Total Toxic Organics - Monitoring Requirements and Toxic Organic Management Plans

The Sanitation Districts of Los Angeles County (Districts) are required to regulate all companies subject to EPA Electroplating (40 CFR 413), Metal Finishing (40 CFR 433) and Electrical and Electronic Components (40 CFR 469) pretreatment standards. These companies are regulated for Total Toxic Organics (TTO) in addition to a variety of other constituents, and are required to either (1) perform self-monitoring for TTO or (2) implement a Toxic Organic Management Plan (TOMP) and submit a certification statement with each Self-Monitoring Report that concentrated toxic organics are not being discharged to the sewerage system. These requirements are discussed in more detail below. The following documents may also be useful:

Toxic Organic Management Plan [DOC] [PDF]

The following attachments are located within the above document

Attachment 1: Toxic Organic Management Plan Guidelines, including two examples of completed TOMPs

Attachment 2: Toxic Organic Minimization Suggestion List

Attachment 3: Chemicals Regulated Under Total Toxic Organics (TTO)

Attachment 4: Toxic Organic Summary (also available as a fill-in form) [PDF] [DOC]

TOXIC ORGANIC MANAGEMENT PLAN - ALL CATEGORIES

Companies which do not use or store toxic organic compounds.

TOMPs are appropriate for companies which do not use or store toxic organic compounds. However, companies in this situation which do not have an approved TOMP must monitor for TTO compounds on a periodic basis. Therefore, it is beneficial to take the time to submit a TOMP for approval by the Districts. The TOMP should include, as a minimum, a process description including a discussion of cleaning and stripping operations which may occur, a description of how it was determined that TTO compounds are not stored or used at the facility, a section which describes how your company will handle future process or chemistry changes which may affect the TOMP, an implementation date and certification statement. The length will be approximately two pages. An example is included in Attachment 1Attachment 4 should also be completed and submitted with the TOMP.

The Districts will notify a company in writing that a TOMP has been approved. Until a company has implemented an approved TOMP, it is still responsible for showing compliance with EPA limitations by periodically monitoring its effluent for toxic organic compounds.

Companies which use or store toxic organic compounds.

TOMPs may be appropriate for companies which store or use toxic organic compounds. These companies should review Attachment 1, the Toxic Organic Management Plan Guidelines, to determine the appropriateness of submitting a TOMP. If it is determined that a TOMP is appropriate, it should be prepared and submitted to the Districts for review, along with Attachment 4.

The Districts will notify a company in writing that a TOMP has been approved. Until a company has implemented an approved TOMP, it is still responsible for showing compliance with EPA limitations by periodically monitoring its effluent for toxic organic compounds.

MONITORING FOR TOXIC ORGANIC COMPOUNDS

Electroplating and Metal Finishing

Companies subject to pretreatment standards for Electroplating and Metal Finishing categories which do not have a TOMP approved by the Districts must monitor their wastewater for TTO at the same frequency as they are performing self-monitoring for metals, etc. There are two options under the monitoring requirements.

  • Option 1: Companies can monitor for the entire list of regulated TTO compounds listed in Attachment 3, located in the Toxic Organic Management Plan. This list contains 111 compounds. Any company which does not submit a partial list as discussed in Option 2 below or have an approved TOMP will automatically be required to monitor for the entire list.  Attachment 4 should be completed and submitted to the Districts.
  • Option 2: Companies may supply a list of toxic organic compounds which are stored or used at their facility and indicate which are expected to be present in the wastewater. The Districts will then use this list to determine which specific toxic organic compounds a company must monitor. Companies will be notified in writing when their Option 2 list of compounds has been approved. Any company which chooses this option will, as a minimum, be required to monitor for 30 volatile organic compounds. Monitoring for other compounds may also be required. Attachment 4 should be completed and submitted for approval. Until the list is approved, the company is obligated to monitor for the entire list of regulated TTO compounds unless the company is operating under a valid and approved TOMP.

Electrical and Electronic Components - Subcategories A, B, C

Dischargers in the Electrical and Electronic Components category which do not have an approved TOMP must monitor for the presence of TTO in their wastewater. These companies must monitor for the entire list of regulated TTO compounds listed in
Attachment 3 (located in the Toxic Organic Management Plan) for the appropriate subcategory. Companies choosing this option should submit Attachment 4, the Toxic Organic Summary, to the Districts.

QUESTIONS?

If you require further assistance, please contact the Districts' Industrial Waste Section at (562) 908-4288, extension 2900.