Environmental Technology Verification Source Water Protection Pilot

In-Drain Treatment Technologies

PROTOCOL FOR THE VERIFICATION OF IN-DRAIN TREATMENT

TECHNOLOGIES

Prepared by:

NSF International
P. O. Box 130140
Ann Arbor, MI 48113-0140
734-769-8010
800-673-6275

with support from the
U.S. Environmental Protection Agency

Copyright 2001 NSF International 40CFR35.6450.

Permission is hereby granted to reproduce all or part of this work, subject to the limitation that
users may not sell all or any part of the work and may not create any derivative work therefrom.
Contact the ETV Source Water Protection Pilot Manager at (800) NSF-MARK with any
questions regarding authorized or unauthorized uses of this work.

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FOREWORD

In 1995, the U.S. Environmental Protection Agency (EPA) instituted a program, the
Environmental Technology Verification Program (ETV), to verify the performance
characteristics of commercial-ready environmental technologies through the evaluation of
objective and quality-assured data. Managed by EPA's Office of Research and Development,
ETV was created to substantially accelerate the entrance of innovative environmental
technologies into the domestic and international marketplaces. ETV provides purchasers and
permitters of technologies with an independent and credible assessment of the technology they
are purchasing or permitting.

During its pilot phase, EPA has cooperatively managed twelve ETV pilots in conjunction with
partner organizations, including states, federal laboratories, associations, and private sector
testing and standards organizations. The pilots have focused on each of the major environmental
media and various categories of environmental technologies and have been guided by the
expertise of a Stakeholder Group. Stakeholder Groups consist of representatives of all
verification customer groups for the particular technology sector, including buyers and users of
technology, developers and vendors, state and federal regulatory personnel, and consulting
engineers. All technology verification activities are based on testing and quality assurance
protocols that have been developed with input from the major stakeholder/customer groups.

NSF International is an independent, not-for-profit organization, dedicated to public health,
safety, and protection of the environment. NSF develops standards, provides educational
services, and offers superior third-party conformity assessment services, while representing the
interests of all stakeholders. In addition to well-established standards-development and
certification programs, NSF specifically responds to and manages research projects, one-time
evaluations and special studies.

NSF is the verification partner organization for three pilots under EPA's ETV Program: Drinking
Water Systems, which has completed the pilot stage and is now a center, Wet Weather Flow
Technologies, and Source Water Protection Technologies. This Protocol for the Verification of
In-Drain Treatment Technologies was developed under the Source Water Protection Pilot, whose
goal is to verify the performance of commercial-ready technologies used to protect ground and
surface waters from contamination. Testing conducted under the ETV program using this
protocol does not constitute an NSF or EPA certification of the product tested. Rather, it
recognizes that the performance of the equipment has been determined and verified by these
organizations.

Verification differs from certification in that it employs a broad, public distribution of test
reports and does not use pass/fail criteria. In addition, there are differences in policy issues
relative to certification versus verification. Certification, unlike verification, requires auditing of
manufacturing facilities, periodic retesting, mandatory review of product changes and use of the
NSF Mark. Both processes are similar, however, in regard to having standardized test methods
and independent performance evaluations and test result preparation. This protocol is subject to
revision; please contact NSF to confirm this revision is current.

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ACKNOWLEDGEMENTS

EPA and NSF acknowledge and thank those persons who participated in the preparation and
review of this Protocol for the Verification of In-Drain Treatment Technologies. Without their
hard work and dedication to the project, this document would not have been approved through
the process that has been set forth for this ETV project.

Protocol Writers
Karl Scheible
Elizabeth Kang
Edward Mignone

HydroQual, Inc.
HydroQual, Inc.
HydroQual, Inc.

NSF Staff

Thomas Stevens
Maren Roush
Bruce DeMaine

Project Manager, ETV Source Water Protection Pilot
Project Coordinator, ETV Source Water Protection Pilot
Manager, QA & Safety

EPA Staff

Raymond Frederick
Carolyn Esposito
Sam Hayes
Anthony Tafuri

EPA ETV Source Water Protection Pilot Manager
NRMRL-Ci QA Reviewer
NRMRL-Ci QA Reviewer
NRMRL, USEPA

ETV Source Water Protection Pilot — Technolosv Panel Participants

Doug Allard
Janis Bobrin
Rich Bradley
David Cone
Brant Keller

Jay Knight
Greg Potter
Dave Woelkers

KriStar Enterprises, Inc.

Washtenaw County Drain Commissioner
BP Amoco, p.I.e.

GreenTechTexas International

City of Griffin Public Works & Storm Water Utilities and

American Public Works Association (APWA)

Knight Treatment Systems

MYCELX Technologies Corporation, Inc.

Hydro Compliance Management, Inc.

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GLOSSARY OF TERMS

Accuracy - combination of bias and precision of an analytical procedure, which reflects the
closeness of a measured value to a true value.

Bias - consistent deviation of measured values from the true value, caused by systematic errors
in a procedure.

Effluent - the treated liquid stream produced by an in-drain treatment technology.

Influent - wastewater introduced to the in-drain treatment technology under evaluation for
treatment.

Owner - the owner of a test site used for verification testing of an in-drain treatment technology.

Precision - a measure of the degree of agreement among replicate analyses of a sample usually
expressed as the standard deviation.

Protocol - a written document that clearly states the objectives, goals, scope and procedures for
the study. A protocol shall be used for reference during Vendor participation in the verification
testing program.

Quality Assurance Project Plan - a written document that describes the implementation of
quality assurance and quality control activities during the life cycle of the project.

Raw Data/Record - all data and information recorded in support of analytical and process
measurements made during planning, testing, and assessing of the environmental technology,
including support records such as computer printouts, instrument run charts, standards
preparation records, field log records, technology operation logs, and monitoring records.

Representativeness - the degree to which the data accurately and precisely represent the
conditions or characteristics of the parameter represented by the data.

Standard Operating Procedure - a written document containing specific instructions and
protocols to ensure that quality assurance requirements are maintained while performing
verification activities such as sample collection and analytical testing.

Start-Up - The period between the time the in-drain treatment technology is put on-line and
when stable operating conditions are achieved.

Test Plan - a written document that describes the procedures for conducting a test or study
according to the verification protocol requirements for the application of an in-drain treatment
technology at a particular site. At a minimum, the Test Plan shall include detailed instructions
for sample and data collection, sample handling and preservation, precision, accuracy, goals, and
quality assurance and quality control requirements relevant to the particular site.

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Testing Organization - an organization qualified to conduct studies and testing of in-drain
treatment technologies in accordance with protocols and Test Plans.

Verification - To establish evidence on the performance of an in-drain treatment technology
under specific conditions, following a predetermined study protocol(s) and Test Plan(s).

Verification Organization - the party responsible for overseeing test plan development,
overseeing testing activities in conjunction with the Testing Organization, and overseeing the
development and approval of the Verification Report and Verification Statement for the
wastewater treatment technology. NSF is the Verification Organization for the ETV Source
Water Protection Pilot.

Verification Report - a written document, often prepared by the Testing Organization,
containing all raw and analyzed data, all QA/QC data sheets, descriptions of all collected data, a
detailed description of all procedures and methods used in the verification testing, and all
QA/QC results.

Verification Statement - A written document which is prepared for a verification test
conducted under the ETV Source Water Protection Pilot and summarizes the content of the
Verification Report.

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TABLE OF CONTENTS

FOREWORD	II

ACKNOWLEDGEMENTS	Ill

GLOSSARY OF TERMS	IV

TABLE OF CONTENTS	VI

1. INTRODUCTION	1

1.1	ENVIRONMENTAL TECHNOLOGY VERIFICATION (ETV) PROGRAM	1

1.1.1	ETV Pilot Obj ectives	1

1.1.2	Purpose of this Protocol	1

1.1.3	Verification Process	2

1.2	IN-DRAIN TREATMENT TECHNOLOGY DESCRIPTION	2

1.2.1	Technology Application	3

1.2.2	Technology Verification Approach	3

2	VERIFICATION TEST PLAN	4

2.1	TEST PLAN OBJECTIVES	4

2.2	PROJECT ORGANIZATION	4

2.2.1	Verification Organization	4

2.2.2	U.S. Environmental Protection Agency (US EPA)	4

2.2.3	Testing Organization	5

2.2.4	In-Drain Treatment Technology Vendor	5

2.2.5	Support Organizations	6

2.2.6	In-Drain Treatment Peer-Review Group	6

2.3	CAPABILITIES AND DESCRIPTION OF THE SYSTEM	6

2.3.1	SYSTEM DESCRIPTION	6

2.3.2	SYSTEM CAPABILITIES	8

2.4	EXPERIMENTAL DESIGN	9

2.5	HEALTH AND SAFETY PLAN	9

2.6	QUALITY ASSURANCE PROJECT PLAN (QAPP)	9

3	PERFORMANCE MEASUREMENTS	 10

3.1	SYSTEM/COMPONENTS OPERATION AND MAINTENANCE (O&M)	10

3.2	CONTAMINANTS THAT CAN BE REMOVED OR REDUCED	10

3.3	EFFLUENT QUALITY THAT CAN BE ACHIEVED	11

3.4	QUANTIFICATION OF RESIDUALS	11

4	EXPERIMENTAL DESIGN	13

4.1	EXPERIMENTAL SET-UP -- TEST FACILITY	14

4.2	TEST PHASES	14

4.3	INFLUENT CHARACTERIZATION	17

4.4	EFFLUENT CHARACTERIZATION	19

4.5	RESIDUALS MANAGEMENT	19

4.6	OPERATION AND MAINTENANCE (O&M)	19

5	SAMPLING AND ANALYTICAL PLAN	20

5.1	CHAIN OF CUSTODY	20

5.2	SAMPLING LOCATIONS	20

5.3	SAMPLING FREQUENCY	20

5.4	SAMPLE PRESERVATION AND STORAGE	21

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5.5 ANALYTICAL METHODOLOGY	21

