for illicit connections.  The
purpose of this classification exercise is to organize the
outfalls according to their potential for illicit connections.
Those most likely to exhibit contamination from illicit
connections are the first to be visited during the field survey.
Several factors can aid in the classification of outfalls into
high or low potential for illicit connection categories.  A few
of these factors are briefly described below:


          Density of industrial activities within delineated
          areas.  If several industries are confined to a
          relatively small area, then the potential for illicit
          or inadvertent cross-connections is greater.

          Type of industrial activity.  The industrial activity
          in terms of principal products or services provided
          should be correlated with the nature of the water
          quality problems of the receiving water, if such
          information is known.  Often a single industry may
          contribute significant levels of pollutants to a water
          body.  For example, in one study, highly odorous and
          colored discharges at an outfall were attributed to a
          tannery.

          Proximity of industries.  The proximity of an industry
          to an outfall should also be correlated with the water
          quality of the receiving water if such information  is
          known.

Mapping and other available  information required for outfall
identification and classification are described in the following
sections.


Land Use

Land use maps document the  land surface according to generalized
uses.  This  is  valuable because the type  of  land use has  been

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found to be highly correlated to the pollution characteristics of
storm waters that originate from an area.   Land use maps are
usually maintained by local and/or regional governments.
Generally, land use is categorized according to the following
classifications:

          residential
          industrial
          commercial
          recreational
          agricultural
          open space

Drainage/Topography

These maps document the elevations and general relief of the land
surface.  The topography of a land surface determines the
direction of overland flow of storm water runoff.  For example,
in an area drained by two streams, it is possible to identify the
contributing areas to the flows of each stream by examination of
topographic maps.  Water will flow in the path of decreasing
elevation.  Therefore, using topographic maps, it is possible to,
construct the probable drainage path of surface runoff.

Aerial Photographs

Aerial photographs are another means of determining features on
the  land  surface.  The aerial photographs should be of  large
enough scale so that  industrial areas can be  identified.  Aerial
photographs can also  be used to identify storage areas  at
industrial  sites that may  contribute significant amounts of
pollutants  during wet weather.  Finally, they can  also  be used to
determine the proximity and  density of  industrial  areas relative
to  outfall  locations.  Aerial photographs may be obtained from
local  land  use  planning committees  as well  as from state
agencies.

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Sewers

Developed areas in the United States have extensive networks of
sewers.  They can be classified as follows:


          Sanitary Sewer.  These are conduits intended to carry
          liquid and water-carried wastes from residences,
          commercial buildings, industrial plants, and
          institutions together with minor quantities of ground,
          storm, and surface water that are not admitted
          intentionally  [40 CFR 35.2005(b) (37) ].

          Storm Sewer.  A sewer designed to carry only storm
          waters, surface runoff, street wash waters, and
          drainage  [40 CFR 35.2005(b) (47)].

          Combined Sewer.  A sewer that is designed as a sanitary
          sewer an a storm sewer [40 CFR 35.2005(b)(11)].

Sewer maps may be obtained from state agencies, local engineering
departments, or from other authorities such as publicly owned
treatment works.  They can be used to determine where industrial
manufacturing process and operational wastestreams should
discharge.


Summary

Mapping and data obtained for the study area should be summarized
as follows:


          Assign an identification number  to each industrial
          storm sewer outfall with potential industrial sources
          Delineate a contributing industrial area to each
          outfall
          Identify industries within  these areas

Based  on the likelihood  for  illicit connections,  the field
surveys should  be organized  such that outfalls  exhibiting the
highest potential for illicit  connections  are the first to  be
surveyed.

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STEP 2 - WALKING TOUR
The purpose of the walking tour is to identify storm water
outfalls exhibiting characteristics of possible contamination by
illicit connections for further analysis.  In addition, other
outfalls not identified during the mapping effort may be
discovered.  It is important to note that storm sewers may
discharge below the water level or may be inaccessible for some
other reason.  Thus, the screening of both inaccessible and
directly accessible storm water outfalls is addressed.

Inaccessible Outfalls

If a storm sewer outfall is submerged under water or inaccessible
for some other reason, it will be necessary to evaluate the storm
sewer sewer at an accessible upstream location.

The storm sewer manhole nearest to the outfall discharge point
should be located.  During a period of dry weather, the manhole
cover can be removed and visual observations made to detect any
non-storm water discharges.  If a dry weather flow is discovered,
the flow can be evaluated in a number of ways.  Odors or residues
can be indications of illicit connections.  Grab samples can be
collected and analyzed using either simple colormetric methods or
comprehensive laboratory analysis.  Noticeable physical and
elementary chemical properties of the discharge should also be
recorded.  These signs indicate the need for additional
observations in order to detect the potential discharge at the
manhole.

Accessible Outfalls

If the outfall is accessible, the  inspectors should visit each of
the selected outfalls to perform  initial visual inspections for
signs of  illicit discharges.  When walking from one outfall to
the next,  inspectors  should  check  for outfalls from storm drains

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or other pipes which are not indicated on maps.  Visual
observations should also be made at any newly-discovered outfalls
as well.  Identification data should be noted for unmarked
outfalls so that current maps can be updated.

When performing a visual outfall inspection, the inspector should
first check for discharges or parameters which may indicate the
presence of discharges such as wet pavement or residues.  Flows
during dry weather, when it has not rained recently, are a
definite sign of possible illicit connections.

After checking for the presence of discharges, the following
physical characteristics of any detected flows, the outfall, and
surrounding area should be observed.

Physical Characteristics

Odor

The odor of a discharge can vary widely and often directly
reflects the source(s) of contamination.  Thus, potential non-
storm water discharges will often cause a flow to smell like a
particular spoiled product, sewage, oil, gasoline, certain
chemicals and solvents, or whatever else may be the cause or a
component of the contamination.  For example,  in many  facilities
the decomposition of organic wastes will release sulfur into the
atmosphere creating a smell of rotten eggs.  Industries involved
in the  production of meats, dairy products, and the preservation
of vegetables or fruits, are commonly found to discharge organic
materials into storm drains.  As these  organic products or
byproducts spoil and decay, the sulfur  production creates this
readily apparent and unpleasant smell.

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Color
Non-storm water discharge can be any color.  Often they are a
darker color, such as brown, gray or black.  Outfall discharges
may become highly colored from the direct discharge of industrial
wastes.  For instance, the color of industrial wastewaters from
meat processing industries is usually a deep reddish-brown.
Paper mill wastes are also brown.  In contrast, textile wastes
are varied, intense colors, while plating-mill wastes are often
yellow.  The waste from spray paint booths which may be washed
down to floor drains may also result in varied colors.  Field
measurements of color can be performed using a colorimeter.

Turbidity
Turbidity determines the clarity of an outfall discharge.  It is
a measurement of the amount of suspended matter which interferes
with the passage of light through water.  Turbidity may be caused
by both fine and coarse suspended materials.  These materials may
range from purely inorganic substances to those that are largely
organic in nature.  Turbidity values may range from essentially
zero in pure water to several thousand in highly polluted
conditions.  Many industrial wastewaters are highly turbid.
Thus, a dry weather discharge at an outfall with a high degree of
turbidity is a strong sign of a possible contamination from an
industrial discharge.

Floatables
A contaminated flow may also contain floatables.  These are any
floating solids or liquids derived from non-storm water discharge
or storm water washoff.  Evaluation of floatables often leads to
the  identity of the source of industrial pollution since these
substances are usually direct products or  byproducts  of a
manufacturing process.  Floatables may  include substances  such as
animal  fats, spoiled  food products, oils,  plant parts, solvents,

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sawdust, foams, packing materials, or any type of fuel.
Residue

Residue refers to any type of coating which remains after a non-
storm water discharge has taken place.  Residues tend to coat the
area surrounding the outfall and are usually a dark color.  They
often will contain fragments of floatable substances and may take
the form of a crystalline or amorphous powder.  These situations
are illustrated by the grayish-black residue, containing
fragments of animal flesh and hair, which is often produced by
leather tanneries or the white crystalline powder which commonly
coats sewer outfalls at nitrogenous fertilizer plants.

Vegetation

Vegetation surrounding an outfall will also show the effects of
intermittent or random non-storm water discharge.  Pollutants
will often cause a substantial alteration in the chemical
composition and pH of the discharge stream.  This alteration will
affect plant growth even when the exposure is intermittent.  For
example, decaying organic materials coming from various food
product wastes would cause an increase in plant life.  The loss
of chemical dye and inorganic pigments from textile mills could
noticeably decrease vegetation as these non-storm water
discharges often have a very acidic pH.  In either case, even if
the source of pollution is not continuous, the vegetation
surrounding the outfall may show the  effects of the
contamination.

To evaulate if the vegetation surrounding an outfall  is normal,
the observer should consider the climate as well as the time of
year.  In addition, the vegetation of outfalls close  in proximity
to the one under investigation should also be noted as a means of
comparison.  Inhibited plant growth as well  as dead and decaying
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foliage can indicate the season or weather conditions in addition
to being a sign of pollution.

Structural Damage
Structural damage is another highly visible indication of both
continuous and intermittent non-storm water discharge
contamination.  This occurs when certain pollutants cause
structural damage such as cracking, deterioration, and spauling
of the concrete or peeling of surface paint.  These contaminants
are usually very acidic or basic in nature.  For example, batch
dumps of highly acidic wastes at primary metal industries can
cause structural damage.
STEP 3 - DISCHARGE ANALYSIS
Closer analysis of an outfall is warranted if any flows are
detected and/or any physical characteristics appear to indicate
the potential  for illicit connections during the initial
inspection.  If a flow  is occurring during dry weather, the time
and day of the week should immediately be recorded.  Next,
documentation  of the observed physical characteristics at the
contaminated outfall should also be recorded.

Testing for pH, total dissolved solids,  and conductivity can be
easily performed in the field with specialized meters.  Further
testing for specific elements, total phenol, free cyanide,  and
for many other chemicals can also  be done  in the  field using
field kits  (such as those using colormetric methods).  These
parameters, as well as  other pollutant parameters,  can also be
analyzed through  laboratory analysis  of  samples.

Observation of basic  chemical  characteristics  may reveal  a great
deal  of  information about the  flow quality of  a  discharge as
well.   Once preliminary documentation has been completed,  an

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elementary chemical analysis of any discharges should also be
performed.

EH
Measurement of pH determines if a solution is either acidic or
alkaline.  Several kinds of pH meters are available which can be
used to determine the approximate acidic or alkaline condition of
a discharge.  The possibility of direct discharge of industrial
wastewater is often indicated by dry weather flows which are
found to be acidic, alkaline, or which alternate between the two
extremes.

The normal pH of storm water is usually between 6 and 7.5.
However, the pH of a discharge affected by a source of non-storm
water may vary in the range from 3 to 12.  Illicit connections
conveying discharges from manufacturing or other commerical
processes could lead to extreme pH levels.

Acidic,  non-storm water discharges in the range of 3 to 6 are
possible from textile mills, pharmaceutical manufacturers, metal
fabricators as well as companies producing resins, fertilizers,
pesticides, or other similar materials.  Wastes containing
sulfuric, hydrochloric, or nitric acids are the common cause of
acidic  contamination.

Alkalis may cause non-storm water discharges to become more basic
and enter the higher pH range  of 8   to  12.  Many industrial
alkaline wastes contain chemicals such  as sodium cyanide,  sodium
sulfide,  and sodium hydroxide.  High concentrations  of these
contaminants are found in non-storm  water discharges from soap
manufacturers, textile mills,  metal  plating  industries,  steel
mills,  and  producers of rubber or plastic.   In addition,  alkaline
wash waters used by many industries  to  clean floors  or
manufacturing machinery are a  typical source of illicit

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discharges.
Total Dissolved Solids

Total Dissolved Solids (TDS) refers to the amount of solid
material completely dissolved in a water sample.  Dissolved
solids consist mainly of inorganic salts, small amounts of
organic matter, and dissolved gases.  A high amount of total
dissolved solids is a strong indication that flows from sources
other than storm water could be entering the storm water system.

Ranges of possible TDS readings are as follows:
     Clear Water
     Rainwater
     Storm water Runoff
     Non-Storm water Discharge
     Undiluted Industrial Wastes
   100 - 200 ppm
   150 - 500 ppm
   200 - 5,000 ppm
- greater than 2,000 ppm
- greater than 10,000 ppm
Conductivity
The conductivity of a solution is a measure of its ability to
conduct an electrical current.  Conductivity measurements may be
taken with a special meter to provide a rapid estimate of the
dissolved solids content of a water sample.

Only charged particles such as ions carry electrical current.
Therefore, water samples with high proportions of uncharged
organic molecules will have low specific conductivity values.  It
should be noted, however, that samples with very high or low pH
values will show high specific conductivities due to the high
concentrations  of H* and OH'  ions.  Conductivity measurements  are
also temperature dependent.

If a discharge  is present at  the time of the initial  inspection,
elementary  chemical  analysis  for pH, total dissolved  solids,  and
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specific conductivity can be performed.  Results of any testing
should always be recorded.  (Parameters of concern for laboratory
analysis are discussed in detail in the section on Field Survey
Techniques.)
SUMMARY
If signs of an illicit discharge appear evident but there is no
flow occurring, additional field surveys of the outfall will be
necessary.  Further inspections of the outfall should be
scheduled for various times and days throughout the week in order
to completely evaluate the discharge.  Or, as an alternative, an
automatic sampler may be installed and checked on a regular
basis.  Once the discharge has been discovered, the time and day
of the week on which the flow occurred should be recorded.
Elementary chemical analysis can be performed using either field
testing methods or more comprehensive laboratory analysis.

Once the field surveys of all outfalls scheduled for the walking
tour have been completed and initial inspections for illicit
discharges have been fully documented, the identification of
potential industrial sources may be pursued.
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     Section 4

IDENTIFICATION OF POTENTIAL INDUSTRIAL SOURCES OF NON-STORM WATER
The purpose of this section is to define guidelines to assist in
finding sources of non-storm water at industrial facilities which
may be responsible for an illicit discharge to a municipal
seperate storm sewer.  Information is also presented which will
aid in the correlation between an illicit discharge and the
suspected industrial source.  This section should serve as a
basis for organizing data in a fashion which will allow the user
of this manual to narrow the choices and select the industrial
source most likely responsible for the illicit discharge.

In order to identify the potential sources of a non-storm water
discharge when industrial contributors are suspected, the
following questions should be considered:

          What is the flow pattern of the non-storm water
          discharge?
          What distinctive qualities of the non-storm water
          discharge are revealed by the observed physical and
          chemical properties?

Answering these questions will lead to a characterization of the
discovered illicit discharge.  The following text describes the
evaluation process to determine which industrial "facilities could
be responsible according to non-storm water discharge
characterization.  Step 1 begins with establishing the flow
pattern of the non-storm water discharge.  In Step 2, documented
data  is analyzed to reveal any distinguishing characteristics.
Step  3 involves making the correlation between an illicit
discharge and the most likely industrial source.
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STEP 1 - EVALUATE FLOW PATTERN
The flow pattern of an illicit discharge may be either continuous
or intermittent, as described below.

Continuous Dry Weather Flow

Dry weather flows  in a storm water drainage system pipe or
drainage ditch may be a visible sign of non-storm water
discharges.  Flow in the absence of a storm events clearly
indicates that a secondary source (or sources) is contributing
flows to the storm drain flow.

Continuous discharges will release water or other liquids at a
uniform and uninterrupted rate.  Typical sources of continuous
flows include leaks from manufacturing equipment, constant
overflows from wet processes, and released non-contact cooling
water which has been contaminated.  Continuous dry weather flows
are not always contaminated.  They may also originate from either
groundwater infiltration and/or industrial discharges authorized
by an NPDES permit.

Continuous discharges may result from non-industrial sources as
well.  Several examples of potential non-industrial sources are
listed below:
     Sewage Sources:
          raw sewage from leaking sanitary sewers
          septage from improperly operating septic tank  systems
     Groundwater infiltration
 Intermittent  Dry Weather Flow
 Intermittent  flow during dry weather can also be  a  strong
 indicator  of  non-storm water discharge.  Intermittent discharges
 release  flow  periodically.  This may be a  fixed cycle,  for

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example at every half hour, or at variable intervals.  If the
source is industrial, discharge may occur on a regular basis or
randomly, depending on production schedules.  The main sources
are rinse waters, batch dumps, process dumps, process line
discharge, or spills.

