Development Document for Proposed Effluent Limitations Guidelines and Standards for the Transportation Equipment Cleaning Category


United States
Environmental Protection
Agency
Office of Water
(4303)
EPA-821-B-98-011
May 1998

Development Document For
Proposed Effluent Limitations
Guidelines And Standards For
The Transportation Equipment
Cleaning Category

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       DEVELOPMENT DOCUMENT
                   FOR
   PROPOSED EFFLUENT LIMITATIONS
      GUIDELINES AND STANDARDS
                FOR THE
TRANSPORTATION EQUIPMENT CLEANING
       POINT SOURCE CATEGORY
              Carol M. Browner
               Administrator

              Robert Perciasepe
     Assistant Administrator, Office of Water

              Tudor T. Davies
    Director, Office of Science and Technology

               Sheila E. Frace
 Acting Director, Engineering and Analysis Division

                 NeilPatel
  Chief, Economic and Statistical Analysis Branch

                John linger
              Project Manager
                May 1998
     U.S. Environmental Protection Agency
              Office of Water
           Washington, DC 20460

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                               TABLE OF CONTENTS
                                                                                 Page
1.0   LEGAL AUTHORITY	1-1
      1.1    Clean Water Act (CWA)	1-1
             1.1.1   Best Practicable Control Technology Currently Available (BPT)
                    (Section 304(b)(l) of the CWA) 	1-1
             1.1.2   Best Conventional Pollutant Control Technology (BCT) (Section
                    304(b)(4) of the CWA)	1-2
             1.1.3   Best Available Technology Economically Achievable (BAT)
                    (Section 304(b)(2) of the CWA) 	1-2
             1.1.4   New Source Performance Standards (NSPS) (Section 306 of the
                    CWA)	1-3
             1.1.5   Pretreatment Standards for Existing Sources (PSES) (Section
                    307(b) of the CWA)	1-3
             1.1.6   Pretreatment Standards for New Sources (PSNS) (Section 307(b)
                    of the CWA)	1-4
      1.2    Section 304(m)  Requirements	1-4
      1.3    Pollution Prevention Act	1-5

2.0   SUMMARY AND SCOPE	2-1
      2.1    Applicability of the Proposed Regulation 	2-1
      2.2    Subcategorization	2-2
      2.3    Summary of Proposed Rule	2-2
             2.3.1   Best Practicable Control Technology Currently Available (BPT)	2-2
             2.3.2   Best Conventional Pollutant Control Technology (BCT)  	2-3
             - 2.3.3   Best Available Technology Economically Achievable (BAT) 	2-3
             2.3.4   New  Source Performance Standards (NSPS)	2-3
             2.3.5   Pretreatment Standards for Existing Sources (PSES)  	2-4
             2.3.6   Pretreatment Standards for New Sources (PSNS)	2-4

3.0   DATA COLLECTION ACTIVITIES	3-1
      3.1    Summary of TECI Information Collected Prior to 1992	3-1
      3.2    Summary of the TECI Questionnaires	3-2
             3.2.1   Identification of Potential TECI Population  	3-2
             3.2.2   1993 Screener Questionnaire for the Transportation Equipment
                    Cleaning Industry (Screener Questionnaire)  	3-5
                    3.2.2.1 Development of the Screener Questionnaire Sample Frame .. .  3-5
                    3.2.2.2 Development of the Screener Questionnaire	3-8
                    3.2.2.3 Administration of the Screener Questionnaire	3-8
                    3.2.2.4 Calculation of National Estimates	3-10
             3.2.3   1994 Detailed Questionnaire for the Transportation Equipment
                    Cleaning Industry (Detailed Questionnaire)  	3-11

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                         TABLE OF CONTENTS (Continued)
                                                                                Page
                   3.2.3.1 Development of the Detailed Questionnaire Sample Frame  .. 3-12
                   3.2.3.2 Development of the Detailed Questionnaire	3-15
                   3.2.3.3 Administration of the Detailed Questionnaire		3-19
                   3.2.3.4 Calculation of National Estimates	3-20
      3.3    Summary of EPA's TECI Site Visit Program from 1993 Through 1996 ..... 3-21
             3.3.1  Criteria for Site Selection	3-22
             3.3.2  Information Collected 	,	3-23
      3.4    Summary of EPA's TECI Sampling Program from 1994 through 1996	3-24
             3.4.1  Criteria for Site Selection	3-25
             3.4.2  Information Collected 	• • 3-25
             3.4.3  Sample Collection and Analysis 	3-26
      3.5    Existing Data Sources  	3-27
             3.5.1  Other EPA Effluent Guidelines Databases	3-27
             3.5.2  EPA's Risk Reduction Engineering Laboratory Treatability
                   Database	3-28
             3.5.3  EPA's Fate of Priority Pollutants in Publicly Owned Treatment
                   Works Database	3-28
             3.5.4  State and Local Agencies	-	3-29
             3.5.5  EPA's Permit Compliance System and Industrial Facilities
                   Discharge Databases 	•	3-29
             3.5.6  U.S. Navy Bilge Wastewater Characterization Data	 3-30
      3.6    Summary of Publicly-Owned Treatment Works Data	3-30
      3.7    References 	3-31

4.0   INDUSTRY DESCRIPTION	4-1
      4.1    Operational Structure	4-1
      4.2    Cleaning Purpose	4"2
      4.3    TEC Operations	4'3
             4.3.1   Tank and Hopper Truck, BBC, and Intermodal Tank Container
                    Cleaning	4"5
             4.3.2  Rail Tank and Hopper Car Cleaning	4-6
             4.3.3  Tank and Hopper Barge and Ocean/Sea Tanker Cleaning	4-6
             4.3.4  Special Cleaning Processes	4-7
       4.4   Tank Types Cleaned	4"8
       4.5   Cargo Types Cleaned	4-l°
       4.6   Heel Removal and Disposal	4-H
       4.7   Chemical Cleaning Solutions	4-13
       4.8   Non-TEC Operations	4-15
       4.9   Geographic Profile	4'16
       4.10  References 	4"18
                                           11

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                          TABLE OF CONTENTS (Continued)
                                                                                   Page

5.0    INDUSTRY SUBCATEGORIZATION	5-1
       5.1    Factors Considered for Basis of Subcategorization	5-2
              5.1.1  Cleaning Processes (Production Processes)	5-2
              5.1.2  Tank Type Cleaned 	5-4
              5.1.3  Cargo Type Cleaned	5-7
              5.1.4  Water Use and Wastewater Reuse Practices  	5-9
              5.1.5  Wastewater Characteristics 	5-10
              5.1.6  Facility Age	5-12
              5.1.7  Facility Size	5-13
              5.1.8  Geographical Location	5-13
              5.1.9  Water Pollution Control Technologies  		 5-14
              5.1.10 Treatment Costs	 5-15
              5.1.11 Non-Water Quality Impacts	5-15
       5.2    Selection of Subcategorization Approach  	5-15
       5.3    References  	5-21

6.0    WATER USE AND WASTEWATER CHARACTERIZATION  	6-1
       6.1    Water Use and Wastewater Generation	6-2
       6.2    Sources of Wastewater	6-4
       6.3    Wastewater Discharge Practices  	6-6
       6.4    Water Reuse and Recycling	6-8
       6.5    Wastewater Characterization	6-9

7.0    POLLUTANTS SELECTED FOR REGULATION	7-1
       7.1    Pollutants Considered for Regulation 	7-2
       7.2    Pollutants of Interest for the TECI	7-2
              7.2.1  Truck/Chemical, Rail/Chemical, and Barge/Chemical & Petroleum
                    Subcategories	7-3
              7.2.2  Truck/Food, Rail/Food, and Barge/Food Subcategories	7-4
              7.2.3  Truck/Petroleum and Rail/Petroleum Subcategories	7-5
              7.2.4  Truck/Hopper, Rail/Hopper, and Barge/Hopper Subcategories	7-6
       7.3    Pollutants Effectively Removed	7-6
       7.4    Pollutant Selection Criteria for Direct Dischargers	7-9
              7.4.1  Pollutants Selected for Regulation for Truck/Chemical Direct
                    Dischargers	7-12
              7.4.2  Pollutants Selected for Regulation for Rail/Chemical Direct
                    Dischargers	7-13
              7.4.3  Pollutants Selected for Regulation for Barge/Chemical &
                    Petroleum Direct Dischargers	7-13
              7.4.4  Pollutants Selected for Regulation for Truck/Food, Rail/Food, and
                    Barge/Food Direct Dischargers	7-14
                                           in

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                         TABLE OF CONTENTS (Continued)
                                                                                  Page
       7.5    Pollutant Selection Criteria for Indirect Dischargers	7-15
             7.5.1  Pollutants Selected for Regulation for Truck/Chemical Indirect
                    Dischargers	7-17
             7.5.2  Pollutants Selected for Regulation for Rail/Chemical Indirect
                    Dischargers	 7-17
             7.5.3  Pollutants Selected for Regulation for Barge/Chemical &
                    Petroleum Indirect Dischargers 	7-18
       7.6    References	7-18

8.0    POLLUTION PREVENTION AND WASTEWATER TREATMENT TECHNOLOGIES	8-1
       8.1    Pollution Prevention Controls	8-1
             8.1.1  Use of Dedicated Tanks	8-2
             8.1.2  Heel Reduction	8-3
             8.1.3  Reduction in the Amount and Toxicity of Chemical Cleaning
                    Solutions 	8-6
       8.2    Flow Reduction Technologies	8-8
             8.2.1  High-Pressure, Low-Volume Cleaning Equipment	8-8
             8.2.2  Monitoring TEC Water Use	8-9
             8.2.3  Equipment Monitoring Program	  8-9
             8.2.4  Cleaning Without Use of Water	8-9
             8.2.5  Cascade Tank Cleaning	8-10
             8.2.6  Wastewater Recycle and Reuse	8-10
       8.3    End-of-Pipe Wastewater Treatment Technologies  	8-11
             8.3.1  Gravity Settling	8-12
             8.3.2  pH Adjustment	8-13
             8.3.3  Equalization	8-13
             8.3.4  Oil/Water Separation	8-14
             8.3.5  Sludge Dewatering	8-15
                    8.3.5.1 Sludge Drying Bed	8-15
                    8.3.5.2 Plate-and-Frame Filter Press  	8-16
                    8.3.5.3 Rotary Vacuum Filter	8-16
                    8.3.5.4 Centrifuge 	8-17
              8.3.6  Dissolved Air Rotation	8-17
              8.3.7  Coagulation/Flocculation	,	8-18
              8.3.8  Filtration	8-19
              8.3.9  Clarification	8-20
              8.3.10 Biological Oxidation	8-20
              8.3.11 Chemical Precipitation/Separation	8-21
              8.3.12 GritRemoval	8-22
              8.3.13 Chemical Oxidation	8-22
              8.3.14 Activated Carbon Adsorption 	8-23
                                           IV

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                         TABLE OF CONTENTS (Continued)
                                                                                Page

             8.3.15  Membrane Filtration	8-24
                    8.3.15.1       Microfiltration	8-25
                    8.3.15.2       Ultrafiltration	 8-25
                    8.3.15.3       Reverse Osmosis 	8-25
       8.4    References	8-26

9.0    DEVELOPMENT OF CONTROL AND TREATMENT OPTIONS  	9-1
       9.1    Introduction 	9-1
             9.1.1   Common Elements of All Options	9-2
             9.1.2   Development of Subcategory-Specific Regulatory Flows	9-6
       9.2    Best Practicable Control Technology Currently Available (BPT)	9-7
             9.2.1   BPT Options for the Truck/Chemical Subcategory	9-8
             9.2.2   BPT Options for the Rail/Chemical Subcategory 	9-11
             9.2.3   BPT Options for the Barge/Chemical & Petroleum Subcategory .... 9-14
             9.2.4   BPT Options for the Truck/Food, Rail/Food, and Barge/Food
                    Subcategories	9-16
             9.2.5   BPT Options for the Truck/Petroleum and Rail/Petroleum
                    Subcategories	9-18
             9.2.6   BPT Options for the Truck/Hopper, Rail/Hopper, and
                    Barge/Hopper Subcategories	9-19
       9.3    Best Conventional Pollutant Control Technology (BCT) 	9-19
       9.4    Best Available Technology Economically Achievable (BAT)  	9-20
       9.5    New Source Performance Standards (NSPS)	9-21
             9.5.1   NSPS Options for the Truck/Chemical Subcategory	9-22
             9.5.2  NSPS Options for the Rail/Chemical Subcategory	9-22
             9.5.3   NSPS Options for the Barge/Chemical & Petroleum Subcategory ... 9-23
             9.5.4  NSPS Options for the Truck/Food, Rail/Food, and Barge/Food
                    Subcategories	9-23
             9.5.5  NSPS Options for the Truck/Petroleum and Rail/Petroleum
                    Subcategories	9-24
             9.5.6  NSPS Options for the Truck/Hopper, Rail/Hopper, and
                    Barge/Hopper Subcategories	9-24
       9.6    Pretreatment Standards for Existing Sources (PSES) 	9-24
             9.6.1  PSES Options for the Truck/Chemical Subcategory	9-25
             9.6.2  PSES Options for the Rail/Chemical Subcategory  	9-26
             9.6.3  PSES Options for the Barge/Chemical & Petroleum Subcategory  ... 9-28
             9.6.4  PSES Options for the Truck/Food, Rail/Food, and Barge/Food
                    Subcategories	9-30
             9.6.5  PSES Options for the Truck/Petroleum and Rail/Petroleum
                    Subcategories	9-31

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                        TABLE OF CONTENTS (Continued)
                                                                                Page
             9.6.6  ' PSES Options for the Truck/Hopper, Rail/Hopper, and
                   Barge/Hopper Subcategories	9-33
      9.7    Pretreatment Standards for New Sources (PSNS)	9-34
             9.7.1  PSNS Options for the Truck/Chemical Subcategory	9-34
             9.7.2  PSNS Options for the Rail/Chemical Subcategory	9-34
             9.7.3  PSNS Options for the Barge/Chemical & Petroleum Subcategory ... 9-35
             9.7.4  PSNS Options for the Truck/Food, Rail/Food, and Barge/Food
                   Subcategories	9-36
             9.7.5  PSNS Options for the Truck/Petroleum and Rail/Petroleum
                   Subcategories	9-36
             9.7.6  PSNS Options for the Truck/Hopper, Rail/Hopper, and
                   Barge/Hopper Subcategories	9-36
      9.8    References 	9-37

10.0  COSTS OF TECHNOLOGY BASES FOR REGULATIONS	10-1
      10.1   Development of Model Sites	10-3
             10.1.1 Model Site Development	10-3
             10.1.2 Supplemental Model Site Development 	10-4
             10.1.3 Pollutant Control Technology Development	10-6
             10.1.4 Model Sites with Production in Multiple Subcategories	10-7
      10.2   Costing Methodology	10-8
             10.2.1 Wastewater Streams Costed	,	• 10-8
             10.2.2 Influent Pollutant Concentrations 	10-10
             10.2.3 Cost Model Development  	• 10-10
             10.2.4 Components of Compliance Costs	10-11
                    10.2.4.1      Capital Costs  	10-12
                    10.2.4.2      Annual Costs  	10-15
             10.2.5 Treatment-in-Place Credit	10-16
             .10.2.6 Calculation of Baseline Parameters	10-18
             10.2.7 Contract Haul in Lieu of Treatment	10-18
       10.3   Design and Cost Elements for Pollutant Control Technologies  	10-19
             10.3.1 Cost Model Components	10-19
             10.3.2 Flow Reduction 	10-21
             10.3.3 Equalization	10-23
             10.3.4 Oil/Water Separation (Vertical Tube Coalescing)	 .  10-24
             10.3.5 Oil/Water Separation (American Petroleum Institute [API]
                    Separator)	10-26
             10.3.6 Oil/Water Separation (Gravity)	10-27
             10.3.7 Gravity Separation	10-29
             10.3.8 Chemical Oxidation, Neutralization, Coagulation, and Clarification  10-31
             10.3.9 DAP (with pH Adjustment and Chemical Addition)	10-32
                                          VI

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                         TABLE OF CONTENTS (Continued)
                                                                                Page

             10.3.10      DAF (without Chemical Addition)  	10-34
             10.3.11      Chemical Precipitation  	10-35
             10.3.12      Filter Press (for Wastewater Clarification and
                          Biological Treatment Sludge Dewatering)	10-36
             10.3.13      Biological Treatment-	10-37
             10.3.14      Activated Carbon Adsorption (Vessels)  	10-39
             10.3.15      Activated Carbon Adsorption (Canisters) 	10-40
             10.3.16      Organo-Clay/Activated Carbon Adsorption	10-40
             10.3.17      Reverse Osmosis		10-42
             10.3.18      Sludge Dewatering (Plate-and-Frame Filter Press)	10-43
             10.3.19      Contract Hauling of Wastewater in Lieu of
                          Treatment	10-44
             10.3.20      Compliance Monitoring	10-45
             10.3.21      Waste Hauling	10-46
       10.4   Summary of Costs by Regulatory Option  	10-46
       10.5   References 	10-46

11.0   POLLUTANT REDUCTION ESTIMATES	11-1
       11.1   General Methodology Used to Calculate Pollutant Loadings and Pollutant
             Reductions	11-2
       11.2   General Methodology Used to Estimate Untreated Pollutant Loadings  	11-4
       11.3   Multiple Subcategory Facility PNPLs	'.	11-8
       11.4   TECI Untreated Pollutant Loadings	11-8
       11.5   TECI Baseline Pollutant Loadings	11-9
       11.6   TECI Post-Compliance Pollutant Loadings by Regulatory Option	1.1-9
       11.7   TECI Pollutant Loading Reduction Estimates	11-10
             11.7.1  BPT 	11-10
             11.7.2  BCT	11-11
             11.7.3  BAT	11-12
             11.7.4  PSES  	11-12
       11.8   References 	11-13

12.0   NON-WATER QUALITY IMPACTS	12-1
       12.1   Energy Impacts	12-1
       12.2   Air Emission Impacts	12-2
       12.3   Solid Waste Impacts  	12-2
             12.3.1  Wastewater Treatment Sludge	12-3
             12.3.2  Waste Oil	12-4
             12.3.3  Spent Activated Carbon	12-47
             12.3.4  Spent Organo-Clay	12-5
       12.4   References 	12-5
                                         vu

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                       TABLE OF CONTENTS (Continued)
                                                                           Page
13.0   IMPLEMENTATION OF PROPOSED EFFLUENT LIMITATIONS GUIDELINES AND
      STANDARDS 	
14.0   ANALYTICAL METHODS
13-1
                                                                            14-1
      14.1   Semiyolatile Organic Compounds	14-2
      14.2   Metals	•• • • 14"2
      14.3   Hexane Extractable Material and Silica-Gel Treated Hexane Extractable
            Material  	14~3
      14.4   Chemical Oxygen Demand 	14"3
      14.5   Biochemical Oxygen Demand	14-4
      14.6   Total Suspended Solids	14"4
      14.7   References  	14"5
15.0  GLOSSARY
                                                                            15-1
                                        Vlll

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                                 LIST OF TABLES
2-1


2-2


2-3

2-4



•2-5



2-6



2-7


2-8


2-9


2-10

2-11


2-12


2-13
                                                                  Page

Proposed Subcategorization for the Transportation Equipment
Cleaning Industry	2-5

Summary of Proposed Rules for the Transportation Equipment
Cleaning Industry Point Source Category 	2-6

Summary of Technology Basis for BPT, BCT, BAT, and NSPS  	2-7
Truck/Chemical Subcategory:  BPT, BCT, BAT, and NSPS
Proposed Mass Based Limitations for Discharges to Surface
Waters  	
Rail/Chemical Subcategory: BPT, BCT, BAT, and NSPS
Proposed Mass Based Limitations for Discharges to Surface
Waters  	
Barge/Chemical & Petroleum Subcategory: BPT, BCT, BAT, and
NSPS Proposed Mass Based Limitations for Discharges to Surface
Waters  	
 2-8
 2-9
2-10
Truck/Food Subcategory: BPT, BCT, and NSPS Proposed Mass
Based Limitations for Discharges to Surface Waters  	2-11

Rail/Food Subcategory: BPT, BCT, and NSPS Proposed Mass
Based Limitations for Discharges to Surface Waters  	2-12

Barge/Food Subcategory: BPT, BCT, and NSPS Proposed Mass
Based Limitations for Discharges to Surface Waters  	2-13

Summary of Technology Basis for PSES and PSNS	2-14

Truck/Chemical Subcategory:  PSES and PSNS Proposed Mass
Based Limitations for Discharges to POTWs 	2-15

Rail/Chemical Subcategory: PSES and PSNS Proposed Mass
Based Limitations for Discharges to POTWs 	2-16

Barge/Chemical & Petroleum Subcategory:  PSES and PSNS
Proposed Mass Based Limitations for Discharges to POTWs	2-17
                                         IX

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                            LIST OF TABLES (Continued)
3-1


3-2

3-3



3-4


3-5


3-6



3-7


3-8

4-1


4-2


4-3



 6-1


 6-2
                                                                    Page

Major Sources Used to Identify Potential TEC Facilities by
Tank Type and Business Operational Structure	3-33

Sources Used to Identify Potential TEC Facilities	3-34

Original Screener Questionnaire Sample Frame and Distribution of
Facilities in the TECI Screener Questionnaire Mailing List by
Facility Type and Level of Assurance	3-37
Summary of TECI Screener Questionnaire Mail-Out and Follow-
Up Activities  	•	
Final Screener Questionnaire Sample Frame Strata and Total
Population Estimates	
Detailed Questionnaire Sample Frame and Distribution of
Facilities in the TECI Detailed Questionnaire Mailing List by
Strata 	
3-38
3-39
3-40
 Summary of TECI Detailed Questionnaire Mail-Out and Follow-
 Up Activities  	3-41

 Detailed Questionnaire Sample Frame Strata and Weights	3-42

 Distribution of Facilities That Clean a Single Cargo Type -
 Discharging and Zero Discharge Facilities 	4-19

 Average Volume of Heel Removed per Tank Cleaning by Cargo
 Group and Tank Type - Discharging and Zero Discharge Facilities	4-20

 Total Volume of Heel Discharged/Disposed by Cargo Group and
 Discharge/Disposal Method - Discharging and Zero Discharge
 Facilities	4'21
 Estimates of Total Annual Volume of Wastewater Generated by
 Subcategory - Discharging Facilities Only	
 6-12
 Average Volume of Interior Cleaning Wastewater Generated per
 Tank Cleaning by Cargo Group and Tank Type - Discharging
 Facilities Only  	6-13

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                            LIST OF TABLES (Continued)
6-3



6-4


6-5

6-6


6-7


6-8


6-9


6-10


6-11


6-12


6-13


6-14


6-15


 6-16
Average Volume of Wastewater Generated per Facility per Day by
Wastewater Stream Type and Subcategory - Discharging Facilities
Only	

Total Volume of Wastewater Generated per Day by Wastewater
Stream Type and Subcategory - Discharging Facilities Only	
Discharge Status by Subcategory
Estimates of Total Annual Volume of Wastewater Discharged
By Subcategory and Discharge Status	
Number of Facilities That Reuse All or Part of TEC Wastewater as
Source Water for TEC Operations	
Summary of Raw Wastewater Characterization Data for
Truck/Chemical Facilities 	
Summary of Raw Wastewater Characterization Data for
Rail/Chemical Facilities	
Summary of Raw Wastewater Characterization Data for
Barge/Chemical & Petroleum Facilities  	
 Summary of Raw Wastewater Characterization Data for
 Truck/Food Facilities	
 Summary of Raw Wastewater Characterization Data for Rail/Food
 Facilities	

 Summary of Raw Wastewater Characterization Data for
 Barge/Food Facilities	

 Summary of Raw Wastewater Characterization Data for
 Truck/Petroleum Facilities	'.	
 Page



. 6-14


. 6-15

. 6-16


. 6-17


. 6-18


. 6-19


. 6-29


. 6-38


. 6-46


. 6-50


. 6-53
 Summary of Raw Wastewater Characterization Data for
 Barge/Hopper Facilities	
 Summaries of the Raw Wastewater Characterization Data for Each
 Subcategory	
  6-57
  6-61
                                                                                  6-64
                                           XI

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                            LIST OF TABLES (Continued)
7-1

7-2



7-3


7-4


7-5



7-6



7-7

7-8

7-9


9-1

10-1


10-2

10-3

10-4


10-5
                                                                   Page

Priority Pollutant List	7-19

Pollutants Effectively Removed for Truck/Chemical Subcategory
Direct Dischargers for Proposed BPT, BCT, BAT, and NSPS
Option 2	7-20

Pollutants Effectively Removed for Rail/Chemical Subcategory
Direct Dischargers for Proposed BPT, BCT, and BAT Option 1  	7-22

Pollutants Effectively Removed for Rail/Chemical Subcategory
Direct Dischargers for Proposed NSPS Option 3	7-24

Pollutants Effectively Removed for Barge/Chemical & Petroleum
Subcategory Direct Dischargers for Proposed BPT, BCT, BAT,
andNSPS Option 1  	7-26

Pollutants Effectively Removed for Truck/Food, Rail/Food, and
Barge/Food Subcategory Indirect and Direct Dischargers for
Proposed BPT, BCT, and NSPS Option 2	:	7-28

Pass-through Analysis for the Truck/Chemical Subcategory	7-29

Pass-through Analysis for the Rail/Chemical Subcategory	7-29

Pass-through Analysis for the Barge/Chemical & Petroleum
Subcategory	7-30

Subcategory-Specific Regulatory How	9-38

Number of Costed Technology Options for Each TECI
Subcategory	10-51

Direct Capital Costs Used by the TECI Cost Model	10-52

Components of Total Capital Investment  	10-60

Operation and Maintenance Unit Costs Used by the TECI Cost
Model	10-61

Cost Summary of Regulatory Options for BPT/BAT/BCT	10-65
                                         XII

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                            LIST OF TABLES (Continued)
10-6

11-1



11-2



11-3



11-4



11-5



11-6



11-7



11-8



11-9



11-10
Cost Summary of Regulatory Options for PSES
Truck/Chemical Subcategory - Direct Dischargers
Summary of Pollutant Loadings and Reductions by Technology
Option  	,	

Rail/Chemical Subcategory - Direct Dischargers
Summary of Pollutant Loadings and Reductions by Technology
Option	

Barge/Chemical & Petroleum Subcategory - Direct Dischargers
Summary of Pollutant Loadings and Reductions by Technology
Option	

Barge/Hopper Subcategory - Direct Dischargers
Summary of Pollutant Loadings and Reductions by Technology
Option	

Truck/Chemical Subcategory - Indirect Dischargers
Summary of Pollutant Loadings and Reductions by Technology
Option  	
  Page

.  10-66



.  11-14



.  11-19



.  11-24



.  11-28



:  11-29
Rail/Chemical Subcategory - Indirect Dischargers
Summary of Pollutant Loadings and Reductions by Technology
Option  	11-34

Barge/Chemical & Petroleum Subcategory - Indirect Dischargers
Summary of Pollutant Loadings and Reductions by Technology
Option	  11-39

Truck/Food Subcategory - Indirect Dischargers
Summary of Pollutant Loadings and Reductions by Technology
Option  	11-43

Rail/Food Subcategory - Indirect Dischargers
Summary of Pollutant Loadings and Reductions by Technology
Option	11-45

Barge/Food Subcategory - Indirect Dischargers
Summary of Pollutant Loadings and Reductions by Technology
Option  	11-47
                                         xin

-------
                           LIST OF TABLES (Continued)
11-11        Truck/Petroleum Subcategory - Indirect Dischargers
             Summary of Pollutant Loadings and Reductions by Technology
             Option  	

11-12        Rail/Petroleum Subcategory - Indirect Dischargers
             Summary of Pollutant Loadings and Reductions by Technology
             Option  	•

11-13        Truck/Hopper Subcategory - Indirect Dischargers
             Summary of Pollutant Loadings and Reductions by Technology
             Option  	

11-14        Rail/Hopper Subcategory - Indirect Dischargers
             Summary of Pollutant Loadings and Reductions by Technology
             Option  	

11-15        Barge/Hopper Subcategory - Indirect Dischargers
             Summary of Pollutant Loadings and Reductions by Technology
             Option	•
                                                                                Page
11-49
11-54
11-59
11-60
11-61
                                          xiv

-------
                                  LIST OF FIGURES
4-1

4-2


4-3


4-4


4-5


4-6


4-7



4-8



4-9



6-1

8-1

8-2

8-3

8-4

8-5
                                                                      Page

Diagram of General TEC Operations	4-22

Distribution of TEC Facilities by Number of Cargo Types Cleaned
- Discharging and Zero Discharge Facilities	4-23

Geographic Profile of Discharging and Zero Discharge Facilities in
the TECI Detailed Questionnaire Sample Population	4-24

Geographic Profile of Discharging and Zero Discharge Truck
Facilities in the TECI Detailed Questionnaire Sample Population	4-25

Geographic Profile of Discharging and Zero Discharge Rail
Facilities in the TECI Detailed Questionnaire Sample Population	4-26

Geographic Profile of Discharging and Zero Discharge Barge
Facilities in the TECI Detailed Questionnaire Sample Population	4-27

Geographic Profile of Discharging and Zero Discharge Facilities in
the TECI Detailed Questionnaire Sample Population that Clean
Chemical Cargos 	4-28

Geographic Profile of Discharging and Zero Discharge Facilities in
the TECI Detailed Questionnaire Sample Population that Clean
Food Grade Cargos  	4_29

Geographic Profile of Discharging and Zero Discharge Facilities in
the TECI Detailed Questionnaire Sample Population that Clean
Petroleum Cargos	4_30

Water Use Diagram for TEC Operations	6-65

API Oil/Water Separator	8-27

Coalescing Oil/Water Separator	8-28

Plate-and-Frame Filter Press 	8-29

Rotary Vacuum Filter	8-30

Dissolved Air Flotation Unit with Pressurized Recycle  	8-31
                                          xv

-------
                         LIST OF FIGURES (Continued)
8-6




8-7




8-8




8-9
Clarifier
                                                                            Page




                                                                            . 8-32
Activated Sludge System	8'33



                            .                                     O ^A






Membrane Filtration Unit	8'35
                                        XVI

-------
Section 1.0 - Legal Authority
1.0
LEGAL AUTHORITY
Effluent limitations guidelines and standards for the Transportation Equipment
Cleaning Industry (TECI) are being proposed under the authority of Sections 301, 304, 306, 307,
308, and 501 of the Clean Water Act, 33 U.S.C. 1311, 1314, 1316, 1317, 1318, and 1361.
1.1
Clean Water Act (CWA)
The Federal Water Pollution Control Act Amendments of 1972 established a
comprehensive program to "restore and maintain the chemical, physical, and biological integrity
of the Nation's waters" (Section 101(a)). To implement the Act, the United States
Environmental Protection Agency (EPA) is to issue effluent limitations guidelines, pretreatment
standards, and new source performance standards for industrial dischargers. These guidelines
and standards are summarized briefly in the following sections.
1.1.1
Best Practicable Control Technology Currently Available
(BPT) (Section 304(b)(l) of the CWA)
In the guidelines for an industry category, EPA defines BPT effluent limits for
conventional, priority,1 and nonconventional pollutants. In specifying BPT, EPA looks at a
number of factors. EPA first considers the cost of achieving effluent reductions in relation to the
effluent reduction benefits. The Agency also considers: the age of the equipment and facilities;
the processes employed and any required process changes; engineering aspects of the control
technologies; non-water quality environmental impacts (including energy requirements); and
such other factors as the Agency deems appropriate (CWA 304(b)(l)(B)). Traditionally, EPA
In the initial stages of EPA CWA regulation, EPA efforts emphasized the achievement of BPT limitations for
control of the "classical" pollutants (e.g., TSS, pH, BOD5). However, nothing on the face of the statute explicitly
restricted BPT limitation to such pollutants. Following passage of the Clean Water Act of 1977 with its
requirement for points sources to achieve best available technology limitations to control discharges of toxic
pollutants, EPA shifted its focus to address the listed priority pollutants under the guidelines program. BPT
guidelines continue to include limitations to address all pollutants.
1-1

-------
                                                                      Section 1.0 - Legal Authority
establishes BPT effluent limitations based on the average of the best performances of facilities
within the industry of various ages, sizes, processes, or other common characteristics. Where,
however, existing performance is uniformly inadequate, EPA may require higher levels of
control than currently in place in an industrial category if the Agency determines that the
technology can be practically applied.
1.1.2
Best Conventional Pollutant Control Technology (BCT)
(Section 304(b)(4) of the CWA)
              The 1977 amendments to the CWA required EPA to identify effluent reduction
levels for conventional pollutants associated with BCT technology for discharges from existing
industrial point sources.  In addition to other factors specified in Section 304(b)(4)(B), the CWA
requires that EPA establish BCT limitations after consideration of a two part "cost-
reasonableness" test. EPA explained its methodology for the development of BCT limitations in
July 1986 (51 PR 24974).

              Section 304(a)(4) designates the following as conventional pollutants:
biochemical oxygen demand (BOD5), total suspended solids (TSS), fecal coliform, pH, and any
additional pollutants defined by the Administrator as conventional. The Administrator
designated oil and grease as an additional conventional pollutant on July 30,1979 (44 FR
44501).
1.1.3
Best Available Technology Economically Achievable (BAT)
(Section 304(b)(2) of the CWA)
              In general, BAT effluent limitations guidelines represent the best economically
achievable performance of plants in the industrial subcategory or category. The factors
considered in assessing BAT include the cost of achieving BAT effluent reductions, the age of
equipment and facilities involved, the process employed, potential process changes, and non-
water quality environmental impacts, including energy requirements. The Agency retains
                                           1-2

-------
Section 1.0 - Legal Authority
considerable discretion in assigning the weight to be accorded these factors. BAT limitations
may be based on effluent reductions attainable through changes in a facility's processes and
operations. As with BPT, where existing performance is uniformly inadequate, BAT may require
a higher level of performance than is currently being achieved based on technology transferred
from a different subcategory or category. BAT may be based upon process changes or internal
controls, even when these technologies are not common industry practice.
1.1.4
New Source Performance Standards (NSPS) (Section 306 of the
CWA)
NSPS reflect effluent reductions that are achievable based on the best available
demonstrated control technology. New facilities have the opportunity to install the best and most
efficient production processes and wastewater treatment technologies. As a result, NSPS should
represent the most stringent controls attainable through the application of the best available
control technology for all pollutants (i.e., conventional, nonconventional, and priority pollutants).
In establishing NSPS, EPA is directed to take into consideration the cost of achieving the effluent
reduction and any non-water quality environmental impacts and energy requirements.
1.1.5
Pretreatment Standards for Existing Sources (PSES)
(Section 307(b) of the CWA)
PSES are designed to prevent the discharge of pollutants that pass through,
interfere with, or are otherwise incompatible with the operation of publicly-owned treatment
works (POTWs). The CWA authorizes EPA to establish pretreatment standards for pollutants
that pass through POTWs or interfere with treatment processes or sludge disposal methods at
POTWs. Pretreatment standards are technology-based and analogous to BAT effluent limitations
guidelines.

The General Pretreatment Regulations, which set forth the framework for the
implementation of categorical pretreatment standards, are found at 40 CFR Part 403. Those
1-3

-------
Section 1.0 - Legal Authority
regulations contain a definition of pass-through that addresses localized rather than national
instances of pass-through and establish pretreatment standards that apply to all nondomestic
dischargers (see 52 FR 1586, January 14, 1987).
1.1.6
Pretreatment Standards for New Sources (PSNS)
(Section 307(b) of the CWA)
Like PSES, PSNS are designed to prevent the discharges of pollutants that pass
through, interfere with, or are otherwise incompatible with the operation of POTWs. PSNS are
to be issued at the same time as NSPS. New indirect dischargers have the opportunity to
incorporate into their plants the best available demonstrated technologies. The Agency considers
the same factors in promulgating PSNS as it considers in promulgating NSPS.
1.2
Section 304dn) Requirements
Section 304(m) of the CWA, added by the Water Quality Act of 1987, requires
EPA to establish schedules for (1) reviewing and revising existing effluent limitations guidelines
and standards ("effluent guidelines") and (2) promulgating new effluent guidelines. On
January 2,1990, EPA published an Effluent Guidelines Plan (55 FR 80) that established
schedules for developing new and revised effluent guidelines for several industry categories.
One of the industries for which the Agency established a schedule was the TECI.

In 1992, EPA entered into a Consent Decree requiring proposal and final agency
action of effluent limitations guidelines and standards final rule for the TECI (NRDC vs.
Browner D.D.C. 89-2980). In December of 1997, the Plaintiffs and EPA agreed to modify the
deadlines for proposal to May 15,1998 and a deadline of June 15, 2000 for final action.
1-4

-------
                                                                       Section 1.0 - Legal Authority
1.3
Pollution Prevention Act
              In the Pollution Prevention Act (PPA) of 1990 (42 U.S.C. 13101 et seq.. Pub. Law
101-508, November 5, 1990), Congress declared pollution prevention a national policy of the
United States. The PPA declares that pollution should be prevented or reduced at the source
whenever feasible; pollution that cannot be prevented should be recycled in an environmentally
safe manner whenever feasible; pollution that cannot be prevented or recycled should be treated;
and disposal or other release into the environment should be chosen only as a last resort and
should be conducted in an environmentally safe manner. The PPA directs EPA to, among other
things, "review regulations of the Agency prior and subsequent to their proposal to determine
their effect on source reduction" (Sec. 6604; 42 U.S.C.  13103(b)(2)).  This proposed regulation
for the TECI was reviewed for its incorporation of pollution prevention as part of the Agency
effort.  Pollution prevention practices applicable to the TECI are described in Section 8.1.
                                           1-5

-------

-------
                                                                     Section 2.0 - Summary and Scope
2.0
SUMMARY AND SCOPE
              The proposed regulations for the Transportation Equipment Cleaning Industry
(TECI) include effluent limitations guidelines and standards for the control of pollutants in
wastewater. This document presents the information and rationale supporting the proposed
effluent limitations guidelines and standards.  Section 2.0 highlights the applicability,
subcategorization, and technology bases of the proposed rule.
2.1
Applicability of the Proposed Regulation
              Transportation equipment cleaning (TEC) facilities are defined as those facilities
that generate wastewater from cleaning the interior of tank trucks, closed-top hopper trucks, rail
tank cars, closed-top hopper rail cars, intermodal tank containers, inland tank barges, closed-top
hopper barges, ocean/sea tankers, and other similar tanks (excluding drums and intermediate bulk
containers) used to transport materials or cargos that come into direct contact with the tank or
container interior. Facilities which do not engage in cleaning the interior of tanks are not
considered within the scope of this proposal.

              The focus of this proposed rule is on transportation equipment cleaning facilities
that function independently of other industrial activities that generate wastewater.  This proposal
would therefore not apply to wastewater discharges from transportation equipment cleaning
operations located at industrial facilities regulated under other Clean Water Act (CWA) effluent
guidelines, provided that the facility cleans only tanks containing cargos or commodities
generated or used on site, or by  a facility under the same corporate structure.
              The wastewater flows covered by the proposed rule include all washwaters which
have come into direct contact with the tank or container interior including prerinse cleaning
solutions, chemical cleaning solutions, and final rinse solutions.  Additionally, the rule would
cover wastewater generated from washing vehicle exteriors, and equipment and floor washings
for those facilities covered by the proposed guidelines.
                                           2-1

-------
                                                                  Section 2.0 - Summary and Scope

             EPA has identified an estimated population of 1,239 TEC facilities that are not

already covered by other CWA effluent guidelines. EPA estimates that 341 facilities will be

affected by the proposal.
2.2
Subcategorization
              EPA is proposing to subcategorize the TEC point source category into 11

subcategories based on types of cargos carried and transportation mode. The subcategories are

listed below and are described in Table 2-1 at the end of this section.
                    Subcategory A:
                    SubcategoryB:
                    Subcategory C:
                    Subcategory D:
                    Subcategory E:
                    Subcategory F:
                    Subcategory G:
                    Subcategory H:
                    Subcategory I:
                    Subcategory J:
                    Subcategory K:
                      Truck/Chemical;
                      Rail/Chemical;
                      Barge/Chemical & Petroleum;
                      Truck/Food;
                      Rail/Food;
                      Barge/Food;
                      Truck/Petroleum;
                      Rail/Petroleum;
                     Truck/Hopper;
                     Rail/Hopper; and
                      Barge/Hopper.
 2.3
Summary of Proposed Rule
              The components of the proposed rules applicable to each subcategory of the TECI

 are shown in Table 2-2 and are described in the following subsections.
 2.3.1
 Best Practicable Control Technology Currently Available
 (BPT)
              EPA is proposing BPT for the three chemical subcategories of the TECI to control

 priority, nonconventional, and conventional pollutants in wastewater from direct dischargers.
 EPA is also proposing BPT for the three food grade subcategories of the TECI to control

 conventional pollutants in wastewater from direct dischargers. The specific pollutants controlled
                                           2-2

-------
Section 2.0 - Summary and Scope
vary for each subcategory. Table 2-3 summarizes the technology basis for BPT for each
regulated subcategory. Tables 2-4 through 2-9 present the proposed effluent limitations
guidelines for each regulated subcategory.
2.3.2
Best Conventional Pollutant Control Technology (BCT)
EPA is proposing BCT equivalent to BPT for the three chemical and three food
grade subcategories of the TECI to control conventional pollutants in wastewater from direct
dischargers. Table 2-3 summarizes the technology basis for BCT for each regulated subcategory.
Tables 2-4 through 2-9 present the proposed effluent limitations guidelines for each regulated
subcategory.
2.3.3
Best Available Technology Economically Achievable (BAT)
EPA is proposing BAT equivalent to BPT for the three chemical subcategories of
the TECI to control priority and nonconventional pollutants in wastewater from direct
dischargers. EPA is not proposing BAT for the food subcategories because EPA is not proposing
to regulate any priority pollutants in these subcategories. The specific pollutants controlled vary
for each subcategory. Table 2-3 summarizes the technology basis for BAT for each regulated
subcategory. Tables 2-4 through 2-6 present the proposed effluent limitations guidelines for each
regulated subcategory.
2.3.4
New Source Performance Standards (NSPS)
EPA is proposing NSPS for the three chemical subcategories of the TECI to
control priority, nonconventional, and conventional pollutants in wastewater from new direct
dischargers. EPA is also proposing NSPS for the three food grade subcategories of the TECI to
control conventional pollutants in wastewater from new direct dischargers. The specific
pollutants controlled vary for each subcategory. Table 2-3 summarizes the technology basis for
2-3

-------
                                                                   Section 2.0 - Summary and Scope
NSPS for each regulated subcategory. Tables 2-4 through 2-9 present the proposed effluent
limitations guidelines for each regulated subcategory.
2.3.5
Pretreatment Standards for Existing Sources (PSES)
              EPA is proposing PSES for two chemical subcategories of the TECI to control
priority and nonconventional pollutants in wastewater from indirect dischargers.  The specific
pollutants controlled vary for each subcategory. Table 2-10 summarizes the technology basis for
PSES for each regulated subcategory. Tables 2-11 through 2-13 present the proposed
pretreatment standards for each regulated subcategory for discharges to publicly-owned treatment
works (POTWs).
 2.3.6
Pretreatment Standards for New Sources (PSNS)
              EPA is proposing PSNS for the three chemical subcategories of the TECI to
 control priority and nonconventional pollutants in wastewater from new indirect dischargers.
 The specific pollutants controlled vary for each subcategory.  Table 2-10 summarizes the
 technology basis for PSNS for each regulated subcategory. Tables 2-11 through 2-13"present the
 proposed pretreatment standards for each regulated subcategory for discharges to POTWs.
                                            2-4

-------
                                                      Section 2.0 - Summary and Scope
                              Table 2-1

Proposed Subcategorization for the Transportation Equipment Cleaning
                              Industry
Proposed Subcafegory
A
B
C
D
E
F
G
H
I
J
K
Truck/Chemical
Rail/Chemical
Barge/Chemical &
Petroleum
Truck/Food
Rail/Food
Barge/Food
Truck/Petroleum
Rail/Petroleum
Truck/Hopper
RaMIopper
Barge/Hopper
' , -^'^^'V:^'X^l^%te^^De^P^(^'" -;, V " :, \ -J C,
TEC facilities that clean tank trucks and intermodal tank containers where 10% or
more of the total tanks cleaned at that facility in an average year contained
chemical cargos.
TEC facilities that clean rail tank cars where 10% or more of the total tanks
cleaned at that facility in an average year contained chemical cargos.
TEC facilities that clean tank barges or ocean/sea tankers where 10% or more of
the total tanks cleaned at that facility in an average year contained chemical and/or
petroleum cargos.
TEC facilities that clean tank trucks and intermodal tank containers where 10% or
more of the total tanks cleaned at that facility in an average year contained food
grade cargos, so long as that facility does not clean 10% or more of tanks
containing chemical cargos. If 10% or more of the total tanks cleaned at that
facility in an average year contained chemical cargos, then that facility is in
Subcategory A: Truck/Chemical.
TEC facilities that clean rail tank cars where 10% or more of the total tanks
cleaned at that facility in an average year contained food grade cargos, so long as
that facility does not clean 10% or more of tanks containing chemical cargos. If
10% or more of the total tanks cleaned at that facility in an average year contained
chemical cargos, then that facility is in Subcategory B: Rail/Chemical.
TEC facilities that clean tank barges or ocean/sea tankers where 10% or more of
the total tanks cleaned at that facility in an average year contained food grade
cargos, so long as that facility does not clean 10% or more of tanks containing
chemical cargos. If 10% or more of the total tanks cleaned at that facility in an
average year contained chemical and/or petroleum cargos, then that facility is in
Subcategory C: Barge/Chemical & Petroleum.
TEC facilities that clean tank trucks and intermodal tank containers where 80% or
more of the total tanks cleaned at that facility in an average year contained
petroleum cargos, so long as that facility is not in Subcategory A: Truck/Chemical
or Subcategory D: Truck/Food.
TEC facilities that clean rail tank cars where 80% or more of the total tanks
cleaned at that facility in an average year contained petroleum cargos, so long as
that facility is not in Subcategory B: Rail/Chemical or Subcategory E: Rail/Food.
TEC facilities that clean closed-top hopper trucks which transport dry bulk
commodities that are not chemical commodities.
TEC facilities that clean closed-top hopper rail cars which transport dry bulk
commodities mat are not chemical commodities.
TEC facilities that clean closed-top hopper barges which transport dry bulk
commodities that are not chemical commodities.
                                 2-5

-------
                                                     Section 2.0 - Summary and Scope
                             Table 2-2

Summary of Proposed Rules for the Transportation Equipment Cleaning
                   Industry Point Source Category
Subpart Subcategory
A
B
C
D
E
F
G
H
I
J
! K
Truck/Chemical
Rail/Chemical
Barge/Chemical &
Petroleum
TruckflFood
Rail/Food
Barge/Food
Truck/Petroleum
Rail/Petroleum
Truck/Hopper
Rail/Hopper
Barge/Hopper
PSJES
•
•




BET
•
•
•
•
•
•
BAT
•
•
•



BCT
•
•
•
•
•
•
PSNS; '
•
•
•



NSPS
•
•
•
•
•
•
No regulations
No regulations
                                 2-6

-------
                                              Section 2.0 - Summary and Scope
                       Table 2-3
Summary of Technology Basis for BPT, BCT, BAT, and NSPS
Proposed, Strt> category
A
B
B
C
D
E
F
Truck/Chemical
Rail/Chemical
Rail/Chemical
Barge/Chemical &
Petroleum
Truck/Food
Rail/Food
Barge/Food
';lX|'V;;-' ^ - Technology Basis ,„ ' ' ,-
BPT
BCT
BAT
NSPS
BPT
BCT
BAT
NSPS
BPT
BCT
BAT
NSPS
BPT
BCT
NSPS
BPT
BCT
NSPS
BPT
BCT
NSPS
Flow reduction; Equalization; Oil/water separation; Turn-key
treatment system including chemical oxidation, neutralization,
coagulation, and clarification; Biological treatment;
Carbon adsorption; and Sludge dewatering.
Flow reduction; Oil/water separation; Biological treatment; and
Sludge dewatering.
Flow reduction; Equalization, Dissolved Air Flotation; Biological
treatment; Organo-clay/activated carbon filtration; and Sludge
dewatering.
Flow reduction; Oil/water separation; Dissolved air flotation; Filter
press (in-line wastewater treatment); Biological treatment; and Sludge
dewatering.
Flow reduction; Oil/water separation; Biological treatment; and
Sludge dewatering.
Flow reduction; Oil/water separation; Biological treatment; and
Sludge dewatering.
Flow reduction; Oil/water separation; Biological treatment; and
Sludge dewatering.
                         2-7

-------
                                                            Section 2.0 - Summary and Scope
                                   Table 2-4
 Truck/Chemical Subcategory: BPT, BCT, BAT, and NSPS Proposed Mass
             Based Limitations for Discharges to Surface Waters


Pollutant or
Pollutant Property
BOD5 (a)
TSS(b)
Oil and Grease
(HEM)(c)
Chromium
Zinc
COD (d)
Bis (2-ethylhexyl)
Phthalate
Di-n-Octyl Phthalate
n-Dodecane
n-Hexadecane
Styrene
1 ,2-DichIorobenzene
[Grams/Tank]
BPT
Daily
Maximum
145
281
25.3
0.16
0.09
3760
0.12
0.12
0.12
0.12
0.20
0.12
Monthly
Average-
67.6
115
16.1
0.16
0.09
3760
0.12
0.12
0.12
0.12
0.20
0.12
BCT
Daily
Maximum
145
281
25.3
NA
NA
NA
• NA
NA
NA
NA
NA
NA
Monthly
Average
67.6
115
16.1
NA
NA
NA
NA
NA
NA
NA
NA
NA
BAT
Daily
Maximum/
Monthly
Average
NA
NA
NA
0.16
0.09
3760
0.12
0.12
0.12
0.12
0.20
0.12
' NSPS
Daily
Maximum
145
281
25.3
0.16
0.09
3760
0.12
0.12
0.12
0.12
0.20
0.12
<
Monthly^
' Average ,
67.6
115
16.1
0.16
0.09
3760
0.12
0.12
0.12
0.12
0.20
0.12
(a) BOD5 - Biochemical oxygen demand (5-day).
(b) TSS - Total suspended solids.
(c) HEM - Hexane extractable material.
(d) COD - Chemical oxygen demand.
NA - Not applicable.
                                       2-8

-------
                                                                 Section 2.0 - Summary and Scope
                                       Table 2-5
   Rail/Chemical Subcategory: BPT, BCT, BAT, and NSPS Proposed Mass Based
                     Limitations for Discharges to Surface Waters
Pollutant or Pollutant
Property
BOD5 (a)
TSS (b)
Oil and Grease (HEM)
(c)
COD (d)
n-Dodecane
n-Hexadecane
n-Tetradecane
Anthracene
Pyrene
Fluoranthene
Phenanthrene
* A *,'/•
£
Daily
Maximum
3,840
338
470
42,200
0.63
0.43
0.43
2.20
0.68
0.74
1.96
&^/s-'&'"
ifc
1,790
141
286
42,200
0.63
0.43
0.43
2.20
0.68
0.74
1.96
=— =— — — i
"''^,, ' [Grams/Tahiti '' ' ' "; ^ ,,\:-/ ;,„,
t , BC? -:.
-j Daily
Maximum
3,840
338
470
NA
NA
NA
NA
NA
NA
NA
NA
—
Monthly
Average
1,790
141
286
NA
NA
NA
NA
NA
NA
NA
NA
BAT
Daily
Maximiirn/
Monthly '
Average
NA
NA
NA
42,200
0.63
0.43
0.43
2.20
0.68
0.74
1.96
- S"SSP&/S"O
Daily
Maximum
3,840
338
130
42,200
0.43
0.43
0.43
2.20
0.68
0.74
1.96
\ NX '
Average
1,790
141
83
42,200
0.43
0.43
0.43
2.20
0.68
0.74
1.96
(a) BOD5 - Biochemical oxygen demand (5-day).
(b) TSS - Total suspended solids.
(c) HEM - Hexane extractable material.
(d) COD - Chemical oxygen demand.
NA - Not applicable.
                                         2-9

-------
                                                               Section 2.0 - Summary and Scope
                                     Table 2-6
 Barge/Chemical & Petroleum Subcategory:  BPT, BCT, BAT, and NSPS Proposed
             Mass Based Limitations for Discharges to Surface Waters
Pollutant or Pollutant
Property
BODj (a)
TSS(b)
Oil and Grease (HEM)
(c)
COD (d)
Cadmium
Chromium
Copper
Lead
Nickel
Zinc
1-Methylphenanthrene
Bis (2-ethylhexyl)
Phthalate
Di-n-Octyl Phthalate
n-Decane
n-Docosane
n-Dodecane
n-Eicosane
n-Octadecane
n-Tetracosane
n-Tetradecane
p-Cymene
Pyrene
- (Grams/TankJ ^ " f
Bpxr —
Daily
Maximum
18,300
9,540
658
74,300
0.19
1.82
2.17
1.93
15.3
153
2.04
1.88
2.68
5.96
3.02
16.7
6.67
7.45
2.19
7.30
0.29
1.20
Monthly
Average
8,600
6,090
294
74,300
0.19
1.82
2.17
1.93
15.3
153
2.04
1.88
2.68
5.96
3.02
16.7
6.67
7.45
2.19
7.30
0.29
1.20
5CT
Daily '
Maximum
18,300
9,540
658
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Monthly
Average
8,600
6,090
294
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
BAT
Daily
Maximum/
Monthly
Average
NA
NA
NA
74,300
0.19
1.82
2.17
1.93
15.3
153
2.04
1.88
2.68
5.96
3.02
16.7
6.67
7.45
2.19
7.30
0.29
1.20
NSPS
Daily
Maximum
18,300
9,540
658
74,300
.0.19
1.82
2.17
1.93
15.3
153
2.04
1.88
2.68
5.96
3.02
16.7
6.67
7.45
2.19
7.30
0.29
1.20
-J
>Mo«flilyJ
"Average;;
8,600
6,090
294
74,300
0.19
1.82
2.17
1.93
15.3
153
2.04
1.88
2.68
5.96
3.02
16.7
6.67
7.45
2.19
7.30
0.29
1.20
(a) BODj - Biochemical oxygen demand (5-day).
(b) TSS - Total suspended solids.
(c) HEM - Hexane extractable material.
(d) COD - Chemical oxygen demand.
NA - Not applicable.
                                         2-10

-------
                                                                Section 2.0 - Summary and Scope
                                      Table 2-7
Truck/Food Subcategory: BPT, BCT, and NSPS Proposed Mass Based Limitations
                          for Discharges to Surface Waters
Pollutant or
Pollutant Property
BOD5 (a)
TSS (b)
Oil and Grease
(HEM) (c)
^ rdrams/Tankl ' - c.-%*'^\- - ' , v
* * > f '• J" •• "> •• * •,*•• -.' f ' :•.-.,">. '' "• ' ^ v^ 0 ,f
BPT
Daily
Maximum
166
673
60.4
Monthly
Average
72.4
256
26.3
SOT
; Bafly
Maximum
166
673
60.4
Monthly
Average
72.4
256
26.3
BAT
Daily
Maximum/ „
Monthly
, Average %
NA
NA
NA
' v -1SSBS' V's''
^ -.5
/Daily ,
, Maximum
166
673
60.4
.Monthly-;
Average-,
72.4
256
26.3
(a) BOD5 - Biochemical oxygen demand (5-day).
(b) TSS - Total suspended solids.
(c) HEM - Hexane extractable material.
NA - Not applicable.
                                          2-11

-------
                                                                Section 2.0 - Summary and Scope
                                       Table 2-8
 Rail/Food Subcategory: BPT, BCT, and NSPS Proposed Mass Based Limitations
                          for Discharges to Surface Waters
Pollutant or
Pollutant
Property
BOD5 (a)
TSS(b)
Oil and Grease
(HEM)(c)
[Grams/Tank] " *
BPT
Dafly
Maximum
945
3,830
344
Monthly
Average
412
1,460
150
BCT
Daily
Maximum
945
3,830
344
Monthly
Average
412
1,460
150
BAT
Daily
Maximum/
Monthly
;Average
NA
NA
NA
NSPS ^ " '/
DaDy
Maximum
945
3,830
344
'Monthly
Average .
412
1,460
150
(a) BODj - Biochemical oxygen demand (5-day).
(b) TSS - Total suspended solids.
(c) HEM - Hexane extractable material.
NA - Not applicable.
                                          2-12

-------
                                                                 Section 2.0 - Summary and Scope
                                       Table 2-9
 Barge/Food Subcategory:  BPT, BCT, and NSPS Proposed Mass Based Limitations
                           for Discharges to Surface Waters
Pollutant or
Pollutant Property
BOD5 (a)
TSS (b)
Oil and Grease (HEM)
(c)
f*S £ / '
BPT; f^; ;„,
Dafly
Maximum
945
3,830
344-

''Vv ' , '
Monthly'-
Average-^
412
1,460
150
===
[Grams/Tank] , , , \ f
,BCT
•^
Bafly
TVTaTfimiim

945
3,830
344
=====
Monihly
Average
412
1,460
150
=====
BAT
JDaily
Mavimnm/
Monthly -
s Average '
NA
NA
NA
=====
-NSPS, ' ; ?':j
P^y
Maximum
945
3,830
344
========
Monthly
Average'-".
412
1,460
150
=====
(a) BOD5 - Biochemical oxygen demand (5-day).
(b) TSS - Total suspended solids.
(c) HEM - Hexane extractable material.
NA - Not applicable.
                                         2-13

-------
                                          Section 2.0 - Summary and Scope
                   Table 2-10
Summary of Technology Basis for PSES and PSNS
Proposed Subcategory
A
B
B
C
Truck/Chemical
Rail/Chemical
Rail/Chemical
Barge/Chemical &
Petroleum
' - Technology Basis
PSES
&
PSNS
PSES
PSNS
PSNS
How reduction; Equalization; Oil/water separation; Turn-key treatment
system including chemical oxidation, neutralization, coagulation, and
clarification; Carbon adsorption; and Sludge dewatering.
How reduction; and Oil/water separation.
How reduction; Oil/water separation; Equalization; Dissolved air
flotation; Organo-clay/activated carbon filtration; and Sludge dewatering.
How reduction; Oil/water separation; Dissolved air flotation; Filter press
(in-line wastewater treatment); Biological treatment; and Sludge
dewatering.
                      2-14

-------
                                                       Section 2.0 - Summary and Scope
                               Table 2-11
    Truck/Chemical Subcategory:  PSES and PSNS Proposed Mass Based
                   Limitations for Discharges to POTWs


<
Pollutant or Pollutant Property
Chromium
Zinc
COD (a)
Bis (2-ethylhexyl) Phthalate
Di-n-Octyl Phthalate
n-Dodecane
n-Hexadecane
Styrene
1 ,2-Dichlorobenzene
-- ,
'»
'- s ' - .. " PS'
-Daily X
, ' Maxtmum
0.20
0.12
3760
0.23
0.15
0.19
0.19
0.40
0.15


ES* -
'MontKly
„- ' Average - '
0.20
0.12
3760
0.23
0.15
0.19
0.19
0.40
0.15
'1-1' -,; "*>•** •
.,
\j*S
/Patty ;
Maximum
0.20
0.12
3760
0.23
0.15
0.19
0.19
0.40
0.15

- ' // , ?-'&t
m^' ;v'^
Mpntldy r
0.20
0.12
3760
0.23
0.15
0.19
0.19
0.40
0.15
(a) COD - Chemical oxygen demand.
                                  2-15

-------
                                                          Section 2.0 - Summary and Scope
                                 Table 2-12
    Rail/Chemical Subcategory:  PSES and PSNS Proposed Mass Based
                   Limitations for Discharges to POTWs
r 	 ~"
Pollutant or Pollutant Properly
Total Petroleum Hydrocarbons (SGT-HEM) (a)
COD(b)
n-Hexadecane
n-Tetradecane
Fluoranthene
; [Grams/^ank] ,
PSES
Daily
Maximum
942
42,200
2.56
3.98
0.60
Monthly
Average
942
42,200
2.56
3.98
0.60
PSNS -
s'''
Daily
Maximum
207
42,200
2.56
0.66
0.60
— =
. Monthly
Average
207
42,200
2.56
0.66
0.60
(a) SGT-HEM - Silica-gel treated hexane extractable material.
(b) COD - Chemical oxygen demand.
                                      2-16

-------
                                                           Section 2.0 - Summary and Scope
                                 Table 2-13
Barge/Chemical & Petroleum Subcategory:  PSES and PSNS Proposed Mass
                 Based Limitations for Discharges to POTWs
-• f\
Pollutant or Pollutant Property
Total Petroleum Hydrocarbons (SGT-HEM) (a)
COD (b)
Cadmium
Chromium
Copper
Lead
Nickel
Zinc
1 -Methylphenanthrene
Bis (2-ethylhexyl) Phthalate
Di-n-Octyl Phthalate
n-Decane
n-Docosane
n-Dodecane
n-Eicosane
n-Octadecane
n-Tetracosane
n-Tetradecane
p-Cymene
Pyrene
- ^ } ' ^ t&rams/Tankl - ,- '/""- ' -' {;
; s ; ; -, PSES
Daily,
Maximum :
NA
NA
NA
NA
NA
NA
NA
• NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Monthly
Average
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA .
NA
NA
^ t -, psNsy - 'i
, Daily ,
, Maximum *
347
74,300
0.51
0.61
79.9
5.04
39.1
241
9.70
2.05
7.69
7.26
3.67
20.3
8.13
9.07
5.51
8.90
2.21
2.94
Monday
Average ~
347
74,300
0.51
0.61
79.9
5.04
39.1
241
9.70
2.05
7.69
7.26
3.67
20.3
8.13
9.07
5.51
8.90
2.21
2.94
(a) SGT-HEM - Silica-gel treated hexane extractable material.
(b) COD - Chemical oxygen demand.
NA - Not applicable.
                                     2-17

-------

-------
Section 3.0 - Data Collection Activities
3.0
DATA COLLECTION ACTIVITIES
EPA collected data from a variety of sources including existing data from
previous EPA and other governmental data collection efforts, industry provided information, data
collected from questionnaire surveys, and field sampling data. Each of these data sources is
discussed below, as well as the quality assurance/quality control (QA/QC) and other data editing
procedures. Summaries and analyses of the data collected by EPA are presented in Sections 4.0
through 12.0.
3.1
Summary of TECI Information Collected Prior to 1992
Prior to 1992, EPA conducted two studies of the TECI. The first study was
performed during the 1973-74 period for the Transportation Industry Point Source Category.
This broad study of the transportation industry was not specific to TEC processes and
wastewaters and did not result in any regulations for the TECI. Information from the first study
was obtained from only a few TEC facilities and was limited to conventional pollutants. Because
of the age of this study, EPA did not use any data from this study in the development of the
proposed rule.

In 1989, EPA published the Preliminary Data Summary for the Transportation
Equipment Cleaning Industry (1). This second study was performed in response to the Domestic
Sewage Study, which identified TEC facilities as potentially discharging high levels of
conventional, toxic, and nonconventional pollutants in raw and treated wastewaters. The study
was a preliminary investigation to determine the size of the TECI and to estimate the total
discharge of priority pollutants. EPA used this data to perform an environmental impact analysis
which formed the basis for EPA's decision to develop effluent guidelines specifically for the
TECI.
For the second study, the Agency sampled eight TEC facilities between 1986-87,
including one aircraft, three tank truck, two rail tank car, and two tank barge cleaning facilities.
3-1

-------
                                                                 Section 3.0 - Data Collection Activities
Raw TEC wastewater, treated effluent, and sludge were collected and analyzed at each facility.
The samples were analyzed for analytes on the 1987 Industrial Technology Division List of
Analytes. This list contains conventional pollutants, EPA's priority pollutants (excluding fecal
coliform bacteria and asbestos), and 285 additional organic and inorganic nonconventional
pollutants or pollutant characteristics.
3.2
Summary of the TECI Questionnaires
              A major source of information and data used in developing effluent limitations
guidelines and standards was industry responses to technical and economic questionnaires
distributed by EPA under the authority of Section 308 of the Clean Water Act.  These
questionnaires requested information concerning tank cleaning operations and wastewater
generation, treatment and discharge, as well as wastewater characterization data.  Questionnaires
also requested financial and economic information for use in assessing economic impacts and the
economic achievability of technology options.
3.2.1
Identification of Potential TECI Population
              In order to characterize the TECI, EPA first developed a potential list of TEC
facilities by identifying all potential segments within the industry. EPA characterized the TECI
into industry segments based on tank type cleaned (truck, rail, barge, etc.) and business
operational structure (independents, carriers, shippers, and builder/leasers) as described in
Section 4.0. Since transportation facilities may clean a variety of tank types and may perform a
variety of business operations, TEC facilities may have been classified under more than one of
these tank type and operational structure segments.
              The Agency was unaware of any single source or set of sources that specifically
identify facilities that perform TEC operations.  Likewise, there is no single Standard Industrial
Classification (SIC) code or set of SIC codes that specifically identify facilities that perform TEC
operations.  Therefore, a variety of sources were identified and evaluated including transportation

                                           3-2

-------
                                                                  Section 3.0 - Data Collection Activities
industry directories, Dun and Bradstreet's Information Services, several Agency databases, trade
journals, trade associations, and contacts with state and local authorities.

              The Agency performed an exhaustive search to identify all available sources
listing facilities that potentially perform TEC operations.  In addition to obtaining lists of
facilities known to be performing TEC activities, data sources were also used to identify potential
TEC facilities by one or more of the following criteria: (1) they own, operate, or maintain
transportation equipment (tank trucks, rail tank cars, tank barges); (2) they own, operate, or
maintain equipment used by the transportation segments applicable to the TECI (truck haulage,
rail transportation, and water transportation); or (3) they report under an SIC code that includes
facilities that have the potential to own, operate, or maintain transportation equipment (e.g., local
liquid haulage, marine cargo handling, loading or unloading vessels). Table 3-1 lists the major
sources identified by EPA by tank type and business operational structure.

              The list of facilities obtained from different sources varied in terms of the
probability that the facilities on the list actually performed TEC operations. For example, EPA
considered facilities identified through trade association lists or telephone contacts to have a high
probability of performing TEC operations, while facilities identified through the various SIC
codes had a lower likelihood of actually performing TEC  operations. In order to account for the
variation in the quality of data sources, each facility in the TECI site identification database was
assigned a level of assurance representing the probability  that the facility performs TEC
operations.
              Facilities were assigned level of assurances of either high, medium, or low based
upon the Agency's evaluation of information provided by each facility source, including
information provided by industry and trade association representatives, research of industrial
practices, and information obtained during telephone conversations. In general, a high level of
assurance indicated that a facility was specifically identified as performing TEC operations.
Facilities assigned a medium level of assurance were identified as either owning, operating, or
maintaining transportation equipment or performing cleaning of transportation equipment (not

                                            3-3

-------
                                                                  Section 3.0 - Data Collection Activities
specifically tanks) in the transportation segments applicable to the TECI (e.g., SIC Codes 4789-
0402 Railroad Car Repair and 4789-0401 Cleaning Railroad Trailers). A low level of assurance
was assigned to facilities identified as owning, operating, or maintaining equipment related to the
transportation industry with no indication of whether cleaning operations are performed (e.g.,
SIC Code 4491-0101 Marine Cargo Handling, Loading Vessels). Table 3-2 includes a complete
list of sources and source level of assurance used to identify potential TEC facilities.