6	QUALITY ASSURANCE PROJECT PLAN (QAPP)	23

6.1	PURPOSE AND SCOPE	23

6.2	QUALITY ASSURANCE RESPONSIBILITIES	23

6.3	CONTENTS OF THE QAPP IN TEST PLAN	23

6.4	QUALITY CONTROL CHECKS	24

6.4.1	Quality Control for Equipment Operation	24

6.4.2	Water Quality Data	24

6.4.3	Data Quality Indicators	24

6.5	DATA REDUCTION, VALIDATION, AND REPORTING	25

6.5.1	Data Reduction	25

6.5.2	Data Validation	25

6.5.3	Data Reporting	25

7	DATA MANAGEMENT AND DOCUMENTATION	26

7.1	GENERATED DATA	26

7.1.1	Raw Data	26

7.1.2	Analyzed/Calculated Data	27

7.1.3	Manual Data	28

7.1.4	Electronic Data	28

7.2	DATA ANALYSIS AND PRESENTATION	30

7.3	VERIFICATION REPORT	30

8	REFERENCES	32

LIST OF TABLES

Table 1 - Suggested Synthetic Wastewater Characteristics	18

Table 2 - Summary of Special Sampling and Handling Requirements	21

Table 3 - Parameters for Lab Analysis and Analytical Methods	22

LIST OF FIGURES

Figure 1 - Example Schematic Process Flow Diagram	8

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1. INTRODUCTION

This document provides the generic protocol for verification testing of in-drain treatment
technologies. The protocol has been prepared under the Environmental Technology Verification
Program.

1.1 ENVIRONMENTAL TECHNOLOGY VERIFICATION (ETV) PROGRAM

The Environmental Technology Verification (ETV) Program was established in 1995 by the
United States Environmental Protection Agency (US EPA). The ETV program was created to
accelerate the development and commercialization of improved environmental technologies
through third party verification and reporting of performance.

The ETV Program is divided into 12 pilot projects, one of which is the Source Water Protection
(SWP) Pilot. NSF International is the Partner Organization for the SWP Pilot and is responsible
for the Pilot's administration and implementation. The goal of the SWP Pilot is to verify
technologies that protect the quality of ground and surface waters by preventing or reducing
contamination. The SWP Pilot is active in several technology areas, among which is in-drain
treatment. A Technology Panel formed through NSF International advises on the design of the
In-Drain Treatment Technologies protocol, and its subsequent implementation.

The Technology Panel recommended that a generic, broad-based protocol for testing in-drain
treatment technologies should be written. This would specify the objectives and procedural
approach to technology verification through the ETV Source Water Protection Pilot, and the
procedures to be followed in order to meet specific technology verification objectives. This
protocol, reviewed by the Technology Panel and a Source Water Protection Pilot Stakeholder
Advisory Group (SAG), is then offered to technology vendors who may elect to participate in the
pilot. A project and technology-specific Test Plan is written for each technology verification,
refining the protocol to meet the technology's configuration and the test site conditions, but
staying within the framework and objectives of the generic protocol.

1.1.1	ETV Pilot Objectives

The objectives of the ETV Source Water Protection Pilot are to verify performance of and gather
operational data for commercial-ready technologies, following technically sound protocols and
appropriate quality assurance and control. Another objective of the Pilot is to provide permit
writers, buyers, and users with an independent and credible assessment of the technology. The
key outputs of the Pilot will be quality test data and US EPA/NSF International-verified test
reports. Additionally, protocols will have been developed by which different technologies can
be evaluated in a consistent and scientific manner.

1.1.2	Purpose of this Protocol

The protocol that follows is meant to satisfy the "generic protocol" requirement for the In-Drain
Treatment Technologies area. This protocol describes the steps that must be followed in order to
ensure that the technology verification process is carried out in a consistent and objective
manner. The protocol presents the technical approach for the verification and offers guidance
for preparing a test plan that is specific to the test system offered by a vendor. The protocol also
addresses guidance for testing and for the analysis and reporting of the verification results.

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1.1.3 Verification Process

The verification process under the ETV program consists of three major steps:

1.	Planning: The planning phase establishes the procedures to be followed for verification
of a specific technology. A test plan is developed by the designated Testing
Organization, with input from both the Vendor and the Verification Organization, in
addition to any other reviewers. Once drafted and revised as necessary, it is submitted to
the Verification Organization, which will obtain approvals from the EPA Pilot Manager
and the Vendor. The Test Plan will include detailed site and equipment specifications,
procedures for testing (including documentation for conformity to the generic protocol),
and a quality assurance project plan for assuring valid data. Guidelines for this phase of
the program are provided in Sections 2 and 3.

2.	Verification Testing: This phase of the project involves the actual assembly, installation,
and operation of the test facility, collection of the targeted samples, and completion of all
analyses required under the Test Plan. Sections 4 and 5 present the protocols for the
testing phase.

3.	Data Assessment and Reporting: The final phase of the verification program includes
analysis of the data generated during testing, and preparation of a Verification Report.
Guidelines for this phase of the project are given in Sections 6 and 7.

1.2 IN-DRAIN TREATMENT TECHNOLOGY DESCRIPTION

In-drain treatment technologies are defined as inserts placed in floor or area drains to treat waters
entering the drain for contaminant removal. Applications could include floor drains from
machine repair, auto body shops, or other operations where floor areas are washed down to a
drain. These technologies are similar to wet-weather flow, source-area treatment technologies,
which include inserts and other structures that treat stormwater at the point it enters the catch
basin or area drain. However, within the context of this protocol, in-drain treatment technologies
are not designed to handle the large volume of water encountered with storm events.
Contaminants of concern may include solids, metals and organics, particularly hydrocarbons.

Currently, commercially-available in-drain technologies utilize filtration and/or adsorption
mechanisms. The processes are generally directed to the removal of particulates (and the metals
and organics that may be bound to these particulates), hydrocarbons and other dissolved organics
and organically-complexed metals. Specific units may be suited to a narrow class of
contaminants and marketed as a component of a larger system. This is generally articulated in
the vendor's claims for the equipment.

In-drain technologies are typically comprised of inserts with removable media cartridges, such as
filters, adsorption pads, debris/contaminant traps, etc., and, as such, form the basis for this test
protocol. If new emerging technology alternatives, which may not have been addressed by this
protocol, are proposed for testing, the test plan shall specifically describe the attributes of the
technology and any modifications made to the protocol to accommodate its testing.

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1.2.1	Technology Application

The in-drain treatment technologies are applicable to closed, impermeable, and defined drainage
areas, typically associated with, but not limited to, the following:

•	Garages;

•	Open and covered parking lots;

•	Vehicle wash-down areas;

•	Vehicle maintenance areas;

•	Truck stops;

•	Heavy construction equipment maintenance centers;

•	Gas stations; and

•	Machine shops and scrap storage areas.

Major contaminants typically observed with these applications are hydrocarbons and solids.
Their removal should be the focus of the verification test. In addition, other contaminants of
concern, such as metals, nutrients, and surfactants should be quantified as part of the test plan.

1.2.2	Technology Verification Approach

The protocol for verification of in-drain technologies uses a generic synthesized wastewater to
challenge the offered equipment. The makeup of the wastewater is based on reported experience
and analyses of targeted wastewaters, and covers a broad spectrum of known contaminants. The
Test Unit shall be set-up in a controlled test facility. The wastewater shall be fed to the Test Unit
under hydraulic loading conditions that match the rated capacity of the equipment. Its
performance shall be measured by removal of targeted contaminants. The installation, operation
and maintenance requirements of the Test Unit shall also be quantified.

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2 VERIFICATION TEST PLAN

A detailed test plan shall be prepared before each technology verification. The Testing
Organization will typically prepare this, with the participation of the Vendor. The test plan shall
clearly present how, where, and by whom the testing is to be conducted. The Verification
Organization shall review the Test Plan, offer comments, suggest modifications, and arrange for
its additional review by one or more peer-reviewers. Final EPA and Vendor approval of the Test
Plan shall be obtained before any testing is initiated. The format of the ETV Test Plan shall
follow those offered by the Verification Organization and provide, at a minimum, the following
information.

2.1	TEST PLAN OBJECTIVES

The objectives of the verification test shall be clearly explained, including those identified by the
ETV Program and those claimed or identified by the Vendor.

2.2	PROJECT ORGANIZATION

The organization of the project shall be explained, including staff and management activities.
Firms and individuals assigned to the project shall be identified, and their specific roles
described. Key individuals must be identified, including a brief description of their relevant
experience. General guidelines on the roles and responsibilities for the major parties are
summarized in the following discussions.

2.2.1	Verification Organization

NSF International is the US EPA's Verification Partner and the Verification Organization for
technology verifications performed under the ETV Source Water Protection Pilot. The
Verification Organization's responsibilities shall include:

•	Qualification of Testing Organizations and Laboratories;

•	Coordination of Test Plan reviews by EPA, the Verification Organization, and peer-
reviewers;

•	Coordination of EPA and Vendor approvals of the Verification Test Plan;

•	Oversight of project quality assurance, including on-site audit of test procedures, and
technical system performance and data quality audits, as prescribed in this protocol and in
the Quality Management Plan for the Verification Organization;

•	Coordination of Verification Report peer-reviews; and

•	Preparation, approval, and dissemination of the Verification Report and Verification
Statement in conjunction with EPA.

