United States
Environmental Protection
Agency
Office of Water
(4303)
EPA-821-R-00-012
June 2000
EPA Final Development Document For
Effluent Limitations Guidelines and
Standards for the Transportation
Equipment Cleaning Category
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FINAL
DEVELOPMENT DOCUMENT
FOR
EFFLUENT LIMITATIONS GUIDELINES AND STANDARDS
FOR THE
TRANSPORTATION EQUIPMENT CLEANING
POINT SOURCE CATEGORY
Carol M. Browner
Administrator
J. Charles Fox
Assistant Administrator, Office of Water
Geoff Grubbs
Director, Office of Science and Technology
Sheila E. Frace
Director, Engineering and Analysis Division
Ronald Jordan
Acting Chief, Chemicals Branch
John linger
Project Manager
June 2000
U.S. Environmental Protection Agency
Office of Water
Washington, DC 20460
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Acknowledgments and Disclaimer
This document has been reviewed and approved for publication by the Engineering and Analysis
Division, Office of Science and Technology. This document was prepared with the support of
Eastern Research Group, Inc. (Contract No. 68-C5-0033), under the direction and review of the
Office of Science and Technology.
EPA would like to acknowledge the exceptional efforts and contributions of Eastern Research
Group, Inc. in the development of this document. ERG has provided invaluable support for the
data collection, data analysis, and engineering assessments and materials contained in this
document.
Neither the U.S. government nor any of its employees, contractors, subcontractors, or their
employees make any warranty, expressed or implied, or assume any legal liability or responsibility
for any third party's use of, or the results of such use of, any information, apparatus, method,
product, or process discussed in this report, or represent that its use by such a third party would
not infringe on privately owned rights.
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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 1-4
2.0 SUMMARY AND SCOPE 2-1
2.1 Applicability of the Regulation 2-1
2.2 Subcategorization 2-3
2.3 Summary of Rule 2-3
2.3.1 Best Practicable Control Technology Currently Available (BPT) 2-3
2.3.2 Best Conventional Pollutant Control Technology (BCT) 2-4
2.3.3 Best Available Technology Economically Achievable (BAT) 2-4
2.3.4 New Source Performance Standards (NSPS) 2-4
2.3.5 Pretreatment Standards for Existing Sources (PSES) 2-5
2.3.6 Pretreatment Standards for New Sources (PSNS) 2-5
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 3-18
3.2.3.4 Calculation of National Estimates 3-20
3.3 Summary of EPA s TECI Site Visit Program from 1993 Through 1999 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 3-24
3.4.2 Information Collected 3-25
3.4.3 Sample Collection and Analysis 3-26
3.5 Summary of Post-Proposal Data Collected 3-26
3.6 Existing Data Sources 3-28
3.6.1 EPA s Ri sk Reduction Engineering Laboratory Treatability
Database 3-28
3.6.2 EPAs Fate of Priority Pollutants in Publicly Owned Treatment Works
Database 3-29
3.6.3 State and Local Agencies 3-29
3.6.4 EPA's Permit Compliance System and Industrial Facilities Discharge
Databases 3-30
3.6.5 U.S. Navy Bilge Wastewater Characterization Data 3-30
3.7 Summary of Publicly Owned Treatment Works Data 3-30
3.8 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, IBC, 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 4-10
4.6 Heel Removal and Disposal 4-11
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
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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 5-6
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 5-15
5.1.10 Treatment Costs 5-15
5.1.11 Non-Water Quality Environmental Impacts 5-15
5.2 Selection of Subcategorization Approach 5-16
5.3 References 5-19
6.0 WATER USE, WASTEWATER CHARACTERIZATION, AND POLLUTANTS OF INTEREST .... 6-1
6.1 Water Use and Wastewater Generation 6-2
6.2 Sources of Wastewater 6-5
6.3 Wastewater Discharge Practices 6-7
6.4 Water Reuse and Recycling 6-8
6.5 Wastewater Characterization 6-10
6.6 Pollutants of Interest 6-12
6.6.1 Truck/Chemical & Petroleum, Rail/Chemical & Petroleum, and
Barge/Chemical & Petroleum Subcategories 6-14
6.6.2 Food Subcategory 6-15
6.6.3 Truck/Hopper, Rail/Hopper, and Barge/Hopper Subcategories 6-15
7.0 POLLUTION PREVENTION AND WASTE WATER TREATMENT TECHNOLOGIES 7-1
7.1 Pollution Prevention Controls 7-1
7.1.1 Use of Dedicated Tanks 7-2
7.1.2 Heel Reduction 7-3
7.1.3 Reduction in the Amount and Toxicity of Chemical Cleaning
Solutions 7-6
7.2 Flow Reduction Technologies 7-8
7.2.1 High-Pressure, Low-Volume Cleaning Equipment 7-8
7.2.2 Monitoring TEC Water Use 7-9
7.2.3 Equipment Monitoring Program 7-9
7.2.4 Cleaning Without Use of Water 7-9
7.2.5 Cascade Tank Cleaning 7-10
7.2.6 Wastewater Recycle and Reuse 7-10
in
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TABLE OF CONTENTS (Continued)
Page
7.3 End-of-Pipe Wastewater Treatment Technologies 7-11
7.3.1 Gravity Settling 7-12
7.3.2 pH Adjustment 7-13
7.3.3 Equalization 7-13
7.3.4 Oil/Water Separation 7-14
7.3.5 Sludge Dewatering 7-15
7.3.5.1 Sludge Drying Bed 7-15
7.3.5.2 Plate-and-Frame Filter Press 7-16
7.3.5.3 Rotary Vacuum Filter 7-16
7.3.5.4 Centrifuge 7-17
7.3.6 Dissolved Air Flotation 7-17
7.3.7 Coagulation/Flocculation 7-18
7.3.8 Filtration 7-19
7.3.9 Clarification 7-20
7.3.10 Biological Oxidation 7-20
7.3.11 Chemical Precipitation/Separation 7-21
7.3.12 Grit Removal 7-22
7.3.13 Chemical Oxidation 7-22
7.3.14 Activated Carbon Adsorption 7-23
7.3.15 Membrane Filtration 7-24
7.3.15.1 Microfiltration 7-25
7.3.15.2 Ultrafiltration 7-25
7.3.15.3 Reverse Osmosis 7-25
7.4 References 7-26
.0 DEVELOPMENT OF CONTROL AND TREATMENT OPTIONS 8-1
8.1 Introduction 8-1
8.2 Best Practicable Control Technology Currently Available (BPT) 8-3
8.2.1 BPT Options for the Truck/Chemical & Petroleum Subcategory 8-4
8.2.2 BPT Options for the Rail/Chemical & Petroleum Subcategory 8-6
8.2.3 BPT Options for the Barge/Chemical & Petroleum Subcategory 8-8
8.2.4 BPT Options for the Food Subcategory 8-10
8.2.5 BPT Options for the Truck/Hopper, Rail/Hopper, and Barge/Hopper
Subcategories 8-11
8.3 Best Conventional Pollutant Control Technology (BCT) 8-12
8.4 Best Available Technology Economically Achievable (BAT) 8-12
8.5 New Source Performance Standards (NSPS) 8-13
8.6 Pretreatment Standards for Existing Sources (PSES) 8-13
8.6.1 PSES Options for the Truck/Chemical & Petroleum Subcategory . . . 8-14
8.6.2 PSES Options for the Rail/Chemical & Petroleum Subcategory 8-15
8.6.3 PSES Options for the Barge/Chemical & Petroleum Subcategory ... 8-17
IV
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TABLE OF CONTENTS (Continued)
Page
8.6.4 PSES Options for the Food Subcategory 8-18
8.6.5 PSES Options for the Truck/Hopper, Rail/Hopper, and Barge/Hopper
Subcategories 8-19
8.6.6 Pollution Prevention Alternative 8-20
8.7 Pretreatment Standards for New Sources (PSNS) 8-21
9.0 COSTS OF TECHNOLOGY BASES FOR REGULATIONS 9-1
9.1 Development of Cost Model Inputs 9-3
9.1.1 Model Site Development 9-3
9.1.2 Supplemental Model Site Development 9-4
9.1.3 Pollutant Control Technology Development 9-6
9.1.4 Model Sites with Production in Multiple Subcategories 9-7
9.2 Costing Methodology 9-8
9.2.1 Wastewater Streams Costed 9-9
9.2.2 Influent Pollutant Concentrations 9-10
9.2.3 Cost Model Development 9-10
9.2.4 Components of Compliance Costs 9-12
9.2.4.1 Capital Costs 9-12
9.2.4.2 Annual Costs 9-15
9.2.5 Treatment-in-Place Credit 9-16
9.2.6 Calculation of Baseline Parameters 9-18
9.2.7 Good Water Conservation Practices and Flow Reduction 9-19
9.2.7.1 Flow Reduction Control Technologies 9-20
9.2.7.2 Development of Target Flows 9-22
9.2.8 Contract Haul in Lieu of Treatment 9-23
9.2.9 Costing Methodology for Direct Dischargers in the Barge/Chemical &
Petroleum Subcategory 9-23
9.3 Design and Cost Elements for Pollutant Control Technologies 9-24
9.3.1 Cost Model Components 9-24
9.3.2 Flow Reduction 9-26
9.3.3 Equalization 9-28
9.3.4 Oil/Water Separation (Vertical Tube Coalescing) 9-29
9.3.5 Oil/Water Separation (American Petroleum Institute
[API] Separator) 9-31
9.3.6 Oil/Water Separation (Gravity) 9-32
9.3.7 Gravity Separation 9-34
9.3.8 Chemical Oxidation, Neutralization, Coagulation, and Clarification .. 9-35
9.3.9 DAF (with pH Adjustment and Chemical Addition) 9-36
9.3.10 DAF (without Chemical Addition) 9-39
9.3.11 Filter Press (for Wastewater Clarification and Biological Treatment Sludge
Dewatering) 9-40
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TABLE OF CONTENTS (Continued)
Page
9.3.12 Biological Treatment 9-41
9.3.13 Biological Treatment with Extended Aeration and/or Polymer-Assisted
Clarification 9-42
9.3.14 Activated Carbon Adsorption (Vessels) 9-44
9.3.15 Organo-Cl ay/Activated Carbon Adsorption 9-45
9.3.16 Reverse Osmosis 9-46
9.3.17 Sludge Dewatering (Plate-and-Frame Filter Press) 9-47
9.3.18 Contract Hauling of Wastewater in Lieu of Treatment 9-49
9.3.19 Compliance Monitoring 9-49
9.3.20 Waste Hauling 9-50
9.4 Summary of Costs by Regulatory Option 9-50
9.5 References 9-51
10.0 POLLUTANT REDUCTION ESTIMATES 10-1
10.1 Methodology Used to Identify Pollutants Included in the Load Removal
Estimates 10-2
10.2 General Methodology Used to Calculate Pollutant Loadings and Pollutant
Reductions 10-3
10.3 General Methodology Used to Estimate Untreated Pollutant Loadings 10-5
10.4 Multiple Subcategory Facility PNPLs 10-9
10.5 TECI Untreated Pollutant Loadings 10-9
10.6 TECI Baseline Pollutant Loadings 10-10
10.7 TECI Post-Compliance Pollutant Loadings by Regulatory Option 10-10
10.8 TECI Pollutant Loading Reduction Estimates 10-11
10.8.1 BPT 10-11
10.8.2 BCT 10-12
10.8.3 BAT 10-12
10.8.4 PSES 10-13
10.9 References 10-14
11.0 NON-WATER QUALITY ENVIRONMENTAL IMPACTS 11-1
11.1 Energy Impacts 11-1
11.2 Air Emission Impacts 11-2
11.3 Solid Waste Impacts 11-4
11.3.1 Wastewater Treatment Sludge 11-4
11.3.2 Waste Oil 11-5
11.4 References 11-6
12.0 OPTION SELECTION AND REGULATED POLLUTANTS 12-1
12.1 Option Selection for Direct Dischargers 12-2
12.1.1 Truck/Chemical & Petroleum 12-2
VI
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TABLE OF CONTENTS (Continued)
Page
12.1.2 Rail/Chemical & Petroleum 12-3
12.1.3 Barge/Chemical & Petroleum 12-5
12.1.4 Food 12-6
12.1.5 Truck/Hopper and Rail/Hopper 12-7
12.1.6 Barge/Hopper 12-7
12.2 Indirect Discharging Options 12-8
12.2.1 Truck/Chemical & Petroleum 12-8
12.2.2 Rail/Chemical & Petroleum 12-10
12.2.3 Barge/Chemical & Petroleum 12-11
12.2.4 Food 12-13
12.2.5 Truck/Hopper, Rail/Hopper, and Barge/Hopper 12-13
12.3 Rationale for Selecting Regulated Pollutants 12-14
12.4 Regulated Pollutants for Direct Dischargers 12-16
12.4.1 Truck/Chemical & Petroleum 12-17
12.4.2 Rail/Chemical & Petroleum 12-18
12.4.3 Barge/Chemical & Petroleum 12-19
12.4.4 Food 12-20
12.5 Regulated Pollutants for Indirect Dischargers 12-20
12.5.1 Truck/Chemical & Petroleum 12-23
12.5.2 Rail/Chemical & Petroleum 12-23
12.5.3 Barge/Chemical & Petroleum 12-23
12.6 References 12-23
13.0 IMPLEMENTATION OF EFFLUENT LIMITATIONS GUIDELINES AND STANDARDS 13-1
13.1 Facilities Excluded from the TECI Regulation 13-2
13.1.1 Low Flow Exclusion - Unregulated Wastewater 13-2
13.1.2 Manufacturing Facility Covered by Another Point Source Category . 13-3
13.1.3 Manufacturing Facility Not Covered by Another Point Source
Category 13-4
13.1.4 Facility That Cleans Tanks and IBCs 13-5
13.2 Numerical Effluent Limitations 13-6
13.2.1 Single Subcategory Facility 13-6
13.2.2 Multiple Subcategory Facility 13-7