Intermittent discharges may result from non-industrial sources as
well.  Several examples of potential non-industrial sources are
listed below:

     Household Automobile and Maintenance:
          car washing runoff
          radiator flushing
          improper oil disposal

     Residential Watering Runoff
     Roadway and Other Accidents:
          fuel spills
          spills of truck contents
          pipeline spills

     Other:
          washing of ready-mix trucks
          laundry wastes
          improper disposal of other household toxic substances
          sump pump discharges

Infiltration of groundwater into sewers in areas with high
groundwater tables may result in flows observed in sewer systems
as noted  above.  However, flows will typically not exhibit
fluctuations, such as short-term, hourly variations which may be
more typical for industrial discharges.

If the flow pattern was not established during the initial
outfall  inspection from the walking tour, additional field
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surveys will be necessary.  These inspections should be scheduled
for various times and days throughout the week or an automatic
monitor may be used to determine the flow pattern.
STEP 2 - ANALYSIS OF DATA
The purpose of this step is to review all recorded data for
distinguishing characteristics of the potentially illicit
discharge.  This review typically includes an analysis of all
physical observations and chemical parameters which appear as
unusual.

Physical observations which work well include the odor and color
of the discharge as well as any floating material or residues.
Extremely high or low values for the various parameters as
measured from the elementary chemical analysis or the
comprehensive laboratory testing are also strong indicators.
These factors can be used to identify possible industrial
sources.

All distinguishing characteristics should be noted before
proceeding to the next step.

STEP 3 - CORRELATION TO POSSIBLE INDUSTRIAL SOURCES
In this step, an answer to the following question is sought:

          Which industrial sources could be responsible for this
          particular non-storm water discharge?

The following support data has been provided to simplify the  task
of selecting the most likely industrial source for an  illicit
discharge.
                                19

-------
Sources of Non-Storm Water Discharge Related to Industry
Table l is provided to rank the most likely ways in which various
facilities could produce non-storm water discharges.  The
categories considered included loading and unloading of dry bulk
or liquids, water usage in reference to cooling and process
waters, and illicit or inadvertent industrial connections.  The
likelihood of a facility producing a non-storm water discharge in
each of these categories was rated on the basis of high,
moderate, or low potential or not applicable if there was no
evident correlation.

Chemical and Physical Properties

The information in Table 2 indicates possible chemical and
physical characteristics of contaminated non-storm water
discharge which could come from various facilities.  The chemical
properties considered are pH and Total Dissolved Solids.  The
physical properties included are odor, color, turbidity,
floatable substances, vegetation, and structural damage.  The
descriptions in each of these categories explain the most likely
test results for a contaminated non-storm water discharge coming
from a particular industrial facility.  It should be noted that
any combination of these characteristics may occur at an outfall.

Waste Characterization

Appendix A provides detailed information regarding wastestream
identification and characterization for various facilities listed
under industrial SIC categories.  The following data are included
for each SIC code:

           SIC Subcategory Listing
           Typical Sources of Wastestream Flows
           Wastestream Characterization
                                20

-------
                   TADLE  1
 SOURCES Of NON-STORMWATER DISCHARGE  RELATED  TO  INDUSTRY
INDUSTRIAL CATEGORIES LOADING/UNLOADING
MAJOR CLASSIFICATIONS DRY
SIC GROUP NUMBERS BULK LIQUIDS
PRIMARY INDUSTRIES
20 FOOD AND KINDRED PRODUCTS
201 MEAT PRODUCTS
202 DAIRY PRODUCTS
PROCESSING INDUSTRY
203 CANNED AND PRESERVED
FRUITS AND VEGETABLES
204 GRAIN MILL PRODUCTS
2C5 BAKERY PRODUCTS
206 SUGAR AND CONFECTIONARY
PRODUCTS
207 FATS AND OILS
202 BEVERAGES
21 TOCACCO MANUFACTURES
22 TEXTILE MILL PRODUCTS
23 APPAREL AND OTHER FINISHED
PRODUCTS MADE FROM FABRICS
AND SIMILAR MATERIALS
MATERIAL MANUFACTURE
24 LUMBER AND WOOD PRODUCTS
25 FURNITURE AND FIXTURES
26 PAPER AND ALLIED PRODUCTS
27 PRINTING, PUBLISHING,
AND ALLIED INDUSTRIES
31 LEATHER AND LEATHER PRODUCTS
32 STONE, CLAY, GLASS,
AND CONCRETE PRODUCTS
33 PRIMARY METAL INDUSTRIES
34 FABRICATED METAL PRODUCTS
37 TRANSPORTATION EQUIPMENT
CHEMICAL MANUFACTURE
23 CHEMICALS AND ALLIED PRODUCTS
231 INDUSTRIAL INORGANIC
CHEMICALS
222 PLASTIC MATERIALS AND
SYNTHETICS
2Ł3 DR'JCS


H

H

H
H
H

H
H
H
H
H


H

H
H
H

H
H

H
H
H
L



H

H
L


L

H

H
11
M

M
H
H
H
L


L

L
M
H

M
H

M
H
H
H



H

H
L
WATER
COOLING


H

H

H
H
NA

L
H
H
NA
H


NA

NA
NA
H

NA
L

L
H
H
H



H

H
H
USAGE
PROCESS


H

H

H
H
H

M
H
H
M
H


H

H
L
H

M
H

H
H
H
H



H

M
M
ILLICIT/
INAOVERTANT
CONNECTIONS


H

H

H
H
L

L
M
L
M
H


L

L
L
H

L
H

L
H
H
H



K

H
L
(H -  HIGH,  M  - MODERATE, L - LOW, NA - NOT APPLICABLE)
                   ^\

-------
                                                       TABLE   1
                                     SOURCES OF NON-STORMUATER DISCHARGE RELATED TO IKDUSTRY
INDUSTRIAL CATEGORIES
  MAJOR CLASS If .'CATIONS
    SIC CRO'JP  NUMBERS
LOADING/UNLOADING
DRY
DULK      LIQUIDS
    WATER USAGE
COOLING     PROCESS
ILLICIT/
1NADVERTANT
CONNECTIONS
CHEMICAL MANUFACTURE (continued)
  284  SOAP,  DETERGENTS,  AND
         CLEANING PREPARATIONS
  285  PAINTS,  VARNISHES, LACQUERS,
         ENAMELS, AND ALLIED
         PRODUCTS
 H
  236  INDUSTRIAL ORGANIC CHEMICALS   H
  2S7  AGRICULTURAL CHEMICALS         L
                           L
                           M
                           L
  29   PETROLEUM REFINING AND RELATED INDUSTRIES
  291   PETROLEUM REFINING             L           H
  295   PAVING AKD ROOFING MATERIALS   H           H
                         H
                         NA
               L
               M
  30   RUGGER  AND MISCELLANEOUS
         PLASTICS PRODUCTS
TRANSPORTATION AND CONSTRUCTION
  15   BUILDING CONSTRUCTION          M
  16   HEAVY CONSTRUCTION             M
                         NA
                         NA
RETAIL
  52   BUILDING MATERIALS, HARDWARE,
         GARDEN SUPPLY, AND MOBILE
         HOME DEALERS
  53   GENERAL MERCHANDISE STORES
  54   FOOD STORES
  55   AUTOMOTIVE DEALERS AND
         GASOLINE SERVICE STATIONS
  56   APPAREL AND ACCESSORY STORES
  57   HOME FURNITURE, FURNISHINGS,
         AND EQUIPMENT STORES
  58   EATING AND DRINKING PLACES
H
H
H
H
H
H
H
H
L
M
H
H
L
L
L
M
NA
NA
NA
NA
NA
NA
NA
NA
L
L
M
M
L
L
L
M
L
L
L
H
L
L
L
M
 OTHER
  COAL STEAK ELECTRIC POWER
  NUCLEAR STEAM ELECTRIC POWER
 H
 NA
                           L
                           NA
                                   (H - HIGH, M - MODERATE,  L - LOW,  NA -  NOT APPLICABLE)

-------
                                                                                               TABLE   i
                                                                                    CHEMICAL  AND  PHYSICAL PROPERTIES
INDUSTRIAL CATEGORIES
KAJOR CLASSIFICATIONS
S1C GROUP NUMBERS
PRIMARY
20
201
202
203
204
INDUSTRIES
fOOO AND KINDRED PRODUCTS
HEAT PRODUCTS
DAIRY PRODUCTS
CANNED AND PRESERVED
FRUITS AMD VEGETABLES
GRAIN MILL PRODUCTS
ODOR COLOR
SPOILED HEATS BROUN TO
ROTTEN EGGS AND FLESH REDDISH-BROWN
SPOILED HILK GREY TO WHITE
RANCID BUTTER
DECAYING PRODUCTS VARIOUS
COMPOST PILE
SLIGHTLY SWEET AND MUSTY BROUN TO
GRAINY REDDISH-BROWN
TURBIDITY FLOATABLES RESIDUE STRUCTURAL VEGETATION pH 1!
HIGH AN/HAL FATS, BYPRODUCTS BKOUH 10 BLAC< HIGH
PIECES OF PROCESSED MEATS
HIGH ANIMAL FATS GREY TO HIGH
SPOILED MILK PRODUCTS LIGHT-BROWN
HIGH VEGETABLE WAXES, SEEDS, BROUN LOU
SKINS, CORES, LEAVES
HIGH GRAIN HULLS AND SKINS LIGHT BROWN LOW
STRAW AND PLANT FRAGMENTS
FLOURISH VORK-U H
FLOURISH ACIDIC H
NORMAL WIDE RANGE H
NORMAL NORMAL H
?05   BAKERY FRODUCIS
206   SUGAR AND CONFECTIONARY
        PRODUCTS
                                    SUEET  AWD  OR  SPOILED
                                    NA
                            BROUN TO BLACK    HIGH
                                                               NA
                                                                                          COOKING OILS, LARD
                                                                                          FLOUR, SUGAR
                                              LOW      LOW POTENTIAL
                                                                                                                        GREY TO         LOU
                                                                                                                        LIGHT BROUN
                                                                                                                                                  NORMAL    NORMAL     H
                                                                                     WHITE  CRYSTALS LOU        NORMAL    NORMAL      H
207   FATS AND OILS
                                    SPOILED  HEATS
                                    LARD  OR  GREASE
                                                               BROUN  TO BLACK     HIGH      ANIMAL  FATS,  LARD
                                                                                     GREY  TO
                                                                                     LIGHT-BROWN
               LOU        NORMAL    NORMAL
208   BEVERAGES
21    TOBACCO MANUFACTURES
22    TEXTILE HILL PRODUCTS
23    APPAREL AND OTHER
        FINISHED PRODUCTS
FLAT SODA, BEER, OR WINE    VARIOUS
ALCOHOL. YEAST
DRIED TOBACCO
CIGARS, CIGARETTES

WET BURLAP, BLEACH
SOAP, DETERGENTS

NA
                                                               VARIOUS
                                                               VARIOUS
                                                                                 MODERATE GRAINS AND HOPS, BROKEN GLASS LIGHT BROUN
                                                                                          DISCARDED CANNING ITEMS
                                                                                                                                        HIGH        INHIBITED  WIDE  RANGE
                                                               BROWN TO BLACK    LOU
                                                                                           TOBACCO STEMS AND LEAVES
                                                                                           PAPERS  AND  FILLERS
BROWN
                                                                                                                                       LOU
                                                                                 HIGH     FIBERS, OILS, GREASE
                                                                                  LOU       SOME  FABRIC PARTICLES
                                                                                                                        NA
                                                                                                    LOW
                                                                                                                                                  NORMAL    NORMAL     i
                                                                                                                        GREY TO BLACK   LOU         INHIBITED BASIC      >
                                                                                                               NORMAL    NORMAL      L

-------
                                                                                                TABLE    Z.
                                                                                      CHEMICAL AND PHYSICAL PROPERTIES
INDUSTRIAL CATEGORIES
  KAJOR CLASSIFICATIONS
    SIC GROUP NUMBERS
       OOOR
                               COLOR
                                              TURBIDITY
                                                             FLOATABLES
                                                                                        RESIDUE
                                                                        STRUCTURAL VEGETATION  pH
                                                                                                                                    IDS
MATERIAL MANUFACTURE
  24    LUMBER AND WOOD PRODUCTS

  <5    FURNITURE AND FIXTURES

  26    PAPER AND ALLIED PRODUCTS
  27    PRINTING,  PUBLISHING,
          AND ALLIED INDUSTRIES
NA

VARIOUS

BLEACH
VARIOUS CHEMICALS

INC. SOLVENTS
 NA

 VARIOUS

 VARIOUS
LOU      SOME SAWDUST

LOW      SOME SAUDUST,  SOLVENTS

MODERATE SAUDUST,  PULP  PAPER
         WAXES,  OILS
BROUM  TO  BLACK    MODERATE PAPER DUST, SOLVENTS
LIGHT BROUN    LOU

LIGHT BROUN    LOU

LIGHT BROUN    LOU
                                       GREY TO        LOU
                                       LIGHT-BROUN
NORMAL    NORMAL     LOU

NORMAL    NORMAL     LOU

NORMAL    U1DE RANGE LOU


INHIBITED NORMAL     H1C
  31    LEATHER AND LEATHER PRODUCTS   LEATHER,  BLEACH
                                      ROTTEN  EGGS OR FLESH
  33    PRIMARY KETAL  INDUSTRIES
                                      VARIOUS
  34    FABRICA1ED METAL  PRODUCTS     DETERGENTS
                                     ROTTEN EGGS

  32    STONE, CLAY,  GLASS,  AND       UET CLAY, MUD
          CONCRETE PRODUCTS           DETERGENTS
                            VARIOUS           HIGH     ANIKAL FLESH AND HAIR
                                                       OILS,  GREASE

                            BROUN TO BLACK    MODERATE ORE,  COKE,  LIMESTONE
                                                       MJLLSCALE,  OILS

                            BROUN TO BLACK    HIGH     DIRT,  GREASE,  OILS
                                                       SAND,  CLAY  DUST

                            BROUN TO          MODERATE GLASS  PARTICLES
                            REDD1SH-BROUN              DUST  FROM CLAY OR STONE
                                                         GREY TO BLACK  HIGH
                                                         SALT CRYSTALS

                                                         GREY TO BLACK  HIGH
                                                         GREY TO BLACK  LOU
                                                         GREY TO        LOU
                                                         LIGHT-BROUN
                                                                 HIGHLY     UIDE  RANGE  HIC
                                                                 INHIBITED

                                                                 INHIBITED  ACIDIC     HIC
                                                                                    INHIBITED UIDE RANGE HIC
                                                                 NORMAL     BASIC       LOU
CHEMICAL MANUFACTURE
  28    CHEMICALS AND ALLIED  PRODUCTS
  2812  ALKALIES AND CHLORINE
STRONG HALOGEN OR CHLORINE
PUNGENT BURNING
ALKALIES - NA     LOW
CHLORINE • YELLOW
         TO GREEK
  2816  INORGANIC PIGMENTS            NA

  28    CHEMICALS AND  ALLIED  PRODUCTS

  ?82   PLASTIC MATERIALS             PUNGENT, FISHY
          AND SYNTHETICS
                                                                 VARIOUS
                           VARIOUS
                                                                                   HIGH
         NA
                                                       LOW POTENTIAL
                                              HIGH     PLASTIC  FRAGMENTS,  PIECES
                                                       OF  SYNTHETIC  PRODUCTS
                                       ALKALIES  -  UH1THIGH
                                         CARBONATE SCALE
                                       CHLORINE  -  NA
                                                                                     VAR1OUS
                                                         VARIOUS
                                                                                                    LOU
                                                                        LOU
                          HIGHLY    BASIC      HIC
                          INHIBITED
                                                                                                               HIGHLY     UIDE  RANGE HIC
                                                                                   INHIBITED WIDE RANGE nlC