Note that the Verification Organization may act as the Testing Organization and/or write the
Verification Report.

2.2.2	U.S. Environmental Protection Agency (US EPA)

This protocol was developed with financial and quality assurance assistance from the
Environmental Technology Verification (ETV) Program, which is overseen by the US EPA.
Any Verification Report developed under the ETV Program using this protocol shall be subject

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to the approval of the ORD laboratory director. The US EPA shall have technical and quality
assurance review and approval responsibilities throughout the various phases of an
environmental technology verification, including:

•	Verification Test Plan development;

•	Verification Report development;

•	Verification Statement development; and

•	Posting the Verification Report and Verification Statement on the US EPA web site.

2.2.3	Testing Organization

The Testing Organization must be qualified by the Verification Organization to conduct an in-
drain treatment technology verification project. It shall have direct or comparable experience in
the operation and evaluation of in-drain treatment technologies, in the performance of the various
procedures comprising the protocol, and in the design and performance of pilot studies. The
Testing Organization shall serve as the primary consultant for developing, implementing, and
reporting the verification test. The responsibilities of the Testing Organization shall include, but
not be limited to:

•	Preparing a site-specific Test Plan in conformance with the generic protocol, and revising
the Test Plan in response to comments made during the review period;

•	Coordinating the Test Plan development with the Vendor and the Verification
Organization, including documentation of equipment and facility information and
specifications for the Test Plan;

•	Contracting with sub-consultants and general contractors, as needed, to implement the
test plan;

•	Coordinating and contracting, as needed, with the owner of the test facility, and arranging
the necessary logistics for activities at the test site, including controlling access to the
area where verification testing is being carried out;

•	Maintaining safe conditions at the test site for the health and safety of all personnel
involved in with verification testing;

•	Managing the communications, documentation, staffing, and scheduling activities
necessary to successfully and efficiently complete the verification;

•	Overseeing and/or performing the verification testing per the approved Test Plan; and

•	Managing, evaluating, interpreting, and reporting the data generated during the
verification testing.

2.2.4	In-Drain Treatment Technology Vendor

An ETV is initiated by an in-drain treatment technology vendor by submitting an application to
the Verification Organization. In the case of testing to be performed under the ETV Source
Water Protection Pilot, the application shall be submitted to NSF International. The application
may offer suggested test sites and request a Testing Organization. The Vendor's responsibilities
shall include, but not be limited to:

•	Provide verification testing objectives to be incorporated into the Test Plan;

•	Provide the test unit for verification, including all ancillary equipment, instrumentation,
materials and supplies necessary to operate, monitor, maintain, and repair the system;

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•	Provide documentation and calculations necessary to demonstrate the system's
conformity to commercial systems, hydraulic scalability, and to the requirements of this
protocol;

•	Provide descriptive details of the system, its operation and maintenance, its capabilities
and intended function in in-drain treatment applications;

•	Provide technical support for the installation and operation of the in-drain treatment
system, including designation of technical support staff and of an on-site technician for
training;

•	Review and approve the Verification Test Plan; and

•	Review and comment on the Verification Report and Verification Statement.

2.2.5	Support Organizations

The Test Plan may require support from other organizations, if certain activities cannot be
provided by the Verification Organization, US EPA, Testing Organization, or Vendor. These
activities include, but are not limited to, chemical analyses, instrumentation calibrations,
mechanical construction, electrical installation, and operations. Any contractors brought into the
project shall be subordinate to the Testing Organization and shall be identified as part of the
Verification Test Plan, along with their roles and responsibilities.

2.2.6	In-Drain Treatment Peer-Review Group

The ETV In-Drain Treatment Peer Review Group will serve as a technical and professional
resource during all phases of the verification, including the review of test plans and verification
reports.

2.3 CAPABILITIES AND DESCRIPTION OF THE SYSTEM
2.3.1 SYSTEM DESCRIPTION

In this section, the Testing Organization, with input from the Vendor shall describe in detail all
components of the in-drain treatment system, including the purpose for each component, the
proposed equipment, and its application. This part of the Test Plan must also address the test
unit's conformity with full-scale commercial systems offered by the Vendor.

The test equipment submitted for evaluation by the ETV protocol must be or must closely
simulate the commercial unit offered by the vendor. It will be critical to clearly describe both the
commercial unit and the test unit as part of the test plan, if there is any dissimilarity between the
two. For an example, if the pilot-test equipment is not a full-scale commercial unit, then
discussion of hydraulic scalability must be included in the Test Plan. For this reason, testing of
other than full-scale equipment is not recommended by the ETV Program.

A process flow diagram illustrating the testing facility components shall be provided. Figure 1
presents an example schematic process flow diagram. The diagram shall show all components of
the test facility, including supporting equipment, location of sampling points and flow metering.
The facility description shall clearly delineate the test equipment components that are being
verified and those that are being provided through the vendor and others to support the test
facility. In addition, the following information shall be included:

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•	Detailed dimensional drawings of the equipment showing all components;

•	A detailed description of physical characteristics of the equipment including its weight
and size;

•	A detailed drawing of the equipment layout;

•	Utility requirements such as water and electricity;

•	Identification of any special permitting requirements associated with the operation of the
equipment, if appropriate; and

•	Wastewater disposal method. The Test Plan shall state the method for disposal and verify
that it is a permitted practice for the site.

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Figure 1 - Example Schematic Process Flow Diagram

Sampling
Point (SP1) to
Composite
Sampler

Sampling
Point (SP2) to
Composite
Sampler

2.3.2 SYSTEM CAPABILITIES

Statements shall be made in the Test Plan regarding the appropriate applications for the
equipment, its capabilities, limitations, and potential advantages. The statement of capabilities
forms the basis of the equipment verification testing and should be chosen carefully. The
statement of capabilities shall include, but not be limited to, the following:

•	Contaminant(s) that can be removed or reduced by the candidate technology;

•	Suitable applications for the technology;

•	The operating envelope in terms of flow and contaminant loading;

•	Instrumentation and control requirements;

•	Equipment installation requirements;

•	Operation and maintenance requirements, including replacement of treatment medium;
and

•	Residuals management, including options for disposal.

Both quantitative and qualitative performance measurements shall be evaluated to assess the
system capabilities. The procedures for obtaining these measurements are described in Section
3.

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2.4	EXPERIMENTAL DESIGN

The overall conceptual approach to the technology verification, including its compliance with the
generic protocol, shall be summarized. The approach shall clearly describe the test, test location,
and treatment component(s) that will be incorporated into the test facility. Any deviation from
the generic protocol shall be highlighted and discussed, including justification for the alternative
approach.

Reference is made to Section 4 for a detailed discussion of the experimental design. Within this
framework, a Sampling and Analysis Plan (Section 5) must be prepared in support of the
Experimental Design. This must address the procedures that will be followed for sampling, and
references for all analytical methods. All monitoring equipment and instrumentation shall be
described.

2.5	HEALTH AND SAFETY PLAN

The Verification Test Plan shall include a Health and Safety Plan, which addresses safety
considerations that are appropriate to the test site, the equipment being tested, and storage,
handling, and disposal of wastewater and residuals.

2.6	QUALITY ASSURANCE PROJECT PLAN (QAPP)

The Test Plan shall include a QAPP that specifies procedures to be used to ensure data quality
and integrity. This should follow the generic outline presented separately in Section 6.

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3 PERFORMANCE MEASUREMENTS

The performance objective of in-drain treatment technologies is to generate an effluent quality
that meets local, state, or federal discharge limits to a receiving body of water or the discharge or
pretreatment requirements of a local Publicly Owned Treatment Works (POTW). The
performance capabilities of the test equipment shall be quantitatively and qualitatively measured
as discussed below, and presented in the Verification Report and Statement. This shall also
compare the observed performance measures against the vendor claims and within that context,
discuss some potential applications of the equipment.

3.1	SYSTEM/COMPONENTS OPERATION AND MAINTENANCE (O&M)

The performance of the overall system and/or its components shall be measured by its range of
operation and level of maintenance. The range of operation can be determined by hydraulics and
mass removal of contaminants. The hydraulic capacity of the treatment system shall be
measured by its hydraulic loading rate in volume of treated water/volume of medium or
treatment volume, or volume of treated water/mass of treatment medium. Similarly, the mass
removal of a contaminant shall be measured in mass of contaminant removed/volume of medium
or treatment volume and/or mass of contaminant removed/mass of treatment medium.

In-drain technologies are generally expected to be passive, with minimal direct handling during
their operational life cycles, except to the extent that a technology needs to be maintained. The
system and its components shall be qualitatively measured by the level of maintenance required.
The level of maintenance can be assessed by the relative ease of maintenance, and how often and
how long the maintenance is required. This can be quantified by estimating the hours necessary
for training and for specific maintenance tasks. The specifics of the O&M manual, access to
pertinent parts of the system, and the number of parts for maintenance are factors included in
assessing the test unit's maintenance requirements. The Verification Test Plan shall address the
treatment medium, including installed indicators that alert users when to replace it, medium
maintenance during operation (with or without flow), cleaning of clogged medium, gathering of
loose elements of medium if dispersed, and other procedures and/or claims appropriate to the
specific test equipment. In addition, the operation of instrumentation and controls, if they are
part of an in-drain system, shall be described in detail.