13.2.3 Regulated and Unregulated Wastewater at a Facility 13-9
13.3 Pollutant Management Plan 13-11
14.0 ANALYTICAL METHODS 14-1
14.1 Semivolatile Organic Compounds 14-2
14.2 Metals 14-3
14.3 Hexane Extractable Material and Silica-Gel Treated Hexane
Extractable Material 14-3
vn
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TABLE OF CONTENTS (Continued)
Page
14.4 Biochemical Oxygen Demand 14-3
14.5 Total Suspended Solids 14-4
14.6 References 14-4
15.0 GLOSSARY 15-1
Vlll
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LIST OF TABLES
Page
2-1 Subcategorization for the Transportation Equipment Cleaning Industry 2-6
2-2 Summary of Rules for the Transportation Equipment Cleaning Industry Point
Source Category 2-7
2-3 Summary of Technology Basis for BPT, BCT, BAT, and NSPS 2-8
2-4 Truck/Chemical & Petroleum Subcategory: BPT, BCT, BAT, and NSPS
Concentration-Based Limitations for Discharges to Surface Waters 2-9
2-5 Rail/Chemical & Petroleum Subcategory: BPT, BCT, BAT, and NSPS
Concentration-Based Limitations for Discharges to Surface Waters 2-10
2-6 Barge/Chemical & Petroleum Subcategory: BPT, BCT, BAT, and NSPS
Concentration-Based Limitations for Discharges to Surface Waters 2-11
2-7 Food Subcategory: BPT, BCT, and NSPS Concentration-Based
Limitations for Discharges to Surface Waters 2-12
2-8 Summary of Technology Basis for PSES and PSNS 2-13
2-9 Truck/Chemical & Petroleum Subcategory: PSES and PSNS
Concentration-Based Limitations for Discharges to POTWs 2-14
2-10 Rail/Chemical & Petroleum Subcategory: PSES and PSNS Concentration-
Based Limitations for Discharges to POTWs 2-15
2-11 Barge/Chemical & Petroleum Subcategory: PSES and PSNS Concentration-
Based Limitations for Discharges to POTWs 2-16
3-1 Major Sources Used to Identify Potential TEC Facilities by
Tank Type and Business Operational Structure 3-33
3-2 Sources Used to Identify Potential TEC Facilities 3-34
3-3 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
3-4 Summary of TECI Screener Questionnaire Mail-Out and
Follow-Up Activities 3-38
ix
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LIST OF TABLES (Continued)
Page
3-5 Final Screener Questionnaire Sample Frame Strata and Total Population
Estimates 3-39
3-6 Detailed Questionnaire Sample Frame and Distribution of Facilities in
the TECI Detailed Questionnaire Mailing List by Strata 3-40
3-7 Summary of TECI Detailed Questionnaire Mail-Out and Follow-Up
Activities 3-41
3-8 Detailed Questionnaire Sample Frame Strata and Weights 3-42
4-1 Number of Tanks Cleaned by Cargo Type - Discharging and Zero
Discharge Facilities 4-19
4-2 Distribution of Facilities That Clean a Single Cargo Type - Discharging
and Zero Discharge Facilities 4-20
4-3 Average Volume of Heel Removed per Tank Cleaning by Cargo Group
and Tank Type - Discharging and Zero Discharge Facilities 4-21
4-4 Total Volume of Heel Discharged/Disposed by Cargo Group and
Discharge/Disposal Method - Discharging and Zero Discharge Facilities . . . 4-22
6-1 Estimates of Total Annual Volume of Wastewater Generated
by Facility Type - Discharging Facilities Only 6-17
6-2 Average Volume of Interior Cleaning Wastewater Generated per Tank
Cleaning by Cargo Group and Tank Type - Discharging Facilities Only .... 6-18
6-3 Average Volume of Wastewater Generated per Facility per Day by
Wastewater Stream Type and Facility Type - Discharging Facilities Only ... 6-19
6-4 Total Volume of Wastewater Generated per Day by Wastewater Stream
Type and Facility Type - Discharging Facilities Only 6-20
6-5 Discharge Status by Facility Type 6-21
6-6 Estimates of Total Annual Volume of Wastewater Discharged
By Facility Type and Discharge Status 6-22
6-7 Number of Facilities That Reuse All or Part of TEC Wastewater as
Source Water for TEC Operations 6-23
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LIST OF TABLES (Continued)
Page
6-8 Priority Pollutant List (a) 6-24
6-9 Summary of Raw Wastewater Characterization Data for Truck/Chemical
Facilities 6-25
6-10 Summary of Raw Wastewater Characterization Data for Rail/Chemical
Facilities 6-34
6-11 Summary of Raw Wastewater Characterization Data for Barge/Chemical &
Petroleum Facilities 6-42
6-12 Summary of Raw Wastewater Characterization Data for Truck/Food
Facilities 6-49
6-13 Summary of Raw Wastewater Characterization Data for Rail/Food
Facilities 6-53
6-14 Summary of Raw Wastewater Characterization Data for Barge/Food
Facilities 6-56
6-15 Summary of Raw Wastewater Characterization Data for Truck/Petroleum
Facilities 6-60
6-16 Summary of Raw Wastewater Characterization Data for Barge/Hopper
Facilities 6-64
6-17 Summaries of the Raw Wastewater Characterization Data
for Each Facility Type 6-67
6-18 Pollutants Of Interest By Subcategory 6-68
9-1 Number of Costed Technology Options for Each TECI Subcategory 9-55
9-2 Direct Capital Costs Used by the TECI Cost Model 9-56
9-3 Components of Total Capital Investment 9-62
9-4 Operation and Maintenance Unit Costs Used by the TECI Cost Model 9-63
9-5 Target Wastewater Flow by Facility Type 9-67
9-6 Cost Summary of Regulatory Options for BPT/BAT/BCT (a) 9-68
XI
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LIST OF TABLES (Continued)
Page
9-7 Cost Summary of Regulatory Options for PSES (a) 9-69
10-1 Truck/Chemical & Petroleum Subcategory - Direct Dischargers
Summary of Pollutant Loadings and Reductions by Technology
Option (a) 10-15
10-2 Rail/Chemical & Petroleum Subcategory - Direct Dischargers
Summary of Pollutant Loadings and Reductions by Technology
Option (a) 10-20
10-3 Barge/Chemical & Petroleum Subcategory - Direct Dischargers
Summary of Pollutant Loadings and Reductions by Technology
Option (a) 10-25
10-4 Barge/Hopper Subcategory - Direct Dischargers
Summary of Pollutant Loadings and Reductions by Technology
Option (a) 10-26
10-5 Truck/Chemical & Petroleum Subcategory - Indirect Dischargers
Summary of Pollutant Loadings and Reductions by Technology
Option (a) 10-27
10-6 Rail/Chemical & Petroleum Subcategory - Indirect Dischargers
Summary of Pollutant Loadings and Reductions by Technology
Option (a) 10-32
10-7 Food Subcategory - Indirect Dischargers
Summary of Pollutant Loadings and Reductions by Technology
Option (a) 10-37
10-8 Truck/Hopper Subcategory - Indirect Dischargers
Summary of Pollutant Loadings and Reductions by Technology
Option (a) 10-38
10-9 Rail/Hopper Subcategory - Indirect Dischargers
Summary of Pollutant Loadings and Reductions by Technology
Option (a) 10-39
10-10 Barge/Hopper Subcategory - Indirect Dischargers
Summary of Pollutant Loadings and Reductions by Technology
Option (a) 10-40
xn
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LIST OF TABLES (Continued)
Page
10-11 BPT Pollutant Loading Reductions 10-41
10-12 PSES Pollutant Loading Reductions 10-42
12-1 Pass-Through Analysis for the Truck/Chemical & Petroleum
Subcategory 12-25
12-2 Pass-Through Analysis for the Rail/Chemical & Petroleum Subcategory ... 12-25
12-3 Pass-Through Analysis for the Barge/Chemical & Petroleum
Subcategory 12-25
xni
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LIST OF FIGURES
Page
4-1 Diagram of General TEC Operations 4-23
4-2 Distribution of TEC Facilities by Number of Cargo Types Cleaned -
Discharging and Zero Discharge Facilities 4-24
4-3 Geographic Profile of Discharging and Zero Discharge Facilities in the
TECI Detailed Questionnaire Sample Population 4-25
4-4 Geographic Profile of Discharging and Zero Discharge Truck Facilities
in the TECI Detailed Questionnaire Sample Population 4-26
4-5 Geographic Profile of Discharging and Zero Discharge Rail Facilities
in the TECI Detailed Questionnaire Sample Population 4-27
4-6 Geographic Profile of Discharging and Zero Discharge Barge Facilities
in the TECI Detailed Questionnaire Sample Population 4-28
4-7 Geographic Profile of Discharging and Zero Discharge Facilities in the TECI
Detailed Questionnaire Sample Population that Clean Chemical Cargos .... 4-29
4-8 Geographic Profile of Discharging and Zero Discharge Facilities in the TECI
Detailed Questionnaire Sample Population that Clean Food Grade Cargos . . 4-30
4-9 Geographic Profile of Discharging and Zero Discharge Facilities in the TECI
Detailed Questionnaire Sample Population that Clean Petroleum Cargos .... 4-31
6-1 Water Use Diagram for TEC Operations 6-75
7-1 API Oil/Water Separator 7-27
7-2 Coalescing Oil/Water Separator 7-28
7-3 Plate-and-Frame Filter Press 7-29
7-4 Rotary Vacuum Filter 7-30
7-5 Dissolved Air Flotation Unit with Pressurized Recycle 7-31
7-6 Clarifier 7-32
7-7 Activated Sludge System 7-33
xiv
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LIST OF FIGURES (Continued)
Page
7-8 Batch Chemical Precipitation Unit 7-34
7-9 Membrane Filtration Unit 7-35
xv
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Section 1.0 - Legal Authority
i.o LEGAL AUTHORITY
Effluent limitations guidelines and standards for the Transportation Equipment
Cleaning Industry (TECI) are being promulgated 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 (CWA1
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
establishes BPT effluent limitations based on the average of the best performances of facilities
'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
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Section 1.0 - Legal Authority
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(51FR24974).
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 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
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Section 1.0 - Legal Authority
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
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).
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Section 1.0 - Legal Authority
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 304(m) 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.
1.3 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;
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Section 1.0 - Legal Authority
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 regulation for the
TECI was reviewed for its incorporation of pollution prevention as part of the Agency effort.
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Section 2.0 - Summary and Scope
2.0 SUMMARY AND SCOPE
The final 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 final effluent limitations
guidelines and standards. Section 2.0 highlights the applicability, subcategorization, and
technology bases of the final rule.
2.1 Applicability of the 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, tank barges, closed-top hopper
barges, and ocean/sea tankers used to transport materials or cargos that come into direct contact
with the tank or container interior. Facilities that do not engage in cleaning the interior of tanks
are not within the scope of this rule.
The wastewater flows covered by the final rule include all washwaters that 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 covers wastewater
generated from washing vehicle exteriors, equipment and floor washings, and TEC-contaminated
stormwater for those facilities covered by the guidelines. These wastewater streams are defined
as TEC process wastewater.
The TEC rule includes a low flow exclusion that applies to any facility that
discharges less than 100,000 gallons per year of TEC process wastewater. Facilities discharging
less than 100,000 gallons per year of TEC process wastewater will remain subject to limitations
and standards established on a case-by-case basis using Best Professional Judgement by the
permitting authority.
