Monday, September 26, 2011

What is a Toxic Organic Management Plan?

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.

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 specialized expertise to clients nationwide in the evaluation environmental rules, developing EH&S compliance procedures, and preparing pollution prevention and spill control plans, including toxic organic management plans.

For further information contact Caltha LLP at or Caltha LLP Website

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