Seven federally regulated industrial categories have pretreatment standards established for total toxic organics (TTO). The term TTO is defined as the sum of specific toxic organic compounds found in the process discharge at a concentration of 0.01 mg/l (10 ppb) or more.
Categories affected by a TTO limit include:
• Electroplating (40 CFR 413),
• Metal Finishing (40 CFR 433),
• Electrical and Electronic Components (40 CFR 469),
• Metal Molding and Casting (40 CFR 464),
• Coil Coating (40 CFR 465),
• Aluminum Forming (40 CFR 467), and
• Copper Forming (40 CFR 468).
In addition to these seven categories, Pharmaceutical Manufacturing (40 CFR 439) is subject to a specific list of toxic organics with individual discharge limits. Because the TTO compounds are an established list of high priority pollutants, some POTWs use limits for TTO for other types of industrial discharges.
Compliance with the pretreatment standards may be demonstrated in several different ways, including to develop and certify the implementation of a toxic organic management plan (TOMP). The TOMP details Best Management Practices or BMPs to be used to implement the general prohibitions listed in 40 CFR 403.5(a)(1) and specific prohibitions listed in 40 CFR 403.5(b). BMPs could include treatment requirements, operating procedures, and practices to control plant site runoff, spillage or leaks, sludge or waste disposal, or drainage from raw materials storage.
Caltha LLP provides expert consulting services to facilities nationwide which are subject to Categorical Discharge Standards, or other requirements imposed by the local sewer authority, including the preparation of a a toxic organic management plan (TOMP).