              EPA identified a total potential industry population of 30,280 facilities by
compiling the lists from all sources.  EPA then constructed a database, called the TECI site
identification database, of 7,940 facilities that potentially clean tank interiors. For some data
sources, only a portion (i.e., a statistical sample) of the total available records were entered into
the database. Therefore, the 7,940 facilities contained in TECI site identification database
represents a total potential industry population of 30,280 facilities. For each potential TEC
facility identified, the following data were entered into the database:  facility type (e.g., truck,
rail), facility name, facility address, facility telephone numbers, primary and secondary facility
contacts, source(s) of facility information, and level of assurance.

               Since multiple sources were used to identify the TEC population, duplicate
searches were performed  on the database to ensure that there were no duplicate records in the
TECI site identification database.  This database served as the initial population for EPA to
collect industry provided data.

               During identification of the potential TECI population and development of the
Screener Questionnaire sample frame (see Section 3.2.2.1), the Agency included facilities that
clean the exteriors of aircraft and facilities that deice/anti-ice aircraft and/or pavement in the
scope of the TECI.  As such, the Agency endeavored to identify the population of facilities that
perform these operations and entered information for these facilities into the TECI site
identification database. The TECI site identification database includes information for an
additional 3,960 facilities that potentially clean the exteriors of aircraft or deice/anti-ice aircraft
and/or pavement. These 3,960 facilities represent a total potential industry population of 4,781

                                             3-4

-------
                                                                Section 3.0 - Data Collection Activities
facilities. However, the Agency has decided to postpone consideration of developing effluent
limitations guidelines and standards for this segment. Therefore, references to the aircraft
segment in this section are limited to those required to accurately describe the statistical sampling
performed to develop the TECI Screener Questionnaire mailing list (see Section 3.2.2.3).
3.2.2
1993 Screener Questionnaire for the Transportation
Equipment Cleaning Industry (Screener Questionnaire)
              The objectives of the Screener Questionnaire were to:
 3.2.2.1
•      Identify facilities that perform TEC operations;
•      Evaluate TEC facilities based on wastewater, economic, and/or operational
       characteristics;
•      Develop technical and economic profiles of the TECI;
•      Select a statistical sample of screener respondents to receive a Detailed
       Questionnaire (see Section 3.2.3) such that the sample responses may be
       used to characterize the TECI; and
•      Select facilities for EPA's TECI engineering site visit and sampling
       program.
Development of the Screener Questionnaire Sample Frame
              In order to gather all available information on the TECI, the Agency could have
 mailed Screener Questionnaires to all 11,900 facilities in the TECI site identification database;
 however, the Agency decided that a sample size of 4,000 would sufficiently represent the variety
 of technical and economic characteristics of the TECI and meet the objectives of the Screener
 Questionnaire while minimizing the burden to both industry and government. Therefore, a
 database containing information on potential TEC facilities was developed from a sample of
 4,000 facilities (including both tank interior cleaning and aircraft deicing facilities).
 Development of the statistical sample frame for the Screener Questionnaire is discussed below.
                                            3-5

-------
                                                                 Section 3.0 - Data Collection Activities
              Facilities were selected from the TECI site identification database to receive a
Screener Questionnaire based upon two factors: (1) facility type (i.e., tank truck cleaning, rail
tank car cleaning, tank barge cleaning, transfer facilities, and aircraft segment), and
(2) probability of performing TEC operations (level of assurance, as discussed in Section 3.2.1).
This selection approach divides the TECI into 15 distinct categories or cells (i.e.; five facility
types times three levels of assurance).

              Since facilities that were specifically identified as performing TEC operations
were assigned a high level of assurance, all records in the TECI site identification database with a
high level of assurance were selected for the mailing list. The initial sample size selected from
the remaining cells was calculated using the following equation (2), which minimizes the
statistical variance for a fixed total sample size:
where:
              n
              N
              Oh
                                       R
                              nh  = n
                                                           (1)
Cell (e.g., barge-medium)
Total number of facilities remaining to be allocated [4,000 - 1,211
(high) = 2,789]
Sample size for each cell
Total number of facilities in each cell for which records are
available
Probability of performing TEC operations
1-P,
The Agency estimated that 15% of facilities with a low level of assurance perform TEC
operations, and assigned a Ph value of 0.15 to these facilities.  This estimate was based on
contacts with a representative sample of facilities in the TECI, contacts with trade associations,

                                            3-6

-------
; Section 3.0 - Data Collection Activities
and information contained in facility identification sources. Similarly, a Ph value of 0.50 was
assigned to the medium level-of-assurance facilities since the Agency estimated that 50% of
these facilities perform TEC operations.

The Agency performed statistical precision estimates based on the sample cell
sizes determined by equation (1) and the assigned Ph value for the medium and low level-of-
assurance cells. These precision estimates predicted unacceptably high statistical variances for
cells with a medium level of assurance and less than 400 records in the TECI site identification
database (rail-medium, transfer-medium, and barge-medium). Therefore, all records within these
cells were selected for the mailing list.

Equation (1) was then reapplied to the remaining cells from which random
samples would be selected. The total number of facilities to be allocated, n, was revised from
2,789 to 2,205 after eliminating the three additional census cells (i.e., 4,000 - 1,211 (high) - 218
(rail-medium) - 357 (barge-medium) - 9 (transfer-medium) = 2,205). Table 3-3 summarizes the
final distribution of facilities in the TECI Screener Questionnaire mailing list by facility type and
level of assurance. .

Facilities in the TECI site identification database were then randomly selected for
the noncensus cells, with the exceptions of the truck-medium and transfer-low cells. For the
truck-medium cell, a "stratified" random selection of facilities, based on source, was required
because the truck-medium cell includes facilities identified by several sources from which only a
fraction of the potential records available were received as well as by several sources for which
all available records were received (i.e., randomly selecting facilities from this cell, without
consideration of source, would bias sources for which a larger percentage of the records available
were received). To develop an accurate statistical representation of this cell, the Agency
calculated a sample size for each source. Facilities in the truck-medium cell were then selected
randomly within each source using the individually calculated, source-specific sample size, with
the sum of the source-specific sample sizes equalizing to the total number of facilities to be
selected from the truck-medium cell as calculated using equation (1).
3-7

-------
                                                                 Section 3.0 - Data Collection Activities
              Only two facilities were available for selection from the transfer-low cell. Due to

the low probability that the transfer-low facilities perform TEC operations, EPA chose only one

of the two facilities to receive a questionnaire.
3.2.2.2
Development of the Screener Questionnaire
              The Agency requested the following site-specific information for calendar year

1992 in the four-page Screener Questionnaire:
                     Facility name and address;
                     Contact person;
                     Business entity that owns the facility;
                     Number of TEC facilities operated by the business entity;
                     Whether the facility performs TEC operations;
                     Whether the facility generates TEC process wastewater;
                     TEC process wastewater discharge information;
                     Number of tank interior cleanings performed by tank type;  .
                     Percentage of tank interior cleanings performed by cargo type;
                     Types of cleaning processes performed;
                     Facility total average daily wastewater discharge;
                     Wastewater treatment technologies or disposal methods;
                     Facility operational structure (e.g., carrier, independent);
                     Number of employees - total and TEC-related; and
                     Annual revenues - total and TEC-related.
3.2.2.3
Administration of the Screener Questionnaire
              In December 1993, the Agency mailed 3,240 Screener Questionnaires to potential

tank interior cleaning facilities. This Screener Questionnaire mail-out comprised the statistical

sample frame described in Section 3.2.2.1.  Additionally, EPA mailed out Screener

Questionnaires to 28 facilities that transport hazardous waste in order to obtain additional data

for use in determining their applicability under the TECI guideline. For the same reason, EPA

mailed one Screener Questionnaire to a facility that cleans the interiors of ocean/sea tankers.

This facility had been identified subsequent to development of the TECI site identification

database. Since these 29 facilities were not included in the statistical sample population,

                                            3-8

-------
Section 3.0 - Data Collection Activities
responses from these facilities were not used in calculating national estimates for the TECI.
Table 3-4 summarizes the Screener Questionnaire mail-out, follow-up, and receipt activities.

EPA established a toll-free helpline to assist Screener Questionnaire recipients in
completing the questionnaire. The helpline received calls from 698 questionnaire recipients.

Following receipt of the Screener Questionnaire responses, an initial review was
performed to determine whether the facility indicated .that TEC operations were performed at
their location. Facilities that indicated that TEC operations were performed at their location and
that they generated TEC wastewater were preliminarily designated "in-scope" facilities.
Facilities that indicated that TEC operations were performed at their location but that they did not
generate TEC wastewater were designated "dry" facilities. Facilities that indicated that TEC
operations were not performed at their location were designated "out-of-scope" facilities.
Responses from a total of 754 in-scope facilities and 24 dry facilities were received by the
Agency. An additional 245 Screener Questionnaires for which responses were not received were
determined to be either inactive or out-of-scope based on telephone calls or other follow-up
activities. Responses for 90 facilities, approximately two percent of the mailing list, were
unaccounted for (i.e., certified mail cards not returned, Screener Questionnaire returned as
undeliverable, and follow-up phone calls not returned). The remaining responses were from out-
of-scope facilities.

Screener Questionnaire responses from in-scope facilities were then entered into
the Screener Questionnaire database. The quality of responses in the database was evaluated by
performing a number of database range and logic checks. For example, one check verified that
the total number of facility employees exceeded the number of employees that perform TEC-
related activities. The Agency followed up with facilities that "failed" a prioritized list of range
and logic checks to resolve missing or contradictory information.
3-9

-------
                                                                  Section 3.0 - Data Collection Activities
3.2.2.4
Calculation of National Estimates
              Each source used to develop the TECI site identification database was considered
a statistical "stratum" during development of the Screener Questionnaire sample frame. Each
surveyed facility in a stratum represents a specific number of facilities in the national population.
For example, if a surveyed facility falls within stratum "A" and the "weight" of that stratum is 5,
the responses received from that facility represent a total of five facilities in the overall TECI
population. Following receipt of the Screener Questionnaire responses (to account for
nonrespondents), EPA determined a weight associated with each stratum using the following
equation:
                                                 N,
                              Stratum Weight  =
                                                                          (2)
 where:
               n,.
                             Total number of facilities in stratum
                             Number of facilities that responded to the Screener Questionnaire
               Subsequent to administration of the Screener Questionnaire, the Agency reviewed
 the Screener Questionnaire strata and specific facility assignments within the strata and
 determined that post-stratification of certain sources (strata) and adjustment of certain facility
 assignments within the strata would improve the statistical confidence of the strata and reduce
 sample bias within the original sample frame. Post-stratification adjustments made are described
 below. Additional details concerning post-stratification of the Screener Questionnaire sample
 frame are included in reference 3.

                •      Some facilities were identified by multiple sources in multiple
                      transportation types applicable to the TECI (e.g., truck facility in one
                      source and rail facility in another source). For the Screener Questionnaire
                      sample frame, these facilities were classified as "transfer" facilities.
                      During post-stratification, since these facilities are not characteristically
                      different from other facilities in the primary source (facilities identified by
                      multiple sources were assigned a primary source, generally based on the
                                             3-10

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                                                                 Section 3.0 - Data Collection Activities

                     source level of assurance), they were reassigned to the original tank type in
                     the primary source for scale-up purposes.

                     Facilities identified as performing TEC operations based on telephone
                     contacts during development of source level-of-assurance assignments had
                     been classified as "high", regardless of the original source, because EPA
                     knew (i.e., had a high level of assurance) that these facilities performed
                     TEC operations.  Classifying these facilities as "high" biased the national
                     estimates; therefore, these facilities were post-stratified to their original
                     source, facility type, and level of assurance group.

                     In order to reduce the variability of the national estimates, several Screener
                     Questionnaire strata with similar weighting factors were collapsed into a
                     single strata and  assigned a conglomerated weighting factor for the entire
                     collapsed strata.  For example, all censused Screener Questionnaire strata
                     (e.g., truck-high, rail-high, barge-medium), with a few exceptions, were
                     collapsed into a single stratum.
              After incorporating the post-stratification adjustments described above, the
Screener Questionnaire sample frame included 13 strata, which are listed in Table 3-5. EPA
recalculated the survey weighting factors for each of the revised Screener Questionnaire strata
and estimated that the total number of facilities in the TECI was 2,739 facilities.  These data are

also listed in Table 3-5.
3.2.3
1994 Detailed Questionnaire for the Transportation
Equipment Cleaning Industry (Detailed Questionnaire)
              EPA designed and administered a Detailed Questionnaire to a statistical sample of
eligible TEC facilities from the Screener Questionnaire respondents.  The objectives of the
Detailed Questionnaire were to collect detailed site-specific technical and economic information

pertaining to the year 1994 to:
                                            3-11

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3.23.1
Section 3.0 - Data Collection Activities
• Develop an industry profile;
• Characterize TEC processes, industry production (i.e., number and type(s)
of tanks cleaned), and water usage and wastewater treatment;
• Perform an industry subcategorization analysis;
• Develop pollutant loadings and reductions estimates;
• Develop compliance cost estimates; and
• Determine the impacts of the rulemaking on the TECI.

Development of the Detailed Questionnaire Sample Frame
Facilities responding to the Screener Questionnaire were preliminarily identified
as "in-scope" if they performed TEC operations that generated wastewater in 1992. As shown in
Table 3-4, EPA received Screener Questionnaire responses from 754 in-scope facilities. Twenty-
four of these responses were from the second mailing to 29 facilities described in Section 3.2.2.3
that were not part of the statistical sampling effort. Another 16 facilities indicated that although
they performed TEC operations in 1992, they would not be performing these operations in the
future. Therefore, 40 in-scope respondents were ineligible for selection to receive a Detailed
Questionnaire and were not included in the Detailed Questionnaire sample design. The 714
remaining in-scope respondents were then used as a basis for the sample design.

Based on responses to the Screener Questionnaire, four variables were considered
in designing the Detailed Questionnaire sample draw. The four variables were tank type,
operational structure, number of employees, and wastewater treatment in place. Each of the 714
potential Detailed Questionnaire recipients was classified based on these four variables as listed
below. Facilities with multiple classifications were assigned a primary classification based on
their predominant tank type cleaned, predominant operational structure, and highest level of
wastewater treatment with some exceptions noted below.
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                                                                 Section 3.0 - Data Collection Activities
              Tank Type
              Truck
              Rail
              Barge
              Intermodal Tank Container
              Intermediate Bulk Container
              Tanker
              Land-Water (clean barges or tankers and any other tank types)
              Water (clean barges and tankers and no other tank types)
              Land (clean any combination of trucks, intermodal tank containers, intermediate
              bulk containers, or rail cars with no predominant tank type cleaned)

              Operational Structure

              Builder/Leaser
              Carrier
              Independent
              Shipper
              Not Elsewhere Classified (i.e., no predominant operational structure or
              operational structure not provided)

              Number of Employees

              Small (varies by operational structure)
              Large (varies by operational structure)

              Level of Wastewater Treatment in Place

              None or Pretreatment
              Primary
              Secondary
              Advanced
              Recycle/Reuse
Additional details concerning the methodology used to classify facilities within these four
variables are included in references 4 and 5.
              The following criteria were used to select the 275 Detailed Questionnaire
recipients:
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                                                                 Section 3.0 - Data Collection Activities
                    Select a random sample of facilities, stratified by tank type, from the TECI
                    Screener Questionnaire census stratum;
                    Select all facilities in the TECI Screener Questionnaire noncensus strata
                    considered to be primarily composed of operational structures other than
                    "shippers";
                    Select a random sample of facilities in the TECI Screener Questionnaire
                    noncensus strata considered to be primarily shippers;
                    Select all facilities with the tank type "land-water", "tanker", and "water";
                    Select a random sample of at least 20 barge facilities; and
                    Select all facilities in strata with two or fewer facilities comprising small
                    businesses (i.e., with small number of employees for the operational
                    structure).
              The sampling strategy was designed to meet two objectives most effectively:
(1) to ensure that at least one facility was sampled from most cells (i.e., combinations of the four
variables previously listed), and (2) to ensure that the variance around the national estimates
would not be grossly inflated in attempting to meet the first objective.  The design sampled
relatively fewer facilities in strata primarily composed of shippers than in strata primarily
composed of nonshippers, because, in many cases, the TEC wastewater generated by shippers
would be covered by other effluent guidelines. The last criterion described above was included
to evaluate cost impacts on small businesses.

              To achieve the sample draw criteria listed above, the Detailed Questionnaire
stratification consisted of 23 strata created from the 13 Screener Questionnaire strata described in
Section 3.2.2.4. Table 3-6 lists the 23 Detailed Questionnaire strata and the distribution of
facilities in the TECI Detailed Questionnaire mailing list by these strata.
               As part of the standard process of developing the Detailed Questionnaire, nine
 facilities were selected and sent pretest questionnaires. EPA decided that data from the pretest
 Detailed Questionnaire responses would not be used in national estimates because they
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                                                                  Section 3.0 - Data Collection Activities
represented data from the year 1993 rather than 1994, the .baseline year for the Detailed
Questionnaire data. The Detailed Questionnaire sample design treated the facilities that received
a pretest questionnaire as eligible for sample selection with the understanding that, if selected, a
replacement facility would be chosen. Four questionnaire pretest facilities were selected during.
the sample draw and were replaced. One of the four facilities was a member of a stratum from
which all facilities were to receive a Detailed Questionnaire (i.e., a census stratum). For this
stratum, the responses of the facilities remaining in the stratum were used to represent responses
from the pretest facility (i.e., the survey weight for the census stratum was revised from 1 to a
weight of more than  1).
3.2.3.2
Development of the Detailed Questionnaire
              The Agency developed the Detailed Questionnaire to collect information
necessary to develop effluent limitations guidelines and standards for the TECI. The
questionnaire was developed in conjunction with EPA's Office of Pollution Prevention and
EPA's Office of Solid Waste. A draft version of the questionnaire was sent to nine pretest
facilities to complete and to several industry trade associations and companies for review and
comment. Comments from these facilities, trade associations, and companies were incorporated
into the final version of the Detailed Questionnaire.

              The Detailed Questionnaire included two parts:
              1.      Part A:  Technical Information
                     —     Section 1:     General Facility Information
                     —     Section 2:     TEC Operations
                     —     Section 3:     Wastewater Generation, Treatment, and Discharge
                     —     Section 4:     Wastewater Characterization Data
                     —     Section 5:     Pollution Prevention and Water Conservation
                     —     Section 6:     Questionnaire Certification for Part A - Technical
                                          Information
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                                                                 Section 3.0 - Data Collection Activities
              2.     Part B: Financial and Economic Information
                           Section 1:    Facility Identification
                           Section 2:    Facility and TEC Financial Information
                           Section 3:    Business Entity Financial Information
                           Section 4:    Corporate Parent Financial Information
              Part A, Section 1 requested information necessary to identify the facility and to
determine wastewater discharge locations. The information collected by this section included
facility name, mailing and physical facility address, technical contract person and address, facility
layout diagram, age of facility, major modifications made to the facility, environmental permits
held by the facility, wastewater discharge location(s), and whether the facility is regulated by any
existing or upcoming national categorical limitations or standards.

              Part A, Section 2 requested information necessary to develop an industry profile,
characterize TEC processes, determine industry production (i.e., number and type(s) of tanks
cleaned), and perform an industry subcategorization analysis. The information collected included
a TEC process flow diagram, description of TEC processes, TEC operating days per year and
hours per day, types and numbers of tanks cleaned, cleaning processes performed, cleaning
solutions used and disposition of spent cleaning solutions,  general cargo types and specific
cargos cleaned, heel generation and disposition, other operations performed (e.g., tank
hydrotesting, exterior washing), and air emissions from TEC operations.

              Part A, Section 3 requested information regarding wastewater generation,
recycle/reuse, and discharge and to determine wastewater treatment in place.  This information
was used to develop regulatory compliance cost estimates. The information collected in this
section included a wastewater generation, treatment, and discharge diagram; wastewater streams
generated and volume; wastewater streams discharged, volume, and destination; wastewater
recycle/reuse streams and destination; wastewater treatment  unit operations; wastewater
treatment residuals generated, volume, disposition, and costs; wastewater treatment system
capital and annual costs; and space availability at the facility.
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                                                                 Section 3.0 - Data Collection Activities
              Part A, Section 4 requested information concerning the availability of wastewater
stream characterization data and/or treatability data. This information was used to determine
whether supplemental analytical data requests would be required.

              Part A, Section 5 requested information concerning pollution prevention and
water conservation activities. This information was used to identify applicable pollution
prevention and water conservation technologies for consideration in developing regulatory
technology options. The information collected included submittal of any facility pollution
prevention policies or plans, wastewater pollution prevention activities performed and their
impacts, water conservation practices used and their impacts, solid waste pollution prevention
activities performed and their impacts, and air pollution prevention activities performed and their
impacts.

              Part A, Section 6 included a certification form indicating that information
submitted to EPA was true, accurate, and complete; a check box indicating whether any portion
of questionnaire responses were considered confidential business information; and a check box
indicating whether contract personnel perform TEC operations or whether TEC operations are
performed by a mobile facility.

              Part B, Section 1 requested information necessary to identify the facility and
identify the facility's corporate hierarchy. The information collected by this section included
facility name,.mailing and physical facility address, county, street names of closest intersection,
contact person and address, types of TEC operations performed, corporate hierarchy, corporation
type, and facility type.

              Part B, Section 2 requested information necessary to develop an industry
economic profile and to assess facility-level economic impacts associated with TECI effluent
guidelines.  The information collected by this section included primary and secondary SIC codes,
first month of facility fiscal year, whether the facility  performs non-TEC operations and types,
purpose of TEC and non-TEC operations, cost increase that would lead to using commercial tank

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                                                                 Section 3.0 - Data Collection Activities
cleaning sources, percentage of commercial tank interior cleanings performed, and how TEC
costs are recovered. The section also requested why clients use TEC services, whether the
facility rejects cargos, who accepts rejected cargos, factors that affect TEC operations used,
number and types of tanks cleaned, impact of 1993 flooding on TEC revenues and costs, distance
to nearest commercial TEC facility, sensitivity of clients to price increases, discount rate of
borrowed money, balance sheet information including assets and liabilities, TEC revenue and
cost information, income statement information, assessed value, number of employees, and
financial statements.

              Part B, Section 3 requested information necessary to assess business entity-level
economic impacts associated with TECI effluent guidelines. The information collected by this
section included name and mailing address, primary and secondary SIC codes, business entity
type, list of TEC facilities operated by the business entity and TEC operations performed,  year
the business entity gained control of facility, and first month of fiscal year. The section also
requested top revenue-generating activities, discount rate of borrowed money, balance sheet
information including assets and liabilities, TEC revenue and cost information, financial
statement information, number of employees, and financial statements.

              Part B, Section 4 requested information necessary to assess corporate parent-level
economic impacts associated with potential TECI effluent guidelines. The information collected
by this section included name and mailing address, primary and secondary SIC codes, year the
corporate parent gained control of the business entity, corporate parent type, and financial
statements.

              A blank copy of the Detailed Questionnaire and copies of the Detailed
Questionnaire responses (nonconfidential portions) are contained in the administrative record for
this rulemaking. Further details on the types of information collected and the potential use of the
information are contained in the Information Collection Request for this project (6).  Detailed
information on Part B is presented in the economic analysis report (7).
                                           3-18

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Section 3.0 - Data Collection Activities
3.2.3.3
Administration of the Detailed Questionnaire
In April 1995, the Agency mailed 275 Detailed Questionnaires to in-scope TEC
facilities identified from Screener Questionnaire responses. This Detailed Questionnaire mail-
out comprised the statistical sample. EPA evaluated the specific facilities selected to receive the
Detailed Questionnaire and determined that the Detailed Questionnaire sample population would
not include a sufficient number of facilities that operate potential BAT end-of-pipe treatment
technologies. To obtain additional detailed wastewater treatment information for use in
developing regulatory options and estimating compliance cost, EPA mailed an additional 12
Detailed Questionnaires to facilities that operate potential BAT end-of-pipe treatment
technologies. Since these 12 facilities were not included in the statistical sample population,
responses from these facilities were not used in calculating national estimates for the TECI.
Table 3-7 summarizes the Detailed Questionnaire mail-out, follow-up, and receipt activities.

EPA established toll-free helplines, one for Part A and one for Part B, to assist
Detailed Questionnaire recipients in completing the questionnaire. The Part A helpline received
a total of 477 calls from 192 facilities. The Part B helpline received a total of 161 calls.

The Agency completed a detailed engineering review of Part A of the Detailed
Questionnaire responses to evaluate the completeness, accuracy, and consistency of information
provided by the respondents, and to perform additional response coding to facilitate data entry
and analysis of questionnaire responses. The TEC Questionnaire Part A Coding/Review
Checklist (8) outlines the processes used by engineering reviewers to evaluate and code the
questionnaire responses. The Data Element Dictionary for Part A of the U.S. Environmental
Protection Agency 1994 Detailed Questionnaire for the Transportation Equipment Cleaning
Industry Database (9) contains information codes reported either by the respondents or added by
the engineering reviewers during questionnaire response evaluation. The Agency contacted
respondents by telephone or letter who provided inaccurate, incomplete, or contradictory
technical information.
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Section 3.0 - Data Collection Activities
The Agency entered the questionnaire responses into the Detailed Questionnaire
database, the structure of which is documented in the Detailed Questionnaire Data Element
Dictionary referenced above. The database was developed in FoxPro™; however, the database
was converted to SAS® for other users to access. After engineering review and coding,
questionnaire responses were double key entered using a data entry and verification system, also
developed in FoxPro™. Additional documentation concerning the data entry and verification
system is contained in the administrative record for this rulemaking. Inconsistencies in double
key entry were verified by the questionnaire reviewers.

After population of the questionnaire database, the Agency performed range and
logic checks to ensure that the database was complete and accurate. During questionnaire
analysis, additional questionnaire database "cleanup" was performed to identify and resolve any
additional data that were questionable based on engineering judgement. Responses not
standardized during coding were standardized, where appropriate, to facilitate questionnaire
analysis.
3.2.3.4
Calculation of National Estimates
Each surveyed facility in a stratum represents a specific number of facilities in the
national population. Therefore, EPA determined a weight associated with each stratum. For
example, if a surveyed facility falls within stratum "A" and the weight of that stratum is 5, the
responses received from that facility represent a total of five facilities in the overall TECI
population. EPA calculated the survey weighting factors for each of the Detailed Questionnaire
strata using equation (2) in Section 3.2.2.4. Details concerning calculation of the Detailed
Questionnaire survey weights are included in reference 13. Table 3-8 shows the Detailed
Questionnaire strata and their associated strata weights. Calculation of survey weighting factors,
which account for nonrespondents, is described in reference 10.

During review of the Detailed Questionnaire responses, the Agency classified
each facility within one of the following three categories:
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                                                                  Section 3.0 - Data Collection Activities

              1.      Direct and Indirect Discharge Facilities: TEC facilities that discharge
                     wastewater to surface waters of the United States (direct discharge) or to a
                     publicly-owned treatment works (POTW) (indirect discharge).

              2.      Zero Discharge Facilities: TEC facilities that do not discharge
                     wastewater to surface waters or to a POTW, and may instead haul
                     wastewater off site to a centralized waste treater, practice total waste water
                     recycle/reuse, or land apply wastewater.

              3.      Previously Regulated (also called captive facilities): TEC facilities that
                     are covered by existing or upcoming effluent guidelines.  TEC operations
                     are a very small part of their overall operations.  These facilities include
                     facilities regulated under the Organic Chemicals, Plastics, and Synthetic
                     Fibers Effluent Guideline, the Dairies Effluent Guideline, the Centralized
                     Waste Treaters Effluent Guideline, and the Internal Waste Incinerators
                     Effluent Guideline.  These facilities will not be covered by the TECI
                     effluent guideline as long as they commingle and treat the TEC wastewater
                     with their major source wastewater.
National estimates of the total population of these three TEC facility types are listed in the
following table:
Facility Type
Direct and Indirect Discharge
Facilities
Zero Discharge Facilities
Previously Regulated Facilities
Number of Sample Population i
Responses Received ,-'
93
49
34
Estimated Number of Faculties
in Total Population
692
547
1,166
3.3
Summary of EPA's TECI Site Visit Program from 1993
Through 1996
              The Agency conducted 39 engineering site visits (13 of which were conducted
concurrently with sampling) at 38 facilities to collect information about TEC processes, water

use practices, pollution prevention practices, wastewater treatment technologies, and waste
disposal methods.  These facilities were also visited to evaluate potential sampling locations (as

described in Section 3.4).  In general, the Agency visited facilities that encompass the range of

                                           3-21

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Section 3.0 - Data Collection Activities
TEC facilities. The following table summarizes the number of site visits performed by primary
tank type cleaned.
Primary Tank Type Cleaned
Truck
Ran
Barge
Tanker
Closed-Top Hopper Barge
Number of >Facffiti«» Visited,
, ' - „ , , r, ' -•' :' '/\ , 'A
19
10
7 (one facility visited twice)
1
1
3.3.1
Criteria for Site Selection
The Agency based site selection on information submitted in response to the TECI
Screener and Detailed Questionnaires. The Agency also contacted trade association
representatives to identify representative TEC facilities for site visits. The Agency used the
following five criteria to select facilities that encompassed the range of TEC operations,
wastewater characteristics, and wastewater treatment practices within the TECI.

1. Tank Types Cleaned: Truck, Rail, Barge, Intermodal Tank Container,
Intermediate Bulk Container, Tanker, Closed-Top Hoppers;
2. Operational Structure: Independent, Carrier, Shipper, Combinations;
3. Treatment: Advanced, Secondary, Primary, None;
4. Cargo Types Cleaned: Chemicals, Food grade, Petroleum, Combinations;
and
5 Discharge Status: Direct, Indirect, 100% Wastewater Recycle/Reuse,
Contract Haul.

Facility-specific selection criteria are contained in site visit reports (SVRs) prepared for each
facility visited by EPA. Exceptions include site visits performed concurrently with sampling in
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                                                                Section 3.0 - Data Collection Activities
which case facility-specific selection criteria are contained in sampling episode reports (SERs)

prepared for each facility sampled by EPA.  The S VRs and SERs are contained in the

administrative record for this rulemaking.
3.3.2
Information Collected
              During the site visits, EPA collected the following types of information:


              •      General facility information including size and age of facility, number of
                    employees, operating hours per day and days per year, number of cleaning
                    bays or docks, facility clients, and non-TEC operations;

              •      Types of tanks and cargos cleaned, number of tanks cleaned by cargo type,
                    reasons for tank cleaning, most difficult cargos to clean, whether and why
                    tanks are rejected;

              •      Typical cleaning processes used by tank and cargo type;

              •      Types of cleaning equipment used and operating volume and pressure;

              •      Heel removal, management, volume, and disposition;

              •      Cleaning solutions used, temperature, whether cleaning solutions are
                    recirculated, and disposition of spent cleaning solutions;

              •      Types and disposition of wastewater generated;

              •      Volumes of wastewater generated per tank cleaned by tank and cargo type;

              •      Types of in-process source reduction and recycling performed;

              •      Wastewater treatment units and operation including volume, flow rate, and
                    treatment chemicals used, amounts, and purpose;

              •      Wastewater discharge location and monitoring requirements;

              •      Types, volume, and disposition of wastewater treatment residuals;
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Section 3.0 - Data Collection Activities
Identification of potential sampling points and sampling methodologies;
and
Logistical and health and safety information required for sampling.
This information is documented in the SVRs or SERs for each visited facility.
3.4
Summary of EPA's TECI Sampling Program from 1994
through 1996
The Agency conducted 20 sampling episodes at 18 facilities (two facilities were
sampled twice). Twelve of these sampling episodes were conducted to obtain untreated TEC
process wastewater and treated final effluent characterization data from facilities representative
of the variety of TEC facilities. Wastewater treatment sludge was also characterized at two of
these twelve facilities to determine whether the sludge was hazardous. Each of these
"characterization" sampling episodes encompassed one sampling day. Eight additional sampling
episodes were conducted to obtain both untreated TEC process wastewater characterization data
and to evaluate the effectiveness and variability of wastewater treatment units used to treat TEC
wastewater. Of these 8 sampling episodes, 1 was conducted for 1 day, 2 were conducted for 3
days each, 4 were conducted for 4 days each, and 1 was conducted for 5 days. The following
table summarizes the number of sampling episodes performed by primary tank type cleaned.
Primary Tank Type Cleaned
Truck
Rail
Barge
Closed-Top Hopper Barge
Number of Facilities Sampled
7
5
7 (two facilities sampled twice)
1
At several facilities, sampled TEC waste streams were commingled with other wastewater
sources including exterior cleaning wastewater, boiler wastewater, and contaminated stormwater.
Samples were typically analyzed for volatile organics, semi-volatile organics, organo-halide
3-24

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Section 3.0 - Data Collection Activities
pesticides, organo-phosphorus pesticides, phenoxy-acid herbicides, dioxins and furans, metals,
and classical wet chemistry parameters. The results of this data collection are discussed in
Sections 6.0, 7.0, and 8.0.
3.4.1
Criteria for Site Selection
The Agency based site selection on information submitted in response to the TECI
Screener and Detailed Questionnaires or information collected during TECI engineering site
visits. The Agency used the same five general criteria to select facilities for sampling as that
used to select facilities for site visits:
1. Tank Types Cleaned: Truck, Rail, Barge, Closed-Top Hoppers;
2. Operational Structure: Independent, Carrier, Shipper;
3. Cargo Types Cleaned: Chemicals, Food grade, Petroleum;
4. Treatment: Advanced, Secondary, Primary, None; and
5. Discharge Status: Direct, Indirect, 100% Wastewater Recycle/Reuse.
Facilities sampled during the "characterization" sampling episodes were selected primarily based
on tank type and cargo type cleaned, for the overall purpose of characterizing wastewater that
was typical of the TECI and representative of the variety of technical and economic
characteristics of the TECI. Facilities sampled during the wastewater treatment evaluation
sampling episodes were selected primarily based on use of potential BAT and PSES control
technologies and widest possible coverage of the TECI effluent guidelines subcategories.
Facility-specific selection criteria are contained in sampling episode reports (SERs) and/or
sampling and analysis plans (SAPs) prepared for each facility sampled by EPA. The SERs and
S APs are contained in the administrative record for this rulemaking.
3.4.2
Information Collected
In addition to wastewater and solid waste samples, the Agency collected the
following information during each sampling episode:
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                                                               Section 3.0 - Data Collection Activities
                    Dates and times of sample collection;
                    How data corresponding to each sample;
                    Production data (i.e., number of tanks cleaned per sampling day)
                    corresponding to each wastewater sample;
                    Design and operating parameters for source reduction, recycling, and
                    treatment technologies evaluated during sampling; and
                    Temperature, free chlorine, and pH of the sampled waste streams.
All data collected during sampling episodes are documented in the SER prepared for each
sampled facility. SERs are included in the administrative record for this rulemaking. The SERs
also contain technical analyses of treatment system performance (where applicable).
3.4.3
Sample Collection and Analysis
              During the sampling episode, teams of EPA personnel and EPA contractor
engineers, scientists, and technicians collected and preserved samples and shipped them to EPA
contract laboratories for analysis. Sample collection and preservation were performed according
to EPA protocols as specified in the TEC Quality Assurance Project Plan (QAPP) (11) and the
BAD Sampling Guide (12).

              In general, composite samples were collected from wastewater streams with
compositions that were expected to vary over the course of a production period (e.g., untreated
TEC process wastewater prior to equalization). Grab samples were collected from streams that
were not expected to vary over the course of a production period (e.g., wastewater streams
collected subsequent to extended equalization).  Composite samples of wastewater treatment
sludge were also collected. EPA collected the required types of quality control samples as
specified in the TEC QAPP, such as trip blanks, equipment blanks, and duplicate samples, to
verify the precision and accuracy of sample analyses. The list of analytes for each waste stream,
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                                                                Section 3.0 - Data Collection Activities
analytical methods used, and the analytical results, including quality control samples, are
included in the SERs prepared for each facility sampled.
3.5
Existing Data Sources
              In developing the TECI effluent guidelines, EPA evaluated the following existing
data sources:
                     EPA databases from development of effluent guidelines for other
                     industries;
                     The Office of Research and Development (ORD) Risk Reduction
                     Engineering Laboratory (RREL) treatability database;
                     The Fate of Priority Pollutants in Publicly Owned Treatment Works (50
                     POTW Study) database;
                     Lists of potential TEC facilities from state and local agencies;
                     EPA's Permit Compliance System and Industrial Facilities Discharge and
                     Databases; and
                     U.S. Navy bilge wastewater characterization data.
These data sources and their uses for the development of the TECI effluent guidelines are
discussed below.
 3.5.1
 Other EPA Effluent Guidelines Databases
              In developing effluent guidelines for Centralized Waste Treaters, EPA collected
 wastewater samples to characterize oily wastewaters. Oily wastewater characterization data were
 not collected during sampling episodes conducted at a TEC facility in the Truck/Petroleum
 Subcategory; however, pollutant loadings and pollutant reduction estimates for these
 subcategories included off-site disposal of oily wastewater. EPA reviewed the sampling episode
                                           3-27

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                                                               Section 3.0 - Data Collection Activities
reports for oily wastewater samples collected at Centralized Waste Treaters and determined that
some data from this program were appropriate for transfer to the TECI effluent guidelines
development effort. Reference 13 provides a detailed description of the source of the oily
wastewater characterization data and EPA's rationale for transfer of the data to the TECI effluent
guidelines development effort.
3.5.2
EPA's Risk Reduction Engineering Laboratory Treatability
Database
              EPA's Office of Research and Development (ORD) developed the Risk Reduction
Engineering Laboratory (RREL) treatability database to provide data on the removal and
destruction of chemicals in various types of media, including water, soil, debris, sludge, and
sediment. One component of the RREL database is treatability data from POTWs for various
pollutants.  This database includes physical and chemical data for each pollutant, the types of
treatment used to treat the specific pollutants (predominantly activated sludge and aerobic
lagoons for POTWs), the type of media treated (domestic wastewater for POTWs), the scale of
the treatment system (i.e., full-, pilot-, or bench-scale), treatment concentrations achieved,
treatment efficiency, and source of treatment data.  EPA used this database to assess removal by
POTWs of TECI pollutants effectively removed and to select pollutants to be regulated (see
Section 7.0).
3.5.3
EPA's Fate of Priority Pollutants in Publicly Owned
Treatment Works Database
              In September 1982, EPA published the Fate of Priority Pollutants in Publicly
Owned Treatment Works (14), referred to as the 50 POTW Study. The purpose of this study was
to generate, compile, and report data on the occurrence and fate of the 129 priority pollutants in
50 POTWs. The report presents all the data collected, the results of preliminary evaluations of
these data, and the results of calculations to determine the following:
                                          3-28

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                                                                Section 3.0 - Data Collection Activities
              •      The quantity of priority pollutants in the influent to POTWs;
              •      The quantity of priority pollutants discharged from POTWs;
              •      The quantity of priority pollutants in the effluent from intermediate
                    process streams; and
              •      The quantity of priority pollutants in the POTW sludge streams.

EPA used the data from this study to assess removal by POTWs of TECI pollutants of concern.
3.5.4
State and Local Agencies
              A number of state and local agencies provided the Agency with lists of facilities
within their jurisdiction that directly discharge wastewaters and were identified as either
performing TEC operations or reporting under an SIC code for facilities that own and/or operate
transportation equipment. The following agencies supplied lists of potential TEC facilities:
Alabama Department of Environmental Management, Baton Rouge Department of Public
Works, City of Houston Industrial Wastewater Service, Kentucky Department of Environmental
Protection, Metropolitan Water Reclamation District of Chicago, and State of Mississippi
Permitted Facilities.
3.5.5
EPA's Permit Compliance System and Industrial Facilities
Discharge Databases
              The Agency searched the Permit Compliance System (PCS) and the Industrial
Facilities Discharge (IFD) databases to identify facilities that potentially perform TEC operations
(see Section 3.2.1).  These databases identify facilities that discharge wastewater by four-digit
SIC code. Facilities in SIC codes potentially applicable to the TECI were entered into the TECI
site identification database.
                                          3-29

-------
                                                              Section 3.0 - Data Collection Activities
3.5.6
U.S. Navy BUge Wastewater Characterization Data
             Several facilities in the Barge/Chemical Subcategory for which compliance costs
were estimated commingle non-TEC wastewater with TEC wastewater prior to treatment. The
non-TEC wastewater of concern consists primarily of marine wastewaters such as bilge
wastewater and ship-building wastewater.  The U.S. Navy published a report titled "The
Characterization of Bilge Water Aboard Navy Ships." EPA reviewed the report for bilge
wastewater characterization data and determined that these data were appropriate for use in
characterizing marine wastewater streams treated by facilities in the Barge/Chemical
Subcategory. A detailed description of the source of the bilge wastewater data and EPA's
rationale for transfer of the data to the TECI effluent guidelines development effort is provided in
reference 15.
3.6
Summary of Publiclv-Owned Treatment Works Data
              In October 1993 the Association of Metropolitan Sewerage Authorities (AMSA)
provided EPA with data from POTW members on industrial users that conducted TEC
operations in 1992. The POTWs provided the following information: (1) POTW contact,
location, and limits; (2) industrial user information including TEC facility contact, location,
average wastewater discharged in gallons per day, and the types of TEC operations performed;
(3) industrial user sampling point information; (4) industrial user treatment technologies
employed; (5) industrial user pollution prevention practices; and (6) industrial user sampling data
collected by the POTW or the industrial user.

              EPA considered using the AMSA data as a source in developing the TECI site
 identification database (see Section 3.2.1); however, because the AMSA data were not received
 until after the TECI site identification database was finalized, EPA decided not to use these data
 in developing the database. In addition, the sampling data were not used because very little
 sampling data were provided and because influent and effluent data were not paired, precluding
                                          3-30

-------
Section 3.0 - Data Collection Activities

use to determine treatment performance efficiencies. For these reasons, EPA decided not to use

the AMS A data in the development of the proposed rule.
3.7
References1
1.

9.
U.S. Environmental Protection Agency, Office of Water Regulations and
Standards. Preliminary Data Summary for the Transportation Equipment
Cleaning Industry. EPA 440/1-89/104, September 1989 (DCN T10201).

Cochran, W.S. Sampling Techniques. John Wiley & Sons, 1977. p. 108.

Eastern Research Group, Inc., Development of Survey Weights for the U.S.
Environmental Protection Agency Tank and Container Interior Cleaning Screener
Questionnaire. May 15,1998 (DCN Tl 1000).

Radian Corporation. Transportation Equipment Cleaning Industry (TECT) Tank
and Aircraft Screener Database Postings. Memorandum from Debbie Falatko,
Radian Corp., to Gina Matthews, U.S. EPA, June 30,1995 (DCN T10269).

Science Applications International Corporation (SAIC). Final Transportation
Equipment Cleaning Industry Detailed Questionnaire Sample Design Report.
May, 1998 (DCN Til 100).

U.S. Environmental Protection Agency. Information Collection Request 1994
Detailed Questionnaire for the Transportation Equipment Cleaning Industry.
November 1994 (DCN T09843).

U.S. Environmental Protection Agency. Economic Analysis of Proposed Effluent
Limitations Guidelines and Standards for the Transportation Equipment Cleaning
Category. EPA-821-B-98-012, May 1998.

Radian Corporation. TEC Questionnaire Part A Coding/Review Checklist.
September 12,1995 (DCN T10249).

Eastern Research Group, Inc. Data Element Dictionary for Part A of the U.S.
Environmental Protection Agency 1994 Detailed Questionnaire for the
Transportation Equipment Cleaning Industry. April 4, 1997 (DCN T10271).
1 For those references included in the administrative record supporting the proposed TECI rulemaking, the
document control number (DCN) is included in parentheses at the end of the reference.

3-31

-------
10.


11.


12.

13.
14.
15.
                                                Section 3.0 - Data Collection Activities

SAIC.  Statistical Methods for Calculating National Estimates.  May 1998 (DCN
Til 101).

Radian Corporation. Draft Quality Assurance Project Plan for the Transportation
Equipment Cleaning Industry. January 19, 1995 (DCN T10233).

Viar and Company. BAD Sampling Guide. June 1991 (DCN T10218).

Eastern Research Group, Inc. Development of Transportation Equipment
Cleaning Industry Production Normalized Pollutant Loadings. Memorandum
from Grace Kitzmiller, Eastern Research Group, Inc. to the TECI Rulemaking
Record. May 6,1998 (DCNT09981).

U.S. Environmental Protection Agency. Fate of Priority Pollutant in Publicly-
Owned Treatment Works.  EPA 440/1-82/303, September 1982 (DCN T10311).

Eastern Research Group, Inc.  Development of Transportation Equipment
Cleaning Industry Production Normalized Pollutant Loadings. Memorandum
from Grace Kitzmiller, Eastern Research Group, Inc. to the TECI Rulemaking
Record. May 6, 1998 (DCN T09981).
                                         3-32

-------
I
.3

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-------
                                            Section 3.0 - Data Collection Activities
                     Table 3-2
Sources Used to Identify Potential TEC Facilities
Source
Level of
Assurance
Potential Tank Barge C3eaning Facilities
Telephone Contacts (All sources)
1993 Inland River Guide (Tank barge cleaning operations specifically
identified)
1993 American Waterways Shipyard Conference (AWSC) Shipyard
Services Directory (Tank barge cleaning operations specifically identified)
Metronolitan Water Reclamation District of Chicago List
1993 Inland River Guide (Perform tank barge operations)
1993 AWSC Shipyard Services Directory (Perform tank barge operations)
Kentucky Department for Environmental Protection List
Dun and Bradstreet (Second order of SIC codes) (Assessed based on SIC
Dun and Bradstreet (First order of SIC codes) (Assessed based on SIC
codes descriptions)
1993 Industrial and Hazardous Waste Transporters
TRINC Users File
Dun and Bradstreet (First order of SIC codes) (Assessed based on SIC
code descriptions)
Dun and Bradstreet (Second order of SIC codes) (Assessed based on SIC
code descriptions)
EPA's Permit Compliance System
high
high
high
high
medium
medium
medium
medium
medium
medium
medium
low
low
low
Source 
-------
                                Section 3.0 - Data Collection Activities
Table 3-2 (Continued)
Source - * ' , - - --'',,"
Mississippi Permitted Facilities
Dun and Bradstreet (First order of SIC codes) (Assessed based on SIC
code descriptions)
Dun and Bradstreet (Second order of SIC codes) (Assessed based on SIC
code descriptions)
Dun and Bradstreet (First order of SIC codes) (Assessed based on SIC
code descriptions)
Dun and Bradstreet (Second order of SIC codes) (Assessed based on SIC
code descriptions)
EPA's Permit Compliance System
Potential Transfer Facilities •'<>,>
1993 Inland River Guide
Modern Bulk Transporter, December 1992, Bulk Transfer Directory
Dun and Bradstreet (First order of SIC codes) (Assessed based on SIC
code descriptions)
Dun and Bradstreet (Second order of SIC codes) (Assessed based on SIC
code descriptions)
Dun and Bradstreet (First order of SIC codes) (Assessed based on SIC
code descriptions)
Dun and Bradstreet (Second order of SIC codes) (Assessed based on SIC
code descriptions)
EPA's Permit Compliance System
Potential Tank Truck Cleaning Facilities
Telephone Contacts (All sources)
Modern Bulk Transporter, March 1993, Tank Cleaners Directory
Modern Bulk Transporter, February 1993, Tank Trailer Repair Directory
Modern Bulk Transporter, December 1992, Tank Container Depot
Directory
Modern Bulk Transporter, March 1992, Tank Cleaners Directory
Modern Bulk Transporter, January 1992, Advertisement
Modern Bulk Transporter, September 1992, Advertisement
City of Houston Industrial Wastewater Service List
Metropolitan Water Reclamation District of Chicago List
1993 Industrial and Hazardous Waste Transporters
; LeveLof ' ,
", Assurance' <'"
medium
medium
medium
low
low
low
/ ,
high
high
medium
medium
low
low
low
1 ^ s %
high
high
high
high
high
high
high
high
high
medium
^ s •- \
/ SourcesGoJie ?,
16
11
12
11
12
18
s >. f *""^
14
6
11
12
11
12
18
t "•>
' •" i **
All
4
5
6
7
8
9
26
25
13
          3-35
-------
                                Section 3.0 - Data Collection Activities
Table 3-2 (Continued)
Source
1993 National Motor Carriers Directory
XKENC Owners File
TRINC Users File (Facilities operate tank trucks)
Alabama Department of Environmental Management List
Mississippi Permitted Facilities
Kentucky Department for Environmental Protection List
Dun and Bradstreet (Second order of SIC codes) (Assessed by SIC code
descriptions)
Dun and Bradstreet (First order of SIC codes) (Assessed by SIC code
descriptions)
1993 Private Fleet Dkectory
TRINC Users File (Assessed by SIC code descriptions)
Dun and Bradstreet (Second order of SIC codes) (Assessed by SIC code
descriptions)
Dun and Bradstreet (First order of SIC codes) (Assessed by SIC code
descriptions)
EPA's Permit Compliance System
Level of
Assurance
medium
medium
medium
medium
medium
medium
medium
low
low
low
low
low
Sburce^Code -
17
22
23
3
15
12
11
2
23
12
11
18
           3-36
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-------
                                                       Section 3.0 - Data Collection Activities
                                 Table 3-6
 Detailed Questionnaire Sample Frame and Distribution of Facilities in the
            TECI Detailed Questionnaire Mailing List by Strata
Detailed
Questionnaire
Strata
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
Detailed Questionnaire Strata eode (Source) (a)
Census - Barge; Census
Census - Barge; Random
Census - Land-Water; Census
Census - Rail; Census
Census - Rail; Random
Census - Truck-Land; Census
Census - Truck-Land; Random
Census - Tanker-Water; Census
Barge-Low (1,12); Nonshipper
Truck-Low (2); Nonshipper
Truck-Low (2); Shipper
Transfer-Low (11,12,18); Nonshipper
Truck-Low (12); Nonshipper
Truck-Medium (12); Nonshipper
Truck-Medium (13); Nonshipper; Random
Truck-Medium (13); Nonshipper; Census
Truck-Medium (17); Nonshipper
Rail-High (19); Nonshipper
Rail-High (19); Shipper
Rail-High (19); Shipper; Land-Water
Truck-Medium (22); Nonshipper
Truck-Low (23); Shipper
Truck-Medium (23); Shipper
TOTAL
Number of Facilities Selected
for Detailed Questionnaire
Mailing List
4
16
9
9
11
3
75
6
1
8
12
1
11
12
15
7
22
18
8
3
7
10
7
275
(a) Source code listed in Table 3-2.
                                     3-40
-------
                                                     Section 3.0 - Data Collection Activities
                                Table 3-7
Summary of TECI Detailed Questionnaire Mail-Out and Follow-Up Activities
Activity ,
Detailed Questionnaires Mailed
Reminder Phone Calls
Delinquent Response Phone Calls or Letters
Questionnaire Responses Received
— Part A
— PartB
Responses Received, Insufficient for Analyses
— Part A
— PartB
Out-of-Scope Responses
Helpline Calls
— Part A
— PartB
Follow-up Calls During Questionnaire Review
— Part A
— PartB
Number of Facilities ' „,
287
156
75
200
195
1
5
40 (3 Dry Facilities)
192 (477 Total Calls)
(161 Total Calls)
171
142
                                   3-41
-------
                                              Section 3.0 - Data Collection Activities
                        Table 3-8
Detailed Questionnaire Sample Frame Strata and Weights
Detailed Questionnaire
Strata
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
Detailed Questionnaire Strata Code (Source) (a) f
Census - Barge; Census
Census - Barge; Random
Census - Land-Water; Census
Census - Rail; Census
Census - Rail; Random
Census - Truck-Land; Census
Census - Truck-Land; Random
Census - Tanker-Water; Census
Barge-Low (1,12); Nonshipper
Truck-Low (2); Nonshipper
Truck-Low (2); Shipper
Transfer-Low (1 1,12,18); Nonshipper
Truck-Low (12); Nonshipper
Truck-Medium (12); Nonshipper
Truck-Medium (13); Nonshipper; Random
Truck-Medium (13); Nonshipper; Census
Truck-Medium (17); Nonshipper
Rail-High (19); Nonshipper
Rail-High (19); Shipper
Rail-High (19); Shipper; Land-Water
Truck-Medium (22); Nonshipper
Truck-Low (23); Shipper
Truck-Medium (23); Shipper
' Surrey "Weighting,
Factor " - '-;
•> j •> y/
1.31
2.10
1.05
1.05
4.86
1.05
5.37
1.05
7.40
10.62
25.66
9.50
8.76
8.53
6.31
1.00
8.03
2.09
10.20
2.09
3.07
84.37
41.95
                            3-42
-------
                                                                     Section 4.0 - Industry Description
4.0
INDUSTRY DESCRIPTION
              The Transportation Equipment Cleaning Industry (TECI) includes facilities that
use water to clean the interiors of tank tracks, closed-top hopper trucks, intermodal tank
containers, rail tank cars, closed-top hopper rail cars, inland tank barges, closed-top hopper
barges, ocean/sea tankers, and other similar tanks (excluding intermediate bulk containers (IBCs)
and drums). This section describes and provides a profile of the TECI.  Information presented in
this section is based on data provided by facilities in response to the Detailed Questionnaire (1)
and obtained by EPA's site visit and sampling programs. The Detailed Questionnaire database
(2) includes information necessary to develop an industry profile, characterize transportation
equipment cleaning (TEC) processes, and perform an industry subcategorization analysis. Note
that the data contained in the Detailed Questionnaire database reflect TECI operations in calendar
year 1994.

              Information presented in this section is based on operations performed by the
estimated total TECI population of 1,229J facilities. This total includes an estimated 692
discharging facilities and 537! zero discharge facilities.
4.1
Operational Structure
              The TECI is characterized by four business operational segments:  independents,
carriers, shippers, and builder/leasers. Independent facilities provide commercial cleaning
services, either as a primary or secondary business, for tanks that they do not own or operate.
Carrier-operated facilities, or "for-hire facilities", own, operate, and clean tank fleets used to
transport cargos for other  companies. Shipper-operated facilities transport their own cargos or
engage carriers to transport their cargos, and clean the fleets used for such transport. Builder/
leaser facilities manufacture and/or lease tanks, and clean the interiors of these tanks after
1  Does not include an additional estimated 10 facilities represented by a single nonrespondent.
                                            4-1
-------
                                                                    Section 4.0 - Industry Description
equipment has been placed in service. Since transportation facilities may perform a variety of
business operations, TEC facilities may be classified under more than one operational segments.

              The TECI is additionally classified based on the relationship between the cleaning
facility and the customer:  commercial and in-house. The first category, commercial facilities,
includes independent tank wash facilities and builder/leaser-operated facilities, at which
customers pay a fee for tank cleaning. The second category comprises shipper-operated or
carrier-operated facilities that provide tank cleaning facilities to support in-house operations.
These facilities are considered private because tank cleaning services may not be offered to
nonaffiliated transportation equipment.

              Approximately two-thirds of the TECI are shipper-operated or carrier-operated
facilities that provide tank cleaning services to support in-house operations. Tank trucks and rail
tank cars that last transported food grade products are most likely to be cleaned by in-house
facilities because these tanks usually transport the same cargos for the same food processing
facility and because quality control measures are more stringent for cleaning food-grade tanks.  In
contrast, tank and hopper barges are typically cleaned by independent tank wash facilities located
on their travel routes, because these carriers usually transport cargos in both directions to
maximize their large capacities and minimize the effects of the slower travel.
4.2
Cleaning Purpose
              Tank and container interiors are cleaned for two primary purposes: (1) to prevent
contamination of materials from one cargo shipment to the next and (2) to facilitate inspection
and repair. Facility responses to the Detailed Questionnaire indicate that tanks are used to
transport more than 700 unique cargos.  Tanks that are not in dedicated service (i.e., tanks that
carry a variety of products) are generally cleaned before each product changeover to prevent
contamination of the new cargo. Some tanks in dedicated service also require cleaning to
prevent contamination of subsequent cargos if product purity is a concern, such as for certain
                                            4-2
-------
                                                                     Section 4.0 - Industry Description
process chemicals and food products, including milk, vegetable oils, molasses, and com syrup.
Sections 4.4 and 4.5 discuss in detail the tank types and cargo types cleaned, respectively.

              Tank interiors are also cleaned to facilitate internal inspection of the tank and/or
inspection of fittings and valves that may be required as part of a routine inspection and
maintenance program. In addition, the interior of the tank must be rendered nonexplosive and
nonflammable through a cleaning process called "gas-freeing" to provide a safe environment for
manual cleaning and for tank repairs that require "hot work" (e.g., welding or cutting).
4.3
TEC Operations
              Although different types of tanks are cleaned in various manners, the basic
cleaning process for each tank is similar.  A typical sequence is as follows:

              •      Review shipping manifest forms to determine the cargo last transported in
                     the tank;
              •      Determine the next cargo to be transported in the tank;
              •      Drain the tank heel (residual product) and, if necessary, segregate the heel
                     for off-site disposal;
              •      Rinse the tank with water;
              •      Wash the tank using one or more cleaning methods and solutions;
              •      Rinse the tank with water; and
              •      Dry the tank.

Figure 4-1 illustrates the general TEC processes performed. The following paragraphs further
describe these processes.
                                            4-3
-------
                                                                     Section 4.0 - Industry Description
              The cleaning facility determines the cargo last transported in the tank to:
(1) assess the facility's ability to clean the tank efficiently; (2) determine the appropriate cleaning
sequence and cleaning solutions; (3) evaluate whether the residue cleaned from the tank will be
compatible with the facility's wastewater treatment system; and (4) establish an appropriate level
of health and safety protection for the employees who will clean the tank. The next cargo to be
transported in the tank is identified to determine if the available level of cleaning at the facility is
adequate to prevent contamination of the next cargo. The facility may decide to reject a tank
based on any of the preceding concerns.

              Once a tank has been accepted for cleaning, the facility checks the volume of heel
(residual cargo) in the tank and determines an appropriate heel disposal method. Any water-
soluble heels that are compatible with the facility's treatment system and the conditions of the
facility's wastewater discharge permit are usually combined with other wastewaters for treatment
and discharge at the facility.  Incompatible heels are segregated into drums or tanks for disposal
or reuse by alternative means, which may include reuse on site, return to the consignee, sale to a
reclamation facility, landfilling, or incineration. The TEC facility may reuse heels comprising
soaps, detergents, solvents, acids, or alkalis as tank cleaning solutions or as neutralizes for future
heels and for wastewater treatment.  Section 4.6 discusses heel removal and disposal in detail.

               Cleaning processes vary among facilities depending on available cleaning
equipment and the cargos last transported in the tanks to be cleaned. Certain residual materials
 (such as sugar) only require a water rinse, while other residual materials (such as latexes or
 resins) require a detergent or strong caustic solution followed by a final water rinse.  Other
 cleaning processes include presolve (application of solvent or diesel to the tank interior for
 cargos that are difficult to remove), steam cleaning, and forced air drying. The  state of the
 product last transported in the tank affects the cleaning processes used.  For example, hardened
 or caked-on products sometimes require an extended processing time. Some tanks require
 manual cleaning with scouring pads, shovels, or razor blades to remove residual materials. The
 cleaning of tanks used to transport gases  or volatile material sometimes requires filling the tank
                                             4-4
-------
                                                                    Section 4.0 - Industry Description
to capacity with water to displace vapors, followed by flushing of the wastewater.  Section 4.7
discusses chemical cleaning solutions in detail.

              Tanks are typically washed using one of two methods: (1) low- or high-pressure
spinner nozzles or (2) hand-held wands and nozzles. Spinner nozzles, which are inserted through
the main tank hatch, operate at pressures between 100 pounds per square inch (psi) and 600 psi to
deliver hot or cold water rinses and a variety of cleaning solutions.  They are designed to rotate
around both their vertical and horizontal axes to create an overlapping spray pattern that cleans
the entire interior of the tank.  Operating cycles range from rinse bursts of a few seconds to
recirculating detergent or caustic washes of 20 minutes or longer for caked or crystallized
residues. Washing with hand-held wands and nozzles achieves the same result as with high-
pressure spinner nozzles, but requires facility personnel to manually direct the wash solution
across the interior surface of the tank.

              After cleaning, tanks may be dried by applying ambient or heated air using a
blower. Cleaning personnel may enter and inspect tank interiors and perform manual cleaning as
required. Valves, fittings, and other tank components may be removed and cleaned by hand.
Hoses are generally cleaned in a separate hose bath using the same cleaning solutions as those
used to clean tank interiors.
4.3.1
Tank and Hopper Truck, EBC, and Intermodal Tank
Container Cleaning
              Tank trucks, IBCs, and intermodal tank containers are generally considered empty
when they arrive at the facility, but may contain between one quart and twenty gallons of heel
(typically less than 1% of tank capacity). Closed-top hopper trucks generally contain less than
five pounds of residual material. Tank interior cleaning is typically performed in wash racks (or
cleaning bays), but may also be performed in designated wash areas that are not constructed
specifically for tank interior cleaning. Tank exterior cleaning is often performed in the same
wash racks with the wastewater commingled with tank interior cleaning wastewater. Facilities
                                           4-5
-------
                                                                   Section 4.0 - Industry Description
may have separate, dedicated cleaning bays, cleaning solutions, and equipment for cleaning tanks
that previously contained chemical and food grade cargos.  On average, tank and hopper truck,
IBC, or intermodal tank container cleaning requires two hours:  one-half hour for equipment
handling (i.e., moving the tank in and out of the cleaning bay and preparation  for cleaning), and
one and one-half hours for cleaning, which includes visual inspection and any manual cleaning.
4.3.2
Rail Tank and Hopper Car Cleaning
              Rail tank cars are generally considered empty when they arrive at the facility, but
cars typically contain approximately 60 gallons of heel (typically less than 1% of tank capacity).
Rail hopper cars may contain approximately 100 gallons of heel. Rail tank and hopper car
cleaning processes are similar to the processes used for tank and hopper truck cleaning described
above; however, rail cars are more likely to be cleaned using steam rather than caustic or
detergent cleaning solutions.  Rail car exteriors are less likely to be cleaned. Of particular
concern during rail tank car cleaning is the potential to damage the interior tank lining, which is
designed to protect the tank wall from corrosion by the tank contents.
 4.3.3
Tank and Hopper Barge and Ocean/Sea Tanker Cleaning
              Tank barges are generally considered empty when they arrive at the facility, but
 typically contain approximately 1,000 gallons of heel (typically less than 1% of tank capacity).
 Tank barge cleaning facilities typically perform six basic operations:  strip liquid free, strip and
 blow, clean for a Marine Chemist's Certificate, cold water manual wash, cold water Butterworth®
 (low-pressure, high-volume spinner) wash, and hot water Butterworth® wash.  Depending on the
 specifications of the cleaning request, any one of these operations is performed or repeated, and
 cleaning solutions may be used. The most common cleaning operation involves heel stripping
 followed by a Butterworth® wash and rinse. Heel, wash, and rinse waters are removed from the
 tanks using vacuum pumps.  The barge is then certified for entry by a Marine Chemist and
 facility personnel enter the tanks to inspect the interior. If necessary, a manual wash is
 performed.  Cleaning time for tank barges typically ranges from four to eight hours.

                                            4-6
-------
                                                                      Section 4.0 - Industry Description
                Hopper barges require more manual cleaning than tank barges because of the
  dense nature of the dry bulk cargos last transported. Hopper barges have covers that are easily
  removed by a crane to facilitate tank entry by personnel and equipment and eliminate confined-
  space entry concerns.  Typically, a skid loader (e.g., Bobcat®) is lowered by crane into the barge
  and collects the heel into a large container. The skid loader and container are then removed and
  personnel manually wash the inside of the barge using a high-pressure, high-volume fire hose.
  Wash water is continually stripped from the barge using a vacuum pump. The barge may then be
  inspected by a grain inspector.

               The cleaning operations performed for ocean/sea tankers  are similar to those of
  tank barges, although larger in scale. Cargo hold interiors are predominantly cleaned at sea by
  the tanker crew, with wastewater either discharged shore side at ballast water treatment facilities
  or at sea within the provisions of the International Convention for the Prevention of Pollution by
  Ships (MARPOL). A relatively small percentage of cargo hold interiors are cleaned shore side to
  facilitate inspection and repair and are performed concurrently with ballast tank and bunker (fuel)
  tank cleanings.
 4.3.4
Special Cleaning Processes
               Tanks (particularly tank tracks) that last contained food grade products such as
 corn and sugar sweeteners, juice, and chocolate are typically cleaned using a computer operated
 and controlled washing system, which regulates the cleaning equipment for each step in the
 selected cleaning sequence, including flow rate, pressure, temperature, and cleaning sequence
 duration. The cleaning process is performed in dedicated food grade cleaning bays equipped
 with stainless steel cleaning equipment. A hot water wash is performed according to standards
 adopted by the Coca-Cola Company®, which require certification that each tank has been washed
 and sanitized at a temperature of at least 180°F for a minimum of 15 minutes as measured by the
 temperature of the wash water exiting the tank.  The system includes a temperature chart to
i continuously record the temperature of the recirculating wash water and generates a cleaning
                                            4-7
-------
                                                                   Section 4.0 - Industry Description
ticket for each tank certifying that the temperature and time requirements have been met. The
specification requires tank recleaning if not loaded within 24 hours of certification.
4.4
Tank TVDCS Cleaned
              Facilities responding to the TECI Detailed Questionnaire reported cleaning nine
primary tank types.  These nine tank types can be subdivided into a total of 34 tank
classifications by tank capacity; however, only the primary tank type classifications were
considered for this discussion. The table below lists each of the nine primary tank types and
number cleaned. A  definition of these tank types is located in the glossary in Section 15.0.
Tank Type
Tank Truck (T)
Intermediate Bulk Container (EBC)
Intermodal Tank Container (IM)
Closed-Top Hopper Truck (TH)
Rail Tank Car (R)
Ocean/Sea Tanker (NT)
Closed-Top Hopper Barge (BH)
Closed-Top Hopper Rail Car (RH)
Inland Tank Barge (B)
TOTAL (a)
Number of Cleanings
2,110,000
84,500
81,500
65,500
49,700
14,800
12,600
8,990 .
8,960
2,440,000
Percentage of Total Number
of Tank Cleanings C%) >,
87
3
3
3'
2
<1
<1
<1
<1
100
(a) Differences occur due to rounding.
              The majority of facilities in the TECI reported cleaning only one primary tank
type; however, a total of twenty tank types and combinations of tank types were reported to be
cleaned by facilities in the TECI. The distribution of tank types cleaned is summarized below/
                                           4-8
-------
                                                                      Section 4.0 - Industry Description
-s- /v'
Facility Group c. '^
Facilities that clean only one primary
tank type (e.g., T only, R only)
Facilities that clean both tanks and
closed-top hoppers within the same mode
of transport only (e.g., T and TH, R and
RH)
Facilities that clean tank types with
multiple modes of transport (e.g., T and
R, R and B)
Facilities that clean miscellaneous
combinations of tank types (i.e., no
apparent tank type trends)
TOTAL (a)
;TotaI Number of Facilities in
Group
913
142
13
160
1,229
Percentage of Total Facilities •>
intheTECI<,%)
74
12
1
13
100
 (a) Differences occur due to rounding.