-------
                                                                                                   TABLE   2.
                                                                                        CHEMICAL AND  PHYSICAL  PROPERTIES
  IKDUS1RIAI. CAIE COSIES
    KAJOR CLASSIFICATIONS
      SIC CROUP NUMBERS
       ODOR
                               COLOR
                   TuRBiDiTi       FLOATABLES
   RESIDUE     STRUCTURAL VEGETATION  pH
                                                                                                                                    ID'
CHEMICAL MANUFACTURE (Continued)

    283   DRUGS
    2M   SOAP, DETERGENTS, AND
            CLEANING PREPARATIONS

    285   PAIHTS, VARNISHES.
            LACOUERS, ENAMELS,
            AND ALLIED PRODUCTS
            (SB = SOLVENT BASE)
NA
SWEET OR FLOWERY
                            VARIOUS
                                                                    VARIOUS
LATEX - AMMONIA             VARIOUS
SB - DEPENDANT UPON SOLVENT
  (PAINT IHINNER.
  MINERAL SPIRITS)
                   HIGH     GELATIN  BYPRODUCTS FOR
                            CAPSUUT/WG DRUGS

                   HIGH     OILS.  GREASE
                   HIGH      LATEX  -  NA
                            SB  - ALL  SOLVENTS
                                                                                     VARIOUS
                                                                                                    LOU
GREY 10 BLACK  LOU
                                                                                                               HIGHLY    NORMAL     H|(
                                                                                                                                                       INHIBITED  BASIC      HIC
GREY TO BLACK  LOU        INHIBITED LATEX -  BASHK

                                    S8 - WQRKAL
    286   INDUSTRIAL ORGANIC CHEMICALS
    2861   GUM AND WOOO CHEMICALS        PINE SPIRITS
                            BROUN TO BLACK    HIGH     ROSINS AND PINE TARS
                                                         GREY TO BLACK  LOU
                                                                                                                                                       INHIBITED  ACIDIC      HC
    2B65  CYCLIC CRUDES,  AND CYCLIC
            INTERMEDIATES,  DYES,  AND
            ORGANIC PIGHENIS
SWEET ORGANIC SMELL
                                                                    NA
                  LOW      TRANSLUCENT SHEEN
                                                                                     k'A
                                                                                                    LOU        HIGHLY    NOflKAL      101-
                                                                                                               1NH1BMED
    267   AGRICULTURAL CHEMICALS
    2873  NITROGENOUS FERTILIZERS
NA
                            NA
                                              LOW      NA
                                                                                                                            WHITE CRYSTALLIHIGH        INHIBITED  ACIDIC     Hi:
    2874  PHOSPHAIIC FERTILIZERS        PUNGENT  SWEET
    2875  FERTILIZERS,  MIXING ONLT      VARIOUS
                            MILKY WHITE       HIGH     NA
                            BROWN TO BLACK    HIGH     PELLETIZED FERTILIZERS
                                                         WHITE AMORPHOUSHJGH
                                                           POWDER

                                                         BROWN AMORPHOUSLOW
                                                           POWDER
                                                                                                                                                       INHIBI TED  ACIDIC      Hi;
                                                                                                               NORMAL    NORMAL      Hit
    29    PETROLEUM REFINING
            AND RELATED INDUSTRIES
    291    PETROLEUM REFINING
    30    RUBBER AND MISCELLANEOUS
            PLASTICS PRODUCTS
ROTTEN EGGS
KEROSENE, GASOLINE

ROTTEN EGGS
CHLORINE, PEROXIDE
BROWN TO BLACK    HIGH     ANY CRUDE OR
                           PROCESSED FUEL
BLACK          LOU
SALT CRYSTALS
BROWN TO BLACK    MODERATE SCHREDDED RUBBER              GREY TO BLACK  LOU
                           PIECES OF FABRIC OR METAL
                                                                                                                                                      INHIBI TED U1DE RANGE H.'C
                          INHIBITED WIDE RANGE Hid

-------
                                                                                                TABLE   2.
                                                                                     CHEMICAL AND PHYSICAL PROPERTIES
 INDUSTRIAL CATEGORIES
  MAJOR CLASSIFICATIONS
    SIC GROUP NUMBERS
       OOOR
                               COLOR
                                              TURBIDITY      FLOATABLES
                                                                                                                             RESIDUE      STRUCTURAL VEGETATION  pH
                                                                                                                                   TDS
                                                                                                                            POUDER
IRANSPORTATION AND CONSTRUCTION
   IS    BUILDING CONSTRUCTION         VARIOUS

   16    HEAVY CONSTRUCTION            VARIOUS
RETAIL
  52    BUILDING MATERIALS,  HARDWARE, NA
          GARDEN SUPPLY,  AND
          MOBILE HOME DEALERS

  53    GENERAL MERCHANDISE  STORES    NA

  5d    FOOO STORES
  55    AUTOMOTIVE DEALERS AND        OIL OR GASOLINE
          GASOLINE SERVICE STATIONS

  56    APPAREL  AND                  KA
          ACCESSORY STORES

  57    HOME FURNITURE,  FURNISHINGS,  NA
          AND EQUIPMENT  STORES

  58    EATING AND DRINKING PLACES    SPOILED FOODS
                                     OIL AND GREASE
                            BROWH TO BLACK    HIGH     OILS.  GREASE,  FUELS

                            BROWH TO BLACK    HIGH     OILS.  GREASE,  FUELS
                                                       DILUTED ASPHALT OR CEMENT
                                                                 BROUH TO BLACK    LOW
NA
SPOILED PRODUCE
RANCID, SOUR
NA
VARIOUS

NA
LOU

                                                       SOME SEEDS,  PLANT  PARTS,
                                                       DIRT,  SAWDUST,  OR  OIL
                                                                                            NA

                                                                                            FRAGMENTS OF FOOD
                                                                                            DECAYING PRODUCE
                                                                 BROUN TO BLACK    MODERATE OIL OR GASOLINE
                                                                                   LOW      NA
                                                                 NA
                                                                                   LOU      NA
                                                                 BROWH TO BLACK    LOW
                                                      SPOILED OR  LEFTOVER  FOODS
                                                      OIL AND GREASE
GREY TO BLACK  LOW

GREY TO BLACK  LOW



LIGHT BROUN    LOU
                                                                                                                          NA
                                                                                                                          BROWN
                                                                                                                                         LOU
                                                                                                                                         LOW
                                                                                                                                         LOW
NORMAL    NORMAL     HIGH
NORMAL    NORMAL     HIGH


NORMAL    NORMAL     LOU
                                                                                    NA              LOU        NORMAL     NORMAL     LOU

                                                                                    LIGHT BROUN     LOU        FLOURISH   NORMAL     LOW


                                                                                    BROUH           LOU        INHIBITED  NORMAL     LOU
                                                                                                                                                    NORMAL    NORMAL      LOW
                                                                                                                                                    NORMAL    NORMAL     LOU
                                                                                                                                                    NORMAL    NORMAL      LOU
COAL STEAM ELECTRIC POWER
NUCLEAR STEAM ELECTRIC POWER
NA
                                     NA
                           BROWH TO BLACK     HIGH     COAL DUST
                           LIGHT BROWH       LOW      OILS, LUBRICANTS
                                                                                                                         BLACK AMORPHOUSLOU
                                                                                                                           POWER

                                                                                                                         LIGHT BROUN    LOU
                          NORMAL    SLIGHTLY   LOU
                                      AC/D/C

                          NORMAL     NORMAL     LOW
                                                                                                     2'4

-------
Common sources of wastestream flows as well as typical values for
conventional and.toxic pollutants are presented to aid in the
industrial identification process.

These tables and appendix were organized according to the SIC
code.  The intent of classifying by SIC code was that similar
facilities should produce non-storm water discharges in basically
the same manner with fairly identical characteristics.
Furthermore, SIC codes give the best estimate of typical
wastewater discharges by virtue of principal manufacturing
operations.  Thus, those facilities which are not individually
listed should iiave qualities resembling those of other facilities
with which they  are classified in the SIC code.

Correlation Process

The correlation  process begins by generating a list of all
industries in the area which could have a connection to the
drainage system  pipe network leading to the contaminated storm
water outfall.   Once this list is completed, the selected
industries should be organized according to their appropriate SIC
classification and, if possible, by subcategory.  Next, the
outstanding characteristics which were determined in the previous
steps should be  compared - industry by industry - to the coded
support data.

The  flow pattern established in Step 1 should be compared to
Table 1.  High cooling and process water usage indicates a
greater likelihood for a continual discharge or a very frequent
intermittent discharge.  While low water usage would generally
indicate a random discharge of little volume or perhaps none at
all.

The  distinguishing characteristics as determined in Step 2 should
be compared to Table 2,  A particular industrial facility could

                                27

-------
be the actual source when there are several correlations between
noted features and those listed in the table.

The results from the comprehensive laboratory testing of the grab
samples should be compared to the typical conventional and toxic
pollutant values listed in Appendix A.  Strong similarities
between the test results and typical listed values may indicate a
particular facility as the possible industrial source of the non-
storm water discharge.

Age of Facilities
A final factor of consideration is the age of an industrial
facility.  There is a high potential for unauthorized connections
for industries that occupy older buildings.  Sanitary sewers may
not have been in existence, since storm sewers predate the
development of sanitary sewers.  During the time of an industry's
development there may have been a lack of information regarding
the location of sanitary and storm sewer lines which led to
confusion as to the proper function of a storm sewer line.  In
addition, over time as the activities within an industry change
or expand, there is a possibility for illicit  or inadvertent
connections as floor drains and other storm sewer connections may
begin to process non-storm water discharges which require
treatment.

Also, since pollution control requirements regarding storm water
have been minimal or non-existent in  the past, older industrial
facilities possess  a greater potential for having illicit
connections to the  storm water drainage system.

Upon the  completion of this correlation process, it will become
evident that many of the previously listed industrial  facilities
should be eliminated  as possible  sources of  the illicit
discharge.   In most cases,  either  one particular industry  may

                                28

-------
clearly appear to be the most likely source or several facilities
may still seem to all be possible sources.

At this point, the only way of identifying the actual source of
an illicit discharge is to perform an on-site industrial
investigation for illicit connections to the storm water drainage
system.  On-site industrial investigations should proceed from
the most to the least likely facility appearing to be the source
of the illicit discharge.  A priority listing of investigations
should be generated based upon the findings of the correlation
process.

A brief discussion of common types of industrial non-storm water
discharges and illicit connections is presented in Section 5.
This information is provided to serve as a basis for Section 6
which defines a methodology for performing an on-site industrial
investigation for illicit connections.
                                29

-------
     Section 5

     INDUSTRIAL WATER USE AND SPILL POTENTIAL
This section describes typical water uses and potential sources
of spills at industrial facilities and is intended to provide
technical background for the investigative team.  The
descriptions provided are by no means exhaustive.  Therefore, the
investigative team is encouraged to consult with plant personnel
for more complete descriptions of water use processes during
actual on-site investigations.
NON-CONTACT COOLING WATER

Non-contact cooling water is water that decreases the temperature
of a particular part or process without ever physically touching
it.  "Non-contact" is achieved by allowing cooling waters to
circulate around the part or process in a contained jacket or
external channel.

In order to discharge non-contact cooling water into a storm
drain, an industry must obtain an NPDES permit.  These discharges
should not be contaminated as long as cooling waters remain fully
separated from the part or process they are cooling, the
discharges are not above permit temperature limits, and chemical
additives are not used.  However, when cooling systems are not
functioning properly, they become potential sources for
contamination as cooling waters may come in contact with various
toxic substances and carry them into storm sewers.

Industries will use  large amounts of non-contact cooling water
for several reasons.  Non-contact water is often used to cool raw
materials, final products, and machinery such  as compressors or

                                30

-------
rectifiers.  For example,  the turbines and boilers used in coal
steam electric power generation are cooled by using non-contact
waters.  These cooling waters are also frequently used for
temperature control of chemical reaction vats or metal plating
baths.  The temperature of reactor vessels used in the production
of plastics and synthetics is controlled by non-contact cooling
waters.  These could become contaminated by leaks and spillovers
in the primary process.

At some industrial facilities chemicals are added to cooling
waters to prevent the deposition of scale on pipes and equipment,
and also to prevent rust formation.  They are also added to
cooling waters to prevent biological growth.  These chemicals may
be toxic or harmful to animal, plant, or aquatic life.  Such
cooling water discharges are usually discharged into sanitary
sewers, with appropriate pretreatment when applicable.
RINSE WATER
Rinse water is water which cleans or reduces the temperature of
an object through actual physical contact with the object.
Discharges resulting from rinse waters are often allowed to enter
floor drains which may be inadvertently connected to storm sewers
rather than to sanitary sewers.  They can also enter storm sewers
through direct connections by piping.  A high potential for
continuous or intermittent dry weather flow exists for those
industries in which raw materials, final products, or production
machinery must be sanitized or cooled by using rinse waters.

Rinse waters may originate from facilities that utilize regular
washdown procedures.  For instance, soft drink bottling plants
use  rinse waters for removal of waste liquids, debris, and labels
from returned bottles.  Rinse waters can also be used for
temperature reduction by dipping, washing, or spraying objects
                                31

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with cool water.  For example, rinse water is sometimes sprayed
over the final products in the metal plating industry in order to
cool them.

Rinse waters which are most likely to cause an intermittent flow
are those used for clean-up at the end of a work shift, before
product changeover, or after raw materials have been unloaded.
One such case could be the flushing of a chemical delivery tank
at an unloading dock.  This would lead to contamination if toxic
chemicals were washed down to floor drains connected to the storm
water system.

PROCESS WATER
Process water may also be discharged into floor drains or could
be piped directly into the storm water sewer system.  Process
water is used in a facility to perform a variety of functions or
an actual product ingredient.  Process waters which are likely to
cause continual dry weather flows are those used for filtration,
dilution, soaking, and conveyance.
PROCESS LINE DISCHARGE

Process line discharge refers to the disposal of anything used in
or resulting from a manufacturing process including substances
such as wastes, byproducts, chemicals, and fuels.  This type of
waste is often seen in the food processing industry.  For
instance, cannery procedures for vegetables often produce process
line discharge.  The process line wastes usually consist of
solids from sorting, peeling, and coring operations as well as
can spillage from filling and sealing procedures.
                                32

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BATCH DUMPS
Batch dumps are the disposal of process batches which may be
composed of a wide variety of substances.  However, some of the
more common batches include combinations of chemicals, solvents,
dyes, paints, or may simply be rinse water baths.  A common
example of batch dump waste comes from the pickling process used
in steel mills.  To remove dirt and grease, steel is immersed in
dilute batches or sulfuric acid.  This process produces a waste
known as "pickling liquor" which is mainly composed of iron
sulfate.  Batch dump disposal occurs when the iron sulfate
concentration has increased enough to inhibit the pickling
process.  At this point the pickling liquor is replaced by a
fresh batch of sulfuric acid.

In the cases of both batch dumps as well as process line
discharge described above, these substances may be disposed of by
allowing them to drain to the storm water sewer system.

SLOWDOWN

Slowdown represents a portion of water purposely wasted from a
water system to help control buildup of solids or minerals.  Two
common examples are blowdown from boilers as well as that from
cooling towers.  In some cases the volume of blowdown generated
by an individual plant is significant and it may require
treatment before discharge.  More frequently, however,
contributions of blowdown are very small, and it is merely
combined with other wastewater prior to discharge.

The  water used in boilers or cooling towers is often subjected to
treatment designed to control corrosion and scale  formation.  In
most cases,  chemical agents such as zinc or sodium chromate,
caustics, and acids are used for these purposes.   Therefore, the
existence of these chemicals qualifies blowdown  as an  industrial

                                33

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process wastestream.
INDUSTRIAL SPILLS

The previous situations are most likely to cause continuous or
intermittent dry weather flows on a fairly regular basis.  In
some cases, observed flows may exhibit random behavior.  A
primary cause of random flows is industrial spills, since they
are accidental.  After a spill has taken place, the spilled
materials are often washed down to floor drains which may be
connected to storm sewers.  Unless there is some dilution (such
as rainwater), this type of pollution will be very concentrated.