3.2	CONTAMINANTS THAT CAN BE REMOVED OR REDUCED

As part of the Test Plan, the statement of capabilities shall name the contaminant(s) that will be
tested for removal or reduction by the proposed technology. These are the "targeted
contaminants". As a performance indicator, the level of removal of these targeted contaminants
must be analyzed. In addition, a number of ancillary, or "secondary contaminants" that may or
may not be affected by the technology, but are still of concern, shall also be analyzed. The
combined lists of "targeted" and "secondary" contaminants comprise the "contaminants of
concern." These generally encompass a practical listing of contaminants that can be found with
the targeted applications (see Section 1.2.1. The following is a list of potential contaminants of
concern.

• Hydrocarbon Related:

> Total Petroleum Hydrocarbon (TPH)

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>	Total Organic Carbon (TOC)

>	Oil & Grease (O&G)

>	Benzene, Toluene, Ethylbenzene, and Xylene (BTEX)

>	Total Phenol

>	Methyl tertiary butyl ether (MTBE)

•	Total Suspended Solids (TSS)

•	Heavy metals: Al, Cd, Cr, Cu, Fe, Pb, Zn

•	Surfactants (MBAS)

•	Chemical Oxygen Demand (COD)

•	Nutrients:

>	Phosphate (PO4-P)

>	Total Kj eldahl Nitrogen (TKN)

>	Ammonia (NH3 -N)

>	Nitrates (NO3-N)

All of the above are potential contaminants or measures of contaminants generated from washing
vehicles, or found in floor areas of auto body shops, machine repair shops, or in the residue in
parking garages or other automotive traffic areas. The hydrocarbon related contaminants, solids,
metals, and surfactants are typically major targeted contaminants for in-drain treatment
applications. On the other hand, nutrients are likely to be found in measurable quantities and are
parameters of concern for source water protection. COD is a bulk parameter that is easy and
quick to analyze, can be used as a measure of general organic contaminant removal, and may be
appropriate for long-term system performance monitoring.

Note that in certain cases, the in-drain device may have been designed to trap and remove
floatable materials such as leaves, sticks, paper litter, etc. If this is a specific claim for the
device, the wastewater matrix constructed for the Verification Test shall include introduction of a
floatables matrix and measurement of its removal through the device. The Test Plan shall
address the claim, the matrix composition and any special sampling that would be directed to
quantifying floatables removal through the Test Unit.

All contaminants of concern must be included in the sampling and analysis plan for monitoring
and quantifying the performance of the proposed test equipment. The Test Plan must state which
contaminants of concern are targeted by the technology and which are secondary to its
performance.

3.3	EFFLUENT QUALITY THAT CAN BE ACHIEVED

As essential performance measurements, the effluent concentrations of the targeted contaminants
must be measured. In addition, although not claimed by Vendor, the removal of secondary
contaminants must be analyzed and reported. The analysis for both targeted and secondary
contaminants will help in understanding the full capability of the tested technology.

3.4	QUANTIFICATION OF RESIDUALS

The in-drain treatment technologies will generate residuals, including the removed contaminants,
spent media inserts, traps, etc. The quantity of residuals for disposal shall be a factor in

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performance measurement. Examples of residual quantification may include the total mass and
volume of residuals, mass of residual disposed per volume of water treated, and mass of residual
disposed per mass of a specific contaminant removed. The Test Plan shall include the
quantification of equipment related residuals, such as media inserts and traps, that must be
disposed or serviced. This shall be in terms of replacement or servicing rates as a function of the
quantity of water treated and/or mass of contaminant removed. The Test Plan and Verification
Report shall present a discussion of the handling of these residuals and their ultimate disposal.

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4 EXPERIMENTAL DESIGN

The experimental design defines the technical approach to verify the stated capabilities of the
treatment system. It includes test conditions, measurement requirements, and data quality
indicators for verification testing. Standard Operating Procedures (SOPs) for testing equipment
and procedures should be presented with the experimental design and incorporated into the Test
Plan.

The verification test of in-drain treatment technologies will be a controlled pilot test, in which a
known synthesized wastewater will be used as feed water. The use of the synthetic wastewater
has several advantages, including independence from the application site, and control with
respect to quantity and quality.

Because the use of synthetic wastewater is independent of a test site, the test can be conducted
virtually anywhere. The test site shall be large enough to accommodate the test equipment, and
utilities such as water and electricity shall be readily available. One potential test location is a
POTW. Pilot testing would not be conspicuous and the plant would allow for direct discharge of
effluent. Certainly, this would be dependent on the characteristics of the discharge, but one
would expect that the relatively minor flows from the pilot unit could be discharged to the
headworks of the WWTP. It shall be verified that the POTW is large enough to handle the
discharges from the test unit without any significant impact on plant operations or performance.
Other test sites can be offered by the Testing Organization. In all cases, there must be written
approval by the site owner, if different from the Testing Organization, and the testing must be in
conformance with all permits and discharge requirements associated with the site.

The amount of wastewater generated at the targeted application sites such as garages and truck
stops is typically not high, as it excludes stormwater runoff and is confined to the area or
operation serviced by a single drain. In addition, it is characterized by intermittent flow. By
using a synthesized wastewater, the feed wastewater would always be available for testing, and
in sufficient volume. This significantly reduces the required testing period.

The fact that synthetic wastewater is not a real wastewater may be viewed as a disadvantage.
However, given the wide variation in wastewater quality that is associated with the potential
application sites, one can also understand that there would be difficulty in identifying a
"representative" site. Using a carefully constructed wastewater, with characteristics that can
represent multiple applications, offers both flexibility and reproducibility to the verification test.
Vendors' specific claims can be directly quantified across a broad spectrum of contaminants in
an efficient and cost-effective manner, and users have a consistent benchmark for the selection of
appropriate technologies. These factors outweigh the fact that the test is not being performed
under "real-time" conditions.

The Testing Organization and Vendor can offer an alternative direct site application to conduct
the verification test. The Test Plan must clearly state the justification for such a site in
comparison to the controlled test, and must address the contaminants of concern included within
this protocol.

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4.1	EXPERIMENTAL SET-UP - TEST FACILITY

The Testing Organization shall provide a complete description of the test site and amenities to
the project, the test equipment and the experimental setup. These shall be in the form of
equipment specifications, layouts, sizing calculations and engineering drawings. In general, as
discussed earlier, the Verification Test will be conducted under a controlled condition using an
engineered test facility. An example-schematic of such a facility is provided in Figure 1.

4.2	TEST PHASES

The primary operational characteristics of the targeted in-drain technology shall be addressed
within the experimental design. These shall include, but need not be limited to:

1.	Performance under intermittent flow conditions;

2.	Performance at different hydraulic loadings, including at peak flow;

3.	Performance at different contaminant loadings, including at peak concentration of
targeted contaminants;

4.	Capacity of the equipment with respect to contaminant mass; and

5.	Maintenance logistics with respect to cleanout and/or insert replacement.

The Test Plan shall address these performance and operational elements, and others that may be
identified by the Verification Organization, USEPA and Testing Organization, or claimed by the
Vendor at the time of application for an ETV. A phased testing approach shall be used, allowing
for isolation and direct testing of the specific verification objectives. To assure that sufficient
data are obtained, the Testing Organization must clearly provide a sampling and analysis
program for each test element and the schedule for testing.

Four phases of testing shall be included in the Test Plan, unless otherwise offered by the Testing
Organization and approved by the Verification Organization. The following is a generic outline
of these Test Phases, assuming that the technology involves a filtration/adsorption-type medium
insert. Modifications and rearrangement of these Test Phases can be made and presented in the
specific Test Plan; the following is meant to identify test elements that should be addressed in the
Test Plan.

Test Phase 1. Performance Under Intermittent Flow Conditions

In Phase 1, the system shall operate intermittently to simulate actual in-drain treatment
applications. Phase 1 shall consist of an alternating sequence for a one-week (5-day) period: an
8-hour-on/16-hour-off cycle. When the system is "on", there is normal flow through the system,
simulating the operating or active period for a possible facility, while the system's "off period
represents no flow and no activity, that is, the system is at "rest". The normal flow is defined as
typical average flows intercepted by the in-drain treatment technology, as determined by the
Testing Organization and claimed by the Vendor. It is recommended that during this on cycle
the flow should be at a constant, predetermined rate, but intermittent; for example, flow for 15
minutes and no flow for 15 minutes. The flow should be from a well-mixed feed tank, with the
wastewater adjusted to known targeted characteristics, as discussed in Section 4.2. The flow rates
shall be measured and cumulative volumes treated shall be recorded. The flow should be
introduced to the test unit in a manner that reflects actual operating conditions. Thus, if the flow
is normally introduced by gravity from an overhead floor drain, then the test configuration

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should be configured as such. The Test Plan shall demonstrate how the test unit simulates proper
field-scale installations. Sampling shall be conducted on the influent once per day at minimum,
while a flow-proportioned effluent sample shall be accumulated for each 8-hr operating period
during the 5-day period. Additionally, one-hour composites shall be collected every hour in the
eight-hour period on two days and measured for TSS and COD, at minimum. Physical
observations shall be made regarding the operation of the equipment. These should include head
losses through the media, the appearance of discoloration, debris accumulation (if included as
part of the wastewater matrix), oil sheens, and possible release of contaminants (e.g., solids and
oils) during a transition from no-flow to flow. Head loss measurements can be elevation
differentials, if appropriate, or simple manometers can be placed in the upstream flow stream.
The Test Plan shall detail the method to be used for head loss measurements.