              This distribution demonstrates that the TECI is mostly characterized by facilities
 that clean only one primary tank type. Of the 913 facilities that clean only one primary tank type,
 73% clean only tank trucks and 11 % clean only rail tank cars. The remaining 16% of facilities
 clean, in descending order by percentage of facilities, intermediate bulk containers, closed-top
 hopper trucks, tank barges, closed-top hopper barges, and ocean/sea tankers.  This distribution
 corresponds closely to the total number of each type of tank cleaned. The Agency did not
 identify any facilities that clean only either intermodal tank containers or closed-top hopper rail
 cars.

              For facilities that clean both tanks and closed-top hoppers within the same mode
 of transport (e.g., T and TH, R and RH, or B and BH), the percentage of tank cleanings
performed versus hopper cleanings performed was estimated.  At 94% of the facilities that clean
both tank trucks and closed-top hopper trucks, tank truck cleanings account for at least 75% of all
cleanings performed.  For the remaining 6% of facilities, hopper truck cleanings account for
more than 99% of all cleanings performed. At 91% of facilities that clean both rail tank cars and
closed-top rail hopper cars, rail tank car cleanings typically account for greater than 60% of all
                                           4-9
-------
                                                                    Section 4.0 - Industry Description
cleanings performed. For the remaining 9% of facilities, rail hopper car cleanings account for
nearly 86% of all cleanings performed.  For facilities that clean both tank barges and closed-top
hopper barges, tank barge cleanings comprise less than 1% of all cleanings performed. These
distributions suggest that facilities that clean both tanks and closed-top hoppers typically clean
either predominantly tanks or predominantly closed-top hoppers.

              Only 1% of the TECI consists of facilities that clean tank types within multiple
modes of transportation and 13% cleans combinations of tank types. Of the 13%, all of these
facilities clean tank trucks and some combination of intermediate bulk containers and/or
intermodal tank containers.  Some of these facilities also clean a relatively small percentage of
closed-top hopper trucks.
4.5
Cargo-Tvpes Cleaned
              Facilities responding to the TECI detailed questionnaire reported cleaning 15
general cargo types listed below. Appendix A of the Detailed Questionnaire contains a more
detailed description of these cargo types.

              •      Group A - Food Grade Products, Beverages, and Animal and Vegetable
                     Oils;
              •      Group B - Petroleum and Coal Products;
              •      Group C - Latex, Rubber, and Resins;
              •      Group D - Soaps and Detergent;
              •      Group E - Biodegradable Organic Chemicals;
              •      Group F - Refractory (Nonbiodegradable) Organic Chemicals;
              •      Group G - Inorganic Chemicals;
              •      Group H - Agricultural Chemicals and Fertilizers;
                                           4-10
-------
                                                                    Section 4.0 - Industry Description
              •      Group I - Chemical Products;
              •      Group J - Hazardous Waste (as defined by RCRA in 40 CFR Part 261);
              •      Group K - Nonhazardous Waste;
              •      Group L - Dry Bulk Cargos; and
              •      Group M, N, and O - Other (Not Elsewhere Classified).

              Figure 4-2 illustrates the distribution of TEC facilities by the number of cargo
types cleaned. As demonstrated by this distribution, the TECI is characterized by facilities that
clean either a single cargo type (48%) or a variety of cargo types (52%).

              The distribution of the facilities that clean a single cargo type is presented in
Table 4-1.  Of the facilities that reported cleaning only one cargo type, 81%  clean either food
grade products, beverages, and animal and vegetable oils (65%) or petroleum and coal products
(16%). Facilities that reported cleaning only "other" cargos (Groups M, N, and O) comprise 10%
of facilities that clean a single cargo type. Over half of these facilities that clean only "other"
cargos clean tanks that last contained drilling mud, drilling fluids, salt water, or frac-sand mix
from oil well drilling operations.

              A cursory review of the facilities that clean two or more cargo types suggests no
apparent trends of cargo types cleaned, but rather a wide variety of combinations of "chemical-
type" cargos.
4.6
Heel Removal and Disposal
              As noted in Section 4.3, heel is residual cargo remaining in a tank or container
following unloading, delivery, or discharge of the transported cargo. The amount of heel
removed per tank cleaning depends primarily on the type of tank being cleaned.  Other significant
factors that impact residual heel volume include cargo viscosity, tank internal construction, tank
                                          4-11
-------
                                                                    Section 4.0 - Industry Description
offloading system design, and consignee tank offloading system design.  Table 4-2 provides a
detailed analysis of the average volume of heel removed per tank cleaning by cargo group and
tank type. (Note that ocean/sea tankers are not included in this analysis because that group of
tankers is represented by only one Detailed Questionnaire response and because the facility that
responded reported that no heel was removed from tanks cleaned). As shown in the table, tank
barges contain the largest amount of heel of all the tank types due to their large capacities.  On
average, tank trucks, intermediate bulk containers, and intermodal tank containers contain less
than 10 gallons of heel and rail cars contain approximately 60 gallons of heel.

              Listed below are the 10 discharge or disposal methods for heels reported in
responses to the Detailed Questionnaire:

              •      Discharged with tank cleaning wastewater (WW);
              •      Discharged or hauled separately from tank cleaning wastewater to a
                  •   treatment works (ID);
              •      Evaporation (EV);
              •      On-site or off-site land disposal (LD);
              •      On-site or off-site land application (LA);
              •      On-site or off-site incineration (IN);
              •      On-site or off-site heat recovery (HR);
              •      On-site or off-site reuse or recycle (RR);
                     Deep well injection (DW);  and
              •      Discharged or hauled separately from tank cleaning wastewater to a
                     hazardous waste treatment, storage, and disposal facility (HD).
               Table 4-3 provides a distribution of the total volume of heel discharged or  •
 disposed in 1994 by cargo group and by discharge/disposal method.  As shown in the table, the
                                            4-12
-------
                                                                    Section 4.0 - Industry Description
largest volume of heel (58%) is reused or recycled on or off site.  The largest percentage of
reused or recycled heel consists of food grade products, petroleum and coal products, organic and
inorganic chemicals, and chemical products. Food grade products heel is often reused as animal
feed; petroleum and coal products heel is typically sold for product recovery. The second largest
volume of heel (15%) is land disposed; petroleum and coal products heel and dry bulk cargos
heel comprise 82% of heel that is land disposed.

              Twelve percent of the total heel removed by the TECI is discharged with tank
interior cleaning wastewater and comprises primarily inorganic chemical products, food grade
products, and latex, rubber, and resin heels. Land application, deep well injection, and
incineration are used to dispose less than 2% of the total volume of heel removed.

              Many facilities implement measures to reduce the amount of heel received.  Of
the 1,229 facilities in the TECI, 589 facilities (48% of the population) reported practicing one or
more heel minimization measures.  The most commonly practiced of these measures is to refuse
or reject tanks for cleaning if excessive heel is present.  Some facilities charge an extra fee per
weight or volume of heel received as an incentive to tank owners to minimize heel. Most TEC
facilities maintain good communications with their customers, and drivers are instructed to
inspect all tanks to ensure complete product offloading and to eliminate the need to reject tanks
for cleaning or to assess extra fees.
4.7
Chemical Cleaning Solutions
              As noted in Section 4.3, many cargo types require the use of chemical cleaning
solutions in the tank cleaning process. Responses to the Detailed Questionnaire indicate that
facilities typically use four types of chemical cleaning solutions: (1) acid solution; (2) caustic
solution; (3) detergent solution; and (4) presolve solution.  Acid solutions most commonly used
by TEC facilities are composed of hydrofluoric and/or phosphoric acid and water. In addition to
tank interior cleaning, these acid solutions are used as metal brighteners on aluminum and
stainless steel tank exteriors. Caustic solutions typically comprise a mixture of sodium

                                          4-13
-------
                                                                     Section 4.0 - Industry Description
hydroxide and water in different proportions. The most common ingredients in detergent
solutions are sodium metasilicate and phosphate-based surfactants.  Some facilities use off-the-
shelf brands of detergent solutions such as Tide®, Arm & Hammer®, and Pine Power®.  Often,
concentrated detergents ("boosters") such as glycol ethers or esters are added to acid and caustic
solutions to improve their effectiveness. Presolve solutions usually consist of diesel fuel,
kerosene, or some other petroleum-based solvent.  Other miscellaneous chemical cleaning
solutions include passivation agents (oxidation inhibitors), odor controllers such as citrus oils,
and sanitizers; these solutions are usually applied on a cargo-specific or tank-specific basis.
Responses to the Detailed Questionnaire indicate no obvious trends between the chemical
cleaning solutions used and the cargo types cleaned (i.e., each chemical cleaning solution
category is reported as being used to clean each cargo type noted in Section 4.5). The choice of
chemical cleaning solutions used is more likely a factor of wastewater treatment system
compatibility, POTW limitations, facility preference, and/or customer preference.

              Of the 1,229 facilities in the TECI, 656 (53% of the population) reported using
one or more chemical cleaning solutions. The following table shows the number of facilities that
reported using each chemical cleaning solution.
Chemical Cleaning Solution
Acid Solution
Caustic Solution
Detergent Solution
Presolve Solution
Other Chemical Cleaning Solution
.Number of Facilities That Use
• - Each Chemical Cleaning
' <,, ., Solution '
50
434
560
137
134
Percentage of All Facili ties
That Use Chemical Cleaning
Solutions (%)
8
66
85
21
20
As shown in the table, detergent solution is the most commonly used cleaning solution, used by
85% of all facilities that use chemical cleaning solutions. The second most commonly used
chemical cleaning solution is caustic solution, which is used by 66% of all facilities that use
chemical cleaning solutions.  Acid solution is used by only 8% of all facilities that use chemical
cleaning solutions.
                                           4-14
-------
                                                                    Section 4.0 - Industry Description
              Chemical cleaning solutions are generally reused until they are no longer
 effective, as determined by cleaning personnel. Make-up solution is periodically added to
 replace solution lost in the final rinse or to boost efficacy. Spent cleaning solutions may be
 hauled off site for disposal or discharged to the on-site wastewater treatment system, if
 compatible. Of the 656 facilities that reported using chemical cleaning solutions, 84% discharge
 one or more cleaning solutions to their on-site wastewater treatment systems, 59% of these
 facilities reuse their cleaning solutions before discharge to wastewater treatment, and 16 % send
 their cleaning solutions off site.
4.8
Non-TEC Operations
              In addition to tank interior cleaning, TEC facilities often perform other operations
that may generate wastewater. Some of these operations support transportation equipment
operations such as tank exterior cleaning, tank hydrostatic testing, and tank repair and
maintenance.  Other facilities perform processing or manufacturing operations as their primary
business and use transportation equipment as a component of their primary business. The
following table shows the number of facilities that generate wastewater from each of the non-
TEC operations noted above.
Non-TEC Operation
Tank Exterior Cleaning
Processing and Manufacturing
Tank Hydrotesting
Tank Repair and Maintenance
" .. *<#$&&m^ '- , <•
-- ^l^iKV >'-
-'JSnHHpg^af!! -•? ,,
735
368
197
94
<: * ' ' ^ f , -. .,
„ percentage o'f Total
," -J^opidMon<%> , ' ,-
60
30
16
7
'-' '' ^To^al'^astewater v'--^
•" j A Jf '"'*"*'• "*v ^ ? ""* ' •» "-^
, - ^'Generanoii:^' •,--/
* ~* %aHons>peC'''da3();,' - " > \
1,050,000
62,400,000
900,000
6,920
              Approximately 60% of facilities generate wastewater from tank exterior cleaning
activities. Tank exterior cleaning is usually performed at the same wash rack as tank interior
cleaning; therefore, nearly all tank exterior cleaning wastewater is commingled with TEC interior
cleaning wastewater prior to treatment. Exterior cleaning wastewater may be contaminated by
wastes from a variety of sources, including the cargos last transported in the tank, spent cleaning
                                          4-15
-------
                                                                     Section 4.0 - Industry Description

solutions, exterior surface dirt, soot from engine exhaust, metals from the tank components

(including rust), and engine fluids (including fuel, hydraulic fluid, and oil).


              Processing and manufacturing operations are performed at nearly one third of

facilities and generate relatively large volumes of wastewater. These wastewaters are usually

treated and/or discharged together with tank interior cleaning wastewater due to their similar

composition.


              Tank hydrotesting (i.e., hydrostatic pressure testing), a DOT requirement, is

performed to determine the integrity of a tank and is a component of routine tank inspection.

Since tanks are usually cleaned before hydrotesting, hydrotesting wastewater contains minimal

contaminants and is easily reused or recycled.


              Only 7% of facilities in the TECI reported generating wastewater from repair and

maintenance activities.
4.9
Geographic Profile
              EPA performed a geographical mapping analysis of the Detailed Questionnaire
 sample population of 142 facilities (discharging facilities plus zero discharge facilities). Note
 that a simple geographical mapping of these facilities may not accurately represent the TECI
 because each facility in the sample population has a unique statistical survey weight, ranging
 from 1.0489 to 87.6106, which is not reflected in the maps. The mapping analysis, however,
 may be appropriate to identify geographic trends within the TECI. Figures 4-3 through 4-9

 illustrate the following facility geographic distributions:
                      Figure 4-3: All Facilities;
                      Figure 4-4: Truck Facilities;
                      Figure 4-5: Rail Facilities;
                      Figure 4-6: Barge Facilities;
                      Figure 4-7: Chemical Facilities;


                                            4-16
-------
                                                                      Section 4.0 - Industry Description
              •      Figure 4-8: Food Grade Facilities; and
              •      Figure 4-9: Petroleum Facilities.

              As illustrated in Figure 4-3, TEC facilities are distributed primarily within the
industrial portions of the United States, with relatively high concentrations in the area between
Houston and New Orleans and within specific urban areas such as Los Angeles, Chicago, and St.
Louis. The distribution of truck facilities illustrated in Figure 4-4 mirrors the distribution of all
facilities illustrated in Figure 4-3. The distribution of rail facilities (illustrated in Figure 4-5)
shows lower concentrations in the area between Houston arid New Orleans and higher
concentrations across eastern Texas as compared to Figure 4-3. As illustrated in Figure 4-6,
barge facilities are located along inland waterways of the United States (note the location of an
ocean/sea tanker cleaning facility in Florida). Presumably, differences among the geographical
distributions illustrated in Figures 4-4 through 4-6 indicate major thoroughfares by road,  rail, and
inland waterway, respectively.

              The distribution of chemical facilities illustrated in Figure 4-7 resembles the
distribution of all facilities illustrated in Figure 4-3 except for a relatively lower concentration of
facilities in the northwestern region of the United States. As illustrated in Figure 4-8, food grade
facilities are specifically not located within the area between Houston and New Orleans, and
appear to be located primarily within  agricultural areas of the United States. The distribution of.
petroleum facilities does not include a concentration of facilities within the area between
Houston and New Orleans, an area typically associated with the petroleum industry.  A possible
explanation is that petroleum tanks are loaded in  the Houston/New Orleans area for transport to
other regions of the United States; the tanks may then be cleaned in the local area of the
consignee. Another possible explanation is that pipelines rather than tanks are the primary mode
of petroleum product transportation in this area.
                                            4-17
-------
r
                                                                                   Section 4.0 - Industry Description
              4.10
References1
              1.
              2.
U.S. Environmental Protection Agency.  Information Collection Request. 1994
Detailed Questionnaire for the Transportation Equipment Cleaning Industry.
November 1994 (DCN T09843).

Eastern Research Group, Inc. Data Element Dictionary for Part A of the U.S.
Environmental Protection Agency 1994 Detailed Questionnaire for the
Transportation Equipment Cleaning Industry Database. April 4, 1997 (DCN
T10271).
               1 For those references included in the administrative record supporting the proposed TECI rulemaking, the
                document control number (DCN) is included in parentheses at the end of the reference.

                                                          4-18
-------
                                                                           Section 4.0 - Industry Description
                                           Table 4-1
 Distribution of Facilities That Clean a Single Cargo Type - Discharging and
                                 Zero Discharge Facilities
Cargo Type Cleaned - ,
Food Grade Products, Beverages, and
Animal and Vegetable Oils (A)
Petroleum and Coal Products (B)
Latex, Rubber, and Resins (C)
Soaps and Detergents (D)
Biodegradable Organic Chemicals (E)
Refractory (Nonbiodegradable) Organic
Chemicals (F)
Inorganic Chemicals (G)
Agricultural Chemicals and Fertilizers (H)
Chemical Products (I)
Hazardous Waste (J)
Nonhazardous Waste (K)
Dry Bulk Cargos (L)
Other (M, N, or O)
TOTAL (b)
, Number of Facilities
385
96
(a)
''NC
NC
NC
11
20
NC
NC
NC
22
60
596
Percentage.©/ Facilities That^
,X3eaitOiilyThis €argoxType ;
(%) s ;. ,:
65
16
(a)
NC
NC
NC
2
3
NC
NC
NC .
4
10
100
(a) The data in this cell represents three or fewer facilities and therefore is not shown here due to confidential
business information and/or other data disclosure considerations.
(b) Differences due to rounding.
NC - Facilities with this characteristic were not identified by responses to the Detailed Questionnaire. Therefore,
data for these facilities, if facilities with these characteristics do indeed exist, are not available for this analysis.
                                               4-19
-------
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                                  4-21
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4-22
-------
                                                             Section 4.0 - Industry Description
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Figure 4-2.  Distribution of TEC Facilities by Number of Cargo Types Cleaned
                   Discharging and Zero Discharge Facilities
                                    4-23
-------
                                                                 Section 4.0 - Industry Description
Figure 4-3.  Geographic Profile of Discharging and Zero Discharge Facilities in the TECI
                      Detailed Questionnaire Sample Population
                                         4-24
-------
                                                                 Section 4.0 - Industry Description
Figure 4-4. Geographic Profile of Discharging and Zero Discharge Truck Facilities in the
                   TECI Detailed Questionnaire Sample Population
                                        4-25
-------
                                                               Section 4.0 - Industry Description
Figure 4-5.  Geographic Profile of Discharging and Zero Discharge Rail Facilities in the
                  TECI Detailed Questionnaire Sample Population
                                       4-26
-------
                                                                 Section 4.0 - Industry Description
Figure 4-6. Geographic Profile of Discharging and Zero Discharge Barge Facilities hi the
                   TECI Detailed Questionnaire Sample Population
                                        4-27
-------
                                                               Section 4.0 - Industry Description
Figure 4-7. Geographic Profile of Discharging and Zero Discharge Facilities in the TECI
        Detailed Questionnaire Sample Population that Clean Chemical Cargos
                                       4-28
-------
                                                                Section 4.0 - Industry Description
Figure 4-8. Geographic Profile of Discharging and Zero Discharge Facilities hi the TECI
       Detailed Questionnaire Sample Population that Clean Food Grade Cargos
                                       4-29
-------
                                                               Section 4.0 - Jhdnstty Description
Figure 4-9. Geographic Profile of Discharging and Zero Discharge Facilities in the TECI
        Detailed Questionnaire Sample Population that Clean Petroleum Cargos
                                       4-30

-------
                                                                Section 5.0 - Industry Subcategorization
5.0
INDUSTRY SUBCATEGORIZATION
              The division of a point source category into groups called "subcategories"
provides a mechanism for addressing variations among products, raw materials, processes, and
other parameters that can result in distinct effluent characteristics. This provides each
subcategory with a uniform set of effluent limitations guidelines that take into account
technology achievability and economic impacts unique to that subcategory.  In developing
effluent limitations, EPA assesses several factors including manufacturing processes, products,
the size and age of the facility, wastewater use, and wastewater characteristics. The
Transportation Equipment Cleaning Industry (TECI), however, is not typical of many of the other
industries regulated under the Clean Water Act (CWA) because it does not produce a product.
Therefore, EPA developed additional factors that specifically address the characteristics of
transportation equipment cleaning (TEC) operations. Similarly, several factors typically
considered for subcategorization of manufacturing facilities were not considered applicable to
this industry.  For this proposed rulemaking, EPA considered the following factors:

              •      Cleaning processes (production processes);
              •      Tank type  cleaned;
              •      Cargo type cleaned;
              •      Water use practices;
              •      Wastewater characteristics;
              •      Facility age;
              •      Facility size;
              •      Geographical location;
              •      Water pollution control technologies;
              •      Treatment costs; and
              •      Non-water quality impacts.

              After evaluating the above factors, EPA determined that subcategorization of the
TECI is necessary.
                                           5-1
-------
5.1
                                                                Section 5.0 - Industry Subcategorization
Factors Considered for Basis of Subcategorization
              EPA considered a number of potential subcategorization approaches for the TECI.
EPA used information collected during 39 engineering site visits, the Screener Questionnaire for
the TECI (1), and the Detailed Questionnaire for the TECI (2) to develop potential
subcategorization approaches. EPA considered eleven factors in developing its subcategorization
scheme for the TECI. A discussion of each is presented below.

              Consistent with other effluent guidelines subcategorization efforts, information
presented in this section is based on operations performed by the estimated total TECI population
of 1,229 facilities. This total includes an estimated 692 discharging facilities and 537 zero
discharge facilities. Section 3.2.3.4 further discusses these facilities.

              The following paragraphs summarize EPA's consideration of the eleven factors
listed in the beginning of this section in determining appropriate subcategories for the TECI.  A
detailed analysis can be found in the Subcategorization Analysis for the Transportation
Equipment Cleaning Industry (3).
5.1.1
 Cleaning Processes (Production Processes)
              EPA interpreted "production processes" to be the cleaning processes used by TEC
 facilities. Section 4.3 describes TEC operations and the various methods used to clean tank
 interiors. In summary, the cleaning process descriptions provided in Section 4.3 show the
 following characteristics within the TECI:
               1.     Fundamental cleaning processes are the same for all tanks;
               2.     Use of chemical cleaning solutions versus water washes is dependent upon
                     the type of cargo cleaned;
               3.     Cleaning equipment includes either low- or high-pressure spinner nozzles
                     or hand-held wands and nozzles;
                                            5-2
-------
                                                                 Section 5.0 - Industry Subcategorization
              4.     Heel volumes vary significantly depending on the type of tank cleaned;
              5.     Time required for tank cleaning varies significantly depending on the tank
                     type and cargo type cleaned;
              6.     Rail car cleaning processes are more likely to include steam cleaning than
                     truck or barge cleaning processes;
              7.     Hopper barge cleaning processes differ significantly from tank barge
                     cleaning processes; and
              8.     Cleaning processes for food grade cargos differ significantly from cleaning
                     processes for other cargo types.

              Characteristics 1 and 3 were not considered bases for industry Subcategorization
and were not evaluated further.

              Characteristics 2 and 8 suggest potential, Subcategorization of the TECI based on
use of chemical solutions and/or type of cargo cleaned. EPA analyzed the use of chemical
cleaning solutions in the TECI and the relationship between the use of chemical cleaning
solutions and type of cargo cleaned in the TECI. Approximately 56% of TEC facilities use
chemical cleaning solutions in one or more of their cleaning processes.  Facilities that clean a
variety of cargo types (i.e., five or greater) are more likely to use chemical cleaning solutions
than facilities that clean four or fewer cargo types. EPA further evaluated facilities that clean
four or fewer cargo types to identify trends based on specific cargo types cleaned. Significantly,
only 4% of facilities that clean only petroleum and coal products use chemical cleaning solutions.
For the remaining facilities grouped by cargo types cleaned, the use of chemical cleaning
solutions is not a distinguishing factor.
              Characteristics 4, 5, 6, and 7 suggest potential Subcategorization of the TECI
based on the type of tank cleaned. However, characteristics 4 and 5 were not analyzed further
because these characteristics are not anticipated to result in distinct effluent characteristics. For
example, the volume of heel removed is primarily an indication of product offloading efficiency
by the consignee rather than an indication of the efficiency of heel removal (an associated water

                                            5-3
-------
                                                                  Section 5.0 - Industry Subcategorization
pollution prevention practice) by the cleaning facility. The time required for cleaning is often an
indication of the duration of recirculating wash cycles, which generally do not generate
wastewater.

              EPA evaluated the relationship between the predominant type of tank cleaned and
the use of chemical cleaning solutions.  This analysis revealed that none of the facilities that
clean predominantly closed-top hoppers uses chemical cleaning solutions, indicating that these
facilities use significantly different cleaning processes than tank truck, rail tank car, and tank
barge cleaning facilities. As determined from Detailed Questionnaire responses, typical cargos
cleaned by closed-top hopper facilities include dry bulk products such as agricultural chemicals,
fertilizers, and coal cargos not typically hauled in tank trucks, rail tank cars, and tank barges.
Therefore, closed-top hopper cleaning facilities are unique from other facilities based on both
cleaning processes used and cargo types transported.

              In summary, these results indicate differences between certain types of facilities
based on cleaning processes used. Unique facility types include facilities that clean a wide
variety of cargo types, facilities that clean only food grade products, facilities that clean only
petroleum and coal products, and facilities that clean predominantly closed-top hoppers.
However, these differences are primarily related to cargo types and tank types cleaned. Further
Subcategorization analyses related to cargo types and tank types cleaned are described below.
Therefore, cleaning processes alone were not considered an appropriate basis for
Subcategorization.
 5.1.2
Tank Type Cleaned
               EPA analyzed the distribution of TEC facilities by tank type and combinations of
 tank types cleaned. Section 4.4 of this document discusses in detail the various tank types
 cleaned. In general, facilities responding to the Detailed Questionnaire reported cleaning the nine
 primary tank types listed below:
                                             5-4
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                                                                 Section 5.0 - Industry Subcategorization
                     Tank Truck (T);
                     Rail Tank Car (R);
                     Tank Barge (B);
              •      Intermediate Bulk Container (IBC);
              •      Intermodal Tank Container (IM);
                     Ocean/Sea Tanker (NT);
                     Closed-Top Hopper Truck (TH);
                     Closed-Top Hopper Rail Car (RH); and
                     Closed-Top Hopper Barge (BH).

              The majority of facilities in the TECI (913 of 1,229 facilities) reported cleaning
only one primary tank type, indicating that the TECI is mostly characterized by facilities that
clean only one primary tank type. Of these 913 facilities, 73% clean only tank tracks and 11%
clean only rail tank cars. The remaining 16% of facilities clean, in descending order by
percentage of facilities,  only intermediate bulk containers, closed-top hopper tracks, tank barges,
closed-top hopper barges, or ocean/sea tankers. None of the facilities (as represented by the
Detailed Questionnaire sample population) clean only either intermodal tank containers or
closed-top hopper rail cars.
              EPA conducted 39 engineering site visits at facilities that clean tank tracks, rail
tank cars, or tank barges. Information collected during these visits suggests many distinct
physical and operational characteristics among these three facility types that warrant distinct
subcategories for these three facility types. First, although all three facility types use chemical
cleaning solutions in tank cleaning processes as  discussed above, rail tank car cleaning facilities
are niore likely than other facility types to use steam in place of, or in addition to, chemical
cleaning solutions in the cleaning process.  Second, the specific cargos cleaned by the three
facility types vary significantly. Tank tracks are used to transport refined end-use products. This
contrasts with tank barges, which are used to transport predominantly crude, unrefined cargos
and major manufacturing feedstock cargos such as petrochemicals and bulk oils (including
foodgrade oils).  Cargos transported by rail tank car include products primarily in the middle of
this cargo type range, between crude, unrefined products and refined end-use products.  Third,
volume and characteristics of wastewater generated by these facility types differ significantly, as
described in Section 6.0.  Finally, as a result of differences in the volume and characteristics of

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                                                                 Section 5.0 - Industry Subcategorization
wastewater generated, average wastewater treatment costs currently incurred by facilities differ
significantly for these facility types.

              Facilities that clean ocean/sea tankers represent less than one percent of facilities
within the TECI.  Cleaning operations performed and specific commodities cleaned are similar to
those of tank barges, although different in scale. Based on the size of the ocean/sea tanker
cleaning segment and its similarity to the tank barge segment, development of a separate
subcategory within the TECI for ocean/sea tankers is not warranted.

              Thirteen percent of facilities clean combinations of tank types; all of these
facilities clean tank trucks and some combination of intermediate bulk containers and/or
intermodal tank containers.  Information collected  during engineering site visits at these facilities
indicates that the cargo types cleaned and cleaning operations performed are identical for tanks
and containers, with minor modifications for cleaning intermediate bulk containers due to their
relatively small capacity. Therefore, development of a separate subcategory within the TECI for
intermediate bulk and/or intermodal tank containers is not warranted.

              An additional 12% of facilities clean both tanks and closed-top hoppers within the
same mode of transportation (e.g., T and TH, R and RH, or B and BH).  An analysis of these
facilities indicates that they clean either predominantly tanks or predominantly closed-top
hoppers. Based on this characterization, development of a separate subcategory within the TECI
for these facilities is not warranted.  These facilities are best characterized and regulated as
facilities with operations in multiple subcategories.

               In summary, these results indicate significant differences between facilities based
 on tank types cleaned.  Therefore, EPA determined that subcategorization based, in part, on tank
 types cleaned is appropriate.
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                                                               Section 5.0 - Industry Subcategorization
5.1.3
Cargo Type Cleaned
              EPA considered subcategorizing the TECI based on the cargo type cleaned.
Respondents to the Detailed Questionnaire reported cleaning tanks which transported 15 general
cargo types. The reported cargo types are listed below:

              •     Group A - Food Grade Products, Beverages, and Animal and Vegetable
                    Oils;
              •     Group B - Petroleum and Coal Products;
              •     Group C - Latex, Rubber, and Resins;
              •     Group D - Soaps and Detergents;
              •     Group E - Biodegradable Organic Chemicals;
              •     Group F - Refractory (Nonbiodegradable) Organic Chemicals;
              •     Group G - Inorganic Chemicals;
              •     Group H - Agricultural Chemicals and Fertilizers;
              •     Group I - Chemical Products;
              •     Group J - Hazardous Waste (as defined by RCRA in 40 CFR Part 261);
              •     Group K - Nonhazardous Waste;
              •     Group L - Dry Bulk Cargos (i.e., hopper cars); and
              •     Group M, N, and O - Other (Not Elsewhere Classified).
              Of all responding TEC facilities not previously regulated, 48% clean only one
cargo type while 52% clean a variety of cargo types.  Of the facilities that reported cleaning only
one cargo type, 65% reported cleaning food grade products, beverages, and animal and vegetable
oils (Group A), 16% reported cleaning petroleum and coal products (Group B), and 10% reported
cleaning "other cargos" (Groups M, N and O).  A review of the data for facilities that clean two

                                          5-7
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                                                                Section 5.0 - Industry Subcategorization
or more cargos suggests no apparent trend in cargo types cleaned, but rather a wide variety of
combinations of "chemical-type" cargos.

             There are several reasons to consider subcategorization based on type of cargo.
Facilities that clean tanks which contained only food grade products (Group A), petroleum grade
products (Group B), or dry bulk goods (Group L) represent distinct and relatively large segments
of the TECI that differ significantly from facilities that clean tanks containing a wide variety of
cargos. The type of cargo transported and the type of cleaning processes utilized influences
wastewater characteristics. EPA therefore concluded that subcategorization of the TECI based,
in part, on cargo type is an appropriate means of subcategorization.

              EPA was not able to identify any other distinct segments of the TECI among the
remaining groups which included Latex, Rubber, and Resins (Group C), Soaps and Detergents
(Group D), Biodegradable Organic Chemicals (Group E), Refractory (Nonbiodegradable)
Organic Chemicals (Group F), Inorganic Chemicals (Group G), Agricultural Chemicals and
Fertilizers (Group H), Chemical Products (Group I), Hazardous Waste (Group J), Nonhazardous
Waste (Group K), and Groups M, N, and O consisting of cargos not elsewhere classified. EPA
concluded that facilities which do not clean primarily food grade products (Group A), petroleum
grade  products (Group B), or dry bulk goods (Group L) are likely to clean a wide variety of
cargos types consisting of various combination of cargos types products. EPA has therefore
created a subcategory termed "chemical" for any facility that cleans a wide variety of cargos and
commodities.

              EPA originally considered developing separate  subcategories for barge-chemical
 and barge-petroleum facilities. However, based on raw wastewater characterization data
 collected in support of this proposed rule, EPA concluded that the wastewater characteristics and
 treatability of wastewaters generated from barge-chemical and barge-petroleum facilities were
 similar, and thus it was reasonable to combine these subcategories.
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                                                                  Section 5.0 - Industry Subcategorization
5.1.4
Water Use and Wastewater Reuse Practices
              TEC facilities use water for cleaning and rinsing as well as for a number of
ancillary purposes such as hydrotesting, air pollution control, and process cooling water.  Water
use varies based on a number of factors including type of tank cleaned, type of cleaning solution
utilized, type of cargo last contained in the tank, type of cargo to be transported, and tank
capacity. Significant observations of distinctions in water use include:
                     Rail facilities use significantly larger volumes of water for tank
                     hydrotesting than truck facilities, presumably because rail tanks have
                     larger capacities; barge cleaning facilities do not report performing
                     hydrotesting.

                     Truck facilities use significantly larger volumes of water for tank exterior
                     cleaning operations, presumably because tank exterior appearance is more
                     important for trucks, which are highly visible to the public.

                     Rail facilities use significantly larger volumes of boiler water, presumably
                     because of their more extensive use of steam cleaning. (Virtually all
                     facilities, regardless of tank type, use boilers to heat cleaning solutions and
                     rinses and to heat air for tank drying.)

                     Food grade facilities use significant volumes of cooling water, both for
                     TEC operations and for other on-site processes (e.g., juice processing,
                     rendering).

                     Petroleum facilities use significantly larger volumes of tank hydrotesting
                     water, presumably because petroleum tanks are often in dedicated service
                     and are cleaned primarily to facilitate inspection and repair, which
                     typically includes tank hydrotesting.
These observations indicate differences among facilities based on water use practices; however,
these differences are primarily related to types of tanks and cargos cleaned.


              EPA also investigated facilities that do not discharge TEC process wastewater to
surface waters or to POTWs (i.e., zero discharge facilities) to determine whether they exhibited
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                                                                 Section 5.0 - Industry Subcategorization
any unique water use characteristics that might represent a distinct subcategory. Of the estimated
537 zero discharge facilities, 46% achieved zero discharge by hauling their wastewater off site
for treatment and/or disposal. Facilities may haul wastewater offsite because it is less expensive
than on-site treatment. An estimated 46% of zero discharge facilities disposed of their
wastewater by on-site land application, land disposal, deep-well injection, or evaporation. These
alternative disposal options are available to some facilities because of site-specific conditions
which may include being situated on land suitable for land-application, or being located close to
an off site waste treatment facility.

              Only 8% of zero discharge facilities recycled or reused 100% of their TEC process
wastewater.  Of these, 70% clean predominantly (i.e., 95% or greater) tanks that last contained
petroleum and coal products. As noted in Section 6.0, facilities that clean tanks containing
petroleum and coal products discharge significantly less wastewater per tank cleaned than other
types of facilities.

              In summary, the variations in water use practices among different types of
facilities demonstrate that the most appropriate method of Subcategorization that encompasses
water use practices is based on the type of tank cleaned and type of cargo cleaned at a facility.
 5.1.5
Wastewater Characteristics
               EPA evaluated two wastewater characteristics for this Subcategorization analysis:
 volume of tank interior cleaning wastewater generated per tank cleaned and concentration of
 pollutants in TEC process wastewater.  Section 6.0 provides additional information concerning
 these two wastewater characteristics.

               In order to evaluate wastewater volumes, EPA calculated the median wastewater
 volume generated per tank cleaned from several different tank and cargo classifications.  The
 classifications selected represented cleaning processes performed, tank type cleaned, cargo type
 cleaned, and water use and wastewater reuse practices described earlier in this section.
                                            5-10
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                                                        :         Section 5.0 - Industry Subcategorization

              The median tank interior cleaning wastewater volumes generated by tank type

(gallons per tank) indicate significant differences, particularly for tank trucks (452) versus rail

tank cars (1,229) and tank barges (1,669); and for tanks (452 to 1,669) versus closed-top hoppers

(144 to 712). The median tank interior cleaning wastewater volumes generated by tank type and

cargo type (gallons per tank) also indicate significant differences, particularly for truck-chemical

(449) versus rail-chemical (1,701) versus barge-chemical (2,365); and for chemical (449 to

2,365) versus petroleum (11 to 150).


              EPA also evaluated available raw wastewater characterization data by tank type

and cargo classification. Significant observations from these analyses include:
                     The number and types of pollutants detected at truck-chemical, rail-
                     chemical, and barge-chemical facilities were similar.

                     Fewer pollutants were detected at the truck-petroleum facilities than at the
                     truck-chemical facilities, and similarly detected pollutants were found at
                     significantly lower concentrations at the truck-petroleum facilities.

                     The majority of pollutants detected at barge-chemical facilities were also
                     detected at the barge-petroleum facility.

                     The number and types of pollutants detected in the truck-food, rail-food,
                     and barge-food facilities were similar.

                     The one closed-top hopper barge facility sampled was significantly
                     different from the other facility types in terms of the number of priority
                     pollutants detected, the total number of pollutants detected, and the
                     specific pollutants detected.
              In conclusion, the distribution of median wastewater volume generated supports
 the development of distinct subcategories within the TECI based on tank type and cargo type
 cleaned. Analysis of raw wastewater characterization data collected during EPA's sampling
 program also supports development of distinct subcategories within the TECI, with the exception
 of the barge-chemical and barge-petroleum segments. For the barge-chemical and barge-
                                            5-11
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                                                                Section 5.0 - Industry Subcategorization
petroleum segments, the raw wastewater characterization data support combining these two
facility types into a single subcategory: barge-chemical & petroleum.
5.1.6
Facility Age
              EPA evaluated the age of facilities as a possible means of Subcategorization
because older facilities may have different processes and equipment that result in different
wastewater characteristics, and which therefore may require significantly greater or more costly
control technologies to comply with regulations

              EPA evaluated the treatment technologies in place as related to the year in which
the facility first conducted TEC operations. For this analysis, EPA characterized older facilities
as those that began TEC operations prior to 1980, and compared their wastewater treatment-in-
place to that of facilities that began TEC operations after 1980.  Treatment-in-place was
evaluated by whether facilities use treatment technologies classified as follows:  no treatment,
pretreatment, primary treatment, secondary treatment, and advanced treatment. The specific
treatment technologies included within these technology classifications are listed in the Detailed
Questionnaire Data Element Dictionary (4).  These analyses indicated that older facilities are as
likely to be currently operating treatment in place for each wastewater treatment classification as
are newer facilities. In addition, many older facilities have improved, replaced, or modified
equipment over time.

              As described in Section 6.0, wastewater characteristics are predominantly
dependent on the type of cargos being cleaned, the type of tank being cleaned, and the types of
cleaning operations performed.  The age of a facility does not have an appreciable impact on
wastewater characteristics and was not considered as a basis for Subcategorization.
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                                                                 Section 5.0 - Industry Subcategorization
5.1.7
Facility Size
              EPA considered Subcategorization of the TECI on the basis of facility size.  Three
parameters were identified as relative measures of facility size: number of employees, number of
tanks cleaned, and wastewater flow. EPA found that facilities of varying sizes generate similar
wastewaters and use similar treatment technologies within the proposed Subcategorization
approach. A detailed discussion of the pollutant loadings associated with small facilities can be
found in the "Cost-Effectiveness Analysis of Proposed Effluent Limitations Guidelines and
Standards for the Transportation Equipment Cleaning Category" (5). EPA determined that the
industry should not be subcategorized based on facility size.
5.1.8
Geographical Location
              EPA performed a geographical mapping analysis of the Detailed Questionnaire
sample population of 142 facilities (discharging facilities plus zero discharge facilities). Note
that a simple geographical mapping of these 142 facilities may not accurately represent the TECI
because each facility in the sample population has a unique statistical survey weight, ranging
from 1 to 87.6, which is not reflected in the maps; however, the mapping analysis may be
appropriate to identify potential geographic trends within the TECI.  Maps were prepared to
reflect all surveyed facilities and to reflect facilities classified by tank type and by cargo type
(these maps are also presented and discussed in Section 4.9). The following geographic trends
were observed:
                     TEC facilities are located primarily within the industrial portions of the
                     United States, with relatively high concentrations in the area between
                     Houston and New Orleans and within specific urban areas, such as Los
                     Angeles, Chicago, and St. Louis;
                     The distribution of truck facilities mirrors the distribution of all facilities;
                     The distribution of rail facilities shows lower concentrations in the area
                     between Houston and New Orleans and higher concentrations across
                     eastern Texas as compared to all TEC facilities;
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                                                                 Section 5.0 - Industry Subcategorization
                     Barge facilities are located along inland waterways of the United States;
                     The distribution of chemical facilities resembles the distribution of all
                     TEC facilities except for a relatively lower concentration of facilities in the
                     northwestern region of the United States;
                     Food grade facilities are specifically not located within the area between
                     Houston and New Orleans, and appear to be located primarily within
                     agricultural areas of the United States; and
                     Petroleum facilities are not concentrated in the area between Houston and
                     New Orleans, an area typically associated with the petroleum industry.
              These trends suggest differences among facilities based on geographic
distribution; however, these differences are primarily related to types of tanks and cargos
cleaned. Therefore, geographic location alone is not an appropriate basis for subcategorization.

              Geographic location may impact costs if additional land is required to install
treatment systems, since the cost of land will vary depending on whether the site is located in an
urban or rural location.  The treatment systems used to treat TEC wastewaters typically do not
have large land requirements; therefore, subcategorization based on land availability is not
appropriate. Water availability is also a function of geographic location. However, limited water
supply encourages conservation by efficient use of water, including recycling and reuse, and
encourages the early installation of practices advisable for the entire category to reduce treatment
costs and improve pollutant removals.  For this reason also, geographic location alone is not an
appropriate basis for subcategorization.
5.1.9
Water Pollution Control Technologies
              EPA evaluated water pollution control technologies currently being used by the
industry as a basis for establishing regulations.  The technologies are appropriate for the
wastewater characteristics typical of the TECI.  As discussed in Section 5.1.5, TEC wastewater
characteristics (including wastewater volume generated and pollutant concentrations) are
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                                                                Section 5.0 - Industry Subcategorization
dependent upon tank type and cargo type cleaned.  Sections 5.1.2 and 5.1.3 discuss
subcategorization of the TECI based on tank type and cargo type cleaned, respectively.
Therefore, water pollution control technologies alone are not considered an appropriate basis for
subcategorization.
5.1.10
Treatment Costs
              Treatment costs vary significantly among facilities and are primarily dependent
upon water pollution control technologies being used and on facility wastewater flow rates. As
discussed in Section 5.1.9, water pollution control technologies used are based upon the facility
wastewater characteristics, which are dependent upon tank type and cargo type cleaned.
Therefore, treatment costs alone are not considered an appropriate basis for subcategorization.
5.1.11
Non-Water Quality Impacts
              Non-water quality environmental impacts from the TECI result from solid waste
disposal, transportation of wastes to off-site locations for treatment and disposal, and emissions
of volatile organic compounds to the air. However, as these impacts are a result of individual
facility practices and do not apply uniformly across different industry segments, non-water
quality impacts are not an appropriate basis for subcategorization. Section 12.0 provides further
information concerning non-water quality impacts of the TECI.
5.2
Selection of Subcategorization Approach
              Based on its evaluation of above factors, EPA determined that subcategorization
of the TECI is necessary and that different effluent limitations and pretreatment standards should
be developed for subcategories of the industry. EPA concluded that the most appropriate basis
for subcategorization of the industry be based on tank type and cargo type cleaned.
                                           5-15
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                                                                Section 5.0 - Industry Subcategorization
              EPA has classified a facility into one subcategory by establishing a hierarchy of
applicability as follows: if 10% or more of the tanks cleaned on a yearly basis at a tank track or
rail car facility contain chemical cargos, then that facility is placed in the Truck/Chemical or
Rail/Chemical Subcategory, and subject to the effluent limitations and pretreatment standards
proposed for the Truck/Chemical or Rail/Chemical Subcategory. For a barge facility, if 10% or
more of the tanks cleaned on a yearly basis contain chemical or petroleum cargos, then that
facility is placed in the Barge/Chemical & Petroleum Subcategory and is subject to the effluent
limitations proposed for the Barge/Chemical & Petroleum Subcategory.

              If a truck or rail facility does not clean 10% or more of tanks containing chemical
cargos, but does clean 10% or more of tanks containing food grade cargos on a yearly basis, then
that facility is placed in the Truck/Food or Rail/Food Subcategory. There are no pretreatment
standards being proposed for indirect discharging Truck/Food or Rail/Food facilities, but EPA is
proposing effluent limitations for conventional pollutants for direct discharging Track/Food and
Rail/Food facilities.

              Similarly, if a barge facility does not clean  10% or more of tanks containing
chemical and/or petroleum cargos, but does clean 10% or more of tanks containing food grade
cargos on a yearly basis, then that facility is placed in the Barge/Food Subcategory.  There are no
pretreatment standards being proposed for indirect discharging Barge/Food facilities, but EPA is
proposing effluent limitations for conventional pollutants for direct discharging Barge/Food
facilities.

              Remaining rail and track facilities which clean more  than 80% of tanks containing
petroleum cargos on a yearly basis have been placed in the Track/Petroleum and Rail/Petroleum
Subcategories. Facilities which clean hopper tanks have been placed in the Track/Hopper,
Rail/Hopper, or Barge/Hopper Subcategories. EPA is not proposing to regulate wastewater
discharged from the Track/Petroleum and Rail/Petroleum, and Track/Hopper, Rail/Hopper, and
Barge/Hopper Subcategories.
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                                                                  Section 5.0 - Industry Subcategorization
              EPA is not proposing to regulate toxic parameters for facilities that clean tanks
that have transported only petroleum, food, or dry bulk cargos, with the exception of barge
facilities that clean tanks containing petroleum cargos.

              From the possible combinations of tank types and cargos last hauled, EPA
proposes subcategorization of the TECI into 11 subcategories. The tank type classifications
include: (1) tank tracks and intermodal tank containers; (2) rail tank cars; (3) inland tank barges
and ocean/sea tankers; (4) closed-top hopper tracks; (5) closed-top hopper rail cars; and
(6) closed-top hopper barges. A description of each of these tank type classifications is presented
in Section 15.0. Containers defined as drams  or intermediate bulk containers (IBCs) are
proposed not to be covered by this guideline.

              The cargo type classifications used as a basis for subcategorization include:
(1) petroleum; (2) food grade; (3) dry bulk; and (4)  chemical. A description of the cargo type
classifications is provided below.

              Petroleum

              Petroleum cargos include the products of the fractionation or straight distillation
of crude oil, redistillation of unfinished petroleum derivatives, cracking, or other refining
processes. Petroleum cargos also include products  obtained from the refining or processing of
natural gas and coal.  Specific examples of petroleum products include but are not limited to:
asphalt; benzene; coal tar; crude oil; cutting oil; ethyl benzene; diesel fuel; fuel additives; fuel
oils; gasoline; greases; heavy, medium, and light oils; hydraulic  fluids, jet fuel; kerosene; liquid
petroleum gases (LPG) including butane and propane; lubrication oils; mineral spirits; naphtha;
olefin, paraffin, and other waxes; tall oil; tar; toluene; xylene; and waste oil.
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                                                                Section 5.0 - Industry Subcategorization
cargos.  If 10% or more of the total tanks cleaned at that facility in an average year contained
chemical cargos, then that facility is in Subcategory B: Rail/Chemical.

              Subcategory F: Barge/Food

              Subcategory F would apply to apply to TEC facilities that clean tank barges or
ocean/sea tankers where 10% or more of the total tanks cleaned at that facility in an average year
contained food grade cargos, so long as that facility does not clean 10% or more of tanks
containing chemical cargos. If 10% or more of the total tanks cleaned at that facility in an
average year contained chemical and/or petroleum cargos, then that facility is in Subcategory C:
Barge Chemical & Petroleum.

              Subcategory G: Truck/Petroleum

              Subcategory G would apply to apply to TEC facilities that clean tank trucks and
intermodal tank containers where 80% or more of the total tanks cleaned at that facility in an
average year contained petroleum cargos, so long as that facility is not in Subcategory A:
Truck/Chemical or Subcategory D: Truck/Food.

              Subcategory H: Rail/Petroleum

              Subcategory H would apply to TEC facilities that clean rail tank cars where 80%
or more of the total tanks cleaned at that facility in an average year contained petroleum cargos,
so long as that facility is not in Subcategory B: Rail/Chemical or Subcategory E: Rail/Food.

              Subcategory I: Truck/Hopper

              Subcategory I would apply to TEC facilities that clean closed-top hopper trucks
which transport dry bulk commodities that  are not chemical commodities.
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                                                               Section 5.0 - Industry Subcategorization
              Subcategory J: Rail/Hopper
              Subcategory J would apply to TEC facilities that clean closed-top hopper rail cars
which transport dry bulk commodities that are not chemical commodities.


              Subcategory K: Barge/Hopper


              Subcategory K would apply to TEC facilities that clean closed-top hopper barges
which transport dry bulk commodities that are not chemical commodities.
5.3
References1
1.
2.
3.
4.
5.
U.S. Environmental Protection Agency.  Information Collection Request, Tank
and Container Interior Cleaning Screener Questionnaire. December 1993
(DCNT00312).

U.S. Environmental Protection Agency.  Information Collection Request. 1994
Detailed Questionnaire for the Transportation Equipment Cleaning Industry.
November 1994 (DCN T09843).

Eastern Research Group, Inc. Subcategorization Analysis for the Transportation
Equipment Cleaning Industry. May 5, 1998 (DCN T04653).

Eastern Research Group, Inc. Data Element Dictionary for Part A of the U.S.
Environmental Protection Agency 1994 Detailed Questionnaire for the
Transportation Equipment Cleaning Industry. April 4, 1997 (DCNT10271).

U.S. Environmental Protection Agency.  Cost-Effective Analysis of Proposed
Effluent Limitations Guidelines and Standards for the Transportation Equipment
Cleaning Category. EPA-821-B-98-013, May 1998.
1  For those references included in the administrative record supporting the proposed TECI rulemaking, the
  document control number (DCN) is included in parentheses at the end of the reference.

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6.0
                                       Section 6.0 - Water Use and Wastewater Characterization
WATER USE AND WASTEWATER CHARACTERIZATION
              As part of the characterization of the Transportation Equipment Cleaning Industry
(TECI), EPA determined water use and wastewater generation practices associated with
transportation equipment cleaning (TEC) operations and assessed what constituents may be
present in TEC wastewater. Information presented in this section is based on data provided by
facilities in response to the Detailed Questionnaire and obtained by EPA's site visit and sampling
programs. The Detailed Questionnaire database includes information regarding each facility's
water use, wastewater discharge, and disposal practices. The following topics are discussed in
this section:
                    Section 6.1: An overview of water use and wastewater generation in the
                    TECI;
                    Section 6.2: The sources of wastewater identified in the TECI;
                    Section 6.3: A discussion of the wastewater discharge practices within the
                    TECI;
                    Section 6.4: An overview of water reuse and recycling in the TECI; and
                    Section 6.5: Wastewater characterization data collected during EPA's
                    sampling program.
              Sections 6.1, 6.2, and 6.3 discuss water use and wastewater generation, sources of
wastewater, and wastewater discharge practices at only the estimated total TECI population of
692 discharging facilities.  Section 6.4 includes water reuse and recycling information on the
discharging facilities as well as the zero discharge facilities.

              Some data summaries included in this section are presented by industry
subcategory. To simplify data analyses by subcategory, EPA assigned facilities with production
in multiple subcategories to a single, predominant subcategory. Therefore, for these facilities,
                                           6-1
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                                                      Section 6.0 - Water Use and Wastewater Characterization
facility characteristics for all facility operations are attributed to the single predominant
subcategory.
6.1
Water Use and Wastewater Generation
              This section describes water use and wastewater generation practices of
discharging facilities which, by definition, use water or water-based cleaning solutions to clean
or rinse tank interiors. The amount of water required and wastewater generated to clean each
tank depends upon the cleaning process, as well as the tank type, tank size, and commodity last
transported. In addition, the TECI uses water and generates wastewater during other processes
related to TEC operations.  The most significant uses of water associated with TEC operations
include:

              •       Tank interior prerinse, prior to cleaning;
              •       Tank interior cleaning hot or cold water washes and/or rinses;
              •       Tank exterior washing;
              •       Boiler feed water for conversion to steam for steam cleaning, for heating
                     cleaning solutions, or heating or drying tank interiors; and
              •       Formulation of cleaning solutions.

              Following removal of the transported commodity from the tank, a residue or heel
remains, which is generally removed prior to tank cleaning. During or after heel removal, TEC
facilities may perform a rinse prior to commencing cleaning consisting of a short burst of water
applied to the tank interior to remove additional heel that adheres to the tank's interior.  Purposes
of the prerinse include (1) enhancing heel removal; (2) minimizing the amount of heel ultimately
contained in tank cleaning wastewater (pollution prevention); (3) extending the service life of
tank cleaning solutions by reducing solution contamination from tank heel; and (4) protecting the
wastewater treatment system, which may not be acclimated or designed to treat residual heel.
                                           6-2
-------
                                                     Section 6.0 - Water Use and Wastewater Characterization
Prerinse wastewater is typically segregated rather than commingled with subsequent TEC
wastewater.

              TEC facilities perform hot or cold water washes and rinses to clean tank interiors.
Water-soluble cargos and many food grade cargos are typically cleaned using only hot or cold
water washes without chemical cleaning solutions. Virtually all cleaning sequences include a
final water rinse to remove cleaning solution residue, particularly when recirculated cleaning
solutions or water are used during the cleaning process. Steam cleaning is also performed,
particularly by rail tank car cleaning facilities. Tank interior cleaning is typically the largest use
of water at TEC facilities.

              Large volumes of water are typically used to clean tank exteriors, particularly at
tank truck cleaning facilities where appearance is important due to the high visibility on U.S.
roadways.  Soaps and hydrofluoric acid-based aluminum brighteners may also be used in this
process.  On-site boilers may use significant volumes of water both as a feed stream and for
maintenance, such as during boiler blowdown. Finally, since cleaning solutions are often
received in concentrated form, water is used to formulate the cleaning solutions to appropriate
concentrations. Water is also used to "make up" cleaning solutions, due to loss by evaporation
and solution carry-over into subsequent tank rinse wastewater.

              Table 6-1 summarizes the total annual volume of wastewater generated by the
TECI. Since many facilities perform both TEC and non-TEC operations, this table includes the
amount of wastewater generated by TEC operations (total TEC wastewater) and the total amount
of wastewater reported to be generated by the TECI (total TEC and non-TEC wastewater).
Approximately 5.5 billion gallons of wastewater (both TEC and non-TEC wastewater) is
generated annually by the TECI.  The Truck/Food Subcategory accounts for 70% of this volume,
due to the large number of tanks cleaned, relatively greater use of exterior cleaning as part of the
routine tank cleaning procedures, and wastewater generated by food processing operations at
many Truck/Food facilities. The Truck/Chemical Subcategory, having the next largest volume,
                                           6-3
-------
                                                     Section 6.0 - Water Use and Wastewater Characterization
accounts for 17% of all wastewater generated by the TECI, while 13% of the total volume of
wastewater generated is divided among the remaining nine subcategories.

              Approximately 1.3 billion gallons of wastewater from interior cleaning operations
is generated annually, as shown in Table 6-1. The Truck/Chemical Subcategory accounts for
56% of the total TEC wastewater volume, while the Truck/Food subcategory accounts for 19%
of the total TEC wastewater volume. These percentages differ significantly from those based on
wastewater generation volume. These differences indicate that the Truck/Chemical Subcategory
generates the majority of its wastewater from cleaning the interiors of tanks, while the
Truck/Food subcategory generates the majority of its wastewater from cleaning tank exteriors
and other processes.

              Table 6-2 provides  a more detailed analysis of the average volume of TEC
wastewater generated per tank cleaning by commodity type and tank type. Truck tank, rail tank,
tank barge, truck hopper, rail hopper, barge hopper, intermediate bulk container (IBC), and
intermodal tank container (ETC) are the eight major tank types listed. In general, the tank
capacity decreases in the following order by tank type:  tank barge, barge hopper, rail tank, rail
hopper, truck tank, truck hopper, JTC, and BBC. This decrease in tank size corresponds to a
decrease in the amount of wastewater generated per tank cleaning. The volume of wastewater
generated per tank cleaning for tank trucks is relatively  similar for all commodity groups except
for the Latex, Rubber, and Resins  Group, the Chemical Products Group, and the Hazardous .
Waste Group. Facility personnel at facilities visited during engineering site visits  and sampling
episodes indicated that resins are the most difficult commodity to clean.  Chemical products such
as water treatment chemicals were also identified as difficult commodities to clean by facility
personnel.
 6.2
Sources of Wastewater
              EPA has identified the following operations as primary sources of wastewater
 within the TECI:
                                           6-4
-------
                                                     Section 6.0 - Water Use and Wastewater Characterization
              •      Tank interior cleaning;
              •      Tank exterior cleaning;
              •      Boiler blowdown;
              •      Tank hydrotesting;
              •      Safety equipment cleaning; and
              •      TEC-contaminated stormwater.

              Tank interior cleaning wastewater includes water and steam condensate generated
by tank cleaning operations, prerinse solutions, chemical cleaning solutions, and final rinse
solutions. Tank exterior cleaning wastewater includes water and cleaning solutions generated by
tank exterior cleaning operations. Boiler blowdown is wastewater generated during maintenance
of on-site boilers used to heat tank cleaning solutions and rinses and to generate steam.  Tank
hydrotesting (i.e., hydrostatic pressure testing) is performed by completely filling the tank with
water and applying a pressure of at least 150% of the maximum allowable working pressure.
The water is then typically discharged as a waste stream. Wastewater is also generated by
cleaning safety equipment.  TEC-contaminated stormwater is commonly generated when rain
water blows or runs into the tank cleaning bay (most cleaning bays are enclosed or covered). In
addition, many wastewater treatment systems are not enclosed or covered resulting in generation
of TEC-contaminated stormwater from these areas.

              Additional wastewater sources reported in responses to the Detailed Questionnaire
include air pollution control devices, maintenance and repair operations, laboratory wastewater,
TEC noncontact cooling water, and flare condensate; however, these sources were reported by
relatively few facilities and were generated in relatively small volumes.

              Some facilities generate large volumes of non-TEC wastewater from food
processing or other manufacturing operations and from non-TEC process equipment cleaning.
Other facilities accept wastewater for treatment on site such as TEC wastewater from other
facilities or  marine wastewater (e.g., bilge and ballast water). In these cases, non-TEC
wastewater may comprise 50% or more of the total volume of wastewater generated.
                                           6-5
-------
                                                     Section 6.0 - Water Use and Wastewater Characterization
              Table 6-3 summarizes the average volume of wastewater generated per day for the
six wastewater streams listed above. Average wastewater generation volumes were calculated
based on data from all the facilities within a specific subcategory. If a facility did not report:
generating a wastestream, then that facility was assumed to generate zero gallons per day of that
wastestream.

              Tank interior cleaning wastewater comprises the largest wastewater stream
generated by facilities in eight of the eleven subcategories (data for some facilities is not shown
to protect data confidentiality). For the remaining three subcategories (Rail/Chemical,
Truck/Petroleum, and Rail/Food), either tank hydrotesting wastewater or tank exterior cleaning
wastewater comprise the largest wastewater stream.

              Table 6-4 presents the total volume of wastewater generated per day by
wastewater stream type and subcategory. This value is obtained by multiplying the average
volume of wastewater generated per facility per day (Table 6-3) by the total number of facilities
within each respective subcategory. The Truck/Chemical and Truck/Food Subcategories
generate the largest volumes of interior wastewater and exterior wastewater because the largest
number of tanks are cleaned by facilities in these subcategories.

              Although Barge/Hopper and Barge/Chemical & Petroleum facilities generate the
largest volume of TEC interior cleaning wastewater per facility as shown in Table 6-3, the total
volume of wastewater generated by these two subcategories is significantly less man that
generated by the Truck/Chemical and Truck/Food subcategories. Although barge cleaning
generates significantly more wastewater per tank cleaning than truck cleaning, the total number
of tank trucks  cleaned is much greater than the total number of tank barges cleaned.
6.3
Wastewater Discharge Practices
              EPA estimates that 692 facilities discharge TEC wastewater either directly or
indirectly. Table 6-5 summarizes the TECI discharge status by subcategory. Approximately
                                           6-6
-------
                                                     Section 6.0 - Water Use and Wastewater Characterization
97% of the discharging facilities discharge wastewater indirectly, while only 3% discharge
wastewater directly. However, the majority of barge (tank and closed-top hopper) facilities
(77%) discharge directly to U.S. surface waters because these facilities are usually located on
major waterways. EPA has identified direct discharging facilities in subcategories in addition to
those shown in Table 6-5 (see Section 10.1.2); however, EPA has not identified any direct
discharging facilities in the following five subcategories:  Truck/Petroleum, Rail/Petroleum,
Rail/Food, Truck/Hopper, and Rail/Hopper.

              Table 6-6 summarizes the total annual volume of wastewater discharged by the
TECI. Approximately 2.2 billion gallons of wastewater is discharged annually by TEC facilities.
This volume includes  all wastewater sources such as TEC and non-TEC wastewaters, but
excludes wastewaters  that are not commingled with TEC wastewater such as sanitary .wastewater
and noncontaminated  stormwater. The Truck/Food Subcategory accounts for 41% of this
volume, due to the large number of tanks cleaned, relatively greater use of exterior cleaning as
part of the routine tank cleaning operations, and wastewater generated by food processing
operations at many Truck/Food Subcategory facilities. The Truck/Chemical Subcategory, having
the next largest volume, accounts for 39% of all wastewater generated by the TECI, while 20%
of the total volume of wastewater generated is divided among the remaining nine subcategories.

              EPA estimates that 547 facilities generate TEC wastewater but do not discharge
wastewater directly to surface waters or indirectly to POTWs.   The majority of these facilities
achieve zero discharge of TEC wastewater by hauling the wastewater to a treatment, storage, and
disposal facility (TSDF), ballast water treatment facility, privately owned treatment works, or
centralized waste treatment (CWT) facility, or disposing of the wastewater by land application,
land disposal, or evaporation. An estimated 44 TEC facilities achieve zero discharge of TEC
wastewater by recycling or reusing 100% of TEC wastewater.
                                           6-7
-------
                                                     Section 6.0 - Water Use and Wastewater Characterization
6.4
Water Reuse and Recycling
              Water reuse and recycle activities commonly performed by discharging and zero
discharge facilities include:

              •       Recirculation of cleaning solutions, including chemical cleaning solutions
                     and water washes;
              •       Reuse of final rinse wastewater as initial rinse water; and
              •       Reuse of treated TEC wastewater as source water for TEC operations.

Other water reuse and recycle activities reported in responses to the Detailed Questionnaire
include:

              •       Reuse of hydrotest wastewater as source water for TEC operations;
              •       Use of TEC contaminated stormwater as source water for TEC operations;
                     and
              •       Reuse of final tank rinse wastewater as cleaning solution "make-up" water.

Additional information concerning water conservation and water recycle and reuse technologies'
applicable to the TECI is included in Section 8.2.

              Approximately 10% of facilities, including discharging and zero discharging
facilities, reuse all or part of treated TEC wastewater as source water for TEC operations. The
majority of these facilities are zero discharging facilities, as shown in Table 6-7. The
subcategory with the highest percentage of facilities that reuse wastewater in TEC operations is
the Truck/Petroleum Subcategory. For this subcategory,  52 zero dischargers out of the total 104
facilities reuse TEC wastewater as source water for TEC operations.
                                            6-8
-------
                                                      Section 6.0 - Water Use and Wastewater Characterization
              Wastewater streams that are recycled or reused for TEC operations include tank
interior cleaning wastewater and hydrotesting wastewater. Hydrotesting wastewater is typically
clean and does not require extensive treatment prior to recycle or reuse. Tank interior cleaning
wastewater generated by facilities in the Truck/Petroleum or Rail/Petroleum Subcategories can
typically be reused for cleaning after treatment by simple oil/water separation. Tank interior
cleaning wastewater generated by facilities in the chemical subcategories generally requires more
extensive treatment prior to reuse as source water in TEC operations. Accordingly, few facilities
in the chemical subcategories reuse treated TEC wastewater as source water for TEC operations.
Finally, sanitation requirements at many food grade facilities precludes reuse of TEC wastewater
as source water for TEC operations at these facilities.

              The Agency analyzed wastewater generation, treatment, and discharge diagrams
submitted in response to the Detailed Questionnaire to evaluate typical TEC wastewater
management practices and common wastewater recycle and reuse practices. Figure 6-1
illustrates common wastewater management practices. The figure shows wastewater recycling
that was reported to be performed by one or more facilities within the Detailed Questionnaire
sample population.  Review of the  water flow diagrams submitted by facilities in responses to the
Detailed Questionnaire resulted in the following observations:
                     Facilities that recycle one wastewater stream type do not necessarily
                     recycle additional wastewater stream types;
                     Facilities that recycle wastewater streams generally segregate these
                     streams for treatment and recycle; and
                     Wastewater stream recycle and reuse activities performed are dependent
                     upon the type of cargo cleaned.
6.5
Wastewater Characterization
              As discussed in Section 3.4, EPA conducted 20 sampling episodes at 18 facilities
 representative of the variety of facilities in the TECI (2 facilities were sampled twice). As part of

                                            6-9
-------
                                                     Section 6.0 - Water Use and Wastewater Characterization
this sampling program, EPA routinely analyzed wastewater samples for conventional, priority,
and nonconventional pollutants. Subsequent to sampling, wastewater characterization data from
four facilities were determined to not represent TEC wastewater, either because the facility was
covered by another effluent guideline or because the sampled waste stream was determined to not
represent TEC wastewater. Tables 6-8 through 6-15 present available wastewater
characterization data by TECI subcategory as follows:

              •      Truck/Chemical Subcategory (Table 6-8);
                    Rail/Chemical Subcategory (Table 6-9);
              •      Barge/Chemical & Petroleum Subcategory (Table 6-10);
                    Truck/Food Subcategory (Table 6-11);
                    Rail/Food Subcategory (Table 6-12);
              •      Barge/Food Subcategory (Table 6-13);
              •      Truck/Petroleum Subcategory (Table 6-14); and
              •      Barge/Hopper Subcategory (Table 6-15).

              Raw wastewater characterization data for the Truck/Hopper, Rail/Hopper, and
Rail/Petroleum Subcategories were not collected  during EPA's sampling program. EPA believes
that characterization data from the Barge/Hopper Subcategory represent the Truck/Hopper and
Rail/Hopper Subcategories since facilities in these subcategories clean similar pargos; however,
the volume of TEC wastewater generated during tank cleaning differs significantly among these
three subcategories. EPA believes that characterization data from the Truck/Petroleum
Subcategory represent the Rail/Petroleum Subcategory since facilities in these subcategories also
clean similar cargos.