Spills result from many activities, but among the most common
are:


     Boil Overs;  Boil overs principally result from bulk
overheating, hot spots, uncontrolled exothermic reactions, and
overloading.

     Transfer To and From Storage;  Inadequate personnel
training, poor maintenance and irregular inspections may be
causative factors for spills during transfer.  In addition,
inadvertent damage to facilities, i.e., valves, piping and
storage tanks by vehicles or work crews may contribute to
accidental discharge.

     Transfer To and From Carriers;  Spills during transfer to
and from carriers generally result from improper or poorly
maintained facilities and equipment, malfunctions of equipment,
and operator error.

     Storage Facility Leaks and Failures;  Leaks in storage tanks
that escape detection may result in large amounts of pollutants
reaching separate storm sewers via illicit connections.  These
spills are typical for storage tanks and/or lagoons used for the
temporary storage of concentrated wastes or reject materials.

     Process Facilities and Failures;  This type of spill may
result from operator inattention, poor equipment up-keep, or

                                34

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faulty piping connections.

     Storm Water Drainage:   Storm water may discharge large
quantities of pollutants from areas that include:

          Spilled dry materials,
          Dust collector accumulations,
          Small leaks which are impounded by topography,
          Rubbish piles, and
          Containers with residues.

The causes of such storm water runoff hazards can include
operator neglect, poor maintenance, and poor housekeeping.
Loading and unloading areas as well as outdoor storage of raw or
waste materials are where spills are most likely to occur.
                                35

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     Section 6

     ON-SITE INDUSTRIAL INVESTIGATION
This section presents a methodology for conducting on-site
investigations to detect illicit connections to the storm water
drainage system at an industrial site.  The methodology for the
on-site industrial investigation is divided into four steps.

          Step 1 - Data Collection
          Step 2 - Preliminary Analysis of Water Use and Other
                  Discharges
          Step 3 - On-Site Investigation
          Step 4 - Confirmatory Analysis
It is suggested that industry personnel participate as members of
the investigative team since they are the most familiar with the
processes and operations within a facility.

STEP 1 - DATA COLLECTION
The objective of this step of the methodology is to obtain and
evaluate all relevant mapping and spill history information
pertaining to the industrial site under investigation.  The
information necessary to complete this step is discussed below.

Mapping Information

Mapping information is essential for identification of key
features of the storm water drainage system relative to potential
sources of non-storm water at an industrial site.  Key features
of the storm water drainage system may include swales, open
ditches, channels, brooks, closed pipes, or sewer lines.  Various
industrial processes and operations are determined on a site-by-
site basis.
                                36

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Pertinent mapping information,  when available,  should include;

          Plant Layout Drawings (Schematics)
          Sewer System Maps
          Topographic Maps

Available mapping usually reflects the intended design of the
facility.  Due to process modification these maps may not
represent existing conditions and may need to be updated.

The following sections describe the various types of mapping
information.
Plant Layout Drawings (Schematics)

These drawings should show the actual physical layout of an
industrial plant.  They may also indicate the locations of major
industrial or commercial processes and equipment within the
facility.  Plant layout drawings will show the geographic
orientation of the facility relative to local streets as well.

Additionally, plant layout drawings may show an overview of the
in-facility piping and sewer locations.  The piping and sewer
plans show the location of floor drains and hard piping
connections to plumbing fixtures, wet processes or other
equipment.  Plant layout drawings may also show the locations of
both indoor and outdoor storage areas.  Figure 1 shows a typical
plant layout drawing.
Sewer System Maps
Most municipalities provide storm and sanitary sewer service at
the property line.  Facilities may have complete drawings of
         and storm water sewers to which its wastewaters and

                                37

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                                                      Figure  1
                               TYPICAL  PLANT LAYOUT AND SETTER OVERVIEW
                                                        NORTH STREET
                T
                        T-—r
                           . ROOF DRAIN
   SAWITARY
          HUff-DRAIN
         f 'HARD- PIPING

         CROSS SECTION
                         STORM WATER
                         SEWER
 NpN-RCCULA7tD
0
(S)
    OPERATION J
    OPLRAT10N 2
    OPERATION 3
    OPERATION 4
    OPLRAT10N 5
 STORM DRAIN SYSTEM	0	
 (ROOF DRAINS. YARD DRAINS AND CATCH-BASINS)
 SANITARY SYSTIU    	O	
 BUILDING PEWMETtR  — •  —  • —
                          r •  ~
_L
         L         !J    LL*—"
        ^ ~ ~ m ~v>iŁr__ _ JT_J -T"— —
                                                       SOUTH STREET

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storm water runoff drain.   Sewer maps also show the junction
points at which storm and sanitary laterals from a facility
connect to the municipal sewer systems.   Figure 2 is a diagram
showing storm and sanitary sewers in an industrial area.

Municipal sewer system schematics are generally shown on street
maps.  These maps will show connection locations to municipal
sewer systems.  During this initial mapping overview effort, it
is important to note and distinguish between storm water and
sanitary sewer lines.  Manholes for each type of sewer  (sanitary
or storm) should be clearly labeled or numbered.  This is
necessary for manhole observations which are discussed in a later
section.
Topographic Maps
Topographic maps, which show the ground elevations at a site, are
useful when determining the direction of flow of storm water
runoff.  In situations where raw or waste materials at a facility
are stored outdoors, storm water runoff may carry pollutants into
separate storm water drainage systems.

Summary
The following check list summarizes the necessary actions for
acquiring accurate mapping data.

     Data Collection
          Make a listing of all available maps and schematics
          Note the dates when such maps and schematics were
          printed
          Obtain, if possible, older versions of the maps and
          schematics and determine if changes have occurred
          Note what changes were made
                                39

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                              Figure 2
          STORM AND  SANITARY  SETTERS  DIAGRAM

QDQ  DDO
.URFACE
RUNOFF
    FROU
    RAJNFALt
    SHOY.V.EU
    STREET
    WASH WATERS
                    g'00TIN'S DRAiKS  ~~\
                                                 CATCH BASINS

                                            WANKOLE
                                      MUNICIPAL
                                      STORM SEV.-tR
                                                     MUNICIPAL
                                                     INTERCEPTOR SEWER
                                                     TO WASTIWATCR
                                                     TREATMENT PLANT
                       •
                                         STORM SEWtR OUTFALL
                                         DISCHARGE INTO
                                         RECEIVING WATERS

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     Plant Layout Drawings
          List all major processes and equipment at the facility
          from the most recent maps (schematics)
          Identify and label all indoor and outdoor material
          storage areas
          Note and label all floor drains within the facility

     Sewer Maps
          Distinguish between sanitary and storm sewers
          Identify all manhole locations and label accordingly

Spill History

Spill history records should be examined in order to determine
the nature of. materials which have been spilled as well as the
frequency of occurrence of any spills.  Typical sources of
industrial spills were listed in the previous section.  Drainage
patterns of areas where spills can occur should be evaluated.
The specific process or area in which the spill occurred should
be investigated in greater detail.

A facility may have developed a spill contingency plan, which may
provide details regarding the spill potential at a facility.  If
a plan is not available, the necessary information will have to
be determined from facility records and industry personnel.

If an industry has previously experienced a spill which resulted
in the discharge of unacceptable material to a separate storm
sewer, information should be gathered so that the corrective
actions taken to eliminate contaimination associated with these
spills can be evaluated.

The following check list summarizes the actions for acquiring
accurate spill history data.

          Obtain spill history records and prevention plan
          Evaluate the potential  of spills in process and storage
          area(s)
          Determine frequency and nature of past  spills
                                41

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          Note volumes and type of materials spilled
          Note the recorded cause of any spills
          Note corrective actions taken
STEP 2 - PRELIMINARY EVALUATION OF WATER USE AND OTHER DISCHARGES
The purpose of this step is to evaluate the water usage and other
discharges at the industrial facility under consideration.  This
information can serve as a useful aid in determining the probable
source of an illicit connection.

Typical sources of industrial water use were listed in the
previous section.  These processes, as well as any other water-
consuming operations, should be identified for the industrial
site.  Facilities may also use a wide array of solvents, oils,
and other liquids for various applications in manufacturing.
Processes utilizing these substances should be determined as
well.

A preliminary step in listing these processes is the examination
of all discharge permits.  These permits generally provide
information on the characteristics and quantities of all
discharges allowed to surface waters or in some cases to sanitary
sewer collection systems.  Other discharges of non-storm water
not requiring a discharge permit may be identified through
inquiry with industry personnel and/or from an evaluation of
plant operations.

The following check  list summarizes the data which should be
gathered during this step.

          List which processes  use water and which use  other
          liquids.
          Note any distinctive  physical or  chemical
          characteristics  of  the  other  liquids used.
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          Note the potential for contamination associated with
          water use at the facility.
          Note the flow pattern of any unconfined discharges
          (e.g. cleaning, rinse and wash waters,  etc.)  and
          potential spills.
          Note the point of discharge as either connecting to the
sanitary sewer, storm sewer, or as an unknown connection.

STEP 3 - ON-SITE INVESTIGATION

The previous steps described the collection and evaluation of
available data and information at a given facility.  It was noted
that availabl'e information may not reflect existing conditions at
a site.  Therefore, the purpose of the third step is to:

          Confirm, modify and update available information
          Identify processes or areas that exhibit the potential
for illicit connections

The on-site investigation procedure should add to the already
existing information.  For example, not all manholes may have
been indicated on the sewer maps.  Therefore, the actual on-site
investigation may result in the identification of additional
manholes.

The success of the on-site investigation depends upon careful
visual inspections of both indoor and outdoor areas of the
facility.

Outdoor Inspection
Depending upon the size  of the  facility, the  outdoor inspection
may be conducted by  walking and/or driving.   The specific
objectives  of  the inspection  are  to  locate all:
          Manholes
          Catch  basins
          Storm  water runoff  directions and  inlets
          Material storage areas

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In addition, the general condition of the site grounds should be
observed.   These observations should focus on:
          Cleanliness of loading and unloading areas
          Spill control of outdoor material storage areas
          The nature and condition of waste storage facilities at
          the site
          The potential for contact of outdoor material storage
          with storm water runoff

Indoor Inspection

The indoor inspection should be conducted in a similar fashion to
the outdoor inspection  (i.e., careful visual observation).  This
step of the procedure can be expediently executed by using a list
(as determined in Step 2) of manufacturing processes, equipment
locations, and on-site storage facilities.  The investigative
team should query the plant personnel on the following issues:


     Processes and Equipment

          Record name and brief description
          Identify nature of chemicals used
          Determine the nature of discharges  (continuous,
          intermittent, or batch)
          Identify if the process wastes are regulated for
          discharge

     Floor  Drains/Other Discharge Points for the Process

          Identify the  point of discharge for the process
          Locate nearest floor drain
          Identify the  catch basin
          Determine the sump pump location

     Inside Storage Locations

          Determine all storage areas
          Identify  if  spill  control measures  are  in place

At the conclusion of the  indoor  inspection, all existing
information should  be  updated.   Processes  or  equipment whose
                                44

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discharge points are not known should be considered suspect
(i.e., exhibiting illicit connections).  Material storage areas
that show any physical evidence of spills (e.g., powder, stains,
or discoloratiorls) should also be considered suspect.  Additional
guidance regarding typical sources of wastestream flows within
various facilities as classified by SIC codes is provided in
Appendix A of this manual.

By using the updated information from both the indoor and outdoor
inspections, it is now possible to conduct the confirmatory
analysis.
STEP 4 - CONFIRMATORY ANALYSIS

Upon conclusion of the on-site investigation, one or several
sources from the industrial facility may appear to be the cause
of an illicit discharge.  The purpose of the fourth step is to
determine the actual location of the illicit connection to the
storm water drainage system.

This step of the procedure involves implementation of
investigative strategies to pinpoint the source of the
contaminated discharge.  The confirmatory analysis begins with
examination for dry weather storm sewer discharges from the
industrial facility.  This is followed by pipeline examination to
verify the location of the illicit connection.
Dry Weather Discharge Examination

The examination for dry weather discharges to the storm sewerage
system fulfills the following two objectives:

          Verification that the discharge from the particular
          industrial site under investigation is the same one as
          originally detected at the storm water outfall.
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          Indication of the industrial source of the illicit
          discharge by virtue of relative site location as well
          as by discharge composition.
Procedure
This procedure involves determining outfall locations or the
junction points at which a storm water sewer line from the
facility connects to a municipal separate storm sewer line.
Direct access to these junction points may be possible as
manholes are often placed prior to private-municipal separate
storm sewer line connections.

Observation for dry weather discharges from the facility entails
either direct observation of an outfall or physically removing
manhole covers at the selected locations and visually inspecting
for the presence of flow.  Proper precautions should be taken to
ensure worker safety.

Tming of the observations is a crucial factor. Observations
should take place at those times when various sources of non-
storm water are being used at the facility and flows from  illicit
connections may be occurring.  How much earlier the inspection
should take place is dependent upon the distance from the  sewer
line connection to the contaminated storm sewer outfall.   In
general, the farther apart these two locations are, the earlier
the manhole inspection time  should take place from the time of
the recorded outfall discharge detection.

If a dry weather  discharge is detected during a manhole
observation, the  flow should be characterized in the same  manner
as was discussed  in  Section  3.

The  following  physical  and chemical properties of the dry  weather
discharge  should  be  observed and  recorded:
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     Physical Properties
          Odor
          Color
          Temperature
          Turbidity
          Floatables
          Residue

     Chemical Properties
          pH
          Total Dissolved Solids
          Specific Conductivity

Grab samples of the dry weather discharge can be taken to a
laboratory for detailed chemical analysis.   This analysis should
focus upon chemicals known to be used at the industry.  Guidance
regarding typical conventional and toxic pollutant concentrations
is provided as part of the industrial wastestream
characterization classified by SIC codes in Appendix A of this
manual.  Additional information regarding chemical parameters,
which should be tested for, may also be obtained through
reference to NPDES discharge limitations or consultation with
industry personnel.

It should be noted, however, that the detected dry weather
discharge may be a permitted discharge  (such as non-contact
cooling water) from the industrial facility to the storm sewerage
system.  This case may be confirmed by checking if a discharge
permit exists for that particular sewer line connection, as well
as from the chemical composition and physical nautre of the flow.

If the observed dry weather discharge is determined as being  non-
permitted and/or contaminated, the results of the recorded
analysis should be compared against potential sources of non-
storm water at the facility.

comparisons should seek to  find common  pollutant characteristics

                                47

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between the observed dry weather discharges, and potential non-
storm water sources at suspect industrial processes or spill
areas.

If waste flows can be established as essentially identical, then
it may be assumed that the industrial source responsible for the
detected illicit discharge has been identified.

In some cases, more than one dry weather discharge may be
observed at various manholes.  It is possible that more than one
illicit connection to the storm water drainage system may exist
within the industrial facility and that the contaminated outfall
discharge is the result of a culmination of several flows.
Therefore, all suspect industrial sources of observed manhole
discharges should be identified before proceeding on to the
pipeline examination.
Summary
          Locate  industrial-municipal sewer line connections
          Select  manhole observation points
          Determine the presence of dry weather discharges
          Characterize observed dry weather discharges
          Determine if discharge is permitted or contaminated
          If  discharge is not permitted, conduct a comparison of
          characteristics to identify the industrial source
          Identify all industrial sources of all dry weather
          discharges  observed
 Pipeline  Examination

 The major objective of the pipeline examination is  to identify
 the specific point at which the illicit connection  exists.
 Illicit connections may result from failing plumbing fixtures,
 direct connections, or in many cases inadvertent connections.
 The pipeline examination also serves to verify the  industrial
 source responsible for an observed discharge.
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Inadvertent connections result when a storm sewer is mistaken for
a sanitary sewer.  In some cases, illicit connections were
actually permitted at the time they were built.  Regardless of
the reason behind an illicit connection, a number of procedures
have proven to be successful in identifying their actual
locations.  The main objective of these procedures is to trace
the path taken by a discharge from a process to a downstream
point.  Two procedures recommended for use are:
          Dye tracer tests
          Internal pipe investigations
               Manual visual inspections
               Television (TV) inspections

Dye Tracer Tests

Dye tracer tests involve the introduction of a fluorescent dye
such as fluorescein into the discharge point of the industrial or
commercial process suspected of exhibiting illicit connections.
The discharge points for all processes were determined during the
indoor investigation of the facility.