Test Phase 2. Determination of the Capacity of the Equipment

In Phase 2, the objective is to operate the system to "exhaustion", as defined by the need to
replace the medium insert and/or to perform clean-out maintenance of the equipment. The
system shall be operated in a continuous mode, 24-hours per day during this phase until the
maximum amount of contaminant(s) have been filtered/adsorbed by the treatment medium, and
performance fails. By changing the flow mode from intermittent to continuous, the use of the
medium is accelerated, which facilitates reaching exhaustion in a reasonable amount of time.

If the test unit uses a media insert, the same media insert as used in the first test phase may be
continued through this phase. The insert shall have been characterized as to weight (dry- and
drained-wet weights) before any testing or operations began in the first Test Phase. Otherwise,
the equipment itself shall be thoroughly cleaned and a new, pre-weighed insert shall be installed.
The Test Plan shall clearly indicate this procedure.

The flow rate through the system during Test Phase 2 shall be at the rated flow of the test unit, as
determined and specified in the Test Plan by the Testing Organization and Vendor. The feed to
the system shall be the mixed synthesized wastewater, with continuous recording of flow rate
and cumulative feed volume. Effluent sampling during this period shall be regularly scheduled,
representing performance at progressively higher cumulative treated volumes (for example,
every 5,000 or 10,000 gallons of water treated). Analysis shall include the targeted contaminants
on a regular basis, and the full listing of contaminants of concern on a limited number of samples
(at minimum this shall be at the beginning and end, and at some representative intermediate
point). The influent mixture shall be measured for all contaminants at least twice and more
frequently for TSS and COD, at minimum. The sampling and analysis shall include daily
influent and effluent monitoring for TSS and COD. The complete sampling plan shall be
described in the Test Plan.

Throughout this Test Phase, observations shall be regularly made and recorded with respect to
head loss through the system; appearance of the media and unit with respect to discoloration,
debris, oil sheen, and other visible characteristics; clogging of all or a portion of the media; flow
patterns and evidence of short-circuiting; and other conditions as may be identified in the Test
Plan.

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The determination of when media exhaustion and/or the need for change-out or cleaning occurs
shall be established in the Test Plan, with assistance from the Vendor and the O&M manual. In
addition, quantification of such conditions shall be recorded. At minimum, the drained wet
weight of the filtration/adsorption media insert shall be measured, and any accumulated debris
removed from the equipment upon cleanout. This accumulation of weight in the media and or
traps can then be related to the volume of water treated and the removals determined from the
influent and effluent sampling.

The Test Plan shall present the methods that will be used to characterize the spent inserts, the
maintenance efforts associated with the changeout and cleaning, and the disposal of the residuals
generated from the equipment's operations. The methods for determining media exhaustion
and/or the need for change-out or cleaning shall be compared with the Vendor's product
literature and/or O&M manual for the technology.

Test Phase 3. Performance Under Varied Hydraulic and Concentration Loading

In this phase, the testing shall center on the device's ability to handle hydraulic throughput, and
the impact of spike increases in contaminant concentration. This Test Phase shall be conducted
in three parts, each of which can likely be conducted in one day. Since the treatment medium
has been spent in Phase 2, a new treatment medium shall be inserted at the beginning of Phase 3.

Part 1. Hydraulic Throughput with Clean Water

In the first part of this test phase, clean water shall be used, and, the flow rate shall be
progressively increased to test for hydraulic throughput capacity. Based on the statement of
capability, the system shall be started at approximately one-half the vendor-rated average
operating flow rate. Progressive increases in flow rate shall then be made (for example, at steps
that are 25 percent higher than the preceding step). At each step increase, allow the system to
stabilize (this can be done by allowing about 10 volume changes), and then record the head loss
through the system, and observations with respect to flow patterns and any evidence of short-
circuiting. The Test Plan shall provide the method for measuring the head loss through the unit.
The step flow increases should be continued until there is evidence of flooding due to excessive
headloss. In effect, flooding will occur at the drain because the unit is no longer capable of
passing the liquid at the given flow rate.

Part 2. Hydraulic Throughput with Wastewater Matrix

The feed water shall then be switched to the synthesized wastewater matrix, and the entire
progressive-hydraulic-throughput test repeated. At each step increase, allow time (e.g.,
equivalent to 10 volume changes) for the system to adjust to the new flow and then sample the
effluent, in addition to the flow, headloss and other observations discussed earlier. The effluent
should be analyzed for COD and TSS, at minimum (other targeted contaminants may be
included, depending on the effort and costs). The objective is to demonstrate the impact of the
progressive increases in throughput rate (and consequent decreases in retention time) on removal
efficiency.

Part 3. Impact of Spike Increases in Concentration

Due to spills or other variances in activities, contaminant spikes will likely occur. This will be
tested in the Verification by selecting specific target contaminants (for example, petroleum

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hydrocarbons) and spiking the feed matrix with these contaminants by a predetermined factor.
This factor shall be four, or as otherwise specified and approved in the Test Plan. Once the feed
matrix has been adjusted, the same progressive hydraulic throughput test shall be conducted, and
effluent samples collected. The samples can then be analyzed for the spiked contaminants. The
intent is to gain an understanding of impact of the higher concentrations on removal efficiencies,
coupled with variable retention times.

Test Phase 4. Contaminant Capacity at Higher Hydraulic Throughput

Test Phase 4 is a replicate of Test Phase 2, except that the system shall be operated in a
continuous mode at the maximum acceptable flow rate determined in Phase 3. This shall be 85
percent of the highest flow rate demonstrated in Part 2 of Phase 3 that can be accepted by the
system without flooding. Similar to Phase 2, the saturation of the treatment medium will be
tested. Since the flow rate is much higher than that of Phase 2, the time to exhaustion should be
faster. The same testing and monitoring protocols delineated for Phase 2 should be applied to
Phase 4.

4.3 INFLUENT CHARACTERIZATION

The verification test shall be conducted under controlled conditions using a synthesized
wastewater. As such, the characteristics of the synthetic contaminant matrix that is to be diluted
with clean water are critical. To closely simulate actual wastewater characteristics, the synthetic
contaminant mixture should come from actual products that may contribute to the wastewater.
Based on expectations for typical in-drain treatment applications, the following readily available
products can be used to formulate the synthetic contaminant mixture:

•	Regular unleaded gasoline, with MTBE additive;

•	Truck diesel fuel;

•	10W-30 motor oil;

•	Brake fluid;

•	Antifreeze/coolant (glycol based);

•	Vehicle washing detergent;

•	Windshield washer fluid; and

•	Standard soil of various grain sizes.

The gasoline, diesel fuel, motor oil, brake fluids, and antifreeze/coolant are contributors to
hydrocarbon contamination, while detergents and washer fluids will generate surfactants.
Certain products will also contain nutrients, in the form of organic nitrogen compounds,
ammonia, and/or phosphate. In real applications, emulsified dirt and grime washed from trucks,
automobiles, and floors of garages produce suspended solids. Unfortunately, such dirt is not a
product that can be bought or easily synthesized. Therefore, standard soil of various grain sizes
shall be used instead.

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The standard soil mixture shall include the following:

•	Sand (33.3% by weight);

•	Silt (30.0% by weight)

•	Top soil (21.0%) by weight)

•	Clay (15.7%o by weight)

Montmorillonite (5.7%)

Kaolinite (10.0%)

As a guideline, Table 1 lists suggested characteristics of the synthesized feed wastewater.
Suggestions for alternative characteristics may be offered to the Verification Organization prior
to finalizing the Test Plan. According to vendors, a typical oil and grease concentration in in-
drain treatment applications is about 100 mg/L. An approximate BTEX concentration in
gasoline has been pro-rated to the oil & grease concentration in synthetic wastewater. Estimates
of surfactants from windshield washer fluids and vehicle wash detergents have been also
included. The COD, TSS, phenols, PO4, TKN, and NH3 levels are concentrations found in
commercial paved parking lots. The heavy metal concentration data are from a car wash facility,
and include those metals normally found in traffic areas.

Table 1 - Suggested Synthetic Wastewater Characteristics

Parameter

Concentration

TPH

120 mg/L

TOC

100 mg/L

Oil & Grease

100 mg/L

Benzene

5 mg/L

Toluene

7 mg/L

Ethylbenzene

< 1 mg/L

Total Xylenes

6 mg/L

Total Phenols

10 mg/L

MTBE

7 ng/L

Total Suspended Solids

300 mg/L

Total Metals (A1 + Cd + Cr + Cu + Fe + Pb + Zn)

9 mg/L

Surfactants (MBAS)

10 mg/L

COD

200 mg/L

PO4-P

1 mg/L

TKN

5 mg/L

NH3-N

1 mg/L

The Test Plan shall provide the formulation of the wastewater matrix for testing, and shall
include demonstration of the expected characterization by direct analysis of the matrix, based on
the prescribed makeup. The characterization of an acceptable matrix shall be within a range of
plus or minus 50 percent of the suggested averages given in Table 1. With the exception of the
standard soil, the Testing Organization and Vendor are encouraged use real wastes in place of the
commercial products listed above to formulate this matrix. Sources of real wastes may include
waste diesel and motor oils from an automotive repair shop or oil recovery facility, spent
washwaters from a truck washing operation or car wash, and spent cutting oils from a machine

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shop. These can be collected in sufficient quantity such that, upon combination and dilution,
they will be more than adequate for the full ETV verification test (all phases). Initial testing
within the Test Plan development phase of the Verification is advised. In the case of either using
commercial products or appropriate wastes, dilute solutions of the major inputs (e.g., 100:1
aqueous dilution of a gasoline or detergent) can be analyzed for the key parameters. These data
can then be used to derive the formulation for the stock mixture.