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Section 2.0 - Summary and Scope
The focus of this rule is on TEC facilities that function independently of other
industrial activities that generate wastewater. The final TEC limitations do not apply to
wastewaters associated with tank cleanings operated in conjunction with other industrial,
commercial, or publicly-owned treatment works (POTW) operations so long as the facility only
cleans tanks that have contained raw materials, by-products and finished products that are
associated with the facility's on-site processes. (On-site means the contiguous and non-
contiguous property within the established boundaries of the facility.)
Facilities that clean tank interiors solely for purposes of shipping products (i.e.,
cleaned for purposes other than maintenance and repair) would be regulated solely under the TEC
guideline. On the other hand, wastewater generated from cleaning tank interiors for the purposes
of maintenance and repair on the tank is not considered TEC process wastewater. It is possible
that some facilities or wastewater generated from some unit operations at these facilities will be
subject to the Metals Products & Machinery (MP&M) effluent guidelines currently being
developed by EPA. Facilities that clean tank interiors solely for the purposes of repair and
maintenance would not be regulated under the TEC guideline. If a facility discharges wastewater
from MP&M activities that are subject to the MP&M guideline and also discharges wastewater
from cleaning tanks for purposes other than repair and maintenance of those tanks, then that
facility may be subject to both guidelines.
If a facility generates TEC process wastewater, but also accepts wastewater
generated off site, then that facility may be subject to either the TEC rule or the Centralized
Waste Treatment rule, depending on the nature of the off-site wastewater. If the off-site
wastewater is solely TEC process wastewater, then the facility would be regulated solely under
the TEC rule. If the off-site wastewater is non-TEC process wastewater, or a combination of
TEC and non-TEC process wastewater, then the facility may be considered a Centralized Waste
Treatment facility and may be subject to the standards established in 40 CFR 437.
2-2
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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 this rule.
2.2 Subcategorization
EPA has subcategorized the TEC point source category into 7 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.
• Truck/Chemical & Petroleum;
• Rail/Chemical & Petroleum;
• Barge/Chemical & Petroleum;
• Food;
• Truck/Hopper;
• Rail/Hopper; and
• Barge/Hopper.
2.3 Summary of Rule
The components of the final 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 has promulgated BPT for the three chemical and petroleum subcategories of
the TECI to control priority, nonconventional, and conventional pollutants in wastewater from
direct dischargers. EPA is also promulgating BPT for the Food Subcategory of the TECI to
control conventional pollutants in wastewater from direct dischargers. The specific pollutants
controlled vary for each subcategory. Table 2-3 summarizes the technology basis for BPT for
each regulated subcategory. Tables 2-4 through 2-7 present the effluent limitations guidelines for
each regulated subcategory.
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Section 2.0 - Summary and Scope
2.3.2 Best Conventional Pollutant Control Technology (BCT)
EPA is promulgating BCT equivalent to BPT for the three chemical and petroleum
subcategories and the Food Subcategory 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 2-7 present the effluent limitations guidelines for each
regulated subcategory.
2.3.3 Best Available Technology Economically Achievable (BAT)
EPA is promulgating BAT equivalent to BPT for the three chemical and petroleum
subcategories of the TECI to control priority and nonconventional pollutants in wastewater from
direct dischargers. EPA is not promulgating BAT for the Food Subcategory because EPA is not
regulating 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 effluent limitations guidelines for each regulated
subcategory.
2.3.4 New Source Performance Standards (NSPS)
EPA is promulgating NSPS for the three chemical and petroleum subcategories of
the TECI to control priority, nonconventional, and conventional pollutants in wastewater from
new direct dischargers. EPA is also promulgating NSPS for the Food Subcategory 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
NSPS for each regulated subcategory. Tables 2-4 through 2-7 present the effluent limitations
guidelines for each regulated subcategory.
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Section 2.0 - Summary and Scope
2.3.5 Pretreatment Standards for Existing Sources (PSES)
EPA is promulgating PSES for the three chemical and petroleum subcategories of
the TECI to control priority and nonconventional pollutants in wastewater from indirect
dischargers. The specific pollutants controlled vary for each subcategory. Table 2-8 summarizes
the technology basis for PSES for each regulated subcategory. Tables 2-9 through 2-11 present
the pretreatment standards for each regulated subcategory for discharges to POTWs.
EPA is also promulgating an enforceable pollution prevention alternative, referred
to as the Pollutant Management plan. The requirements of the Pollutant Management Plan are
specified in 40 CFR Part 442 and described in section 8.6.6 of this document.
2.3.6 Pretreatment Standards for New Sources (PSNS)
EPA is promulgating PSNS for the three chemical and petroleum 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 2-8 summarizes
the technology basis for PSNS for each regulated subcategory. Tables 2-9 through 2-11 present
the pretreatment standards for each regulated subcategory for discharges to POTWs.
EPA is also promulgating an enforceable pollution prevention alternative, referred
to as the Pollutant Management Plan. The requirements of the Pollutant Management Plan are
specified in 40 CFR Part 442 and described in Section 8.6.6 of this document.
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Section 2.0 - Summary and Scope
Table 2-1
Subcategorization for the Transportation Equipment Cleaning Industry
Subcategory
Truck/Chemical &
Petroleum
Rail/Chemical &
Petroleum
Barge/Chemical &
Petroleum
Food
Truck/Hopper
Rail/Hopper
Barge/Hopper
Subcategory Description
TEC facilities that clean tank trucks and intermodal tank containers that
contained chemical and/or petroleum cargos.
TEC facilities that clean rail tank cars that contained chemical and/or petroleum
cargos.
TEC facilities that clean tank barges or ocean/sea tankers that contained
chemical and/or petroleum cargos.
TEC facilities that clean tank trucks, intermodal tank containers, rail tank cars,
tank barges, or ocean/sea tankers that contained food grade cargos.
TEC facilities that clean closed-top hopper trucks.
TEC facilities that clean closed-top hopper rail cars.
TEC facilities that clean closed-top hopper barges.
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Section 2.0 - Summary and Scope
Table 2-2
Summary of Rules for the Transportation Equipment Cleaning Industry Point
Source Category
Subcategory
Truck/Chemical &
Petroleum
Rail/Chemical &
Petroleum
Barge/Chemical &
Petroleum
Food
Truck/Hopper
Rail/Hopper
Barge/Hopper
PSES
/
/
/
BPT
/
/
/
/
BAT
/
/
/
BCT
/
/
/
/
PSNS
/
/
/
NSPS
/
/
/
/
No regulations
2-7
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Section 2.0 - Summary and Scope
Table 2-3
Summary of Technology Basis for BPT, BCT, BAT, and NSPS
Subcategory
Truck/Chemical
& Petroleum
Rail/Chemical &
Petroleum
Barge/Chemical
& Petroleum
Food
Technology Basis
BPT
BCT
BAT
NSPS
BPT
BCT
BAT
NSPS
BPT
BCT
BAT
NSPS
BPT
BCT
NSPS
Equalization; Oil/water separation; Turn-key treatment system including
chemical oxidation, neutralization, coagulation, and clarification;
Biological treatment; Activated carbon adsorption; and Sludge
dewatering.
Oil/water separation; Equalizaton; Dissolved air flotation; Biological
treatment; and Sludge dewatering.
Oil/water separation; Dissolved air flotation; Filter press; Biological
treatment; and Sludge dewatering.
Oil/water separation; Equalization; Biological treatment; and Sludge
dewatering.
2-8
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Section 2.0 - Summary and Scope
Table 2-4
Truck/Chemical & Petroleum Subcategory: BPT, BCT, BAT, and NSPS
Concentration-Based Limitations for Discharges to Surface Waters
Pollutant or
Pollutant
Property
BOD5 (a)
TSS (b)
Oil and Grease
(HEM) (c)
pH
Copper
Mercury
[mg/L]
BPT
Daily
Maximum
61
58
36
Monthly
Average
22
26
16
BCT
Daily
Maximum
61
58
36
Monthly
Average
22
26
16
Within 6 to 9 at all times.
0.84
0.0031
NA
NA
NA
NA
NA
NA
BAT
Daily
Maximum
NA
NA
36
NA
0.84
0.0031
Monthly
Average
NA
NA
16
NA
NA
NA
NSPS
Daily
Maximum
61
58
36
Monthly
Average
22
26
16
Within 6 to 9 at all times.
0.84
0.0031
NA
NA
(a) BOD5 - Biochemical oxygen demand (5-day).
(b) TSS - Total suspended solids.
(c) HEM - Hexane extractable material.
NA - Not applicable.
2-9
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Section 2.0 - Summary and Scope
Table 2-5
Rail/Chemical & Petroleum Subcategory: BPT, BCT, BAT, and NSPS
Concentration-Based Limitations for Discharges to Surface Waters
Pollutant or
Pollutant
Property
BOD5 (a)
TSS (b)
Oil and Grease
(HEM) (c)
pH
Fluoranthene
Phenanthrene
[mg/L]
BPT
Daily
Maximum
61
58
36
Monthly
Average
22
26
16
BCT
Daily
Maximum
61
58
36
Monthly
Average
22
26
16
Within 6 to 9 at all times.
0.076
0.34
NA
NA
NA
NA
NA
NA
BAT
Daily
Maximum
NA
NA
36
NA
0.076
0.34
Monthly
Average
NA
NA
16
NA
NA
NA
NSPS
Daily
Maximum
61
58
36
Monthly
Average
22
26
16
Within 6 to 9 at all times.
0.076
0.34
NA
NA
(a) BOD5 - Biochemical oxygen demand (5-day).
(b) TSS - Total suspended solids.
(c) HEM - Hexane extractable material.
NA - Not applicable.
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Section 2.0 - Summary and Scope
Table 2-6
Barge/Chemical & Petroleum Subcategory: BPT, BCT, BAT, and NSPS
Concentration-Based Limitations for Discharges to Surface Waters
Pollutant or
Pollutant
Property
BOD5 (a)
TSS (b)
Oil and Grease
(HEM) (c)
pH
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Zinc
[mg/L]
BPT
Daily
Maximum
61
58
36
Monthly
Average
22
26
16
BCT
Daily
Maximum
61
58
36
Monthly
Average
22
26
16
Within 6 to 9 at all times.
0.020
0.42
0.10
0.14
0.0013
0.58
8.3
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
BAT
Daily
Maximum
NA
NA
NA
NA
0.020
0.42
0.10
0.14
0.0013
0.58
8.3
Monthly
Average
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NSPS
Daily
Maximum
61
58
36
Monthly
Average
22
26
16
Within 6 to 9 at all times.
0.020
0.42
0.10
0.14
0.0013
0.58
8.3
NA
NA
NA
NA
NA
NA
NA
(a) BOD5 - Biochemical oxygen demand (5-day).
(b) TSS - Total suspended solids.
(c) HEM - Hexane extractable material.
NA - Not applicable.
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Section 2.0 - Summary and Scope
Table 2-7
Food Subcategory: BPT, BCT, and NSPS Concentration-Based Limitations for
Discharges to Surface Waters
Pollutant or
Pollutant Property
BOD5 (a)
TSS (b)
Oil and Grease
(HEM) (c)
pH
[mg/L]
BPT
Daily
Maximum
56
230
20
Monthly
Average
24
86
8.8
BCT
Daily
Maximum
56
230
20
Monthly
Average
24
86
8.8
NSPS
Daily
Maximum
56
230
20
Monthly
Average
24
86
8.8
Within 6 to 9 at all times.
(a) BOD5 - Biochemical oxygen demand (5-day).
(b) TSS - Total suspended solids.
(c) HEM - Hexane extractable material.
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Section 2.0 - Summary and Scope
Table 2-8
Summary of Technology Basis for PSES and PSNS
Subpart
A
B
C
Subcategory
Truck/Chemical
& Petroleum
Rail/Chemical
& Petroleum
Barge/Chemical
& Petroleum
Technology Basis
PSES&
PSNS
PSES&
PSNS
PSES&
PSNS
Equalization; Oil/water separation; Turn-key treatment system
including chemical oxidation, neutralization, coagulation, and
clarification; and Sludge dewatering.
Oil/water separation; Equalization; Dissolved air flotation; and Sludge
dewatering.
Oil/water separation; Dissolved air flotation; Filter press; Biological
treatment; and Sludge dewatering.