              Tables 6-8 through 6-15 also present a statistical summary of the raw wastewater
characterization data, including the mean, minimum, and maximum concentration values for
each pollutant or parameter detected at least once in any raw wastewater characterization sample.
For samples in which individual pollutants were not detected, the sample detection limit was
used in calculating the mean concentration. The methodology used to calculate the mean
concentration involved first calculating a mean concentration for each facility characterized and
then calculating a subcategory mean concentration using applicable mean facility concentrations.
                                          6-10
-------
                                                     Section 6.0 - Water Use and Wastewater Characterization
In addition, for those samples in which individual pollutants were not detected, the sample
detection limit is reported as the minimum concentration. Also listed in these tables are the
number of times each pollutant or parameter was analyzed and detected in raw wastewater
samples.

              The summaries shown in Table 6-16 are derived from Tables 6-8 through 6-15.
As expected, the chemical subcategories have the highest number of priority pollutants detected.
In addition, the range of concentrations for the classical pollutants is highest for the
Barge/Chemical & Petroleum and Truck/Chemical Subcategories.
                                           6-11
-------
                                               Section 6.0 - Water Use and Wastewater Characterization
                                  Table 6-1

Estimates of Total Annual Volume of Wastewater Generated by Subcategory
                        - Discharging Facilities Only
Subcategory
Thick/Chemical
Rail/Chemical
Barge/Chemical & Petroleum
TruckflPetroleum
RauVPetroleum
Truck/Food
Rail/Food
Barge/Food
Truck/Hopper
Rail/Hopper
Barge/Hopper
TOTAL (a)
Total Wastewater Generated
Amount
(gal/yr)
929,000,000
262,000,000
194,000,000
35,400,000
2,800
3,850,000,000
88,200,000
21,700
23,900,000
208,000
112,000,000
5,490,000,000
Percentage
of Industry Total
"(%)
' 17
5
4
<1
«1
70
2
<<1
<1
«1
2
100
Wastewater Generated from Interior
Cleaning Operations
Amount •
(gal/yr),
716,000,000
91,900,000
94,100,000
2,500,000
2,830
245,000,000
6,920,000
21,700
14,300,000
17,500
103,000,000
1,270,000,000
Percentage of
Industry Total
' (%) ,,
56
7
7
<1
«1
19
<1
«1
1
«1
8
100
(a) Differences occur due to rounding.
                                     6-12
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                                            6-15
-------
                                                      Section 6.0 - Water Use and Wastewater Characterization
                                        Table 6-5
                          Discharge Status by Subcategory
Subcategory
Truck/Chemical
Rail/Chemical
Barge/Chemical & Petroleum
Truck/Petroleum
Rail/Petroleum
Track/Food
Rail/Food
Barge/Food
Truck/Hopper
Rail/Hopper
Barge/Hopper
TOTAL (a)
, Indirect Discharge
Number of -
Facilities
288
38
1
34
3
173
86
2
34
5
3
669
Percentage of
industry Total
<%)
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6
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13
<1
5
1
<1
100
Direct Discharge
Number of
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0
0
14
0
0
0
0
0
0
0
9
23
Percentage of
.IhdustryTotal'
(*>
0
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61
0
0
0
0
0
0
0
39
100
(a) Differences occur due to rounding.
                                            6-16
-------
                                                Section 6.0 - Water Use and Wastewater Characterization
                                   Table 6-6
        Estimates of Total Annual Volume of Wastewater Discharged
                    By Subcategory and Discharge Status
Subcategory,
Track/Chemical
Rail/Chemical
Barge/Chemical &
Petroleum
Barge/Chemical &
Petroleum
Truck/Petroleum
Rail/Petroleum
Truck/Food
Rail/Food
Barge/Food
Truck/Hopper
Rail/Hopper
Barge/Hopper
Barge/Hopper
Discharge?
Status .
Indkect
Indirect
Dkect
Indirect
Indkect
Indirect
Indirect
Indirect
Indkect
Indkect
Indkect
Dkect
Indkect
TOTAL (a)
T&al3nferior Cleaning;
^asfesjjaterJDischarged „ -
v*
Amount
'(gal/yr>
708,000,000
91,300,000
30,300,000
28,100,000
2,500,000
2,830
243,000,000
19,500,000
21,700
14,300,000
17,400
100,000,000
2,610,000
1,240,000,000
^Percentage '
of Industry',
"Total (&) "
57
7
2
2
<1
«1
20
2
«1
1
«1
8
<1
100
;;\ '^<>^Cott^nnglea':':;,|
Wastewater Discharged "*
Amount ";
," tgal/yr) <\
845,000,000
130,000,000
42,800,000
28,700,000
3,100,000
2,830
889,000,000
131,000,000
21,700
19,500,000
80,200
100,000,000
2,610,000
2,190,000,000
^ercebtage 5
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39
6
2
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(a) Differences occur due to rounding.
                                      6-17
-------
                                            Section 6.0 - Water Use and Wastewater Charactsrization
                               Table 6-7

Number of Facilities That Reuse All or Part of TEC Wastewater as Source
                       Water for TEC Operations
Subcategory
Truck/Chemical
Rail/Chemical
Barge/Chemical & Petroleum
Truck/Petroleum
RaiMPetroleum
IVuck/Food
Raiiypood
Barge/Food
Thick/Hopper
RaiMHopper
Barge/Hopper
Number of Facilities that Reuse TEC
Wastewater
Discharging Facilities
14
1
3
0
0
0
0
0
5
0
0
Zero Discharge
Facilities
33
15
1
52
1
0
0
0
0
0
0
s>Tofal Number of 1
Discharging and ;^ero
Discharge Facilities
556
67
31
104
4
318
86
2
39
5
14
                                   6-18
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                                                     Section 6.0 - Water Use and Wastewater Characterization
                                      Table 6-16
      Summaries of the Raw Wastewater Characterization Data for Each
                                     Subcategory
Subcategory
Truck/Chemical
Rail/Chemical
Barge/Chemical & Petroleum
Truck/Petroleum
Truck/Food
Rail/Food
Barge/Food
Barge/Hopper
Number of Priority Pollutants
Detected
55
43
45
10
7
4
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9
Number of Pollutants Detected
204
180
159
67
76
45
68
57
Subcategory
Truck/Chemical
Rail/Chemical
Barge/Chemical
& Petroleum
Truck/Petroleum
Truclt/Food
Rail/Food '
Barge/Food
Barge/Hopper
Range of Pollutant Concentrations (mg/L) - " .", J"v *
BOD^
320 to 6,000
260 to 4,200
120 to 26,000
48 to 110
160 to 5,200
NQ
890 to 6,800
17
COB
830 to 16,000
810 to 20,000
130 to 200,000
580 to 740
380 to 5,600
34,000
540 to 12,000
640
TOC ,
160 to 3,200
150 to 3,300
30 to 53,000
28 to 210
86 to 2,500
13,000
1,600 to
3,300
61
\TSS s
38 to 4,800
230 to 1,400
55 to 15,000
130 to 360
28 to 800
27
260 to 2,000
1,400
HEM
6.0 to 5,300
56 to 5,200
37 to 220,000
22 to 1,200
5.2 to 270
ND
75 to 1,100
ND
S&ErHEMk
5.0 to 450
18 to 750
21 to 98,000
5.0 to 410
5.0 to 26
ND
5.0 to 140
ND
ND-Not detected.
NQ - Not quantitated due to matrix interference.
BOD5- Biochemical oxygen demand (5-day).
COD - Chemical oxygen demand.
TOC - Total organic carbon.
TSS - Total suspended solids.
HEM - Hexane extractable material.
SGT-HEM - Silica-gel treated hexane extractable material.
                                          6-64
-------
                                       Section 6.0 - Water Use and Wastewater Characterization
                                  Key:
                                        -Primary Path
                                  	Secondary Path
                                        Recycle & Reuse Stream
Solution
Make-Up
ir
Source
Water
A L
Fresh
Water




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1 	 *•
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A

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Land Application
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Incineration
Figure 6-1. Water Use Diagram for TEC Operations
                           6-65
-------
-------
7.0
                                              Section 7.0 - Pollutants Selected for Regulation
POLLUTANTS SELECTED FOR REGULATION
              EPA conducted a study of Transportation Equipment Cleaning Industry (TECI)
wastewaters to determine the presence or absence of priority, conventional, and nonconventional
pollutant parameters.  Priority pollutants parameters are defined in Section 307(a)(l) of the Clean
Water Act (CWA). The list of priority pollutant parameters, presented in Table 7-1, consists of
126 specific priority pollutants listed in 40 CFR Part 423, Appendix A.  Section 301(b)(2) of the
CWA obligates EPA to regulate priority pollutants if they are determined to be present at
significant concentrations and it is technically and economically feasible. Section 304(a)(4) of
the CWA defines conventional pollutant parameters, which include biochemical oxygen demand
(BOD5), total suspended solids (TSS), total recoverable oil and grease (now referred to as hexane
extractable material or HEM), pH, and fecal coliform.  These pollutant parameters are subject to
regulation as specified in Sections 304(b)(l)(A), 304(a)(4), 301(b)(2)(E), and 306 of the CWA.
Nonconventional pollutant parameters are those that are neither priority nor conventional
pollutant parameters.  Sections 301(b)(2)(F) and 301(g) of the CWA give EPA the authority to
regulate nonconventional pollutant parameters, as appropriate, based on technical and economic
considerations.

              This section presents the methodology used to select pollutants for regulation for
the TECI and includes the following topics:

              •      Section 7.1:  The pollutants considered for regulation in the TECI;
              •      Section 7.2:  The pollutants of interest for the TECI;
              •      Section 7.3:  The pollutants effectively removed by EPA's regulatory
                     options;
              •      Section 7.4:  Pollutant selection criteria for regulation for direct
                     dischargers;
              •      Section 7.5:  Pollutant selection criteria for regulation for indirect
                     dischargers; and
                                            7-1
-------
                                                            Section 7.0 - Pollutants Selected for Regulation
                     Section 7.6: References.
7.1
Pollutants Considered for Regulation
              The Agency considered 4 conventional, 125 priority, and 348 nonconventional
pollutant parameters for potential regulation in the TECI.  The nonconventional pollutants
include organics, metals, pesticides, herbicides, dioxins, and furans that do not appear on the list
of conventional or priority pollutants. The Agency analyzed TECI wastewater for these
pollutants during EPA's sampling program, which is discussed in Section 3.4.
7.2
Pollutants of Interest for the TECI
              The first step in considering a pollutant for regulation was to determine if it is a
pollutant of interest for the TECI on a subcategory-by-subcategory basis. Pollutants of interest
were identified based on the raw transportation equipment cleaning (TEC) wastewater
characterization data (presented in Section 6.0). EPA considered the following two general
criteria to identify pollutants of interest:
              1.     The frequency of detection in subcategory wastewater characterization
                     samples; and
              2.     The average raw wastewater concentration at those facilities sampled for
                     treatment performance.
              The first criterion indicates that the presence of the pollutant is representative of
the subcategory, rather than an isolated occurrence.  The second criterion ensures that the
pollutant was present at treatable levels where EPA evaluated treatment performance.
Application of these two general criteria are described in Sections 7.2.1 through 7.2.4.
              If wastewater characterization samples were collected at two or more facilities
 within a subcategory, EPA considered pollutants detected at least two times in wastewater

                                            7-2
-------
                                                             Section 7.0 - Pollutants Selected for Regulation
characterization samples as pollutants of interest for that subcategory. If wastewater
characterization samples were collected at only one facility within a subcategory, then only one
detect was required for consideration as a pollutant of interest. Where EPA sampling data shows
that a pollutant concentration is below the detection limit at all sampled facilities within a
subcategory, that pollutant is excluded from consideration as a pollutant of interest in that
subcategory.

              EPA considered an average pollutant concentration of at least five times the
pollutant method detection limit to be a treatable level. To determine the average pollutant
concentration within each subcategory, EPA averaged both the detected and the nondetected
concentrations  (nondetected concentrations were assumed to be equal to the pollutant detection
limit). For subcategories with treatment performance data from more than one facility, pollutants
present at treatable levels in the wastewater of at least one facility were considered pollutants of
interest for that subcategory.

              EPA used a different approach for pesticide and herbicide pollutants because of
the relative toxicity of these pollutants.  EPA considered a single detection of the pollutant in
wastewater characterization samples, regardless of the number of facilities sampled, sufficient to
consider the pollutant as a pollutant of interest. Also, the average raw wastewater concentration
at those facilities sampled for treatment performance only had to be greater than the method
detection limit for consideration as  a pollutant of interest.
7.2.1
Truck/Chemical, Rail/Chemical, and Barge/Chemical &
Petroleum Subcategories
              Wastewater characterization samples were analyzed for all 477 pollutants
considered for regulation. The same selection criteria were applied separately to the analytical
data available for the Truck/Chemical, Rail/Chemical, and Barge/Chemical & Petroleum
Subcategories to identify pollutants of interest. These include:
                                            7-3
-------
                                                             Section 7.0 - Pollutants Selected for Regulation
                     For non-pesticide/herbicide pollutants, the pollutant was detected in at
                     least two TEC wastewater characterization samples.
                     For pesticide/herbicide pollutants, the pollutant was detected in at least
                     one TEC wastewater characterization sample.
                     For non-pesticide/herbicide pollutants, the average raw wastewater
                     concentration was at least five times the method detection limit.
                     For pesticide/herbicide pollutants, the average raw wastewater
                     concentration was greater than the method detection limit.
7.2.2
Truck/Food, Rail/Food, and Barge/Food Subcategories
              Wastewater characterization samples were analyzed for all 477 pollutants
considered for regulation. Available characterization data for food grade facilities include five
days of sampling at a Barge/Food Subcategory facility, one day of sampling at a Truck/Food
Subcategory facility, and one day of sampling at a Rail/Food Subcategory facility.

              EPA used wastewater treatment system performance data collected at one
Barge/Food facility to represent all three food grade subcategories. Samples collected at this one
facility were only analyzed for 190 pollutants including all 176 semi volatile organics and 14
classical pollutants. Volatile organics, pesticides, herbicides, dioxins, furans, metals, and six
classical pollutants (adsorbable organic halides, total cyanide, amenable cyanide, surfactants,
total sulfide, and volatile residue) were not analyzed because these analytes were not detected at
significant levels in wastewater characterization samples. The following selection criteria were
applied to identify pollutants of interest for the food grade subcategories. These include:
                     The pollutant was detected in at least one TEC wastewater characterization
                     sample; and
                     The average raw wastewater concentration was at least five times the
                     method detection limit.
                                            7-4
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7.2.3
                                               Section 7.0 - Pollutants Selected for Regulation
Truck/Petroleum and Rail/Petroleum Subcategories
              In its analysis of facilities that cleaned tanks that last transported petroleum
cargos, EPA sampled one facility in the Truck/Petroleum Subcategory. Samples collected during
this sampling episode were analyzed for 318 pollutants including all 57 volatile organics, 176
semivolatile organics, 70 metals, and 15 of the 20 classical pollutants.  Pesticides, herbicides,
dioxins, and furans were not analyzed because they were not expected to be present at significant
levels in wastewater characterization samples based on an  engineering assessment of the cargos
cleaned and the cleaning processes used at these facilities.  Five classical pollutants (adsorbable
organic halides, surfactants, total phenols, total sulfide, and volatile residue) were not analyzed
in this subcategory.

              This one facility sampled in the Truck/Petroleum Subcategory treated only final
rinse wastewater on site. Initial rinses and other TEC wastewaters were contract hauled for off-
site treatment and were therefore not included in the sampling performed by EPA. There was no
additional data provided by the industry on raw TEC wastewater characteristics; therefore,
sampling data obtained from the Centralized Waste Treatment (CWT) Industry were also used to
characterize TEC wastewater for the Truck/Petroleum and Rail/Petroleum Subcategories (see
Section 3.5.1 for a discussion of the CWT data).

               The only criterion used to identify pollutants of interest for the Truck/Petroleum
and Rail/Petroleum Subcategories was that the pollutant was detected at least once in samples of
the influent to wastewater treatment at either the TEC facility or the CWT facility.  The second
criterion, developed to ensure that the pollutant was present at treatable levels, was not applicable
because EPA primarily considered zero discharge options  for these Subcategories based on 100
percent recycle/reuse of TEC wastewater.
                                            7-5
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7.2.4
                                              Section 7.0 - Pollutants Selected for Regulation
Truck/Hopper, Rail/Hopper, and Barge/Hopper Subcategories
              The Agency used the sampling data collected at one Barge/Hopper facility to
represent all three hopper subcategories. Samples collected during this sampling episode were
analyzed for 453 pollutants, 24 fewer than the usual 477 pollutants. These 24 pollutants include
the 17 dioxins and furans, 5 classical wet chemistry parameters (adsorbable organic halides,
surfactants, total phenols, total sulfide, and volatile residue), and 2 volatile organics (m-xylene
and o- + p-xylene).  With the exception of the xylenes, these pollutants were not analyzed
because they were not expected to be present in TEC wastewater based on an assessment of the
cargos cleaned and the cleaning processes used by facilities in these subcategories. M-xylene
and o- + p-xylene were not analyzed because the laboratory inadvertently analyzed for m- + p-
xylene and o-xylene instead, which were not detected. The same selection criteria were applied
to the Truck/Hopper, Rail/Hopper, and Barge/Hopper Subcategories to identify pollutants of
interest. These include:
                     The pollutant was detected in the single TEC wastewater characterization
                     sample;
                     For non-pesticide/herbicide pollutants, the average raw wastewater
                     concentration was at least five times the method detection limit; and
                     For pesticide/herbicide pollutants, the average raw wastewater
                     concentration was greater than the method detection limit.
7.3
Pollutants Effectively Removed
              The second step in considering a pollutant for regulation was to determine if a
pollutant of interest was effectively removed by one or more of the wastewater treatment
technology options evaluated for each subcategory and discharge type (i.e., indirect and direct).
(The options considered for each subcategory are discussed in Section 9.0).  This criterion
ensures that EPA does not select for regulation pollutants that are not removed or controlled by
the technology options considered by the Agency. In developing the technology options, EPA

                                            7-6
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                                                            Section 7.0 - Pollutants Selected for Regulation
attempted to identify pollutant control technologies or combinations of pollutant control
technologies that control all of the pollutants of interest for each subcategory.

              EPA determined if a pollutants was effectively removed by analyzing the percent
reduction achieved by the technology option. This criterion ensures that the pollutant was
demonstrated to be controlled by the technology option. The criterion was applied to the base
technology option and to each incremental technology option individually.  For example, EPA's
criterion for hypothetical pollutant X for indirect dischargers for Subcategory Y was at least a
50% reduction in the pollutant concentration. Technology A removed the pollutant X by 20%.
Technology B removed the pollutant X by 30%, and Technology C removed the pollutant X by
80%. Pollutant X is effectively removed for Subcategory Y indirect dischargers because it was
removed by at least 50% by Technology C. Specifically, pollutant X is a pollutant effectively
removed only for the regulatory options that include Technology C.

              EPA used a different approach, however, for pesticide and herbicide pollutants
because of the relative toxicity of these pollutants.  EPA considered pollutants with percent
reductions greater than zero to be pollutants effectively removed. These pollutants were often
detected at concentrations close to their sample detection limits and were commonly treated to
nondetectable levels by pollutant control technologies. Because of analytical limitations, it is
difficult to determine the actual percent reduction of these pollutants. However, EPA considered
a reduction from levels  above the detection limit in the untreated wastewater to nondetect levels
in treated effluent to represent treatment of these pollutants.

              EPA considered the following two criteria to identify pollutants effectively
removed for all subcategories except for the Truck/Petroleum and Rail/Petroleum Subcategories:
                     For non-pesticide/herbicide pollutants, the average pollutant concentration
                     was at least five times the method detection limit in the influent to the
                     proposed technology option.
                                            7-7
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                                                            Section 7.0 - Pollutants Selected for Regulation
                     For pesticide/herbicide pollutants, the average pollutant concentration was
                     greater than the method detection limit in the influent to the proposed
                     technology option.
                     For non-pesticide/herbicide pollutants, the pollutant was reduced by at
                     least 50% by the proposed technology option.
                     For pesticide/herbicide pollutants, the pollutant was reduced by greater
                     than 0% by the proposed technology option.
Note that EPA did not analyze for dioxins and furans in treated wastewater samples at facilities
sampled to assess wastewater treatment performance. Although EPA believes that these
pollutants may be removed by the control technologies (based on nondetect levels measured in
limited final effluent wastewater characterization samples), the Agency did not consider these
data to be sufficient to consider dioxins and furans as pollutants effectively removed.

              EPA believes that concentrations of dioxins and furans above the detection limit
in untreated wastewater samples were isolated, site-specific instances, and that dioxins and
furans typically are not present in concentrations above the detection limit in TEC wastewaters.
Where dioxins and furans are present, EPA has concluded that these pollutants are either
predominantly partitioned in the oil phase of the wastewater or are associated with the suspended
solids, and therefore will be detected at only trace levels, if at all, in TEC wastewater.

              Tables 7-2 through 7-6 present the pollutants effectively removed by the proposed
technology option by subcategory and discharge type as follows:
                     Table 7-2:  Pollutants Effectively Removed for Truck/Chemical
                     Subcategory Direct Dischargers;
                     Table 7-3:  Pollutants Effectively Removed for Rail/Chemical
                     Subcategory Direct Dischargers;
                     Table 7-4:  Pollutants Effectively Removed for Rail/Chemical
                     Subcategory Direct Dischargers (NSPS);
                                            7-8
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                                                            Section 7.0 - Pollutants Selected for Regulation
                     Table 7-5: Pollutants Effectively Removed for Barge/Chemical &
                     Petroleum Subcategory Direct Dischargers; and
                     Table 7-6: Pollutants Effectively Removed for Truck/Food, Rail/Food,
                     and Barge/Food Subcategory Direct Dischargers.
              For the Truck/Petroleum and Rail/Petroleum Subcategories, EPA primarily
considered zero discharge options for these subcategories based on 100% recycle/reuse of TEC
wastewater.  Because a zero discharge option eliminates discharge of pollutants (i.e., complete or
100% removal), EPA considered all pollutants of interest for these subcategories to be pollutants
effectively removed.
7.4
Pollutant Selection Criteria for Direct Dischargers
              The pollutants selected for regulation for each Subcategory were chosen from the
list of pollutants effectively removed discussed in Section 7.3 and listed in Tables 7-2,7-3, 7-4,
7-5, and 7-6 at the end of this section. From these lists, EPA selected a subset of pollutants to
establish numerical effluent limitations. Due to the wide range of cargos transported in tanks
cleaned by TEC facilities, and due to the limited amount of data available, it would be very
difficult to establish numerical limitations for all of the pollutants which may be found in TECI
wastewaters. Additionally, monitoring for all pollutants effectively removed is not necessary to
ensure that TECI wastewater pollution is adequately controlled, since many of the pollutants .
originate from similar sources, have similar treatabilities, and are expected to be removed by the
same mechanisms and treated to similar levels.
              Therefore, rather than set effluent limitations for all pollutants detected in EPA's
wastewater characterization and wastewater treatment effectiveness sampling episodes, EPA
attempted to select a group of pollutants that were frequently detected in TECI wastewater and
whose control through a combination of physical and chemical treatment processes would lead to
the control of a wide range of pollutants with similar properties.  Compounds selected for
regulation were selected to be representative of the various groups of compounds found to be

                                           7-9
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                                                           Section 7.0 - Pollutants Selected for Regulation

effectively treated in each of the regulated subcategories.  Specific compounds selected vary for

each of the subcategories, but include compounds from various groups including metals,

conventionals and organics. Organic compounds were selected to be representative of the

various groups of organic compounds detected (hydrocarbons, organohalogens, carboxylic acid

derivatives, phthalic acid esters, etc.). In addition, priority pollutants which were detected at

treatable levels and were demonstrated to be effectively removed were selected for regulation.


             Pollutants determined to be effectively removed were selected for regulation

based on the following criteria:
                     EPA selected pollutants that were detected most frequently in TECI
                     wastewater.  Generally, this meant that a pollutant had to be detected at
                     least four times in wastewater characterization samples for the
                     Truck/Chemical and Barge/Chemical & Petroleum Subcategories, and at
                     least three times in the Rail/Chemical Subcategory.  Priority pollutants
                     which were effectively removed and were present at significant
                     concentrations in wastewaters, but were not detected at the frequencies
                     described above, were also considered for regulation.

                     EPA selected pollutants that were detected at significant concentrations in
                     raw wastewater at those facilities sampled for treatment performance.
                     Generally, the average pollutant concentration in raw wastewater had to be
                     at least 10 times the method detection limit (MDL) to be considered for
                     regulation. Priority pollutants that were effectively removed and that were
                     detected frequently in the industry, but whose average concentration was
                     less than 10 times the MDL, were also considered for regulation.

                     EPA did not select pesticides or herbicides for regulation.

                     EPA did not select chemicals that are used in wastewater treatment
                     operations of the proposed treatment technology option.

                     EPA did not select pollutant parameters that were not considered toxic.
              EPA is not proposing to establish limits for pesticides or herbicides in any
 subcategory for several reasons. First, pesticides were generally found at very low levels in raw
 wastewater.  Second, the treatment technologies sampled and proposed by EPA were found to

                                           7-10
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                                                            Section 7.0 - Pollutants Selected for Regulation
incidentally remove pesticides and herbicides from the wastewater. The proposed treatment
technologies in each subcategory treated most pesticides and herbicides to non-detect levels in
the effluent. Therefore, especially considering the high cost of pesticide/herbicide monitoring,
EPA has determined that it is unnecessary to set nationally-applicable discharge standards for
specific pesticides or herbicides.

              EPA is also not proposing to establish limits for phenol in any subcategory.
Based on the small number of direct dischargers present in the industry, EPA feels that local
permitting authorities can decide whether establishing discharge limitations based on water
quality considerations is appropriate. For indirect dischargers, phenol is readily biodegradable
and is not expected to pass through a publicly-owned treatment works (POTW).

              For direct discharging facilities, EPA is proposing to regulate the conventional
pollutant oil and grease but is not proposing to regulate the nonconyentional pollutant total
petroleum hydrocarbons.  The analysis for oil and grease quantifies the total amount of oil and
grease present in the wastewater, and includes both petroleum based oils and greases as well as
edible oils from vegetables or fish. Total petroleum hydrocarbons, however, quantifies only the
petroleum based fraction.  EPA believes that it is unnecessary to establish effluent limitations for
both oil and grease and total petroleum hydrocarbons because the petroleum component present
in the wastewater is a subset of the total oil and grease measurement. EPA therefore concluded
that establishing effluent limitations for both oil and grease and total petroleum hydrocarbons
would be redundant for direct discharging facilities.

              Based on the methodology described above, EPA feels that it has selected
pollutants for regulation in each subcategory which will provide adequate control for the wide
range of pollutants which may be found in TECI wastewaters. Listed below are the pollutants
selected for regulation in each subcategory. Note that the Agency  has chosen not to regulate
direct dischargers in the Truck/Hopper, Rail/Hopper, Barge/Hopper, Truck/Petroleum, and
Rail/Petroleum Subcategories.
                                           7-11
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7.4.1
                                                            Section 7.0 - Pollutants Selected for Regulation
Pollutants Selected for Regulation for Truck/Chemical Direct
Dischargers
              EPA is proposing to establish BPT, BCT, BAT and NSPS limitations for the
Truck/Chemical Subcategory.  The following pollutants were not selected for regulation because
they are not present at treatable concentrations or are not likely to cause toxic effects: alpha
terpineol, benzene, benzoic acid, benzyl alcohol, chloroform, dimethyl sulfone, n-decane,
-triacontane, o-cresol, p-cresol, p-cymene, trichchloroethene, 2-methylnaphthalene, 2-
chlorophenol, 2-isopropylnaphthalene, boron, copper, mercury, phosphorus, silicon, tin, and
titanium.

              The following pollutants were not selected for regulation because they are
commonly used in the industry as wastewater treatment chemicals: aluminum, iron, and
manganese.

              The following pollutants were not selected for regulation because they are likely
to be volatilized in the treatment system and are therefore not considered to be treated by the
proposed technology: acetone, 1,2-dichloroethane, ethylbenzene, methyl ethyl ketone, methyl
isobutyl ketone, methylene chloride, tetrachloroethene, toluene, 1,1,1-trichloroethane, m-xylene,
o- + p-xylene, and naphthalene.

              The following pollutants were not selected for regulation because they are
controlled through the regulation of other pollutants:  n-docosane, n-eicosane, n-hexacosane, n-
octadecane, n-tetracosane, and n-tetradecane.

              EPA is therefore proposing limitations for BODS  TSS, oil and grease (HEM),
chromium, zinc, COD, bis (2-ethylhexyl) phthalate, di-n-octyl phthalate, n-dodecane, n-
hexadecane, styrene, and 1,2-dichlorobenzene.
                                           7-12
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                                                            Section 7.0 - Pollutants Selected for Regulation
7.4.2
Pollutants Selected for Regulation for Rail/Chemical Direct
Dischargers
              For the Rail/Chemical Subcategory, EPA is proposing to establish BPT, BCT,
BAT and NSPS limitations. The following pollutants were not selected for regulation because
they are not present at treatable concentrations or are not likely to cause toxic effects:  acetone,
benzoic acid, carbazole, dimethyl sulfone, ethylbenzene, o-+p xylene, 1-methylphenanthrene, 2-
methylnapthalene, naphthalene, n-octacosane, styrene, and n-triacontane.

              The following pollutant was not selected for regulation because it are commonly
used in the industry as a wastewater treatment chemical: aluminum.

              The following pollutant was not selected for regulation because it is likely to be
volatilized in the treatment system and are therefore not considered to be treated by the proposed
technology: m-xylene.

              The following pollutants were not selected for regulation because they are
controlled through the regulation of other pollutants: n-docosane, n-eicosane,.n-hexacosane, n-
octadecane, and n-tetracosane.

              EPA is therefore proposing to regulate BOD5  TSS, oil and grease (HEM), COD,
n-dodecane, n-hexadecane, n-tetradecane, anthracene, pyrene, fluoranthene, and phenanthrene.
7.4.3
Pollutants Selected for Regulation for Barge/Chemical &
Petroleum Direct Dischargers
              For the Barge/Chemical & Petroleum Subcategory, EPA is proposing to establish
BPT, BCT, BAT and NSPS limitations.  The following pollutants were not selected for
regulation because they were present only in trace amounts, are not present at treatable
concentrations, or are not likely to cause toxic effects: acenaphthylene, acrylonitrile, anthracene,
                                           7-13
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                                                           Section 7.0 - Pollutants Selected for Regulation
benzole acid, chloroform, methylene chloride, 2,3,-benzofluorene, n-octacosane, mercury,
osmium, ruthenium, silicon and titanium.

              The following pollutants were not selected for regulation because they are
commonly used in the industry as wastewater treatment chemicals: aluminum, iron, magnesium,
and manganese.

              The following pollutants were not selected for regulation because they are likely
to be volatilized in the treatment system and are therefore not considered to be treated by the
proposed technology:  acetone, benzene, ethylbenzene, methyl ethyl ketone, methyl isobutyl
ketone, toluene, m-xylene, o-+p-xylene, acenaphthene, biphenyl, fluorene, naphthalene,
phenanthrene, and styrene.

              The following pollutants were not selected for regulation because they are
controlled through the regulation of other pollutants:  3,6-dimethylphenanthrene, n-hexacosane,
n-hexadecane, 1-methylfluorene, 2-methymaphthalene, and pentamethylbenzene.

              EPA is therefore proposing to regulate BOD5, TSS, oil and grease (HEM), COD,
cadmium, chromium, copper, lead, nickel, zinc, 1-methylphenanthrene, bis (2-ethylhexyl)
phthalate, di-n-octyl phthalate, n-decane, n-docosane, n-dodecane, n-eicosane, n-octadecane, n-
tetracosane, n-tetradecane, p-cymene, and pyrene.
7.4.4
Pollutants Selected for Regulation for Truck/Food, Rail/Food,
and Barge/Food Direct Dischargers
              EPA is proposing to establish BPT, BCT, and NSPS limitations for the
Truck/Food, Rail/Food, and Barge/Food Subcategories for BOD5, TSS, and oil and grease
(HEM).
                                          7-14
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7.5
                                             Section 7.0 - Pollutants Selected for Regulation
Pollutant Selection Criteria for Indirect Dischargers
              Section 307(b) of the CWA requires the Agency to promulgate pretreatment
standards for existing sources (PSES) and new sources (PSNS). To establish pretreatment
standards, EPA must first determine whether each BAT pollutant under consideration passes
through a POTW, or interferes with the POTW's operation or sludge disposal practices.

              The Agency evaluated POTW pass-through for the TEC pollutants of interest for
all subcategories where EPA is proposing to regulate priority and nonconventional pollutants. In
determining whether a pollutant is expected to pass through a POTW, the Agency compared the
nation-wide average percentage of a pollutant removed by well-operated POTWs with secondary
treatment to the percentage of a pollutant removed by BAT treatment systems. A pollutant is
determined to "pass through" a POTW when the average percentage removal achieved by a well-
operated POTW  (i.e. those meeting secondary treatment standards) is less than the percentage
removed by the industry's direct dischargers that are using the proposed BAT technology.

              This approach to the definition of pass-through satisfies two competing objectives
set by Congress:  1) that wastewater treatment performance for indirect dischargers be equivalent
to that for direct  dischargers, and 2) that the treatment capability and performance of the POTW
be recognized and taken into account in regulating the discharge of pollutants from indirect
dischargers. Rather than compare the mass or concentration of pollutants discharged by the
POTW with the mass or concentration of pollutants discharged by a BAT facility, EPA compares
the percentage of the pollutants removed by the BAT treatment system with the POTW removal.
EPA takes this approach because a comparison of mass or concentration of pollutants in a POTW
effluent to pollutants in a  BAT facility's effluent would not take into account the mass of
pollutants discharged to the POTW from non-industrial sources, nor the dilution of the pollutants
in the POTW effluent to lower concentrations from the addition of large amounts of non-
industrial  wastewater.
                                          7-15
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                                                           Section 7.0 - Pollutants Selected for Regulation
             To establish the performance of well-operated POTWs, EPA primarily compiled
POTW percent-removal data from previous effluent guidelines rulemaking efforts, which have
established national POTW percent-removal averages for a broad list of pollutants.  These
guidelines have used the information provided in "The Fate of Priority Pollutants in Publicly
Owned Treatment Works", commonly referred to as the 50 POTW Study. For those pollutants
not found in the 50 POTW study, EPA used data from EPA's National Risk Management
Research Laboratory's (RREL) treatability database.  These studies were discussed previously in
Section 3.0.

             In order to perform the TEC pass-through analysis, EPA was able to use percent
removal rates generated for the rulemaking efforts from the Metal Products and Machinery
(MP&M) Industry (1), the Centralized Waste Treatment (CWT) Industry (2), the Industrial
Laundries Industry (3), and the Pesticide Manufacturing Industry (4).

             In order to determine removal rates for total petroleum hydrocarbons, EPA
applied the methodology developed for the Industrial Laundries proposal (3), which determined
an average POTW removal rate of 65 percent. The Agency is in the  process of reviewing this
methodology and removal rate.

             For indirect dischargers, EPA did not conduct the pass through analysis on the
conventional pollutant oil and grease because of a POTWs ability to treat the non-petroleum
based oils and greases, such as animal fats and vegetable oils. EPA instead conducted the pass
through analysis only on total petroleum hydrocarbons.  Total petroleum hydrocarbons quantifies
the petroleum based fraction of oil and grease which may not be treated as effectively in  a POTW
as with the BAT treatment technology. In cases where EPA has demonstrated that the proposed
BAT treatment  technology will achieve greater removals for the petroleum fraction of oils and
grease, (i.e., total petroleum hydrocarbons), EPA is proposing to establish pretreatment standards
for total petroleum hydrocarbons.
                                          7-16
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                                                           Section 7.0 - Pollutants Selected for Regulation
             Based on the criteria described above, EPA selected pollutants for regulation for
each of the subcategories proposed for regulation. Note that the Agency has chosen not to
regulate indirect dischargers in the Truck/Hopper, Rail/Hopper, Barge/Hopper, Truck/Petroleum,
Rail/Petroleum, Truck/Food, Rail/Food, and Barge/Food Subcategories.

             The following sections give the results of the pass-through analysis for each
subcategory.  The pass-through analysis was not conducted for the conventional pollutants
(BOD5, TSS, pH,  and oil and grease) proposed to be regulated for direct dischargers because
conventional pollutants are not regulated under PSES and PSNS. Pollutants in each subcategory
and technology option that were demonstrated to pass-through a POTW were considered for
regulation. The results of the pass-through analysis for the Truck/Chemical, Rail/Chemical, and
Barge/Chemical & Petroleum Subcategories are listed in Tables 7-7, 7-8, and 7-9.
7.5.1
Pollutants Selected for Regulation for Truck/Chemical Indirect
Dischargers
              EPA is proposing to establish PSES and PSNS limitations for the Truck/Chemical
Subcategory. Based on the pass-through analysis, EPA determined that the following pollutants
passed through a POTW and is therefore proposing to establish pretreatment standards for
chromium, zinc, COD, bis (2-ethylhexyl) phthalate, di-n-octyl phthalate, n-dodecane, n-
hexadecane, styrene, and 1,2-dichlorobenzene.
7.5.2
Pollutants Selected for Regulation for Rail/Chemical Indirect
Dischargers
              For the Rail/Chemical Subcategory, EPA is proposing to establish PSES and
PSNS limitations.  Based on the pass-through analysis, EPA determined that the following
pollutants passed through a POTW and is therefore proposing to establish pretreatment standards
for total petroleum hydrocarbons (SGT-HEM), COD, n-hexadecane, n-tetradecane, and
fluoranthene.
                                          7-17
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7.5.3
                                                          Section 7.0 - Pollutants Selected for Regulation
Pollutants Selected for Regulation for Barge/Chemical &
Petroleum Indirect Dischargers
             For the Barge/Chemical & Petroleum Subcategory, EPA is proposing to establish

PSNS limitations only. Based on the pass-through analysis, EPA determined that the following

pollutants passed through a POTW and is therefore proposing to establish pretreatment standards

for total petroleum hydrocarbons (SGT-HEM), COD, cadmium, chromium, copper, lead, nickel,

zinc, 1-methylphenanthrene, bis (2-ethylhexyl) phthalate, di-n-octyl phthalate, n-decane, n-

docosane, n-dodecane, n-eicosane, n-octadecane, n-tetracosane, n-tetradecane, p-cymene, and

pyrene.
7.6
References
1.
2.
3.
4.
U.S. Environmental Protection Agency. Development Document for Proposed
Effluent Limitations Guidelines and Standards for the Metals Products and
Machinery Phase I Point Source Category. EPA821-R-95-021, April 1995.

U.S. Environmental Protection Agency. DevelopmentDocumsnt for Proposed
Effluent Limitations Guidelines and Standards for the Centralized Waste
Treatment Industry. EPA 821-R-95-006, January 1995.

U.S. Environmental Protection Agency. Development Document for Proposed
Pretreatment Standards for Existing and New Sources for Industrial Laundries
Point Source Category.  EPA 821-R-97-007, November, 1997.

U.S. Environmental Protection Agency. Development Document for Effluent
Limitations Guidelines and New Source Performance Standards for Pesticide
Chemical Manufacturers. EPA 821-R-93-016, September 1993.
                                         7-18
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                                                                                    Section 7.0 - Pollutants Selected for Regulation
                                                       Table 7-1
                                          Priority Pollutant List (a)
 1 Acenaphthene
 2 Acrolein
 3 Acrylonitrile
 4 Benzene
 5 Benzidine
 6 Carbon Tetrachloride (Tetrachloromethane)
 7 Chlorobenzene
 8 1,2,4-Trichlorobenzene
 9 Hexachlorobenzene
 10  1,2-Dichloroethane
 11  1,1,1-Trichloroethane
 12  Hexachloroethane
 13  1,1-Dichloroethane
 14  1,1,2-Trichloroethane
 15  1,1,2,2-Tetrachloroethane
 16  Chloroethane
 17  Removed
 18  Bis (2-chloroethyl) Ether
 19  2-Chloroethyl Vinyl Ether (mixed)
 20  2-Chloronaphthalene
 21  2,4,6-Trichlorophenol
 22  Parachlorometa Cresol (4-Chloro-3-Methylphenol)
 23  Chloroform (Trichloromethane)
 24  2-Chlorophenol
 25  1,2-Dichlorobenzene
 26  1,3-Dichlorobenzene
 27  1,4-Dichlorobenzene
 28  3,3'-Dichlorobenzidine
 29  1,1-Dichloroethene
 30  1,2-Trans-Dichloroethene
 31  2,4-Dichlorophenol
 32  1,2-Dichloropropane
 33  1,3-Dichloropropylene (Trans-1,3-Dichloropropene)
 34  2,4-Dimethylphenol
 35  2,4-Dinitrotoluene
 36  2,6-Dinitrotoluene
 37  1,2-Diphenylhydrazine
 38  Ethylbenzene
 39  Huoranthene
 40  4-Chlorophenyl Phenyl Ether
 41  4-Bromophenyl Phenyl Ether
 42  Bis (2-chloroisopropyl) Ether
 43  Bis (2-chloroethoxy) Methane
 44  Methylene Chloride (Dichloromethane)
 45  Methyl Chloride (Chloromethane)
 46  Methyl Bromide (Bromomethane)
 47  Bromoform (Tribromomethane)
 48  Dichlorobromomethane (Bromodichloromethane)
 49  Removed
 50  Removed
 51  Chlorodibromomethane (Dibromochloromethane)
 52  Hexachlorobutadiene
 53  Hexachlorocyclopentadiene
 54  Isophorone
 55  Naphthalene
 56  Nitrobenzene
 57  2-Nitrophenol
 58  4-Nitrophenol
 59  2,4-Dinitrophenol
 60  4,6-Dinitro-o-Cresol (Phenol, 2-methyl-4,6-dinitro)
 61  N-Nitrosodimethylamine
 62  N-Nitrosodiphenylamine
 63  N-Nitrosodi-n-propylamine (Di-n-propylnitrosamine)
 64  Pentachlorophenol
 65  Phenol	
66 Bis (2-ethylhexyl) Phthalate
67 Butyl Benzyl Phthalate
68 Di-n-butyl Phthalate
69 Di-n-octyl Phthalate
70 Diethyl Phthalate
71 Dimethyl Phthalate
72 Benzo(a)anthracene (1,2-Benzanthracene)
73 Benzo(a)pyrene (3,4-Benzopyrene)
74 Benzo(b)fluoranthene (3,4-Benzo fluoranthene)
75 Benzo(k)fluoranthene (11,12-Benzofluoranthene)
76 Chrysene
77 Acenaphthylene
78 Anthracene
79 Benzo(ghi)perylene (1,12-Benzoperylene)
80 Huorene
81 Phenanthrene
82 Dibenzo(a,h)anthracene (1,2,5,6-Dibenzanthracene)
83 Indeno(l,2,3-cd)pyrene (2,3-o-Phenylenepyrene)
84 Pyrene
85 Tetrachloroethylene (Tetrachloroethene)
86 Toluene
87 Trichloroethylene (Trichloroethene)
88 Vinyl Chloride (Chloroethylene)
89 Aldrin
90 Dieldrin
91 Chlordane (Technical Mixture & Metabolites)
92 4,4'-DDT(p,p'-DDT)
93 4,4'-DDE (p,p'-DDX)
94 4,4'-DDD (p,p'-TDE)
95 Alpha-endosulfan
96 Beta-endosulfan
97 Endosulfan Sulfate
98 Endrin
99 Endrin Aldehyde
100 Heptachlor
101 Heptachlor Epoxide
102 Alpha-BHC
103 Beta-BHC
104 Gamma-BHC (Lindane)
105 Delta-BHC
106 PCB-1242 (Arochlor 1242)
107 PCB-1254 (Arochlor 1254)
108 PCB-1221 (Arochlor 1221)
109 PCB-1232 (Arochlor 1232)
110 PCB-1248 (Arochlor 1248)
111 PCB-1260 (Arochlor 1260)
112 PCB-1016 (Arochlor 1016)
113 Toxaphene
114 Antimony (total)
115 Arsenic (total)
116 Asbestos (fibrous)
117 Beryllium (total)
118 Cadmium (total)
119 Chromium (total)
120 Copper (total)
121 Cyanide (total)
122 Lead  (total)
123 Mercury (total)
124 Nickel (total)
125 Selenium (total)
126 Silver (total)
127 Thallium (total)
128 Zinc (total)
129 2,3.7,8-Tetrachlorodibenzo-p-Dioxin	
Source: Clean Water Act

(a)  Priority pollutants are numbered 1 through 129 but include 126 pollutants since EPA removed three pollutants from the list (Numbers 17,
49, and 50).
                                                            7-19
-------
                                             Section 7.0 - Pollutants Selected for Regulation
                            Table 7-2

  Pollutants Effectively Removed for Truck/Chemical Subcategory
Direct Dischargers for Proposed BPT, BCT, BAT, and NSPS Option 2
CAS
Number
1CAS
Number
' Analyte ' ' ';
Volatile Organics - '" ' „ / /, '-"-'
67641
71432
67663
107062
100414
78933
108101
ACETONE
BENZENE
CHLOROFORM
1,2-DICHLOROETHANE
ETHYLBENZENE
METHYL ETHYL KETONE
METHYL ISOBUTYL KETONE
75092
127184
108883
71556
79016
108383
136777612
METHYLENE CHLORIDE
TETRACHLOROETHENE
TOLUENE
1 , 1 , 1 -TRICHLOROETHANE
TRICHLOROETHENE
M-XYLENE
O- + P-XYLENE
Semivolatile Organics - ?
98555
65850
100516
117817
95578
95487
106445
99876
124185
95501
67710
117840
629970
ALPHA-TERPINEOL
BENZOICACID
BENZYL ALCOHOL
BIS(2-ETHYLHEXYL) PHTHALATE
2-CHLOROPHENOL
O-CRESOL
P-CRESOL
P-CYMENE
N-DECANE
1,2-DICHLOROBENZENE
DIMETHYL SULFONE
DI-N-OCTYL PHTHALATE
N-DOCOSANE
112403
112958
630013
544763
2027170
91576
91203
593453
108952
100425
646311
629594
638686
N-DODECANE
N-EICOSANE
N-HEXACOSANE
N-HEXADECANE
2-ISOPROPYLNAPHTHALENE
2-METHYLNAPHTHALENE
NAPHTHALENE
N-OCTADECANE
PHENOL
STYRENE
N-TETRACOSANE
N-TETRADECANE
N-TRIACONTANE
Organo-Phosphorus Pesticides . , '"
2642719
86500
56724
97176
298044
AZINPHOS ETHYL
AZINPHOS METHYL
COUMAPHOS
DICHLOFENTHION
DISULFOTON
2104645
21609905
150505
22248799

EPN
LEPTOPHOS
MERPHOS
TETRACHLORVENPHOS
Organo-Halide Pesticides - _
319857
58899
BETA-BHC 1133213659
GAMMA-BHC || 1031078
ENDOSULFANH
ENDOSULFAN SULFATE
                               7-20
-------
                             Section 7.0 - Pollutants Selected for Regulation
Table 7-2 (Continued)
- GAS
Number
5103742
510156
50293
2303164
60571
''", '^
Analyte ' ;/- *-,/;,
GAMMA-CHLORDANE
CHLOROBENZELATE
4,4'-DDT
DIALLATE
DffiLDRIN
: OAS
; ' ^Namber , \
.1836755 .
82688
122349
5915413
- ' / Analyte ; , ' v'"Jl
NTIROFEN
PENTACHLORONITROBENZENE
SBVLAZINE
TERBUTHYLAZINE
Phenoxy-Acid Herbicides N , ^ ' ', - , - ' * {
94757
94826
75990
88857
94746
2,4-D
2,4-DB (BUTOXON)
DALAPON
DINOSEB
MCPA
7085190
1918021
93765
93721
MCPP
PICLORAM
2,4,5-T
2,4,5-IP
Metejs ' ^ '<,,,"••"',,'' '- " ^ >, '-/
7429905
7440428
7440473
7440508
18540299
7439896
7439965
ALUMINUM
BORON
CHROMIUM
COPPER
HEXAVALENT CHROMIUM
IRON
MANGANESE
7439976
7723140
7440213
7440315
7440326
7440666
Classical Pollutants - \ ' -,!'.,
7664417
59473040
C002
C004
16984488
COOS
AMMONIA AS NITROGEN
ADSORBABLE ORGANIC HALIDES
(AOX)
BOD 5-DAY (CARBONACEOUS)
CHEMICAL OXYGEN DEMAND
(COD)
FLUORIDE
NITRATE/NITRITE
U014
C012
C020
14265442
C036
C009
MERCURY
PHOSPHORUS
SILICON
TIN
TITANIUM
ZINC
- ^ ys\. J ^
SURFACTANTS (MBAS)
TOTAL ORGANIC CARBON (TOC)
TOTAL PHENOLS
TOTAL PHOSPHORUS
HEXANE EXTRACTABLE
MATERIAL
TOTAL SUSPENDED SOLIDS
           7-21
-------
                                           Section 7.0 - Pollutants Selected for Regulation
                         Table 7-3
Pollutants Effectively Removed for Rail/Chemical Subcategory
Direct Dischargers for Proposed BPT, BCT, and BAT Option 1
CAS
Number
Analyte
' CAS
Number
f •! V'
X J
Analyte
Volatile Organics ' / *
67641
100414
ACETONE I! 108383
ETHYLBENZENE || 136777612
m-XYLENE
o--t-p-XYLENE
Semivolatile Organics > ^'" '''*,'",'?'„,', /',
120127
65850
86748
67710
629970
112403
112958
206440
630013
544763
91576
ANTHRACENE
BENZOICACID
CARBAZOLE
DIMETHYL SULFONE
N-DOCOSANE
N-DODECANE
N-EICOSANE
ELUORANTHENE
N-HEXACOSANE
N-HEXADECANE
2-METHYLNAPHTHALENE
832699
91203
630024
593453
85018
108952
129000
100425
646311
629594
638686
1-METHYLPHENANTHRENE
NAPHTHALENE
N-OCTACOSANE
N-OCTADECANE
PHENANTHRENE
PHENOL
PYRENE
STYRENE
N-TETRACOSANE
N-TETRADECANE
N-TRIACONTANE
Organo-Phosphorus Pesticides ~- - * ~
78342
22248799
34643464
DIOXATfflON
TETRACHLORVINPHOS
TOKUTHION
52686
327980
512561
TRICHLORFON
TRICHLORONATE
TRIMETHYLPHOSPHATE
Organo-Halide Pesticides - " -\ '/",;' ''"""" -~" '''" "v -"/s#' ";-(
30560191
15972608
1861401
319857
319868
58899
23184669
2425061
786196
5103719
1861321
ACEPHATE
ALACHLOR
BENEFLURALIN
BETA-BHC
DELTA-BHC
GAMMA-BHC
BUTACHLOR
CAPTAFOL
CARBOPHENOTfflON
ALPHA-CHLORDANE
DACTHAL (DCPA)
60571
1031078
7421934
465736
21087649
1836755
72560
1918167
139402
122349
8001501
DffiLDRIN
ENDOSULFAN SULFATE
ENDRIN ALDEHYDE
ISODRIN
METRIBUZIN
NTTROFEN
PERTHANE
PROPACHLOR
PROPAZINE
SIMAZINE
STROBANE
                            7-22
-------
                             Section 7.0 - Pollutants Selected for Regulation
Table 7-3 (Continued)
s CAS
Number
72548
50293
2303164
•• * ^ * , ^'^
%s , ~* f 'i^'* * .? ^e*
Anaiyte;> l_ ;
4,4'-DDD
4,4'-DDT
DIALLATE
!-,-C^\ ,
Number
5902512
43121433
1582098
' * i *' ' " '," A ' ' ' '•~-"'X%,';> ^
s ^ * ^ "" ', S ^ \ ' '^ '$^%
A ; ,,AMaiyte,- ,1 , '-i."^i
TERBACEL
TRIADIMEFON
TRIFLURALIN
Phenoxy-Acid Herbicides N '"''-,"' V \i ' ' - ?- % V,
94757
75990
120365
2,4-D
DALAPON
DICHLOROPROP
88857
93765
DINOSEB
2,4,5-T
Metals, , / ,.,-'( '-~''' ' .'/',- .1'^ ,'$ ? -"",^ .„ -/ • ''' >:\. >\ Vs- , S^ ,/V "- ' <"- >
7429905
ALUMBSIUM ||

"Classical Pollutants^ , ' -f ///-'- v/> ;;,/ *"-'\ •• , v _ ,_ ^ '^;%, 
-------
                                            Section 7.0 - Pollutants Selected for Regulation
                          Table 7-4

Pollutants Effectively Removed for Rail/Chemical Subcategory
       Direct Dischargers for Proposed NSPS Option 3
CAS
Number
1CAS
Number; ;
Volatile Organics , ' ,,'
67641
100414
78933
ACETONE
ETHYLBENZENE
METHYL ETHYL KETONE
108383
136777612
J ';',;' * ,?
, , Analyte , s ;
' ' " f ** <.*- f S s •- '/ X'
M-XYLENE
O- + P-XYLENE
Semivolatile Organics ,, r ' ^ , f / ,- '......' \
120127
65850
86748
106445
95807
67710
629970
112403
112958
206440
630013
544763
ANTHRACENE
BENZOICACID
CARBAZOLE
P-CRESOL
2,4-DIAMINOTOLUENE
DIMETHYL SULFONE
N-DOCOSANE
N-DODECANE
N-HCOSANE
FLUORANTHENE
N-HEXACOSANE
N-HEXADECANE
91576
832699
91203
630024
593453
85018
108952
129000
100425
646311
629594
638686
2-METHYLNAPHTHALENE
1-METHYLPHENANTHRENE
NAPHTHALENE
N-OCTACOSANE
N-OCTADECANE
PHENANTHRENE
PHENOL
PYRENE
STYRENE
N-TETRACOSANE
N-TETRADECANE
N-TRIACONTANE
Organo-Phosphorus Pesticides ' " -'".'',"-, ^ /-< s '- " * ' ^
78342
22248799
34643464
DIOXATfflON
TETRACHLORVINPHOS
TOKUTHION
52686
327980
512561
TRICHLORFON
TRICHLORONATE
1RIMETHYLPHOSPHATE
Organo-Halide Pesticides , " - " ," , - ' - f^ ,"
30560191
15972608
1912249
1861401
319846
319857
319868
58899
314409
1689992
23184669
2425061
ACEPHATE
ALACHLOR
ATRAZINE
BENEFUJRALIN
ALPHA-BHC
BETA-BHC
DELTA-BHC
GAMMA-BHC
BROMACBL
BROMOXYNIL OCTANOATE
BUTACHLOR
CAPTAFOL
1031078
72208
53494705
7421934
55283686
2593159
60168889
1024573
465736
33820530
72435
21087649
ENDOSULFAN SULFATE
ENDRIN
ENDRIN KETONE
ENDRIN ALDEHYDE
ETHALFLURALIN
ETRIDIAZOLE
FENARIMOL
HEPTACHLOR EPOXIDE
ISODRIN
ISOPROPAUN
METHOXYCHLOR
METRIBUZIN
                             7-24
-------
                             Section 7.0 - Pollutants Selected for Regulation
Table 7-4 (Continued)
CAS
Number
133062
786196
5103719
5103742
510156
2675776
1861321
72548
72559
50293
2303164
117806
115322
60571
959988
Analyte - -, '
CAFTAN
CARBOPHENOTfflON
ALPHA-CHLORDANE
GAMMA-CHLORDANE
CHLOROBENZELATE
CHLORONEB
DACTHAL(DCPA)
4,4'-DDD
4,4'-DDE
4,4'-DDT
DIALLATE
DICHLONE
DICOFOL
DIELDR1N
ENDOSULFANI
1?fienoxy-Aci4 Herbicides
94757
75990
94826
1918009
120365
88857
2,4-D
DALAPON
2,4-DB (BUTOXON)
DICAMBA
DICHLOROPROP
DINOSEB
CAS'?
'Number
2385855
1836755
40487421
82688
61949766

72560
1918167
139402
122349
8001501
5902512
5915413
43121433
1582098
-',
94746
7085190
1918021
93765
93721
'* -f < ^ •• v ^ Jff
- s Analyte \ * '' '-1
MIREX
NITROFEN
PENDIMETHALIN
PENTACHLORONITROBENZENE
(PCNB)
CIS-PERMETHRIN

PERTHANE
PROPACHLOR
PROPAZINE
SIMAZINE
STROBANE
TERBACIL
TERBUTHYLAZINE
TRIADIMEFON
TRIFLURALIN
; ' , '\
MCPA
MCPP
PICLORAM
2,4,5-T
2,4,5-TP
Metals \ ' " ' ''' > t \
7429905
7440393
7440473
7440473
ALUMINUM
BARIUM
CHROMIUM
COPPER
7439896
7723140
7440326
7440666
IRON
PHOSPHORUS
TITANIUM
ZINC
Classical Pollutants , /
7664417
59473040
C002
C004
16984488
COOS
C037
AMMONIA AS NITROGEN
ADSORBABLE ORGANIC HAUDDES
BOD 5-DAY (CARBONACEOUS)
CHEMICAL OXYGEN DEMAND
FLUORIDE
NITRATE/NrrRITE
SGT-HEM
U014
C012
C020
14265442
C036
C009
SURFACTANTS (MBAS)
TOTAL ORGANIC CARBON
TOTAL PHENOLS
TOTAL PHOSPHORUS
HEXANE EXTRACTABLE
MATERIAL
TOTAL SUSPENDED SOLIDS
           7-25
-------
                                              Section 7.0 - Pollutants Selected for Regulation
                              Table 7-5

    Pollutants Effectively Removed for Barge/Chemical & Petroleum
Subcategory Direct Dischargers for Proposed BPT, BCT, BAT, and NSPS
                              Option \
CAS
Number
1CAS
Number
Analyte N -,,
Volatile Organics , ,-,,,, \ '; T r;
67641
107131
71432
67663
100414
78933
ACETONE
ACRYLONTTRILE
BENZENE
CHLOROFORM
ETHYLBENZENE
METHYL ETHYL KETONE
108101
75092
108883
108383
136777612
METHYL ISOBUTYL KETONE
METHYLENE CHLORIDE
TOLUENE
M-XYLENE
O- + P-XYLENE
Semivolatile Organics , - " > , ' ' ' '" \
83329
208968
120127
243174
65850
92524
117817
99876
124185
1576676
117840
629970
112403
112958
86737
ACENAPHTHENE
AOBNAPHTHYLENE
ANTHRACENE
2,3-BENZOFLUORENE
BENZOICACE)
BIPHENYL
BIS(2-ETHYLHEXYL) PHTHALATE
P-CYMENE
N-DECANE
3,6-DIMETHYLPHENANTHRENE
DI-N-OCTYL PHTHALATE
N-DOCOSANE
N-DODECANE
N-EICOSANE
FLUORENE
630013
544763'
1730376
91576
832699
91203
630024
593453
700129
85018
108952
129000
100425
646311
629594
N-HEXACOSANE
N-HEXADECANE
1-METHYLFLUORENE
2-METHYLNAPHTHALENE
1-METHYLPHENANTHRENE
NAPHTHALENE
N-OCTACOSANE
N-OCTADECANE
PENTAMETHYLBENZENE
PHENANTHRENE
PHENOL
PYRENE
STYRENE
N-TETRACOSANE
N-TETRADECANE
Phenoxy-Acid Herbicides ;
75990
DALAPON ||

Metals -
7429905
7440439
7440473
7440508
18540299
7439896
7439921
ALUMINUM
CADMIUM
CHROMIUM
COPPER
HEXAVALENT CHROMIUM
IRON
LEAP
7439976
7440020
7440042
7723140
7440188
7440213
7440326
MERCURY
NICKEL
OSMIUM
PHOSPHORUS
RUTHENIUM
SILICON
TITANIUM
                                7-26
-------
                             Section 7.0 - Pollutants Selected for Regulation
Table 7-5 (Continued)
CAS
Number
7439954
7439965
V *
Analyte
MAGNESIUM
MANGANESE
CAS-"
Number
7440666

Analyte " " ' /
ZINC

pg&i^iil|i|S10ibnts ' - _ , ', , "'' "<- - , -,-' "V, -„ -. \ - ;?- ' ;:'t*i
59473040
7664417
C002
C004
COOS.
U014
ADSORBABLE ORGANIC HALEDES
(AOX)
AMMONIA AS NITROGEN
BOD 5-DAY (CARBONACEOUS)
CHEMICAL OXYGEN DEMAND
(COD)
NITRATE/NTTRITE
SURFACTANTS (MBAS)
C012
C037
C020
14265442
C036
C009
TOTAL ORGANIC CARBON (TOC)
SGT-HEM
TOTAL PHENOLS
TOTAL PHOSPHORUS
HEXANE EXTRACTABLE
MATERIAL
TOTAL SUSPENDED SOLIDS
           7-27
-------
                                                 Section 7.0 - Pollutants Selected for Regulation
                                Table 7-6
 Pollutants Effectively Removed for Truck/Food, Rail/Food, and Barge/Food
Subcategory Direct Dischargers for Proposed BPT, BCT, and NSPS Option 2
CAS
Number
11 CAS
Analyte j Number
Semivolatile Organics
65850
95487
BENZOIC ACID II 142621
O-CRESOL || 108952
Analyte t
s >
/ " J y
HEXANOIC ACID
PHENOL
Classical Pollutants " \ / ' , /
7664417
C002
C004
16887006
C010
C012
AMMONIA AS NITROGEN
BOD 5-DAY (CARBONACEOUS)
CHEMICAL OXYGEN DEMAND
(COD)
CHLORIDE
TOTAL DISSOLVED SOLIDS
TOTAL ORGANIC CARBON (TOG)
C037
C020
14265442
C036
C009
SGT-HEM
TOTAL PHENOLS
TOTAL PHOSPHORUS
HEXANE EXTRACTABLE
MATERIAL
TOTAL SUSPENDED SOLIDS
                                  7-28
-------
                                          Section 7.0 - Pollutants Selected for Regulation
                        Table 7-7
Pass-through Analysis for the Truck/Chemical Subcategory
Pollutant
COD
Chromium
Zinc
Bis (2-ethylhexyl) Phthalate
Di-n-Octyl Phthalate
n-Dodecane
n-Hexadecane
Styrene
1 ,2-Dichlorobenzene
BATBereeaiTtemoval
94
80
97
90
95
99
97
98
97
POTW Percent Removal
• 82
67
78
60
83
95
71
94
89
'PassVThrough -
Yes
. Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
                        Table 7-8
 Pass-through Analysis for the Rail/Chemical Subcategory
Pollutant
COD
Total Petroleum Hydrocarbons
(SGT-HEM)
Anthracene
Fluoranthene
n-Dodecane
n-Hexadecane
n-Tetradecane
Phenanthrene
Pyrene
BAT Percent Removal ,
88
75
72
87
83
99
97
87
85
POTWPercentRemoval
82
65
96
42
95
71
71
95
95
'Pass>Throughr
Yes
Yes
No
Yes
No
Yes
Yes
No
No
                           7-29
-------
                                                  Section 7.0 - Pollutants Selected for Regulation
                                Table 7-9
Pass-through Analysis for the Barge/Chemical & Petroleum Subcategory
Pollutant
COD
Total Petroleum Hydocarbons
(SGT-HEM)
Cadmium
Chromium
Copper
Lead
Nickel
Zinc
1-Methylphenanthrene
Bis (2-ethylhexyl) Phthalate
Di-n-Octyl Phthalate
n-Decane
n-Docosane
n-Dodecane
n-Eicosane
n-Octadecane
n-Tetracosane
n-Tetradecane
p-Cymene
Pyrene
Average BAT Percent
Removal
98
>99
97
98
98
95
96
93
>99
>99
>99
>99
>99
>99
>99
>99
>99
>99
>99
99
Average POTW Percent
Removal
82
65
90
67
84
92
51
78
. 95
60
83
9
88
95
92
71
71
71
99
95
Pass Through
Yes
Yes
Yes
Yes
Yes
Yes
. Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
                                   7-30
-------
                                          Section 8.0 - Pollution Prevention and Wastewater Treatment Technologies
8.0
POLLUTION PREVENTION AND WASTEWATER
TREATMENT TECHNOLOGIES
             This section describes technologies that are used by the Transportation Equipment
Cleaning Industry (TECI) to prevent the generation of wastewater pollutants or reduce the
discharge of wastewater pollutants. Various combinations of these technologies were considered
as the basis for the proposed effluent limitations guidelines and standards for the industry (see
Section 9.0).

             Three major approaches are used by the TECI to improve effluent quality:
(1) cleaning process technology changes and controls to prevent or reduce the generation of
wastewater pollutants; (2) flow reduction technologies to decrease wastewater generation and
increase pollutant concentrations, thereby improving the efficiency of treatment system pollutant
removals; and (3) end-of-pipe wastewater treatment technologies to remove pollutants from
transportation equipment cleaning (TEC) wastewater prior to discharge. These approaches are
discussed in the following sections:

             •      Section 8.1:  Pollution prevention controls used by the TECI;
             •      Section 8.2:  Flow reduction technologies used by the TECI;
             •      Section 8.3:  End-of-pipe wastewater treatment technologies used by the
                    TECI; and
             •      Section 8.4:  References used in this section.
8.1
Pollution Prevention Controls
              EPA has defined pollution prevention as source reduction and other practices that
reduce or eliminate pollution at the source. Source reduction includes any practices that reduce
the amount of any hazardous substance or pollutant entering any waste stream or otherwise
released into the environment, or any practice that reduces the hazards to public health and the

                                          8-1
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                                           Section 8.0 - Pollution Prevention and Wastewater Treatment Technologies

environment associated with the release of such pollutants. Data gathered from the Detailed

Questionnaire shows that approximately 27% of TEC facilities currently practice water pollution

prevention, and approximately 61% of TEC facilities currently practice heel pollution prevention.

The principal pollution prevention controls applicable to the TECI are the use of dedicated tanks,

heel reduction, and reduction in the amount or toxicity of chemical cleaning solutions. These

pollution prevention controls are discussed in the following subsections.
8.1.1
Use of Dedicated Tanks
              Tank cleanings are performed for two primary purposes: (1) to prevent

contamination of materials from one cargo shipment to the next and (2) to facilitate inspection

and repair. Certain segments of the TECI, such as shippers and carriers, frequently use tanks

dedicated to hauling a single cargo (e.g., gasoline) that require no, or less frequent, cleaning

between loads. Benefits from the use of dedicated tanks include:


              •      Reduced costs as a result of fewer tank cleanings;

              •      Reduced waste management and disposal costs because heel removal and
                     disposal are not required;

              •      Elimination of the generation of tank cleaning wastewater and associated
                     pollutant discharges; and

              •      Reduced tank cleaning wastewater treatment costs and/or sewerage fees.



Impediments to the use of dedicated tanks include:
                     Product purity concerns that necessitate cleaning to prevent contamination
                     of subsequent cargos; and

                     Financial loss due to inefficient equipment allocation (i.e., dedicated tanks
                     are precluded from use to transport other cargos).
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                                           Section 8.0 - Pollution Prevention and Wastewater Treatment Technologies
8.1.2
Heel Reduction
              Heel is the residual cargo remaining in a tank or container following unloading,
delivery, or discharge of the transported cargo and is the primary source of pollutants in TEC
wastewater. Measures may be taken before, during, and after the tank cleaning process to reduce
the amount of heel that enters the wastewater stream. These heel reduction measures are
described later in this section.