The dye, once introduced, is flushed down with clear water.
Various observation points are then observed.  If the fluorescent
dye comes through, then an illicit connection has been
identified.  In most cases, illicit connections can be identified
by conducting dye tracer studies.  However, situations may arise
in which the dye tracing process fails to identify illicit
connections.  This may be the case when there  is a break or crack
in an adjacent sanitary sewer.   In such cases, an internal
investigation of the sewer lines may be necessary.
 Internal  Pipe  Investigations
 When  sewer  systems  are large  enough,  they  should  be  inspected by

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walking through them in order to locate the entry points of
polluted discharges.  In such cases, appropriate safety
precautions as described under the OSHA confined space entry
requirements should be employed.

The use of TV inspections is relatively expensive.  This is an
alternative to manual inspections and may be used when sewers are
smaller or for safety reasons.
                                50

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     Section 7

     FIELD SURVEY TECHNIQUES
The objective of this section is to provide detailed information
regarding the field survey techniques discussed in previous
sections of this manual.  The relative success of this
methodology for identifying illicit industrial connections relies
heavily upon careful field organization.  Topics are addressed in
the following order:

          Necessary Equipment and Materials
          Personnel Requirements
          Estimated Timeline
          Organizational Ideas

NECESSARY EQUIPMENT AND MATERIALS
Necessary equipment and materials must be gathered prior to
conducting the field survey.  A list of essential equipment and
materials for both the outfall screening and the on-site
investigation is provided in Table 3 and discussed below.
Field Test Kit
Elementary chemical analysis can be performed with a field test
kit.  These kits  can be used to provide estimates of
concentrations  of varous parameters in flow samples.   There  are
several brands  of kits with features  suited to the needs  of  this
manual.   Information regarding typical field test kits is
presented in Appendix B.  The data provided includes the
manufacturer, model number, general capabilities, and  cost.
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pH and Conductivity Meters

The pH meter and conductivity meter are also used to determine
initial values for discharges detected at storm water outfalls
and during manhole observations.   Highly sophisticated models are
generally not be necessary.   Rather, a moderately priced meter
can be selected.  Buffer solutions are also essential and should
always be brought along to calibrate the meters prior to taking
readings.  Information regarding typical pH and conductivity
meters is presented in Appendix B.  The data provided include the
manufacturer, model number,  general capabilities, and cost.
Automatic Sampler

An automatic sampler can be used at the storm water outfall to
detect flows, collect samples, and determine flow patterns.  The
use of an automatic sampler eliminates the need for inspectors to
constantly observe a sampling point for intermittent discharges
at sampling locations exhibiting characteristics of industrial
contamination.  There are many brands of automatic samplers
available with a diversity of characteristics.  Table 4 presents
a list of considerations for an automatic sampler suitable to the
needs outlined in this manual.  Additional information regarding
typical automatic samplers is presented in Appendix B.  The data
provided include the manufacturer, model number, general
capabilities, and cost.
 Instant Camera and Film

 An  instant  camera should be used to photograph  all  locations
 exhibiting  signs of contamination by potential  illicit
 connections.  This photo will  serve as a visual aid for each
 location  and  also supplement the written documentation of the
 observed  pollutant characteristics.  Photographs may also be
 taken  during  the on-site  investigation to  log various suspect
                                52

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processes or potential spill areas.  This may be especially
helpful for large facilities with extensive manufacturing
operations.

It is important to note that most facilities have strict policies
concerning photographs taken by visitors.  The inspector should
always ask the plant manager about the plant's policy before
carrying a camera into a manufacturing area.  The inspector might
need to obtain special permission or agree to have all
photographs reviewed by the plant manager.

The instant camera selected for use should produce color
photographs.  A one-step model is generally the easiest to use as
no waste paper is produced from the photographing.
Collecting Samples

Samples of discharges are collected at storm water outfalls, from
manholes, and occasionally from industrial processes.  Plastic
bottles are preferred for a container since they will not break
and are easily labeled.  A waterproof marker should be used to
label each sample immediately after it has been collected.
Identification data should always include the date, time of day,
inspector name, sample number, and the location from which the
sample was taken.  Once labeled, all samples should be tightly
sealed and packed in ice.
Recordkeepinq

Recordkeeping materials include a clipboard, pad of  paper,  and
pen or pencil.  Data Inventory Forms on which to summarize
pertinent  information  should also be used to simplify
documentation during field  surveys.  Typical forms are discussed
      the  topic of  organizational ideas at  the  end of this

                                53

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section.  In addition, any maps or plant layout drawings should
be kept with the recordkeeping material.  Maps and drawings
brought along should be of manageable size,  if possible, 8-1/2 by
11 inches.  Finally, it is highly suggested that all
documentation be organized into a three-ring binder.  This will
keep information readily available and ensure that little
potential exists for losing or misplacing important data.

Outfall Identification

All contaminated and newly discovered storm water outfalls should
be physically labeled with an identification number, in order to
prevent confusion or mix-ups during additional field surveys.
Visible outfall id numbers will also reduce unnecessary
referencing to maps and thus save time as well.  Outfall marking
can be accomplished with wooden stakes.  The stakes should be
spray painted a fluorescent color with the id number of the
outfall carefully marked in black.  A thick waterproof marker
should be used for stake labeling.  Each stake should be placed
next to its corresponding storm water outfall in an area away
from trees or shrubbery for easy visibility.  A hammer may be
necessary to pound the stakes into the ground as it may be quite
hard due to the fact that analysis is conducted during dry
weather.
Manhole Observation Equipment
Manhole observation for  illicit discharges requires several kinds
of equipment.   A crowbar will be necessary in order to remove the
manhole lid.   Also, a  bright flashlight will be helpful  for
visual inspection inside of the manhole.

If dry weather flows are detected  inside  of a manhole but  entry
to obtain a sample is  impossible or unsafe, an alternative
sampling  procedure must  be employed.   If  the manhole  is  not too

                                54

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deep, one method of obtaining a sample is to tape the sampling
bottle to a long stick which can reach the discharge.  A fold-up
tape measure is a compact way of carrying a long stick.  Heavy
duty tape should also be used to ensure that the sampling bottle
remains affixed.

Finally, if the manholes are located along a roadway or street,
precautionary measures should be taken to protect the inspectors
and minimize traffic disruption.  Orange safety cones and/or a
flashing barricade should be used to segregate the necessary
working area.  Also, all inspectors should wear orange safety
vests.

Pipeline Examination
Fluorescein dye tracer may be needed to conduct pipeline
examinations.  Ample dye should be brought along as several tests
may be necessary.
Inspector Safety

Attention to safety procedures is a must during all field
surveys.  This  includes inspector apparel from head to toe.  Work
clothes should  always be worn for all inspections.  Rubber boots
should be brought along in case of wet or muddy conditions during
the screening of storm water outfalls.  Essential materials  for
the industrial  on-site investigation include  safety shoes, safety
glasses, a  hard hat, and hearing protection.  Protective gloves
should always be worn when collecting samples of any  potentially
dangerous discharges.  Finally, a complete  first aid  kit should
always be kept  on hand in case of an emergency.
                                55

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     TABLE 3
     FIELD EQUIPMENT AND MATERIALS
Field Test Kit
pH Meter and Buffer Solution
Conductivity Meter and Buffer Solution
Batteries
Automatic Sampler
Instant Camera and Film
Sampling Bottles and Waterproof Marker
Tracer
Cooler
Clipboard, Pad, Pen or Pencil
Data Inventory Forms
Maps
Marked Stakes
Hammer
Flashing Barricade
Orange Safety Cones
Orange Safety Vest
Crowbar
Flashlight and

Fold-Up Tape Measure
Heavy Duty Tape
Fluorescein Dye

Work Clothes
Rubber Boots
Safety Shoes
Safety Glasses
Hard Hats
Hearing Protection
Protective Gloves
First Aid Kit
                                56

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TABLE 4

CONSIDERATIONS FOR AUTOMATIC SAMPLER
Capability for AC/DC operation with adequate dry battery
energy storage for 120-hour operation at l-hour sampling
intervals

Total weight including batteries

Sample collection interval (adjustability from 10 minutes to
4 hours)

Capability for time proportional sample - constant sample
volume, time interval between samples proportional to stream
flow

Capability for collecting discrete samples in 24 containers

Watertight exterior case to protect components in the event
of rain or submersion

Exterior case capable of being locked to prevent tampering
and provide security

No metal parts in contact with waste source or samples

An integral sample container compartment capable of
maintaining samples at 4 to 6°C for a period of 24 hours at
ambient temperatures ranging from -30 to 50°c

Operation capabilities in the temperature range from -30 to
50°C

Sampler exterior surface painted light color to reflect
sunlight
                           57

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PERSONNEL REQUIREMENTS

The objective of the following discussion is to provide general
information regarding the personnel demand and training necessary
to perform the methodology outlined in this manual.

Clearly, as the size of the industrial area to be investigated
increases, so too does the demand for personnel.  The following
suggestions are based upon an optimum fixed number of inspectors
per phase of the field survey.  These suggestions were offered in
order to set a standard as well as to simplify the overall
procedure.
Phase I - Screening of Storm Water Outfalls

It is suggested that a minimum of two (2) investigators perform
the observations and analyses at a storm water outfall.  There
are several reasons behind this selected minimum among which the
most important are the following:

          Correspondence regarding visual observations and
          elementary chemical analyses
          Safety in numbers
          Load distribution for carried equipment

Thus, a coupled effort will result in greater efficiency as well
as mobility.  When very large numbers of storm water outfalls
exist for screening in an industrial area, it is suggested that
several pairs of investigators perform outfall surveys in order
to expedite the process.
Phase II - Industrial On-site Investigation
In order to perform the industrial on-site investigation, it  is
suggested that either three investigators be aided by one
industry personnel or two  investigators be aided by two  industry

                                58

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personnel.  The reasoning behind a total number of four being
such that the on-site investigation may be divided into two
tasks.  Thus, one pair of investigators may perform the outside
inspection while the other pair focuses their attention upon the
inside inspection.
The selected industry personnel should have a thorough knowledge
of the operations performed at the facility.  In addition, it is
beneficial if they also have a practical understanding of
environmental management procedures as well.
Personnel Training

In addition to efficiency, the inspectors performing a field
survey must also be accurate.  High levels of accuracy may only
be obtained through complete and proper training.  Training
should encompass a formal orientation of the methodology
presented in this manual along with practical field techniques.

Therefore, inspectors should have an understanding of the various
identification strategies presented in this text.  They should
also be knowledgeable of typical kinds and sources of industrial
uaste.  If possible, training should include an actual field
orientation of common industrial water use processes and types of
spills.  Factual information should also be provided summarizing
the contacts and access details necessary for obtaining pertinent
data such as sewer maps or environmental records.

Inspectors must be able to correctly operate all field equipment
- in particular specialized meters and automatic samplers.
Training should include the proper procedures for collecting
samples as well as for performing manhole observations.  Finally,
steps must always be taken to make personnel aware of potential
occupational hazards, precautionary measures to prevent them, and
special plans to follow in the event of an emergency.
                                59

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TIMELINE

There are several steps to be performed when following the
methodology outlined in this manual.  The following chart is
intended to provide a generalized indication of the time required
for each step.


It is important to note that the chart provided does not take
into account unexpected problems such as poor weather or
equipment failure.  In addition, the time needed to conduct the
on-site industrial investigation and confirmatory analysis is
highly dependent upon the size of the facility.  Thus, these
estimates should be considered only as idealized guidelines.
Procedure and StepTime Range  fdavs^

Outfall Evaluation

Step 1 - Mapping Effortl-3
Step 2 - Walking Tour2 outfalls surveyed/day*
Step 3 - Outfall Analysis2 outfalls analyzed/day

Identification of Potential Industrial Sources

Step 1 - Establish Flow Patterns-?
Step 2 - Analysis of Recorded Datal-3
Step 3 - Correlation to Possible Industrial Sourcesl-3

On-Site Industrial Investigation

Step 1 - Data Collection2-4
Step 2 - Preliminary Evaluation of Water  Use  and2-4
other Discharges
Step 3 - On-Site  Investigations-?
Step 4 - Confirmatory  Analysis3-7
 *NOTE:
 Inspectors should be able to complete the initial survey and
 analysis for two outfalls per day.

                                60

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ORGANIZATIONAL IDEAS

The use of Data Inventory Forms can greatly simplify the process
of recording information.  A variety of Data Inventory Forms are
provided in Appendix C of this manual.  Thus, the objective of
the following discussion is to briefly describe the function for
each form.
outfall Analysis Data

This three-page form should be used to record data collected from
the screening of storm water outfalls.  The form organizes
information regarding the detected flow pattern, physical
observations, and elementary chemical analysis results for a
particular outfall.
Laboratory Analysis

This two-page form should be used to check off the parameters
which should be tested for in a grab sample laboratory analysis,
The form summarizes the grab sample identification details,
laboratory information, and provides a listing for conventional
as well as toxic pollutants.  The toxic pollutants were
determined according to the listing provided originally in the
Clean Water Act.
Process Data:  Direct Discharge

This form summarizes information regarding industrial processes
which directly discharge into a receiving water body.  Data
regarding a particular industrial process as well as any permit
details are to be recorded on this form.
                                61

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Process Data:  Indirect Discharge

This form summarizes information regarding industrial processes
which discharge to the local POTW for treatment before entrance
to a receiving water body.  The information recorded includes
details of the particular industrial process and any pretreatment
for it discharges as well as general data for the local POTW.
Spill History

This form should be used to record information regarding any past
spills which occurred at an industrial facility.
Spill Potential
This form should be used to summarize information regarding
industrial processes which have spill potential.
Facility Runoff

This form should be used during the outside portion of the
industrial on-site investigation.  The form summarizes potential
sources of pollutants associated with storm water runoff.
Correlation of Data

This form should be used during the correlation process to
determine similarities between the detected illicit discharge and
suspect industrial process discharges.  Comparisons are drawn
based upon the wastestream characterization of discharges from
the contaminated outfall, manhole observations, and suspect
industrial process discharges.
                                62

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     Section 8

     SUMMARY
This manual has outlined a procedure which begins with the
screening of stormwater outfalls for signs of contamination from
sources of non-storm water.  The methodology then proceeds to the
identification of likely sources for the detected non-stormwater
discharge.  Then, procedures to pinpoint the location of the
industrial illicit connection are discussed.  This manual
concludes with a section focusing upon field survey techniques as
the success of this methodology depends largely upon the careful
collection and analysis of site information.

The strategy underlying this methodology involves correlating the
characteristics of discharges observed at outfalls and that of
various sources of non-storm water, such as industrial
manufacturing or operational process discharges.

By applying common sense and professional judgement to the
procedures outlined in this manual, successful evaluation of a
facility's separate storm sewer for the presence of non-storm
water discharges can be accomplished.
                                63

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               APPENDIX A
         WASTE CHARACTERIZATION
10123

-------
WASTE CHARACTERIZATION

The objective of the following section is to provide a general survey of information
regarding wastestream identification and characterization for various facilities listed
under industrial SIC categories. Listings of the subcategories falling under each
industrial SIC category will be followed by potential sources of wastestream flows. In
addition,  a characterization  of the potential wastewaters discharged from each of the
defined subcategories will be presented.  This characterization will define typical values
for chemical and physical parameters as determined  from  laboratory wastestream
analysis.

Some of the subcategories for listed classifications have been eliminated due to their
insignificance in the industry.  In  addition, the parameters defined for the wastestream
characterization vary according to the data available for a particular industrial category.
Thus, the tables presented in this appendix list various  combinations of conventional,
toxic, and non-toxic pollutants.  The values  presented in each table may be typical
wastestream concentrations or ranges of concentrations.  In either case, these tables
should provide the user of this manual with guidelines as to the  types and general
concentrations of pollutants likely to be identified for a specific industrial subcategory.

It  is also  important to note that  each wastestream characterization presents values
taken from  raw wastewaters  prior to discharge into a  sewerage system.  Thus, the
concentrations  actually detected  at a storm sewer outfall are  likely to be lower due to
possible dilution from storm water or other wastewaters.