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Section 2.0 - Summary and Scope
Table 2-9
Truck/Chemical & Petroleum Subcategory: PSES and PSNS Concentration-Based
Limitations for Discharges to POTWs
Pollutant or Pollutant Property
Non-polar Matenal (SGT-HEM)
(a)
Copper
Mercury
Daily Maximum [mg/L]
PSES
26
0.84
0.0031
PSNS
26
0.84
0.0031
(a) SGT-HEM - Silica-gel treated hexane extractable material.
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Section 2.0 - Summary and Scope
Table 2-10
Rail/Chemical & Petroleum Subcategory: PSES and PSNS Concentration-Based
Limitations for Discharges to POTWs
Pollutant or Pollutant Property
Non-polar Matenal (SGT-HEM) (a)
Fluoranthene
Phenanthrene
Daily Maximum [mg/L]
PSES
26
0.076
0.34
PSNS
26
0.076
0.34
(a) SGT-HEM - Silica-gel treated hexane extractable material.
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Section 2.0 - Summary and Scope
Table 2-11
Barge/Chemical & Petroleum Subcategory: PSES and PSNS Concentration-Based
Limitations for Discharges to POTWs
Pollutant or Pollutant Property
Non-polar Matenal (SGT-HEM) (a)
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Zinc
Daily Maximum [mg/L]
PSES
26
0.020
0.42
0.10
0.14
0.0013
0.58
8.3
PSNS
26
0.020
0.42
0.10
0.14
0.0013
0.58
8.3
(a) SGT-HEM - Silica-gel treated hexane extractable material.
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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 Transportation Equipment
Cleaning Industry (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 transportation equipment cleaning (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 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 (2). 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.
Raw TEC wastewater, treated effluent, and sludge were collected and analyzed at each facility.
3-1
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Section 3.0 - Data Collection Activities
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
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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 perform 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 perform 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
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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 facilities. However,
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Section 3.0 - Data Collection Activities
the Agency 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:
• 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.
3.2.2.1 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.
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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, which minimizes the statistical
variance for a fixed total sample size (3):
% = n -nrhvh (1)
where:
h = Cell (e.g., barge-medium)
n = Total number of facilities remaining to be allocated [4,000 - 1,211
(high) = 2,789]
nh = Sample size for each cell
Nh = Total number of facilities in each cell for which records are
available
Ph = Probability of performing TEC operations
Qh = l-Ph
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,
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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).
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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, responses from these facilities
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Section 3.0 - Data Collection Activities
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.
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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:
Nh = Total number of facilities in stratum
nh = 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 4.
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 source
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Section 3.0 - Data Collection Activities
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:
• Develop an industry profile;
• Characterize TEC processes, industry production (i.e., number and type(s)
of tanks cleaned), and water usage and wastewater treatment;
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Section 3.0 - Data Collection Activities
• Perform an industry sub categorization analysis;
• Develop pollutant loadings and reductions estimates;
• Develop compliance cost estimates; and
• Determine the impacts of the rulemaking on the TECI.
3.2.3.1 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.
Tank Type
Truck
Rail
Barge
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Section 3.0 - Data Collection Activities
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 5 and 6.
The following criteria were used to select the 275 Detailed Questionnaire
recipients:
Select a random sample of facilities, stratified by tank type, from the TECI
Screener Questionnaire census stratum;
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Section 3.0 - Data Collection Activities
• 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 most 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
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
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Section 3.0 - Data Collection Activities
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
2. PartB: 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
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Section 3.0 - Data Collection Activities
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.
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.
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Section 3.0 - Data Collection Activities
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
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
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Section 3.0 - Data Collection Activities
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 (7). Detailed
information on Part B is presented in the economic analysis report (8).
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
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Section 3.0 - Data Collection Activities
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
(9) 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 (10)
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.
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
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Section 3.0 - Data Collection Activities
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 11.
During review of the Detailed Questionnaire responses, the Agency classified each
facility within one of the following three categories:
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).
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
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Section 3.0 - Data Collection Activities
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 Industrial Waste Combustors (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
Responses Received
93
49
34
Estimated Number of Facilities in
Total Population
692
547
1,166
3.3 Summary of EPA's TECI Site Visit Program from 1993 Through 1999
The Agency conducted 44 engineering site visits (13 of which were conducted
concurrently with sampling) at 43 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 TEC
facilities. The following table summarizes the number of site visits performed by primary tank
type cleaned.
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Section 3.0 - Data Collection Activities
Primary Tank Type Cleaned
Truck/Intermediate Bulk Container
Rail
Barge
Tanker
Closed-Top Hopper Barge
Number of Facilities Visited
22
10
9 (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.
4.
5.
Tank Types Cleaned: Truck, Rail, Barge, Intermodal Tank Container,
Intermediate Bulk Container, Tanker, Closed-Top Hoppers;
Operational Structure: Independent, Carrier, Shipper, Combinations;
Treatment: Advanced, Secondary, Primary, None;
Cargo Types Cleaned: Chemicals, Food grade, Petroleum, Combinations; and
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
which case facility-specific selection criteria are contained in sampling episode reports (SERs)
prepared for each facility sampled by EPA. The SVRs and SERs are contained in the
administrative record for this rulemaking.
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Section 3.0 - Data Collection Activities
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;
• 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.
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Section 3.0 - Data Collection Activities
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
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 12.0.
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
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Section 3.0 - Data Collection Activities
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 SERs and/or sampling and analysis plans (SAPs) prepared for each
facility sampled by EPA. The SERs and SAPs 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:
• Dates and times of sample collection;
• Flow 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
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Section 3.0 - Data Collection Activities
• 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) (12) and the
EAD Sampling Guide (13).
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,
analytical methods used, and the analytical results, including quality control samples, are included
in the SERs prepared for each facility sampled.
3.5 Summary of Post-Proposal Data Collected
EPA received 50 comment submissions on the TEC proposed rule. From these
comments, EPA obtained additional data and information from the industry and POTWs,
including monitoring data and information related to cost of treatment and pass through of
3-26
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Section 3.0 - Data Collection Activities
pollutants at POTWs. The monitoring data submitted included 5 days of effluent data from two
truck/chemical facilities and 11 days of final effluent data from an indirect discharger than cleans
IBCs; however, these data were not used because the following were not provided: paired
influent data; specific flow production data for the sampling point; the treatment technologies
used at the facility; and the specific waste streams treated. EPA also received five days of SGT-
HEM data from a POTW for raw wastewater, primary effluent, and secondary effluent waste
streams. EPA acquired additional information regarding IBCs as well as data critiques on the
pesticide/herbicide data. The specific data, information, and comments provided to EPA are
located in the administrative record for this rulemaking.
The Agency obtained self-monitoring data from two additional Barge/Chemical &
Petroleum facilities operating BPT/BAT treatment. The data consisted of effluent data for
conventional pollutants over a one-year period from both facilities, and effluent data for priority
pollutants over a one-year period from one facility, totaling approximately 190 effluent data
points. The facilities also provided self-monitoring data for chemical oxygen demand (COD) at
the influent to biological treatment over the same time period. Complete site visit reports, raw
data results, and statistical methodology are located in the administrative record for this
rulemaking. EPA used these data to calculate effluent limitations for BOD and TSS for the
Barge/Chemical & Petroleum Subcategory as discussed in the Final Statistical Support Document
(14).
EPA also received 17 comment submissions on the Notice of Availability (NOA).
From these comments, EPA obtained additional self-monitoring data for truck/chemical facilities
from one commenter. These data were more representative of the effluent levels at a facility over
a much longer period than was represented by EPA's original data set. Therefore, these data
were used to calculate final limitations. EPA used the data from one Truck/Chemical &
Petroleum Subcategory facility for the calculation of variability factors for copper and mercury.
The complete data set, including lab reports and certified monitoring reports, can be found in
Section 15.2.2 in the administrative record for this rulemaking.
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Section 3.0 - Data Collection Activities
3.6 Existing Data Sources
In developing the TECI effluent guidelines, EPA evaluated the following existing
data sources:
• 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.
3.6.1 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 of interest and to select pollutants to be regulated (see Section 12.0).
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Section 3.0 - Data Collection Activities
3.6.2 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 (15), 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:
• 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.
3.6.3 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.
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Section 3.0 - Data Collection Activities
3.6.4 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.
3.6.5 U.S. Navy Bilge Wastewater Characterization Data
Several facilities in the Barge/Chemical & Petroleum 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 & Petroleum
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 16.
3.7 Summary of Publicly 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
3-30
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Section 3.0 - Data Collection Activities
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
use to determine treatment performance efficiencies. For these reasons, EPA decided not to use
the AMSA data in the development of the final rule.
3.8 References1
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).
U.S. Environmental Protection Agency, Office of Water Regulations and
Standards, February 1986, Report to Congress on the Discharge of Hazardous
Wastes to Publicly-Owned Treatment Works (referred to as the Domestic Sewage
Study "DSS").
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 (DCNT11000).
Radian Corporation. Transportation Equipment Cleaning Industry (TECI) 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).
'For those references included in the administrative record supporting the TECI rulemaking, the document control
number (DCN) is included in parentheses at the end of the reference.
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Section 3.0 - Data Collection Activities
7. U.S. Environmental Protection Agency. Information Collection Request. 1994
Detailed Questionnaire for the Transportation Equipment Cleaning Industry.
November 1994 (DCN T09843).
8. U.S. Environmental Protection Agency. Economic Analysis of Final Effluent
Limitations Guidelines and Standards for the Transportation Equipment Cleaning
Category. EPA 821-R-00-013, June 2000.
9. Radian Corporation. TEC Questionnaire Part A Coding/Review Checklist.
September 12, 1995 (DCN T10249).
10. 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).
11. SAIC. Statistical Methods for Calculating National Estimates. May 1998 (DCN
T11101).
12. Radian Corporation. Draft Quality Assurance Project Plan for the Transportation
Equipment Cleaning Industry. January 19, 1995 (DCNT10233).
13. Viar and Company. BAD Sampling Guide. June 1991 (DCN T10218).
14. U.S. Environmental Protection Agency. Statistical Support Document of Final
Effluent Limitations Guidelines and Standards for the Transportation Equipment
Cleaning Category. June 2000 (DCN 20636).
15. U.S. Environmental Protection Agency. Fate of Priority Pollutant in Publicly-
Owned Treatment Works. EPA 440/1-82/303, September 1982 (DCN T10311).
16. 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).