In addition to quality characterization, flow characterization of influent will also be required. A
flow meter in the influent line, with a totalizer, will provide the necessary flow information.
Details of flow monitoring methods, calibration procedures, and data editing and evaluation
procedures shall be documented in the Test Plan.

4.4	EFFLUENT CHARACTERIZATION

As described in Section 3.3, the effluent quality of the targeted contaminants and the secondary
contaminants, as identified by the Vendor and Testing Organization in the Test Plan, shall be
determined and reported.

4.5	RESIDUALS MANAGEMENT

In-drain treatment technologies will produce residuals, in the form of spent filtration and/or
adsorption treatment media, and any debris trapped by the device. The residuals shall be
quantified as a part of its performance measurement (see Section 3.4). Before its disposal, a
sample of the spent medium residual shall be tested using the Toxicity Characteristic Leaching
Procedure (TCLP)13 to determine its classification.

4.6	OPERATION AND MAINTENANCE (O&M)

The Testing Organization shall be responsible for the operation of the system. As a part of the
Test Plan, a procedure for routine checks shall be developed. A log of daily activities, including
the time and date of all events, shall be maintained.

An O&M manual shall be provided by the Vendor with the equipment. The manual shall
include, but not be limited to:

•	Clear and concise recommendations for procedures related to proper operation of the in-drain
treatment systems and equipment, including startup and shutdown procedures;

•	Clear and concise procedures for performing maintenance on the system and its components,
including the replacement and/or cleaning of the treatment medium insert, if used;

•	A list of spare parts to be kept on hand, if required;

•	A list of special tools and equipment; and

•	Disposal requirements.

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5 SAMPLING AND ANALYTICAL PLAN

The Test Plan shall include a Sampling and Analysis Plan in conformance with the specific
experimental design for the Verification Test. The primary objective of a sampling and analysis
plan is to obtain representative data that accurately reflect the treatment and operating
performance of the technology being tested. The plan shall include:

•	Selection of field sampling and flow monitoring equipment and their operational
parameters, as appropriate;

•	Selection of sampling and analytical methodologies;

•	Sample types, numbers, quantities, handling, packaging, shipping, and custody, if
applicable;

•	Sampling location, storage, and holding times;

•	Requirements for field and laboratory QA/QC activities;

•	Protection of health and safety of test personnel;

•	Data reporting requirements; and

•	Methods for validating and verifying the data.

5.1	CHAIN OF CUSTODY

An essential part of any sampling/analytical plan is ensuring the integrity of the sample from
collection to data reporting. The possession and handling of samples shall be traceable from the
time of collection through analysis and final disposition. To establish the documentation
necessary to trace sample possession from the time of collection, a chain-of-custody record shall
be filled out for and accompany every sample. The Test Plan shall provide sample forms and
outline procedures for adequate chain-of-custody tracking.

5.2	SAMPLING LOCATIONS

As shown in Figure 1, the example test facility includes two aqueous sampling locations: SP1
and SP2. SP1 (Sampling Point 1) represents the influent stream to the in-drain treatment system
and is the combined stream of clean water and synthetic contaminant mixture. SP2 (Sampling
Point 2) represents the effluent from the in-drain treatment system. At each of these locations,
an automatic composite sampler shall be provided.

5.3	SAMPLING FREQUENCY

The sampling plan shall detail the number and type of samples to be collected, as dictated by the
experimental design of the Verification Test. For targeted contaminants, frequent sampling and
analysis shall be required. For all secondary contaminants, less frequent sampling and analysis
will suffice and shall be indicated in the site-specific Test Plan. When the test phase is in
intermittent flow mode (8-hour-on / 16-hour-off), an 8-hour composite sample during the "on"
period shall be collected. When the test phase is in continuous flow mode, a 24-hour composite
shall be collected. Oil and grease (O/G) and volatile organic compounds (TPH and BTEX)
samples shall be grab samples, collected at the end of a particular operating or compositing
period.

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5.4 SAMPLE PRESERVATION AND STORAGE

Special precautions are necessary for samples containing organic compounds and trace metals.
Because many constituents may be present at low concentrations, they may be totally or partially
lost or easily contaminated when proper sampling and preservation procedures are not followed.
A summary of special sampling and handling requirements for targeted and secondary
contaminants is provided in Table 2.

Table 2 - Summary of Special Sampling and Handling Requirements

Determination

Container

(1)

Min. Sample
Size, mL

Sample
type (2)

Preservation (3)

Max.

Holding

Time

TPH

G

1000

g

Refrigerate, add H2S04 to pH < 2

28d

TOC

G (B)

100

g,c

Add H2S04 to pH < 2

14d

Oil & Grease

G

1000

g

Refrigerate, add H2S04 to pH < 2,

28d

BTEX

G, PTFE-
lined cap

4x40

g

Collect with no head space. Add HC1
to pH < 2, add 1000 mg ascorbic
acid/L if residual chlorine present,
refrigerate

14d

Phenol

P,G, PTFE-
lined cap

500

g,c

Refrigerate, add H2S04 to pH < 2

28d

MTBE

G, PFTE-
lined cap

4x40

g

Collect with no head space. Add HC1
to pH < 2, add 1000 mg ascorbic
acid/L if residual chlorine present,
refrigerate

14d

Solids (TSS)

P,G

100

g,c

Refrigerate

7d

Surfactants
(MBAS)

P,G

250

g,c

Refrigerate

48h

Metals, general

P(A), G(A)

1000

g,c

For dissolved metals filter
immediately, add HN03 to pH < 2

6 mth

COD

P,G

100

g,c

Add H2S04 to pH < 2; refrigerate

7d

Phosphate

P,G

100

g,c

Add H2S04 to pH < 2; refrigerate

28d

TKN

P,G

500

g, C

Refrigerate, add H2S04 to pH < 2

28d

Ammonia

P,G

500

g,c

Refrigerate, add H2S04 to pH < 2.

28d

Notes:

1)	P = plastic (PE or equivalent), G = glass, G(A) or P(A) = rinsed with 1 + 1HN03; G(B) = glass, borosilicate

2)	g = grab, c = composite

3)	Refrigerate = storage at 4°C + 2°C; in the dark; analyze immediate = analyze usually within 15 min of sample
collection

5.5 ANALYTICAL METHODOLOGY

The analytical methodology shall follow the most recent version of EPA's "Methods and
Guidance for Analysis of Water". Where EPA does not provide an analytical method, standard
procedures such as "Standard Methods for the Examination of Water and Wastewater, 20th
Edition" shall be used. Table 3 lists parameters for analysis and recommended analytical
methods.

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Table 3 - Parameters for Lab Analysis and Analytical Methods

Parameter

5.5.1.1.1 Methodology

TPH

EPA 1664A SGT-HEM

TOC

EPA 415.2

Oil & Grease

SW846-1664

BTEX (benzene, toluene, ethylbenzene, xylene)

EPA 502.2, 524.2

Phenol

EPA 420.4

MTBE

EPA 502.2, 524.2

Total Suspended Solids (TSS)

EPA 160.2

Heavy Metals: Al, Cd, Cr, Cu, Fe, Pb, Zn

EPA 200.7, 200.8, 200.9

Surfactants

EPA 425.1

COD

EPA 410.4

PO4-P

EPA 365.2

TKN

EPA 351.2

NH3-N

EPA 350.1

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6 QUALITY ASSURANCE PROJECT PLAN (QAPP)

Every Test Plan developed for a technology verification shall include a Quality Assurance
Project Plan (QAPP). The QAPP for this verification testing specifies procedures that shall be
used to ensure data quality and integrity. Careful adherence to these procedures will ensure that
data generated from the verification testing will provide sound analytical results that can serve as
the basis for performance verification.

6.1	PURPOSE AND SCOPE

The purpose of this section is to outline steps that shall be taken by operators of the equipment
and by the analytical laboratory to ensure that data resulting from this verification testing are of
known quality and that a sufficient number of critical measurements are taken.

6.2	QUALITY ASSURANCE RESPONSIBILITIES

The Testing Organization shall prepare a QAPP for the verification test, to be included in the
Test Plan, that specifies procedures to be followed to ensure the validity of test results and their
use as the basis for equipment performance verification. The QAPP applies to all organizations
involved in the Equipment Verification Testing, including the Testing Organization and
laboratories qualified by the Verification Organization. The Testing Organization, having been
qualified by the Verification Organization and with the Verification Organization's oversight,
shall have the primary responsibility for ensuring that the QAPP is implemented during the
verification testing activities. Both the Vendor and the EPA Pilot Manager, for evaluations
under the Environmental Technology Verification Program, must approve the entire test plan,
including the QAPP, before the verification testing can proceed.

If problems arise or any data appear unusual during the course of verification testing, they shall
be thoroughly documented and corrective actions shall be implemented, as specified in the
QAPP.