              Excessive heels are also an important economic consideration for the TECI. For
example, many cargos  are valuable, and any product waste represents a significant loss. In
addition, profits from transporting product and/or cleaning tanks can be offset by large heel
disposal costs.  As a result, the TECI has a strong economic incentive to minimize heels.

              Heel generation occurs during the unloading of a tank.  Since tank unloading
frequently does not occur at the TEC facility, the carrier, shipper, or consignee may have a more
direct control over heel generation than the TEC facility that will ultimately clean the tank and
dispose the heel. TEC facilities can develop a heel minimization program that identifies the
sources of heels and institutes practices that discourage heel generation by carriers, shippers, and
consignees.

              Tank cleaning facility personnel cite education of, and communication among, the
carrier, shipper, and consignee as critical components of an effective heel minimization program.
Carriers, shippers, and consignees may not be aware of the problems associated with excess heels
and may not understand how heel minimization best serves their interests. An effective heel
minimization program is best implemented as a partnership among the carrier, shipper,
consignee, and tank cleaning facility and may include the following components:
                     Drivers should be trained to identify excess heels;
                     Drivers should perform pre- and post-trip inspections and discuss with the
                     consignee methods for reducing excess heels;
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                                           Section 8.0 - Pollution Prevention and Wastewater Treatment Technologies

                     If excess heel is not resolved with the consignee, the driver should report
                     excess heel to the driver's.manager.  Drivers should document heel issues
                     or problems including offloading conditions which may have caused
                     excess heel;

                     Carriers should provide data to the shipper on amounts of heels;

                     Facilities should consider heel management options other than disposal,
                     such as redelivering the product to the consignee or drumming the heel
                     and returning it to the shipper or consignee;

                     Facilities should evaluate any company policies that punish or fine drivers
                     for excess heel to ensure that the policies do not encourage illicit heel
                     disposal;

                     Drivers should consider inviting shippers to accompany them during
                     product delivery to gain a first hand perspective and understanding of
                     factors impacting heel volumes;

                     Facilities may refuse or reject tanks for cleaning if excessive heel is
                     present;

                     Facilities may charge an extra fee per amount of heel received as an
                     incentive to minimize heel;

                     Facilities may refuse to accept particular cargos for one or more of the
                     following reasons: federal, state, local, or other environmental permit
                     limitations; safety considerations; facility cleaning capabilities; and/or
                     facility wastewater treatment system capabilities;

                     The heel minimization programs, pollution prevention plans, and tank
                     cleaning standard operational procedures should be written and carefully
                     followed by all personnel involved in heel generation  and management;
                     and

                     Personnel should undergo ongoing training so that changes in the heel
                     minimization program and new procedures and policies will not be
                     overlooked.
              Implementation of an effective heel program can provide significant
environmental and economic benefits.  In order to achieve the environmental and economic
benefits associated with heel reduction, TEC facilities should employ appropriate heel reduction
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                                           Section 8.0 - Pollution Prevention and Wastewater Treatment Technologies
techniques in addition to implementing an effective heel minimization program. Heel reduction
techniques are discussed in the following paragraphs.

              During tank cleaning operations, some TEC facilities incorporate procedures to
remove as much heel as possible so that it can be segregated from the tank cleaning wastewater.
One procedure, used particularly for tanks that last transported petroleum products, is to steam
the inside of the tank to lower the viscosity of the heel. The steamed tank is then drained to
remove additional heel. Similarly, tanks, drains,  and fittings may be preheated with steam or hot
water to facilitate product draining. Another procedure applicable to certain cargos is for tank
cleaning personnel to enter the tank and manually squeegee heel toward the valve openings.
(Physically entering a tank may not be advisable in many circumstances.  Personnel must be
trained in health and safety procedures and a confined space entry permit may be required.)

              A third procedure is to perform a hot or cold water prerinse (subsequent to
primary heel removal via draining) to enhance heel removal.  This procedure uses a short burst of
water (e.g. 5 to 10 seconds) to remove heel from  the tank interior. The prerinse wastewater
(containing residual heel) is drained and managed separately from tank cleaning wastewater.
Note that some facilities perform tank prerinses solely as a means to increase the useful life of
tank cleaning solutions (by minimizing solution contamination with heel) rather than as a TEC
wastewater pollution prevention procedure. These facilities do not manage the prerinse
wastewater separately from the other tank interior cleaning wastewaters.

              After tank cleaning is complete, facilities employ various heel management
practices (such as reuse, recycle, or disposal) so that heel is managed separately from tank
interior cleaning wastewater. Reuse and recycle may be accomplished by any one of several
methods.  One method is to return the heel to the consignee.  Some heels can be reused  at the
TEC facility. For example, fuel and fuel oil heels can be used in TEC facilities' on-site boilers or
in their own transportation  equipment.  Heels comprised of soaps, detergents, solvents,  acids, or
alkalis may be reused by TEC facilities for tank cleaning, neutralization, or wastewater  treatment.
                                            8-5
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                                           Section 8.0 - Pollution Prevention and Wastewater Treatment Technologies
Many food grade heels can be recycled as animal feed. Some heels, such as fertilizers, can be
segregated, stored, and sold as product.

              Heel that cannot be recycled or reused can be managed separately from tank
interior cleaning wastewater.  The most common method of heel disposal is land disposal.  This
practice is most often performed with petroleum and coal product heels and dry-bulk cargo heels.
Heels may also be hauled to a privately owned treatment works, federally owned treatment
works, centralized waste treatment works, ballast water treatment facility, or hazardous waste
treatment, storage, and disposal facility, all of which are frequently better equipped to treat these
wastes.
8.1.3
Reduction in the Amount and Toxicity of Chemical Cleaning
Solutions
              Many cargo types require the use of chemical cleaning solutions in the tank
cleaning process. In addition to the contaminants contained in the heel removed by chemical
cleaning solutions, the chemicals used in the solutions may themselves be toxic.  These chemical
cleaning solutions are a significant source of pollutants in TEC wastewater. By reducing the
amount and toxicity of chemical cleaning solutions used in the tank cleaning process, tank
cleaning facilities can reduce the contribution of cleaning solutions to the total wastewater
pollutant concentrations. These pollution prevention procedures include recirculating and
reusing cleaning solutions, disposing cleaning solutions separately from tank interior cleaning
wastewater, and using less toxic cleaning solutions.  These measures are described further in the
following paragraphs.
              The majority of TEC facilities that discharge chemical cleaning solutions with
their tank cleaning wastewater recycle and reuse the solutions at least once prior to discharge.
Recycle and reuse is usually achieved through the use of automated cleaning systems or cleaning
solution recirculation loops that allow reuse of the cleaning solutions until their efficacy
diminishes below acceptable levels. This reduces the amount of additional chemical cleaning
                                            8-6
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                                            Section 8.0 - Pollution Prevention and Wastewater Treatment Technologies
solution required for each tank cleaned; instead, smaller amounts of make-up solution are
periodically added to replace solution lost in the final rinse or to boost efficacy.  As previously
mentioned, a hot or cold water prerinse may also be used to extend the useful life of a chemical
cleaning solution, thereby reducing the total amount of chemical cleaning solution needed for
tank cleaning.

              Another method of reducing the introduction of chemical cleaning solutions to the
wastewater streams is to capture the spent solutions and dispose them off site at a treatment
facility that is better equipped to treat these concentrated chemical wastes than on-site
wastewater treatment systems. Off-site disposal can be combined with the recirculation and
reuse of cleaning solutions (described above) to reduce the need for fresh  cleaning solution and
to minimize the amount of cleaning solutions that enter the facility wastewater treatment system.

              Many facilities in the TECI substitute less toxic cleaning solutions, where
appropriate, to reduce the amount of toxic pollutants that are introduced to the wastewater
stream. Typically, presolve solutions are the most toxic chemical cleaning solutions and are least
compatible with facility wastewater treatment systems. Presolve usually consists of diesel fuel,
kerosene, pr some other petroleum-based solvent and is used to clean hardened or caked-on
products that are not easily removed by other cleaning processes. In many cases, presolve may
be substituted by acidic or caustic solutions to which detergent "boosters" (e.g., glycol ethers or
esters) are added to improve their effectiveness.  At some facilities, chemical cleaning solutions
may be eliminated by using steam cleaning or hot or cold water washes for water-soluble cargos
or by extending the process time of cleaning steps that do not use toxic cleaning solutions.

              As in the case of heel reduction, these methods to reduce the amount and toxicity
of chemical cleaning solutions benefit from written cleaning process standard operating
procedures and  pollution prevention plans that are carefully followed by cleaning personnel.
Facilities should also conduct ongoing training for cleaning personnel to insure that the
procedures contained in these resources will be practiced at all times.
                                             8-7
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                                           Section 8.0 - Pollution Prevention and Wastewater Treatment Technologies
8.2
Flow Reduction Technologies
              This section describes technologies that can reduce the volume of wastewater
discharges from TEC facilities.  Flow reduction offers the following benefits: (1) increased
pollutant concentrations which increase the efficiency of the wastewater treatment system;
(2) decreased wastewater treatment system equipment sizes, resulting in reduced treatment
system capital and operating and maintenance costs; and (3) decreased water and energy usage.
Data gathered from the Detailed Questionnaire shows that approximately 45% of TEC facilities
currently practice flow reduction/water conservation. Flow reduction technologies applicable to
the TECI serve to reduce the amount of fresh water required for tank cleaning through cleaning
process modifications and/or recycling and reusing process wastewaters in TEC or other
operations. These flow reduction technologies are presented in the following subsections.
8.2.1
High-Pressure, Low-Volume Cleaning Equipment
              The use of high-pressure, low-volume cleaning equipment is one of the most
effective tools for reducing water use.  The most common type of this equipment is spinner
nozzles, which are nozzles designed to rotate around both vertical and horizontal axes to create
an overlapping spray pattern that cleans the entire interior of the tank. Spinner nozzles are
inserted through the main tank hatch and operated at pressures between 100 pounds per square
inch (psi) and 600 psi to deliver hot or cold water rinses and a variety of cleaning solutions for
tank cleaning final rinses. Spinners can be operated using pulsing pump technology where water
is delivered in bursts of a few seconds, further reducing the volume of water.  Washing with
high-pressure, hand-held wands with stationary nozzles achieves the same result as washing with
high pressure spinner nozzles but requires facility personnel to manually direct the wash solution
across the interior surface of the tank.
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                                           Section 8.0 - Pollution Prevention and Wastewater Treatment Technologies
8.2.2
Monitoring TEC Water Use
              Cleaning personnel can monitor the amount of water required for tank cleaning so
that the minimum amount of water is used to clean each specific tank and cargo type. One
approach is to inspect each tank to determine the state and amount of residual cargo remaining
and thereby determine the duration and amount of water required for cleaning.  A more general   •
approach is to have a predetermined water use and cleaning time for each tank type and cargo
combination based on previous tank cleaning experience.
8.2.3
Equipment Monitoring Program
              The implementation of an equipment monitoring program can significantly reduce
fresh water requirements by eliminating water waste. Pumps, hoses, nozzles, water storage
tanks, and cleaning solution tanks may develop leaks and require prompt attention by facility
personnel.  Preventative maintenance, periodic inspection, and prompt repair of leaks can help
ensure that no unnecessary water waste occurs.
8.2.4
Cleaning Without Use of Water
              Dry cleaning processes (i.e., cleaning processes that do not require water) are
effective for removing some cargos, particularly dry-bulk goods and viscous liquids. Some dry
cleaning processes require cleaning personnel to enter the tank and shovel or sweep dry-bulk
cargos, or mop or squeegee liquid cargos to remove as much residual material as possible.
Mechanical devices may also be used to vibrate hoppers to improve heel removal.  Depending on
the effectiveness of these dry cleaning processes, the need for subsequent tank cleaning with
water may be eliminated. At a minimum, these techniques will reduce the amount of water and
cleaning solution required for tank cleaning.
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                                           Section 8.0 - Pollution Prevention and Wastewater Treatment Technologies
8.2.5
Cascade Tank Cleaning
              Facilities that primarily clean tanks used to transport the same cargos (e.g.,
petroleum facilities) often operate "cascading" tank cleaning processes. In these processes, the
most contaminated TEC process wastewater is used for initial tank rinses, with initial tank rinse
wastewater routed to disposal. Clean water, or relatively clean TEC process wastewater, is used
for final tank rinses, with final tank rinse water reused as an initial tank rinse when cleaning
subsequent tanks. Through this process, wash water is used at least twice prior to discharge or
disposal.
8.2.6
Wastewater Recycle and Reuse
              In addition to cascading tank cleaning processes, TEC facilities may incorporate
other methods of water recycle and reuse to reduce or eliminate the need for fresh process water.
Wastewater streams most commonly recycled and reused for TEC operations include tank
interior cleaning wastewater, hydrotesting water, uncontaminated stormwater, and noncontact
cooling water. If hydrotesting water, uncontaminated stormwater, and noncontact cooling water
are segregated from tank interior cleaning wastewater, these wastewaters do not require extensive
treatment prior to recycle and reuse.

              Tank interior cleaning wastewater generated by cleaning tanks used to transport
petroleum products can typically be reused as tank interior cleaning water after treatment by
oil/water separation and activated carbon treatment.  Wastewater generated by cleaning tanks that
last transported chemical products generally requires more extensive treatment prior to reuse as
source water in TEC operations. Final tank rinse water may also be used as cleaning solution
make-up water.

              Tank hydrotesting wastewater may be reused as future hydrotesting water by
pumping to a storage tank between tests.  Because hydrotesting usually requires that the entire
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                                           Section 8.0 - Pollution Prevention and Wastewater Treatment Technologies
tank be filled (approximately 5^000 gallons for an intermediate sized tank truck), the reuse of
hydrotest wastewater can save substantial volumes of fresh water.
8.3
End-of-Pipe Wastewater Treatment Technologies
              End-of-pipe wastewater treatment includes physical, chemical, and biological
processes that remove pollutants from TEC wastewater prior to discharge to a receiving stream
or POTW.  Many TEC facilities use.pretreatment, primary treatment, biological treatment, and/or
advanced treatment for end-of-pipe treatment of wastewater.  [See Table C-6 of the Data Element
Dictionary for the Detailed Questionnaire (1) for the specific technologies included within these
technology classifications.] Typical end-of-pipe treatment currently used by the TECI includes
pretreatment and primary treatment. TEC facilities that operate biological and/or advanced
treatment units are commonly those that practice extensive water and wastewater recycle and
reuse or discharge directly to U.S. surface waters.

              The following subsections describe the major wastewater treatment technologies
used by the TECI. Each subsection includes a general description of how the technology works
and what types of pollutants the technology treats. The number of TEC facilities that use each
treatment technology is presented in the following table.  The numbers of facilities presented in
this table have been adjusted using statistical scaling factors and therefore represent the entire
industry rather than only the surveyed facilities.  The following subsections  describe each of
these technologies in the order that they appear in the table.
" £ <*&
Treatment Technology <^f
/?<& j>
Gravity Settling
pH Adjustment
Equalization
Oil/Water Separation
Sludge Dewatering
;v> lWa1jrer,of;< " Utilize the Treatment Technology ' %
393 (57%)
303 (44%)
289 (42%)
251 (36%)
195 (28%)
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                                           Section 8.0 - Pollution Prevention and Wastewater Treatment Technologies
Treatment Technology
Dissolved Air Flotation
Coagulation/Flocculation
Filtration
Clarification
Biological Oxidation
Chemical Precipitation/Separation
Grit Removal
Chemical Oxidation
Activated Carbon Adsorption
Membrane Filtration
Number of Faculties <% of Discharging Facilities) That
Utilize the Treatment Technology y -
175 (25%)
169 (24%)
166 (24%)
157 (23%)
60 (9%)
43 (6%)
30 (4%)
16 (2%)
4 (<1%)
1 (<1%)
83.1
Gravity Settling
              Gravity settling, or sedimentation, removes suspended solids from TEC process
wastewater by maintaining wastewater in a quiescent state so that contaminants can separate by
density. Gravity settling is utilized by more than half of the TEC facilities (57%).  During
gravity settling, wastewater is typically collected in a tank or catch basin, where it is detained for
a period of time, allowing solids with a specific gravity higher than water to settle to the bottom
of the tank and solids with a specific gravity lower than water to float to the surface. The
effectiveness of gravity separation depends upon the characteristics of the TEC wastewater and
the length of time the wastewater is held in the treatment unit. Properly designed and operated
gravity separation units are capable of achieving significant reductions of suspended solids and
5-day biochemical oxygen demand in many TEC wastewaters.

              Some facilities add chemicals, such as lime or polymers, to aid in the settling of
solids. The solids that settle out or float to the surface may be removed from the unit
continuously using automatic scrapers or skimmers. Alternatively, the units may be periodically
shut down and the solids removed manually.
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                                           Section 8.0 - Pollution Prevention and Wastewater Treatment Technologies
8.3.2
pH Adjustment
              Adjustment of pH is a process in which chemicals are added to a wastewater to
make it acidic or basic or to neutralize acidic or basic wastewaters. Of the total TEC facilities,
44% utilize pH adjustment. A pH adjustment system normally consists of a small tank in which
the wastewater pH is adjusted by mixing and chemical addition under the control of a pH meter.
To adjust the pH of the wastewater, either caustic or acidic chemicals are added to the mixing
tank.  Because many treatment technologies used in the TECI are sensitive to pH fluctuations, pH
adjustment may be required as part of an effective treatment system. Some treatment
technologies require a high pH (e.g., chemical precipitation), while others require a neutral pH
(e.g., biological oxidation). In addition, the pH of the final effluent from these technologies must
often be adjusted prior to discharge to meet permit conditions for wastewater discharge.
8.3.3
Equalization
              Equalization involves homogenizing variable wastewaters over time to control
fluctuations in flow and pollutant characteristics, thereby reducing the size and cost and
improving the efficiency of subsequent treatment units.  Approximately 42% of TEC facilities
incorporate equalization in their wastewater treatment processes. Equalization units include
tanks which are often equipped with agitators (e.g., impeller mixers and air spargers) to mix the
wastewater and to prevent solids from settling at the bottom of the unit.  Chemicals may also be
added to the equalization units to adjust pH, as necessary, for further treatment.

              Equalization units can allow downstream treatment units to be sized and operated
on a continuous-flow basis, because they can minimize the variation in the characteristics of
untreated wastewaters.  This reduces the probability of treatment system upsets and allows
treatment systems to be optimized for a narrower range of influent wastewater characteristics.
The amount of residence time required by an equalization unit to achieve optimum effects is
dependent upon the specific characteristics and daily flow patterns of the wastewater.
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                                           Section 8.0 - Pollution Prevention and Wastewater Treatment Technologies
8.3.4
Oil/Water Separation
              Oil/water separation uses the difference in specific gravity between oil and water
to remove free or floating oil from wastewater. More than one-third of TEC facilities (36%) use
oil/water separation as a method of removing varying levels of oil and grease.

              The most common mechanism for oil removal is an oil skimmer. Some skimming
devices work by continuously contacting the oil with a material, such a belt or rope, onto which
the oil readily adheres. As the material passes through the floating oil layer, the oil coats the
surface of the material.  The oil-coated material then passes through a mechanism that scrapes
the oil from the material into an oil collection unit. Another type of skimming device uses
overflow and underflow baffles to skim the floating oil layer from the surface of the wastewater.
An underflow baffle allows the oil layer to flow over into a trough for disposal or reuse while
most of the water flows underneath the baffle.  This is followed by an overflow baffle, which is
set at a height relative to the first baffle such that only the oil-bearing portion will flow over the
first baffle during normal operation.

              A standard oil/water separator utilized by the TECI is an American Petroleum
Institute (API) oil/water separator.  A typical API oil/water separator is rectangular and
constructed with surface skimmers for oil removal and a bottom sludge rake or sludge auger for
solids removal. It is designed such that lighter floating matter rises and remains on the surface of
the water until removed, while the liquid flows out continuously under partitions or through deep
outlets.  Figure 8-1 presents  a diagram of an API oil/water separator.
              Another common type of oil/water separator used by the TECI is a coalescing
oil/water separator, which is used to remove oil droplets too finely dispersed for conventional
gravity separation and skimming technology.  These units are comprised of a series of corrugated
and/or inclined plates or tubes arranged parallel to one another and transverse to the flow of
water. The plates and rubes are often built of materials that attract oil away from the water, such
as polypropylene, ceramic, or glass. As the oil droplets impinge on the. surfaces of the plates or

                                           8-14
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                                          Section 8.0 - Pollution Prevention and Wastewater Treatment Technologies
tubes, they coalesce into a layer of oil that flows or is pumped from the unit.  Figure 8-2 presents
a diagram of a coalescing oil/water separator.

              Due to the complex nature of TEC wastewater and the presence of detergents and
high-pH chemicals, oils may form a stable emulsion which does not separate well in a gravity or
coalescing separator. Stable emulsions require pH adjustment, the addition of chemicals, and/or
heat to break the emulsion.  The method most commonly used by the TECI to perform oil/water
separation on stable emulsions is acid cracking. Acid cracking entails the addition of sulfuric or
hydrochloric acid to the tank containing the oil mixture until the pH reaches 1 or 2. A coagulant
may also be added during acid cracking to aid in oil/water separation. After the  emulsion bond is
broken, the free oil floats to the top of the tank where it is removed by a skimming device.
8.3.5
Sludge Dewatering
              Sludge dewatering reduces sludge volume by decreasing its water content.
Various methods of this particular process are employed by 28% of the TECI. Sludge dewatering
may involve simple techniques such as the use of sludge drying beds, or it may be accomplished
through more complicated mechanical techniques, including filter presses, rotary vacuum filters,
and centrifuges. The decrease in sludge volume achieved through sludge dewatering
substantially reduces the cost for sludge disposal and allows for easier sludge handling.
8.3.5.1
Sludge Drying Bed
              The sludge drying bed process involves applying sludge to land, collecting the
 supernatant after solids settle, and allowing the sludge to dry.  The sludge cake may then be
 scraped manually or by a front-end loader and dumped into a truck. Disadvantages to using a
 sludge drying bed are potential odor problems, large land area requirements, and the cost of labor
 to remove the dried cake.  The main components of a sludge drying bed include watertight walls
 extending above the surface of the bed; an opening in the wall for entrance of a front-end loader
 to scrape up the sludge cake; drainage trenches filled with a coarse sand bed supported
                                                                .on a
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                                           Section 8.0 - Pollution Prevention and Wastewater Treatment Technologies
gravel filter with a perforated pipe underdrain; paved areas on both sides of the trenches with a
slope for gravity drainage; and a sludge inlet and supernatant draw-off (2). The supernatant
collected from the sludge may be returned as influent to wastewater treatment. Depending on
sludge content and climate conditions for evaporation, sludge drying times may range from
several days to weeks.
8.3.5.2
Plate-and-Frame Filter Press
              The most widely used filter press is referred to as the plate-and-frame filter press.
A filter press uses positive pressure provided by a mechanical device, such as a hydraulic ram, to
drive water contained in the sludge through a filter medium. This type of unit comprises a series
of recessed plates that are affixed with a filter medium (e.g., filter cloth) and are stacked together
on a horizontal shaft. The plates form a series of spaces separated by the filter media and are
otherwise sealed to withstand the internal pressures created during the filtration cycle. As the
sludge is forced through the system, the water passes through the filter medium and is discharged
through the filtrate port while the solids become trapped within the spaces, forming a dewatered
cake against the filter medium.

              When the cycle is over, the plates are separated, and the dewatered cake is
released from the spaces into a collection bin. Removing the cake from the filter media is often
performed manually by an operator. The filter press filtrate that results from the dewatering is
usually piped back to the beginning of the treatment system. Figure 8-3 presents a diagram of a
plate-and-frame filter press.
8.3.5.3
Rotary Vacuum Filter
              A rotary vacuum filter consists of a cylindrical drum with a filter medium, such as
cloth or wire mesh, around its perimeter. The drum is horizontally suspended within a vessel and
is partially submerged in the sludge.  The drum is rotated and the filter surface contacts the
sludge within the vessel while a vacuum is drawn from within the drum. This draws the water

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                                            Section 8.0 - Pollution Prevention and Wastewater Treatment Technologies
through the filter medium toward the axis of rotation and discharges it through a filtrate port.
The solids become trapped against the filter medium, forming a dewatered cake around the
outside of the drum. The dewatered cake is continuously scraped from the drum into a collection
bin. Figure 8-4 presents a diagram of a rotary vacuum filter.
8.3.5.4
Centrifuge
              Another method of sludge dewatering is centrifuging. Centrifuge designs are
based on the principal of centrifugal force. To settle and separate higher density solids from
wastewater, sludge is spun or rotated in the centrifuge, collected on the inner wall of the
mechanism, and then scraped from the walls of the centrifuge.  Certain wastewater treatment
chemicals may be added to sludge in the centrifuge to bring additional pollutants out of solution
and form an insoluble floe (e.g., as in chemical precipitation) that is also separated by the
centrifugal forces.
8.3.6
Dissolved Air Flotation
              Flotation is the process of influencing suspended particles to rise to the
wastewater surface where they can be collected and removed. Dissolved air flotation is utilized
by approximately 25% of TEC facilities in their treatment systems. During flotation, gas bubbles
introduced into the wastewater attach themselves to suspended particles, thereby reducing their
specific gravity and causing them to float.  Flotation processes are utilized because they can
remove suspended solids that have a specific gravity slightly greater than 1.0 more quickly than
sedimentation.
              Dissolved air flotation (DAF) is one of several flotation techniques used for
wastewater treatment to extract free and dispersed oil and grease, suspended solids, and some
dissolved pollutants from process wastewater.  In DAF, two modes of operation may be
employed to pressurize wastewater. In recycle pressurization, air is injected into a portion of
recycled, clarified effluent and dissolved into a wastewater stream in an enclosed tank or pipe,
                                           8-17
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                                           Section 8.0 - Pollution Prevention and Wastewater Treatment Technologies
pressurizing the wastewater. In full flow pressurization, all of the influent wastewater is injected
with air in a surge tank and is pumped to a retention tank under pressure to dissolve the air into
the wastewater.

              When the wastewater enters the flotation tank, the pressure is reduced, which
causes fine air bubbles to be released.  These bubbles make contact with the suspended particles
via two separate mechanisms.  The first mechanism involves the use of a flocculant, which
causes rising air bubbles to be trapped inside flocculated masses as they increase in size. The
second mechanism involves the intermolecular attraction between the solid particle and the air
bubble, which causes the solid to adhere to the bubble. In either mechanism, the low density of
the air bubble causes it to rise to the surface of the flotation tank with the flocculated or adhered
solids attached.

              DAF units are equipped with rakes that scrape the floe from the surface and into a
sludge collection  vessel, where it is subsequently pumped to a dewatering unit and later disposed.
A sludge auger may be included in the DAF unit to remove solids that have settled to the bottom
of the tank.  Units are typically operated on a continuous basis and incorporate chemical mix
tanks (if flocculants are used), flotation vessels, and sludge collection tanks in a single enclosed
unit. Figure 8-5 presents a diagram of a DAF unit with pressurized recycle.
83.7
Coagulation/Flocculation
              Coagulation and flocculation are processes that cause suspended solids in
wastewater to coalesce. The coalesced particles tend to settle out of the wastewater more quickly
than particles that have not undergone coagulation/flocculation. Approximately 24% of TEC
facilities use coagulation/flocculation.
              Coagulation consists of the addition and rapid mixing of a "coagulant", the
destabilization of colloidal and fine suspended solids, and the initial aggregation of those
particles. Flocculation is the slow stirring to complete aggregation of those particles and form a

                                           8-18
-------
                                            Section 8.0 - Pollution Prevention and Wastewater Treatment Technologies
floe which will in turn settle by gravity (3). After rapid mixing, coagulant aids, such as
polyelectrolytes, are often added to reduce the repulsive forces between the charged particles.
Flocculation may also be accomplished by adding such materials as lime or sodium silicate to
form loose agglomerates that carry the fine particles down with them. These settled solids form a
sludge; therefore, coagulation/flocculation is typically followed by clarification to remove solids
(see Section 8.3.9).
8.3.8
Filtration
              Filtration is used to remove solids from wastewater by passing the wastewater
through a material that retains the solids on, or within, itself. The percentage of TEC facilities
that use filtration (excluding membrane filtration, which is discussed separately in Section
8.3.15) is 24 percent. A wide variety of filter types are used by the TECI including media filters
(e.g., sand, gravel, charcoal), bag filters, and cartridge filters. A filter press (see Section 8.3.5)
may be used for in-line wastewater filtration. The flow pattern of filters is usually top-to-bottom;
however, upflow filters, horizontal filters, and biflow filters are also used.

              The complete filtration process typically involves two phases: filtration and
backwashing. As the filter becomes saturated with trapped solids, the efficiency of the filtration
process decreases.  As the head loss across the filter bed (i.e., measure of solids trapped in the
filter) increases to a limiting value, the end of the filter run is reached, and the filter must be
backwashed to remove the suspended solids in the bed. During backwashing, the flow through
the filter is reversed so that the solids trapped in the media are dislodged and can exit the filter.
The bed may also be agitated with air in order to aid in solids removal.  The backwash water is
then recycled back into the wastewater feed stream.

              The type of filter used depends on various factors such as the operating cycle (i.e.,
whether the wastewater is being filtered continuously or in batches) or the nature of the solids
passing through the filter. The filter type can also be determined by the filtration mechanism
                                            8-19
-------
                                           Section 8.0 - Pollution Prevention and Wastewater Treatment Technologies
(i.e., whether the filtered solids are stopped at the surface of the medium and accumulate to form
a filter cake or are trapped within the pores or body of the filter).
8.3.9
Clarification
              Clarification involves holding wastewater in a quiescent state so that
contaminants can separate by density.  Clarification uses the same principles for treatment as
gravity settling but differs from gravity settling in that it is typically used after
coagulation/flocculation and/or biological treatment.  Approximately 23% of the TECI use
clarification in their wastewater treatment systems.

              Clarifiers consist of settling tanks and are commonly equipped with a sludge
scraper mounted on the floor of the clarifier to rake sludge into a sump for removal. The bottom
of the clarifier may also be sloped to facilitate sludge removal. Clarification can be used as either
a pre-or post-treatment step for various operations to aid in removing settleable solids, free oil
and grease, and other floating material. Clarifiers are often referred to as primary or secondary
sedimentation tanks. Primary clarification is used to remove settleable solids from raw
wastewater or wastewater treated by coagulation/flocculation. Secondary clarification is
normally used in activated sludge systems to remove biomass. A portion of the sludge biomass
is often recycled from the secondary clarifier back to the activated sludge biological oxidation
unit (see Section 8.3.10).  Figure 8-6 presents a diagram of a clarifier.
8.3.10
Biological Oxidation
              Biological oxidation is a reaction caused by biological activity which results in a
chemical combination of oxygen with organic matter to yield relatively stable end products such
as carbon dioxide and water (3). Approximately 9% of the TECI uses biological oxidation to
treat wastewater. In wastewater treatment, this is most commonly accomplished with an
activated sludge treatment system, but aerated lagoons, trickling filters, and rotating biological
contactors (RBCs) can also be used to perform biological oxidation of wastewater.

                                           8-20
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                                           Section 8.0 - Pollution Prevention and Wastewater Treatment Technologies
              An activated sludge treatment system normally consists of an aeration basin, a
secondary clarifier, and a sludge recycle line.  Equalization of flow, pH, temperature, and
pollutant loading is necessary to obtain consistent, adequate treatment.  A settling tank may.be
used to remove settleable solids prior to aeration. An aerobic bacterial population is maintained
in the aeration basin where oxygen, recycled sludge, and nutrients (usually nitrogen and
phosphorus) are added to the system. Prior to the aeration basin, oxygen may also be added to
wastewater in preaeration tanks. Oxygen is normally supplied by aerators that also provide
mixing to help keep microorganisms in suspension.  The activated sludge-wastewater mixture, or
"mixed liquor," is then sent to a secondary clarifier that controls the amount of suspended solids
discharged and provides recycled sludge back to the aeration basin to keep an optimal
concentration of acclimated microorganisms in suspension.

              Sludge produced by these systems generally consists of biological waste products
and expired microorganisms and is typically discharged from the clarifier. However, under
certain operating conditions, this sludge may accumulate in the aeration basin and may require
periodic removal. Figure 8-7 presents a diagram of an activated sludge system.
8.3.11
Chemical Precipitation/Separation
              Chemical precipitation/separation is a process that renders dissolved pollutants
insoluble and uses the resulting phase differential to separate pollutants from wastewater.
Approximately 6% of TEC facilities use chemical precipitation/separation. During chemical
precipitation processes typical in the TECI, insoluble solid precipitates are formed from the
organic or inorganic compounds in the wastewater through the addition of chemicals and/or pH
adjustment.  Sedimentation or filtration then separates out the solids from the wastewater.
Chemical precipitation is generally carried out in four phases:
               1.     Addition of the chemical to the wastewater;
               2.     Rapid (flash) mixing to homogeneously distribute the chemical;
               3.     Slow mixing to promote particle growth by flocculation; and
               4.     Sedimentation or filtration to remove the flocculated solid particles.
                                           8-21
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                                           Section 8.0 - Pollution Prevention and Wastewater Treatment Technologies
              Chemical precipitation systems normally consist of a rapid mixer, a chemical feed
system to add the precipitation agent, a flocculation tank, and a sedimentation tank. In batch
chemical precipitation systems, the treated wastewater is held in the unit long enough to allow
the solids to settle out.  The water is then pumped from the unit, and the resulting sludge is
removed for further dewatering and subsequent disposal.

              Precipitation agents, such as polyaluminum chloride, ferric chloride, and lime,
work by reacting with pollutant cations (e.g., metals) and some anions to convert them into an
insoluble form for subsequent removal by gravity settling. The pH of the wastewater also affects
how much pollutant mass is precipitated, as pollutants precipitate more efficiently in different pH
ranges.  Figure 8-8 presents a diagram of a batch chemical precipitation unit.
8.3.12
Grit Removal
              Grit removal is the process of eliminating heavy, suspended material from
wastewater. Grit removal is only used by 4% of TEC facilities. Grit removal differs from
gravity settling/clarification in that it is typically performed in a smaller tank and has a shorter
retention time. Removal is accomplished using a settling chamber and a collection mechanism,
such as a rake. Grit chambers may also be aerated to remove floatable solids. This unit
operation is performed to prevent excess wear on pumps, accumulations in aeration tanks and
clarifiers, and clogging of sludge piping (3).
8.3.13
Chemical Oxidation
              Chemical oxidation is used in wastewater treatment to destroy priority pollutants
or other organic pollutants by oxidizing them with an oxidizing agent. Approximately 2% of
TEC facilities use chemical oxidation. Chemical oxidation systems consist of a tank, a mixer,
and a chemical feed system to add the oxidizing agent.  During the chemical oxidation reaction,
one or more electrons are transferred from the oxidizing chemical (electron donor) to the targeted
pollutants (electron acceptor), causing their destruction. An oxidant often used by the TECI is

                                          8-22
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                                           Section 8.0 - Pollution Prevention and Wastewater Treatment Technologies
hydrogen peroxide. Other oxidants used in industry include chlorine, ozone, and potassium
permanganate.
8.3.14
Activated Carbon Adsorption
              Activated carbon removes organic constituents from wastewater by physical and
chemical forces that bind the constituents to the carbon surface and internal pores. Activated
carbon adsorption is widely used in the treatment of industrial wastewaters because it adsorbs an
extensive variety of organic compounds. However, less than 1% of TEC facilities currently use
activated carbon adsorption. The term "activated carbon" refers to carbon materials, such as coal
or wood, that are processed through dehydration, carbonization, and oxidation to yield a material
that is highly adsorbent due to a large surface area and a high number of internal pores per unit of
mass. In general, organic constituents possessing certain properties (e.g., low water solubility
and high molecular weight) and certain chemical structures (e.g., aromatic functional groups) are
amenable to treatment by activated carbon adsorption.

              An activated carbon adsorption system usually consists of a column of bed
containing the activated carbon.  The most common form of activated carbon for wastewater
treatment is granular. Powdered activated carbon is used less frequently for wastewater
treatment due to the difficulty of regeneration, reactor system design considerations, and its
tendency to plug more easily than granular activated carbon, although it may be used in
conjunction with biological treatment  systems.

              The carbon adsorption  capacity (i.e., the mass of the contaminant adsorbed per
mass of carbon) for specific organic contaminants is related in part to the characteristics of each
compound. Competitive adsorption of mixed compounds has a major effect on adsorption (i.e.,
the carbon may begin preferentially adsorbing one compound over another compound and may
even begin desorbing the other compound).  Process conditions, process design factors, and
carbon characteristics also affect adsorption capacity.
                                           8-23
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                                           Section 8.0 - Pollution Prevention and Wastewater Treatment Technologies
              When the adsorption capacity of the carbon is exhausted, the spent carbon is
either disposed or regenerated; the choice is generally determined by cost. Carbon may be
regenerated by removing the adsorbed organic compounds from the carbon through steam
regeneration, thermal regeneration, or physical/chemical regeneration. The most common
methods to regenerate carbon used for wastewater treatment are thermal and steam regeneration.
These methods volatilize the organic compounds that were adsorbed onto the carbon.
Afterburners are required to ensure destruction of the organic vapors. A scrubber may also be
necessary to remove particulates from the air stream.  Physical/chemical regeneration uses a
solvent, which can be a water solution, to remove the organic compounds.
8.3.15
Membrane Filtration
              Membrane filtration is a term applied to a group of processes that use a pressure-
driven, semipermeable membrane to separate suspended, colloidal, and dissolved solutes from a
process wastewater. Less than 1% of TEC facilities use membrane filtration.  During operation,
the feed solution flows across the surface of the membrane. "Clean" water permeates the
membrane by passing through pores in the membrane, leaving the contaminants and a portion of
the feed behind. The clean or treated water is referred to as the permeate or product water
Stream, while the stream containing the contaminants is called the concentrate, brine, or reject
stream. The size of the pores hi the membrane is selected based on the type of contaminant to be
removed. The pore size will be relatively large for the removal of precipitates or suspended
materials, or very small for the removal of inorganic salts or organic molecules. Figure 8-9
presents a diagram of membrane filtration unit.

              For industrial applications, the product water stream will either be discharged or,
more likely, recycled or reused. The reject stream is normally disposed, but if the reject is of
suitable quality, it can also be recycled or reused. Types of membrane filtration systems
available include microfiltration, ultrafiltration (UF), and reverse osmosis  (RO). The
applicability of each of these membrane filtration technologies to the TECI is discussed below.
                                           8-24
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                                           Section 8.0 - Pollution Prevention and Wastewater Treatment Technologies
8.3.15.1
Microfiltration
              Microfilters are generally capable of removing suspended solids and colloidal
matter with diameters of greater than 0.1 microns and are commonly made from woven polyester
or ceramic materials.  The systems can be operated at feed pressures of less than 50 pounds per
square inch gauge (psig). The feed stream does not require extensive pretreatment, and the
membrane is relatively resistant to fouling and easily cleaned. Microfilters are capable of
recovering up to 95% of the feed stream as product water.
8.3.15.2
Ultraffltration
              Ultrafiltration is similar to microfiltration except that a UF membrane has smaller
pores. The "tightest" UF membrane is typically capable of rejecting molecules having diameters
of greater than 0.001 microns.  The system operates at a feed pressure of 50 to 200 psig. UF
systems are capable of recovering from 90 to 95% of the feed as product water.
8.3.15.3
Reverse Osmosis
              Reverse osmosis systems differ from microfiltration and ultrafiltration systems in
that they have the ability to reject dissolved organic and inorganic molecules. RO systems are
generally capable of removing particles with diameters less than 0.001 microns. RO membranes
are commonly made from cellulose acetate; however, polysulfone, polyamide, or other polymeric
materials may also be used.  Reverse osmosis systems can be operated at feed pressures of 250 to
600 psig. RO membranes are very susceptible to fouling and may require extensive pretreatment
of wastewater to remove wastewater constituents that can cause fouling. Oxidants (which may
attack the membrane), particulates, oil, grease, and other materials that could cause a film or
scale to form, plugging the membrane, must be removed by pretreatment. Reverse osmosis
systems are capable of recovering up to 50 to 90% of the feed stream as product water.  The
dissolved solids concentration in the feed determines the percent recovery that can be obtained as
well as the required feed pressure to operate the system.

                                           8-25
-------
8.4
                                            Section 8.0 - Pollution Prevention and Wastewater Treatment Technologies
References1
1.
2.
3.
Eastern Research Group, Inc.  Data Element Dictionary for Part A. of the U.S.
Environmental Protection Agency 1994 Detailed Questionnaire for the
Transportation Equipment Cleaning Industry. April 4, 1997 (DCN T10271).

Viessman, Warren, Jr. and Mark J. Hammer. Water Supply and Pollution
Control. Fifth Edition. Harper Collins College Publishers. New York, NY, 1993.

Reynolds, Tom and Paul Richards. Unit Operations and Processes in
Environmental Engineering.  PWS Publishing. Boston, MA, 1996.
'  For those references included in the administrative record supporting the proposed TECI rulemaking, the
  document control number (DCN) is included in parentheses at the end of the reference.

                                            8-26
-------
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                                             8-35
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-------
                                                 Section 9.0 - Development of Control and Treatment Options
9.0
DEVELOPMENT OF CONTROL AND TREATMENT
OPTIONS
             This section describes the combinations of pollution prevention practices, water
conservation practices, and end-of-pipe wastewater treatment that EPA configured as technology
options for consideration as bases for the Transportation Equipment Cleaning Industry (TECI)
effluent limitations guidelines and standards.

             •      Best practicable control technology currently available (BPT);
             •      Best conventional pollutant control technology (BCT);
             •      Best available technology economically achievable (BAT);
             •      New source performance standards (NSPS);
             •      Pretreatment standards for existing sources (PSES); and
             •      Pretreatment standards for new sources (PSNS).

             Technology bases for each option for each regulation were selected from the
pollution prevention and wastewater treatment technologies described in Section 8.0. Sections
9.2 through 9.7 discuss the regulatory options that were considered for each of the regulations
listed above, including the technology bases and the rationale for developing each option.
9.1
Introduction
             The proposed regulations establish quantitative limits on the discharge of
pollutants from industrial point sources. The applicability of the various limitations EPA is
proposing for the TECI is summarized below:
v
BPT
BAT
BCT
NSPS
Direct
Discharge
•
•
•
•
. Indirect
Discharge >




Existing
- Source
•
•
•

New
Source



t/
Conventional
Pollutants .
•

•
•
Priority {raitf;
Nonconventional
Pollutants '
•
•

•
                                         9-1
-------
                                                  Section 9.0 - Development of Control and Treatment Options

PSES
PSNS
Direct
Discharge


Indirect
Discharge
•
•
Existing
Source
•

New
Source

•
Conventional
Pollutants


Priority and,'
, Nonconventional
Pollutants
•
•
All of these regulations are based upon the performance of specific technologies but do not
require the use of any specific technology. The regulations applicable to direct dischargers are
effluent limitations guidelines which are applied to individual facilities through National
Pollutant Discharge Elimination System (NPDES) permits issued by EPA or authorized states
under Section 402 of the Clean Water Act (CWA). The regulations applicable to indirect
dischargers are standards and are administered by local permitting authorities (i.e., the
government entity controlling the publicly-owned treatment works (POTW) to which the
industrial wastewater is discharged. The pretreatment standards are designed to control
pollutants that pass through or interfere with POTWs.
9.1.1
Common Elements of All Options
              Technology options for all subcategories have two common elements.
              1.     Good Heel Removal and Management Practices. The benefits of good
                    heel removal and management practices include the following:
                    —    Prevent pollutants from entering the wastewater stream (Let,
                           maximum removal of heel prior to tank cleaning minimizes the
                           pollutant loading in the tank interior cleaning wastewater stream);
                    —    Provides a potential to recover/reuse valuable product; and
                    —    May reduce wastewater treatment system capital and annual costs
                           due to reduced wastewater pollutant loadings.
The components of good heel removal and management practices are discussed in detail in
Section 8.1.2.
                                           9-2
-------
                                                  Section 9.0 - Development of Control gnd Treatment Options
             Based on responses to the Detailed Questionnaire, the majority of transportation
equipment cleaning (TEC) facilities currently operate good heel removal and management
practices. Because of the many benefits of these practices, and a demonstrated trend in the TECI
to implement these practices, EPA believes that the TECI will have universally implemented
good heel removal and management practices prior to implementation of TECI effluent
guidelines.  Therefore, EPA is allocating no costs or pollutant reductions for this component of
the technology option bases.
              2.     Good Water Conservation Practices.  The benefits of good water
                    conservation practices include the following:
                    —    Reduced water usage and sewage fees;
                    —    Improved wastewater treatment performance and efficiency
                           because influent wastewater pollutant concentrations will be
                           higher; and
                    —    Reduced wastewater treatment system capital and annual operating
                           and maintenance (O&M) costs due to reduced wastewater flows.
The components of good water conservation practices are discussed in detail in Section 8.2.

              End-of-pipe wastewater treatment cannot achieve complete removal of pollutants.
There is a lowest concentration that wastewater treatment technologies have been demonstrated
to achieve. As shown in the equation below, pollutant loadings in wastewater are dependent
upon wastewater pollutant concentration and on wastewater flow.
                                        C x PNF
                                PNPL =
                                         264,170
                                                         (1)
where:
              PNPL =
              {~*     —
              PNF  =
Production normalized pollutant load, g/tank
Concentration, ug/L
Production normalized flow, gallons/tank
                                          9-3
-------
                                                   Section 9.0 - Development of Control and Treatment Options
Equation (1) demonstrates that optimal pollutant reductions are achieved using a combination of
good water conservation practices and end-of-pipe wastewater treatment.

              In developing effluent guidelines limitations and standards for the TECI, the EPA
included good water conservation practices as a component of the technology bases for all
regulatory options. The Agency considered good water conservation practices to be represented
by the median tank interior cleaning wastewater volume discharged per tank cleaning (including
non-TEC wastewater streams not easily segregated) for each subcategory.  This wastewater
volume is referred to as the "regulatory flow" for each subcategory. Table 9-1 at the end of this
section presents the subcategory-specific regulatory flows for existing facilities. Development of
the subcategory-specific regulatory flows is described in the following subsection.

              Since good water conservation practices are defined by the median subcategory
flow, 50% of existing TEC facilities currently operate good water conservation practices.  For the
remaining 50% of TEC facilities, EPA considered a variety of control technologies depending
upon the extent of flow reduction required at a given facility to achieve the median subcategory
flow. For the truck and rail subcategories, with the exception of hoppers, the control
technologies include the following:
                     For facilities with current flow to regulatory flow ratios greater than 1 and
                     less than or equal to 1.5:
                     —    Facility water use monitoring, and
                     —    Personnel training in water conservation.
                     For facilities with current flow to median subcategorv flow ratios greater
                     than 1.5 and less than or equal to 2:
                     —    Facility water use monitoring,
                     —    Personnel training in water conservation, and
                           Two new spinners and spinner covers.
                                           9-4
-------
                                                     Section 9.0 - Development of Control and Treatment Options
                     For facilities with current flow to median subcategorv flow ratios greater
                     than 2:
                     —    Facility water use monitoring,
                     —    Personnel training in water conservation, and
                     —    New tank interior cleaning system(s)1.
For the hopper subcategories, the control technologies include the following:
                     For facilities with current flow to regulatory flow ratios greater than 1:
                     —    Facility water use monitoring, and
                     —    Personnel training in water conservation.
For the barge subcategories, the control technologies include the following:
                     For facilities with current flow to regulatory flow ratios greater than 1:
                     —     Facility water use monitoring,
                     —     Personnel training in water conservation, and
                     —     Contract hauling of heel.
              In calculating compliance cost estimates (see Section 10.0), EPA assumed that the
flow reduction technology options are sufficient to achieve the regulatory flow for all facilities
based on the selection criteria described above. Additional details concerning EPA's flow
reduction methodology, the flow reduction control technologies, and application of the flow
technologies are included in the TECI cost model documentation contained in the rulemaking
record.
 1 New tank interior cleaning system(s) include(s) solution tanks, controls, pumps, piping, catwalks, stairways, rails,
  and spinners.
                                             9-5
-------
9.1.2
                                     Section 9.0 - Development of Control and Treatment Options
Development of Subcategory-Specific Regulatory Flows
              Waste streams considered in developing the regulatory flows include TEC
wastewater. TEC wastewater includes the following waste streams:
                    Water and steam used to clean tank and container interiors;
                    Prerinse cleaning solutions;
                    Chemical cleaning solutions;
                    Final rinse solutions;
                    Tank or trailer exterior cleaning wastewater;
                    Equipment and floor washings; and
                    TEC-contaminated stormwater.
The following waste streams were not considered in developing the regulatory flows:

              •      Bilge and ballast waters;
              •      Non-TEC process wastewaters;
              •      Sanitary wastewater;
              •      Tank hydrotesting water; and
              •      Wastewater generated from rebuilding or maintenance activities.

              Subcategory-specific regulatory flows were calculated based on responses to the
Detailed Questionnaire. EPA first reviewed wastewater streams discharged by each facility and
classified these streams as described above.  EPA then calculated a facility-specific production-
normalized flow expressed in gallons of wastewater discharged per tank cleaned based on the
TEC wastewater flow rate and the annual number of tanks cleaned. Facilities that clean tanks
representing multiple modes of transportation (e.g., road, rail, or inland waterway) or that clean
both tanks and closed-top hoppers are considered multi-subcategory facilities.  For the purpose of
developing the subcategory-specific regulatory flows, these facilities were assigned a primary
subcategory, and the flow contribution of any secondary subcategory was not considered in the
analysis.
              For each subcategory, using the facility-specific production-normalized flows and
the corresponding facility-specific survey weighting factors, EPA performed a statistical analysis

                                           9-6
-------
                                                   Section 9.0 - Development of Control and Treatment Options
to determine the median wastewater volume generated per tank cleaned. Detailed information
concerning calculation of the regulatory flows is included in the Statistical Support Document
(1).
9.2
Best Practicable Control Technology Currently Available
(BPT)
              EPA proposes BPT effluent limitations for the Truck/Chemical, Rail/Chemical,
Barge/Chemical & Petroleum, Truck/Food, Rail/Food, and Barge/Food Subcategories. The
proposed BPT effluent limitations would control identified conventional, priority, and
nonconventional pollutants when discharged from TEC facilities to surface waters of the U.S.
Generally, EPA determines BPT effluent levels based upon the average of the best existing
performances by plants of various sizes, ages, and unit processes within each industrial category
or subcategory.  In industrial categories where present practices are uniformly inadequate,
however, EPA may determine that BPT requires higher levels of control than any currently in
place if the technology to achieve those levels can be practicably applied.

              In addition, CWA Section 304(b)(l)(B) requires a cost assessment for BPT
limitations.  In determining the BPT limits, EPA must consider the total cost of treatment
technologies in relation to the effluent reduction benefits achieved. This inquiry does not limit
EPA's broad discretion to adopt BPT limitations that are achievable with available technology
unless the required additional reductions are "wholly out of proportion to the costs of achieving
such marginal level of reduction." See Legislative History, op. cit. p. 170. Moreover, the inquiry
does not require the Agency to quantify benefits in monetary terms. See e.g. American Iron and
Steel Institute v. EPA, 526 F. 2d 1027 (3rd Cir., 1975).
              In balancing costs against the benefits of effluent reduction, EPA considers the
 volume and nature of expected discharges after application of BPT, the general environmental
 effects of pollutants, and the cost and economic impacts of the required level of pollution control.
 In developing guidelines, the CWA does not require or permit consideration of water quality
                                            9-7
-------
                                                   Section 9.0 - Development of Control and Treatment Options
problems attributable to particular point sources, or water quality improvements in particular
bodies of water. Therefore, EPA has not considered these factors in developing the limitations
being proposed today. See Weyerhaeuser Company v. Costle. 590 F. 2d 1011 (D.C. Cir. 1978).

              EPA identified relatively few direct discharging facilities for most subcategories
in the TECI as compared to the number of indirect discharging facilities. However, the Agency
concluded that direct discharging facilities are similar to indirect discharging  facilities in terms of
types of tanks cleaned, types of commodities cleaned, water use, and wastewater characteristics.
With respect to existing end-of-pipe wastewater treatment in place, direct discharging facilities
typically operate biological treatment in addition to physical/chemical treatment technologies
typically operated by indirect discharging facilities.
9.2.1
BPT Options for the Truck/Chemical Subcategory
              BPT options for the Truck/Chemical Subcategory include the following
technology bases in addition to the common technology option elements discussed in Section
9.1.1.
Option 1:     Equalization, Oil/Water Separation, Chemical Oxidation, Neutralization,
              Coagulation, Clarification, Biological Treatment, and Sludge Dewatering
Option 2:     Equalization, Oil/Water Separation, Chemical Oxidation, Neutralization,
              Coagulation, Clarification, Biological Treatment, Activated Carbon Adsorption,
              and Sludge Dewatering
The purpose and design bases of the components of these technology options are described
below. These technologies are also described in further detail in Section 8.3.
                                           9-8
-------
Equalization

Purpose:
                                                   Section 9.0 - Development of Control and Treatment Options
Reduce wastewater variability and accumulate wastewater to optimize subsequent
treatment system size arid operating costs.
Design Basis:  Minimum 12-hour residence time. Includes aerators/mixers to homogenize
              wastewater.

Oil/Water Separation

Purpose:      Removal of entrained oil and grease.

Design Basis:  Vertical tube coalescing separator with rotary oil skimmer. Includes demulsifier
              chemical additive, oil storage tank, and sludge storage tank.

Chemical Oxidation. Neutralization. Coagulation, and Clarification

Purpose:      Chemical Oxidation - chemically oxidize pollutants using oxidants such as
              hydrogen peroxide.

              Neutralization - adjust wastewater pH.

              Coagulation - destabilize (reduce repulsive interaction) particle suspension using
              electrolytes to aggregate suspended matter.

              Clarification - settle and remove agglomerated coagulated solids.

Design Basis:  Turn-key treatment system consisting of four reaction tanks in series plus a
              clearwell. Includes chemical feed systems, mixers, control system, and sludge
              storage tanks.

Biological Treatment

Purpose:      Biologically decompose organic constituents.

Design Basis: Activated sludge biological treatment system with a 4.6-day residence time.
              Includes two preaeration tanks in series and a sludge storage tank.

Activated Carbon Adsorption

Purpose:      Wastewater polishing.

Design Basis: Two carbon columns in series with nominal carbon change-out frequency of once
              per month. Includes carbon charge of 250 Ib/gpm/vessel.
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                                                    Section 9.0 - Development of Control and Treatment Options
Sludge Dewatering
Purpose:      Reduce sludge volume by removing water.
Design Basis: Plate-and-frame filter press. Generates dewatered sludge at 32.5% solids.

              EPA is proposing to establish BPT effluent limitations based on Option 2.
Agency data indicate that a treatment train consisting of physical/chemical treatment for the
removal of metals and toxics, biological treatment for the removal of decomposable organic
material, and activated carbon adsorption for removal of residual organics and toxics represents
the average of the best treatment in the industry.  As noted above, all existing direct discharging
facilities in this subcategory currently employ equalization, coagulation/clarification, biological
treatment and activated adsorption. Although no direct discharging facilities were given credit in
EPA's costing model for a coalescing plate oil/water separator, this technology is common and
demonstrated practice in the industry to improve the overall efficiency of the treatment system.
EPA has included the use of oil/water separation in its cost estimates to the industry in order to
ensure that the biological system performs optimally.

              EPA's decision to base BPT limitations on Option 2 treatment reflects primarily
two factors: 1) the degree of effluent reductions attainable and 2) the total cost of the proposed
treatment technologies in relation to the effluent reductions achieved.

              No basis could be found for identifying different BPT limitations based on age,
size, process, or other engineering factors. Neither the age nor the size of the TEC facility will
directly affect the treatability of the TEC wastewaters. For Truck/Chemical facilities, the most
pertinent factors for establishing the limitations are costs of treatment and the level of effluent
reductions obtainable.

              The estimated compliance costs for Option 2 are $104,000 in O&M annual costs
and $134,000 in total capital costs.
                                           9-10
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9.2.2
                                     Section 9.0 - Development of Control and Treatment Options

BPT Options for the Rail/Chemical Subcategory
              BPT options for the Rail/Chemical Subcategory include the following technology
bases in addition to the common technology option elements discussed in Section 9.1.1.
Option 1:      Oil/Water Separation, Equalization, Biological Treatment, and Sludge Dewatering

Option 2:      Oil/Water Separation, Equalization, Dissolved Air Flotation (with Flocculation
              and pH Adjustment), Biological Treatment, and Sludge Dewatering

Option 3:      Oil/Water Separation, Equalization, Dissolved Air Flotation (with Flocculation
              and pH Adjustment), Biological Treatment, Organo-Clay/Activated Carbon
              Adsorption, and Sludge Dewatering
The purpose and design bases of the components of these technology options are described

below. These technologies are also described in further detail in Section 8.3.


Oil/Water Separation

Purpose:      Removal of entrained oil and grease.

Design Basis: API separator with slotted pipe surface oil skimmer, fabric belt skimmer for
              entrained thin oils, and bottom sludge rake.  Includes oil storage tank and sludge
              storage tank.

Equalization

Purpose:      Reduce wastewater variability and accumulate wastewater to optimize subsequent
              treatment system size and operating costs.

Design Basis: Two tanks in parallel, each with minimum 24-hour residence time. Includes
              aerators to homogenize wastewater.
                                          9-11
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                                                   Section 9.0 - Development of Control and Treatment Options
Dissolved Air Flotation
Purpose:      Removal of entrained solid or liquid particles.

Design Basis:  Dissolved air flotation unit with recycle pressurization system. Includes chemical
              addition systems for polymers (coagulants and flocculant) and pH adjustment,
              sludge collection tank, and pre-fabricated building.

Biological Treatment

Purpose:      Biologically decompose organic constituents.

Design Basis:  Activated sludge biological treatment system with a 4.6-day residence time.
              Includes two preaeration tanks in series and a sludge storage tank.

Organo-Clav/Activated Carbon Adsorption

Purpose: '     Wastewater polishing.

Design Basis:  Two columns in series - organo-clay followed by carbon - with nominal carbon
              change-out frequency of one vessel per month and nominal organo-clay change-
              out frequency of one vessel every two months. Includes organo-clay charge of
              1.44 ftVgpm/vessel and carbon charge of 1.44 ftVgpm/vessel.

Sludge Dewatering

Purpose:      Reduce sludge volume by removing water.

Design Basis:  Plate-and-frame filter press. Generates dewatered sludge at 32.5% solids.
              Includes sludge storage tank.
              EPA is proposing to set BPT regulations for the Rail/Chemical Subcategory based

on technology Option 1. EPA's decision to base BPT limitations on Option 1 treatment reflects

primarily two factors: 1) the degree of effluent reductions attainable and 2) the total cost of the

proposed treatment technologies in relation to the effluent reductions achieved.


              No basis could be found for identifying different BPT limitations based on age,

size, process, or other engineering factors.  Neither the age nor the size of the TEC facility will

directly affect the treatability of the TEC wastewaters. For Rail/Chemical facilities, the most
                                           9-12
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                                                   Section 9.0 - Development of Control and Treatment Options
pertinent factors for establishing the limitations are costs of treatment and the.level of effluent
reductions obtainable.

              EPA has selected Option 1 based on the comparison of the three options in terms
of total costs of achieving the effluent reductions, pounds of pollutant removals, economic
impacts, and general environmental effects of the reduced pollutant discharges.

              EPA estimates that implementation of Option 1 will cost $103 dollars per pound
of pollutants removed. Although this projected cost per pound appears to be high, EPA has used
a very conservative cost approach to project costs to the industry. The one facility in EPA's cost
model is already projected to meet the proposed effluent limitations due to the low effluent levels
achieved at this facility, which average 8 mg/L of BOD5.  However, because EPA's proposed
treatment technology includes oil/water separation, the cost model has assumed that this facility
will incur additional costs to install this treatment. Additionally, EPA has given no credit to any
facility for current monitoring practices.  Therefore, EPA has assumed that all monitoring
requirements will result in an increase in costs to the industry. In reality, this facility will likely
not need to install additional treatment to meet the proposed limits, and some of the monitoring
costs assumed by EPA will not be an additional cost burden to the industry.

              The technology proposed in Option 1 represents the average of the best
performing facilities due to the prevalence of biological treatment and sludge dewatering.
Although no direct discharging facilities were given credit in EPA's costing model for oil/water
separation, this technology is common and demonstrated practice in the industry to improve the
overall efficiency of the wastewater treatment system.  EPA has included the  use of oil/water
separation in its cost estimates to the industry in order to ensure that the biological system
performs optimally.
              Finally, EPA also looked at the costs of all options to determine the economic
impact that this proposal would have on the TECI. EPA expects the financial and economic
profile of the direct dischargers to be comparable to that of the estimated 38 indirect dischargers.
                                           9-13
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                                                   Section 9.0 - Development of Control and Treatment Options
EPA anticipates that the economic impact, in terms of facility closures and employment losses,
due to the additional controls at BPT Option 2 and 3 levels would be comparable to that
estimated in EPA's assessment for indirect dischargers, potentially leading to six facility closures
and the associated loss of over 400 employees. The annual cost per facility for BPT Option 1 is
projected to be $12,900 less than the technology evaluated for PSES which caused six facility
closures. Therefore, EPA has concluded that the costs of BPT Option 1 are  achievable and are
reasonable as compared to the removals achieved by this option.

              The estimated compliance costs for Option 1 are $42,000 in O&M annual costs
and $113,000 in total capital costs.
9.2.3
BPT Options for the Barge/Chemical & Petroleum
Subcategory
              BPT options for the Barge/Chemical & Petroleum Subcategory include the
following technology bases in addition to the common technology option elements discussed in
Section 9.1.1.
Option 1:     Oil/Water Separation, Dissolved Air Flotation, Filter Press, Biological Treatment,
              and Sludge Dewatering
Option 2:     Oil/Water Separation, Dissolved Air Flotation, Filter Press, Biological Treatment,
              Reverse Osmosis, and Sludge Dewatering
The purpose and design bases of the components of these technology options are described
below. These technologies are also described in further detail in Section 8.3.
                                          9-14
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                                                    Section 9.0 - Development of Control and Treatment Options
Oil/Water Separation
Purpose:
Removal of low to moderate amounts of insoluble oil.
Design Basis: Gravity separator with 6.4-day residence time for wastewater equalization and oil,
              water, and solids separation. Includes two separation tanks in series with an oil
              removal pump and an oil storage tank.

Dissolved Air Flotation

Purpose:      Removal of entrained solid or liquid particles.

Design Basis: Dissolved air flotation unit with influent pressurization system. Includes sludge
              storage tank.

Filter Press

Purpose:      Wastewater filtration.

Design Basis: In-line plate-and-frame filter press for wastewater filtration. Generates dewatered
              sludge at 32.0% solids. Includes diatomaceous earth mix tank and wastewater
              effluent storage tank.

Biological Treatment

Purpose:      Biologically decompose organic constituents.

Design Basis: Activated sludge biological treatment system with a 4.6-day residence time.
              Includes two preaeration tanks in series, a clarifier, and a sludge storage tank.

Reverse Osmosis

Purpose:      Wastewater polishing.

Design Basis: Reverse osmosis system including unit with membranes, influent wastewater
              storage tanks, and flooded suction tank.

Sludge Dewatering

Purpose:      Reduce biological treatment sludge volume by removing water.

Design Basis: Sludge is dewatered in in-line wastewater plate-and-frame filter press described
              above.
                                           9-15
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                                                  Section 9.0 - Development of Control and Treatment Options
             EPA estimates that implementation of Option 1 will cost $0.35 per pound of
pollutants removed, and has found that cost to be reasonable. Additionally, the Agency
concluded that reverse osmosis is not commonly used in the industry, and therefore Option 2
does not represent the average of the best treatment. Finally, EPA also looked at the costs of all
options to determine the economic impact that this proposal would have on the TECI. EPA's
assessment showed that implementation of BPT is projected to result in no facility closures and
no employment losses.  Therefore, EPA has concluded that the total costs associated with the
proposed BPT option are achievable and are reasonable as compared to the removals achieved by
this option.

             The estimated compliance costs for Option 1 are $1,900,000 in O&M annual costs
and $3,200,000 in total capital costs.
9.2.4
BPT Options for the Truck/Food, Rail/Food, and Barge/Food
Subcategories
              BPT options for the Truck/Food, Rail/Food, and Barge/Food Subcategories
include the following technology bases in addition to the common technology option elements
discussed in Section 9.1.1.

Option 1:     Oil/Water Separation
Option 2:     Oil/Water Separation, Equalization, Biological Treatment, and Sludge Dewatering

The purpose and design bases of the components of these technology options are described
below. These technologies are also described in further detail in Section 8.3.
                                          9-16
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                                                   Section 9.0 - Development of Control and Treatment Options
Oil/Water Separation
Purpose:      Removal of low to moderate amounts of insoluble oil.
Design Basis:  Gravity separator with 6.4-day residence time for wastewater equalization and oil,
              water, and solids separation. Includes two separation tanks in series with an oil
              removal pump and an oil storage tank.
Equalization
Purpose:      Reduce wastewater variability and accumulate wastewater to optimize subsequent
              treatment system size and operating costs.
Design Basis:  Eight-day residence time. Includes aerators/mixers to homogenize wastewater.
Biological Treatment
Purpose:      Biologically decompose organic constituents.
Design Basis:  Activated sludge biological treatment system with a 4.6-day residence time.
              Includes two preaeration tanks in series and a sludge storage tank.
Sludge Dewatering
Purpose:      Reduce biological treatment sludge volume by removing water.
Design Basis:  Plate-and-frame filter press for wastewater filtration.  Generates dewatered sludge
              at 32.0% solids. Includes diatomaceous earth mix tank.

              Based on Screener Questionnaire results, EPA estimates that there are 19 direct
discharging facilities in the Truck/Food, Rail/Food, and Barge/Food Subcategories.  However,
EPA's survey of the TECI did not initially identify any direct discharging facilities through the
Detailed Questionnaire sample population.
              Because all types of facilities in the food subcategories accept similar types of
cargos which generate similar types of wastewater in terms of treatability and toxicity, EPA has
tentatively determined that the same treatment technology can be applied to all three (truck, rail
and barge) food subcategories.  The wastewater generated by the food subcategories contains
high loadings of biodegradable organics, and few toxic pollutants. EPA conducted sampling at a

                                           9-17
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                                                   Section 9.0 - Development of Control and Treatment Options
direct discharging Barge/Food facility which EPA believes to be representative of the entire
population.

              Based on the data collected by EPA, raw wastewater contained significant levels
of organic material in the raw wastewater, exhibiting an average BOD5 concentration of 3,500
mg/L.  Therefore, EPA concluded that some form of biological treatment is necessary to reduce
potential impacts to receiving waters from direct discharging facilities and EPA anticipated that
all direct discharging facilities in these subcategories would have some form of biological
treatment in place. All existing facilities which responded to the Screener Questionnaire
indicated that they did, in fact, have a biological treatment system in place. Therefore, EPA
proposes to establish BPT based on Option 2 for the Truck/Food, Rail/Food, and Barge/Food
Subcategories

              EPA projects no additional pollutant removals and no additional costs to the
industry based on EPA's selection of Option 2 because all facilities identified by EPA currently
have the proposed technology in place.