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Section 3.0 - Data Collection Activities
Table 3-1
Major Sources Used to Identify Potential TEC Facilities by
Tank Type and Business Operational Structure
Tank Trucks, Closed-Top Hopper
Trucks, Intermodal Tank Containers,
and Intermediate Bulk Containers
Rail Tank Cars and Closed-
Top Hopper Rail Cars
Tank Barges, Closed-Top Hopper
Barges, and Ocean/Sea Tankers
Transfer Facilities (Multiple
Modes of Transportation)
Independent
Modern Bulk Transporter, 1993 Tank
Cleaners Directory
Modern Bulk Transporter, 1993 Tank
Trailer Repair Directory
Dun & Bradstreet
1993 Repair Car Directory
1992 Pocket List of Railroad
Officials
Dun & Bradstreet
1993 Inland River Guide
Dun & Bradstreet
1993 American Waterways Shipyard
Conference Shipyard Services
Directory
Modern Bulk Transporter, 1993
Tank Cleaners Directory
1993 Inland River Guide
Carrier
Dun & Bradstreet
1993 National Motor Carriers Directory
Modern Bulk Transporter, 1993 Tank
Cleaners Directory
Modern Bulk Transporter, 1992 Tank
Container Depot Directory
Dun & Bradstreet
Dun & Bradstreet
1993 Inland River Guide
1993 Industrial and Hazardous Waste
Transporters
1993 National Motor Carriers
Directory
Modern Bulk Transporter, 1992
Bulk Transfer Directory
Shipper
TRTNC Users File
1993 Private Fleet Directory
1992 Pocket List of Railroad
Officials
1993 Private Fleet Directory
TRTNC Users File
Dun & Bradstreet
TRTNC Users File
1992 Pocket List of Railroad
Officials
1993 National Motor Carriers
Directory
Builder/Leaser
Modern Bulk Transporter, 1993 Tank
Trailer Repair Directory
1992 Pocket List of Railroad
Officials
Union Tank Car List of Facilities
1993 Inland River Guide
Modern Bulk Transporter, 1993
Tank Trailer Repair Directory
-------
Section 3.0 - Data Collection Activities
Table 3-2
Sources Used to Identify Potential TEC Facilities
Source
Level of
Assurance
Source Code
Potential Tank Barge Cleaning 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)
Metropolitan 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 code
descriptions)
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
All
14
1
25
14
1
15
12
11
13
23
11
12
18
Potential Rail Tank Car Cleaning Facilities
1992 Pocket List of Railroad Officials
Telephone Contacts (All sources)
Union Tank Car List of Facilities
Repair Car Directory, February, 1993
Repair Car Directory, February, 1992
Modem Bulk Transporter, February, 1993, Tank Trailer Repair Directory
1993 Industrial and Hazardous Waste Transporters
Alabama Department of Environmental Management List
Kentucky Department for Environmental Protection List
Mississippi Permitted Facilities
high
high
high
high
high
high
medium
medium
medium
medium
19
All
24
21
20
5
13
3
15
16
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Section 3.0 - Data Collection Activities
Table 3-2 (Continued)
Source
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
Level of
Assurance
medium
medium
low
low
low
Source Code
11
12
11
12
18
Potential Transfer Facilities
1993 Inland River Guide
Modem Bulk Transporter, December 1 992, 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
high
high
medium
medium
low
low
low
14
6
11
12
11
12
18
Potential Tank Truck Cleaning Facilities
Telephone Contacts (All sources)
Modem Bulk Transporter, March 1993, Tank Cleaners Directory
Modem Bulk Transporter, February 1993, Tank Trailer Repair Directory
Modem Bulk Transporter, December 1992, Tank Container Depot Directory
Modem Bulk Transporter, March 1 992, Tank Cleaners Directory
Modem Bulk Transporter, January 1 992, 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
1993 National Motor Carriers Directory
TRINC Owners File
TRINC Users File (Facilities operate tank trucks)
high
high
high
high
high
high
high
high
high
medium
medium
medium
medium
All
4
5
6
7
8
9
26
25
13
17
22
23
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Section 3.0 - Data Collection Activities
Table 3-2 (Continued)
Source
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 Directory
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
low
low
low
low
low
Source Code
3
15
12
11
2
23
12
11
18
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Section 3.0 - Data Collection Activities
Table 3-3
Original Screener Questionnaire Sample Frame and Distribution of Facilities in the TECI Screener
Questionnaire Mailing List by Facility Type and Level of Assurance
Level of Assurance
(Probability of
Performing TEC
Operations)
High
Medium
Low
TOTAL Facilities
Facility Type
Aircraft
Segment (a)
266
487
7
760
Rail Tank Car
Cleaning
157
218
30
405
Tank Barge
Cleaning
78
357
114
549
Tank Truck
Cleaning
604
433
1,133
2,170
Transfer Facilities
106
9
1
116
Total
Facilities
1,211
1,504
1,285
4,000
(a) The Agency has postponed consideration of developing effluent limitations guidelines and standards for the aircraft segment. Data for the aircraft segment are
included only to describe the statistical sampling performed to develop the TECI site identification database and the TECI screener mailing list.
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Section 3.0 - Data Collection Activities
Table 3-4
Summary of TECI Screener Questionnaire Mail-Out and Follow-Up Activities
Activity
Screeners mailed
Screeners remailed
Screeners returned undelivered
Follow-up letters mailed
Follow-up phone calls completed
Number of dry facilities
Screener responses received
In-scope responses
Helpline calls
Inactive facilities
Screeners unaccounted for
Number of Facilities
3,269
184
244
450
755
26
2,963
754
698
268
60
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Section 3.0 - Data Collection Activities
Table 3-5
Final Screener Questionnaire Sample Frame Strata and Total Population
Estimates
Screener
Questionnaire
Strata
1
2
3
4
5
6
7
8
9
10
11
12
13
Screener Questionnaire
Strata Code (Source) (a)
Census (multiple)
Barge-Low (1,12)
Truck-Low (2)
Transfer-Low (11, 12,18)
Truck-Low (12)
Truck-Medium (12)
Truck-Medium (13); Non-
Census
Truck-Medium (17)
Rail-High (19)
Truck-Medium (22)
Truck-Low (23)
Truck-Medium (23)
Truck-Medium (13); Census
Number of In-
Scope Screener
Responses
509
1
38
1
11
13
15
23
63
7
25
17
7
Survey
Weighting
Factor
1.049
7.400
10.619
9.500
8.762
8.532
6.308
8.033
2.093
3.074
33.749
17.272
1.00
TOTAL
Estimated Total
Number of Facilities
in TECI
533.94
7.40
403.51
9.50
96.38
110.91
94.62
184.77
131.86
21.52
843.73
293.62
7.00
2,738.76
(a) Source code listed in Table 3-2.
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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 Code (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 (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
TOTAL
Number of Facilities Selected for
Detailed Questionnaire Mailing
List
4
16
9
9
11
o
3
75
6
1
8
12
1
11
12
15
7
22
18
8
o
J
7
10
7
275
(a) Source code listed in Table 3-2.
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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
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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)
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
Survey Weighting
Factor
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
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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 trucks, closed-top hopper trucks, intermodal tank
containers, rail tank cars, closed-top hopper rail cars, 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 5371 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
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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 segment.
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 process
4-2
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Section 4.0 - Industry Description
chemicals and food products, including milk, vegetable oils, molasses, and corn 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
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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 neutralizers 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 to capacity with
4-4
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Section 4.0 - Industry Description
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, IBC, 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 may
have separate, dedicated cleaning bays, cleaning solutions, and equipment for cleaning tanks that
4-5
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Section 4.0 - Industry Description
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 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
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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 trucks) 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
continuously record the temperature of the recirculating wash water and generates a cleaning
4-7
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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 Types 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 (IBC)
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)
Tank Barge (B)
TOTAL (a)
Number of Cleanings
Per Year
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 (%)
87
o
J
3
o
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
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Section 4.0 - Industry Description
Facility Group
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)
Total Number of Facilities in
Group
913
142
13
160
1,229
Percentage of Total Facilities in
the TECI (%)
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 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
4-9
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Section 4.0 - Industry Description
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 Types 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;
• Group I - Chemical Products;
Group J - Hazardous Waste (as defined by RCRA in 40 CFR Part 261);
• Group K - Nonhazardous Waste;
4-10
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Section 4.0 - Industry Description
• Group L - Dry Bulk Cargos; and
• Group M, N, and O - Other (Not Elsewhere Classified).
Table 4-1 lists the number of tanks cleaned by the industry by cargo type.
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
4-2. 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
offloading system design, and consignee tank offloading system design. Table 4-3 provides a
detailed analysis of the average volume of heel removed per tank cleaning by cargo group and
4-11
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Section 4.0 - Industry Description
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 4-4 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
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
4-12
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Section 4.0 - Industry Description
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 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
4-13
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Section 4.0 - Industry Description
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 Facilities 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.
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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
Number of
Facilities
735
368
197
94
Percentage of Total
Population (%)
60
30
16
7
Total Wastewater
Generation
(gallons per day)
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
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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.
Seven percent 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
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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 and 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
-------
Section 4.0 - Industry Description
4.10 References2
1. U.S. Environmental Protection Agency. Information Collection Request. 1994
Detailed Questionnaire for the Transportation Equipment Cleaning Industry.
November 1994 (DCN T09843).
2. 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).
2For those references included in the administrative record supporting the 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
Number of Tanks Cleaned by 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 Resin (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)
Not specified
TOTAL (a)
Number of Cleanings
Per Year
908,000
214,000
299,000
87,100
137,000
15,500
106,000
14,000
218,000
6,330
12,100
36,900
80,300
305,000
2,440,000
Percentage of Total Number of
Tank Cleanings (%)
37
9
12
4
6
1
4
1
9
<1
<1
2
o
3
13
100
(a) Differences occur due to rounding.
4-19
-------
Section 4.0 - Industry Description
Table 4-2
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 of Facilities That
Clean Only This Cargo Type
(%)
65
16
(a)
NC
NC
NC
2
o
5
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 occur 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.
4-20
-------
Section 4.0 - Industry Description
Table 4-3
Average Volume of Heel Removed per Tank Cleaning by Cargo Group and Tank Type - Discharging and
Zero Discharge Facilities
Cargo Group
Food Grade Products (A)
Petroleum and Coal Products (B)
Latex, Rubber, and Resin (C)
Soaps and Detergent (D)
Biodegradable Organic Chemicals (E)
Refractory Organic Chemicals (F)
Inorganic Chemicals (G)
Agricultural Chemicals and Fertilizers (H)
Chemical Products (I)
Hazardous Waste (J)
Nonhazardous Waste (K)
Dry Bulk Cargos (L)
Tank Type (gallons of heel/tank)
Truck
Tank
20
2
3
2
2
<1
1
<1
<1
<1
9
<1
Rail Tank
58
128
29
51
27
22
19
49
35
(a)
23
6
Tank
Barge
924
1050
(a)
NC
868
683
562
364
616
NC
(a)
NC
Truck
Hopper
6
1
<1
<1
<1
<1
<1
<1
NC
NC
NC
2
Rail
Hopper
165
(a)
(a)
(a)
7
NC
337
15
(a)
NC
NC
90
Barge
Hopper
13
166
NC
NC
NC
NC
NC
112
NC
NC
NC
446
Intermediate
Bulk
Container
NC
<1
2
1
0
NC
<1
NC
0
NC
NC
NC
Intermodal
Tank
Container
2
<1
2
<1
<1
0
0
0
<1
NC
0
NC
(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.
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.
-------
Section 4.0 - Industry Description
Table 4-4
Total Volume of Heel Discharged/Disposed by Cargo Group and Discharge/Disposal Method -
Discharging and Zero Discharge Facilities
Cargo Group
Food Grade Products (A)
Petroleum and Coal Products (B)
Latex, Rubber, and Resin (C)
Soaps and Detergent (D)
Biodegradable Organic Chemicals (E)
Refractory Organic Chemicals (F)
Inorganic Chemicals (G)
Agricultural Chemicals and Fertilizers (H)
Chemical Products (I)
Hazardous Waste (J)
Nonhazardous Waste (K)
Dry Bulk Cargos (L)
Heel Discharge/Disposal Method Code (gallons/year)
WW
591,000
206,000
320,000
35,400
193,000
2,340
951,000
222,000
41,600
NC
15,000
2,160
ID
109,000
45,900
40,100
37,200
15,600
12,500
168,000
NC
(a)
NC
NC
64,400
EV
NC
NC
NC
NC
15,900
NC
NC
NC
NC
NC
NC
NC
LD
212,000
2,100,000
216,000
42,200
12,100
NC
27,800
16,100
53,400
NC
2,050
561,000
LA
NC
659
(a)
2,230
2,790
NC
(a)
138
(a)
NC
(a)
NC
IN
NC
67,000
66,900
3,660
66,100
26,800
717
807
29,900
344
NC
NC
HR
16,200
1,300,000
26,200
13,200
15,700
(a)
NC
NC
9,360
NC
NC
NC
RR
4,510,000
5,420,000
36,500
2,020
1,470,000
166,000
569,000
150,000
542,000
NC
NC
1,360
DW
NC
3,450
239
3,450
11,700
NC
31,200
NC
634
NC
96
96
HD
7,000
91,500
44,100
181,000
247,000
67,000
73,800
285
36,100
22,200
10,600
(a)
to
to
(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.
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.
-------
Section 4.0 - Industry Description
to
Fresh
water
- Hot or cold water wash - Detergent wash
- Hot or cold water rinse - Caustic wash
- Steam clean - Acid wash
- Presolve treatment
Vapor recovery system
Forced-air drying
Boiler
Acid
Solution
Caustic
Solution I
Detergent^
Solution I
Spent cleaning
solutions
High pressure-low
volume spinner -
Chemical-Grade Wash Rack
Cleaning solution
recirculation loop
Off-site disposal
To wastewater treatment )
Treated wastewater recycled
to source water
Figure 4-1. Diagram of General TEC Operations
-------
Section 4.0 - Industry Description
600
8500
u.
o
0>
•Q
300
200
100
1 2 3 4 5 6 7 8 9 10 11 12 13 14
Number of Cargo Types Cleaned
Figure 4-2. Distribution of TEC Facilities by Number of Cargo Types Cleaned
Discharging and Zero Discharge Facilities
4-24
-------
Section 4.0 - Industry Description
Figure 4-3. Geographic Profile of Discharging and Zero Discharge Facilities in the TECI
Detailed Questionnaire Sample Population
4-25
-------
Section 4.0 - Industry Description
Figure 4-4. Geographic Profile of Discharging and Zero Discharge Truck Facilities in the
TECI Detailed Questionnaire Sample Population
4-26
-------
Section 4.0 - Industry Description
Figure 4-5. Geographic Profile of Discharging and Zero Discharge Rail Facilities in the
TECI Detailed Questionnaire Sample Population
4-27
-------
Section 4.0 - Industry Description
Figure 4-6. Geographic Profile of Discharging and Zero Discharge Barge Facilities in the
TECI Detailed Questionnaire Sample Population
4-28
-------
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
4-29
-------
Section 4.0 - Industry Description
Figure 4-8. Geographic Profile of Discharging and Zero Discharge Facilities in the TECI
Detailed Questionnaire Sample Population that Clean Food Grade Cargos
4-30
-------
Section 4.0 - Industry Description
Figure 4-9. Geographic Profile of Discharging and Zero Discharge Facilities in the TECI
Detailed Questionnaire Sample Population that Clean Petroleum Cargos
4-31
-------
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, water 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 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 environmental impacts.