The source  referenced to for all detailed information and tables provided in this section
was Volume II of the 1980 USEPA Treatability Manual.
 10123MAP

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INDUSTRIAL LAUNDRIES

Facilities belonging to this category are Jinked by the fact that they provide cleaning
services for their clients. The main subcategories falling under industrial laundries
are as follows:

Subcateaories

       - Industrial Laundries
       - Unen Laundries
       • Power Laundries
       - Coin-Operated Laundries
       - Dry Cleaning Plants
       • Car Washes
Sources of Wastestream Rows

The four basic process divisions in the industrial laundries category include water wash,
dry cleaning, dual-phase processing, and car wash processes.  Typical sources of
wastestream flows for industrial laundries will be generated from the operations
involved for these processes.

Facilities utilizing  a water wash first sort soiled materials.  Stains which may set are
removed which  generally involves the use of acids,  bleaches, and/or various organic
solvents.  Wetting, sudsing with detergents, and rinsing of the materials then takes
place to clean the fabric.

Primary cleaning for dry cleaning processes is accomplished through the use of an
organic-based solvent along with detergent and a controlled amount of water. Solvents
are generally filtered and recovered for further use.

In dual-phase processing, the water-detergent  wash is followed by a separate solvent
wash.  This is used almost exclusively  to clean items that contain large amounts of
water-soluble soils as well as oil and grease, such as for work shirts and wiping rags.
 10123MAP

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Car washes are considered a variation of the water wash process.  Facilities are
designed for either automatic or self-service washing  of vehicles.  Operational
processes generally include washing with various detergents, waxing, rinsing, and
drying.

Wastestream Characterization

The chemical and physical characteristics of laundry wastewaters are influenced by
three primary factors:  the type of cleansing process utilized, the types and quantities of
soil present, and the composition  of the various chemical  additives used in the
process. Wastestream flows deriving from water wash operations may contain all of
the soil removed from  the  materials as well as  the chemical cleaning agents or
detergents added to facilitate the laundering  process.  While wastestream flows  from
dry cleaning processes tend to contain removed soils along with appreciable quantities
of organic-based solvent.  The primary wastes present in car wash wastewater are
suspended  and dissolved solids, oil and grease, lead, and zinc.

An important factor to keep in mind when investigating  facilities falling under this
category is  that the sources of wastes may originate from the cleaning processes as
well as from the materials being cleaned.  This in turn increases the potential number of
pollutants to be found in wastestream flows from industrial laundries and car washes.

Table 1 presents  subcategory wastewater descriptions for conventional and  toxic
pollutants found in this industry.
 10123MAP

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                                  TABLE 1

                 WASTEWATER CHARACTERIZATION OF
                      AUTO AND OTHER LAUNDRIES
Pollutant
  (mg/l)

BOD5
COD
TOC
TSS
Total Phosphorus
Total Phenols
Oil and Grease
pH, pH Units
                      Industrial
                      Laundries
              Linen
            Laundries
                  Number
                  Analyzed
Mean
Number
Analyzed
Mean
                          Power
                        Laundries
Number
Analyzed
Mean
51
60
24
69
12
19
66
62
1,300
5,000
1,400
1,000
12.2
0.32
1,100
10.4
50
26
28
59
5
7
52
58
620
1,600
400
400
18.7
0.12
330
10.1
8
11
4
11
6
5
9
14
340
660
150
220
7.3
0.31
110
9.4
Toxic Pollutant
    (mg/I)

Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Cyanide
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
22
24
14
36
35
36
28
36
24
36
16
26

36
240
77
<1
88
880
1,700
140
4,500
2
290
8
26

3.000
7
7

36
36
15
7
36
36
36
7
7
7
37
10
7

9
100
520
33
460
3
61
2
8
5
900
6
6

5
7
7
5
7
8
7

7

6
160
<15

11
76
160
<28
110
0.7
14

<7

37
 10123TBL

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Pollutant
  (mg/l)
                               TABLE 1 (cont.)

                 WASTEWATER CHARACTERIZATION OF
                     AUTO AND OTHER LAUNDRIES
Coin-Operated Dry Cleaning
Laundries Plants Car Washes
Number
Analyzed
Number
Mean Analyzed
Number
Meari Analyzed
Mean
BOD5
COD
TOC
TSS
Total Phosphorus
Total Phenols
Oil and Grease
pH, pH Units
31
18
1
28
2
3
13
29
140
340
—
140
9.8
0.10
26
7.9
1
1
1
1
1
2
1
1
                  < 0.003
45
NA
NA
45
NA
6
45
7
58
...
...
270
...
< 0.006
26
7.1
Toxic Pollutant
   (mg/l)

Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Cyanide
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
3
3
3
3
3
3
3
10
<10
8
<5
67
36
1
           2

           2
25

20
310
7
7
7
7
7
7
45C
7
7
7
7
7
45C
7,9
230
<5
17
34
340
890
<1
260
<5
<5
<2
750
 10123TBL

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ELECTROPLATING

Facilities which belong to the electroplating category are those that apply a metallic
surface coating to a second material.  This  is generally done by electrodeposition but
may also be accomplished through various coating processes or through electroless
plating.  The main subcategories falling under electroplating are as follows:

Subcateoories
       - Common  Metals Plating
       - Precious Metals Plating
       - Anodizing
       - Coating
       - Chemical  Milling and Etching
       - Electroless Plating
       - Printed Circuit Board Manufacture

Sources of Wastestream Flows

The three  basic process divisions in electroplating  include:  surface preparation,
plating, and posttreatment. These steps are common  to all subcategories and are the
sources from which wastewater flows will be generated.

Surface preparation of the basic material is necessary to ensure that the exterior is
cleaned and descaled prior to plating.  Cleaning removes oil, grease, and any other dirt
which may interfere in the plating of the material.  Several cleaning methods can be
used for this step including solvent, alkaline, acid, emulsion with organic solvents, and
salt bath descaling.

In the plating  step, a surface coating is applied to a  material for either functional or
decorative purposes. The type of electroplating done at facilities can vary greatly in
size as well as character.  However, all tend to rely upon appreciable use of various
acid and alkaline solutions.  In addition, large quantities of rinse water are also gener-
ated often  containing these solutions in a diluted form.

Posttreatment after the initial plating of a material is completed in order to provide an
additional coating. This extra coating is  applied for a variety of reasons such as
 corrosion  protection or  to prepare the surface for  painting.  Posttreatment processes
 include chromating, phosphating, and conversion coating operations.
 10123MAP

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Wastestream Characterization

Wastewater from electroplating processes is typically due to the processing and
finishing solutions generated from  alkaline and acid cleaning operations,  plating
processes, and posttreatment.  While the quantities  of wastewater generated are not
excessive, they tend to be very strong in nature.  Untreated wastestreams may contain
appreciable amounts of acids, detergents, solvents, and metals in significant quantities.

Predominant wastewater constituents for the electroplating industry include various
chemical cleaners and plating solutions as well as the following metals: copper, nickel,
chromium, zinc, lead, tin, cadmium, gold, silver, and platinum.

Table 2 presents raw discharge pollutant concentration ranges for the subcategories of
the electroplating industry.
 10123MAP

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                                         TABLE 2
                           POLLUTANT CONCENTRATION RANGES
                             FOR THE SUBCATEFORIES OF THE
                                ELECTROPLATING INDUSTRY
                                            Concentration Range
Common
Metals
Platino
Precious
Metals
Ptatinq


Electroless Anodizina
Pollutant
Parameter

Conventional Pollutants, mo/1

TSS                    0.1 • 10,000

Toxic Inorganic Pollutants. mo/1
Cadmium
Chromium, Total
Chromium, VI
Copper
Cyanide, Total
Cyanide, A
Lead
Nickel
Silver
Zinc
7 - 21,6,000
88 - 530,000
5 - 330,000
32 - 270,000
5-15,000
3-130,000
660 - 25,000
19-3,000,000

110-250,000
                  0.1 - 10,000
50-180,000
                0.1 -39.0
                 28 - 47,000
                  36.0 - 920



5-10,000
3 - 8,400


2 - 48,000
5-12,000
5 - 1 ,000
270 - 79,000
5 - 5,000

5 - 78,000
4 - 68,000
Non-Toxic Pollutants, mg/i

Fluoride
Gold
Iron
Palladium
Phosphorus
Platinum
Rhodium3
Tin
22-140,000

250-1,500,000

20-140,000


60- 100,000
13-25,000

27 - 630
20- 140,000
110-6,500
34
110- 18,000



30- 109,000


60 - 90,000
180-33,000
 10123TB2

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                                       TABLE 2 (cont.)
Pollutant
Parameter

Conventional Pollutants. mg/J

TSS
                                Coating
19.0-5,300
                                                 Concentration Range
                       Chemical
                       Milling &
                        Etching
0.1 -4,300
                        Printed
                        Circuit
                       _Boafds
1.0-610
Toxic Inorganic Pollutants, mg/l

Cadmium
Chromium, Total
Chromium, VI
Copper
Cyanide, Total
Cyanide, A
Lead
Nickel
Silver
Zinc
190-79,000
5 - 5,000

5-130,000
4 - 68,000



88 - 530,000
5 - 330,000
210-270,000
5-130,000
5-100,000



5 - 48,000
5 - 4,400
200 - 540,000
5-11 ,000
5-9,400
10-10,000
27- 13,000
1 -480
140-200
110-200,000
Non-Toxic Pollutants. mg7l

Fluoride
Gold
Iron
Palladium
Phosphorus
Platinum
Rhodium3
Tin
410- 170,000

60 - 53,000


100-6,600
22-140,000

75 • 260,000

60-140,000


340 - 6,600
2BO - 660,000
6-110

5-230
51 -54,000
60-54,000
 NOTE: Blanks indicate data not available.

 a  Only one plant had a measurable level of this pollutant.
 10123TB2

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INORGANIC CHEMICALS MANUFACTURING

Facilities belonging to this category are those which produce alkalies and chlorine,
industrial gases, inorganic pigments, and those producing other inorganic chemicals.
The main subcategories falling under inorganic chemicals manufacture are as follows:

Subcategories

      - Aluminum- Fluoride
      - Chlor-Alkali {Mercury Cell and Metal Anode)
      - Chrome Pigments
      - Copper Sulfate
      - Hydrofluoric Acid
      - Hydrogen Cyanide
      - Nickel Sulfate
      - Sodium Bisulfate
      - Sodium Dichromate
      - Sodium Hydrosuifite
      - Titanium Dioxide (Chloride and Sulfate)

Sources of Wastestream Flows

The sources of wastestream flows for  the inorganic chemicals industry can vary
considerably.  Each subcategory will have unique waste sources which would not be
found in another type of inorganics facility.  Descriptions of all these sources is beyond
the scope of this manual.  However, there are several wastestream flows which have a
potential for being common to all of these subcategories. The following is a listing of
typical wastestream sources:

      • Noncontact Cooling Water
      - Rinse Water
      - Roor and Equipment Washings
      - Scrubber Wastewater
      - Spent Chemical Solutions and Solvents
      • Condenser Drainage
      - Boiler Slowdown
 10123MAP

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Wastestream Characterization

The pollutants which may be found in ihe wastewaters from the inorganic chemicals
industry also  vary widely for each of the subcategories listed.  Toxic pollutants are
generally metals. In addition, the concentrations of the wastewater flows may vary from
insignificant  to appreciable concentrations.   Table 3 presents  the  maximum
concentration of each toxic pollutant found in each  subcategory for the inorganic
chemicals industry.
 10123MAP

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                               TABLE 3
             MAXIMUM RAW WASTEWATER CONCENTRATIONS
                    OF TOXIC POLLUTANTS FOUND AT
                 SAMPLED INORGANIC CHEMICAL PLANTS
Toxic Pollutant
   (ug/i)
                                      Chlor-Alkali
                Aluminum
                 Fluoride
Mercury Cell
Metal Anode
Chrome
Pigments
Antimony
Arsenic
Asbestos
Beryllium
Cadmium
Chromium
Copper
Cyanide
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
200

0,85
77
120
2
150
110



<200
<10

0,4
7,7
350
1
150
<100

0,6
<250
230
20
10

2
940
525
255
9
54,400

<9
14
24
7,700

79
55,000
7,500
360
36,000
160
<10
7

4,100
                 Copper
                 Sulfate
Toxic Pollutant
    (ug/0
Hydrofluoric
   Acid
Antimony
Arsenic
Asbestos
Beryllium
Cadmium
Chromium
Copper
Cyanide
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
307
3,500


870

1,850,000

175

112,000



1 1 ,000
70
10


2
73
770

5,190
2
150
25

5.5
8,120
Hydrogen
 Cyanide
                                               1,300

                                                166
                                                 25
Nickel
Sulfate
                                    9

                               73,300

                                   55
                                    4
                               175,500
                                 <235

                                   21

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                             TABLE 3 (cont.)
             MAXIMUM RAW WASTEWATER CONCENTRATIONS
                    OF TOXIC POLLUTANTS FOUND AT
                 SAMPLED INORGANIC CHEMICAL PLANTS
                Sodium       Sodium       Sodium        .Titanium Dioxide
                Bisulfate    Dichromate    Hydrosulfite     Chloride    Sulfate
Toxic Pollutant
    (ug/0

Antimony          30                                                20
Arsenic                                                              11
Asbestos
Beryllium
Cadmium            6                       43                      338
Chromium         17     252,000         9,300         15,200     124,000
Copper           375         35         1,450                     1,480
Cyanide                                   101
Lead                8                    1,290          5,150       3,730
Mercury             3                       28
Nickel            250      12,500         1,660          6,230       6,370
Selenium                     <5            34
Silver               2        <0.5           128                       64
Thallium                                                             19
Zinc            2,480        544        27,400          3,110       3.840
NOTE:  Blanks indicate data not available.
 10123TB2

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Tables 5, 6, and 7 summarize conventional and  toxic wastestream characteristics  lor
these subcategories as they represent the largest portion of the leather tanning and
finishing industry.
 10123MAP

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                                TABLES

                  WASTEWATER CHARACTERIZATION OF
                    LEATHER TANNING AND FINISHING
Pollutant

BOD5
COD
TSS
TKN
Total Phenols
Suifides
Oil and Grease
Total Chromium
Ammonia
                     Hair Pulp/Chrome Tan/Retan-Wet Finish Subcateaory
                                            Concentration fmg/l)
Number of
Data Points
205
170
210
58
15
170
75
180
168
Range of
Individual
Data Points
210-4,300
180-27,000
25 - 36,000
90.0 - 630
0.140- 110
0.800 - 200
15-10,000
3.00 - 350
17.0-380
Mean
1,600
4,600
2,400
330
1.0
64
400
76
100
                                            Concentration (mo/fl
Toxic Pollutant
Number of
Data Points
Metals and Inorganics
    Chromium          3
    Copper            3
    Cyanide            2
    Lead              3
    Nickel             3
    Zinc               3
Range of
Individual
Range
                   43,000- 180,000
                      50 • 380
                      20-60
                    1,100-2,400
                      20-60
                     200 - 580
  Mean


80,000
   173
   40
 1,700
   40
   430
 10123TBL

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                               TABLE 6

                  WASTEWATER CHARACTERIZATION OF
                    LEATHER TANNING AND FINISHING
Pollutant

BOD5
COD
TSS
TKN
Total Phenols
Sulfides
Oil and Grease
Total Chromium
Ammonia
                    Hair Save/Chrome Tan/Retan-Wet Finish Subcateoorv
                                            Concentration fmo/0
Number of
Data Points
101
30
82
56
24
70
30
56
31
Range of
Individual
Data-Points
140-2,800
700 - 5,700
94.0 - 8,600
63.0 - 3,600
0.440 - 6,80
0.030 - 300
49.0 - 620
0.006 - 390
0.400 - 660
Mean
980
2,600
1,900
140
2.2
20
240
31
90
Toxic Pollutant
Number of
Data Points
Metals and Inorganics
                                            Concentration (mg/n
  Range of
  Individual
  Data Points
  Mean
    Chromium
    Cyanide
    Lead
    Nickel
    Zinc
     2
     2
     2
     2
     2
31,000-150.000
   20-50
   100-1,300
     5-40
   240 - 400
90,500
   35
  700
   22
   15
 10123TBL

