Total Toxic Organic (TTO) and Volatile Organic Compounds Monitoring Procedures
This guidance document is advisory in nature but is binding on an agency until amended by such agency. A guidance document does not include internal procedural documents that only affect the internal operations of the agency and does not impose additional requirements or penalties on regulated parties or include confidential information or rules and regulations made in accordance with the Administrative Procedure Act. If you believe that this guidance document imposes additional requirements or penalties on regulated parties, you may request a review of the document.

Form #:  17-008
Guidance Documents
Revised: 11/26/18
SizeFile Name
159 KB 17-008 TTO Guidance.pdf


This document is intended to work with an NPDES permit to provide permittees guidance for total toxic organic testing, a requirement in the permit.

A. General
A complete TTO analysis involves testing for up to 5 fractions containing 111 compounds. However, the Pesticide Fraction and Dioxin need not be included in the TTO analysis unless specifically requested by the Department. The Department may also, on a case-by-case basis, add additional parameters to this TTO list.


B. Calculation of TTO Value
TTO test results are calculated by summing all quantifiable values greater than 0.01 milligrams per liter (mg/L) for the TTO compounds. In situations where the concentration of a compound is below the detection limit, it need not be included. However, the Department may reject an analysis as inconclusive and request follow-up monitoring if the detection limits are too high to provide reasonable assurance of compliance.


C. Reporting of Results
The TTO value calculated as set forth above is to be reported on the appropriate Discharge Monitoring Report (DMR) and a copy of the laboratory report showing the test results for each individual compound is to be attached to both the Department's and City's copy of the DMR. If all of the results are below the detection limit, then you will report using the NODI (no data indicator) “B”. The dropdown for NODI code selection is located under the parameter info as seen below.


D. Identification of Compounds, Sampling Methods and Analytical Procedures

1. Volatile Fraction
The compounds included in this fraction are listed below. The volatile fraction is to be analyzed using grab samples and EPA Method 624 or 1624, unless written Departmental approval for alternative methods is provided.

Acrolein
Acrylonitrile
Benzene
Bromoform
Carbon tetrachloride
Chlorobenzene
Chlorodibromomethane
Chloroethane
2-Chloroethyl vinyl ether
Chloroform
Dichlorobromomethane
1, 1-Dichloroethane
1, 2-Dichloroethane
1, 1-Dichloroethylene
1, 2-Dichlorobenzene
1, 3-Dichlorobenzene
1, 4-Dichlorobenzene
1, 2-Dichloropropane
1, 3-Dichloropropylene
Ethylbenzene
Methyl bromide
Methyl chloride
Methylene chloride
Tetrachloroethylene
1, 1, 2, 2-Tetrachloroethane
Toluene
1, 2-trans-Dichloroethylene
1, 1, 1-Trichloroethane
1, 1, 2-Trichloroethane
Trichloroethylene
Vinyl chloride


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2. Acid Fraction

The compounds included in this fraction are listed below. The acid fraction is to be analyzed using production day composite samples and EPA Method 625 or 1625, unless written Departmental approval for alternative methods is provided.

2-Chlorophenol
2, 4-Dichlorophenol
2, 4-Dimethylphenol
4, 6-Dinitro-o-cresol
2, 4-Dinitrophenol
2-Nitrophenol
4-Nitrophenol
N-nitrosodimethylamine
N-nitrosodi-n-propylamine
N-nitrosodiphenylamine
Parachlorometa cresol
Pentachlorophenol
Phenol
2, 4, 6-Trichlorophenol

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3. Base/Neutral Fraction

The compounds included in this fraction are listed below. The volatile fraction is to be analyzed using production day composite samples and EPA Method 625 or 1625, unless written Departmental approval for alternative methods is provided.

Acenaphthene
Acenaphthylene
Anthracene
Benzidine
1, 2-Benzanthracene
3, 4 -Benzopyrene
3, 4-Benzofluoranthene
11, 12-Benzofluoranthene 
1, 12-Benzoperylene
Bis(2-chloroethoxy) methane
Bis(2-chloroethyl) ether
Bis(2-chloroisopropyl) ether
Bis(2-ethylhexyl)phthalate
4-Bromophenyl phenyl ether
Butyl benzyl phthalate
2-Chloronaphthalene
Chrysene
4-Chlorophenyl phenyl ether
1, 2, 5, 6-Dibenzanthracene
3, 3-Dichlorobenzidine 
Diethyl phthalate
Dimethyl phthalate
Di-N-Butyl phthalate
2, 4-Dinitrotoluene
2, 6-Dinitrotoluene
Di-n-octyl phthalate

1, 2-Diphenylhydrazine (as Azobenzene)

Fluoranthene
Fluorene
Hexachlorobenzene
Hexachlorobutadiene
Hexachloroethane
Indeno (1 ,2, 3-cd) pyrene
Isophorone
Hexachlorocyclopentadiene
Naphthalene
Nitrobenzene
Phenanthrene
Pyrene
1, 2 ,4-Trichlorobenzene

4. Pesticide Fraction

The compounds included in this fraction are listed below. The Pesticide Fraction is to be analyzed using production day composite samples and EPA Method 608, unless written Departmental approval for alternative methods is provided. Monitoring for the Pesticide Fraction need not be conducted unless specifically requested by the Department.

Aldrin
Alpha-BHC
Beta-BHC
Gamma-BHC
Delta-BHC
Chlordane
4, 4'-DDT
4, 4'-DDE
4, 4'-DDD
Dieldrin
Alpha-endosulfan
Beta-endosulfan
Endosulfan sulfate
Endrin
Endrin aldehyde
Heptachlor
Heptachlor epoxide
PCB-1016
PCB-1221
PCB-1232
PCB-1242
PCB-1248
PCB-1254
PCB-1260
Toxaphene





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5. Dioxin (2, 3, 7, 8-tetrachlorodibenzo-p-dioxin)

Dioxin is to be analyzed using production day composite samples and EPA Method 613, unless written Departmental approval for alternative methods is provided. Monitoring for Dioxin need not be conducted unless specifically requested by the Department.


Produced by: Nebraska Department of Environmental Quality, P.O. Box 98922, Lincoln, NE 68509-8922; phone (402) 471-2186. To view this, and other information related to our agency, visit our web site at http://deq.ne.gov.