After evaluating the above factors, EPA determined that Subcategorization of the
TECI is necessary.
5-1
-------
Section 5.0 - Industry Subcategorization
5.1 Factors Considered for Basis of Subcategorization
EPA considered a number of potential Subcategorization approaches for the TECI.
EPA used information collected during 44 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, and a detailed analysis can be
found in the Subcategorization Analysis for the Transportation Equipment Cleaning Industry (3).
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.
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 solely 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;
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;
5-2
-------
Section 5.0 - Industry Subcategorization
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
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.
5-3
-------
Section 5.0 - Industry Subcategorization
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:
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);
5-4
-------
Section 5.0 - Industry Subcategorization
• 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 trucks 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 trucks, 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 44 engineering site visits at facilities that clean tank trucks, 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 more 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 trucks 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 wastewater
generated, average wastewater treatment costs currently incurred by facilities differ significantly
for these facility types.
5-5
-------
Section 5.0 - Industry Subcategorization
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 (i.e., 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.
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:
5-6
-------
Section 5.0 - Industry Subcategorization
• 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).
Forty-eight percent of facilities in the TECI 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 or more cargos
suggests no apparent trend in cargo types cleaned, but rather a wide variety of combinations of
"chemical-type" cargos.
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)
5-7
-------
Section 5.0 - Industry Subcategorization
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.
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.
Specifically, EPA developed a separate subcategory for facilities that clean tanks
that contained food grade cargos. EPA also developed separate subcategories for facilities that
clean closed-top hoppers (i.e., vessels that contained dry bulk goods).
EPA considered developing separate subcategories for facilities that clean tanks
that contained "chemical" cargos and for facilities that clean tanks that contained "petroleum"
cargos. EPA compared raw wastewater characterization data collected for wastewaters
generated from barge/chemical and barge/petroleum facilities and concluded the wastewater
characteristics and treatability were similar. Therefore, EPA decided to combine these
subcategories.
EPA also compared raw wastewater characterization data for the truck/chemical
and truck/petroleum facilities, but found fewer similarities. For example, fewer pollutants were
detected at the truck/petroleum facility than at the truck/chemical facilities, and similarly detected
pollutants were found at lower concentrations at the truck/petroleum facility. However, EPA is
concerned that its wastewater characterization data for truck/petroleum facilities does not capture
all pollutant loadings attributable to these facilities (see discussion in Section 6.5) and that
apparent differences in wastewaters for these facilities are incorrect.
5-8
-------
Section 5.0 - Industry Subcategorization
In addition, EPA found it difficult to clearly define "chemical" versus "petroleum"
cargos and was concerned that the rule incorporating separate subcategories would be difficult to
implement. EPA instead decided to develop combined "chemical and petroleum" subcategories in
order to provide unambiguous, straightforward definitions which provide clear direction for
implementation.
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, which typically includes
tank hydrotesting.
5-9
-------
Section 5.0 - Industry Subcategorization
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
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 off site 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 and
types of pollutants in TEC process wastewater. Section 6.0 provides additional information
concerning these two wastewater characteristics.
5-10
-------
Section 5.0 - Industry Subcategorization
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.
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
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.
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Section 5.0 - Industry Subcategorization
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.
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 Subcategorization approach. A
detailed discussion of the pollutant loadings associated with small facilities can be found in the
"Final Cost-Effectiveness Analysis of 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. However, EPA is promulgating an exclusion for facilities
that discharge less than 100,000 gallons per year of TEC process wastewater to provide relief and
flexibility for facilities that perform a relatively small number of TEC operations and for permit
authorities.
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;
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Section 5.0 - Industry Subcategorization
• 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;
• 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 ar
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
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.
water
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Section 5.0 - Industry 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
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 Environmental 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
environmental impacts are not an appropriate basis for Subcategorization. Section 11.0 provides
further information concerning non-water quality environmental impacts of the TECI.
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Section 5.0 - Industry Subcategorization
5.2 Selection of Subcategorization Approach
Based on its evaluation of the 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.
The tank type classifications for this rule include: (1) tank trucks and intermodal
tank containers; (2) rail tank cars; (3) tank barges and ocean/sea tankers; (4) closed-top hopper
trucks; (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 drums or
intermediate bulk containers (IBCs) are not covered by this guideline.
The cargo type classifications used as a basis for Subcategorization include: (1)
food grade; (2) dry bulk; and (3) chemical and petroleum. A description of the cargo type
classifications is provided below.
Food Grade - "Food grade" cargos include edible and non-edible food products.
Specific examples of food grade products include, but are not limited to, the
following cargos: alcoholic beverages, animal by-products, animal fats, animal
oils, caramel, caramel coloring, chocolate, corn syrup and other corn 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 pool water.
Dry Bulk - The dry bulk classification includes cargos containing dry bulk
products such as grain, soybeans, soy meal, soda ash, lime, fertilizer, plastic
pellets, flour, sugar, and similar commodities or cargos.
Chemical - Chemical cargos include, but are not limited to, the following cargos:
latex; rubber; plastic; plasticizers; resins; soaps; detergents; surfactants; agricultural
chemicals and pesticides; hazardous waste; organic chemicals including: alcohols,
aldehydes, formaldehydes, phenols, peroxides, organic salts, amines, amides, other
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Section 5.0 - Industry Subcategorization
nitrogen compounds, other aromatic compounds, aliphatic organic chemicals,
glycols, glycerines, and organic polymers; refractory organic compounds including:
ketones, nitriles, organo-metallic compounds containing chromium, cadmium,
mercury, copper, zinc; and inorganic chemicals including: aluminum sulfate,
ammonia, ammonium nitrate, ammonium sulfate, and bleach. Cargos which are
not considered to be food grade, petroleum, or dry bulk goods are considered to
be chemical cargos.
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. For purposes of this rule, 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; olefm, paraffin, and other waxes; tall oil; tar; toluene;
xylene; and waste oil.
Facilities that clean petroleum and/or chemical cargos are further subcategorized
by tank type as follows:
• Truck/Chemical & Petroleum;
• Rail/Chemical & Petroleum; and
• Barge/Chemical & Petroleum.
Definitions of these subcategories are provided at the end of this section.
Facilities that clean food grade cargos are combined into a single Food
Subcategory (definition provided at the end of this section). EPA determined that further
Subcategorization of these facilities by tank type was not warranted for several reasons. First, the
pollutants of concern (i.e., conventional pollutants as discussed in Section 6.5 ) and achievable
effluent quality are identical for all three facility types. Second, large differences in wastewater
volumes generated are not significant because EPA has promulgated concentration-based rather
than mass-based effluent limitations. Note that EPA is regulating Food Subcategory wastewater
that is directly discharged but is not regulating wastewater that is indirectly discharged.
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Section 5.0 - Industry Subcategorization
Facilities that clean closed-top hoppers (used to transport dry bulk cargos) are
further subcategorized by transportation mode as follows:
• Truck/Hopper;
• Rail/Hopper; and
• Barge/Hopper.
Definitions of these subcategories are provided at the end of this section. Note that EPA is not
regulating wastewater discharges from cleaning closed-top hoppers.
In summary, EPA has divided the TECI into the following 7 subcategories.
Definitions of these subcategories are provided below:
Truck/Chemical & Petroleum
This subcategory applies to TEC facilities that clean tank trucks and intermodal
tank containers which have been used to transport chemical or petroleum cargos.
Rail/Chemical & Petroleum
This subcategory applies to TEC facilities that clean rail tank cars which have been
used to transport chemical or petroleum cargos.
Barge/Chemical & Petroleum
This subcategory applies to TEC facilities that clean tank barges or ocean/sea
tankers which have been used to transport chemical or petroleum cargos.
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Section 5.0 - Industry Subcategorization
Food
This subcategory applies to TEC facilities that clean tank trucks, intermodal tank
containers, rail tank cars, tank barges, or ocean/sea tankers which have been used to transport
food grade cargos.
Truck/Hopper
This subcategory applies to TEC facilities that clean closed-top hopper trucks.
Rail/Hopper
This subcategory applies to TEC facilities that clean closed-top hopper rail cars.
Barge/Hopper
This subcategory applies to TEC facilities that clean closed-top hopper barges.
5.3 References1
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).
'For those references included in the administrative record supporting the TECI rulemaking, the document control
number (DCN) is included in parentheses at the end of the reference.
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Section 5.0 - Industry Subcategorization
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).
U.S. Environmental Protection Agency. Final Cost-Effective Analysis of Effluent
Limitations Guidelines and Standards for the Transportation Equipment Cleaning
Category. EPA 821-R-00-014, June 2000.
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Section 6.0 - Water Use and Wastewater Characterization
6.0 WATER USE, WASTEWATER CHARACTERIZATION, AND
POLLUTANTS OF INTEREST
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 are typically
found 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;
Section 6.5: Wastewater characterization data collected during EPA's
sampling program; and
Section 6.6: The pollutants of interest for the TECI.
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. Section 6.5 presents EPA wastewater
characterization data collected from 20 sampling episodes, and Section 6.6 lists the pollutants of
interest, by subcategory, for the TECI.
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Section 6.0 - Water Use and Wastewater Characterization
Some data summaries included in this section are presented by tank type and cargo
type cleaned. The combination of tank type and cargo type cleaned is referred to as the "facility
type." To simplify data analyses by facility type, EPA assigned facilities that clean multiple cargo
types to a single, predominant cargo group. Therefore, for these facilities, facility characteristics
for all facility operations are attributed to the single predominant cargo group.
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
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Section 6.0 - Water Use and Wastewater Characterization
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.
Prerinse wastewater is typically segregated from, 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 petroleum and coal products 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 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 both
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. Facilities that clean tank trucks last containing
food cargos account for 70% of this volume, due to the large number of tanks cleaned, relatively
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Section 6.0 - Water Use and Wastewater Characterization
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. Truck/chemical facilities,
having the next largest volume, account for 17% of all wastewater generated by the TECI, while
13% of the total volume of wastewater generated is divided among the remaining nine facility
types.
Approximately 1.3 billion gallons of wastewater from interior cleaning operations
is generated annually, as shown in Table 6-1. Truck/chemical facilities account for 56% of the
total TEC wastewater volume, while truck/food facilities account for 19% of the total TEC
wastewater volume. These percentages differ significantly from those based on wastewater
generation volume. These differences indicate that truck/chemical facilities generate the majority
of their wastewater from cleaning the interiors of tanks, while truck/food facilities generate the
majority of their 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
tankcar, tank barge, truck hopper, rail hopper, barge hopper, intermediate bulk container (IBC),
and intermodal tank container (ITC) 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, ITC, and IBC. 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.
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Section 6.0 - Water Use and Wastewater Characterization
6.2 Sources of Wastewater
EPA has identified the following operations as primary sources of wastewater
within the TECI:
• 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.
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Section 6.0 - Water Use and Wastewater Characterization
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, wastewater
generated off site may comprise 50% or more of the total wastewater volume generated.
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 cargo group. 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 facility types (data for some facilities is not shown to
protect data confidentiality). For the remaining three facility types (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 facility type. 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 facility type. Truck/chemical and truck/food facilities generate the largest
volumes of interior wastewater and exterior wastewater because the largest number of tanks are
cleaned by facilities in these facility types.
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 facility types is significantly less than that
generated by truck/chemical and truck/food facilities. 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.
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Section 6.0 - Water Use and Wastewater Characterization
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 facility type. Approximately 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 (69%) discharge
directly to U.S. surface waters because these facilities are usually located on major waterways. In
addition, subsequent to 1994, the basis year of the detailed questionnaire, EPA learned of 4
barge/chemical and petroleum facilities that changed discharge status from direct to indirect.
Where possible, EPA's analyses reflect this change. EPA has identified direct discharging
facilities in addition to those shown in Table 6-5 (see Section 9.1.2); however, EPA has not
identified any direct discharging facilities of the following five facility types: 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. Truck/food facilities account 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 facilities. Truck/chemical facilities, having the next largest volume, account for 39%
of all wastewater generated by the TECI, while 20% of the total volume of wastewater generated
is divided among the remaining nine facility groups.
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,
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Section 6.0 - Water Use and Wastewater Characterization
land disposal, or evaporation. An estimated 44 TEC facilities achieve zero discharge of TEC
wastewater by recycling or reusing 100% of TEC wastewater.