              EPA estimates zero compliance costs for Option 2.
9.2.5
BPT Options for the Truck/Petroleum and Rail/Petroleum
Subcategories
              EPA did not develop or evaluate BPT Options for the Truck/Petroleum and
Rail/Petroleum Subcategories for the following reasons: (1) all direct discharging facilities
previously identified by the Agency are no longer in operation; (2) EPA is not aware of any new
facilities that have recently begun operations; and (3) EPA believes that permit writers can more
appropriately control discharges from these facilities, if any, using best professional judgment.
                                          9-18
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9.2.6
                                                   Section 9.0 - Development of Control and Treatment Options
BPT Options for the Truck/Hopper, Rail/Hopper, and
Barge/Hopper Subcategories
              BPT options for the Truck/Hopper, Rail/Hopper, and Barge/Hopper Subcategories
include the following technology bases in addition to the common technology option elements
discussed in Section 9.1.1.

Option 1:     Gravity Separation

The purpose and design bases of the components of this technology option are described below.
This technology is also described in further detail in Section 8.3.

Gravity Separation
Purpose:      Removal of suspended solids.
Design Basis:  Gravity separator with 4-day residence time for wastewater equalization and
              solids separation. Includes two separation tanks in series.

              EPA is not proposing to establish BPT regulations for any of the hopper
Subcategories. EPA concluded that hopper facilities discharge very few pounds of conventional
or toxic pollutants. This is based on EPA sampling data, which found very few priority toxic
pollutants at treatable levels in raw wastewater. Additionally, very little wastewater is generated
from cleaning the interiors of hopper tanks due to the dry nature of bulk materials transported.
Therefore, nationally-applicable regulations are unnecessary at this time and direct dischargers
will remain subject to limitations established on a case-by-case basis using best professional-
judgement.
9.3
Best Conventional Pollutant Control Technology (BCD
              BCT limitations control the discharge of conventional pollutants from direct
dischargers. Conventional pollutants include BOD, TSS, oil and grease, and pH. BCT is not an

                                          9-19
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                                                   Section 9.0 - Development of Control and Treatment Options
additional limitation, but rather replaces BAT for the control of conventional pollutants. To
develop BCT limitations, EPA conducts a cost reasonableness evaluation, which consists of a
two-part cost test: 1) the POTW test, and 2) the industry cost-effectiveness test.

              In the POTW test, EPA calculates the cost per pound of conventional pollutants
removed by industrial dischargers in upgrading from BPT to a BCT candidate technology and
then compares this to the cost per pound of conventional pollutants removed in upgrading
POTWs from secondary to tertiary treatment. The upgrade cost to industry, which is represented
in dollars per pound of conventional pollutants removed, must be less than the POTW
benchmark of $0.25 per pound (in 1976 dollars). In the industry cost-effectiveness test, the ratio
of the incremental BPT to BCT cost, divided by the BPT cost for the industry, must be less that
1.29 (i.e. the cost increase must be less than 29 percent).

              EPA is proposing to establish effluent limitations guidelines and standards
equivalent to the BPT for the conventional pollutants covered under BPT for all subcategories.
In developing BCT limits, EPA considered whether there are technologies that achieve greater
removals of conventional pollutants than proposed for BPT, and whether those technologies are
cost-reasonable according to the BCT Cost Test. In each subcategory, EPA identified no
technologies that can achieve greater removals of conventional pollutants than those proposed for
BPT that are also cost-reasonable under the BCT Cost Test, and accordingly EPA proposes BCT
effluent limitations equal to the proposed BPT effluent limitations guidelines and standards.
9.4
Best Available Technology Economically Achievable (BAT)
              The factors considered in establishing a BAT level of control include: the age of
process equipment and facilities, the processes employed, process changes, the engineering
aspects of applying various types of control techniques to the costs of applying the control
technology, non-water quality environmental impacts such as energy requirements, air pollution
and solid waste generation, and such other factors as the Administrator deems appropriate
(Section 304(b)(2)(B) of the Act).  In general, the BAT technology level represents the best
                                          9-20
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                                                   Section 9.0 - Development of Control and Treatment Options
existing economically achievable performance among facilities with shared characteristics. BAT
may include process changes or internal plant controls which are not common in the industry.
BAT may also be transferred from a different subcategory or industrial category.

              EPA is proposing BAT effluent limitations for the Truck/Chemical,
Rail/Chemical, and Barge/Chemical & Petroleum Subcategories based upon the same
technologies evaluated and proposed for BPT. The proposed BAT effluent limitations would
control identified toxic and nonconventional pollutants discharged from facilities. EPA did not
identify any additional technologies beyond BPT that could provide additional toxic pollutant
removals and that are economically achievable. EPA is not proposing to establish BAT
limitations for the Truck/Food, Rail/Food or Barge/Food Subcategories because EPA found that
food grade facilities discharge very few pounds of toxic pollutants not amenable to treatment by a
POTW.
9.5
New Source Performance Standards (NSPS)
              New Source Performance Standards under Section, 306 of the CWA represent the
greatest degree of effluent reduction achievable through the application of the best available
demonstrated control technology for all pollutants (i.e. conventional, nonconventional, and toxic
pollutants).  NSPS are applicable to new industrial direct discharging facilities, for which
construction has commenced after the publication of proposed regulations.  Congress envisioned
that new treatment systems could meet tighter controls than existing sources because of the
opportunity to incorporate the most efficient processes and treatment systems into plant design.
Therefore, Congress directed EPA, in establishing NSPS, to consider the best demonstrated
process changes, in-plant controls, operating methods, and end-of-pipe treatment technologies
that reduce pollution to the maximum extent feasible.
                                          9-21
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9.5.1
                                     Section 9.0 - Development of Control and Treattnent Options
NSPS Options for the Track/Chemical Subcategory
              EPA has not identified any more stringent treatment technology option which it
considered to represent NSPS level of control applicable to Truck/Chemical facilities in this
industry.  Further, EPA has made a finding of no barrier to entry based upon the establishment of
this level of control  for new sources. Therefore, EPA is proposing that NSPS for the
Truck/Chemical Subcategory be established equivalent to BPT for conventional, priority, and
nonconventional pollutants.
9.5.2
NSPS Options for the Rail/Chemical Subcategory
              EPA evaluated BPT Options 2 and 3 as a basis for establishing NSPS more
stringent than the BAT level of control being proposed today. The cost implications anticipated
for new sources are not as severe as those projected for existing sources. By utilizing good heel
removal and management practices which prevent pollutants from entering waste streams, and
good water conservation practices in the design of new facilities, treatment unit size can be
substantially reduced and treatment efficiencies improved.  As .a result, costs of achieving BPT
Options 2 and 3 can be significantly reduced by new sources. BPT Option 2 and 3 technologies
have been demonstrated at an existing zero discharge Rail/Chemical facility. EPA anticipates no
barrier to entry for new sources employing these technologies at lower cost. Furthermore, based
on an analysis of benefits for existing sources, significant environmental differences would be
anticipated between Options 1 and 2 and Option 3 for new sources. Therefore, EPA is proposing
to establish new source performance standards for the Rail/Chemical Subcategory based on BPT
Option 3. Option 3 consists of flow reduction, oil/water separation, equalization, dissolved air
flotation (with flocculation and pH adjustment), biological treatment, organo-clay/activated
carbon adsorption, and sludge dewatering.
                                           9-22
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                                                   Section 9.0 - Development of Control and Treatment Options
9.5.3
NSPS Options for the Barge/Chemical & Petroleum
Subcategory
              EPA evaluated BPT Option 2 as a basis for establishing NSPS more stringent than
the proposed BAT level of control. EPA rejected BPT Option 2 as a basis for NSPS for the same
reasons this additional technology was rejected for BAT. Even though the cost implications for
new sources are not as severe as those projected for existing sources, the cost and economic
implications of BPT Option 2 do bear upon the determination that reverse osmosis technology is
inappropriate for consideration as part of the best available technology for the control of
pollutants for this subcategory.

              Reverse osmosis was not considered to be the best available technology due to the
small incremental removals achieved by this option, the lack of additional water quality benefits
potentially achieved by this option, the potential issue of disposing the liquid concentrate created
by treatment, and the high level of pollutant control achieved by the proposed "BAT option.

              Therefore, EPA is proposing that NSPS for the Barge/Chemical & Petroleum
Subcategory be established equivalent to BPT for conventional, priority, and nonconventional
pollutants.
9.5.4
NSPS Options for the Truck/Food, Rail/Food, and Barge/Food
Subcategories .
              EPA has not identified any more stringent treatment technology option which it
considered to represent NSPS level of control applicable to food subcategory facilities in this
industry. Further, EPA has made a finding of no barrier to entry based upon the establishment of
this level of control for new sources. Therefore, EPA is proposing that NSPS for the food
subcategories be established equivalent to BPT for conventional pollutants.
                                          9-23
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9.5.5
                                                   Section 9.0 - Development of Control and Treatment Options
NSPS Options for the Truck/Petroleum and Rail/Petroleum
Subcategories
              EPA did not develop or evaluate BAT options for these subcategories for the
following reasons: (1) all direct discharging facilities previously identified by the Agency are no
longer in operation; (2) EPA is not aware of any new facilities that have recently begun
operations; and (3) EPA currently believes permit writers can more appropriately control
discharges from these facilities, if any, using best professional judgement. EPA is therefore
proposing not to establish NSPS for the Truck/Petroleum and Rail/Petroleum Subcategories.
9.5.6
NSPS Options for the Truck/Hopper, Rail/Hopper, and
Barge/Hopper Subcategories
              EPA is not proposing to establish NSPS regulations for any of the hopper
subcategories. EPA concluded that hopper facilities discharge very few pounds of toxic
pollutants, and contain very few priority toxic pollutants at treatable levels in raw wastewater.
Additionally, very little wastewater is generated from cleaning the interiors of hopper tanks due
to the dry nature of bulk materials transported.  Therefore, nationally-applicable regulations are
unnecessary at this time and direct dischargers will remain subject to limitations established on a
case-by-case basis using best professional judgement.
 9.6
 Pretreatment Standards for Existing Sources (PSES)
              Pretreatment standards are designed to prevent the discharge of toxic pollutants
 that pass through, interfere with, or are otherwise incompatible with the operation of POTWs, as
 specified in Section 307(b) of the CWA. PSES are technology-based and analogous to BAT
 limitations for direct dischargers.
                                           9-24
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9.6.1
                                     Section 9.0 - Development of Control and Treatment Options

PSES Options for the Truck/Chemical Subcategory
              PSES options for the Truck/Chemical Subcategory include the following

technology bases in addition to the common technology option elements discussed in Section

9.1.1.
Option 1:      Equalization, Oil/Water Separation, Chemical Oxidation, Neutralization,
              Coagulation, Clarification, and Sludge Dewatering

Option 2:      Equalization, Oil/Water Separation, Chemical Oxidation, Neutralization,
              Coagulation, Clarification, Activated Carbon Adsorption, and Sludge Dewatering
The purpose and design bases of the components of these technology options are described

below. These technologies are also described in further detail in Section 8.3.
Equalization

Purpose:
Reduce wastewater variability and accumulate wastewater to optimize subsequent
treatment system size and operating costs.
Design Basis: Minimum 12-hour residence time. Includes aerators/mixers to homogenize
              wastewater.

Oil/Water Separation

Purpose:      Removal of entrained oil and grease.

Design Basis: Vertical tube coalescing separator with rotary oil skimmer. Includes demulsifier
              chemical additive, and oil storage tank.

Chemical Oxidation. Neutralization, Coagulation, and Clarification

Purpose:      Chemical Oxidation - chemically oxidize pollutants using oxidants such as
              hydrogen peroxide.

              Neutralization - adjust wastewater pH.
                                           9-25
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                                                   Section 9.0 - Development of Control and Treatment Options

              Coagulation - destabilize (reduce repulsive interaction) particle suspension using
              electrolytes to aggregate suspended matter.

              Clarification - settle and remove agglomerated coagulated solids.

Design Basis: Turn-key treatment system consisting of four reaction tanks in series plus a
              clearwell. Includes chemical feed systems, mixers, control system, and sludge
              storage tanks.

Carbon Adsorption

Purpose:      Wastewater polishing.

Design Basis: Two carbon columns in series with nominal carbon change-out frequency of once
              per month. Includes carbon charge of 250 Ib/gpm/vessel.

Sludge Dewatering

Purpose:      Reduce sludge volume by removing water.

Design Basis: Plate-and-frame filter press. Generates dewatered sludge at 32.5% solids.
              EPA is proposing to establish pretreatment standards based on Option 2 based on
the additional removals achieved by this option. EPA has determined that Option 2 is
economically achievable and results in no facility closures or projected employment losses.


              The estimated compliance costs for Option 2 are $24,700,000 in O&M annual
costs and $53,600,000 in total capital costs.
9.6.2
PSES Options for the Rail/Chemical Subcategory
              PSES options for the Rail/Chemical Subcategory include the following
technology bases in addition to the common technology option elements discussed in Section

9.1.1.
                                          9-26
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                                                   Section 9.0 - Development of Control and Treatment Options

Option 1:      Oil/Water Separation

Option 2:      Oil/Water Separation, Equalization, Dissolved Air Flotation (with Flocculation
              and pH Adjustment), and Sludge Dewatering

Option 3:      Oil/Water Separation, Equalization, Dissolved Air Flotation (with Flocculation
              and pH Adjustment), Organo-Clay/Activated Carbon Adsorption, and Sludge
              Dewatering
The purpose and design bases of the components of these technology options are described

below. These technologies are also described in further detail in Section 8.3.


Oil/Water Separation

Purpose:      Removal of entrained oil and grease.

Design Basis: API separator with slotted pipe surface oil skimmer, fabric belt skimmer for
              entrained thin oils, and bottom sludge rake.  Includes oil storage tank and sludge
              storage tank.

Equalization

Purpose:      Reduce wastewater variability and accumulate wastewater to optimize subsequent
              treatment system size and operating costs.

Design Basis: Two tanks in parallel, each with minimum 24-hour residence time.  Includes
              aerators to homogenize wastewater.

Dissolved Air Flotation

Purpose:      Removal of entrained solid or liquid particles.

Design Basis: Dissolved air flotation unit with recycle pressurization system. Includes chemical
              addition systems for polymers (coagulants and flocculant) and pH adjustment,
              sludge collection tank, and pre-fabricated building.

Organo-Clav/Activated Carbon Adsorption
Purpose:
Wastewater polishing.
Design Basis: Two columns in series - organo-clay followed by carbon - with nominal carbon
              change-out frequency of one vessel per month and nominal organo-clay change-
                                          9-27
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                                                   Section 9.0 - Development of Control and Treatment Options
              out frequency of one vessel every two months.  Includes organo-clay charge of
              1.44 ftVgpm/vessel and carbon charge of 1.44 ftVgpm/vessel.
Sludge Dewatering
Purpose:      Reduce sludge volume by removing water.
Design Basis:  Plate-and-frame filter press. Generates dewatered sludge at 32.5% solids.
              Includes sludge storage tank.
              EPA is proposing to establish pretreatment standards for the Rail/Chemical
Subcategory based on Option 1. EPA estimates that this option does not result in any facility
closures or employment losses to the industry. Option 2, however, was projected to result in six
facility closures and is demonstrated not to be economically achievable.

              The estimated compliance costs for Option 1 are $1,400,000 in O&M annual costs
and $4,400,000 in total capital costs..
9.6.3
PSES Options for the Barge/Chemical & Petroleum
Subcategory
              PSES options for the Barge/Chemical & Petroleum Subcategory include the
following technology bases in addition to the common technology option elements discussed in
Section 9.1.1.
Option 1:      Oil/Water Separation, Dissolved Air Flotation, and Filter Press
Options 2:    Oil/Water Separation, Dissolved Air Flotation, Filter Press, Biological Treatment,
              and Sludge Dewatering
Option 3:      Oil/Water Separation, Dissolved Air Rotation, Filter Press, Biological Treatment,
              Reverse Osmosis, and Sludge Dewatering
The purpose and design bases of the components of these technology options are described
below. These technologies are also described in further detail in Section 8.3.

                                          9-28
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                                                    Section 9.0 - Development of Control and Treatment Options
Oil/Water Separation
Purpose:      Removal of low to moderate amounts of insoluble oil.

Design Basis: Gravity separator with 6.4-day residence time for wastewater equalization and oil,
              water, and solids preparation. Includes two separation tanks in series with an oil
              removal pump and an oil storage tank.

Dissolved Air Flotation

Purpose:      Removal of entrailed solid or liquid particles.

Design Basis: Dissolved air flotation unit with influent pressurization system.  Includes sludge
              storage tank.
Filter Press
Purpose:
Wastewater filtration.
Design Basis: In-line plate-and-frame filter press for wastewater filtration. Generates dewatered
              sludge at 32.0% solids. Includes diatomaceous earth mix tank and wastewater
              effluent storage tank.

Biological Treatment

Purpose:      Biologically decompose organic constituents.

Design Basis: Activated sludge biological treatment system with a 4.6-day residence time.
              Includes two preaeration tanks in series, a clarifier,  and a sludge storage tank.

Reverse Osmosis

Purpose:      Wastewater polishing.

Design Basis: Reverse osmosis system including unit with membranes, influent wastewater
              storage tanks, and flooded suction tank.

Sludge Dewatering

Purpose:      Reduce biological treatment sludge volume by removing water.

Design Basis: Sludge is dewatered in in-line wastewater plate-and-frame filter press described
              above.
                                           9-29
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                                                   Section 9.0 - Development of Control and Treatment Options

              In the Agency's survey of the industry, EPA identified only one facility

discharging to a POTW in this subcategory.  Therefore, EPA does not propose to establish PSES

limitations for the Barge/Chemical & Petroleum Subcategory. However, EPA is proposing to

establish PSNS limitations.
9.6.4
PSES Options for the Truck/Food, Rail/Food, and Barge/Food
Subcategories
              PSES Options for the Truck/Food, Rail/Food, and Barge/Food Subcategories

include the following technology bases in addition to the common technology option elements

discussed in Section 9.1.1.


Option 1:     Oil/Water Separation

Option 2:     Oil/Water Separation, Equalization, Biological Treatment, and Sludge Dewatering


The purpose and design bases of the components of these technology options are described

below. These technologies are also described in further detail in Section 8.3.


Oil/Water Separation

Purpose:      Removal of low to moderate amounts of insoluble oil.

Design Basis: Gravity separator with 6.4-day residence time for wastewater equalization and oil,
              water, and solids separation. Includes two separation tanks in series with an  oil
              removal pump and an oil storage tank.

Equalization

Purpose:      Reduce wastewater variability and accumulate wastewater to optimize subsequent
              treatment system size and operating costs.

Design Basis: Eight-day residence time. Includes aerators/mixers to homogenize wastewater.
                                          9-30
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                                                   Section 9.0 - Development of Control and Treatment Options
Biological Treatment
Purpose:      Biologically decompose organic constituents.
Design Basis:  Activated sludge biological treatment system with a 4.6-day residence time.
              Includes two preaeratiori tanks in series and a sludge storage tank.
Sludge Dewatering
Purpose:      Reduce biological treatment sludge volume by removing water.
Design Basis:  Plate-and-frame filter press for wastewater filtration. Generates dewatered sludge
              at 32.0% solids.  Includes diatomaceous earth mix tank.
              In the Agency's engineering assessment of pretreatment of wastewaters for the
Truck/Food, Rail/Food, and Barge/Food Subcategories, EPA considered the types and
concentrations of pollutants found in raw wastewaters in this subcategory. As expected, food
grade facilities did not discharge significant quantities of toxic pollutants to POTWs.  In addition,
conventional pollutants present in the wastewater were found at concentrations that are amenable
to treatment at a POTW.  As a result, EPA is proposing not to establish pretreatment standards
for any of the food subcategories.
9.6.5
PSES Options for the Truck/Petroleum and Rail/Petroleum
Subcategories
              PSES options for the Truck/Petroleum and Rail/Petroleum Subcategories include
the following technology bases in addition to the common technology option elements discussed
in Section 9.1.1.
Option 1:     Equalization, Oil/Water Separation, and Chemical Precipitation
Option 2:     Zero Discharge Based on Equalization, Oil/Water Separation, and Activated
              Carbon Adsorption Followed by Total Wastewater Recycle/Reuse
                                          9-31
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                                                   Section 9.0 - Development of Control and Treatment Options
The purpose and design bases of the components of these technology options are described
below. These technologies are also described in further detail in Section 8.3.
Equalization
Purpose:
Reduce wastewater variability and accumulate wastewater to optimize subsequent
treatment system size and operating costs.
Design Basis: Minimum 12-hour residence time. Includes aerators/mixers to homogenize
              wastewater.
Oil/Water Separation
Purpose:      Removal of entrained oil and grease.
Design Basis: Vertical tube coalescing separator with rotary oil skimmer. Includes demulsifier
              chemical additive, oil storage tank, and sludge storage tank.
Chemical Precipitation
Purpose:      Removal of dissolved metals and entrained solid or liquid particles.
Design Basis: Batch chemical precipitation unit including chemical feed systems, agitator,
              control system, pH adjustment, and sludge storage tank.
Activated Carbon Adsorption
Purpose:      Wastewater polishing.
Design Basis: One 200-lb carbon column with nominal carbon change-out frequency of at least
              one vessel per 17,000 gallons of treated wastewater. Includes initial carbon
              cartridge of 200 Ib/vessel.

              EPA estimates that there are 38 facilities in the Truck/Petroleum and
Rail/Petroleum Subcategories. EPA estimates that these facilities discharge a total of 28 pound
equivalents to the nation's waterways, or less than one pound equivalent per facility.
Additionally, EPA estimates that the total cost to the industry to implement PSES would be
greater than $600,000 annually.  The estimated costs to control the discharge of these small
amounts of pound equivalents were not considered to be reasonable. Based on this analysis, EPA
                                           9-32
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                                                  • Section 9.0 - Development of Control and Treatment Options
preliminarily concluded that there is no need to develop nationally applicable regulations for
these subcategories due to the low levels of pollutants discharged by facilities in these
subcategories.

              Based on these factors, EPA proposes not to establish pretreatment standards for
the Truck/Petroleum or Rail/Petroleum Subcategories.
9.6.6
PSES Options for the Truck/Hopper, Rail/Hopper, and
Barge/Hopper Subcategories
              PSES options for the Truck/Hopper, Rail/Hopper, and Barge/Hopper
Subcategories include the following technology bases in addition to the common technology
option elements discussed in Section 9.1.1.

Option 1:     Gravity Separation

The purpose and design bases of the components of this technology option are described below.
This technology is also described in further detail in Section 8.3.

Gravity Separation
Purpose:      Removal of suspended solids.
Design Basis: Gravity separator with 4-day residence time for wastewater equalization and
              solids separation. Includes two separation tanks in series.
              EPA estimates that there are 42 indirect discharging hopper facilities.  EPA
estimates that these facilities discharge a total of 3.5 pound equivalents to the nation's
waterways, or less than one pound equivalent per facility. Additionally, EPA estimates that the
total cost to the industry to implement 3?SES would be greater than $350,000 annually. The
estimated costs to control the discharge of these small amounts of pound equivalents were not
considered to be reasonable.
                                          9-33
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                                                  Section 9.0 - Development of Control and Treatment Options
             EPA is not proposing to establish BAT limits for any priority pollutant in the
hopper subcategories. EPA did, however, look at the levels of pollutants in raw wastewaters and
concluded that none were present at levels that are expected to cause inhibition of the receiving
POTW. Based, on these factors, EPA proposes not to establish pretreatment standards for the
Truck/Hopper, Rail/Hopper, or Barge/Hopper Subcategories
9.7
Pretreatment Standards for New Sources (PSNS)
              Section 307 of the CWA requires EPA to promulgate both pretreatment standards
for new sources and new source performance standards. New indirect discharging facilities, like
new direct discharging facilities, have the opportunity to incorporate the best available
demonstrated technologies including: process changes, in-facility controls, and end-of-pipe
treatment technologies.
9.7.1
PSNS Options for the Truck/Chemical Subcategory
              EPA is proposing to establish pretreatment standards for new sources in the
Truck/Chemical Subcategory equivalent to the PSES standards.. In this subcategory, EPA
identified no technology that can achieve greater removals than PSES. Therefore, EPA is
proposing pretreatment standards for those pollutants which the Agency has determined to pass
through a POTW equivalent to PSES.
9.7.2
PSNS Options for the Rail/Chemical Subcategory
              EPA evaluated PSES Options 2 and 3 as more stringent levels of control that may
be appropriate for new indirect sources. The cost implications anticipated for new sources are
not as severe as those projected for existing sources. By utilizing good heel removal and
management practices which prevent pollutants from entering waste streams, and good water
conservation practices in the design of new facilities, treatment unit size can be substantially
reduced and treatment efficiencies improved.  As a result, costs of achieving PSES Option 2 and

                                          9-34
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                                                   Section 9.0 - Development of Control and Treatment Options
3 can be significantly reduced at new facilities. All of the technologies considered have been
demonstrated at an existing zero discharge rail/chemical facility. EPA anticipates no barrier to
entry for new sources employing these technologies at lower cost.

              Therefore, EPA is proposing PSNS for those pollutants which the Agency has
determined to pass through a POTW based on PSES Option 3.  PSES Option 3 consisted of
oil/water separation, equalization, dissolved air flotation (with flocculation and pH adjustment),
organo-clay/activated carbon adsorption, and sludge dewatering.
9.7.3
PSNS Options for the Barge/Chemical & Petroleum
Subcategory
              Although the Agency is not proposing to establish PSES for the Barge/Chemical
& Petroleum Subcategory, EPA did evaluate best available technologies for PSNS.  EPA
evaluated the PSES Options for determining levels of control that may be appropriate for new
indirect sources.

              EPA is not proposing to establish PSNS based on PSES Option 3 because reverse
osmosis was not considered to be the best demonstrated technology due to the small incremental
removals achieved by this option, the lack of additional water quality benefits potentially
achieved by this option, the potential issue of disposing the liquid concentrate created by
treatment, and the high level of pollutant control achieved by the proposed BAT option.
              EPA is proposing to establish PSNS based on PSES Option 2 because of the
removals achieved through this option. The raw wastewater in this Subcategory contains
significant amounts of decomposable organic materials. These materials may not be treated as
efficiently as the proposed technology option in a conventional POTW because a POTW may not
be acclimated to this particular wastewater stream. In this instance, pretreatment based on
biological treatment may be appropriate because the pollutant parameters that pass through, or
which may be present at levels that cause interference, will receive additional treatment not
                                          9-35
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                                                  Section 9.0 - Development of Control and Treatment Options
achieved by the POTW.  Several pollutants were determined to pass through a POTW and are
therefore proposed for PSNS regulation in the Barge/Chemical & Petroleum Subcategory.
9.7.4
PSNS Options for the Truck/Food, Rail/Food, and Barge/Food
Subcategories
             Based on the PSES analysis, EPA preliminarily concluded that there is no need to
develop nationally-applicable regulations for these subcategories due to the low levels of toxic
pollutants discharged by facilities in these subcategories.

             EPA has not identified any more stringent treatment technology option which it
considered to represent PSNS level of control and is therefore proposing not to establish PSNS
for any of the food subcategories.
9.7.5
PSNS Options for the Truck/Petroleum and Rail/Petroleum
Subcategories
              Based on the PSES analysis, EPA preliminarily concluded that there is no need to
develop nationally-applicable regulations for these subcategories due to the low levels of
pollutants discharged by facilities in this subcategory.  EPA proposes not to establish PSNS for
the Truck/Petroleum or Rail/Petroleum Subcategories.
9.7.6
PSNS Options for the Truck/Hopper, Rail/Hopper, and
Barge/Hopper Subcategories
              Based on the PSES analysis, EPA preliminarily concluded that there is no need to
develop nationally-applicable regulations for these subcategories due to the low levels of
pollutants discharged by facilities in this subcategory.  EPA proposes not to establish PSNS for
the Truck/Hopper, Rail/Hopper, and Barge/Hopper Subcategories.
                                         9-36
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                                                      Section 9.0 - Development of Control and Treatment Options
9.8
References1
1.
U.S. Environmental Protection Agency, Office of Water.  Statistical Support
Document of Proposed Effluent Limitations Guidelines and Standards for the
Transportation Equipment Cleaning Category. EPA-821-B-98-014, May 1998.
1 For those references included in the administrative record supporting the proposed TECI rulemaking, the
  document control number (DCN) is included in parentheses at the end of the reference.

                                             9-37
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                           Section 9.0 - Development of Control and Treatment Options
                Table 9-1
Subcategory-Specific Regulatory Flow
Subcategory
Truck/Chemical
Rail/Chemical
Barge/Chemical & Petroleum
Truck/Food
Rail/Food
Barge/Food
Truck/Petroleum
Rail/Petroleum
Truck/Hopper
Rail/Hopper
Barge/Hopper
Regulatorjrllow s-
' ' {gallons/tank)^
605
2,091
4,857
790
4,500
4,500
193
193
144
267
712
                 .  9-38
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10.0
                                       Section 10.0 - Costs of Technology Bases for Regulations

COSTS OF TECHNOLOGY BASES FOR REGULATIONS
              This section describes the methodology used to estimate the implementation costs

associated with each of the regulatory options under consideration for the Transportation

Equipment Cleaning Industry (TECI). Section 9.0 describes in detail the regulatory options and

the technologies used as the bases for those options. The cost estimates presented in this section,

together with the pollutant reduction estimates described in Section 11.0, provide a basis for

evaluating the regulatory options and determining the economic impact of the proposed

regulation on the TECI.  The results of the economic impact assessment for the regulation are

found in the Economic Assessment (EA) for the TECI proposed rulemaking (1).


              EPA used the following approach to estimate compliance costs for the TECI:
                     EPA mailed Detailed Questionnaires to a statistical sample of
                     transportation equipment cleaning (TEC) facilities (discussed in Section
                     3.2.3).  Information from the 93 facilities that responded to the
                     questionnaire, discharge TEC wastewater, and are not covered by other
                     effluent guidelines (see Section 3.2.3.4) was used to characterize industry-
                     wide TEC operations, operating status, and pollutant control technologies
                     in place for the baseline year (1994). EPA also used information from
                     Screener Questionnaire responses (discussed in Section 3.2.2) and other
                     sources for four direct discharging facilities to characterize the baseline'for
                     direct dischargers in two industry subcategories (see Section 10.1.2).

                     EPA collected and analyzed field sampling data to determine the pollutant
                     concentrations of untreated wastewater in the TECI (discussed in
                     Section 6.0).

                     EPA identified candidate pollution prevention and wastewater treatment
                     technologies and grouped appropriate technologies into regulatory options
                     (discussed in Section 9.0).  The regulatory options serve as the bases of
                     compliance cost and pollutant loading calculations.

                     EPA performed sampling episodes at best performing facilities to
                     determine pollutant removal performance for the identified technologies
                     (see Section 11.0).
                                           10-1
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                                                     Section 10.0 - Costs of Technology Bases for Regulations

                     EPA developed cost equations for capital and operating and maintenance
                     (O&M) costs for each technology included in the regulatory options
                     (discussed in Section 10.2.4) based on information gathered from TEC
                     facilities, wastewater treatment system vendors, and technical literature,
                     and on engineering judgement.

                     EPA developed and used a computerized cost model to estimate
                     compliance costs (discussed in Section 10.3) and pollutant loadings
                     (discussed in Section 11.0) for each regulatory option.

                     EPA used output from the cost model to estimate total annualized costs,
                     cost-effectiveness values, and the economic impact of each regulatory
                     option on the TECI (presented in the EA).

                     EPA estimated industry-wide costs for the various subcategories and
                     technology options by estimating compliance costs at 93 model sites and
                     then using statistically calculated weighting factors to extrapolate the
                     results to the estimated 692 TEC facilities that fall within the scope of the
                     rule.
              EPA estimated facility compliance costs for 24 unique technology options.
Table 10-1 lists the number of technology options for which EPA estimated facility compliance

costs.


              The following information is discussed in this section:


              •      Section 10.1:  Development of model sites;

              •      Section 10.2: Methodology used to estimate compliance costs;

              «      Section 10.3: Design and cost elements for pollutant control
                     technologies;

              •      Section 10.4: Summary of estimated compliance costs by regulatory
                     option; and

              •      Section 10.5: References.
                                           10-2
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                                                      Section 10.0 - Costs of Technology Bases for Regulations
10.1
Development of Model Sites
              This section describes the development of the key inputs to the TECI cost model:

model sites and pollutant control technologies.
10.1.1
Model Site Development
              The Agency used a model site approach to estimate regulatory compliance costs

for the TECI.  A model site is an operating TEC facility whose data were used as input to the
TECI cost model. A total of 93 facilities were used as model sites for the cost analysis because

each meets the following criteria:
                     The facility discharges TEC process wastewater either directly to surface
                     waters or indirectly to a publicly-owned treatment works (POTW); and

                     The facility supplied sufficient economic and technical data to estimate
                     compliance costs and assess the economic impacts of these costs.  Such
                     data include daily flow rate, operating schedules, tank cleaning production
                     and types of tanks cleaned, existing treatment in place,  and economic
                     status for the base year 1994.
              As discussed in Section 3.2.3, EPA mailed Detailed Questionnaires to a statistical
sample of TEC facilities. EPA evaluated each of the 176 respondents to determine whether the
facility would be potentially affected by the regulatory options considered by the Agency and
would therefore incur costs as a result of potential proposed regulations. Eighty-three facilities

would not incur costs because:
                     The facility is subject to other Clean Water Act final or proposed
                     categorical standards and thus would not be subject to the limitations and
                     standards under the proposed approach for this guideline (34 facilities); or

                     The facility is a zero or alternative discharging facility (i.e., does not
                     discharge TEC wastewater either directly or indirectly to a surface water)
                                           10-3
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                                                      Section 10.0 - Costs of Technology Bases for Regulations
                     and thus would not be subject to the limitations and standards for this
                     guideline (49 facilities).
              Each of the 93 facilities is considered a "model" facility since it represents a larger
number of facilities in the overall industry population as determined by its statistical survey
weight. The Statistical Support Document (2) discusses in detail the development of the survey
weights. These facilities represent an estimated industry population of 692 facilities that
discharge either directly to surface waters or indirectly to a POTW. EPA selected a facility-by-
facility model approach to estimate compliance costs, as opposed to a more general modeling
approach, to better characterize the variability of processes and resultant wastewaters among
TEC facilities.

              Although EPA estimated regulatory compliance costs on a facility-by-facility
basis, EPA made certain engineering assumptions based on information from standard
engineering costing publications, equipment vendors, and industry-wide data. Thus, for any
given model facility (or facilities represented by the model facility), the estimated costs may
deviate from those that the facility would actually incur. However, EPA considers the
compliance costs to be accurate when evaluated on an industry-wide, aggregate basis.
10.1.2
Supplemental Model Site Development
              EPA reviewed the 93 model facilities and identified direct dischargers in two
subcategories (Barge/Chemical & Petroleum and Barge/Hopper), but none in the remaining
subcategories. To assess the need to develop limitations and standards for direct dischargers for
the remaining subcategories, EPA reviewed the Screener Questionnaire sample population to
identify direct discharging facilities that would be subject to these regulations. This review
identified the following direct dischargers by subcategory:
                     Truck/Chemical (three facilities in sample population);
                     Rail/Chemical (one facility in sample population);
                                            10-4
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                                                       Section 10.0 - Costs of Technology Bases for Regulations
              •      Truck/Food (two facilities in sample population); and
              •      Barge/Food (one facility in sample population).

              EPA decided to estimate compliance costs for direct dischargers in the
Truck/Chemical and Rail/Chemical Subcategories for the following reasons:
                     Regulatory options considered for direct and indirect dischargers differ
                     (i.e., regulatory options for direct dischargers include biological treatment
                     while those for indirect dischargers do not); and
                     Dissimilar regulatory options may result in significantly different
                     estimated compliance costs.
              Technical information required to estimate compliance costs for these facilities
was obtained from the Screener Questionnaire responses, telephone conversations with facility
personnel, and facility NPDES permits.

              Note that the estimated compliance costs for these direct dischargers are not added
to the costs estimated for the 93 model sites (described in Section 10.1) to obtain industry-wide
cost estimates. Statistically, compliance costs for these direct dischargers are included within the
industry-wide cost estimates based on the 93 model facilities. Therefore, EPA used estimated
compliance costs for these direct dischargers only to characterize this segment of the industry
further and to evaluate whether limitations and standards for these facilities are warranted.  .

              EPA estimates that the compliance costs for direct dischargers in the food grade
subcategories will be zero or insignificant for the following reasons:
                     All facilities identified by EPA currently operate biological treatment and
                     are believed to currently achieve the proposed limitations; and
                     EPA assumes that current NPDES permits for these facilities require
                     frequent monitoring for pollutant parameters regulated by this guideline
                     (i.e., BOD5, TSS, and oil and grease). Therefore, these facilities will not
                     incur additional monitoring costs as a result of this proposed rulemaking.
                                            10-5
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                                                     Section 10.0 - Costs of Technology Bases for Regulations


              Based on this assessment, EPA believes that developing model sites in the TECI
cost model for direct discharging food grade facilities is not necessary.
10.1.3
Pollutant Control Technology Development
              EPA evaluated Screener and Detailed Questionnaire responses to identify
applicable pollution prevention and wastewater treatment technologies for the TECI and to select
facilities for EPA's TECI site visit and sampling program. EPA conducted 39 engineering site
visits at 38 facilities to collect information about TEC processes, water use practices, pollution
prevention practices, wastewater treatment technologies, and waste disposal methods. Based on
the information gathered from these site visits, EPA sampled untreated and/or treated wastewater
streams at 18 facilities.  Sections 3.3 and 3.4 discuss in more detail the engineering site visit and
sampling program conducted as part of the TECI rulemaking.

              In most cases, the specific pollutant control technologies costed, including
equipment, chemical additives and dosage rates, and other O&M components, are the same as
those operated by the facilities whose sampling data are used to represent the performance
options, with adjustments made to reflect differences in wastewater flow rates or other facility-
specific conditions. For example, BPT options for the Truck/Chemical Subcategory include
oil/water separation and are specifically based on a vertical tube coalescing separator similar to
that characterized during wastewater sampling. Therefore, EPA's estimated compliance costs are
based upon implementation of a vertical tube coalescing separator. EPA chose this approach to
ensure that the technology bases of the regulatory options can achieve the proposed limitations
and standards and that the estimated compliance costs reflect implementation of these technology
bases. EPA believes this approach overestimates the compliance costs because many facilities
can likely achieve the proposed limitations and standards by implementing less expensive
pollution prevention practices, substituting less expensive alternative equipment, or utilizing
equipment in place that EPA did not assess as equivalent to the technology basis (see
Section 10.2.5 for more detail on treatment-in-place credits).

                                           10-6
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                                                      Section 10.0 - Costs of Technology Bases for Regulations
              EPA emphasizes that the proposed regulations do not require that a facility install
or possess these technologies, but only that the facility comply with the appropriate effluent
limitations and standards.
10.1.4
Model Sites with Prodmction in Multiple Subcategories
              Some model facilities have production in more than one subcategory.  For
example, a facility that cleans both tank trucks and rail tank cars that last transported chemical
cargos has production in both the Truck/Chemical and Rail/Chemical Subcategories. To simplify
compliance costs and pollutant reduction estimates, EPA assigned each multiple-subcategory
facility a primary subcategory. For these facilities, compliance costs and pollutant reduction
estimates for all facility production are assigned to the primary subcategory. This methodology
may bias the subcategory cost and pollutant reduction estimates on a facility-by-facility basis;
however, EPA believes that subcategory costs and pollutant reduction estimates are accurate on
an aggregate basis (i.e., individual facility biases are offset within each subcategory in aggregate).

              This simplification is necessary because the technology bases of the regulatory
options differ for each subcategory. EPA considered an alternative approach that included
designing separate treatment systems for subcategory-specific wastewater based on the
subcategory regulatory options. However, to comply with the proposed regulations, a facility can
implement any technology it chooses, provided it achieves the effluent limitations. Installation
of two (or more) separate treatment systems is not a practical or cost-effective solution to comply
with the proposed regulations. Therefore, EPA rejected this alternative approach.
              Compliance costs and pollutant reduction estimates for individual facilities that
clean multiple tank types are based on the assumption that facilities will install and operate the
technologies chosen as the technology basis for each facility's primary subcategory. EPA does
not have data available demonstrating that the technologies costed to treat each primary
subcategory will effectively treat wastewaters from all potential secondary Subcategories.  For
example, EPA does not have data available on the performance of the Truck/Chemical

                                            10-7
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                                                     Section 10.0 - Costs of Technology Bases for Regulations
Subcategory, technology basis in treating Rail/Chemical Subcategory wastewater.  However, EPA
believes that the costed technology for the Truck/Chemical Subcategory option will control all
pollutants of concern in all TEC wastewaters generated by each facility because the control
technologies included in the different technology bases use similar pollutant removal
mechanisms (e.g., chemical/physical treatment, secondary biological treatment, and advanced
treatment for wastewater polishing).

              For these reasons, EPA believes that its costing methodology for multiple-
subcategory facilities is appropriate and adequately represents the compliance costs and pollutant
reductions estimated at these facilities.
10.2
Costing Methodology
              To accurately determine the impact of the proposed effluent limitations guidelines
and standards on the TECI, EPA estimated costs associated with regulatory compliance.  The
Agency developed a cost model to estimate compliance costs for each of the regulatory options
under BPT, BCT, BAT, PSES, PSNS, and NSPS. EPA used the cost model to estimate costs
associated with implementation of the pollutant control technologies used as the basis for each
option.  Again, the proposed regulations do not require that a facility install and possess these
technologies but only that the appropriate facility effluent limitations and standards be achieved.
10,2.1
Wastewater Streams Costed
              Based on information provided by the sites in their Detailed Questionnaire (or
Screener Questionnaire in the case of the four direct dischargers without a Detailed
Questionnaire), follow-up letters, and telephone calls, EPA classified each wastewater steam at
each site as TEC interior cleaning wastewater, other TEC commingled wastewater stream, or
non-TEC wastewater. The following additional questionnaire data were used to characterize
wastewater streams:
                                          10-8
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                                                     Section 10.0 - Costs of Technology Bases for Regulations
              •      Flow rate;
              •      Production rate (i.e., types and number of tanks cleaned); and
              •      Operating schedule.

              EPA first reviewed wastewater streams discharged by each facility and classified
these streams as interior cleaning wastewater or other commingled wastewater stream. Facilities
that clean tanks representing multiple modes of transportation (e.g., road, rail, or inland
waterway) or that clean both tanks and closed-top hoppers are considered to have multiple
wastewater streams. However, as discussed in Section 10.1.4, these facilities are assigned a
primary subcategory, and the TECI cost model costs the flow contribution of wastewater from
any secondary subcategory as primary subcategory wastewater.

              For costing purposes, TEC wastewater consists of tank interior cleaning
wastewater and other -commingled wastewater streams not easily segregated.  Examples of
interior cleaning wastewater are water, condensed steam, prerinse cleaning solutions, chemical
cleaning solutions, and final rinse solutions generated from cleaning tank and container interiors.
Examples of other commingled waste streams not easily segregated are tank or trailer exterior
cleaning wastewater, TEC-contaminated stormwater, boiler blowdown, safety equipment
cleaning wastewater, bilge and ballast waters, and other non-TEC wastewater streams that are
commingled with TEC wastewaters. Incidental and non-TEC wastewater streams are included in
developing the compliance costs because these streams are difficult or costly to segregate and
treat separately from TEC wastewater.

              Wastewater streams not considered in developing compliance costs include
sanitary wastewater; tank hydrotesting wastewater; and repair, rebuilding, and maintenance
wastewater. These wastewater streams are not costed for treatment because they fall under the
scope of another rulemaking or they do not fall within the scope of the TECI rulemaking, and
they are generally easily segregated from TEC wastewaters.
                                           10-9
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                                                     Section 10.0 - Costs of Technology Bases for Regulations
10.2.2
Influent Pollutant Concentrations
              The concentration of each pollutant in each model site TEC wastewater stream
was estimated using field sampling pollutant loadings data for wastewater discharged by tank
type.  Section 3.4 discusses the field sampling program. These data are used with Detailed or
Screener Questionnaire flow, tank cleaning production, and operating data to calculate the
influent concentrations.  Section 11.0 describes these calculations in more detail.
10.2.3
Cost Model Development
              EPA developed a computerized design and cost model to estimate compliance
costs and pollutant reductions for the TECI technology options. EPA evaluated the following
existing cost models from other EPA effluent guidelines development efforts to be used as the
basis for the TECI cost model:
                    Metal Products and Machinery (MP&M) Phase I Industries Design and
                    Cost Model; and
                    Pharmaceuticals Industry Cost Model.
EPA incorporated modified parts of both models in the TECI cost model.

              The TECI cost model contains technology "modules," or subroutines; each
module calculates direct capital and annual costs for installing and operating a particular
wastewater treatment or pollution reduction technology. In general, each module is exclusive to
one control technology.  For each regulatory option, the TECI cost model combines a series of
technology modules. There are also module-specific "drivers" (technology drivers) that operate
in conjunction with the technology modules.  These drivers access input data, run the
corresponding modules, and populate output databases.  The technology drivers are bound
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                                                      Section 10.0 - Costs of Technology Bases for Regulations
together by primary drivers, which run the technology drivers in the appropriate order for each
regulatory option.

              EPA adapted the MP&M cost model drivers for the TECI cost model with the
following modifications:
                     Costs are tracked by subcategory. The MP&M cost model was not
                     designed to develop separate costs and loads by subcategory.
                     All data values calculated by the cost model are stored in an output
                     database file. This allows the cost model user to examine the importance
                     of each calculated value for each technology module.
              The input data to the cost model include production data (i.e., types and number
of tanks cleaned), wastewater flow, existing technology in place, operational hours per day, and
operational days per year. EPA obtained the flow rates, operating schedules, production data, and
existing treatment-in-place data from Detailed Questionnaire responses from each facility (and
other data sources for supplemental facilities, as discussed in Section 10.1.2). These data
comprise the input data for the technology modules. Each module manipulates the input data
(stored in data storage files) to generate output data (stored in different data storage files), which
represent costs incurred by implementing the costed technology. The output data storage files
become the input data storage files for subsequent technology modules, enabling the cost model
to track operating hours per day and da>ys per year, flows, and costs for subsequent modules.
 10.2.4
Components of Compliance Costs
              EPA used the TECI cost model to calculate capital costs and annual O&M costs
 for each technology and to sum the capital and O&M costs for all technologies at each facility.
 Capital costs comprise direct and indirect costs associated with the purchase, delivery, and
 installation of pollutant control technologies. Annual O&M costs comprise all costs related to
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                                                      Section 10.0 - Costs of Technology Bases for Regulations
operating and maintaining the treatment system for a period of one year, including the estimated
costs for compliance monitoring of the effluent. O&M costs typically include the following:

              •      Operational labor;
              •      Maintenance and repair labor;
              •      O&M materials;
              •      Chemicals, filters, and other items consumed in the routine operations of
                     the treatment system;
              •      Utilities such as water usage and electricity required to power the
                     treatment system;
              •      Removal, transportation, and disposal of any waste solids, sludges, oils, or
                     other wastes generated by the treatment system; and
              •      Analytical monitoring.
10.2.4.1
Capital Costs
              The TECI cost model uses the cost equations listed in Table 10-2 to estimate the
direct capital costs for purchasing, delivering, and installing equipment included in the
technology bases for each regulatory option. Where possible, cost sources (i.e., vendors) provide
all three cost components for varying sized equipment.  Where a vendor quote is not available,
literary references or estimates based on engineering judgement are used to estimate direct capital
cost. Direct capital costs consist of the following:

              •      Purchase of treatment equipment and any accessories;
              •      Purchase of treatment equipment instrumentation (e.g., pH probes, control
                     systems);
              •      Installation costs (e.g., labor and rental fees for equipment such as cranes);
                                           10-12
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                                                       Section 10.0 - Costs of Technology Bases for Regulations

                     Delivery cost based on transporting the treatment system an average of 500
                     miles;

                     Construction of buildings or other structures to house major treatment
                     units (e.g., foundation slab, enclosure, containment, lighting and electricity
                     hook-ups); and

                     Purchase of necessary pumps (e.g., for wastewater transfer, chemical
                     addition, sludge handling).
              Direct capital costs consist of technology-specific equipment capital costs that are

estimated by the TECI cost model.  Indirect capital costs are not technology-specific and are

instead represented as a multiplication factor that is applied to the direct capital costs in the post-

processing portions of the TECI cost model. Indirect capital costs typically include the

following:
                     Purchase and installation of necessary piping to interconnect treatment
                     system units (e.g., pipe, pipe hangers, fittings, valves, insulation, similar
                     equipment);

                     Engineering costs (e.g., administrative, process design and general
                     engineering, communications, consultant fees, legal fees, travel,
                     supervision, and inspection of installed equipment);

                     Secondary containment and land costs;

                     Excavation and site work (e.g., site clearing, landscaping, fences,
                     walkways, roads, parking areas);

                     Construction expenses (e.g., construction tools and equipment,
                     construction supervision, permits, taxes, insurance, interest);

                     Contingency (e.g., allocation for unpredictable events such as foul
                     weather, price changes, small design changes, and errors in estimates); and

                     Contractors' fees.
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                                                     Section 10.0 - Costs of Technology Bases for Regulations
              For each technology, EPA accounted for indirect capital costs by applying a cost
factor related to the purchased, shipped, and installed capital cost.  The total capital investment
(direct and indirect capital cost) is obtained by multiplying the direct capital cost by the indirect
capital cost factor. Table 10-3 (at the end of this section) presents the components of the total
capital investment, including the indirect capital cost factor used by the cost model.

              Capital cost equations relate direct capital cost to equipment design parameters,
such as wastewater flow. Equipment component designs are generally based upon the equipment
operated by the facilities whose sampling data are used as the basis for the technology options.
To relate the design of the equipment operated by the sampled facility to that required by the
costed facilities, the TECI cost model typically uses a "design equation." For example, a
sampled facility  with a nominal wastewater flow rate of 50 gpm operates a 65-gpm dissolved air
flotation (DAF) unit. The design equation developed for the DAF unit is:
           DAFGPM = INFGPM x f — 1  = INFGPM x 1.3
                                    I 50]
                                                   (1)
where:
              DAFGPM
              INFGPM
DAF unit nominal capacity (gpm)
Influent flow rate (gpm)
In this example, the equipment design parameter for the DAF unit is the facility's wastewater
flow rate, and the equipment costing parameter is the DAF unit's nominal capacity.
              Cost equations are used throughout the TECI cost model to determine direct
capital costs. For a given equipment component, a cost curve is developed by plotting different
equipment sizes versus direct capital costs. Equipment sizes used to develop the cost equations
correspond to the range of sizes required by the costed facilities based on an influent flow rate or
volume requirement.  The cost/size data point pairs are plotted and an equation for the curve that
provides the best curve fit for the plotted points with the least standard error is calculated.  The
equations calculated to fit the cost curves are most commonly polynomial, but may be linear,
exponential, or logarithmic.
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                                                     Section 10.0 - Costs of Technology Bases for Regulations
              Because of the variability in wastewater flow rates at TEC facilities, equipment
design equations estimate that some facilities would require very small pieces of equipment. In
some instances, EPA determined that very small equipment is either not commercially available
or not technically feasible. In these cases, the facility is costed for the smallest equipment size
that is both commercially available and technically feasible. For wastewater streams requiring
equipment with a capacity above the maximum-sized unit commercially available and technically
feasible, multiple units of equal capacity are designed to operate in parallel.
10.2.4.2
Annual Costs
              Annual cost components include costs for operational labor, maintenance and
repair labor, operating and maintenance materials, electricity, treatment chemicals, filter
replacements, disposal of treatment system residuals, and monitoring.

              Annual costs typically are not estimated using cost curves. Operational,
maintenance, and repair labor are estimated as a labor time requirement per equipment
component or a fraction of the total operational hours per day and operational days per year for
the costed facility. Labor time is converted to a constant labor cost used throughout the TECI
cost model. The TECI cost model uses the wage rate specified in The Richardson Rapid System
Process Plant Construction Estimating Standards (3) for installation workers in 1994 ($25.90 per
hour) for all required labor to install, operate, and maintain the systems associated with the
technology bases.  Electricity costs are based on operating time and required horsepower, which
are converted to electricity costs using a standard rate used throughout the TECI cost model. The
TECI cost model uses the average cost for electricity of $0.047 per KW-hr from the MP&M cost
model (4). Chemical addition feed rates, filter replacements, and wastewater treatment residual
generation rates are generally based on wastewater flow rate. These rates are converted to costs
using unit cost data (e.g., $/weight) provided by chemical vendors and waste disposal facilities.
The TECI cost model uses water rates from the 1992 Rate Survey of Water and Wastewater
conducted by Ernst and Young (5).  The water rate is adjusted from the 1992 rate of $2.90 per
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                                                      Section 10.0 - Costs of Technology Bases for Regulations
1,000 gallons to the 1994 rate of $2.98 per 1,000 gallons using the capital investment index
discussed later in this section.

              Table 10-4 presents the O&M unit costs used by the cost model and includes
references for the origin of each cost.
              EPA adjusted water fees and monitoring costs calculated by the cost model to
1994 dollars because all facility-specific information in the questionnaire database is from 1994.
This adjustment allows direct comparison between financial data reported in the Detailed
Questionnaire and calculated compliance costs for each facility. Costs are adjusted based on the
Chemical Engineering (CE) Plant Cost 1994 annual index and the index value for the year in
which costs were originally reported using the following formula (6):
where:
                                AC = OC
                              368.1^
                               OClJ
(2)
              AC    =
              OC    =
              OCI   =
              Adjusted cost, 1994 dollars
              Original cost, dollars
              Original cost year index
10.2.5
Treatment-in-Place Credit
              EPA evaluated facility responses to the Detailed Questionnaire to determine
whether pollutant control technologies are currently in place. These facilities are given credit for
having "treatment in place" to ensure that EPA accurately assesses the baseline (1994) costs and
pollutant loadings.  Where appropriate, these treatment credits are used to develop cost estimates
for system upgrades instead of costing for new systems. No costs beyond necessary additional
compliance monitoring are estimated for facilities currently using pollutant control technologies
with sufficient capacity equivalent to a regulatory option.
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                                                       Section 10.0 - Costs of Technology Bases for Regulations
              EPA reviewed questionnaire data for each model facility to assess the types of
end-of-pipe technologies in place at each site (e.g., oil/water separation, biological oxidation).
EPA identified end-of-pipe technologies on site that, based on technical consideration, are
considered equivalent to technologies included in the TECI technology options. For example,
belt filter presses are considered equivalent to plate-and-frame filter presses for sludge
dewatering. EPA also identified technologies that are not considered equivalent, and for which
no credit for treatment in place is given. For example, oil/water separator skimmers are not
considered equivalent to vertical tube oil/water coalescers.  Site-specific assumptions regarding
treatment in place at model sites are included in the administrative record for this rulemaking.

              EPA used operating schedule data and site-specific technology specifications from
the Detailed Questionnaire responses to assess the capacity of the end-of-pipe technologies in
place at the model sites. EPA assumed that each model site operates the technologies in place  at
full capacity at baseline (i.e., currently). Therefore, EPA used the operating schedule and
capacity of each technology as reported in the questionnaire to define its maximum operating
capacity. EPA uses the maximum operating capacity to assign facilities full  or partial treatment-
in-place credit. Partial treatment-in-place credit is assigned to facilities judged to not have
enough treatment capacity in place.

              Facilities receiving full treatment-in-place credit for a given technology are not
expected to incur additional capital or O&M costs. However, the facility may incur additional
costs for items not directly associated with the unit, such as monitoring costs. Facilities receiving
partial treatment-in-place credit incur additional capital and O&M costs under the proposed
regulatory options for an additional unit to treat the wastewater flow that is above the existing
unit's capacity.
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                                                     Section 10.0 - Costs of Technology Bases for Regulations
10.2.6
Calculation of Baseline Parameters
              As discussed in the previous section, EPA determined the treatment in place for
the costed facilities.  Before running the cost model for any of the technology options, a baseline
run of the model is performed to determine the following:

              •      Baseline (1994) annual costs incurred by each model site;
              •      Baseline non-water quality impacts, such as electricity usage, sludge and
                     solid waste generation, and waste oil generation; and
              •      Baseline pollutant loadings.

The baseline values for annual costs, non-water quality impacts, and pollutant loadings are
subtracted from the costs calculated for each technology option to estimate the incremental costs
of compliance with each regulatory option. EPA uses the incremental costs, non-water quality
impacts, and pollutant loadings to represent economic and environmental impacts of the
rulemaking.
10.2.7
Contract Haul in Lieu of Treatment
              For some facilities and regulatory options, particularly those with low flow rates,
contract hauling is less expensive than performing on-site treatment. For those facilities, EPA
estimates compliance costs based on contract hauling wastewater for off-site treatment instead of
the technology bases for the particular regulatory option.

              To assess contract hauling in lieu of treatment, EPA compares the net present cost
of contract hauling the wastewater to be treated to the net present cost of treating that wastewater
on site for each regulatory option (assuming 7% interest and a 15-year equipment life span for all
capital equipment). Capital and annual costs estimated for contract hauling wastewater include a
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                                                     Section 10.0 - Costs of Technology Bases for Regulations

wastewater storage tank, repair labor, O&M materials, and transport and off-site disposal of the

wastewater.
10.3
Design and Cost Elements for Pollutant Control Technologies
10.3.1
Cost Model Components
              The TECI cost model consists of several programming components, which can be

grouped into four major categories:


              •      Model shell programs;
              •      Primary model drivers;
              •      Data storage files; and
              •      Technology drivers and modules.


The model shell includes programs that create the various menus and user interfaces that accept
user inputs and pass them to the appropriate memory storage areas. The primary model drivers

are programs that access technology drivers in the appropriate order for each option and process

the model-generated data.  Data storage files are databases that contain cost model input and

output data.  Information typically stored in data storage files includes:
                     How, production, and operating data associated with each wastewater
                     stream;

                     Pollutant concentrations associated with each wastewater stream; and

                     Facility-specific data regarding existing technologies in place (discussed in
                     Section 10.2.5).
              Technology drivers and modules are programs that calculate costs and pollutant

loadings for a particular pollutant control technology.  EPA developed cost modules for the water

conservation practices and wastewater treatment technologies included in the regulatory options

for the TECI.

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                                                        Section 10.0 - Costs of Technology Bases for Regulations

               The technology drivers perform the following functions, as applicable, for each

 technology costed for a facility:


               •       Locate and open all necessary input data files;

               •       Store input data entered by the user of the model;

               •       Open and run the appropriate technology modules; and

               •       Calculate and track the following types of information generated by each
                      technology module:

                      —     Total direct capital costs,
                      —     Total direct annual costs,
                      —     Electricity use and associated cost,
                             Water use and associated cost,
                      —   .  Sludge generation and associated disposal costs,
                      —     Solid waste generation and associated disposal costs,
                      —     Waste oil' generation and associated disposal costs,
                      —     Effluent flow rate, and
                      —     Effluent pollutant concentrations.


              The following table lists the treatment technologies that are modeled in the cost

model.  Sections 10.3.2 through 10.3.21 discuss the technology modules.
CostMedole J
t^S S *s « > V-
Flow Reduction
Equalization
Oil/Water Separation (Vertical Tube Coalescing)
Oil/Water Separation (API)
Oil/Water Separation (Gravity)
Gravity Separation
Chemical Oxidation, Neutralization, Coagulation, Clarification
Dissolved Air Flotation (DAF) (with pH Adjustment and Chemical Addition)
DAF (No Chemical Addition)
Chemical Precipitation
- Section jfaaajlbee - ^
10.3.2
10.3.3
10.3.4
10.3.5
10.3.6
10.3.7
10.3.8
10.3.9
10.3.10
10.3.11
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                                                     Section 10.0 - Costs of Technology Bases for Regulations
Cost Modiile
Filter Press (For Wastewater Clarification and Sludge Dewatering)
Biological Treatment
Activated Carbon Adsorption (Vessels)
Activated Carbon Adsorption (Canisters)
Organo-Clay/Activated Carbon Adsorption
Reverse Osmosis
Sludge Dewatering
Contract Haul of Wastewater in Lieu of Treatment
Compliance Monitoring
Waste Hauling
Section Number *
10.3.12
10.3.13
10.3.14
10.3.15
10.3.16
10.3.17
10.3.18
10.3.19
10.3.20
10.3.21
10.3.2
Flow Reduction
              In this module, EPA estimates costs for a facility to install wastewater reduction
technologies in order to reduce the volume of wastewater generated per tank cleaned. The flow
reduction module design is based on the ratio of the current volume of wastewater generated per
tank cleaned to the target volume of wastewater generated per tank cleaned. The target volume of
wastewater generated per tank cleaned is the "regulatory flow" as discussed in Section 9.1. The
module compares the regulatory flow to the current flow and costs facilities for different flow
reduction technologies based on their subcategory and/or the magnitude of their ratio of
regulatory flow to current flow (the "flow ratio"). Facilities with a flow ratio less than or equal
to 1 (i.e., facilities generating less than the regulatory flow of wastewater per tank cleaned) are
not costed in the flow reduction module.

              Where the TECI cost model reduces facility wastewater flow rates through
volume reduction, specific capital and O&M costs are estimated to account for the costs those
facilities would incur to implement flow reduction technologies and practices.  Because of the
variation in tank types and cleaning practices between subcategories, the costs for implementing
flow reduction technologies are different for each subcategory.
                                          10-21
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                                                     Section 10.0 - Costs of Technology Bases for Regulations
              EPA bases the implementation costs for flow reduction on data received in
response to the TECI Detailed Questionnaire, technologies and practices observed during site
visits and sampling episodes at TEC facilities, information received from vendors on the flow
reduction technologies, and technical literature.  However, EPA does not have information
available for every costed facility to determine the extent to which flow reduction is achievable
and the exact equipment components and changes in standard operating procedures necessary to
achieve the flow reductions estimated by the cost model. Although the cost model estimates
costs incurred and wastewater volume reduction achieved by flow reduction, the costs and flow
reductions may not be completely accurate for every costed facility due to limitations in the
available data. However, EPA believes that the cost model accurately estimates the flow
reduction and associated costs for the industry as a whole.

              Capital and annual costs for the following equipment and practices listed below
are included in the flow reduction module:
                    Replacement tank cleaning system (Truck/Chemical, Rail/Chemical,
                    Truck/Food, Rail/Food, Truck/Petroleum, and Rail/Petroleum
                    Subcategories);
                    Two spinners - one high flow for cleaning solution and one low flow for
                    rinse (Truck/Chemical, Rail/Chemical, Truck/Food, Rail/Food,
                    Truck/Petroleum, and Rail/Petroleum Subcategories);
                    Excess heel disposal (Barge/Chemical & Petroleum, Barge/Food, and
                    Barge/Hopper Subcategories); and
                    Cleaning crew training and wastewater flow rate monitoring for all
                    Subcategories.
Annual costs include tank cleaning crew training, wastewater flow rate monitoring, and off-site
excess heel disposal for the Barge/Chemical & Petroleum, Barge/Food, and Barge/Hopper
Subcategories. Annual costs for operating a replacement tank cleaning system and spinners are
assumed to equal baseline costs for operating existing tank cleaning systems; therefore, no
                                          10-22
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                                                     Section 10.0 - Costs of Technology Bases for Regulations
additional annual costs are calculated in the cost module for implementing these technologies.
The flow reduction module does estimate additional capital costs for the Barge/Chemical &
Petroleum and Barge/Food Subcategories because EPA determined that additional capital
equipment is not necessary at these facilities to dispose of excess heel.  However, the flow
reduction module includes costs for the annual labor crew training and wastewater flow rate
monitoring associated with disposal of excess heel.
              The flow reduction module uses information from responses to the Detailed
Questionnaire on current wastewater generation per tank and the number of tanks cleaned along
with the regulatory flow (described in Section 9.0) to estimate the annual cost credits (i.e.,
negative annual costs) for savings from reduced water usage. The total volume of water saved is
shown by the following equation:
                          WS = (CWG x NT)  - (RFWG x NT)                       (3)
where:
              WS
              CWG
              NT
              RFWG
                    Water savings (gallons/year)
                    Current wastewater generated per tank cleaned (gallons)
                    Number of tanks cleaned per year
                    Regulatory flow wastewater generated per tank cleaned
                    (gallons) (see Table 9-1 for specific regulatory flows)
The volume of water saved is then multiplied by the cost of fresh water (as described in Section
10.2.4.2) to estimate monetary savings from reductions in wastewater use.
10.3.3
Equalization
              In this module, EPA estimates costs for a facility to install and operate an
equalization tank(s) to accumulate wastewater in order to reduce wastewater variability and to
optimize the size, effectiveness, and operating costs for the subsequent treatment units. The
required equalization tank size depends on a minimum wastewater residence time.  Minimum
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                                                      Section 10.0 - Costs of Technology Bases for Regulations
residence times vary by subcategpry (details provided in Section 9.0) based on the ratio of
equalization tank size to total wastewater flow rate as observed during EPA sampling episodes
and site visits. The equalization module calculates the costs necessary to operate an equalization
unit as well as to adequately mix wastewater.

              Capital and annual costs for the following equipment are included in the
equalization module:

              •      Equalization tank(s); and
              •      Aerators/mixer(s).

Annual costs include operational labor, maintenance and repair labor, O&M materials, and
electricity.  The costs associated with the equalization tank(s) are based on tank volume
necessary to perform adequate equalization of TEC wastewater, as observed during EPA site
visits and sampling episodes. The costs associated with the aerator/mixer(s) are based on the
motor horsepower required to adequately mix the wastewater in the equalization tank, as
observed during EPA site visits and sampling episodes.
10.3.4
Oil/Water Separation (Vertical Tube Coalescing)
              In this module, EPA estimates costs for a facility to install and operate a vertical
tube coalescing oil/water separator to remove entrained oil and grease.  The oil/water separation
module calculates the costs necessary to treat wastewater using a vertical tube coalescing
separator and a demulsifier that is added to the wastewater to aid in oil  separation. The module
also calculates the costs for removing, storing,  and disposing of floating oil and settled solids.

              Capital and annual costs for the following equipment are included in the vertical
tube coalescing oil/water separator module:
                     A demulsifier feed system (including a metered-flow pump and
                     demulsifier);

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                                                      Section 10.0 - Costs of Technology Bases for Regulations
              •       An influent wastewater transfer pump;
              •       An oil/water separator unit (including a water level probe and control
                     system);
              •       An oil storage tank;
              •       A sludge transfer pump; and
              •       A sludge storage tank.

Annual costs include operational labor, maintenance and repair labor, O&M materials,
electricity, raw materials (i.e., demulsifier), and oil and settled solids disposal. The oil/water
separator observed during EPA site visits and sampling episodes at TEC facilities is sized with
25% excess capacity due to fluctuations in daily wastewater flows. EPA likewise estimates
vertical tube coalescing oil/water separator costs based on a unit with a capacity that exceeds
daily wastewater flow rates by 25%.

              The demulsifier feed system costs are based on the feed rate of demulsifier
observed during EPA site visits and sampling episodes.  The costs associated with the
wastewater transfer and sludge transfer pumps are based on the horsepower necessary to pump
wastewater and sludge at the flow rates estimated by the oil/water separator module.