-------
                             TABLE 7

               WASTEWATER CHARACTERIZATION OF
                 LEATHER TANNING AND FINISHING
                     Nonchrome Tan/Re1an-Wet Finish Subcateoory
Pollutant
BOD5
COD
TSS
TKN
Total Phenols
Sulfides
Oil and Grease
Total Chromium
Ammonia
Toxic Pollutant
Number of
Data Points
48
40
55
21
16
29
32
30
20
Number of
Data Points
Concentration
Range of
Individual
Data Points
1.00-7,800
1,100-75,000
28.0 • 8,200
130-1,200
0.280- 100
1.100-330
2.00-1,300
0.250-110
23 - 680
Concentration
Range of
Individual
Data Points
fma/l)
Mean
1,200
5,100
1,700
200
1.2
68
340
11
90
fma/n
Mean
Metals and Inorganics
Chromium
Copper
Cyanide
Lead
Nickel
Zinc
4
4
3
4
4
4
430-10,000
100-740
60 - 100
100-200
40-95
300 - 700
5,100
380
80
140
61
490
10123TBL

-------
                APPENDIX B
             COST ESTIMATES
10123

-------
                     INDIVIDUAL FIELD TEST KITS

TEST
Acidity

Alkalinity

Aluminum
Chloride

Chlorine,
low range
(Free and
Total)

Chlorine,
high range
(Total)


MODEL
AC-6
2223-01
AC-DT
20640-00
AL-AP
1433-01
AL-DT
20637-00
DR 100
41101-01
8-P
1440-01
CD-DT
20635-00
CN-80
21290-00
DR100
41100-02
CN-65
2254-01
CN-DT
0-1000
HACH COMPANY
METHOD/CHEMISTRY
Drop Count Titration/
Sodium Hydroxide
Digital Titrator/
Sodium Hydroxide
Drop Count Titration/
Sulfuric Acid
Digital Titrator/
Sulfuric Acid
Colorimeter/
Eriochrome Cyanine R
Drop Count Titration/
Silver Nitrate
Digital Titrator/
Mercuric Nitrate
Color Disc/
DPD
Colorimeter/
DPD
Drop Count Titration/
Thiosulfate
Digital Titrator/
Thiosulfate

PRICE
$25.75
$136.50
$20.75
$136.50
$215.00
$25.00
$136.50
$67.75
$215.00
$45.00
$139.00
10123-2

-------
                               HACH COMPANY
TEST

Chromium,
low range
(hexavalent)
Chromium,
high range
(hexavalent)
Copper
(free)
Cyanide
(free)
 Detergents
 Dissolved
 Oxygen
 Hydrogen
 Sulfide

 Lead
MODEL

CH-8
1834-00
DR 100
41100-03

CH-14
2227-02
CH-DT
20634-00

CU-5
14213-00

DR 100
41100-06

CYN-3
2010-02

DR100
41100-07

DE-2
1432-03

OX-2P
1469-00

OX-DT
20631-00

HS-7
2239-00

DR100
41100-48
METHOD/CHEMISTRY

Color Disc/
Diphenylcarbazide
Colorimeter/
Diphenylcarbazide

Drop Count Titration/
Thiosulfate
Digital Titrator/
Thiosulfate

Color Disc/
Bicinchoninate

Colorimeter/
Bicinchoninate

Color Disc/
Pyridine-pyrazolone

Colorimeter/
Pyridine-pyrazolone

Color Disc/
Drop Count Titration/
Modified Winkler

Digital Titrator/
Modified Winkler

Color Chart/
Effervescence of Pbg

Colorimeter/
Fast Column  Extraction
 PRICE

 $35.00



$215.00


 $31.50



$140.00


 $37.50


$215.00


 $91.00


$215.00


$155.00


 $39.95


$160.00


 $16.75


$215.00
 10123-2

-------
                             HACH COMPANY
TEST
Manganese

Nickel
Phosphate
(Total)
Silver
Sulfate

Sulfite

Zinc
MODEL
MN-5
1 467-00
DR100
41100-11
DR 100
41100-41
PO-24
2250-01
DR100
41100-42
SF-1
2251-00
DR100
41100-19
SU-5
1480-02
SU-DT
20633-00
DR100
41100-20
METHOD/CHEMISTRY
Color Disc/
Cold Periodate
Colorimeter/
Cold Periodate
Colorimeter
PAN
Color Disk/
Ascorbic Acid
Colorimeter/
Colorimetric
Extinction/
Turbidimetric
Colorimetric/
Turbidimetric
Drop Count Titration/
lodimetric
Digital Titrator/
lodimetric
Colorimeter
Zincon
PRICE
$66.75
$215.00
$275.00
$99.75
$275.00
$33.00
$215.00
$45.00
$140.00
$215.00
NOTE: Listed analysis kits and prices are those available for 1990.
10123-2

-------
                                        FIELD TEST KIT
                                       VWR SCIENTIFIC
BASIC KIT

Complete Water
  Action Set
    MODEL

Milton Roy 33-10-41
 FEATURES

Mini 20 Spectophotorneter
Portable, lightweight
Includes nephelometer module,
 DPD chlorine reagent system
Chlorine reagent system
  PRICE

S1.245.0C
   ADDITIONAL
INDIVIDUAL TESTS

Alkalinity
Chloride
Chloride (5-300)

Chlorine (free
  and total

Chromium
  (hexavalent)

Copper

Copper (.05-.50)
       (.3-5.0)

Cyanide
  (0.002-0.03 ppm)

Cyanide
  (0.03-0.7 ppm)
    MODEL

   3-09-01
   66122-304

   33-09-12
   66122-406

   EM-14401-1

   33-09-03
   66122-428

   33-09-17
   66122-461

   33-09-17
   66122-508
   EM-14414-1
   EM-14417-1

   EM-14417-1
   EM-14429-1
 METHOD/CHEMISTRY

Titration drop count
CaCO3 alkalinity/liter

Titration drop count
Cl/liter

Manual Test

Spectophotometric, DPD
C!2/liter

Spectophotometric, alkaline
hypobromite oxidation

Spectophotometric, cuprethol
Manual Test
 Manual Test
 PRICE

$56.00


$80.00


$82.95

*E7n nn
V* w.w\J


$70.00


$72.00

$82.95
$82.95

$87.10


$82.95
 10123-F

-------
                                       VWR SCIENTIFIC
   ADDITIONAL
INDIVIDUAL TESTS
 MODEL
 METHOD/CHEMISTRY
PRICE
Dissolved Oxygen
Hydrogen Sulfide
 (0.02-0.25 ppm)

Hydrogen Sulfide
 (0.2-5.0 ppm)

Manganese
Nickel (0.25-8.0)

Phosphate (Total)


Phosphate (.1-.16)

Phosphate (.1-2.5)

Sulphate


Sulphate (25-300)

Zinc (0.1-5)
33-09-08
66123-034

EM-14416-1
EM-14435-1


33-09-21
66122-756

EM-14420-1

33-09-23
66123-147

EM-14409-1

EM-1443M

33-09-14
66123-227

EM-14411-1

EM-14412-1
Titration drop count                  S80.00
Dissolved oxygen/liter

Manual Test                        S82.95
Manual Test                        382.95
Spectophotometric                 $120.00
Manual Test                        S82.95

Spectophotometric acid              S72.00
hydrolysis and persulphate oxidation

Manual Test                        S82.95

Manual Test                        S82.95

Spectophotometric,                  $70.00
Turbidimetric, SO4/liter

Manual Test                        S82.95

Manual Test                        $82.95
 NOTE: Listed analysis kits and prices are those available for 1990.
 10123-F

-------
                                  INDIVIDUAL FIELD TEST KITS
                             COLE-PARMER INSTRUMENT COMPANY
TEST

Acidity (0-500 ppm)

Alkalinity
  (0-300 ppm)

Aluminum
  (0-.5 ppm)

Chloride
  (0-2.5 ppm)

Copper
  (0-1, 1-10 ppm)
  (total soluble)

Cyanide

Dissolved Oxygen
  (0-10 ppm)

Lead (CLSOppb)

Phosphate
  (0-5 ppm)

Sulphate
  (0-750 mg/l)

Sulphite
  (0-200 ppm)

Zinc (0-10 mg/l)
 MODEL

L-02652-20

L-02652-02


L-05554-20


L-02652-10


95-00290-50



L-05542-09

L-02652-00


L-00291-50

L-02652-38


L-05542-23


L-02652-24


L-05542021
METHOD/CHEM'STRY

Titrimetric

Titrimetric


Titrimetric tablets


Mercurimetric titration


Colorimetric
Winkler titration


Colorimetric

Colorimetric
lodometric titration
 PRICE

S23.95

S21.95


S37.50


S23.95


S53.00



S52.00

$37.95


$64.50

$23.95


$58.50


$30.75


$72.50
 10123-F

-------
 SUPPLIER
    MODEL
pH METER

      CAPABILITIES
 PRICE
Hach
Hach One System
No. 43800-00
 Non-Clogging Reference Junction
 mV Resolution of 0.1 Unit
 Auto and Manual Mode for Calibration
 One Year Warranty
S395.00
Cole-Parmer
pH Wand with Electrode
Module N-05830-00
 Easy to Replace Electrode Module
 Automatic Signal Amplification
 Automatic Temp. Compensation
 +.0.01 pH Accuracy
S 120.00
V.W.R Scientific    Beckman BK123132
                        Auto Buffer Recognition/Standardization
                        • Auto Read Stability Indicator
                        • Simultaneous Temp. Display
                        • Standardization Indicators
                        • Error Messages
                        • Auto Display Off
                                     $310.00
McMaster Carr
Compact pH Meter
(LCD) No. 8508T9
 Oto 14pH Range
 LCD Display for Outdoor Use
 +.0.01 pH Accuracy
$217.00
 Omega
 Model PHH-43
-Combination pH, Milli Volt,
And Temperature Meter
-Easy pH Calibration
-Microprocessor Based
Temperature Compensation
And pH Calibration
$255.00
 10123-M2

-------
                                   CONDUCTIVITY METER
 SUPPLIER


Cole-Parmer
   MODEL
Hand Held Model
No. N-01481-40
     CAPABILITIES
Adjustable Temp. Coefficient
Auto. Temp. Compensation
Wide Conductivity Range
 PRICE,


S275.00
V.W.R. Scientific
NBS Digital Meter
Cat. No. 23266-501
Chemical Resistant ABS Housing
Fast Response Probe
Battery
NBS Certificate
$218.00
Hach
Digital Model 44600
 Digital Display
 Conductivity, TDS, Temp.
 Patented Probe
 Carrying Case
$395.00
 Omega
Portable Model CDH-70
 Chemical Resistant Case
 Temp., Conductivity, Cell Constant
 Built-in Temp. Compensation
• Membrane Keyboard
$291.00
 Extech Instruments  P341650
                       -3 1 /2 Digit LCD Display                 S229.00
                       -Adjustable Hinged Cover
                       -Neckstrap For Hands Free Operation
                       -9V or AC Adaptor
                       -Measures Conductivity 0.1 to 200,OOOyS/cm
                       -Automatic 0 to 100°c Temperature
                        Compensation
 10123-M2

-------
                        PORTABLE AUTOSAMPLER
MANUFACTURER:
American Sigma
MODEL.


CAPABILITIES:
Model No. 800SL
   Compact design  passes through 18" manhole
   opening.
   24#dry wt.
   Accepts 8# ice in base.
   Corrosion resistant Delrin pump.
   Peristalic pump has no contact with media.
   Liquid sensing system.
   Serial interface for downloading to IBM P.C. or
   Hand Held Data Transfer Unit.
   Large 16 character display.
   Electronic isolation sealed in NEMA 4X, 6 housing.
   Vertical lift 27 ft.
   Transport velocity of 2.7 ft/sec.
   Temperature limits 32°F - 120°F.
   Time and flow proportional sampling capabilities
REQUIRED ACCESSORIES:
1 • Compact base part No. 1405.
1 -Gel electrolyte, 12 VDC, 6 AMP/HR battery No.
   1414.
1 - Battery charger No. 913.
2 - 24-575 ml polypropylene bottles w/caps No. 1369.
1 -Retainer ring No. 1376.
1 - Distributor assembly for compact base No. 1375.
25*-3/8" I.D. Vinyl tubing No. 920.
1 -Teflon/S.S. weighted strainer No. 926.
1 -Silicone pump tubing insert No. 1358.
 PRICE:
 $2,535.00
 NOTE:  Listed accessories included as part of total price.
 10123-4

-------
                       PORTABLE AUTOSAMPLER
MANUFACTURER:


MODEL


CAPABILITIES:
Manning
Model No. S-4040
-  Max. sample lift 22 ft.
-  Time and flow proportional sampling capabilities.
-  Watertight, ABS plastic housing.
-  Superior sample transport velocity of 3 ft/sec
  minimum.
-  Precise equal volume samples.
-  Reliable operation  w/discreet sampling and
  rotating spout assembly.
-  Purge pressure minimum 20 psi.
-  Temperature limits 32°F - 120°F.
•  Interface for Manning portable flowmeters.
-  31 pound dry weight.
REQUIRED ACCESSORIES:
24 - 500 ml autoclave polypropylene bottles w/caps
1 - Battery charger.
1-12 VDC, 16 amp/hr wet cell battery.
1 - Composite base.
1-(.375")  I.D.  nylon  reinforced  PVC  tubina
   w/weighted  PVC  strainer,  various lengths
   available.
PRICE:
$2,090.00
 NOTE: Listed accessories not included as part of total price.
 10123-4

-------
                         PORTABLE AUTOSAMPLER
MANUFACTURER:


MODEL:


CAPABILITIES:
REQUIRED ACCESSORIES:
PRICE:
ISCO
Model No. 3700
-   Rugged corrosion resistant exterior.
-   Exclusive LD90 liquid presence detector.
-   Watertight, dust tight, corrosion resistant.
-   Peristalic pump.
-   No cross contamination.
-   User friendly programming.
-   40 character LCD.
-   Real time date clock.
-   Sealed controller.
-   Sequential 24 bottle sampling.
-   Time and flow proportional sampling capabilities.
-   Temperature limits 32°F • 120°F.
-   Pump rate 3500 ml/min. (3 ft. head)
-   37 pound dry weight.

1 - Nickel cadmium battery.
1 - AC-power converter/battery charger.
1 - 25'-3/8" I.D. vinyl suction line with strainer.

$2,865.00
 NOTE: Listed accessories included as part of total price.
 10123-4

-------
                   ESTIMATED MISCELLANEOUS SURVEY COSTS
    ITEM

Instant Camera

Color Film

Plastic Sampling Bottles
Storage Cooler

Wooden Stakes
Hammer

Flashing Barricade
Orange Safety Cones
Orange SAfety Vests
Crowbar
Flashlight & Batteries
Fold-Up Tape Measure
Heavy Duty Tape

Fluorescein Dye Tracer
pH Buffer Solution
Conductivity Buffer Solution

Gloves
Rubber Boots
Safety Shoes
Safety Glasses
Hard Hats
Work Coveralls
First Aid Kit
       AMOUNT

  1 - Polaroid One-Step

  1 - 20 Exposure Film

150-1602. Bottles
  1 - 48 qt. Cooler

 20 - 2 in. x 4 in. x3ft.
  1 - One-Piece Steel

  1 - 36* Barricade
 10 - Fluorescent 18" Cones
  2 - Nylon Vests
  1 - Crowbar
  2 - Explosion Proof
  1 - 8 ft. Tape Measure
  1 - 60 yd. 2 in.  Duct Tape

 200 Tablets
   1 Pint
   1 Pint

   2 Pair
  • 1 Pair-10in. Overshoe
   2 Pair
   2 Pair
   2 Hats
   2 Coveralls
  1 - Basic Unit
PRICE

45.00

 18.00

60.00
20.00

 15.00
 15.00

70.00
70.00
 10.00
20.00
 15.00
  8.00
  8.00

 18.00
  5.00
  5.00

  5.00
 35.00
100.00
  8.00
 15.00
 50.00
 35.00
                                      TOTAL ESTIMATED COST   $650.00
 10123-M2

-------
              APPENDIX C
         DATA INVENTORY FORMS
10123

-------
                           OUTFALL ANALYSIS DATA
Outfall ID  	   Date
Inspector(s) 	   Time
Weather Conditions
Surrounding lndustrial_
      Facilities
Flow Pattern
TIME/51 OF DETECTED DISCHARGE
Dav of Week
D
2)
3}
4}
5)
Stan Time
1)
2)
3)
4)
5)
End Time
D
2)
3)
4)
5)
Other Comments


 10123FRM

-------
                        OUTFALL ANALYSIS DATA (cont.)
Outfall ID  	   Date
Inspector(s) 	   Time
PHYSICAL OBSERVATIONS
Odor
Color

Turbidity

Floatables

Residue

Vegetation

Structural Damage

Other Comments
 10123FRM

-------
                         OUTFALL ANALYSIS DATA (cont.)
Outfall ID
Inspector(s)
CHEMICAL ANALYSIS
      EM
          Type of Test
          Manufacturer
          Model No.
      Total Dissolved Solids
          Type of Test    	
          Manufacturer   _
          Model No.     _
      Conductivity
          Type of Test    _
          Manufacturer   	
          Model No.     _
      Grab Samples
          Sample ID
 Laboratory Address
Date
Time
           Reading 1)_
                   2).
                   3).

