REGION VIII STRATEGY FOR TOTAL TOXIC ORGANICS
June 29,1999
BACKGROUND
Control authorities are required to inspect and sample the effluent from each
Significant Industrial User (SIU) at least once a year (40 CFR Section
403.8(f) (2) (v)). As stated in the final rule discussion [55 FR 30118] regarding
Domestic Sewage Study amendments, EPA states that "The POTW should,...,
sample for all regulated pollutants discharged to the treatment works" and
recognized the necessity of performing inspection and sampling at a minimum
of once per year. Total Toxic Organics (TTOs) limits were established for the
following categorical industries: Electroplating (40 CFR Part 413), Metal Finishing
(40 CFR Part 433), Electrical and Electric Components (40 CFR Part 469), Copper
Forming (40 CFR Part 468), Aluminum Forming (40 CFR Part 467), and Coil
Coating (40 CFRPart 465). The type of pollutants that comprise the parameter
TTOs vary according to the category, with many having certification and/or
alternative testing requirements. Each category is discussed in the "Guidance
Manual for Implementing Total Toxic Organics (TTO) Pretreatment Standards.
September 1985".
EPA, Region VIII is providing further guidance for Control Authority sampling and
inspection requirements to be applied, at a minimum, in Region VIII approved
pretreatment programs. All questions concerning this Strategy should be
directed to the Pretreatment Coordinator, (8P-W-P), Office of Partnerships and
Regulatory Assistance, USEPA Region VIII, Suite 500, 999 18th Street, Denver,
Colorado 80202.
CATEGORICAL INDUSTRIAL USER TTO REQUIREMENTS
TTO is defined as the sum of the masses or concentrations of specific toxic
organic compounds found in the Categorical Industrial User (CIU) discharges at
>0.01 mg/l.

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TTO monitoring must be submitted in the Baseline Monitoring Report
(BMR) and 90 day Compliance Reports for ClUs subject to a TTO standard
except for those facilities using the alternate oil and grease limits provided for in
Aluminum
Forming, Copper Forming, and Coil Coating regulations. BMR requirements may
be found at 40 CFR Section 403.12 (b) and 90 day compliance report
requirements at 40 CFR 403.12(d).
Periodic compliance reports (40 CFR Section 403.12(e)) may allow the CIU
to use an alternative for the TTO analysis depending on the category. See Table
1 for a summary of requirements.
Metal Finishing/Electroplating Category
Categorical Industrial Users covered by the Electroplating or Metal
Finishing regulations are required to evaluate TTOs as part of their BMR and 90
day compliance reports. Control Authorities must evaluate the data in the
BMRs and 90-day compliance reports to determine which, if any, TTOs the CIU
must analyze for in subsequent periodic compliance reports.
Should the CIU demonstrate through previous chemical sampling that no
discharge of TTOs will occur, the approved program may, at its discretion, allow
the CIU to certify that no TTOs were discharged. The certification must be on
the periodic compliance reports and contain the exact language as shown at
40 CFR Sections 413.03(a) and 433.12(a)). In orderforthe CIU to certify, the CIU
must develop, submit and implement an approvable Toxic Organic
Management Plan (TOMP).
Control Authority Complionce Monitoring
The Control Authority is required to inspect and sample the effluent from
each Significant Industrial User (SIU) at least once a year to determine
compliance with regulated pollutants. This sampling must be independent of
the sampling performed by the industry and sufficient to allow for determination
of compliance with permit limits by the Control Authority.

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TTOs are regulated pollutants in the industrial categories cited earlier, and
therefore, a compliance determination is necessary. In order for a Control
Authority to determine compliance with Pretreatment Standards and
requirements, it must ensure that compliance monitoring and the annual facility
inspection compliment each other. Both the inspection and the compliance
sampling should be unannounced activities.
There are several scenarios that may exist with regard to TTO compliance
monitoring by the Control Authority:
1.	CIU is required to monitor for TTOs for periodic compliance reports: Under
this scenario, the Control Authority would perform compliance monitoring
for all parameters that are required of the CIU. In addition, during the
annual inspection, the Control Authority would confirm that the TTOs that
the CIU must monitor for are still appropriate and representative of the
TTOs that would be reasonably expected to be present based on a survey
of raw materials the CIU has on-hand.
2.	CIU is approved to certify for TTOs
Under this scenario, the CIU must have previously been required to
demonstrate up-front that there are no TTOs present [e.g. through TTO
sgmpling dgfg on the BMR ond 90-dgy complionce report).
The Control Authority would, os pgrt of the onnugl inspection, verify thot
no TTOs ore regsonobly expected to be present in the dischorge bgsed on
g thorough review of row mgterigls, process operations, etc.
The inspection form must document the following:
1.	Chemicol inventories;
2.	Operating practices;
3.	Changes in raw materials, products, etc.
4.	* Chemical characterization of raw materials

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(chemicals);
5.	** Evaluation of the TOMP on-site;
6.	Other information that the Control Authority deems
relevant.
Material Data Safety Sheets (MSDSs) would provide a significant
portion of the information required. However, please note that
many manufacturers do not include pollutants on the MSDS, if they
comprise less than 5% of the product. Therefore, the industrial user
may have to request a more complete analysis from the
manufacturer.
The CIU Toxic Organic Management Plan (TOMP) must be taken
on-site during the inspection and reviewed to ensure that the
practices are being followed and the TOMP is up-to-date.
If the Control Authority completes the items cited in this part, no sampling
and analysis for TTOs are required as part of the annual evaluation. However,
sampling and analysis should be undertaken as a result of any inspection or
report indicating a change in discharge may have occurred.
SAMPLING FOR TTO'S
Sampling for TTOs presents some inherent difficulties due to the diverse
nature of the constituents comprising the TTO parameter. Compliance
decisions require that when TTOs are sampled, a representative sample must be
collected. There are two types of samples that are commonly collected: grab
samples and composites. Grab samples are individual samples collected over a
period of time not exceeding 15 minutes. Grab samples are useful when
information about an instantaneous pollutant concentration is of interest or the
type of pollutants of interest require grab samples, e.g. oil & grease, pH, volatile
organics, etc.
Composite samples are a series of grab samples collected over a 24 hour
period and combined proportionally to flow. Composite samples may also be
collected by continuous sampling. Composite samples are generally used when