6.3	CONTENTS OF THE QAPP IN TEST PLAN

The Testing Organization shall be responsible for including the following elements in the QAPP:

•	Description of methodology for measurement of accuracy and precision;

•	Description of the methodology for use of blanks, the materials used, the frequency, the
criteria for acceptable method blanks, and the actions to be taken if criteria are not met;

•	Description of any specific procedures appropriate to the analysis of the performance
evaluation samples. It has to be clear how these samples are going to be used in the
verification testing;

•	Outline of the procedure for determining samples to be analyzed in duplicate, the
frequency, and approximate number;

•	Description of the procedures used to assure that the data are correct;

•	Listing of equations used for any data quality indicator calculations;

•	Development of a corrective action plan in the test plan;

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•	Provision of all QC information such as calibrations, blanks and reference samples in an
appendix. All raw analytical data shall also be reported in an appendix; and

•	Provision of all data in hard copy and electronic form in a common spreadsheet or
database format.

6.4 QUALITY CONTROL CHECKS

Quality control checks provide a means of measuring the quality of data produced. The checks
to be used in the Verification shall be stated and their selection justified with respect to the
equipment, experimental design, and performance goals.

6.4.1	Quality Control for Equipment Operation

This section shall explain the methods to be used to check on the accuracy of equipment
operating parameters and the frequency with which these quality control checks shall be made.
An essential aspect of the technology verification testing program is to provide acceptable and
verifiable operating results. Examples may include a secondary method for flow measurement
(alternate meter, dilution method), a reference pressure gauge, etc.

6.4.2	Water Quality Data

The quality of water sample analytical results is as important as the quality of the equipment
operating data. Important aspects of sampling and analytical QA include:

•	Duplicate Samples: Duplicate samples shall be collected at specified frequencies in
order to document precision. The precision resulting from duplicate samples is a
function of the variance of water composition, of the sampling and analytical techniques.
The number of duplicate samples shall be specified in the Test Plan and shall comprise at
least one for every 20 samples collected. The actual number of duplicates shall depend
on the frequency of analysis and the approximate number of samples.

•	Field Blanks: Field blanks should be collected at specified frequencies, which will vary
according to the probability of contamination or cross-contamination. Field blanks are
often metal and/or organic-free water aliquots that contact sampling equipment under
field conditions and are analyzed to detect any contamination from sampling equipment,
cross-contamination from previously collected samples, or from conditions during
sampling (e.g., airborne contaminants).

6.4.3	Data Quality Indicators

The data obtained during the verification testing must be of sound quality for conclusions to be
drawn on the equipment. Data quality parameters shall include four indicators:

•	Accuracy: combination of bias and precision of an analytical procedure, which reflects
the closeness of a measured value to a true value.

•	Bias: consistent deviation of measured values from the true value, caused by systematic
errors in a procedure.

•	Precision: a measure of the degree of agreement among replicate analyses of a sample
usually expressed as the standard deviation.

•	Representativeness: the degree to which the data accurately and precisely represent the
	conditions or characteristics of the parameter represented by the data.	

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6.5 DATA REDUCTION, VALIDATION, AND REPORTING

To maintain good data quality, specific procedures shall be followed during data reduction
validation, and reporting. These procedures are detailed below.

6.5.1	Data Reduction

Data reduction refers to the process of converting the raw results from the equipment test into a
form that can be used to evaluate the performance and operating characteristics of the system.
The procedures to be used will be equipment dependent. The purpose of this step is to provide
data that shall be used to verify the statement of performance capabilities. These data shall be
obtained from logbooks, instrument outputs, and computer outputs as appropriate.

6.5.2	Data Validation

The Testing Organization shall verify the completeness of the appropriate data forms and the
completeness and correctness of data acquisition and reduction. In addition, calculations and
laboratory logbooks and data sheets will be reviewed to verify accuracy and completeness. The
individual operators and the laboratory supervisor shall examine calibration and QC data.
Laboratory and project managers shall verify that all instrument systems are in control and those
QA objectives for accuracy, completeness, and method detection limits have been met.

Analytical outlier data are defined as those QC data lying outside a specific QC objective
window for precision and accuracy for a given analytical method. Should QC data be outside of
control limits, the analytical laboratory or field team supervisor shall investigate the cause of the
problem. If the problem involves an analytical problem, the sample shall be reanalyzed.

If the problem can be attributed to the sample matrix, the result shall be flagged with a data
qualifier. This data qualifier shall be included and explained in the final analytical report.

6.5.3	Data Reporting

The results of the entire verification testing process shall be presented in a Verification Report.
The report shall include all results from influent and effluent water quality analyses from in-drain
treatment technology start-up to the conclusion of the verification testing, including all
monitoring and maintenance activities and any changes in performance over time. All QC
information such as calibrations, blanks and reference samples are to be included in an appendix.
All raw analytical data shall also be reported in an appendix. Refer to Section 7.3 for additional
information on reporting requirements.

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7 DATA MANAGEMENT AND DOCUMENTATION

Verification testing will generate a significant amount of data/records. Data to be generated by
verification testing include, but are not limited to, water and wastewater flow data, wastewater
quality data, treatment performance of the in-drain treatment technology under specific operating
conditions, and O&M parameters. Records consist of both paper and electronic data. Paper
records such as field notebooks, bench sheets, field data sheets, custody sheets, and instrument
printouts are part of the raw data test record.

7.1 GENERATED DATA

The types of data generated from the Verification Test are both quantitative and qualitative.
Flow rates at specified time intervals are examples of quantitative data, while observations of the
treatment medium, such as its appearance and potential clogging problems, are examples of
qualitative data. In addition, the data may be classified as raw or analyzed/calculated data. Raw
data are obtained directly from the test unit, such as flow rates, pressures, and concentrations of
contaminants of concern. Analyzed or calculated data are obtained from mathematical analysis
transformation of raw data. An example is the computed hydraulic loading rate, in Lpm/m3.

In the Verification Report, all types of data (qualitative, quantitative, raw, and
analyzed/calculated) shall be presented. When possible, tabular and graphical formats should be
used for clarity and ease of presentation. It is suggested that data be ordered chronologically and
by test phase.

Examples of generated data for verification testing in-drain treatment technologies are:

•	Raw data:

>	Flow rate and cumulative flow rate

>	Headloss data

>	Influent and effluent concentrations of contaminants of concern

>	Handling of the treatment medium, e.g., appearance, clogging problems, etc.

>	Flow pattern, e.g., short-circuiting

>	Maintenance record

•	Analyzed/Calculated data:

>	Hydraulic capacity

>	Mass removal for contaminants of concern

>	Residuals management

7.1.1 Raw Data

Raw data as listed above is self-explanatory, in that the data are generated from instruments or
directly observed during the test. However, the maintenance data can be broad in definition and
further explanation is warranted:

The maintenance data from the tested treatment system shall include all maintenance activities
performed during the verification test. They shall include descriptions of the performed
maintenance tasks, the reason they were done, and the duration of the maintenance activity. It is
acknowledged that the verification test represents an accelerated operation of the treatment

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system. Hence, the performed maintenance during the test may not represent typical
maintenance procedures or frequencies for long-term use of the treatment system. The
verification report shall clearly discuss and present normalization of these data to long-term
applications. For example, one can suggest that inserts have to be removed and replaced every
30,000 gallons processed, rather than suggest that the task is performed within a certain
timeframe.

7.1.2 Analyzed/Calculated Data

Design criteria such as hydraulic and mass removal capacities are two essential analyzed data
requirements to size commercial in-drain treatment systems. As part of the Test Plan, the
Vendor and Testing Organization would have estimated the size of the equipment based on feed
water rate and qualities outlined in the test plan. In the Verification Report, the hydraulic and
mass removal capacities shall be calculated using actual flow rates and feed water qualities
measured within the verification test. These calculations will be compared against the Vendor-
claimed design capacities.

The hydraulic capacity is calculated by the relationship between the volume of treated water
processed and treatment volume (or treatment medium). In other words, a calculation of liters of
treated water/m3 of medium or treatment volume should be performed. Another format of
hydraulic capacity is the relationship between the volume of treated water and mass of treatment
medium, or liters of treated water/kg of medium. If a specific in-drain treatment technology
requires different format to calculate their hydraulic capacity, this should be described in the Test
Plan and calculated in the Verification Report. The hydraulic loading rate should also be
presented as a function of the equipment volume or medium mass. This parameter should be
analyzed with respect to the observed operating range as it compares to the Vendor's rating for
the system. Defining the hydraulic operating range of the unit shall incorporate an analysis of
headlosses under clean and contaminated water conditions.

The mass removal capacity is defined either as mass of contaminant removed per volume of
medium (or treatment volume) or mass of contaminant removed per mass of treatment medium.
These mass removal capacities should be calculated for all targeted contaminants and compared
to vendor claims. In addition, the mass removal of secondary contaminants should be calculated
to measure the overall performance of the treatment system.

In addition to the capacity data, there are other types of analyzed/calculated data, which should
be discussed in the Results and Discussion section of the Verification Report. Examples of
analyzed/calculated data are graphical relationship of the following:

1.	Flow rate and time - this relationship shows feed flow variations, including the intermittent
flows and fluctuations, during each test phase. It also shows the various flows tested from
one test phase to another. Headlosses can be incorporated into this analysis and graphical
presentation.

2.	Cumulative flow and time - this relationship shows the operating time to reach a certain
cumulative flow, which is to be used in the evaluation of the capacity of the equipment.

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3.	Percent removal and time for each contaminant of concern - the percent removal is
defined as (C;nf - Ceff) / Cinr, where C,nr and Ceff are contaminant concentrations of
contaminants in the influent and effluent, respectively. This relationship will graphically
show the percent removal over time for each contaminant of concern at each test phase. It
will also demonstrate the time when the spent medium needs to be replaced, as noted by
deterioration in effluent quality.