           Reading 1)_
                   2).
                   3).

           Reading 1)_
                   2).
                   3)
             Phone
 10123FRM

-------
                         LABORATORY ANALYSIS

Inspector(s)  	     Date
                                                Time
Sample Location
Sample ID
Laboratory Address
      Phone
Date Submitted
Date Completed
Parameters for Testing

CONVENTIONAL POLLUTANTS

      	 pH
      	 Conductivity
      	Total Solids
      	Total Suspended Solids
      	Total Dissolved Solids
      	 BOD (5 day)
      	Organic Solids
      	 Inorganic Solids
            Oil and Grease
 1Q123FRM

-------
                      LABORATORY ANALYSIS (cont.)
Sample Location
Sample !D
TOXIC POLLUTANTS ^As Lifted bv the Clean Wa:er Act)
      Acenaphthene
      Acrolein
      Acrylonitrile
      Aldrin/Dieldrin
      Antimony and compounds
      Arsenic and compounds
      Asbestos
      Benzene
      Benzidine
      Beryllium and compounds
      Cadmium and compounds
      Carbon tetrachloride
      Chlordane
      Chlorinated benzenes
      Chlorinated ethanes
      Chloroalkyl ethers
      Chlorinated naphthalene
      Chlorinated phenols
      Chloroform
      Chloropheno!
      Chromium and compounds
      Copper and compounds
      Cyanides
      DDT and metabolites
      Dichlorobenzenes
      •
      Dichlorobenzidine
       Dichloroethylenes
      2,4-Dichlorophenol
       Dichloropropane & dichloropropene
      " 2,4-Dimethylphenol
       Dinitrotoluene
       Diphenylhydrazine
       Endosulfan and metabolites
Endrin and metabolites
E'.hylbenzene
Fluoranthene
Haloethers
Halomethanes
Heptachlor and metabolites
Hexachlorobutadiene
Hexachlorocyclohexane
Hexachlorocycfopentadiene
Isophorone
Lead and compounds
Mercury and compounds
Naphthalene
Nickel and compounds
Nitrobenzene
Nitrophenols
Nitrosamines
Pentachlorophenol
Phenol
Phthalate esters
Polychlorinated biphenyls
Polynuclear aromatic hydrocarbons
Selenium and compounds
Silver and compounds
2,3,7,8-Tetrachlorodibenzo-p-diox;n
Tetrachloroelhylene
Thallium and compounds
Toluene
Toxaphene
Trichloroethylene
Vinyl chloride
Zinc and compounds
 OTHER PARAMETERS
  10123FRM

-------
                   PROCESS DATA:  DIRECT DISCHARGE
Snspector(s)	  Date
Industrial Facility
Industrial Address
Industrial Contact	    Phone
Process Description  	
Discharge Point Location

Discharge Point ID   	
Receiving Water     	
Is Discharge Covered by an NPDES Permit?
If No, Why Not? 	
 NPDES Permit No.	  Expiration Date
 Issuing Agency  	  Contact	Phone_
 Permitted Parameters	
 Exceedence History

 Other Comments
 10123FRM

-------
                  PROCESS DATA: INDIRECT DISCHARGE
Inspector(s)	Date
Industrial Facility
Industrial Address
Industrial Contact    	   Phone
Process Description  	
Discharge Point Location
Discharge Point ID
Final Receiving Water_
Name of POTW
POTW Contact      	   Phone
Is Discharge Covered by a POTW Contract?	
Has POTW Instituted a Pretreatment Program?	
II Yes, Describe Type of Treatment  	
Limited Parameters
 Other Comments
 10123FRM

-------
                                SPILL POTENTIAL
Inspector(s)
Industrial Facility
Industrial Address
Industrial Contact
SPCC Plan Available
Other Sources
  of Data

Type of Spill

Process Location

Type of Materials

Potential Volume

Possible Causes
Spill Containment
Other Comments
                                             Date
                                                   Phone
                                       If Yes, Date Written
 10123FRM

-------
                                 SPILL HISTORY
Inspector(s)
Industrial Facility
Industrial Address
Industrial Contact
SPCC Plan Available
Olher Sources
  of Data

Date of Spill
Type of Spill

Process Location

Spilled Materials

Volume Spilled

Recorded Cause
 Corrective Actions
 Other Comments
      Date
            Phone
If Yes, Date Written
 10123FRM

-------
                              FACILITY RUNOFF
Inspector(s)   	  Date
Industrial Facility
Industrial Address
Industrial Contact    	   Phone
Runoff Collection Point          	
Description of Contributing Area
POTENTIAL RUNOFF CHARACTER

Description                  Contamination                  Drainage
of Source	Potential	Path
Parking Lots     	    	
Shipping Areas

Receiving Areas

Material Storage

Other Areas
 10123FRM

-------
                          CORRELATION OF DATA
Inspector(s)	  Dale
Industrial Facility
Industrial Address
Industrial Contact    	    Phone
Outfall ID           	
Outta!! Location      	
Manhole ID
Manhole Location

Process ID
Process Location

Process Description
Other Comments
 10123FRM

-------
                      CORRELATION OF DATA (cont.)
SIMILAR CHARACTERISTICS
                       Outfall             Manhole            Process
                       ID	        ID	        ID	
Physical Observations
     Odor
     Color
     Turbidity
     Floatables
     Residue
     Vegetation
     Structural Damage

Chemical Analysis
     pH
     TDS
     Conductivity

Other Parameters
 10123FRM

-------
                             FACILITY RUNOFF
Inspectors)	Dale
Industrial Facility
Industrial Address
Industrial Contact    	   Phone
Runoff Collection Point	
Description of Contributing Area
POTENTIAL RUNOFF CHARACTER

Description                  Contamination                  Drainage
of Source	Potential	Path
Parking Lots    	   	
Shipping Areas

Receiving Areas

Material Storage

Other Areas
 10123FRM

-------
Pipeline Examination

Fluorescein dye tracer will be needed to conduct pipeline examinations. Ample dye
should be brought along  as several tests may be necessary to identify one or more
illicit connections at an industrial site.
Inspector Safety

Attention to safety procedures is a must during all field surveys. This includes inspector
apparel from head to toe.  Work clothes should always be worn for all inspections.
Rubber boots should be brought along in case of wet or muddy conditions during the
screening of storm water outfalls.   Essential materials for the industrial on-site
investigation include safety shoes, safety glasses, a hard hat, and hearing protection.
Protective gloves should always be worn when collecting samples of any potentially
dangerous discharges. Finally, a complete first aid kit should always be kept on hand
in case of an emergency.
                                  TABLE 3

                     FIELD EQUIPMENT AND MATERIALS
Field Test Kit                                  Orange Safety Vest
pH Meter and Buffer Solution                    Crowbar
Conductivity Meter and Buffer Solution           Flashlight and Batteries
Automatic Sampler                            Fold-Up Tape Measure
Instant Camera and Film                        Heavy Duty Tape
Sampling Bottles and Waterproof Marker         Fluorescein Dye Tracer
Cooler                                       Work Clothes
Clipboard, Pad, Pen or Pencil                   Rubber Boots
Data Inventory Forms                          Safety Shoes
Maps                                        Safety Glasses
Marked Stakes                               Hard Hats
Hammer                                     Hearing Protection
Flashing Barricade                             Protective Gloves
Orange Safety Cones                          First Aid Kit
 10123SC7                             51

-------
                                 TABLE 4

              CONSIDERATIONS FOR AUTOMATIC SAMPLER
     Capability for AC/DC operation with adequate dry battery energy storage for
     120-hour operation at 1-hour sampling intervals

     Total weight including batteries

     Sample collection interval (adjustability from 10 minutes to 4 hours)

     Capability for:

            Flow  proportional sample - constant time interval  between samples,
            sample volume proportional to stream flow at time of sampling (variation
            inflow >15%)
           ———
            Time proportional sample - constant sample  volume, time  interval
            between samples proportional to stream flow

     Capability for collecting discrete samples in 24 containers

     Watertight exterior case to protect components in the event of rain or submersion

     Exterior case capable of being locked to prevent tampering and provide security

     No metal parts in contact with waste source or samples

     An integral sample container compartment capable of maintaining samples at 4
     to 6°C for a period of 24 hours at ambient temperatures ranging from -30 to
     50°C

     Operation capabilities in the temperature range from -30 to 50°C

     Sampler exterior surface painted light color to reflect sunlight
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PERSONNEL REQUIREMENTS

The objective of the following discussion is to provide general information regarding the
personnel demand and training necessary to perform the methocology outlined in this
manual.

Clearly, as the size of the industrial area to be investigated increases, so too does the
demand for  personnel. The following suggestions are based upon an optimum fixed
number of inspectors per phase of the field survey. These suggestions were offered in
order to set a standard as well as to simplify the overall procedure.
Phase I • Screening of Storm Water Outlalls

It is suggested that  a minimum of two (2) investigators perform the observations and
analyses at a storm water outfall. There are several reasons behind this selected
minimum among which the most important are the following:

             Correspondence regarding visual observations and elementary chemical
             analyses
             Safety in numbers
             Load distribution for carried equipment

Thus, a coupled effort will result in greater efficiency as well as mobility.  When very
large  numbers of storm water outfalls exist for screening in an industrial area, it is
suggested that several pairs of investigators perform outfall surveys in order to expedite
the process.
 Phase II • Industrial On-Site Investigation
 In order to perform the industrial on-site investigation, it is suggested that either three
 investigators be aided by one industry personnel or two investigators be aided by two
 industry personnel. The reasoning behind a total number of four being such that the
 on-site investigation may be divided into two tasks.  Thus, one pair of investigators may
 perform the outside inspection while the other pair focuses their attention upon the
 inside inspection.
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The selected industry personnel should have a thorough knowledge of the operations
performed at the facility.  In addition, it is beneficial if they also have a practical
understanding of environmental management procedures as well.
Personnel Training

In addition to efficiency, the inspectors performing a field survey must also be accurate.
High levels of accuracy may only be obtained through complete and proper training.
Training should encompass a formal orientation  of the methodology presented in this
manual along with practical field techniques.

Therefore, inspectors should  have an understanding of the various identification
strategies presented in this text. They should also be knowledgeable of typical kinds
and sources of industrial waste. If possible, training should include an actual field
orientation of common industrial water use processes and  types of spills.  Faciuai
information should also be provided summarizing the contacts and access  details
necessary for obtaining pertinent data such as sewer maps or environmental records.

Inspectors  must be able to correctly operate all field equipment • in particular
specialized meters and automatic samplers.  Training  should include the proper
procedures for collecting samples  as well  as for performing manhole observations.
Finally, steps must always be taken  to make personnel aware  of potential occupational
hazards, precautionary measures to prevent them, and special plans to follow in the
event of an emergency.
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TIMELINE

There are several steps to be performed when following the methodology outlined in
this manual. The following chart is intended to provide a generalized indication of the
time required for each step.


It is important to note that the chart provided does not take into account unexpected
problems such  as poor weather or equipment failure.  In addition, the time needed to
conduct the on-site industrial investigation  and  confirmatory analysis is  highly
dependent upon the size of the facility. Thus, these estimates should be considered
only as idealized guidelines.
Procedure and Step                                     Time Range (days)

Outfall Evaluation

      Step 1 • Mapping Effort                                      1-3
      Step 2 - Walking Tour                               2 outfalls surveyed/day*
      Step 3 • Outfall Analysis                             2 outfalls analyzed/day

Identification of Potential Industrial Sources

      Step 1 > Establish Flow Pattern                                3-7
      Step 2 • Analysis of Recorded Data                            1 -3
      Step 3 - Correlation to Possible Industrial Sources               1 -3

On-Site Industrial Investigation

      Step 1 • Data Collection                                      2-4
      Step 2 • Preliminary Evaluation of Water Use and                2-4
                Other Discharges
      Step 3 - On-Site Investigation                                 3-7
      Step 4 - Confirmatory Analysis                                3-7
 'NOTE:
      Inspectors should be able to complete the initial survey and analysis for two
      outfalls per day.
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ORGANIZATIONAL- IDEAS

The use of Data Inventory  Forms can greatly simplify the process of recording
information.  A variety of Data Inventory Forms are provided in Appendix  C of this
manual. Thus, the objective of the following discussion is to briefly describe the
function for each form.
Outfall Analysis Data
This three-page form should be used to record data collected from the screening of
storm water outfalls.  The form  organizes information  regarding the detected flow
pattern, physical observations, and elementary chemical analysis results for a particular
outfall.
 Laboratory Analysis

 This two-page form should be used to check off the parameters which should be tested
 for in a grab sample laboratory analysis. The form summarizes the grab sample
 identification details,  laboratory information, and  provides a listing for conventional as
 well as toxic pollutants.  The toxic pollutants were determined according to the listing
 provided originally in  the Clean Water Act.
 Process Data: Direct Discharge
 This form summarizes information regarding industrial processes which directly
 discharge into a receiving water body.  Data regarding a particular industrial process as
 well as any permit details are to be recorded on this form.
 Process Data:  Indirect Discharge
 This form summarizes information regarding industrial processes which discharge to
 the local POTW for treatment before entrance to a receiving water body.  The
 information recorded includes details of the particular industrial process and any
 pretreatment for it discharges as well as general data for the local POTW.


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$pill History

This form should be used to record  information regarding any past spills which
occurred at an industrial facility.
Spill Potential
This form should be used to summarize information regarding industrial processes
which have spill potential.
Facility Runoff

This form  should be used during the outside portion of the industrial on-site
investigation. The form summarizes potential sources of illicit discharges due to storm
water runoff contamination.
Correlation of Data

This form should be used during the correlation process to determine similarities
between the detected illicit discharge and suspect industrial process discharges.
Comparisons are drawn based upon the wastestream  characterization of discharges
from the contaminated outfall, manhole observations, and suspect industrial process
discharges.
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                                  Section 8

                                 SUMMARY
This manual has outlined a procedure which begins with the screening of stormwater
outfalls for signs of industrial discharge contamination.  The methodology then
proceeds to the identification of likely sources for the detected non-stormwater
discharge.  Ultimately, the actual location of the industrial illicit connection to the storm
drainage system is pinpointed.  This manual concludes with a section focusing solely
upon necessary field survey techniques  as the success of this methodology depends
largely upon the careful collection of data and  analysis of pertinent information.

The actual  strategy underlying this methodology involves a correlation process
between the characteristics  Of discharges observed at outfalls and that of various
industrial manufacturing  or operational process discharges.  It is possible that several
options may appear to  be viable solutions while at other times no alternatives  may
seem to be the correct choice.   Therefore, more than one on-site industrial
investigation may be necessary in order to identify the source of an illicit connection.

By applying common sense and professional judgement to the procedures outlined in
this manual, successful  assessments of a facility's illicit storm water connections can
be accomplished.
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