Total Toxic Organics Management Plan For Metal Finisher

Caltha LLP Project Summary

Project: Total Toxic Organics Management Plan For Metal Finisher
Client: Metal Finishing Company
Location(s): Minnesota

Key Elements: Total Toxic Organics Management Plan, SPCC Plan

Overview: This metal finishing was subject to Categorical Effluent Guidelines. In lieu of monitoring wastewater discharges for the full list of “Total Toxic Organics” the facility opted to prepare and implement a Total Toxic Organic Management Plan (TTOMP) for the site. Caltha was contracted to prepare the TTOMP for the facility. The TTOMP included:
• Inventory and description of TTO compounds used in the electroplating or finishing processes, and degreasing processes;
• Inventory and description of regulated processes where TTO compounds are used;
• Description of disposal methods for materials and wastes that contain TTO compounds;
• Description of controls used to limit or eliminate the discharge of TTO compounds to the sanitary sewer.



Spilled Corrosive Liquid From Aboveground Tank


The TTOMP was combined with a Facility Spill Plan which included processes and containers not specifically addressed under the Effluent Guidelines. Caltha prepared a spill control plan for the site to minimize and control spills from areas where liquids are stored, transferred and used. The spill plan included:
1. Inventory and description of chemical storage and process tanks;
2. Description of batch discharges to sanitary sewer;
3. Description of controls and procedures to prevent entry of chemicals and other restricted materials and wastes from entering the sanitary sewer;
4. Emergency notification procedures;

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