4.	Effluent concentrations and time for each contaminant of concern - this relationship is
very similar to the above relationship between percent removal and time. However, it will
use the actual effluent concentrations for each contaminant of concern and for each test
period. This can also be graphically display as a function of cumulative volume processed.

5.	Influent and effluent concentrations for each contaminant of concern - Parts 2 and 3 of

Test Phase 3 are identical to each other, except that the feed water in Part 3 is spiked with
synthesized contaminant mixture by a pre-determined factor. Therefore, the influent and
effluent concentrations for these two test periods will be compared in this graphical
relationship.

6.	Actual effluent concentrations for each contaminant of concern -The actual test effluent
concentrations will be compared to the vendor's targeted effluent concentration and
removals.

In addition to the above graphically analyzed data, several forms of calculated data in reference
to residual measurements should be performed:

1.	Mass of residuals (e.g., kg) per volume of treated water (e.g., liters);

2.	Volume of residuals (e.g., m3) per volume of treated water (e.g., liters);

3.	Mass of targeted contaminant removed (e.g. kg) per mass of residuals generated (e.g., kg);

4.	Classification of residuals, e.g., spent treatment medium, based on TCLP analysis.

The Testing Organization and Vendor can use the above examples as guidance in setting the
manner in which the results of the testing will be presented and discussed in the Final Report.
These will require approval and may be modified and supplemented by the Verification
Organization.

7.1.3	Manual Data

When manual data recording is employed, the Testing Organization shall record all data and
calculations by hand in laboratory notebooks with carbon copies. Daily measurements shall be
recorded on specially prepared data log sheets, as appropriate. The original notebooks shall be
stored onsite and the carbon copy sheets shall be forwarded to the project manager of the Testing
Organization at least once per week. Logs shall include a description of the system, dates and
times, any problems or issues, names of visitors, calculations, and other pertinent items.

7.1.4	Electronic Data

Data in electronic format shall be included in commercially available programs for word
processing, spreadsheet or database processing, or commercial software developed especially for

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data collection and processing on a specific hardware instrument or piece of equipment. Backup
of the computer databases should be performed on a daily basis, if possible.

7.1.4.1 Verification Testing Database

A database for the project shall be set up in the form of custom-designed spreadsheets. The
spreadsheets shall be capable of storing and manipulating the wastewater quality data from each
sampling event along with the corresponding operational parameters, sampling location, day and
time, etc.

All data shall be kept and maintained in a central location. All manually entered data from the
laboratory notebooks and data log sheets shall be entered into the appropriate spreadsheet on a
weekly basis at minimum. All recorded calculations shall also be checked at this time.
Following data entry, the spreadsheet shall be printed out and the printout shall be checked
against the handwritten data sheet, preferably by Testing Organization personnel not involved
with the data entry. Any corrections shall be noted on the hardcopies and corrected on the
screen, and then a corrected version of the spreadsheet shall be printed out. The printouts shall
be initialed and dated by the Testing Organization personnel performing the checking and data
verification. The printouts shall be stored in chronological order in a project binder. Copies of
the checked and corrected printouts shall be forwarded to the project manager of the Testing
Organization at least once per week. At least two electronic backups of the data spreadsheets
shall be kept (e.g., one copy on computer hard drive and one copy on disk).

Formulae and functions written into the spreadsheets for data manipulation and calculations shall
be checked periodically to ensure that they are being used and entered correctly. The
spreadsheets shall undergo a monthly audit, at minimum, by the Testing Organization to ensure
the formulae and functions are being used and are entered correctly. The checking may involve
reviewing sample formulae and making sure the correct cells are referenced, the formula is
entered correctly (e.g., parenthesis and operations are correct), as well as performing a few
random hand calculations and comparing the results to those calculated by the spreadsheet
program. The spreadsheet audits shall be recorded in a log with the date, reviewer initials, name
and timeframe of data set inspected for identification, audit findings, and any modifications
made to the spreadsheets.

Each sampling event shall be assigned a specific identification number that will be tied to all data
from that sampling event through each step of data entry and analysis. The data from a sampling
event shall include the wastewater quality data as well as system/operational settings and
conditions, flow rates, sampling locations, day, time, personnel involved, etc. Samples delivered
to Verification Organization-qualified analytical laboratories, along with the results in the
laboratory reports, shall be tracked by the identification numbers. Laboratory reports shall be
received and reviewed by the Testing Organization. These data will be entered into the data
spreadsheets, cross-checked, and verified in the same manner as previously discussed.

The QA/QC procedures for managing, reviewing and checking data shall be presented in the
QAPP contained in the Test Plan. The means to obtain, record, check, and store data obtained
manually and electronically (data loggers, computers, etc.) shall be discussed in the QAPP.
Refer to Section 6.0 for further QA/QC information.

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7.2	DATA ANALYSIS AND PRESENTATION

The data obtained in the verification testing shall be statistically analyzed, reduced, and
presented in tables, graphs and/or charts in a clear and concise manner. Raw data shall be
included as an appendix to the final verification testing report.

Note that it must be possible to tie the results as presented to the original raw data and test
conditions under which the results were obtained. The QAPP contained in the Test Plan shall
address this requirement.

A detailed discussion of the results shall accompany the tables, graphs, and charts and shall be
presented in the final verification testing report. The Testing Organization shall provide and
discuss conclusions drawn from the test results.

7.3	VERIFICATION REPORT

The Verification Report shall present the results of the verification testing such that the testing
demonstrates the capability and performance of the in-drain treatment technology.

The draft Verification Report shall be reviewed by the Verification Organization, the US EPA
and peer-reviewers (for evaluations conducted under the Environmental Technology Verification
Program). For verification testing performed against this protocol outside of the ETV Program,
the draft Verification Report shall be reviewed by a peer-review group with no real or perceived
bias concerning the technology. For all technology verifications, the Vendor shall also review
the draft Verification Report and provide comments. For testing conducted under the ETV
Source Water Protection Pilot, the Verification Report and Verification Statement, once
approved, will be posted on the Internet on both the USEPA/ETV and NSF web sites.

The report shall include the following topics:

Executive Summary
Introduction and Background
• Identification and Description of In-Drain Treatment Technology
Include in-drain treatment technology capabilities.

Experimental Setup and In-Drain Treatment Technology Configuration

Include site plan with in-drain treatment technology layout shown.

Test Procedures and Methods

Include methods and procedures for characterization, start-up, verification testing,
field analyses, and laboratory analyses.

Verification Testing Period

Include observations, conditions, reduced influent and effluent data in graphs
and/or tables, results.

Final Results and Discussion

Discuss final results. Present reduced data in graphs and/or tables.

Statement of Verification

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Provide a final statement regarding the treatment performance of the in-drain
treatment technology under specific test conditions.

References

Appendices

Test Plan

Vendor-Supplied O&M Manual(s)

QA/QC Procedures and Results

Laboratory Reports with QA/QC Records, Chain of Custody Forms
Monitoring and Maintenance Records/Logs
Raw Data

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8 REFERENCES

American Petroleum Institute. "Results of a Retail Gasoline Outlet and Commercial Parking Lot
Storm Water Runoff Study." API Publication 1669. 1994.

American Public Health Association, American Water Works Association and Water
Environment Federation. Standard Methods for the Examination of Water and
Wastewater. 20th Edition. 1998.

Federal Register, Methyl Tertiary Butyl Ether (MTBE); Advanced Notice of Intent to Initiate
Rulemaking Under the Toxic Substances Control Act to Eliminate or Limit the Use of
MTBE as a Fuel Additive in Gasoline; Advance Notice of Proposed Rulemaking, 40 CFR
Part 755, Vol. 65, No. 58, pg. 16093-16109, March 24, 2000.

Federal Register, Revisions to the Unregulated Contaminant Monitoring Regulations for Public
Water Systems, Final Rule, 40 CFR Part 9, 141 & 142, Vol. 64, No. 180, pg. 50555-
50620, September 17, 1999.

Federal Register, TCLP Methods, 40 CFR 26, Appendix II, SW 846 Method 1311, July 1992.

Hunter, J.V., et al. "Contribution of Urban Runoff to Hydrocarbon Pollution." Research Journal
of the Water Pollution Control Federation, Vol. 51, No. 8, pg. 2129 - 2138. August 1979.

New Jersey Administrative Code. Groundwater Quality Standards. NJAC 7:9-6 for Class II-A.
1993.

Pitt R., et al. "Urban Stormwater Toxic Pollutants: Assessment, Sources, and Treatability."
Water Environment Research, Vol. 67, No. 3, pg. 260 - 275. May/June 1995.

Rhodes, I.A.L., et al. "Selecting Analytical Methods for the Determination of Oxygenates in
Environmental Samples and Gasoline", API Environmental Monitoring Workgroup,
www. api. org/ehs/oxy mtb e 10. doc.

United States Environmental Protection Agency. 1997. Environmental Technology Verification
Program - Verification Strategy. US EPA Office of Research and Development,
Washington, D.C., EPA/600/K-96/003.

United States Environmental Protection Agency. 1998. Environmental Technology Verification
Program - Quality and Management Plan for the Pilot Period (1995-2000). US EPA
Office of Research and Development, Washington, D.C., EPA/600/R-98/064.

United States Environmental Protection Agency. 1999. Stormwater Treatment at Critical Areas:
The Multi-Chambered Treatment Train (MCTT). US EPA Office of Research and
Development, Washington, D.C., EPA/600/R-99/017.

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Verscheren, K. "Handbook of Environmental Data on Organic Chemicals", Second Edition, Van
Nostrand Reinhold Company. 1983.

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