Does WDNR Require a TOMP Plan?

A number of industrial categories common in Wisconsin have pretreatment standards established for total toxic organics (TTO). 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).

Compliance with the pretreatment standards may be demonstrated in several different ways, one of which is to develop and certify a toxic organic management plan (TOMP). The TOMP details Best Management Practices or BMPs to be used to implement the general and specific prohibitions listed in the Clean Water Act. 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 environmental consultant services in Wisconsin to obtain air and wastewater permits, evaluate regulatory requirements, and to develop cost effective compliance programs, including preparation of pollution prevention and spill control plans, SPCC plans and TOMP plans.

For further information, contact Caltha LLP at:

Email: info@calthacompany.com Website: http://www.calthacompany.com/