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 7.2.
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 highest
percentage of facilities that reuse wastewater in TEC operations are the truck/petroleum facilities.
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Section 6.0 - Water Use and Wastewater Characterization
For these facilities, 52 zero dischargers out of the total 104 truck/petroleum facilities reuse TEC
wastewater as source water for TEC operations.
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 truck/petroleum or rail/petroleum facilities can typically be reused for
cleaning after treatment by simple oil/water separation. Tank interior cleaning wastewater
generated by facilities cleaning chemical cargos generally requires more extensive treatment prior
to reuse as source water in TEC operations. Accordingly, few facilities that clean chemical
cargos reuse treated TEC wastewater as source water for TEC operations. Finally, sanitation
requirements at many food grade facilities preclude the 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.
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Section 6.0 - Water Use and Wastewater Characterization
6.5 Wastewater Characterization
EPA conducted a study of 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 6-8, 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),
pH, fecal coliform, and any additional pollutants defined by the administrator as conventional.
The administrator designated oil and grease (referred to as hexane extractable material or HEM)
as an additional conventional pollutant on July 30, 1979 (44 FR 44501). 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.
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
this sampling program, EPA routinely analyzed wastewater samples for 4 conventional, 125
priority, and 348 nonconventional pollutant parameters, for a total of 477 pollutants analyzed.
The nonconventional pollutants include organics, metals, pesticides, herbicides, dioxins, furans,
and classical wet chemistry parameters (classical pollutants) that do not appear on the list of
conventional or priority 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
6-10
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Section 6.0 - Water Use and Wastewater Characterization
wastewater. Tables 6-9 through 6-16 present available wastewater characterization data by tank
and cargo type cleaned. Data are available for the following:
• Truck/chemical facilities (Table 6-9);
• Rail/chemical facilities (Table 6-10);
• Barge/chemical & petroleum facilities (Table 6-11);
• Truck/food facilities (Table 6-12);
Rail/food facilities (Table 6-13);
• Barge/food facilities (Table 6-14);
• Truck/petroleum facilities (Table 6-15); and
• Barge/hopper facilities (Table 6-16).
Raw wastewater characterization data for truck/hopper, rail/hopper, and
rail/petroleum facilities were not collected during EPA's sampling program. EPA believes that
characterization data from barge/hopper facilities represent truck/hopper and rail/hopper facilities
since these facilities clean similar cargos; however, the volume of TEC wastewater generated
during tank cleaning differs significantly among these facilities. EPA believes that characterization
data from truck/petroleum facilities represent rail/petroleum facilities since these facilities also
clean similar cargos.
However, in its analysis of the industry, EPA sampled one truck/petroleum facility.
This facility treated only final rinse wastewater on site. Initial rinses and other TEC wastewaters
were contract hauled for off-site treatment and were consequently not included in the sampling
performed by EPA. Therefore, EPA did not use the data collected from this facility in further
analyses because the data are not considered to be representative of the Truck/Chemical &
Petroleum and Rail/Chemical & Petroleum Subcategories.
Tables 6-9 through 6-16 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
6-11
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Section 6.0 - Water Use and Wastewater Characterization
involved first calculating a mean concentration for each facility characterized and then calculating
a subcategory mean concentration using applicable mean facility concentrations. 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 is the number of times each
pollutant or parameter was analyzed and detected in raw wastewater samples.
The summaries shown in Table 6-17 are derived from Tables 6-9 through 6-16.
As expected, facilities cleaning chemical cargos have the highest number of priority pollutants
detected. In addition, the range of concentrations for the classical pollutants is highest for
barge/chemical & petroleum and truck/chemical facilities.
6.6 Pollutants of Interest
As discussed in Section 5.2, EPA subcategorized the TECI into 7 subcategories:
Truck/Chemical & Petroleum Subcategory;
Rail/Chemical & Petroleum Subcategory;
Barge/Chemical & Petroleum Subcategory;
Food Subcategory;
Truck/Hopper Subcategory;
Rail/Hopper Subcategory; and
Barge/Hopper Subcategory.
Using the raw wastewater characterization data presented in Tables 6-9 through 6-
16, EPA determined those pollutants commonly present in TECI wastewater for each subcategory
and identified these pollutants as "pollutants of interest." EPA considered a separate list of
pollutants of interest for each subcategory. EPA considered the following two general criteria to
identify pollutants of interest:
1. The frequency of detection in subcategory wastewater characterization
samples; and
6-12
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Section 6.0 - Water Use and Wastewater Characterization
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 is described in Sections 6.6.1 through 6.6.3.
If wastewater characterization samples were collected at two or more facilities
within a subcategory, then pollutants detected at least two times in wastewater characterization
samples were considered 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 show
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 for all pollutants. 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. Table 6-18 shows pollutants of interest by
subcategory.
6-13
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Section 6.0 - Water Use and Wastewater Characterization
6.6.1 Truck/Chemical & Petroleum, Rail/Chemical & Petroleum, and
Barge/Chemical & Petroleum Subcategories
Wastewater characterization samples were analyzed for all 477 pollutants for these
subcategories. As discussed in Section 5.2, facilities that clean petroleum and/or chemical cargos
are sub categorized by tank type (e.g., Truck/Chemical & Petroleum). However, for the purpose
of determining pollutants of interest for the Truck/Chemical & Petroleum Subcategory, EPA
excluded wastewater characterization data from the truck/petroleum facilities for the reasons
discussed in Section 6.5. Therefore, raw wastewater characterization data from only
truck/chemical facilities are used to identify pollutants of interest in the Truck/Chemical &
Petroleum Subcategory.
The same selection criteria were applied separately to the analytical data available
for the Truck/Chemical & Petroleum, Rail/Chemical & Petroleum, and Barge/Chemical &
Petroleum Subcategories to identify pollutants of interest. These include:
The pollutant was detected in at least two TEC wastewater
characterization samples.
The average raw wastewater concentration was at least five times the
method detection limit from at least one facility sampled for treatment
performance.
EPA conducted a rigorous analytical data review of all detects in Sampling
Episode 4676 and 4677 (Truck/Chemical & Petroleum Subcategory). Based on this review, EPA
determined that the presence of disulfoton and EPN are questionable in Truck/Chemical &
Petroleum Subcategory raw wastewater. These pesticides are not further considered in EPA's
analyses for the Truck/Chemical & Petroleum Subcategory.
6-14
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Section 6.0 - Water Use and Wastewater Characterization
6.6.2 Food Subcategory
Wastewater characterization samples were analyzed for all 477 pollutants.
Available characterization data for the Food Subcategory include five days of sampling at a
barge/food facility, one day of sampling at a truck/food facility, and one day of sampling at a
rail/food facility.
EPA used wastewater treatment system performance data collected at one
barge/food facility to represent the Food Subcategory. Samples collected at this one facility were
analyzed for 190 pollutants including all 176 semivolatile 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 Subcategory. These include:
The pollutant was detected in at least one TEC wastewater characterization
sample at any Food facility.
The average raw wastewater concentration was at least five times the
method detection limit at the facility sampled for treatment performance.
6.6.3 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). Except for 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
6-15
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Section 6.0 - Water Use and Wastewater Characterization
cleaning processes used by facilities in these sub categories. M-xylene and o- + p-xylene were not
analyzed because the laboratory inadvertently analyzed for m- + p-xylene and o-xylene instead,
both of 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.
The average raw wastewater concentration was at least five times the
method detection limit at the facility sampled for treatment performance.
6-16
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Section 6.0 - Water Use and Wastewater Characterization
Table 6-1
Estimates of Total Annual Volume of Wastewater Generated
by Facility Type - Discharging Facilities Only
Facility Type
Truck/Chemical
Rail/Chemical
Barge/Chemical & Petroleum
Truck/Petroleum
Rail/Petroleum
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.
6-17
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Section 6.0 - Water Use and Wastewater Characterization
Table 6-2
Average Volume of Interior Cleaning Wastewater Generated per Tank Cleaning by Cargo Group and
Tank Type - Discharging Facilities Only
Cargo Group
Food Grade Products
Petroleum and Coal Products
Latex, Rubber, and Resins
Soaps and Detergents
Biodegradable Organic Chemicals
Refractory Organic Chemicals
Inorganic Chemicals
Agricultural Chemicals and Fertilizers
Chemical Products
Hazardous Waste
Nonhazardous Waste
Dry Bulk Commodities or Cargos
Average Volume of Interior Cleaning Wastewater Generated (gallons/tank)
Truck
Tank
360
410
610
440
330
400
410
330
640
170
280
580
Rail
Tank
1,200
990
1,600
620
1,200
1,200
1,300
1,700
1,700
NC
530
(a)
Tank
Barge
19,000
13,000
(a)
NC
9,100
11,000
12,000
3,600
3,700
NC
(a)
NC
Truck
Hopper
520
(a)
(a)
(a)
(a)
NC
(a)
(a)
NC
NC
NC
470
Rail
Hopper
1,800
(a)
(a)
(a)
(a)
NC
(a)
(a)
(a)
NC
NC
1,900
Barge
Hopper
17,000
(a)
NC
NC
NC
NC
NC
850
NC
NC
NC
(a)
Intermediate
Bulk
Container
NC
87
50
(a)
(a)
NC
(a)
NC
(a)
NC
NC
NC
Intermodal
Tank
Container
430
430
230
550
(a)
NC
NC
NC
810
NC
NC
NC
oo
(a) Not disclosed to prevent compromising confidential business information.
NC - Not characterized by the Detailed Questionnaire sample population.
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-3
Average Volume of Wastewater Generated per Facility per Day by Wastewater Stream Type and Facility
Type - Discharging Facilities Only
Facility Type
Truck/Chemical
Rail/Chemical
Barge/Chemical & Petroleum
Truck/Petroleum
Rail/Petroleum
Truck/Food
Rail/Food
Barge/Food
Truck/Hopper
Rail/Hopper
Barge/Hopper
TEC Interior
Cleaning
(gallons/day)
8,400
8,700
20,000
420
(a)
4,600
(a)
(a)
1,400
(a)
34,000
TEC Exterior
Washing
(gallons/day)
1,200
870
(a)
37
NC
640
(a)
NC
500
NC
NC
Boiler Blowdown
(gallons/day)
15
250
(a)
NC
NC
(a)
NC
NC
NC
NC
NC
Hydrotesting
Wastewater
(gallons/day)
270
8,900
NC
1,800
NC
NC
NC
NC
NC
(a)
NC
Safety Equipment
Rinsate
(gallons/day)
7.8
4.8
(a)
NC
NC
NC
NC
NC
NC
(a)
NC
TEC-Contaminated
Stormwater
(gallons/day)
18
240
(a)
(a)
NC
(a)
NC
NC
NC
NC
(a)
(a) Not disclosed to prevent compromising confidential business information.
NC - Not characterized by the Detailed Questionnaire sample population.
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-4
Total Volume of Wastewater Generated per Day by Wastewater Stream Type and Facility Type -
Discharging Facilities Only
Facility Type
Truck/Chemical
Rail/Chemical
Barge/Chemical & Petroleum
Truck/Petroleum
Rail/Petroleum
Truck/Food
Rail/Food
Barge/Food
Truck/Hopper
Rail/Hopper
Barge/Hopper
TEC Interior
Cleaning
(gallons/day)
2,400,000
330,000
300,000
15,000
(a)
800,000
(a)
(a)
46,000
(a)
430,000
TEC Exterior
Washing
(gallons/day)
340,000
33,000
(a)
1,300
NC
110,000
(a)
NC
17,000
NC
NC
Boiler Slowdown
(gallons/day)
4,400
9,400
(a)
NC
NC
(a)
NC
NC
NC
NC
NC
Hydrotesting
Wastewater
(gallons/day)
77,000
340,000
NC
62,000
NC
NC
NC
NC
NC
(a)
NC
Safety Equipment
Rinsate
(gallons/day)
2,200
180
(a)
NC
NC
NC
NC
NC
NC
(a)
NC
TEC-Contaminated
Stormwater
(gallons/day)
5,300
9100
(a)
(a)
NC
(a)
NC
NC
NC
NC
(a)
to
o
(a) Not disclosed to prevent compromising confidential business information.
NC - Not characterized by the Detailed Questionnaire sample population.