              The waste oil storage tank and sludge storage tank costs are based on tank
volume.  The oil storage tank is sized to hold the volume of oil collected over 10 operating days,
and the sludge storage tank is sized to hold the volume of sludge collected over a period of one
month.

              EPA assumes that floating oils will be disposed off site once every 10 facility
operating days and settled solids will be disposed off site once per month, based on observations
made during site visits and sampling episodes.  Waste disposal costs are calculated separately in
the waste haul module (see Section  10.3.21). The oil/water separator module calculates the
                                           10-25
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                                                     Section 10.0 - Costs of Technology Bases for Regulations
amount of oil to be disposed using the difference between the influent and effluent average total
oil and grease concentrations per day. The oil/water separator module calculates the amount of
sludge to be disposed using the difference between the influent and effluent average total
suspended solids concentrations per day. EPA assumes that the waste oil stream comprises 95%
oil and the settled solids stream comprises 4% solids, based on assumptions used in the MP&M
cost model.
10.3.5        Oil/Water Separation (American Petroleum Institute [API]
              Separator)
              In this module, EPA estimates costs for a facility to install and operate an API
oil/water separator to remove entrained oil and grease. The module calculates costs necessary to
operate an API separator with a slotted pipe surface oil skimmer, a fabric belt skimmer for
entrained thin oils, and a bottom sludge rake. The module also calculates the costs to remove,
store, and dispose of skimmed oils and settled solids.

              Capital and annual costs for the following equipment are included in the API
oil/water separator module:

              •      An API oil/water separator;
              •      A wastewater transfer pump;
              •      An oil storage tank; and
              •      A sludge storage tank.

Annual costs include operational labor, maintenance and repair labor, O&M materials,
electricity, and disposal of residual oil and settled solids. The API oil/water separator costs are
based on the ratio of API oil/water separator nominal capacity to wastewater flow rate observed
during EPA site visits and sampling episodes at TEC facilities. The unit nominal  capacity is four
times that needed to accommodate facility average daily wastewater flow rates to account for
fluctuations in daily wastewater flow and to allow for ample wastewater residence. The unit uses
two motors, a scraper/skimmer motor, and an oil collection belt skimmer motor. Electricity costs
                                          10-26
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                                                     Section 10.0 - Costs of Technology Bases for Regulations
are based on motor horsepower necessary to operate the scraper/skimmer and oil collection belt
skimmer.

              The wastewater transfer pump costs are based on the influent wastewater flow rate
for each facility. The pump is designed to operate at a flow rate of one-half the stated maximum
capacity of the pump. Electricity costs are based on motor horsepower necessary to transfer
wastewater at the flow rates estimated by the oil/water separator module.

              The waste oil storage tank and sludge storage tank costs are based on tank
volume.  The oil storage tank and the sludge storage tank are sized to hold the volume of oil and
the volume of sludge, respectively, collected over a period of one month.

              EPA assumes that floating oils and settled solids will be disposed off site once per
month (provided sludge dewatering is riot costed as part of the regulatory option) based on
observations made during site visits and sampling episodes. Waste disposal costs are calculated
separately in the waste haul module (see Section 10.3.21). The API oil/water separator module
calculates the amounts of oil and sludge to be disposed based on the ratios of the oil and sludge
generation rates to the facility wastewater flow rates observed during EPA site visits and
sampling episodes at TEC facilities.  If sludge dewatering is costed, the sludge is costed to be
pumped from the sludge storage tank to the filter press (the costs for the sludge pump are
included in the sludge dewatering module). EPA assumes that the waste oil stream comprises
95% oil and the settled solids stream comprises 4% solids, based on assumptions used in the
MP&M cost model.
10.3.6
Oil/Water Separation (Gravity)
              In this module, EPA estimates costs for a facility to install and operate a gravity
oil/water separator to remove floating oils from raw wastewater.  The module also calculates the
costs necessary to remove, store, and dispose of floating oils.  For the food subcategories, no oil
disposal costs are incurred because EPA assumes oil will be recycled to animal feed and/or soap

                                          10-27
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                                                     Section 10.0 - Costs of Technology Bases for Regulations
product manufacturing based on practices observed during EPA site visits and sampling episodes
at TEC facilities.  The module calculates the costs for removing, storing, and disposing of settled
solids for the food subcategories but not for the Barge/Chemical & Petroleum Subcategory,
because EPA assumes gravity oil/water separators at Barge/Chemical & Petroleum facilities will
generate a negligible amount of settled solids based on observations made during EPA site visits
and sampling episodes.
                                                       *»

              Capital and annual costs for the following equipment are included in the gravity
oil/water separation module:

              •       A gravity oil/water separator;
              •       Two wastewater transfer pumps (only one for Barge/Chemical &
                     Petroleum);
              •       An oil transfer pump;
              •       An oil storage tank (Barge/Chemical & Petroleum only);
              •       A sludge transfer pump (food subcategories only); and
              •       An oil/water separator effluent pump (Barge/Chemical & Petroleum only).

Annual costs include operational labor, maintenance and repair labor, O&M materials,
electricity, and residual disposal costs. The gravity oil/water separator costs are based on tank
volume designed to provide a wastewater residence time of 6.4 days, as observed during EPA
site visits and sampling episodes at TEC facilities.
              The wastewater transfer pumps and oil transfer pump costs are based on the
respective wastewater and oil flow rates estimated by the oil/water separator module.  The pumps
are designed to operate at an average flow rate of one-half the stated maximum flow-rate capacity
of the pump. Electricity costs are based on the pump motor horsepower necessary to transfer
wastewater and oil at the flow rates estimated by the oil/water separator module.  The sludge
                                          10-28
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                                                     Section 10.0 - Costs of Technology Bases for Regulations
transfer pump costs are based on the horsepower necessary to pump sludge at the flow rates
estimated by the oil/water separator module. The effluent wastewater pump costs are based on
effluent wastewater flow rate. Electricity costs are based on the motor horsepower necessary to
pump wastewater to the subsequent treatment unit.

              Oil and sludge management practices are based on practices observed during EPA
site visits and sampling episodes at TEC facilities.  For the Barge/Chemical & Petroleum
Subcategory, oil is collected in a tank and assumed to be hauled off site every 5 days.  Oil storage
tank costs are based on the tank volume necessary to hold the oil generated over a 5-day period.
For the Truck/Food, Rail/Food and Barge/Food Subcategories, oil is pumped directly from the
gravity oil/water separator tank for off-site  disposal twice per year.  Sludge is collected either
directly from the gravity oil/water separator tank and hauled off site for disposal once per month
or pumped to a sludge storage tank (included in the biological treatment module) for subsequent
on-site sludge dewatering. Waste disposal  costs are calculated separately in the waste haul
module (see Section 10.3.21).  The oil and  sludge volumes generated (where applicable) are
calculated based on the ratios of the oil and sludge generation rates to the facility wastewater
flow rates observed during EPA site visits and sampling episodes at TEC facilities.  EPA
assumes  that the waste oil stream comprises 95% oil and the settled solids stream comprises 4%
solids, based on assumptions used in the MP&M cost model.
10.3.7
Gravity Separation
              In this module, EPA estimates costs for a facility to install and operate a gravity
separator to remove suspended solids from raw wastewater.  The gravity separator module
calculates the costs necessary to treat wastewater using a gravity separator that allows solids to
settle to the bottom of the unit. The module also calculates the costs for removing, storing, and
disposing of settled solids.
              Capital and annual costs for the following equipment are included in the gravity
 separation module:
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                                                     Section 10.0 - Costs of Technology Bases for Regulations
              •      A gravity separator tank;
              •      Two wastewater transfer pumps; and
              •      A sludge transfer pump (if sludge generation is less than 1,265 gallons per
                    month).

Annual costs include operational labor, maintenance and repair labor, O&M materials,
electricity, and residual disposal costs. The gravity separator tank costs are based on a tank
volume designed to provide a wastewater residence time of 4 days, as observed during EPA site
visits and sampling episodes at TEC facilities.

              The wastewater transfer pump costs are based on influent wastewater flow rate.
The pumps are designed to operate at a flow rate of one-half the stated maximum flow rate
capacity of the pumps.  Electricity costs are based on motor horsepower necessary to transfer
wastewater at the flow rates estimated by the gravity separator module. The sludge transfer
pump costs are based on motor horsepower necessary to transfer sludge at the flow rates
estimated by the gravity separator module.

              EPA assumes that settled solids will be disposed off site once per month based on
observations made during site visits and sampling episodes at TEC facilities.  Waste disposal
costs are calculated separately in the waste haul module (see Section 10.3.21). The sludge
volume generated by the gravity separator is calculated based on the ratios of the sludge
generation rates to the facility wastewater flow rates observed during EPA site visits and
sampling episodes at TEC facilities.  Sludge is assumed to accumulate in the bottom of the
gravity separator tank. If the monthly sludge generation is less than 1,265 gallons, it is more
economical for a facility to pump the sludge into drums for disposal. Otherwise, a vacuum truck
(provided by the sludge disposal company) would be used to remove the sludge. EPA assumes
the settled solids stream comprises 4% solids, based on engineering literature.
                                          10-30
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10.3.8
                                                     Section 10.0 - Costs of Technology Bases for Regulations
Chemical Oxidation, Neutralization, Coagulation, and
Clarification
              In this module, EPA estimates costs for a facility to install and operate a turn-key
treatment system consisting of four reaction tanks in series and a clearwell. Treatment steps
include: chemical oxidation to oxidize organic pollutants using hydrogen peroxide; neutralization
to adjust wastewater pH; coagulation to destabilize suspended matter using polyalum chloride
(an electrolyte); and clarification to settle and remove agglomerated solids using a polymer
flocculant. The module calculates costs necessary for the turn-key treatment system, including
the reaction tanks, clearwell, chemical feed systems, mixers, control system, and two sludge
storage tanks. The module also calculates the costs to collect solids from the bottom of the
clarifier and pump the sludge into a sludge storage tank in preparation for dewatering.

              Capital and annual costs for the following equipment are included in the chemical
oxidation, neutralization, coagulation, and clarification module:
              •      Four reaction tanks;
              •      Two sludge storage tanks;
              •      A clearwell;
              •      Five chemical feed systems;
              •      Two mixers;
              •      An influent wastewater pump;
              •      A sludge pump (sized at 20 gpm); and
              •      A control system.

Annual costs include operational labor, maintenance and repair labor, O&M materials, and
electricity. The turn-key package system costs are based on the nominal wastewater flow rate
capacity of the unit.  The turn-key package system observed during EPA sites visits and sampling
episodes at TEC facilities is sized with 25% excess capacity due to fluctuations in daily
wastewater flows. EPA likewise estimates turn-key package system costs based on a unit with a
capacity that exceeds daily wastewater flow rates by 25%. Electricity costs for the mixers,
chemical feed systems, and sludge pump are based on motor horsepower necessary to operate the
turn-key unit.

                                          10-31
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10.3.9
                                       Section 10.0 - Costs of Technology Bases for Regulations
DAF (with pH Adjustment and Chemical Addition)
              In this module, EPA estimates costs for a facility to install and operate a DAF unit
designed to remove entrained solid or liquid particles.  The module calculates the costs necessary
to operate a DAF unit with a recycle pressurization system, chemical addition systems for
polymers (coagulants and flocculant) and pH adjustment, and a sludge collection tank. The
module also calculates costs for a pre-engineered building to enclose the treatment unit.
module:
              Capital and annual costs for the following equipment are included in the DAF
                    A wastewater transfer pump;
                    A chemical treatment tank system;
                    A polymer mixing tank system;
                    A polymer dilution tank system;
                    A DAF unit;
                    An air compressor;
                    A sludge storage tank; and
                    A pre-engineered building.
Annual costs include operational labor, maintenance and repair labor, O&M materials,
electricity, and chemical costs. The DAF unit observed during EPA site visits and sampling
episodes at TEC facilities is sized with 30% excess capacity due to fluctuations in daily
wastewater flows. EPA likewise estimates DAF unit costs based on a unit with a capacity that
exceeds daily wastewater flow rates by 30%. The unit uses two motors: a surface skimmer motor
and a pressurization motor pump. Electricity costs are based on motor horsepower necessary to
operate the surface skimmer and pressurization pump.

             The wastewater transfer pump costs  are based on influent wastewater flow rate.
Pumps are designed to operate at a flow rate of one-half the stated maximum capacity of the
pump.  Electricity costs are based on motor horsepower necessary to transfer wastewater at the
influent wastewater flow rates.
                                          10-32
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                                                    Section 10.0 - Costs of Technology Bases for Regulations
             The chemical treatment tank system consists of a treatment tank, mixer, pH probe,
acid metering pump, and caustic metering pump. The treatment tank costs are based on the ratio
of tank volume to wastewater flow rate observed during EPA site visits and sampling episodes at
TEC facilities. The mixer costs are based on tank volume and motor horsepower necessary to
operate the mixer. The pH probe and acid metering pump costs are the same for every facility.
The caustic metering pump costs are based on tank volume. Sulfuric acid (93%) and sodium
hydroxide (50%) are added to the wastewater. The volume of chemicals added is based on the
ratio of chemical addition to wastewater flow rate observed during EPA site visits and sampling
episodes at TEC facilities.

             The polymer mixing tank system consists of a mixing tank, a mixer, and two
metering pumps. The tank costs are based on the ratio of mixing tank volume to wastewater flow
rate observed during EPA site visits and sampling episodes at TEC facilities. The mixer costs
are based on tank volume and motor horsepower necessary to operate the mixer. The metering
pump cost is the same for every facility. The polymer dilution tank system consists of the same
components as the polymer mixing tank system except it includes only one metering pump.
Polymer addition rates are based on the ratio of polymer addition to wastewater flow rate
observed during EPA site visits and sampling episodes at TEC facilities.

             The sludge storage tank costs are based on the ratio of sludge storage tank volume
to wastewater flow rate observed during EPA site visits and sampling episodes at TEC facilities.
Sludge is collected in the storage tank before being dewatered. Costs for sludge dewatering are
estimated in the sludge dewatering module (see Section 10.3.18). The DAP unit sludge
generation rates are based on information gathered during EPA site visits and sampling episodes
at TEC facilities with DAF units.

              The pH adjustment and DAF units are housed in the pre-engineered building to
provide protection from poor weather conditions. The pre-engineered building costs are based
on the square footage of building space needed to house the DAF unit and associated equipment.
                                         10-33
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                                                      Section 10.0 - Costs of Technology Bases for Regulations
Since differences in the sizes of equipment housed in the pre-engineered building are minor,
costs for all facilities are estimated for the same building size.
10.3.10
DAF (without Chemical Addition)
              In this module, EPA estimates costs for a facility to install and operate a DAF unit
designed to remove entrained solid or liquid particles. The module calculates the 'costs necessary
to operate a DAF unit and collect solids for disposal off site (for facilities with treatment in place
but no sludge dewatering on site) or for on-site sludge dewatering.
              Capital and annual costs for the following equipment are included in this DAF
module:
              •      A DAF unit; and
              •      A sludge storage tank.

Annual costs include operational labor, maintenance and repair labor, O&M materials,
electricity, and residual disposal (if sludge dewatering costs are not included). The DAF unit
costs are based on the ratio of DAF unit capacity to wastewater flow rate observed during EPA
site visits and sampling episodes at TEC facilities. Electricity costs are based on the motor
horsepower necessary to operate the DAF unit.

              A sludge storage tank is only included in baseline options where a facility does
not operate sludge dewatering on site.  A sludge storage tank is sized to hold the volume of
sludge collected over a period of one month. Waste disposal costs  are calculated separately in
the waste haul module (see Section 10.3.21). The sludge storage tank costs are based on volume.
The DAF module calculates the amount of sludge to be disposed based on the ratio of DAF
sludge generation rate to wastewater flow rate observed during EPA site visits and sampling
episodes at TEC facilities. EPA assumes that the DAF sludge comprises 4% solids, based on
assumptions used in the MP&M cost model.
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                                                      Section 10.0 - Costs of Technology Bases for Regulations
10.3.11
Chemical Precipitation
              EPA conducted an abbreviated cost review to determine the feasibility of
installing and operating chemical precipitation treatment at facilities in the Truck/Petroleum and
Rail/Petroleum Subcategories. Based on the results of this review and information currently
available to EPA, the Agency believes that this technology does not provide adequate and/or
cost-effective treatment of TEC wastewaters at facilities in the Truck/Petroleum and
Rail/Petroleum Subcategories. EPA does not currently have sampling data for chemical
precipitation units operated at TEC facilities. All cost estimates for chemical precipitation
treatment of TEC wastewater are based on chemical precipitation costs developed for EPA's
Industrial Laundries Effluent Limitations Guidelines program.

              In this module, EPA estimates costs for a facility to install and operate a chemical
precipitation unit to remove dissolved rnetals and entrained solid or liquid particles from raw
wastewater.  The cost estimate includes the costs necessary to perform batch chemical
precipitation treatment and to remove, store, and dispose of settled sludge.

              Capital and annual costs for the following equipment are included in the chemical
precipitation unit module:
              •      A mixing/settling tank;
              •      Three chemical feed systems;
              «      An agitator;
              •      An effluent pump;
              •      A sludge pump;
              •      A sludge holding tank; and
              •      A control system.

 Annual costs include operational labor, maintenance and repair labor, O&M materials,
 electricity, chemicals, and settled solids disposal.  The chemical precipitation unit operates in
 batch mode, and EPA assumes that the system treats one batch per day (i.e., treatment of one
 day's wastewater). Electricity costs for agitators, chemical transfer pumps (polyalum chloride,

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                                                     Section 10.0 - Costs of Technology Bases for Regulations
anionic polymer, and cationic polymer), and the effluent pump are based on motor horsepower
necessary to operate the unit and chemical or wastewater transfer rates needed to operate the unit.

              Sludge is collected from the chemical precipitation sludge storage tank once per
month. Sludge disposal costs are the same throughout the TECI cost model. The sludge
generation rate is estimated using the difference between the influent and effluent average total
suspended solids concentrations. EPA assumes that the precipitation sludge stream comprises
5.7% solids, based on engineering literature.
10.3.12       Filter Press (for Wastewater Clarification and Biological
              Treatment Sludge Dewatering)
              In this module, EPA estimates costs for a facility to install and operate a single
filter press for two operations:  wastewater clarification and biological treatment sludge
dewatering.  During wastewater treatment operating hours, the filter press functions as a
wastewater clarifier.  Following wastewater treatment operating hours, the filter press dewaters
sludge from biological treatment.  The module calculates the costs necessary to filter and store
wastewater before being discharged or pumped to subsequent treatment units.  The module also
calculates annual costs associated with sludge dewatering. The filter press is designed to treat
one batch of wastewater per day and one batch of biological treatment sludge per day.
              Capital and annual costs for the following equipment are included in the filter
press module:
              •      An influent pump and compressor;
              •      A diatomaceous earth precoat tank;
              •      A diatomaceous earth precoat pump and compressor;
              •      A filter press; and
              •      An effluent storage tank.

Annual costs include operational labor, maintenance and repair labor, O&M materials,
electricity, and residual disposal. Based on observations made during EPA site visits and

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                                                     Section 10.0 - Costs of Technology Bases for Regulations
sampling episodes, EPA assumes that both operations generate equal daily volumes of dewatered
sludge.  Dewatered sludge volumes are based on the ratio of dewatered sludge generation rate to
wastewater flow rate observed during EPA site visits and sampling episodes at TEC facilities.
The filter press volume is based on and equal to the volume of dewatered sludge from just one of
the operations. Waste disposal costs are calculated separately in the waste haul module (see
Section 10.3.21) and are based on the total volume of dewatered sludge from both filter press
operations. EPA assumes the dewatered filter cake volume comprises 32% solids, based on
engineering literature.

              The influent pump and precoat transfer pump costs are based on influent
wastewater flow rate.  Electricity costs for the pumps are based on motor horsepower necessary
to transfer wastewater and polymer at the flow rates estimated by the filter press module.

              The diatomaceous earth precoat tank costs and effluent storage tank costs are
based on tank volumes recommended by filter press vendors.  The amount of diatomaceous earth
necessary to treat wastewater and biological treatment sludge is based on the ratio of
diatomaceous earth usage rate to wastewater flow rate observed during EPA site visits and
sampling episodes at TEC facilities.
 10.3.13
Biological Treatment
              In this module, EPA estimates costs for a facility to install and operate a
 biological oxidation unit used to decompose organic constituents. The module calculates costs
 necessary for operating an aerobic biological treatment unit consisting of two preaeration tanks, a
 post-treatment clarifier, and a sludge storage tank. A portion of the sludge is recycled by
 pumping the sludge from the clarifier to the second preaeration tank.  Sludge is also pumped
 from the clarifier into a sludge storage tank for subsequent dewatering.
              Capital and annual costs for the following equipment are included in the
 biological treatment module:
                                           10-37
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                                                     Section 10.0 - Costs of Technology Bases for Regulations
              •      Wastewater transfer pumps;
              •      Two preaeration tanks;
              •      Diffusers/blowers;
              •      A biological reactor tank;
              •      A clarifier;
              •      A sludge storage tank;
              •      A sludge pump; and
              •      A biological treatment effluent discharge pump.

Annual costs include operational labor, maintenance and repair labor, O&M materials,
electricity, and residual disposal. The biological reactor capital and annual costs are based on a
tank volume designed to provide a wastewater residence time of 4.6 days, as observed during
EPA site visits and sampling episodes at TEC facilities. Annual additions of microorganisms to
the biotreatment unit is based on the ratio of microorganism addition rate to wastewater flow rate
observed during EPA site visits and sampling episodes at TEC facilities.

              The wastewater transfer pump costs are based on influent wastewater flow rate.
Electricity costs for the pumps are based on motor horsepower necessary to transfer wastewater
at the influent flow rate. The diffuser/blower costs are based on the ratio of air flow rate to
wastewater flow rate observed during EPA site visits and sampling episodes at TEC facilities.

              The preaeration and sludge storage tank volumes are based on the ratio of tank
volume to wastewater flow rate observed during EPA site visits and sampling episodes at TEC
facilities. The sludge and effluent discharge pump costs are based on motor horsepower
necessary to transfer sludge and wastewater at the flow rates estimated by the biological
treatment module.

              The clarifier is used to settle sludge following the biological digestion  in the
biological reactor. Clarifier costs are based on the ratio of clarified volume to wastewater flow
rate observed during EPA site visits and sampling episodes at TEC facilities.
                                          10-38
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                                                      Section 10.0 - Costs of Technology Bases for Regulations
10.3.14
Activated Carbon Adsorption (Vessels)
              In this module, EPA estimates costs for a facility to install and operate an
activated carbon adsorption system used as a tertiary treatment technology applicable to waste
streams following treatment by chemical oxidation, neutralization, coagulation, and clarification.
The module calculates costs necessary for operating two activated carbon columns in series.
Spent carbon is assumed to require off-site disposal once per month.

              Capital and annual costs for the following equipment are included in the granular
activated carbon module:

              •      A wastewater transfer pump; and
              •      Two carbon adsorption filters.

Annual costs include operational labor, maintenance and repair labor, O&M materials,
electricity, chemicals (media changeout), and residual disposal. The capital and annual costs
associated with the carbon adsorption filters are based on the ratios  of activated carbon system
size and carbon usage rate to wastewater flow rate observed during EPA site visits and sampling
episodes at TEC facilities.

              The costs associated with the wastewater transfer pump are based on influent
wastewater flow rate. Electricity costs are based on motor horsepower necessary to operate the
carbon adsorption system.

              One column of spent activated carbon is assumed to be changed out once each
month. Media change-out costs include costs for labor and fresh media.  Spent carbon is
assumed to be sent off site for regeneration. Residual disposal costs include costs for waste
shipping and media disposal. For cost estimating purposes, EPA assumes that TEC facilities
typically operate an  average of 265 days per year. Costs are adjusted for facilities operating less
                                           10-39
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                                                     Section 10.0 - Costs of Technology Bases for Regulations
than 265 days per year by multiplying "typical" residual disposal costs by a factor consisting of
actual operating days divided by 265.
10.3.15
Activated Carbon Adsorption (Canisters)
              In this module, EPA estimates costs for a facility to install and operate an
activated carbon adsorption system for wastewater polishing followed by total recycle/reuse of
TEC wastewater in TEC operations. The module calculates the costs necessary for disposal of
spent carbon canisters.

              Capital and annual costs for the following equipment are included in the carbon
canisters module:
                     An influent pump; and
                     Carbon canisters.
Annual costs include operational labor, maintenance and repair labor, O&M materials,
electricity, replacement carbon canisters, and residual disposal costs.  The activated carbon
canister usage rate is calculated using wastewater flow rates, pollutant concentrations, and
estimated carbon adsorption capacities for the pollutants in the wastewater. Annual carbon
canister costs include labor to remove the spent carbon canister and install the new canister,
transportation, and disposal of the spent carbon.

              Influent pump costs are based on influent wastewater flow rate to the system.
Electricity costs are based on motor horsepower necessary to transfer influent wastewater.
10.3.16
Organo-CIay/Activated Carbon Adsorption

              In this module, EPA estimates costs for a facility to install and operate an organo-
clay adsorption unit followed by a granular activated carbon unit for wastewater polishing.  The
                                          10-40
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                                                     Section 10.0 - Costs of Technology Bases for Regulations
module calculates costs to operate two columns in series (organo-clay followed by activated
carbon) with nominal carbon change-out frequency of one vessel per month and nominal organo-
clay change-out frequency of one vessel per two months.

              Capital and annual costs for the following equipment are included in the organo-
clay/activated carbon adsorption module:

              •       A wastewater transfer pump;
              •       An organo-clay vessel; and
              •       A granular activated carbon vessel.

Annual costs include operational labor, maintenance and repair labor, electricity, chemicals
(media), and residual disposal. The costs associated with the organo-clay vessel and granular
activated carbon vessels are based on the ratio of filter media volume to influent flow rate
observed during EPA site visits and sampling episodes at TEC facilities.

              The costs associated with the wastewater transfer pump are based on influent
wastewater flow rate.  The pump is designed to operate at a flow rate of one-half the stated
maximum capacity of the pump.  Electricity costs are based on motor horsepower necessary to
transfer influent wastewater.

              The design media change-out frequency is once per month for granular activated
carbon, and once every two months for organo-clay, based on information provided by treatment
system vendors. Spent carbon is assumed to be sent off site for regeneration or disposal and
spent clay is assumed to be sent off site for incineration. Media change-out costs include costs
for labor and fresh media. Residual disposal costs include costs for waste shipping and media
disposal.
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                                                     Section 10.0 - Costs of Technology Bases for Regulations
10.3.17
Reverse Osmosis
              In this module, EPA estimates costs for a facility to install and operate a reverse
osmosis unit for wastewater polishing. The module calculates costs necessary for wastewater
storage prior to entering the reverse osmosis unit, and the reverse osmosis unit itself. The reverse
osmosis unit is operated as a double pass unit. After the first pass through the reverse osmosis
unit, the wastewater is transferred to a storage tank. When the storage tank is nearly full, the
wastewater is pumped for a second pass through the reverse osmosis unit prior to discharge.
Concentrate from the reverse osmosis unit is recycled to the first biological treatment preaeration
tank.

              Capital and annual costs for the following equipment are included in the reverse
osmosis module:

              •     Two reverse osmosis wastewater storage tanks;
              •     A reverse osmosis flooded suction tank; and
              •     A reverse osmosis unit.

Annual costs include operational labor, maintenance and repair labor, electricity, and membrane
and pretreatment filter replacement costs.  The reverse osmosis unit capital costs are based on
influent wastewater flow rate. Electricity costs are based on motor horsepower necessary to
operate the unit at the flow rate estimated by the reverse osmosis module. Membrane and filter
replacement costs are based on influent wastewater flow rate and information provided by
treatment technology vendors.  EPA estimates that membranes require replacement every five
years, and the pretreatment filter cartridges must be replaced every two months.

              The reverse osmosis wastewater storage tanks and flooded suction tank costs are
based on the ratio of tank volume to wastewater flow rate observed during EPA site visits and
sampling episodes at TEC facilities.
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10.3.18
                                        Section 10.0 - Costs of Technology Bases for Regulations
Sludge Dewatering (Plaite-and-Frame Filter Press)
              In this module, EPA estimates costs for a facility to install and operate a plate-
and-frame filter press. The module calculates costs .necessary to operate a plate-and-frame filter
press to dewater sludge that is generated by wastewater treatment units.

              For the Truck/Chemical Subcategory, EPA assumes that facilities will use a
portable pump to pump sludge from the sludge storage tanks into the filter press. Because EPA
includes a portable purnp in the oil/water separator module (see Section 10.3.4), costs are not
included for an additional pump in the sludge dewatering module for the Truck/Chemical
Subcategory.

              Capital and annual costs for the following equipment are included in the plate-
and-frame filter press module:

              •       A plate-and-frame filter press;
              •       Sludge transfer pumps (Rail/Chemical, Truck/Food, Rail/Food, and
                     Barge/Food Subcategories);
              •       Sludge storage tank (PSES Option 1 for the Rail/Chemical Subcategory);
              •       Precoat (diatomaceous earth) tank (for dewatering biological treatment
                     sludge); and
              •       Precoat transfer pump and compressor (for dewatering biological
                     treatment sludge).

Annual costs include operational labor, maintenance and repair labor, O&M materials,
electricity, chemical costs (diatomaceous earth), and residual disposal costs. The filter press
capital and. annual costs are calculated using the ratio of sludge generation rate to wastewater
flow rate observed during EPA site visits and sampling episodes at TEC facilities, as well as
technical literature on sludge and filter cake solids contents. In general EPA assumes that the
                                           10-43
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                                                     Section 10.0 - Costs of Technology Bases for Regulations
press operates one batch per day; therefore, the press volume generally equals the estimated daily
volume of filter cake generation. However, for the Truck/Chemical and Rail/Chemical
Subcategories, EPA performed an optimization analysis to determine filter press volume versus
the number of batches per day based on the filter cake generation rate and operational days per
year. EPA assumes that the filter press will operate no more than two batches per day.  The cost
for hauling dewatered sludge is estimated separately in the waste haul module (see Section
10.3.21) and is based on the calculated volume of dewatered sludge generated. EPA assumes
that the dewatered sludge comprises 32 to 33% solids, based on engineering literature.

              The sludge transfer pump costs are based on motor horsepower necessary to
transfer sludge at flow rates estimated by the sludge dewatering module. The precoat transfer
pump costs are based on influent wastewater flow rate.  Electricity costs are based on motor
horsepower necessary to transfer polymer at flow rates estimated by the sludge dewatering
module.

              The diatomaceous earth precoat tank costs are based on tank volumes
recommended by filter press vendors. The amount of diatomaceous earth necessary is based on
the ratio of diatomaceous earth usage rate to wastewater flow rate observed during EPA site
visits and sampling episodes at TEC facilities.

10.3.19       Contract Hauling of Wastewater in Lieu of Treatment

              In this module, if contract hauling in lieu of treatment is appropriate, capital and
annual costs for a wastewater holding tank are included in the module. Annual costs include
maintenance and repair labor, O&M materials, transportation, and disposal of wastewater. EPA
assumes that wastewater would be accumulated in a holding tank and then disposed off site every
three months.  Holding tank costs are based on the tank volume needed to contain all of the
wastewater generated by a facility over a three-month period.
                                          10-44
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                                                      Section 10.0 - Costs of Technology Bases for Regulations
              Transportation disposal costs are based on gallons of wastewater to be disposed.
EPA uses quotes from nation-wide vendors to estimate costs for contract hauling wastewater off
site. EPA estimates a cost of $0.44/gallon (7) to contract haul wastewater off site.
10.3.20
Compliance Monitoring
              This practice is included in all of the proposed regulatory options for all
subcategories. Regulatory options were not developed by EPA for BPT, BCT, BAT, and NSPS
for facilities in the Truck/Petroleum and Rail/Petroleum Subcategories.

              In this module, EPA estimates annual compliance monitoring costs for all TEC
facilities.  The annual cost calculated by the model for compliance monitoring included
laboratory costs to analyze wastewater volatile and semivolatile organics, metals, and classical
pollutants. For indirect dischargers, EPA estimates costs for facilities to monitor monthly for all
regulated pollutants! For direct dischargers, EPA estimates costs for facilities to monitor weekly
for classical pollutants and monthly for volatile and semivolatile organics and metals. However,
for the food subcategories direct dischargers, EPA estimates costs for facilities to monitor weekly
for classical pollutants, with no monitoring for any other pollutants, because EPA is regulating
only these pollutants in the food grade subcategories.  The costs for each .type of analysis per
sample were obtained from a laboratory contracted by EPA on past wastewater sampling efforts.
The table below shows the monitoring costs used in the cost model.
•• •. ' •. * ?*•"' '"^'Jsv^V^ ''•,{•••.„ ' s
Analytical Method * "' ;
•>''.'*' •'•>•>' "^ v „ •••, \ .• ^ w v *•• •• •"
Method 1624 - Volatile Organic Compounds
Method 1625 - Semi-Volatile Organic Compounds
Method 1 620 - Metals
Methods 405.1, 410.4, 335.1, 1664, 150.1, 415.1, 420.2 - Classical
Pollutants
laboratory Fee /
', V<$19J>4)^' XJ
$459
$1040.40
$598
$177
' '^ /
' >3J
-------
                                                      Section 10.0 - Costs of Technology Bases fot Regulations
10.3.21
Waste Hauling
              In this module, where applicable, EPA estimates annual waste hauling costs for
oil (95% oil), undewatered sludge (approximately 4% solids), and dewatered sludge
(approximately 32% solids) for all TEC facilities. The cost model calculates annual costs for
waste hauling, including labor and transportation. Cost rates are obtained from nation-wide
vendors. Undewatered sludge disposal costs are based on using either a vac-truck or multiple
drums, depending on the volume to be disposed. Dewatered sludge costs include an annual roll-
off box rental.
10.4
Summary of Costs by Regulatory Option
              Table 10-5 summarizes estimated BPT, BCT, and BAT compliance costs by
regulatory option.  Table 10-6 summarizes estimated PSES compliance costs by regulatory
option.  Costs shown include capital and O&M costs (including energy usage) totaled for each
subcategory for all discharging facilities. All costs represent the estimated incremental
compliance costs to the industry. The capital costs shown in Tables 10-5 and 10-6 represent the
direct capital costs estimated by the technology modules plus the indirect capital costs discussed
in Section 10.2.4.1. The annual costs shown in Tables 10-5 and 10-6 represent the direct annual
costs estimated by the technology modules plus the compliance monitoring and waste hauling
costs discussed in Sections 10.3.20 and 10.3.21.
10.5
References1
1.
U.S. Environmental Protection Agency, Office of Water. Economic Analysis for
the Proposed Effluent Limitations Guidelines for the Transportation Equipment
Cleaning Industry. EPA-821-B-98-012, May 1998.
1 For those references included in the administrative record supporting the proposed TECI rulemaking, the
  document control number (DCN) is included in parentheses at the end of the reference.
                                          10-46
-------
2.



3.


4.



5.


6.

7.


8.


9.



10.



11.



12.
 13.
                                      Section 10.0 - Costs of Technology Bases for Regulations

U.S. Environmental Protection Agency, Office of Water. Statistical Support
Document for the Proposed Effluent Limitations Guidelines for the Transportation
Equipment Cleaning Industry. EPA-821-B-98-014, May 1998.

The Richardson Rapid System Process Plant Construction Estimating Standards.
Volume 4: Process Equipment, 1994.

Eastern Research Group, Inc. Standard Annual Cost Rates Used in the TECI Cost
Model.  Memorandum from Melissa Cantor, Eastern Research Group, Inc. to the
TECI Rulemaking Record, April 22,1998 (DCN T09977).

Eastern Research Group, Lie. Flow Reduction Cost Module Documentation for
the Transportation Equipment Cleaning Cost Model. May 1998 (DCN T09753).

"Economic Indicators." Chemical Engineering. September 1995, page 168.

Eastern Research Group, Inc. Contract Haul Cost Module Documentation for the
Transportation Equipment Cleaning Cost Model. May 1998 (DCN T09754).

Eastern Research Group, Inc. Monitoring Cost Module Documentation for the
Transportation Equipment Cleaning Cost Model. May 1998 (DCN T09852).

Eastern Research Group, Inc. Equalization Cost Module Documentation
Transportation Equipment Cleaning Cost Model Truck/Chemical Subcategory.
May 1998 (DCN T09730).

Eastern Research Group, Inc.  Oil/Water Separation Cost Module Documentation
for the Transportation Equipment Cleaning Cost Model Truck/Chemical
Subcategorv (Direct Dischargers). May 1998 (DCN T09734).

Eastern Research Group, Inc.  Oil/Water Separation Cost Module Documentation
for the Transportation Equipment Cleaning Cost Model Truck/Chemical
Subcategorv (Indirect Dischargers). May 1998 (DCN T09731).

Eastern Research Group, Inc. Chemical Oxidation/Neutralization/Coagulation/
Clarification Cost Module Documentation for the Transportation Equipment
Cleaning Cost Model Tmck/Chemical Subcategory (Direct Dischargers). May
1998 (DCN T09735).

Eastern Research Group, Inc. Chemical Oxidation/Neutralization/Coagulation/
Clarification Cost Module Documentation for the Transportation Equipment
Cleaning Cost Model Tmck/Chemical Subcategory (Indirect Dischargers).  May
1998 (DCN T09732).
                                         10-47
-------
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
                                      Section 10.0 - Costs of Technology Bases for Regulations

Eastern Research Group, Inc. Sludge Dewatering Cost Module Documentation
for the Transportation Equipment Cleaning Cost Model Truck/Chemical
Subcategorv (Direct Dischargers! May 1998 (DCN T09726).

Eastern Research Group, Inc. Sludge Dewatering Cost Module Documentation
for the Transportation Equipment Cleaning Cost Model Truck/Chemical
Subcategorv (Indirect Dischargers!  May 1998 (DCN T09723).

Eastern Research Group, Inc. Biological Treatment Cost Module Documentation
for the Transportation Equipment Cleaning Cost Model Truck/Chemical
Subcategorv (Direct Dischargers). May 1998 (DCN T09736).

Eastern Research Group, Inc. Activated Carbon Adsorption Cost Module
Documentation for the Transportation Equipment Cleaning Cost Model
Truck/Chemical Subcategorv. May  1998 (DCN T09733).

Eastern Research Group, Inc. Oil/Water Separation Cost Module Documentation
for the Transportation Equipment Cleaning Cost Model Rail/Chemical
Subcategorv (Direct Dischargers'). May 1998 (DCN T09741).

Eastern Research Group, Inc. Oil/Water Separation Cost Module Documentation
for the Transportation Equipment Cleaning Cost Model Rail/Chemical
Subcategorv (Indirect Dischargers').  May 1998 (DCN T09737).

Eastern Research Group, Inc. Equalization Cost Module Documentation for the
Transportation Equipment Cleaning Cost Model Rail/Chemical Subcategorv.
May 1998 (DCNT09738).

Eastern Research Group, Inc. pH Adjustment/Dissolved Air Flotation Cost
Module Documentation for the Transportation Equipment Cleaning Cost Model
Rail/Chemical Subcategorv (Direct Dischargers'). May 1998 (DCN T09742).

Eastern Research Group, Inc. pH Adjustment/Dissolved Air Flotation Cost
Module Documentation for the Transportation Equipment Cleaning Cost Model
Rail/Chemical Subcategorv (Indirect Dischargers).  May 1998 (DCNT09739).

Eastern Research Group, Inc. Sludge Dewatering Cost Module Documentation for
the Transportation Equipment Cleaning Cost Model Rail/Chemical Subcategorv
(Direct Dischargers! May 1998 (DCN T09727).

Eastern Research Group, Inc. Sludge Dewatering Cost Module Documentation for
the Transportation Equipment Cleaning Cost Model Rail/Chemical Subcategorv
(Indirect Dischargers').  May 1998 (DCN T09724).

                                        10-48
-------
25.
26.
27.
28.
29.
30.
31.
32.
 33.
 34.
 35.
                                      Section 10.0 - Costs of Technology Bases for Regulations

Eastern Research Group, Inc. Biological Treatment Cost Module Documentation
for the Transportation Equipment Cleaning Cost Model Rail/Chemical
Subcateeorv (Direct Dischargers). May 1998 (DCN T09743).

Eastern Research Group, Inc. Organo-Clav/Granular Activated Carbon Cost
Module Documentation for the Transportation Equipment Cleaning Cost Model
Rail/Chemical Subcategorv. May 1998 (DCN T09740).

Eastern Research Group, Inc. Primary Oil/Water Separation and Dissolved Air
Flotation Cost Module Documentation for the Transportation Equipment Cleaning
Cost Model Barge/Chemical Subcategorv.  May 1998 (DCN T09744).

Eastern Research Group, Inc. Filter Press Cost Module: Sludge Dewatering
Documentation for the Transportation Equipment Cleaning Cost Model
Barge/Chemical Subcategorv (Baseline). May 1998 (DCN T09851).

Eastern Research Group, Inc. Filter Press Cost Module: Wastewater and Sludge
Documentation for the Transportation Equipment Cleaning Cost Model
Barge/Chemical Subcategorv (Direct Dischargers'). May 1998 (DCN T09728).

Eastern Research Group, Inc. Filter Press Cost Module: Wastewater and Sludge
Documentation for the Transportation Equipment Cleaning Cost Model
Barge/Chemical Subcategorv (Indirect Dischargers). May 1998 (DCN T09725).

Eastern Research Group, Inc. Biological Treatment Cost Module Documentation
for the Transportation Equipment Cleaning Cost Model Barge/Chemical
Subcategorv.  May 1998 (DCN T09745).

Eastern Research Group, Inc. Reverse Osmosis Cost Module Documentation for
the Transportation Equipment Cleaning Cost Model Barge/Chemical Subcategorv.
May 1998 (DCN T09746).

Eastern Research Group, Inc.  Equalization Cost Module Documentation for the
Transportation Equipment Cleaning Cost Model Food Subcategories. May 1998
(DCN T09748).

Eastern Research Group, Inc. Oil/Water Separation Cost Module Documentation
for the Transportation Equipment Cleaning Cost Model Food Subcategories.  May
 1998 (DCN T09749).

Eastern Research Group, Inc. Biological Treatment Cost Module Documentation
for the Transportation Equipment Cleaning Cost Model Food Subcategories.  May
 1998 (DCN T09750).
                                        10-49
-------
36.
37.
38.
39.
40.
41.
42.
43.
                                      Section 10.0 - Costs of Technology Bases for Regulations

Eastern Research Group, Inc. Sludge Dewatering Cost Module Documentation
for the Transportation Equipment Cleaning Cost Model Food Subcategories. May
1998(DCNT09729).

Eastern Research Group, Inc. Equalization Cost Module Documentation for the
Transportation Equipment Cleaning Cost Model Truck/Petroleum and
Rail/Petroleum Subcategories. May 1998 (DCN T09853).

Eastern Research Group, Inc. Oil/Water Separation Cost Module Documentation
for the Transportation Equipment Cleaning Cost Model Truck/Petroleum and
Rail/Petroleum Subcategories (Indirect Dischargers). May 1998 (DCN T09751).

Eastern Research Group, Inc. Activated Carbon Adsorption Cost Module
Documentation for the Transportation Equipment Cleaning Cost Model
Truck/Petroleum and Rail/Petroleum Subcategories. May 1998 (DCN T09752).

Eastern Research Group, Inc. Abbreviated Cost Analysis for Compliance with
Option 1 for the Truck/Petroleum and Rail/Petroleum Subcategories.
Memorandum from Melissa Cantor, Eastern Research Group, Inc. to the TECI
Rulemaking Record, April 23,1998 (DCN T09759).

Eastern Research Group, Inc. Gravity Separator Cost Module Documentation for
the Transportation Equipment Cleaning Cost Model Hopper Subcategories. May
1998 (DCN T09747).

Eastern Research Group, Inc. TECI Cost Model Annual Cost Factors for Pumps.
Memorandum from Melissa Cantor, Eastern Research Group, Inc. to the TECI
Rulemaking Record, October 10, 1997 (DCN T04654).

Eastern Research Group, Inc. TECI Cost Model Annual Cost Factors for Tanks.
Memorandum from Melissa Cantor, Eastern Research Group, Inc. to the TECI
Rulemaking Record, March 27,1998 (DCN T09976).

                                        10-50
-------
                                        Section 10.0 - Costs of Technology Bases for Regulations
                           Table 10-1
Number of Costed Technology Options for Each TECI Subcategory
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Rail/Chemical
Barge/Chemical & Petroleum
Truck/Food
Rail/Food
Barge/Food
Truck/Petroleum
Rail/Petroleum
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Rail/Hopper
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4
6
3
2
2
2
1
1
1
1
1
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10-59
-------
                                                    Section 10.0 - Costs of Technology Bases for Regulations
                                     Table 10-3
                     Components of Total Capital Investment
Item
1
2
3
4
5
6
Component
Equipment capital costs (including required
accessories), installation, delivery, electrical and
instrumentation, enclosure, and pumping
Piping
Secondary containment/land costs
Excavation and site work
Indirect costs including: engineering and
supervision, construction expenses, contractor's
fee, and contingency
Total Capital Investment (equals fixed capital
investment)
- Cost '<~ >' "";>
Direct Capital Cost
10% of item 1
10% of item 1
3.5% of item 6
20% of item 6
Sum of items 1 through 5 =
1.57 x Direct Capital Cost
Source: Transportation Equipment Cleaning Design and Cost Model.
                                          10-60
-------
                                          Section 10.0 - Costs of Technology Bases for Regulations
                             Table 10-4
Operation and Maintenance Unit Costs Used by the TECI Cost Model
Item
Cost®1994)/
Cost Equafion ($1994) t
Activity _ ' .
Contract hauling of bulk
wastewater
Disposal of waste oil (95% oil,
5% water)
Nonhazardous dewatered
sludge disposal
Nonhazardous undewatered
sludge disposal
Laboratory fee for volatile
organic compounds
Laboratory fee for semivolatile
organic compounds
Laboratory fee for metals
Laboratory fee for classical
pollutants .
$0.44/gallon
$0.37/gallon
$141.01/yd3 + $4,176/yr for
roll-off box rental
$0.53-$3.58/gallon
(based on volume)
$459/analysis
$1040.40/analysis
$598/analysis
$177/analysis
Tracfice/,
'Eeclmology: *
X-
Reference
- '* _ V>
v s/s '
Contract Haul
Contract Haul
Contract Haul
Contract Haul
Compliance Monitoring
Compliance Monitoring
Compliance Monitoring .
Compliance Monitoring
(7)
(7)
(7)
(7)
(8)
(8)
(8)
(8)
Chemicals ,' ,' , / ';', \^ " \" VC' v, ' r ''-..^ ^ ;_ \^Y~. ,:^
Activated carbon (annual
media change-out and
regeneration)
Biological treatment microbes
Activated carbon canister
(annual change-out and
regeneration)
Demulsifier
Diatomaceous earth
Organo-clay/activated carbon
adsorption (annual media
change-out)
Organo-clay/activated carbon
disposal (organo-clay
incineration and activated
carbon regeneration)
A = 0.00112(ACV)2 +
11.663(ACV) + 11058.543
$2.84/lb
$842.70/canister
$33.36/gallon
$0.76/lb
A = -1.785(FMV)2 +
946.009(FMV) - 450.496
A=!61.429(FMV) +
8464.083
Activated Carbon
Adsorption
Biological Treatment
Activated Carbon
Adsorption
Oil/Water Separator
Filter Press, Sludge
Dewatering
Organo-Clay/Activated
Carbon Adsorption
Organo-Clay/Activated
Carbon Adsorption
(17)
(16, 25, 31,
35)
(39)
(10, 11,
38)
(14, 23, 28,
29, 30, 36)
(25)
(26)
                                10-61
-------
                       Section 10.0 - Costs of Technology Bases for Regulations
Table 10-4 (Continued)
Item
Hydrogen peroxide
Magnesium hydroxide
Polyalum chloride
Polymer
Polymer 7032
Polymer 7181
Polymer 7622
Sodium hydroxide (50%)
Sulfuric acid (93%)
Cost($1994)/
CostEquafion ($1994)
$0.45-$0.69/lb
$0.26-$0.36/lb
$2.53-$4.28/gallon
$2.65-$3.00/lb
$1.10/lb
$4.45/lb
$1.25/lb
$1.689/gallon
$0.095-$0.28/lb
$1.09 I/gallon
Practice/
Technology
Chemical Oxidation,
Neutralization, Coagulation,
Clarification
Chemical Oxidation,
Neutralization, Coagulation,
Clarification
Chemical Oxidation,
Neutralization, Coagulation,
Clarification
Chemical Oxidation,
Neutralization, Coagulation,
Clarification
DAF
DAF
DAF
pH Adjustment
Chemical Oxidation,
Neutralization, Coagulation,
Clarification, and
pH Adjustment
Labor Costs "
Flow reduction training
Pump operational labor
Pump maintenance labor
Oil/water separator (vertical
tube coalescing) operational
labor
Oil/water separator (vertical
tube coalescing) maintenance
labor
A = (FPT-REG)(0.5)(25.9) for
truck and barge tank type
(where A k 34188 for the
Barge/Chemical and
Barge/Food Subcategories and
A ^10360 for the
Barge/Hopper Subcategory)
A=(FPT-REG)(0.5)(25.9)/(1 .7)
for rail tank type
A = (0.05)(DPY)(25.9)
A = (0.005)(DPY)(HPD)(25.9)
A = (0.05)(DPY)(25.9)
A = (0.005)(HPD)(DPY)(25.9)
+ ((48)(25.9))
Flow Reduction
All
All
Oil/Water Separator
Oil/Water Separator
Reference
(12, 13)
(12, 13)
(12, 13)
(12, 13)
(21, 22)
(21,22)
(21, 22)
(21, 22)
(12, 13, 21,
22)
"
(5)
(42)
(42)
(10, 11,
38)
(10, 11,
38)
            10-62
-------
                       Section 10.0 - Costs of Technology Bases for Regulations
Table 10-4 (Continued)
Item
Tanks with mixers maintenance
labor
Tanks without mixers
maintenance labor
Tank(all) repair labor
Filter press operational labor
DAF operational labor
DAF maintenance and repair
labor
Chemical oxidation,
neutralization, coagulation,
clarification operational labor
Chemical oxidation,
neutralization, coagulation,
clarification maintenance and
repair labor
Activated carbon unit repair
labor
pH probe maintenance and
repair labor
Organo-clay/granular activated
carbon unit repair labor
Reverse osmosis operational
labor
Reverse osmosis maintenance
labor
Oil/water separation (API)
maintenance labor
" ,\ '€6st($1994}/, * ' ' •
CojtfjEquation ($1994) :
A = 103.6 -207.2
(based on tank volume)
A = 414.4 -828.8
(based on tank volume)
A = (0-01X0)
A = (BPY)(12.95) -
(BPY)(25.9)
(based on filter press volume)
A = (1)(DPY)(25.9) -
(2)(DPY)(25.9)
(based on chemical addition)
A = (0.01)(C) - (0.02)(C)
(based on chemical addition)
A = (HPD)(DPY)(25.9)
A = (32)(25.9)
A = (0.01)(C)
A = (2X0.01X0)
A = (0.01)(C)
A = (DPY)(25.9)
A = 414.4
A = 414.4
's ^ractiee/^,, ^ /;
'Technology, ,
Equalization,
pH Adjustment,
Filter Press,
DAF,
Biological Treatment,
Sludge Dewatering
All
All
Filter Press,
Sludge Dewatering
DAF
DAF
Chemical Oxidation,
Neutralization, Coagulation,
Clarification
Chemical Oxidation,
Neutralization, Coagulation,
Clarification
Activated Carbon
Adsorption
pH Adjustment
Organo-Clay/Activated
Carbon Adsorption
Reverse Osmosis
Reverse Osmosis
Oil/Water Separation
s f f f
Reference*'
(9, 14, 20,
21, 22, 23,
28, 29, 30,
31, 33, 36,
37,43)
(43)
(43)
(14, 15, 23,
24, 28, 29,
30, 36)
(21, 22,
27)
(21, 22,
27)
(12, 13)
(12, 13)
(17)
(21,22)
(25)
(32)
(32)
(18, 19)
Material and Replacement Costs '''„",-' „-""""'' \
Pump materials
Chemical oxidation/
neutralization/coagulation/
clarification materials
A = (0.01)(C)
. A = (0.01)(C)
All
Chemical Oxidation,
Neutralization, Coagulation,
Clarification
(42)
(12, 13)
           10-63
-------
                                                           Section 10.0 - Costs of Technology Bases for Regulations

                                   Table 10-4 (Continued)
Item
Demulsifier pump materials
Oil/water separator (vertical
tube coalescing) materials
Filter press materials
DAF (with chemical addition)
materials
Annual costs for a building
pH probe materials
Filter press precoat storage
tank materials
Reverse osmosis membrane
replacement
Cost($1994)/
Cost Equation ($1994)
A = 15
A = 8-25
(based on wastewater flow)
A = (0.01)(C)
A = (0.01)(C)
A = (0.035)(C)
A =185/0.75
A = (0.01)(C)
A = -1.409(GPM)2 +
142.64(GPM) + 707.27
General Costs
Electricity usage fee
O&M labor rate
Water usage fee
$0.047/ kilowatt-hour
$25.90/hour
$2.98/1,000 gal of water
Practice/
Technology
Oil/Water Separation
Oil/Water Separation
Filter Press
Sludge Dewatering
DAF
DAF
pH Adjustment
Filter Press,
Sludge Dewatering
Reverse Osmosis
x
All
All
Flow Reduction
Reference
(10, 11,
38)
(10, 11,
38)
(14, 15, 23,
24, 28, 29,
30, 36)
(21, 22)
(21, 22)
(21,22)
(14, 23, 28,
29, 30, 36)
(32)
4
(4)
(3)
(5)
A - Annual costs ($1994/year).
ACV - Activated carbon vessel volume (cubic feet).
BPY - Filter press batches per year.
C - Direct capital equipment costs ($1994).
DPY - Operating days per year.
DAF - Dissolved Air Flotation.
FMV - Filter media vessel volume (cubic feet).
FPT - Flow per tank (gallons).
GPM - Flow rate (gallons per minute).
HPD - Operating hours per day.
REG - Subcategory regulatory flow per tank (gallons).
X - Tank volume (gallons).
                                                10-64
-------
                                                             Section 10 - Costs of Technology Bases for Regulations
                                           Table 10-5
            Cost Summary of Regulatory Options for BPT/BATYBCT (a)
Subcategory
Barge/Chemical
Barge/Chemical
Rail/Chemical
Rail/Chemical
Rail/Chemical
Truck/Chemical
Truck/Chemical
Truck/Food (b)
Truck/Food (b)
Barge/Food (b)
Barge/Food (b)
Barge/Hopper
n
Option 1
1 .
2
1
2
3
1
2
1
2
1
2
1
21?^ iSapitaTCost
f <• £) „, (Ptousamdp$1994)
$3,200
$4,800
$113
$272
$282
$134
$134
$0
$0
$0
$0
$160 (c)
OfcMGost^ " * j
CThousand^r (itf$1994))*'|
$1,900
$2,100
$42
$72.9
$29.9
$104
$104
$0
$0
$0
$0 .
$480 (c)
Source: Output from the Transportation Equipment Cleaning Industry Design and Cost Model.


(a) Costs are based on monthly monitoring for regulated toxic pollutants and weekly monitoring for conventional
pollutants (see (c)).
(b) All direct dischargers in these subcategories currently operate oil/water separation, equalization, and biological
treatment and are expected to meet the pollutant discharge long-term averages without incurring any additional
capital or annual costs.
(c) Costs are based on only monthly monitoring for all pollutants.
                                              10-65
-------
                                                        Section 10 - Costs of Technology Bases for Regulations
                                        Table 10-6
                Cost Summary of Regulatory Options for PSES (a)
Subcategory
Barge/Chemical
Barge/Chemical
Barge/Chemical
Rail/Chemical
Rail/Chemical
Rail/Chemical
Truck/Chemical
Truck/Chemical
Barge/Food
Barge/Food
Rail/Food
Raiiypood
Thick/Food
Truck/Food
Barge/Hopper
Rail/Hopper
Truck/Hopper
Rail/Petroleum and
Truck/Petroleum (b)
Option
1
2
3
1
2
3
1
2
1
2
1
2
1
2
1
1
1
2
Capital Cost
(Thousand $1994)
$110
$320
$430
$4,400
$10,500
$11,000
$43,500
$53,600
$0
$30.2
$4,710
$41,100
$13,400
$55,300
$0
$0
$310
$1,800
O&MCost
(Thousand $/yr (in $1994))
$220
$240
$220
$1,400
$1,600
$2,600 .
$15,400
$24,700
$30.6
$61.6
$2,520
$3,340
$3,500
$5,510
$26
$28
$390
$830
Source: Output from the Transportation Equipment Cleaning Design and Cost Model.

(a) Costs are based on monthly monitoring of all regulated pollutants.
(b) Rail/Petroleum and Truck/Petroleum Subcategories are combined for reporting purposes.
                                            10-66
-------
                                                            Section 11.0 - Pollutant Reduction Estimates
11.0
POLLUTANT REDUCTION ESTIMATES
             This section describes EPA's estimates of industry pollutant loadings and
pollutant reductions for each of the Transportation Equipment Cleaning Industry (TECI)
technology options described in Section 9.0.  The Agency estimated pollutant loadings and
pollutant reductions from TEC facilities in order to evaluate the impact of pollutant loadings
currently released to surface waters and publicly-owned treatment works (POTWs), to evaluate
the impact of pollutant loadings released to surface waters and POTWs following
implementation of each proposed TECI regulatory option, and to assess the cost-effectiveness of
each TECI regulatory option in achieving these pollutant loading reductions. Untreated, baseline,
and post-compliance pollutant loadings and pollutant reductions were estimated for the pollutants
effectively removed for each TECI subcategory. The identification of pollutants effectively
removed is discussed in Section 7.0.  Untreated, baseline, and post-compliance pollutant loadings
are defined as follows:
                    Untreated loadings - pollutant loadings in raw transportation equipment
                    cleaning (TEC) wastewater. These loadings represent pollutant loadings
                    generated by the TECI, and do not account for wastewater treatment
                    currently in place at TEC facilities.
                    Baseline loadings - pollutant loadings in TEC wastewater currently being
                    discharged to POTWs or U.S. surface waters. These loadings account for
                    wastewater treatment currently in place at TEC facilities.
                    Post-compliance loadings - pollutant loadings in TEC wastewater that
                    would be discharged following implementation of each regulatory option.
                    These loadings are calculated assuming that all TEC facilities would
                    operate wastewater treatment technologies equivalent to the technology
                    bases for the regulatory options evaluated.
The following information is presented in this remainder of this chapter:
                    Section 11.1 presents the general methodology used to calculate TECI
                    pollutant loadings and pollutant reductions;
                                          11-1
-------
                                                            Section 11.0 - Pollutant Reduction Estimates

                    Section 11.2 presents the general methodology used to estimate untreated
                    pollutant loadings in TEC wastewaters;

                    Section 11.3 presents methodology, used to estimate untreated production
                    normalized pollutant loadings (PNPLs) in TEC wastewaters for multiple
                    subcategory facilities;

                    Section 11.4 presents the estimated untreated pollutant loadings for the
                    TECI;

                    Section 11.5 presents the estimated baseline pollutant loadings for the
                    TECI;

                    Section 11.6 presents the estimated post-compliance pollutant loadings for
                    the TECI;

                    Section 11.7 presents the estimated pollutant loading reductions achieved
                    by the TECI following implementation of each regulatory option; and

                    Section 11.8 presents references for this section.
11.1
General Methodology Used to Calculate Pollutant Loadings
and Pollutant Reductions
              la general, pollutant loadings and pollutant reductions were calculated for the

TECI using the following methodology:
              1.     Field sampling data were analyzed to determine pollutant concentrations in
                    untreated TEC wastewaters.

              2.     These concentrations were converted to untreated production normalized
                    pollutant loadings (PNPLs) for each TECI subcategory using the sampled
                    facility production data (i.e., the number of tanks cleaned), wastewater
                    flow rates, and operating data.

              3.     Untreated PNPLs were used in the TECI cost model (see Section 10.0) to
                    estimate the loading of each pollutant in each model facility untreated TEC
                    wastewater stream.
                                          11-2
-------
                                                Section 11.0 - Pollutant Reduction Estimates

4.     Model facility daily untreated pollutant loadings were converted to
       untreated influent concentrations using facility flow data and a conversion
       factor.

5.     Model facility untreated pollutant loadings and statistically generated
       weighting factors were used to calculate untreated wastewater pollutant
       loadings for the TECI and each TECI subcategory.

6.     Treated effluent concentrations, or treatment effectiveness concentrations,
       that are achieved by treatment technologies that comprise each TECI
       regulatory option were developed using analytical data collected during
       EPA's TECI sampling program (see Section 7.0).

7.     The TECI cost model calculated the pollutant loadings and pollutant
       loading reductions achieved at baseline. For facilities that have existing
       treatment, the cost model compared the untreated TEC wastewater influent
       concentrations to the treatment effectiveness concentrations achieved by
       existing treatment, and determined the pollutant reductions achieved by
       the existing treatment.

8.     The baseline pollutant concentrations were converted to baseline pollutant
       loadings using facility flow rates and a conversion factor.

9.     TECI and TECI subcategory baseline pollutant loadings were calculated
       for each regulatory option using the model facility baseline pollutant
       loadings and statistically generated weighting factors,

10.    The TECI cost model calculated the post-compliance pollutant loadings
       and pollutant reductions achieved by each regulatory option. As discussed
       in Section 9.0, each TECI regulatory option is comprised of a set of
       pollutant control technologies. For each facility, the cost model compared
       the pollutant concentrations in the wastewater influent to the regulatory
       option treatment unit to the treatment effectiveness concentration achieved
       by the treatment unit, and determined the pollutant reductions achieved.

11.    The post-compliance pollutant concentrations  were converted to post-
       compliance pollutant loadings using facility flow rates and a conversion
       factor.

12.    TECI and TECI subcategory post-compliance pollutant loadings were
       calculated for each regulatory option using the model facility post-
       compliance pollutant loadings and statistically generated weighting
       factors.
                             11-3
-------
                                                             Section 11.0 - Pollutant Reduction Estimates
              13.    For each model facility, the pollutant reductions achieved by each
                     regulatory option were calculated by subtracting the post-compliance
                     pollutant loadings from the baseline pollutant loadings.
              14.    TECI and TECI subcategory pollutant reductions achieved by each
                     regulatory option were calculated using the model facility pollutant
                     reductions and statistically generated weighting factors.
11.2
General Methodology Used, to Estimate Untreated Pollut
Loadings
              The Agency used analytical data collected during EPA's TECI sampling program
to calculate untreated PNPLs for pollutants effectively removed by the regulatory options
evaluated for each TECI subcategory (Section 7.0 contains a discussion of pollutants effectively
removed).  The following table lists the number of wastewater characterization samples
collected and analyzed for each TECI subcategory:
Subcategory
Truck/Chemical
Rail/Chemical
Barge/Chemical & Petroleum
Truck/Petroleum
Rail/Petroleum
Thick/Food
Rail/Food
Barge/Food
TYuck/Hopper
Rail/Hopper
Barge/Hopper
Nnmber of Uiitreated'Wastewater
Characterization Samples Collected
10
5
10
5
0
1
1
5
0
0
1
Number of Faculties -,
Sampled
5
2
3
1
0
1
1
1
0
0
1
              Note that although some analytical data were available from facility responses to
the Detailed Questionnaire, these data were not useable for one or more of the following reasons:
(1) the data provided represented samples collected at a variety of treatment system
influent/effluent points that may not correspond to the technology options considered as the bases
                                           11-4
-------
                                                              Section 11.0 - Pollutant Reduction Estimates
for regulation; (2) the data provided were an average estimated by the facility over one or more
sampling days, rather than individual analytical results as required for statistical analyses; and
(3) analytical quality assurance/quality control (QA/QC) data were not provided, prohibiting an
assessment of the data quality.

              For each facility sampled, data on facility production (i.e., number of tanks
cleaned per day), cargo types cleaned, TEC wastewater flow rate, operating hours per day, and
operating days per year were collected. These data were used in conjunction with the untreated
wastewater analytical data to calculate PNPLs for each subcategory using the methodology
described below.

              EPA first calculated PNPLs for each untreated wastewater sample collected at
each facility using the following equation:
                                          C=xcf XF
where:
              Q

              cf
              F
                                                                                       CD
Pollutant i in waste stream
Pollutant loading generated per tank cleaned (milligram/tank or
microgram/tank, depending on the pollutant)
Pollutant concentration in TEC wastewater characterization sample
(milligram/liter or microgram/liter, depending on the pollutant))
Conversion factor, (liters per gallon)
Daily flow rate (gallons/day); gallons per year calculated by
multiplying the flow in gallons per day by the number of operating
days per year
Number of tanks cleaned per day; the number of tanks cleaned per
year was calculated by multiplying the number of tanks cleaned per
day by the number of operating days per year
                                           11-5
-------
                                                             Section 11.0 - Pollutant Reduction Estimates
              Certain pollutants were not detected above the sample detection limits in some
wastewater samples. Because both nondetect and detect results represent the variability of
pollutant concentrations in TEC wastewater, both results were included in calculating PNPLs.
For nondetect results, EPA assumed the pollutant concentration was equal to the sample
detection limit for that pollutant. EPA based this assumption on the expectation that the
pollutant was present in TEC wastewater, albeit at a concentration less than the sample detection
limit.
              If duplicate samples or multiple grab samples (e.g., for HEM and SGT-HEM
analyses) of untreated wastewater were collected at a facility, EPA calculated the daily average
PNPL for each pollutant at that facility using the following equation:
                                              N
where:
              J
              N
                                    DL: =
                                            j=Sample 1
                                                  ~
                                                                                      (2)
Daily average pollutant loading generated per tank cleaned
(milligram/tank or microgram/tank, depending on the pollutant)
Pollutant i in waste stream
Pollutant loading generated per tank cleaned for sample
(milligram/tank or microgram/tank, depending on the pollutant)
Counter for number of duplicate or grab samples collected
Number of duplicate or grab samples collected
              In cases where EPA collected samples from the same sampling point at the same
facility over multiple sampling days, EPA calculated a facility average PNPL using the following
equation:
                                       DayN
    FLi =
                                       j=Day
                                               N
                                                                                      (3)
                                           11-6
-------
where:
              N
                                                              Section 11.0 - Pollutant Reduction Estimates
Facility-specific average pollutant loading generated per tank
cleaned (milligram/tank or microgram/tank, depending on the
pollutant)

Pollutant i in waste stream

Pollutant loading generated per tank cleaned on Day j
(milligram/tank or microgram/tank, depending on the pollutant)

Daily average pollutant loading generated per tank cleaned on Day
j (milligram/tank or microgram/tank, depending on the pollutant)

Counter for number of days of sampling at a specific facility

Number of sampling days at a specific facility
              Finally, EPA calculated average subcategory PNPLs by averaging the applicable

average facility-specific PNPLs as shown in the equation below.  This methodology ensured that

pollutant data from each sampled facility was weighted equally in calculating the subcategory

PNPLs, regardless of the number of wastewater samples collected at each facility.