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determining compliance with many categorical standards and local limits (daily
average) or where wastewater characteristics are significantly variable.
Sampling requirements for the various TTOs is shown in Table 2.
NOTE: It is important to note that for parameters that require a 40 ml
sample volume due to their volatile nature the samples should be
collected in a glass vial and filled so that no air bubbles pass
through the sample or remain in the bottle. The bottles must be
sealed to prevent loss of volatiles.
NOTE: Contact your contract laboratory for bottles and minimum volumes
required for each type of pollutant. The Table 2 values are
guidelines.
NOTE: All analytical methods must be approved under 40 CFR Part 136.
40 CFR Section 136.3, Table II lists preservation, required containers,
and holding times. Consult Table II prior to sampling.
NOTE: Refer to methods for specific testing protocols and individual
pollutants covered by the particular test method. Many are listed
in the TTO guidance document in Chapter 7.
Representative Samples
For the determination of compliance with TTO standards the Control
Authority and the CIU shall:
1. For parameters requiring grab samples, collect at least four grab
samples during a 24 hour period (or workday) and composite the
samples in the lab. The Control Authority and the CIU (after
approval from the Control Authority) may use a single grab if: (1)
The sampling is on a batch discharge and because of mixing, etc.,
the concentration of pollutants in the batch are relatively uniform;
or (2) The discharge shows little daily variation (demonstrated by
previous chemical sampling, rare condition).

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2. For parameters requiring composite samples, collect a composite
using the grab sampling technique described above or an
automated continuous sampler during a 24 hour period (or
workday).
Many programs may use a single grab as a screening tool forTTOs.
However, the Control Authority must ensure that a representative sample is
taken when compliance determinations are being made.

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TABLE 1
SUMMARY OF TTO REQUIREMENTS
CFR	COMPLIANCE
CATEGORY RE
:ERENCE LIMIT (MG/L) DATE ALTERNATIVES
ELECTROPLATING
413
4.57 (<1 OK GPD)
2.13 (> 1 OK GPD)
7/15/86
7/15/86
CERTIFY, TOMP*
CERTIFY, TOMP*
METAL FINISHING
433
2.13
2/15/86
CERTIFY, TOMP*
ELECTRICAL AND
ELECTRONIC COMPONENTS
469 (A&B)
469 (C)
1.37
1.58
7/1/84
7/1/86
CERTIFY, SOLVENT
MGMT PLAN
COPPER FORMING
468
VARIES
8/15/86
OIL & GREASE
ALUMINUM FORMING
467
VARIES
10/24/83
OIL & GREASE
COIL COATING
465(D)
PRODUCTION
BASED
11/17/86
OIL & GREASE
* - TOXIC ORGANIC MANAGEMENT PLAN

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TABLE 2
SAMPLING REQUIREMENTS FOR TTOs
GRAB OR MINIMUM MAX HOLDING
TTO METH
OD COMPOSITE VOLUME (ml) TIME
PURGEABLE
HALOCARBONS
601
GRAB
40
14 DAYS
PURGEABLE
AROMATICS
602
GRAB
40
14 DAYS
ACROLEIN &
ACRYLONITRILE
603
GRAB
40
14 DAYS
PHENOLS
604
EITHER
1,000
7 DAYS, SEE 40
CFR 136.3
BENZIDINES
605
EITHER
1,000
7 DAYS
PHTHALATE ESTERS
606
EITHER
1,000
7 DAYS, SEE 40
CFR 136.3
NITROSAMINES
607
EITHER
1,000
7 DAYS, SEE 40
CFR 136.3
ORGANOCHLORINE
608
EITHER
1,000
7 DAYS, SEE 40

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PERTICIDES $ PCB



CFR 136.3
CONTAINER TYPE: GLASS TEFLON-LINED SEPTUMS (FOR PURGEABLE HALOCARBONS AND AROMATICS) OR
CAPS FOR OTHERS.

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GRAB OR MINIMUM MAX HOLDING
TTO METH
OD COMPOSITE VOLUME (ml) TIME
NITROAROMATICS
& ISOPHORONE
609
EITHER
1,000
7 DAYS, SEE 40
CFR 136.3
POLYNUCLEAR
AROMATIC
HYDROCARBONS
610
EITHER
1,000
7 DAYS, SEE 40
CFR 136.3
HALOETHERS
611
EITHER
1,000
7 DAYS, SEE 40
CFR 136.3
CHLORINATED
HYDROCARBONS
612
EITHER
1,000
7 DAYS, SEE 40
CFR 136.3
2,3,7,8-TCCD
613
EITHER
1,000
7 DAYS, SEE 40
CFR 136.3
PURGEABLES
624
GRAB
40
14 DAYS
BASE/NEUTRAL AND
ACIDS, AND
PESTICIDES
625
EITHER
1000-2000
7 DAYS, SEE 40
CFR 136.3
NOTE: READ 40 CFR SECTION 136.3, TABLE II FOR PRESERVATIVES PRIOR TO SAMPLING

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