                                             Facility N
where:
              PNPLj =
              N
       PNPL. = j=Facilityl
              1       N
                                                                                      (4)
Subcategory average production normalized pollutant loading
generated per tank cleaned (milligram/tank or microgram/tank,
depending on the pollutant)

Pollutant i in waste stream

Facility-specific average pollutant loading generated per tank
cleaned (milligram/tank or microgram/tank, depending on the
pollutant)
Counter for number of facilities sampled for a specific subcategory

Number of facilities sampled for a specific subcategory
                                           11-7
-------
                                                             Section 11.0 - Pollutant Reduction Estimates
              Additional information on the calculation of untreated PNPLs for each TECI
subcategory can be found in reference 1.
11.3
Multiple Subcatesorv Facility PNPLs
              Some modeled facilities have production in more than one subcategory. For
example, a facility that cleans both tank trucks and rail tank cars that last transported chemical
cargos has production in both the Truck/Chemical and the Rail/Chemical Subcategories.  To
simplify compliance cost and pollutant reduction estimates, EPA assigned each multiple
subcategory facility to a single primary subcategory.  As a result of this simplification, EPA
modeled control of all TEC wastewater generated by multiple subcategory facilities using the
technology options evaluated for the facility's primary subcategory (rather than segregating and
treating the waste streams in separate wastewater treatment systems). EPA accounted for
untreated TEC wastewater pollutant loadings from other secondary subcategories by using the
PNPLs from secondary subcategory wastewater for those pollutants that were also pollutants
effectively removed for the primary subcategory. Estimation of pollutant reductions for multiple
subcategory facilities is described in greater detail in the rulemaking record.
11.4
TECI Untreated Pollutant Loadings
              TECI untreated pollutant loadings represent the industry pollutant loadings before
accounting for pollutant removal by treatment technologies already in place at TEC facilities.
The Agency estimated untreated pollutant loadings generated by model facilities using the
untreated PNPLs developed for each stream type (i.e., PNPLs for tank trucks cleaned at
Truck/Chemical Subcategory facilities, etc.) and the number of tanks cleaned per year at each
model facility.

              The model facility untreated wastewater pollutant loadings were then weighted
using statistically-derived weighting factors for each model facility. The weighted model facility
loadings were then summed to estimate untreated pollutant loadings for each subcategory and the

                                           11-8
-------
                                                              Section 11.0 - Pollutant Reduction Estimates
entire TECI.  Tables 11-1 through 11-15 present total industry untreated pollutant loadings by
pollutant for each subcategory.
11.5
TECI Baseline Pollutant Loadings
              TECI baseline loadings represent the pollutant loadings currently discharged by
TEC facilities to U.S. surface waters or to POTWs after accounting for removal of pollutants by
existing on-site treatment. Section 10.0 describes the assessment of the treatment in place at
each model TEC facility. The model facility baseline pollutant loadings were calculated as the
difference between the model facility untreated wastewater pollutant loadings calculated as
described in Section 11.4 and the pollutant reductions achieved by treatment in place at each
TECI model facility.

              The model facility baseline pollutant loadings were then weighted using the
statistically-derived weighting factors for each model facility.  The weighted model facility
baseline loadings were then summed to estimate the baseline pollutant loadings for the entire
TECI. Tables 11-1 through 11-15 present the total industry baseline pollutant loadings by
pollutant for each subcategory.
11.6
TECI Post-Compliance Pollutant Loadings by Regulatory
Option
              TECI post-compliance pollutant loadings represent the pollutant loadings that
would be discharged following implementation of the regulatory options. Model facility post-
compliance pollutant loadings were calculated using the following steps. First, model facility
baseline pollutant loadings were calculated as described in Section 11.5. Second, these loadings
were converted to baseline pollutant effluent concentrations for each model facility using the
baseline pollutant loadings, the facility process wastewater flow, and a conversion factor. Third,
the baseline pollutant effluent concentrations were compared to the effluent concentrations
achieved by each regulatory option. Finally, the lower of these concentrations was used along
                                           11-9
-------
                                                             Section 11.0 - Pollutant Reduction Estimates
with the facility flow and an appropriate conversion factor to determine the model facility post-
compliance pollutant loadings for each regulatory option.

              The model facility post-compliance pollutant loadings were then weighted using
the statistically-derived weighting factors for each model facility.  The weighted model facility
post-compliance pollutant loadings were then summed to estimate the post-compliance pollutant
loadings for the entire TECI. Tables 11-1 through 11-15 present the total industry post-
compliance pollutant loadings by pollutant for each subcategory.
11.7
TECI Pollutant Loading Reduction Estimates
              The pollutant loading reductions represent the pollutant removal achieved through
implementation of the regulatory options.  Therefore, the pollutant loading reductions are the
difference between the post-compliance pollutant loadings and the baseline pollutant loadings for
each regulatory option considered. Estimated pollutant loading reductions achieved by each
regulatory option are described below by regulation and are shown in Tables 11-1 through 11-15.
11.7.1
BPT
              The following table summarizes pollutant loading reductions for each TECI
regulatory option considered for BPT. Note that EPA did not develop or evaluate BPT options
for the Truck/Petroleum and Rail/Petroleum Subcategories because the Agency is not aware of
any direct discharging facilities in these subcategories.  In addition, although EPA developed a
BPT option for the Truck/Hopper and Rail/Hopper Subcategories, pollutant reductions for this
option were not estimated for these subcategories because none of the model facilities in these
subcategories are direct dischargers.
                                          11-10
-------
                                                                   Section 11.0 - Pollutant Reduction Estimates

•• "iSubcategory
rruck/Chemical

Rail/Chemical


Barge/Chemical &

Truck/Food,
Rail/Food and
Jarge/Food
Barge/Hopper

Option '
1
2
.1
2
3
1
2
1
2
1
su
"i^';
'EODgia^^-f
20
20
1.7
1.7
1.7
490,000
600,000
0(b)
0(b)
NC
~~^'i - ' - : - *-'"
<-V'^ ',,' ' " , *,\
A '<•••-•'' f j ^
i^B&i&iidffig?'
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? '"'(pffaadsfyealcy '
75
75
10
2,200
2,400
750,000
860,000
0(b)
0(b)
8,600
^ .,
j CHI and Grrease '
(HEM) Loading
' - Seduction '
^(pounds/year;)
240,000
240,000
540
610
610
5,100,000
5,100,000
0(b)
0(b)
NC '
' '-*s^ \f f^^
^,Pnority;- ^
, •, Pollutant %
- Loading
• Reduction •
(pomids/year) -
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5
2.1
4.8
5
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29,000
0(b)
0(b)
1.8
Nbnconyentiona
- > %oHufa^ ;t
^ '•"s.lboaOiiis s ^
Reduction ,^
t >(jpoiinds^yeaE)€
'
-------
                                                             Section 11.0 - Pollutant Reduction Estimates
11.7.3
BAT
              BAT options developed and evaluated by EPA are identical to those developed
and evaluated for BPT. Therefore, BAT pollutant loading reductions are identical to the BPT
pollutant loading reductions for priority and nonconventional pollutants discussed in
Section 11.7.1.
11.7.4
PSES
              The following table summarizes pollutant loading reductions for each TECI
regulatory option considered for PSES.
Subcategory
Truck/Chemical
Rail/Chemical
Barge/Chemical & Petroleum
Truck/Food
Rail/Food
Barge/Food
Truck/Petroleum
Rail/Petroleum
T^uck/Hopper
Option
1
2
1
2.
3
1
2
3
1
2
1
2
1
2
1
2
1
2
1
Priority Pollutant Loading
Seduction {pounds/year)
56,000
97,000
370
390
1,030
1,200
3,500
3,500
5.5
470,000
0
130,000
0
890
NC
410
NC
<1
1.4
Nonconventional Pollutant Loading
Reduction (pounds/year) (a)
107,000
620,000
23,000
33,000
14,000
10,200
17,000
17,000
2,300
120,000,000
0
33,700,000
0
222,000
NC
7,500
NC
27
2,200
                                          11-12
-------
                                                               Section 11.0 - Pollutant Reduction Estimates
Subcategory '
Rail/Hopper •
Barge/Hopper
> *: V
"Option
1
1
,JMoR^olM^I*ading '
RediiefloB (pounds/year)
. 0
<1
NonconyentiorialPofluta^t Loading '*
"s < Reduction (pounds/year) (a)
0
250
(a) The loading reductions presented exclude reduction of COD, TDS, TOC, and TPH.
NC - Pollutant loading reductions not calculated because the regulatory options were not fully evaluated by EPA (see Section
9.0).
              Tables 11-5 through 11-15 present the PSES pollutant loading reduction estimates

for all pollutants and regulatory options for the following subcategories:
                     Truck/Chemical Subcategory (Table 11-5);
                     Rail/Chemical Subcategory (Table 11-6);
                     Barge/Chemical & Petroleum Subcategory (Table 11-7);
                     Truck/Food Subcategory (Table 11-8);
                     Rail/Food Subcategory (Table 11-9);
                     Barge/Food Subcategory (Table 11-10);
                     Truck/Petroleum Subcategory (Table 11-11);
                     Rail/Petroleum Subcategory (Table 11-12);
                     Truck/Hopper Subcategory (Table 11-13);
                     Rail/Hopper Subcategory (Table 11-14); and
                     Barge/Hopper Subcategory (Table 11-15).
11.8
References1
 1.
Eastern Research Group, Inc. Development of Transportation Equipment
Cleaning Industry Production Normalized Pollutant Loadings.  Memorandum
from Grace Kitzmiller, Eastern Research Group, Inc. to the TECI Rulemaking
Record. May 6, 1998 (DCNT09981).
•l For those references included in the administrative record supporting the proposed TECI rulemaking, the
  document control number (DCN) is included in parentheses at the end of the reference.
                                            11-13
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V

V

V

V

V

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V

V

V

V

V

V

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V

V

V

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V

V

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V

V

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7439921







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V

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7439976







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7440020







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55

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7440666







1

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1
1
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ft
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rn

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1
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                                          11-41
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|| Priority Organics

VO
VO
VO

V

V
T-4
V
VO


VO
VO


CO
S3



Acenaphthene
ON

ON
•*'

V

V
V
in


in
>n


oo
VO
0\
oo



Acenaphthylene

o
o
o
T— f
S
T— 1

r-H

S
8
C*-
»— i


O
c*»
r— t
CO
I



1 Acrylonitrile
vo
CO
vq
CO
vo
CO

V

V
V
ON
CO



•*


§



Anthracene

o
oo
o
VO
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V


O
oo
1—4
O
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s
t— *

1— 1



I Benzene

*-H
cs
T— 4
1— H
i-H

V

V
r— <
V
C4





CO
OO
OO
OO
O



|| Toluene

o
o
ON

3


1
o
o
ts
CO


o
o
ro
f)

S
1
O
1 TOTAL Priority*
                                       11-42
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H
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sill

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                               o
                               o
                               o
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o
o
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o"
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o"
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o
o
o
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en
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en
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en
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oo
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Calcium
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o
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o
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o
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vo
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oo
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vo
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VO
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|| Magnesium
0,
ON



O






0)
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ON




>D
VO
ON
ON
§














Manganese
0,
en



o






CM
en








01
en




t-~
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§














|| Molybdenum
11-49
-------
I

rt *• B SS
ii!ji
Option 1
Wastewater
Pollutant
Loading
db/yr)

K
IP

b
•1
Z
a
£

0-

ci


0
cl


CN

7723140





Phosphorus

—

0

*— «


»— «
7440097





1



0

8


O
i— (
7440235





1
o
CO



0




*— 1
7704349





Ui
1
CO

V

0

V


V
7440257





1 Tantalum
•n.


0
in


>n

7440315





_e

V

0

V


V
a
to





1 Titanium

V

o

V


V
7440337





| Tungsten

V

0

V


V
7440622





|| Vanadium

V

0

V


V
7440677





Zirconium

§
in
0

o
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o
in

1
>5
1

IB
|| TOTAL Nonconven




-







1

Gfl
1
j
01


0
«.


«

2027170




JH
1 2-Isopropylnaphthale
01


o
01


ol

r- *





2-Methylnaphthalene

oo

0

oo


00
I





« Acetone

CO

0

CO


CO
CO
vo





|| Benzoic Acid

V

o

V


V
<3\





s

V

o

V


V
00
O





I Diphenyl Ether

— '

o





T— (
r— t





| Hexanoic Acid



o

CO


CO
CO
oo
CO
T— 4





I
e

f-

o





CO
CO





1
•?>
!
f^


o
r.


^

1-H
0
I




B
1 Methyl Isobutyl Keto
»H


O
rH


1— 1

CO
T— (
g
s





I n-Hexacosane
                                       11-50
-------
I
•a

i
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   I

CU
£• fl XC Sa '£"
1,1 !»£
fl^l s1^
in


111 ft
4-

1
1



o
o


o
o
o

o
f-4
>0
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f— 1
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n-Decane
0
>n


0
0
o
VI

1
cn




o
C

T— I


O
'"-'

VO
r— 1
cn
cn




|l n-Octadecane

cn


0
vo
cn

t-
cn
oo
>n




n-Eicosane
VO
^


o
vq
vo
^

l-H
T— 1
cn
vo
vo




|| n-Tetracosane

?3



01

cn
c>)
5s




1
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1
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T-H
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O
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V
vo
oo
VO
oo
cn
vo




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5


o
^

f^

cn
vo
1




u
T3
a

VO


o
VO

VO

1
r— 1




o
c
o
^


0
o
0
f^

o
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vo




n-Docosane

oo


0
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00
1— 1
136777612




1
o
vo
oo


o
VO
06
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0)
T-H
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(0
g
Pentamethylben

01


o
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fs
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20324338

&
1
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cn
CO


O
cn
CO
cn
oo

i
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vo
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O
i-T

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6
1
£
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                                              11-51  .
-------
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6
 I

S
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Other Nonconv

en
CO



O

O
en
oo

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en
oo
7664417



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oo



o

VD
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VO
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16984488




Fluoride

S-



0

0
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1


1
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Nonconventi
|| TOTAL Other















snrejniio.1
| Other Priority

V



o


V

»— t
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1




| Total Cyanide

V



o


V

l-H
V

fl
3
a
Priority Poll
1 TOTAL Other
















1
&
1
s

V



o


V

V
7440360




|| Antimony

V



o


V

V
7440382




i

V



o

t— 4
V

V
r-
r— t
t-




Beryllium

V



0


V

V
7440439




Cadmium
p




0

o
en


O
en
7440473




1 Chromium





0















'
1
£•
I
£
                                          11-52
-------
1
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jy-
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1














1,2-Dichloroethane

CN
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s








\o
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1,1,1 -Trichloroethane


o\
CO


o

o\
CO









o\
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1













"o
4-Chloro-3-Methylphe


o
CO


O

0
CO









0
CO








CM
S














Benzene


V


0

V









V








t-
*— i
00












i
•a
Bis (2-ethylhexyl) Phtl


CO
IN


0

S









a








••*














Ethylbenzene

«
^"


o
o\
^









o\








CM
O














Methylene Chloride

P-;
^


o
^
^









oq








CO
§
o\














1
I

O
V£>


0
O
VC5









O
vd








1














1

l-H
cs


Q
r
oi









oi








1














Tetrachloroethylene


§


o

8
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t— i








CO
00
CO
CO
o














Toluene


•**


o
"1
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S








vo
o
o\














Trichloroethylene


i


0

§
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!





















S

TOTAL Priority Orgi







ti
c
=3
G
S
s
s .
o
•o
j
S
=3
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§
£
9
GO
•S
I
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1
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o.
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la
&
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jllJfl

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T||j| g,^
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I
£
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|| Bulk Coaventtonals


o

VO
«n


*

•a
5
«
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| 5-Day Biochemical Oxyg

90
O

CO

t-4
*






Oil and Grease (HEM)


0




*






| Total Suspended Solids














i
I
i

oo
CO
o

oo
CO

CO
2






| Chemical Oxygen Deman
CO

o
CO

o\

*






|| Total Dissolved Solids


o




*






1 Total Organic Carbon

V
0

V

V
*
5C
f;;
CO

c

Total Petroleum Hydroca!














i
i
•a
{
e

V
0

V

V
7429905 .






Aluminum

V
o

V

V
7440393






•c
c?
n

V
o

V

V
7440428






1

V
o

V

V
7440702






|| Calcium

V
o

V

V
7440484






•4-J
I

V
0

V

V
18540299






|| Hexavalent Chromium
CO

o
co

CO

7439896






c

V
O

V

V
7439954






1 Magnesium

V
o

V

V
| 7439965






Manganese

V
o

V

V
| 7439987






Molybdenum

V
o

V

V
| 7723140






((Phosphorus
                                       11-54
-------
 o
M
IS
•*-» C4 •£
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jilfi
4"»^jS twt CS ^Q
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in
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§
I
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V
0

V

V
2027170




tu
c
|| 2-Isopropylnaphthale

V
0

V

V
vo
VI






|| 2-Methylnaphthalene


o
OV

C5

vo






|| Acetone

V
o

V

V
S?
CO
VO






|| Benzoic Acid

V
o

V

V
Ov






I
S

V
o

V

V
00
S
0






1 Diphenyl Ether

V
0

V

V
T— 1






1 HexanoicAcid

V
0

V

V
S3
1






i

V
0

V

V
00






§
£
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"?,
1

V
O

V

V
o
oo
O




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IS
1 Methyl Isobutyl Keto

V
o

V

V
CO
S
0
CO
vo






1 n-Hexacosane

V
o

V

V
oo






1 n-Decane

V
o

V

V
1
CO
VO






I
c
                                       11-55
-------
                &
                O
               U

n







Octadecane
c

V
o


V

V
oo
1







Bicosane
c

V
o


V

V
en
vo







Tetracosane
a

V
o


V

V
a
a
8







Tetradecane
c

V
0


V

V
VO
oo
g
en
vo







Triacontane
a

V
o


V

V
en
vo
1







Hexadecane
c

V
o


V

V
1
1—4







Dodecane
a

V
o


V

V
o
t-~
vo







Docosane
a

V
o


V

V
136777612







§
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f
o

V
o


V

V
o






1
1
u
oJ

V
o


V

V
20324338

ft
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U
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1
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t-

V
o


V

V
1
*-H







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>
<*

o
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es
2<
0
"c3
e
1
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H














*•§
1
j
I
o
p

O
O


»— i

p~
T— 1






e
mmonia as Nit
<

V
o


V

y
oo
ei\
vo







1
i
w
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Tf


^


Cft
•a
o
•-a
«
s*
I
OTAL Other
H
                                                      11-56
_
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                                              11-61
-------
-------
                                                              Section 12.0 - Non-Water Quality Impacts
12.0
NON-WATER QUALITY IMPACTS
              Sections 304(b) and 306 of the Clean Water Act require EPA to consider the non-
water quality environmental impacts of effluent limitations guidelines and standards.  Therefore,
EPA evaluated the effects of the Transportation Equipment Cleaning Industry (TECI) proposed
regulatory options on energy consumption, air pollution, and solid waste generation. Sections
12.1 through 12.3 discuss these impacts and Section 12.4 lists references for this section.
Reference 1 summarizes the results of these analyses.  In addition to these non-water quality
impacts, EPA considered the impacts of the proposed rule on noise pollution and water and
chemical use and determined these impacts to be negligible.
12.1
Energy Impacts
              Energy impacts resulting from the proposed regulatory options include energy
requirements to operate wastewater treatment equipment such as aerators, pumps, and mixers.
The Agency evaluated the annual increase in electrical power consumption for each regulatory
option relative to the estimated current industry consumption for wastewater treatment.

              Flow reduction technologies (a component of the proposed regulatory options)
reduce energy requirements by reducing the number of operating hours per day and/or operating
days per year for wastewater treatment equipment currently operated by the TECI. For some-
regulatory options, energy savings resulting from flow reduction exceed requirements for
operation of additional wastewater treatment equipment, resulting in a net energy savings for
these options.
              Based on EPA's proposed options (see Section 9.0), the Agency estimates a net
increase in electricity use for the TECI as a result of the proposed rale would be approximately 6
million kilowatt hours per year.  In 1990, the total U.S. industrial electrical energy purchase was
approximately 756 billion kilowatt hours (2).  EPA's proposed options would increase U.S.
industrial electrical energy purchase by 0.0008 percent. Therefore, the Agency concludes that the
                                          12-1
-------
                                                              Section 12.0 - Non-Water Quality Impacts
effluent pollutant reduction benefits from the proposed technology options exceed the potential
adverse effects from the estimated increase in energy consumption.
12.2
Air Emission Impacts
              Transportation equipment cleaning (TEC) facilities generate volatile and
semivolatile organic pollutants, some of which are also on the list of Hazardous Air Pollutants in
Title 3 of the Clean Air Act Amendments of 1990. Air emissions from TEC facilities occur at
several stages of the equipment cleaning process. Prior to cleaning, tanks which have transported
volatile materials may be opened and vented with or without steam in a process called gas
freeing. At some facilities, tanks are filled to capacity with water to displace vapors to the
atmosphere or to a combustion device.  Tanks are then cleaned, typically using either heated
cleaning solutions or hot water. For recirculated cleaning solutions, pollutants may be volatilized
from heated cleaning solution storage tanks. For TEC wastewater, pollutants may volatilize as
the wastewater falls onto the cleaning bay floor, flows to floor drains and collection sumps, and
conveys to wastewater treatment.  TEC wastewater typically passes through treatment units open
to the atmosphere where further pollutant volatilization may occur.

              EPA performed a WATERS (3) model analysis to determine the quantity of air
emissions that would result from the proposed treatment technology options. Reference 4
describes EPA's model analysis in detail. EPA estimates that the maximum increase in air
emissions would be 148,000 kilograms per year. EPA therefore concluded that the incremental
air emissions resulting from the proposed wastewater treatment technology options are a small
percentage of the total air emissions generated by TEC facilities.
 12.3
 Solid Waste Impacts
              Solid waste impacts resulting from the proposed regulatory options include
 additional solid wastes generated by wastewater treatment technologies. These solid wastes
 consist of wastewater treatment residuals, including sludge, waste oil, spent activated carbon, and

                                           12-2
-------
                                                               Section 12.0 - Non-Water Quality Impacts
spent organo-clay. These impacts are discussed below in Sections 12.3.1 through 12.3.4
respectively.
12.3.1
Wastewater Treatment Sludge
              Wastewater treatment sludge is generated in two forms: dewatered sludge (or
filter cake) generated by a filter press and/or wet sludge generated by treatment units such as
oil/water separators, chemical precipitation/coagulation, coagulation/clarification, dissolved air
flotation, and biological treatment.  The Agency evaluated impacts of the increased sludge
generation for each regulatory option relative to the estimated current industry wastewater
treatment sludge generation.

              Many facilities that currently operate wastewater treatment systems do not
dewater wastewater treatment sludge. Storage, transportation, and disposal of relatively large
volumes of undewatered sludge that would be generated after implementing the TECI regulatory
options is less cost-effective than dewatering sludge on site and disposing the greatly reduced
volume of resulting filter cake. However, following implementation of these regulations, EPA
believes TEC facilities would install sludge dewatering equipment to handle increases in sludge
generation. For these reasons, EPA estimates net decreases in the volume of wet sludge
generated by the industry and net increases in the volume of dry sludge generated by the industry.

              Based on responses to the Detailed Questionnaire, most TEC facilities currently
dispose wastewater treatment sludge in nonhazardous landfills. Sludge characterization data
provided by industry and collected during EPA's TECI sampling program confirm that
wastewater treatment sludge generated by the TECI is nonhazardous as determined by the
Toxicity Characteristic Rule under the Resource Conservation and Recovery Act. Compliance
cost estimates for the TECI regulatory options are based on disposal of wastewater treatment
sludge in nonhazardous waste landfills.
                                          12-3
-------
                                                              Section 12.0 - Non-Water Quality Impacts

             The Agency concludes that the effluent benefits and the reductions in wet sludge

from the proposed technology options exceed the potential adverse effects from the estimated

increase in wastewater treatment sludge generation.
12.3.2
Waste Oil
              EPA estimates that compliance with this regulation will result in an increase in

waste oil generation at TEC sites based on removal of oil from wastewater via oil/water

separation. The Agency evaluated the impacts of the increased waste oil generation for each

regulatory option relative to the estimated current industry waste oil generation.  The increase in

waste oil generation is attributed to the removal of oil from TEC wastewaters prior to discharge

to publicly-owned treatment works or surface waters. This increase reflects a transfer of oil from

the wastewater to a more concentrated waste oil, and does not reflect an increase in overall oil

generation at TEC sites.


              EPA assumes, based on responses to the Detailed Questionnaire, that waste oil

will be disposed via oil reclamation or fuels blending on or off site. Therefore, the Agency does

not estimate any adverse effects from increase waste oil generation.
 12.3.3        Spent Activated Carbon


              Spent activated carbon is generated by the following regulatory options:


                     Truck/Chemical Subcategory - BPT Option 2;
                     Truck/Chemical Subcategory - PSES Option 2;
              •      Rail/Chemical Subcategory - BPT Option 3;
              •      Rail/Chemical Subcategory - PSES Option 3;
              •      Truck/Petroleum Subcategory - PSES Option 2; and
              •      Rail/Petroleum Subcategory -  PSES Option 2.


 Treatment of TEC wastewater via these technology options will generate 16,940,000 pounds

 (8,470 tons) annually of spent activated carbon. EPA assumes that the spent activated carbon

                                           12-4
-------
                                                              Section 12.0 - Non-Water Quality Impacts

will be sent off site for regeneration rather than disposed of as a waste. Possible air emissions

during regeneration are minimal. Therefore, the Agency does not estimate any adverse effects

from activated carbon treatment technologies.
12.3.4
Spent Organo-Clay
              Spent organo-clay is generated by the following options:


              •       Rail/Chemical Subcategory - BPT Option 3; and
              •       Rail/Chemical Subcategory - PSES Option 3.


Treatment of TEC wastewater via these technology options will generate 236,000 pounds (118

tons) annually of spent organo-clay. EPA assumes that the spent organo-clay will be disposed as

a nonhazardous waste. The Agency concludes that the effluent benefits from the proposed

technology options exceed any potential adverse effects from the generation and disposal of spent
organo-clay.
12.4
References1
1.
2.
3.
4.
Eastern Research Group, Inc. Summary of the Results of Non-Water Quality
Impacts Analyses.  Memorandum from Michelle DeCaire, Eastern Research
Group, Inc. to the TECI Rulemaking Record. May 26, 1998 (DCN T10300).

U.S. Department of Commerce.  1990 Annual Survey of Manufacturers, Statistics
for Industry Groups and Industries. M90 (AS)-l, March 1992.

U.S. Environmental Protection Agency, Office of Air Quality Planning and
Standards.  Wastewater Treatment Compound Property Processor and Air
Emissions Estimator (WATERS), Version 4.0.  U.S. Environmental Protection
Agency, Research Triangle Park, NC, May 1, 1995.

Eastern Research Group, Inc. WATERS Analysis of Air Emission Impacts of
TECI Regulatory Options.  May 1998 (DCN T04660).
1 For those references included in the administrative record supporting the proposed TECI rulemaking, the
 document control number (DCN) is included in parentheses at the end of the reference.

                                          12-5
-------
-------
                                  Section 13.0 - Implementation of Proposed Effluent Limitations Guidelines and Standards
 13.0
IMPLEMENTATION OF PROPOSED EFFLUENT
LIMITATIONS GUIDELINES AND STANDARDS
              Using annual average production information supplied by the facility and the
 effluent guidelines, the permitting authority will establish numerical discharge limitations for the
 facility and specify monitoring and reporting requirements.  For direct discharging facilities, the
 effluent limitation guidelines are applicable to the final effluent discharged to U.S. surface
 waters. For indirect discharging facilities, pretreatment standards are applicable to the final
 effluent discharged to a publicly-owned treatment works.

              For the proposed regulations, the production rate is defined as the number of tanks
 cleaned annually divided by the number of days that the facility performs transportation
 equipment cleaning (TEC) operations during that year. Facility production in each subcategory is
 used with the subcategory production normalized mass effluent limitations guidelines and
 standards to calculate facility-specific permit limitations. Permitting authorities must determine
 production based on past production practices, present trends, or committed growth.  Permitting
 authorities have typically used average production over the past five years to represent past
 production practices. In certain circumstances, however, evaluating production for the past five
 years may not be appropriate. For example, if a facility significantly increased the number of
 tanks cleaned within the past two years, permitting authorities should average the production for
 only the past two years.

             EPA has structured the proposed regulation in a building-block approach.  This
 means that the applicable permit limitations for facilities with production in more than one
 subcategory will be the sum of the mass loadings based upon production in each subcategory and
the respective subcategory effluent limitations guidelines. Examples of facilities that fall under
one and more than one subcategory are provided below.
                                          13-1
-------
                                 Section 13.0 - Implementation of Proposed Effluent limitations Guidelines and Standards
Examolel:
             Facility 1 cleaned 1,000 tank trucks in 1996.  1996 was the highest production
year in the past five years and during that year the facility performed TEC operations 250 days.
Of these 1,000 tanks, 500 (50%) last transported petroleum cargos, 300 (30%) last transported
food grade cargos, and 200 (20%) last transported chemical cargos. From the definitions
provided in Section 5.2, all production at facility 1 falls under Subcategory A - Truck/Chemical
(i.e., facilities that clean tank trucks and intermodal tank containers where 10% or more of the
total tanks cleaned at that facility in an average year contained chemical cargos).  The production
rate for the purpose of calculating limitations is:
                                                PROD
                               PRODRATE =
                                              OPDAYS
                                                   (1)
where:
              PRODRATE  =
              PROD

              OPDAYS
 Production rate, tanks/day
 Highest number of tanks cleaned annually in the past five
. years, tanks/year
 Number of TEC operating days in the calendar year used
 for PROD, days
 Using Equation 1:
                            1.000 tanks/year
                             250 days/year
             = 4 tanks/day
 As an example, from Table 2-4, the BPT effluent guidelines for biochemical oxygen demand
 (BOD5) and total suspended solids (TSS) for the Truck/Chemical Subcategory are:
Subcategory
"Ruck/Chemical
Daily Maximum
(grams/tank.)
BODS
145
TSS
281
Monthly Average '',
(grams/tank) ,
BOB5
67.6
TSS
115
                                          13-2
-------
                                  Section 13.0 - Implementation of Proposed Effluent Limitations Guidelines and Standards
 Permit limitations are calculated as follows.

 Daily Maximum BOD5:
                     145 grams/tank x 4 tanks/day = 580 grams BOD5/day

 Daily Maximum TSS:
                    281 grams/tank x 4 tanks/day = 1,124 grams TSS/day

 Monthly Average BOD5:
                   67.6 grams/tank x 4 tanks/day = 270.4 grams BOD5/day
Monthly Average TSS:
                     115 grams/tank x 4 tanks/day = 460 grams TSS/day
Example 2:
              Facility 2 cleaned 1,000 rail tank cars and 500 tank barges in 1996.  1996 was the
highest production year in the past five years and during that year the facility performed TEC
operations 250 days. Of the 1,000 rail tank cars, 950 (95%) last transported food grade cargos
and 50 (5%) last transported chemical cargos.  Of the 500 tank barges, 300 (60%) last transported
chemical cargos and 200 (40%) last transported petroleum cargos. From the definitions provided
in Section 5.2, production at facility 2 falls under both Subcategory E - Rail/Food (i.e., facilities
that clean rail tank cars where 10% or more of the total tanks cleaned at that facility in an average
year contained food grade cargos, so long as that facility does not clean 10% or more of tanks
containing chemical cargos) and Subcategory C - Barge/Chemical & Petroleum (i.e., facilities
that clean tank barges or ocean/sea tankers where  10% or more of the total tanks cleaned at that
facility in an average year contained chemical and/or petroleum cargos).
                                          13-3
-------
                                Section 13.0 - Implementation of Proposed Effluent Limitations Guidelines and Standards
             Using Equation 1, the production rate for the purpose of calculating limitations is:
          1,000 tanks/year
           250 days/year
= 4 tanks / day Rail / Food Subcategory production
             500 tanks/year _ 2 tanks / day B arge / Chemical & Petroleum
             250 days/year =          Subcategory production

As an example, from Tables 2-6 and 2-8, respectively, the BPT effluent guidelines for BOD5 and
TSS for the Barge/Chemical & Petroleum and Rail/Food Subcategories are:
Subcategory
Barge/Chemical & Petroleum
Rail/Food
Daily Maximum
(grams/tank)
BODS
18,300
945
TSS
9,540
3,830
- Monthly Average
(grams/tank)
B03>5
8,600
412
TSS
6,090
1,460
Permit limitations are calculated as follows.

Daily Maximum BOD5:
                    18,300 grams/tank x 2 tanks/day = 36,600 grams/day
                      945 grams/tank x 4 tanks/day = 3,780 grams/day
                         36,600 + 3,780 = 40,380 grams BOD5/day
Daily Maximum TSS:
                    9,540 grams/tank x 2 tanks/day = 19,080 grams/day
                    3,830 grams/tank x 4 tanks/day = 15,320 grams/day
                         19,080 + 15,320 = 34,400 grams TSS/day
                                         13-4
-------
                                  Section 13.0 - Implementation of Proposed Effluent Limitations Guidelines and Standards
Monthly Average BOD5:
                     8,600 grams/tank x 2 tanks/day = 17,200 grams/day
                       412 grams/tank x 4 tanks/day = 1,648 grams/day
                          17,200 + 1,648 = 18,848 grams BOD5/day
Monthly Average TSS:
                     6,090 grams/tank x 2 tanks/day = 12,180 grams/day
                      1,460 grams/tank x 4 tanks/day = 5,840 grams/day
                          12,180 + 5,840 = 18,020 grams TSS/day
                                          13-5
-------
-------
                                                                    Section 14.0 - Analytical Methods
 14.0
ANALYTICAL METHODS
              Section 304(h) of the Clean Water Act directs EPA to promulgate guidelines
establishing test procedures (analytical methods) for analyzing pollutants.  These test procedures
are used to determine the presence and concentration of pollutants in wastewater, and are used
for filing applications and for compliance monitoring under the National Pollutant Discharge
Elimination System (NPDES) found at 40 CFR Parts 122.41(j)(4) and 122.21(g)(7), and for the
pretreatment program found at 40 CFR 403.7(d).  Promulgation of these methods is intended to
standardize analytical methods within specific industrial categories and across industries.

              EPA has promulgated analytical methods for monitoring pollutant discharges at
40 CR Part 136, and has promulgated methods for analytes specific to given industrial categories
at 40 CFR Parts 400 to 480. In addition to the methods developed by EPA and promulgated at
40 CFR Part 136, certain methods developed by others1 have been incorporated by reference into
40 CFR Part 136.

              The analytical method for Oil and Grease and Total Petroleum Hydrocarbons
(TPH) is currently being revised to allow for the use of normal hexane in place of Freon 113, a
chlorofluorocarbon (CFC). Method 1664 will replace the current Oil and Grease Method 413.1
found in 40 CFR 136. In anticipation of promulgation of method 1664, data collected by EPA in
support of the TECI effluent guideline utilized method 1664. Therefore, all effluent limitations
proposed for Oil and Grease and TPH in this effluent  guideline are to be measured by Method
1664.

              For this proposed rule, EPA intends to regulate certain conventional, priority, and
nonconventional pollutants as identified in Section 7.0.  The methods proposed for monitoring
the regulated pollutants are briefly discussed in the following sections:
1 For example, the American Public Health Association publishes Standard Methods for the Examination of Water
 and Wastewater.

                                          14-1
-------
                                                                 Section 14.0 - Analytical Methods
                   Section 14.1: Semivolatile Organic Compounds;
                   Section 14.2: Metals;
                   Section 14.3: Hexane Extractable Material and Silica-Gel Treated Hexane
                   Extractable Material;
                   Section 14.4: Chemical Oxygen Demand;
                   Section 14.5: Biochemical Oxygen Demand; and
                   Section 14.6: Total Suspended Solids.
Section 14.7 lists the references used in this section.
14.1
Semivolatile Organic Compounds
              Semivolatile organic compounds are analyzed by EPA Method 1625, Revision C
(1).  In this method, samples are prepared by liquid-liquid extraction with methylene chloride in a
separator/ funnel or continuous liquid-liquid extractor.  Separate acid and base/neutral extracts
are concentrated and analyzed by high resolution gas chromatography (HRGC) combined with
low  resolution mass spectrometry (LRMS).  The detection limit of the method is usually
dependent upon interferences rather than instrument limitations.  With no interferences present,
minimum levels of 10,20, or 50 ug/L (ppb) can be achieved, depending upon the specific
compound.
 14.2
 Metals
              Metals are analyzed by EPA Method 1620 (2). This method is a consolidation of
 the EPA 200 series methods for the quantitative determination of 27 trace elements by
 inductively coupled plasma (ICP) and graphite furnace atomic adsorption (GFAA), and
 determination of mercury by cold vapor atomic absorption (CVAA). The method also provides a
 semiquantitative ICP screen for 42 additional elements. The ICP technique measures atomic
                                          14-2
-------
                                                                 Section 14.0 - Analytical Methods
emissions by optical spectroscopy. GFAA measures the atomic absorption of a vaporized
sample, and CVAA measures the atomic absorption of mercury vapor. Method detection limits
(MDLs) are influenced by the sample matrix and interferences.  With no interferences present,
compound-specific MDLs ranging from 0.1 to 75 Aig/L (ppb) can be achieved.
14.3
Hexane Extractable Material and Silica-Gel Treated Hexane
Extractable Material
             Hexane Extractable Material (HEM; formerly known as oil and grease) and Silica-
Gel Treated Hexane Extractable Material (SGT-HEM; formerly known as total petroleum
hydrocarbons) are analyzed by EPA Method 1664 (3). In this method, a 1-L sample is acidified
and serially extracted three times with ri-hexane.  The solvent is evaporated from the extract and
the HEM is weighed. For SGT-HEM analysis, the HEM is redissolved in n-hexane and an
amount of silica gel proportionate to the amount of HEM is added to the HEM solution to
remove adsorbable materials. The solution is filtered to remove the silica gel, the solvent is
evaporated, and the SGT-HEM is weighed. This method is capable of measuring HEM and
SGT-HEM in the range of 5 to 1,000 mg/L (ppm), and may be extended to higher concentrations
by analysis of a smaller sample volume..
14.4
Chemical Oxygen Demand
             Chemical oxygen demand (COD) is a measure of the oxygen equivalent of the
organic matter in a sample that is susceptible to oxidation by a strong chemical oxidant.  COD is
measured by EPA Methods 410.1, 410.2, 410.3, and 410.4 (4).  These methods are incorporated
by reference into 40 CFR Part 136. In Methods 410.1,410.2, and 410.3, the organic and
oxidizable inorganic substances in an aqueous sample are oxidized by a solution of potassium
dichromate in sulfuric acid. The excess dichromate is titrated with standard ferrous ammonium
sulfate using orthophenanthroline ferrous complex (ferroin) as an indicator. Method 410.1
covers COD concentrations in the range of 50 - 2,000 mg/L (ppm) whereas Method 410.2 covers
                                         14-3
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                                                                  Section 14.0 - Analytical Methods
COD concentrations from 5 - 50 mg/L.  Method 410.3 is intended for high levels of COD in
saline waters and is generally not applicable to TEC wastewaters.

             In Method 410.4, COD is determined colorimetrically after digestion of the
organic matter in a sample using hot chromic acid solution. Note that highly colored samples
may interfere with the colorimetric determination of COD, in which case Methods 410.1 or 410.2
are used.
14.5
Biochemical Oxygen Demand
              Biochemical oxygen demand (BOD5) is a measure of the relative oxygen
requirements of wastewaters, effluents, and polluted waters. BOD5 is measured by EPA Method
405.1 (4). The BOD5 test specified in this method is an empirical bioassay-type procedure that
measures dissolved oxygen consumed by microbial life while assimilating and oxidizing the
organic matter present. The standard test conditions include dark incubation at 20 °C for a five-
day period, and the reduction in dissolved oxygen concentration during this period yields a
measure of the biological oxygen demand. The practical minimum level of determination is 2
mg/L (ppm).
 14.6
 Total Suspended Solids
              Total suspended solids (TSS) is measured using EPA Method 160.2 (4). In this
 method, a well-mixed sample is filtered through a pre-weighed glass fiber filter. The filter is
 dried to constant weight at 103 -105°C. The weight of material on the filter divided by the
 sample volume is the amount of TSS. The practical range of the determination is 4 - 20,000
 mg/L (ppm).
                                           14-4
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14.7
                                                                   Section 14.0 - Analytical Methods
References1
 1.
2.
3.
4.
U.S. Environmental Protection Agency.  Method 1625. Revision C: Semivolatile
Organic Compounds by Isotope Dilution GCMS. June 1989 (DCN T10220).

U.S. Environmental Protection Agency.  Method 1620: Metals by Inductively
Coupled Plasma Atomic Emission Spectroscopv and Atomic Absorption
Spectroscopv. September 1989 (DCN T10224).

U.S. Environmental Protection Agency.  Method 1664: n-Hexane Extractable
Material (HEM) and Silica Gel Treated n-Hexane Extractable Material (SGT-
HEM) by Extraction and Gravimetrv COil and Grease and Total Petroleum
Hydrocarbons). EPA-821-B-94-004b, April 1995. (DCN T10227).

U.S. Environmental Protection Agency.  Methods for Chemical Analysis of Water
and Wastes. EPA-600/4-79-020, March 1983. (DCN T10228).
1  For those references included in the administrative record supporting the proposed TECI rulemaking, the
 document control number (DCN) is included in parentheses at the end of the reference.

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                                                                          Section 15.0 - Glossary
15.0
GLOSSARY
Administrator - The Administrator of the U.S. Environmental Protection Agency.

Agency - The U.S. Environmental Protection Agency.

Ballast Water Treatment Facility - A facility which accepts for treatment ballast water or any
water which has contacted the interior of cargo spaces or tanks in an ocean/sea tanker.

Baseline Loadings - Pollutant loadings in TEC wastewater currently being discharged to
POTWs or U.S. surface waters.  These loadings take into account wastewater treatment currently
in place at TEC facilities.

BAT - The best available technology economically achievable, as described in Sec. 304(b)(2) of
the Clean Water Act.

BCT - The best conventional pollutant control technology, as described in Sec. 304(b)(4) of the
Clean Water Act.

BMP - Best Management Practice.  Section 304(e) of the Clean Water Act gives the
Administrator the authority to publish regulations to control plant site runoff, spills, or leaks,
sludge or waste disposal, and drainage from raw material storage.

BOD5 - Five day biochemical oxygen demand.  A measure of biochemical decomposition of
organic matter in a water sample. It is determined by measuring the dissolved oxygen consumed
by microorganisms to oxidize the organic matter in a water sample under standard laboratory
conditions of.five days and 20° C, see Method 405.1. BOD5 is not related to the oxygen
requirements in chemical combustion.

BPT - The best practicable control technology currently available, as described in Sec. 304(b)(l)
of the Clean Water Act.

Builder/Leaser - A facility that manufactures and/or leases tank trucks, closed-top hopper tank
trucks, intermodal tank containers, rail tank cars, closed-top hopper rank tank cars, inland tank
barges, closed-top hopper barges, and/or ocean/sea tankers, and that cleans the interiors of these
tank after equipment has been placed in service.

CAA - Clean Air Act. The Air Pollution Prevention and Control Act (42 U.S.C. 7401 et. seq.),
as amended, inter alia, by the Clean Air Act Amendments of 1990 (Public Law 101-549, 104
Stat. 2399).

Cargo - Any chemical, material, or substance transported in a tank truck, closed-top hopper
truck, intermodal tank container, rail tank car, closed-top hopper rail car, inland tank barge,
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                                                                         Section 15.0 - Glossary

closed-top inland hopper barge, ocean/sea tanker, or a similar tank that comes in direct contact
with the chemical, material, or substance. A cargo may also be referred to as a commodity.

Carrier-Operated (Carrier) - A facility that owns, operates, and cleans a tank fleet used to
transport commodities or cargos for other companies.

Centralized Waste Treater (CWT) - A facility that recycles, reclaims, or treats any hazardous
or nonhazardous industrial wastes received from off site and/or wastes generated on site by the
facility.

Centralized Waste Treaters Effluent Guideline - see proposed 40 CFR Part 437, 60 PR 5464,
January 27,1995.

CFR - Code of Federal Regulations, published by the U.S. Government Printing Office. A
codification of the general and permanent rules published in the Federal Register by the
Executive departments and agencies of the federal government.

Closed-Top Hopper Rail Car- A completely enclosed storage vessel pulled by a locomotive
that is used to transport dry bulk commodities or cargos over railway access lines.  Closed-top
hopper rail cars are not designed or contracted to carry liquid commodities or cargos and are
typically used to transport grain, soybeans, soy meal, soda ash, fertilizer, plastic pellets, flour,
sugar, and similar commodities or cargos.  The commodities or  cargos transported come in
direct contact with the hopper interior. Closed-top hopper rail cars are typically divided into
three compartments, carry the same commodity or cargo in each compartment,  and are generally
top loaded and bottom unloaded. The hatch covers on closed-top hopper rail cars are typically
longitudinal hatch covers or round manhole covers.

Closed-Top Hopper Truck - A motor-driven vehicle with a completely enclosed storage vessel
used to transport dry bulk commodities or cargos over roads and highways. Closed-top hopper
trucks are not designed or constructed to carry liquid commodities or cargos and are typically
used to transport grain, soybeans, soy meal, soda ash, fertilizer, plastic pellets, flour, sugar, and
similar commodities or cargos.  The commodities or cargos transported come in direct contact
with the hopper interior. Closed-top hopper trucks are typically divided into three compartments,
cany the same commodity or cargo in each compartment, and are generally top loaded and
bottom unloaded.  The hatch covers used on closed-top hopper trucks are typically longitudinal
hatch covers or round manhole covers.  Closed-top hopper trucks are also commonly referred to
as dry bulk hoppers.

 Closed-Top Hopper Barge - A self- or non-self-propelled vessel constructed or adapted
 primarily to carry dry commodities or cargos in bulk through inland rivers and waterways, and
 may occasionally carry commodities or cargos through oceans and seas when in transit from one
 inland waterway to another. Closed-top inland hopper barges are not designed to carry liquid
 commodities or cargos and are typically used to transport corn, wheat, soy beans, oats, soy meal,
 animal pellets, and similar commodities or cargos. The commodities or cargos transported come
                                           15-2
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                                                                          Section 15.0 - Glossary

in direct contact with the hopper interior. The basic types of tops on closed-top inland hopper
barges are telescoping rolls, steel lift covers, and fiberglass lift covers.

COD - Chemical oxygen demand. A nonconventional, bulk parameter that measures the
oxygen-consuming capacity of refractory organic and inorganic matter present in water or
wastewater. COD is expressed as the amount of oxygen consumed from a chemical oxidant in a
specific test, see Method 410.1.

Commercial Facility - A facility that performs 50 percent of their cleanings for commercial
customers. Many of these facilities perform 90 percent or more commercial cleanings.

Commodity - Any chemical, material, or substance transported in a tank track, closed-top
hopper truck, intermediate bulk container, rail tank car, closed-top hopper rail car, inland tank
barge, closed-top  inland hopper barge, ocean/sea tanker, or  similar tank that comes in direct
contact with the chemical, material, or substance. A commodity may also be referred to as a
cargo.

Consignee - Customer or agent to whom commodities or cargos are delivered.

Contract Hauling - The removal of any waste stream from the facility by a company authorized
to transport and dispose of the waste, excluding discharges to sewers of surface waters.

Conventional Pollutants - The pollutants identified in Sec. 304(a)(4) of the Clean Water Act
and the regulations thereunder (i.e., biochemical oxygen demand (BOD5), total suspended solids
(TSS), oil and grease, fecal coliform, and pH).

CWA - Clean Water Act. The Federal Water Pollution Control Act Amendments of 1972 (33
U.S.C. 1251 et seq.), as amended, inter alia, by the Clean Water Act of 1977 (Public Law 95-
217) and the Water Quality Act of 1987 (Public Law 100-4).

Daily Discharge - The discharge of a pollutant measured during any calendar day or any 24-hour
period that reasonably represents a calendar day.

Dairy Products Processing Effluent Guideline - see 40 CFR Part 405.

Detailed Questionnaire - The 1994 Detailed Questionnaire for the Transportation Equipment
Cleaning Industry.

Direct Capital  Costs - One-time capital costs associated with the purchase, installation, and
delivery of a specific technology. Direct capital costs are estimated by the TECI cost model.

Direct Discharger - A facility that conveys or may convey untreated or facility-treated process
wastewater or nonprocess wastewater directly into surface waters of the United States, such as
rivers, lakes, or oceans.  (See Surface Waters definition.)
                                          15-3
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                                                                          Section 15.0 - Glossary

Discharge - The conveyance of wastewater to: (1) United States surface waters such as rivers,
lakes, and oceans, or (2) a publicly-owned, privately-owned, federally-owned, centralized, or
other treatment works.

Drum - A metal or plastic cylindrical container with either an open-head or a tight-head (also
known as bung-type top) used to hold liquid, solid, or gaseous commodities or cargos which are
in direct contact with the container interior.  Drums typically range in capacity from 30 to 55
gallons.

Dry Bulk Cargo - A cargo which includes dry bulk products such as fertilizers, grain, and coal.

EA - Economic assessment.  An analysis which estimates the economic impacts of compliance
costs on facilities, firms, employment, domestic and international market, inflation, distribution,
environmental justice, and transportation equipment cleaning customers.

Effluent - Wastewater discharges.

Effluent Limitation - Any restriction, including schedules of compliance, established by a State
or the Administrator on  quantities, rates, and concentrations of chemical, physical, biological,
and other constituents which are discharged from point sources into navigable waters, the waters
of the contiguous zone, or the ocean. (CWA Sections 301(b) and 304(b).)

Emission - Passage of air pollutants into the atmosphere via a gas stream or other means.

EPA - The U.S. Environmental Protection Agency.

Facility - A facility is all contiguous property owned, operated, leased, or under the control of the
same corporation or business entity. The contiguous property may be divided by public or
private right-of-way.

Federally-Owned Treatment Works (FOTW) - Any device or system owned and/or operated
by a United States Federal Agency to recycle, reclaim, or treat liquid sewage or liquid industrial
wastes.

Food Grade Cargo - Food grade cargos include edible and non-edible food products.
Specific examples of food grade products include but are not limited to: alcoholic beverages,
animal by-products, animal fats, animal oils, caramel, caramel coloring, chocolate, corn syrup
and other com products, dairy products, dietary supplements, eggs, flavorings, food
preservatives, food products that are not suitable for human consumption, fruit juices, honey,
lard, molasses, non-alcoholic beverages, salt, sugars, sweeteners, tallow, vegetable oils, vinegar,
and water.
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                                                                          Section 15.0 - Glossary

FR - Federal Register, published by the U.S. Government Printing Office, Washington, D.C. A
publication making available to the public regulations and legal notices issued by federal
agencies.

Hazardous Air Pollutants (HAPs) - Substances listed by EPA as air toxics under Section 112
of the Clean Air Act.

Heel - Any material remaining in a tank or container following unloading, delivery, or discharge
of the transported cargo. Heels may also be referred to as container residue, residual materials or
residuals.

Hexane Extractable Material (HEM) - A method-defined parameter that measures the presence
of relatively nonvolatile hydrocarbons, vegetable oils, animal fats, waxes, soaps, greases, and
related materials that are extractable in the solvent n-hexane.  The analytical method for Oil and
Grease is currently being revised to allow for the use of normal hexane in place of Freon 113, a
chlorofluorocarbon (CFC).  Method 1664 (Hexane Extractable Material) will replace the current
Oil and Grease Method 413.1 found in 40 CFR 136.

Independent - A facility that provides cleaning services on a commercial basis, either as a
primary or secondary business, for tanks which they do not own or operate.

Indirect Capital Costs - One-time capital costs that are not technology-specific and are
represented as a multiplication  factor that is applied to the direct capital costs estimated by the
TECI cost model.

Indirect Discharger - A facility that discharges or may discharge pollutants into a publicly-
owned treatment works (POTW).

Industrial Waste Combusters Effluent Guidelines - see proposed 40 CFR Part 444, FR 6325,
February 6, 1998.

In-house Facility - A facility that performs less than 50 percent of their cleanings for
commercial clients. In-house TEC facilities primarily clean their own transportation equipment
and have very few commercial  clients.  Most of these facilities perform less than 10 percent of
their total cleanings for commercial clients.

Inland Tank Barge - A self- or non-self-propelled vessel constructed or adapted primarily to
carry commodities or cargos in bulk in cargo spaces (or tanks) through rivers and inland
waterways, and may occasionally carry commodities or cargos through oceans and seas when in
transit from one inland waterway to another.  The commodities or cargos transported are in direct
contact with the tank interior. There are no maximum or minimum vessel or tank volumes.

Inorganic Chemicals Manufacturing Effluent Guidelines - see 40 CFR Part 415.
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                                                                         Section 15.0 - Glossary

Intermediate Bulk Container (BBC or Tote) - A completely enclosed storage vessel used to
hold liquid, solid, or gaseous commodities or cargos which are in direct contact with the tank
interior. Intermediate bulk containers may be loaded onto flat beds for either truck or rail
transport, or onto ship decks for water transport. IBCs are portable containers with 450 liters
(119 gallons) to 3000 liters (793 gallons) capacity. IBCs are also commonly referred to as totes
or tote bins.

Inter-modal Tank Container - A completely enclosed storage vessel used to hold liquid, solid,
or gaseous commodities or cargos which come in direct contact with the tank interior.
Intermodal tank containers may be loaded onto flat beds for either truck or rail transport, or onto
ship decks for water transport. Containers larger than 3000 liters capacity are considered
mtermodal tank containers. Containers smaller than 3000 liters capacity are considered IBCs.

MP&M - Metal Products & Machinery Effluent Guidelines, new regulation to be proposed in
2000.

New Source - As defined in 40 CFR  122.2 and 122.29, and 403.3(k), a new source is any
building, structure, facility, or installation from which there is or may be a discharge  of
pollutants, the construction of which commenced (1) for purposes of compliance with New
Source Performance Standards, after the promulgation of such standards under CWA Section
306; or (2) for the purposes of compliance with Pretreatment Standards for New Sources, after
the publication of proposed standards under CWA Section 307(c), if such standards are thereafter
promulgated in accordance with that section.

Nonconventional Pollutant - Pollutants that are neither conventional pollutants nor priority
toxic pollutants listed at 40 CFR Section 401.

Nondetect Value - A concentration-based measurement reported below the sample-specific
detection limit that can reliably be measured by the analytical method for the pollutant.

Nonprocess Wastewater - Wastewater that is not generated from industrial processes or that
does not come into contact with process wastewater.  Nonprocess wastewater includes, but is not
limited to, wastewater generated from restrooms, cafeterias, and showers.

Non-Water Quality Environmental Impact - An environmental impact of a control or
treatment technology, other than to surface waters.

NPDES - The National Pollutant Discharge Elimination System authorized under Sec. 402 of the
 CWA. NPDES requires permits for discharge of pollutants from any point source into waters of
 the United States.

 NRDC - Natural Resources Defense Council.

 NSPS - New source performance standards, under Sec. 306 of the CWA.
                                           15-6
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                                                                          Section 15.0 - Glossary

Ocean/Sea Tanker - A self- or non-self-propelled vessel constructed or adapted to transport
commodities or cargos in bulk in cargo spaces (or tanks) through oceans and seas, where the
commodity or cargo carried comes in direct contact with the tank interior. There are no
maximum or minimum vessel or tank volumes.

OCPSF - Organic Chemicals, Plastics, and Synthetic Fibers Manufacturing Effluent Guideline,
see 40 CFR Part 414.

Off Site - "Off site" means outside the bounds of the facility.

Oil and Grease (O&G) - A method-defined parameter that measures the presence of relatively
nonvolatile hydrocarbons, vegetable oils, animal fats, waxes, soaps, greases, and related
materials that are extractable in Freon 113 (l,l,2-trichloro-l,2,2-trifluoroethane). The analytical
method for Oil and Grease and Total Petroleum Hydrocarbons (TPH) is currently being revised
to allow for the use of normal hexane in place of Freon 113, a chlorofluorocarbon (CFC).
Method 1664 (Hexane Extractable Material) will replace the current Oil and Grease Method
413.1 found in 40 CFR 136.  In anticipation of promulgation of Method 1664, data collected by
EPA in support of the TECI effluent guideline utilized Method 1664.  Therefore, all effluent
limitations proposed for Oil and Grease and TPH in this effluent guideline are to be  measured by
Method 1664.

On Site - "On site" means within the bounds of the facility.

Operating and Maintenance (O&M) Costs - All costs related to operating and maintaining a
treatment system for a period of one year, including the estimated costs for compliance
wastewater monitoring of the effluent.

Petroleum Cargo - Petroleum cargos include the products of the fractionation or straight
distillation of crude oil, redistillation of unfinished petroleum derivatives, cracking,  or other
refining processes. For purposes of this rule, petroleum cargos also include products obtained
from the refining or processing of natural gas and coal.  For purposes of this rule, specific
examples of petroleum products include but are not limited to: asphalt; benzene; coal tar; crude
oil; cutting oil; ethyl benzene; diesel fuel; fuel additives; fuel oils; gasoline; greases; heavy,
medium, and light oils; hydraulic fluids, jet fuel; kerosene; liquid petroleum gases (LPG)
including butane and propane; lubrication oils; mineral spirits; naphtha; olefin, paraffin, and
other waxes; tall oil; tar; toluene; xylene; and waste oil.

Petroleum Refining Effluent Guidelines - see 40 CFR Part 415.

PNPL - Production Normalized Pollutant Loading. Untreated wastewater pollutant loading
generated per tank cleaning.

Point Source Category - A category of sources of water pollutants.
                                          15-7
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                                                                          Section 15.0 - Glossary

Pollutants Effectively Removed - Non-pesticide/herbicide pollutants that meet the following
criteria are considered effectively removed: detected two or more times in the subcategory
influent, an average treatment technology option influent concentration greater than
 or equal to five times their analytical method detection limit, and a removal rate of 50 percent or
greater by the treatment technology option. Pesticide/herbicide pollutants that meet the
following criteria are considered effectively removed:  detected in the subcategory influent one or
more times at a concentration above the analytical method detection limit, and a removal rate of
greater than zero by the treatment technology option. All pollutants effectively removed were
used in the environmental assessment and cost effectiveness analyses.

Pollution Prevention - The use of materials, processes, or practices that reduce or eliminate the
creation of pollutants or wastes. It includes practices that reduce the use of hazardous and
nonhazardous materials, energy, water, or other resources, as well as those practices that protect
natural resources through conversation or more efficient use. Pollution prevention consists of
source reduction, in-process recycle and reuse, and water conservation practices.

Post-Compliance Loadings - Pollutant loadings in TEC  wastewater following implementation
of each regulatory option. These loadings are calculated assuming that all TEC facilities would
operate wastewater treatment technologies equivalent to the technology bases for the  selected
regulatory options.

POTW - Publicly-owned treatment works, as defined at 40 CFR 403.3(o).

PPA - Pollution Prevention Act. The Pollution Prevention Act of 1990 (42 U.S.C. 13101 et
seq., Pub. Law 101-508), November 5,1990.

Prerinse - Within a TEC cleaning process, a rinse, typically with hot or cold water, performed at
the beginning of the cleaning sequence to remove residual material from the tank interior.

Presolve Wash - Use of diesel, kerosene, gasoline, or any other type of fuel or solvent as a tank
interior cleaning solution.

Pretreatment Standard - A regulation that establishes industrial wastewater effluent quality
required for discharge to a POTW. (CWA Section 307(b).)

Previously Regulated Facility - Any TEC facility that has major process wastewater streams
that are covered by other effluent  guidelines. TEC operations are usually a very small part of
 their overall  operation. These facilities include organic chemical manufacturers (OCPSF
 Effluent Guideline), centralized waste treaters (CWT Effluent Guideline), dairies (Dairies
 Effluent Guideline), and incinerators (Incinerators Effluent Guideline).

 Priority Pollutants - The pollutants designated by EPA as priority in 40 CFR Part 423,
 Appendix A.
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                                                                         Section 15.0 - Glossary

Privately-Owned Treatment Works - Any device or system owned and operated by a private
company that is used to recycle, reclaim, or treat liquid industrial wastes not generated by that
company.

Process Wastewater - Any water which, during manufacturing or processing, comes into direct
contact with or results from the production or use of any raw material, intermediate product,
finished product, byproduct, or waste product.

PSES - Pretreatment standards for existing sources, under Sec. 307(b) of the CWA.

PSNS - Pretreatment standards for new sources, under Sec. 307(b) and (c) of the CWA.

Rail Tank Car - A completely enclosed storage vessel pulled by a locomotive that is used to
transport liquid, solid, or gaseous commodities or cargos over railway access lines. A rail tank
car storage vessel may have one or more storage compartments, and the stored commodities or
cargos come in direct contact with the tank interior. There are no maximum or minimum vessel
or tank volumes.

RCRA - Resource Conservation and Recovery Act (PL 94-580) of 1976, as amended (42 U.S.C.
6901, et. seq.).

RREL - Risk Reduction Engineering Laboratory.

Screener Questionnaire - The 1993 Screener Questionnaire for the Transportation Equipment
Cleaning Industry.

Shipper-Operated (Shipper) - A facility that transports or engages a carrier for transport of
their own commodities or cargos and cleans the fleet used for such transport. Also included in
the scope of this definition are facilities which provide tank cleaning services to fleets that
transport raw materials to their location.

SIC - Standard industrial classification. A numerical categorization system used by the U.S.
Department of Commerce to catalogue economic activity. SIC codes refer to the products, or
group of products, produced or distributed, or to services rendered by an operating establishment.
SIC codes are used to group establishments by the economic activities in which they are engaged.
SIC codes often denote a facility's primary, secondary, tertiary, etc. economic activities.

Silica Gel Treated Hexane Extractable  Material (SGT-HEM) - A method-defined parameter
that measures the presence of mineral oils that are extractable in the solvent n-hexane and not
adsorbed by silica gel. The analytical method for Total Petroleum Hydrocarbons (TPH) and Oil
and Grease is currently being revised to allow for the use of normal hexane in place of Freon
113, a chlorofluorocarbon (CFC). Method 1664 (Hexane Extractable Material) will replace the
current Oil and Grease Method 413.1 found in 40 CFR 136.  In anticipation of promulgation of
Method 1664, data collected by EPA in support of the TECI effluent guideline utilized Method
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                                                                          Section 15.0 - Glossary

1664. Therefore, all effluent limitations proposed for Oil and Grease and TPH in this effluent
guideline are to be measured by Method 1664.

Source Reduction - Any practice which reduces the amount of any hazardous substance,
pollutant, or contaminant entering any waste stream or otherwise released into the environment
prior to recycling, treatment, or disposal. Source reduction can include equipment or technology
modifications, process or procedure modifications, substitution of raw materials, and
improvements in housekeeping, maintenance, training, or inventory control.

Surface Waters - Waters including, but not limited to, oceans and all interstate and intrastate
lakes, rivers, streams, mudflats, sand flats, wetlands, sloughs, prairie potholes, wet meadows,
playa lakes, and natural ponds.

Tank - A generic term used to describe any closed container used to transport commodities or
cargos. The commodities or cargos transported come in direct contact with the container interior,
which is cleaned by TEC facilities.  Examples of containers which are considered tanks include
but are not limited to: tank trucks, closed-top hopper trucks, intermodal tank containers, rail tank
cars, closed-top hopper rail cars, inland tank barges, closed-top inland hopper barges, ocean/sea
tankers, and similar tanks (excluding drums and intermediate bulk containers). Containers used
to transport pre-packaged materials are not considered tanks, nor are 55-gallon drums or pails.

Tank Truck - A motor-driven vehicle with a completely enclosed storage vessel used to
transport liquid, solid or gaseous materials  over roads and highways. The storage vessel or tank
may be detachable, as with tank trailers, or permanently  attached. The commodities or cargos
transported come in direct contact with the tank interior. A tank truck may have one or more
storage compartments. There are no maximum or minimum vessel or tank volumes.  Tank trucks
are also commonly referred to as cargo tanks or tankers.

TECI - Transportation Equipment Cleaning Industry.

Total Annualized Cost - The sum of annualized total capital investment and O&M costs.  Total
capital investment costs are annualized by spreading them over the life of the project. These
annualized costs are then added to the annual O&M costs.

Total Capital Investment - Total one-time capital costs required to build a treatment system
(i.e., sum of direct and indirect capital costs).

Totes or Tote Bins - A completely enclosed storage vessel used to hold liquid, solid, or gaseous
commodities or cargos which come in direct contact with the vessel interior.  Totes may be
loaded onto flat beds for either truck or rail transport, or onto ship decks for water transport.
There are no maximum or minimum values for tote volumes, although larger containers are
generally considered to be intermodal tank containers. Totes or tote bins are also referred to as
intermediate bulk containers or IBCs. Fifty-five gallon drums and pails are not considered totes
or tote bins.
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                                                                          Section 15.0 - Glossary

TPH,- Total petroleum hydrocarbons. A method-defined parameter that measures the presence
of mineral oils that are extractable in Freon 113 (l,l,2-trichloro-l,2,2-trifluoroethane) and not
adsorbed by silica gel.  The analytical method for TPH and Oil and Grease is currently being
revised to allow for the use of normal hexane in place of Freon 113, a chlorofluorocarbon (CFC).
Method 1664 (Hexane Extractable Material) will replace the current Oil and Grease Method
413.1 found in 40 CFR 136. In anticipation of promulgation of Method 1664, data collected by
EPA in support of the TECI effluent guideline utilized Method 1664.  Therefore, all effluent
limitations proposed for Oil and Grease and TPH in this effluent guideline are to be measured by
Method 1664.

Transportation Equipment Cleaning Facility - Any facility that generates wastewater from
cleaning the interior of tank trucks, closed-top hopper trucks, rail tank cars, closed-top hopper
rail cars, intermodal tank containers, inland tank barges, closed-top hopper barges, ocean/sea
tankers, and other similar tanks (excluding drums and intermediate bulk containers).

Transportation Equipment Cleaning Wastewater - Washwaters which  have come into direct
contact with the tank or container interior including prerinse cleaning solutions, chemical
cleaning solutions, and final rinse solutions. In addition, wastewater generated from washing
vehicle exteriors and equipment and floor washings for those facilities are covered by the
proposed guidelines.

Treatment Effectiveness Concentration - Treated effluent pollutant concentration that can be
achieved by each treatment technology that is part of a TECI regulatory option.

Treatment, Storage, and Disposal Facility (TSDF) - A facility that treats, stores, or disposes
hazardous waste in compliance with the applicable standards and permit requirements set forth in
40 CFR Parts 264, 265, 266, and 270.

TSS - Total suspended solids.  A measure of the amount of particulate matter that is suspended
in a water sample. The measure'is obtained by filtering a water sample of known volume. The
particulate material retained on the filter is then dried and weighed, see Method 160.2.

Untreated Loadings - Pollutant loadings in raw TEC wastewater. These loadings represent
pollutant loadings generated by the TECI, and do no account for wastewater treatment currently
in place at TEC facilities.

U.S.C. - The United States Code.

Zero discharge facility - A facility that does not discharge pollutants to waters of the United
States or to a POTW. Also included in this definition are discharge or disposal of pollutants by
way of evaporation, deep-well injection, off-site transfer to a treatment facility, and land
application.
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