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Section 6.0 - Water Use and Wastewater Characterization
Table 6-5
Discharge Status by Facility Type
Facility Type
Truck/Chemical
Rail/Chemical
Barge/Chemical & Petroleum (a)
Truck/Petroleum
Rail/Petroleum
Truck/Food
Rail/Food
Barge/Food
Truck/Hopper
Rail/Hopper
Barge/Hopper
TOTAL (b)
Indirect Discharge
Number of
Facilities
288
38
5
34
3
173
86
2
34
5
3
673
Percentage of
Industry Total
(%)
43
6
<1
5
<1
26
13
<1
5
<1
<1
100
Direct Discharge
Number of
Facilities
0
0
10
0
0
0
0
0
0
0
9
19
Percentage of
Industry Total
(%)
0
0
53
0
0
0
0
0
0
0
47
100
(a) Subsequent to 1994, the basis year of the detailed questionnaire, EPA learned of 4 barge/chemical and petroleum
facilities that changed discharge status from direct to indirect.
(b) Differences occur due to rounding.
6-21
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Section 6.0 - Water Use and Wastewater Characterization
Table 6-6
Estimates of Total Annual Volume of Wastewater Discharged
By Facility Type and Discharge Status
Facility Type
Truck/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
Indirect
Indirect
Direct
Indirect
Indirect
Indirect
Indirect
Indirect
Indirect
Indirect
Indirect
Direct
Indirect
TOTAL (a)
Total Interior Cleaning
Wastewater Discharged
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
Total Commingled
Wastewater Discharged
Amount
(gal/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
Percentage
of Industry
Total (%)
39
6
2
1
<1
«1
41
6
«1
<1
«1
5
<1
100
(a) Differences occur due to rounding.
6-22
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Section 6.0 - Water Use and Wastewater Characterization
Table 6-7
Number of Facilities That Reuse All or Part of TEC Wastewater as Source
Water for TEC Operations
Facility Type
Truck/Chemical
Rail/Chemical
Barge/Chemical & Petroleum
Truck/Petroleum
Rail/Petroleum
Truck/Food
Rail/Food
Barge/Food
Truck/Hopper
Rail/Hopper
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
Total Number of
Discharging and Zero
Discharge Facilities
556
67
31
104
4
318
86
2
39
5
14
6-23
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Section 6.0 - Water Use and Wastewater Characterization
Table 6-8
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 Fluoranthene
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 Fluorene
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).
6-24
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Section 6.0 - Water Use and Wastewater Characterization
Table 6-9
Summary of Raw Wastewater Characterization Data for Truck/Chemical Facilities
Priority
Pollutant
Code
Analyte
Units
Mean
Concentration
(a)
Minimum
Concentration
(b)
Maximum
Concentration
(c)
Number
of Times
Detected
Number of
Times
Analyzed
Volatile Organics
P011
P013
P029
P010
P032
P004
P048
P007
P023
P038
P044
P085
P006
1,1,1 -Trichloroethane
1 , 1 -Dichloroethane
1 , 1 -Dichloroethene
1 ,2-Dibromoethane
1 ,2-Dichloroethane
1 ,2-Dichloropropane
1,4-Dioxane
Acetone
Benzene
Bromodichloromethane
Chlorobenzene
Chloroform
Diethyl Ether
Ethylbenzene
m-Xylene
Methyl Ethyl Ketone
Methyl Isobutyl Ketone
Methylene Chloride
o- + p-Xylene
Tetrachloroethene
Tetrachloromethane
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
710
12
14
17
400
11
19
24,000
35
10
16
65
110
440
1,700
5,200
1,600
12,000
860
1,100
14
10
9.9
10
10
10
9.9
9.9
57
10
9.9
10
10
50
10
10
50
50
29
10
10
9.9
2,700
36
40
86
1,700
19
150
67,000
270
12
29
420
900
3,900
7,100
28,000
8,200
63,000
3,600
6,500
49
9
2
2
2
4
1
1
10
o
J
I
4
6
1
6
6
6
7
10
6
8
1
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
to
-------
Table 6-9 (Continued)
Section 6.0 - Water Use and Wastewater Characterization
Priority
Pollutant
Code
P086
P047
P087
Analyte
Toluene
Tribromomethane
Trichloroethene
Units
Mg/L
Mg/L
Mg/L
Mean
Concentration
(a)
1,600
10
26
Minimum
Concentration
(b)
10
9.9
10
Maximum
Concentration
(c)
7,000
14
81
Number
of Times
Detected
7
1
4
Number of
Times
Analyzed
10
10
10
Semivolatile Organics
P025
P021
P031
P024
P057
P058
P001
P066
P069
P063
1 ,2-Dichlorobenzene
1 -Methylphenanthrene
2,3 -Dichloroaniline
2,4,6-Trichlorophenol
2,4-Dichlorophenol
2,6-Dichlorophenol
2-Chlorophenol
2-Isopropylnaphthalene
2-Methylnaphthalene
2-Nitrophenol
3 ,6-Dimethy Iphenanthrene
4-Nitrophenol
Acenaphthene
alpha-Terpineol
Aniline
Benzoic Acid
Benzyl Alcohol
Biphenyl
Bis (2-ethylhexyl) Phthalate
Di-n-Octyl Phthalate
Di-n-Propylnitrosamine
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
190
140
3,600
180
57
56
67
240
150
110
160
270
130
340
130
24,000
410
140
900
350
270
10
10
10
10
10
10
10
10
10
20
10
50
10
10
10
1,500
28
10
12
10
20
1,000
1,000
34,000
1,500
160
160
160
1,000
1,000
320
1,000
800
1,000
2,000
1,000
110,000
1,900
1,000
4,200
2,200
2,000
2
2
2
2
2
1
o
J
o
J
7
1
2
1
1
4
1
10
9
2
9
5
1
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
to
-------
Table 6-9 (Continued)
Section 6.0 - Water Use and Wastewater Characterization
Priority
Pollutant
Code
P080
P054
P062
P055
P081
P065
Analyte
Dimethyl Sulfone
Diphenylamine
Fluorene
Hexanoic Acid
Isophorone
n-Decane
n-Docosane
n-Dodecane
n-Eicosane
n-Hexacosane
n-Hexadecane
n-Nitrosodiphenylamine
n-Octacosane
n-Octadecane
n-Tetracosane
n-Tetradecane
n-Triacontane
Naphthalene
o-Cresol
p-Cresol
p-Cymene
Phenanthrene
Phenol
Styrene
Tripropyleneglycol Methyl Ether
Units
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mean
Concentration
(a)
150
140
140
77
140
350
330
1,100
410
810
640
270
940
450
640
560
1,200
330
160
130
150
180
2,000
3,300
1,300
Minimum
Concentration
(b)
10
10
10
10
10
10
10
10
10
10
10
20
10
10
10
10
10
10
10
10
10
10
100
10
99
Maximum
Concentration
(c)
1,000
1,000
1,000
200
1,000
1,100
2,600
3,200
1,900
7,600
1,800
2,000
9,000
1,700
5,400
2,100
11,000
1,000
1,000
670
1,000
1,000
6,400
27,000
9,900
Number
of Times
Detected
2
1
1
2
1
2
8
4
8
8
8
1
6
8
9
7
o
J
7
2
4
2
2
9
7
1
Number of
Times
Analyzed
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
to
-------
Table 6-9 (Continued)
Section 6.0 - Water Use and Wastewater Characterization
Priority
Pollutant
Code
Analyte
Units
Mean
Concentration
(a)
Minimum
Concentration
(b)
Maximum
Concentration
(c)
Number
of Times
Detected
Number of
Times
Analyzed
Phenoxy-Acid Herbicides
2,4,5-T
2,4,5-TP
2,4-D
2,4-DB (Butoxon)
Dalapon
Dichloroprop
Dinoseb
MCPA
MCPP
Picloram
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
0.85
0.59
2.5
6.6
0.81
2.8
2.3
680
130
1.2
0.20
0.20
1.0
2.0
0.20
1.0
0.50
50
50
0.50
4.4
3.2
10
31
5.7
10
18
3,500
740
5.0
4
3
2
2
2
2
o
J
7
1
2
10
10
10
10
10
10
10
10
10
10
Organo-Phosphorous Pesticides
Azinphos Methyl
Demeton B
Diazinon
Dichlofenthion
Dimethoate
Ethion
Leptophos
Merphos
Methyl Chlorpyrifos
Methyl Parathion
Tetrachlorvinphos
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
4.4
5.4
3.9
2.8
2.3
2.4
5.6
2.5
3.3
2.3
2.7
1.0
2.0
2.0
2.0
1.0
2.0
2.0
2.0
2.0
2.0
2.0
22
35
16
9.0
6.8
4.3
34
5.4
14
4.0
7.1
o
J
1
2
o
J
1
1
o
J
1
1
1
o
J
10
10
10
10
10
10
10
10
10
10
10
Organo-Halide Pesticides
P094
4,4'-DDD
Mg/L
0.59
0.20
2.0
1
10
to
oo
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-9 (Continued)
Priority
Pollutant
Code
P092
P103
P090
P096
P097
P099
P104
P091
Analyte
4,4'-DDT
beta-BHC
Bromoxynil Octanoate
Chlorobenzilate
Diallate A
Diallate B
Dieldrm (d)
Endosulfan II
Endosulfan Sulfate
Endrin Aldehyde
gamma-BHC
gamma-Chlordane
Nitrofen
Pentachloronitrobenzene (PCNB)
Propachlor
Simazine
Terbuthylazine
Units
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mean
Concentration
(a)
0.29
0.35
1.5
3.5
6.9
10
0.13
2.9
0.30
3.3
0.20
0.16
0.60
7.9
2.3
28
15
Minimum
Concentration
(b)
0.10
0.10
0.50
1.0
2.0
2.0
0.040
1.0
0.10
0.10
0.050
0.050
0.20
0.050
0.10
8.0
5.0
Maximum
Concentration
(c)
1.0
1.0
5.0
10
20
62
0.40
10
1.0
15
0.50
0.50
2.0
77
11
84
50
Number
of Times
Detected
1
3
1
4
2
2
3
1
2
2
2
1
1
3
1
1
1
Number of
Times
Analyzed
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
Metals
P114
P115
P117
Aluminum
Antimony
Arsenic
Barium
Beryllium
Bismuth
Boron
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
6,100
57
15
530
0.92
110
4,700
48
3.4
4.6
73
0.30
0.10
140
30,000
240
28
1,200
1.4
650
26,000
10
6
9
10
2
1
10
10
10
10
10
10
10
10
to
VO
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-9 (Continued)
Priority
Pollutant
Code
P118
P119
P120
P122
P123
Analyte
Cadmium
Calcium
Chromium
Cobalt
Copper
Dysprosium
Europium
Gadolinium
Gallium
Germanium
Gold
Hafnium
Hexavalent Chromium
Holmium
Indium
Iron
Lanthanum
Lead
Lithium
Lutetium
Magnesium
Manganese
Mercury
Molybdenum
Neodymium
Units
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mean
Concentration
(a)
18
300,000
2,400
85
1,100
46
24
98
280
200
68
160
0.29
140
580
30,000
35
25
96
22
72,000
800
1.8
100
52
Minimum
Concentration
(b)
1.0
71,000
3.1
6.0
40
26
2.9
28
8.6
72
11
1.0
0.010
0.50
42
270
0.10
2.8
31
0.58
10,000
2.3
0.20
18
0.50
Maximum
Concentration
(c)
49
540,000
19,000
330
9,200
100
100
300
1,100
500
200
500
3.3
500
4,400
150,000
100
76
180
100
270,000
6,300
5.0
370
200
Number
of Times
Detected
9
10
9
8
10
2
3
2
2
3
3
1
3
1
4
10
1
3
7
2
10
10
8
10
1
Number of
Times
Analyzed
10
10
10
10
10
10
10
10
10
10
10
10
9
10
10
10
10
10
10
10
10
10
10
10
10
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-9 (Continued)
Priority
Pollutant
Code
P124
P125
P126
P127
Analyte
Nickel
Niobium
Osmium
Palladium
Phosphorus
Platinum
Potassium
Praseodymium
Rhenium
Rhodium
Ruthenium
Samarium
Scandium
Selenium
Silicon
Silver
Sodium
Strontium
Sulfur
Tantalum
Tellurium
Terbium
Thallium
Thorium
Thulium
Units
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mean
Concentration
(a)
360
170
91
190
42,000
570
19,000
140
160
1,200
320
150
21
11
14,000
3.5
1,000,000
2,300
360,000
200
270
140
3.7
170
110
Minimum
Concentration
(b)
9.0
32
0.10
0.50
1,300
66
6,100
1.0
19
1.0
62
0.50
0.10
1.0
2,800
2.2
140,000
140
68,000
0.50
1.0
8.3
1.0
1.0
0.50
Maximum
Concentration
(c)
2,100
500
490
500
190,000
3,700
34,000
500
500
6,700
590
500
100
23
51,000
6.4
2,800,000
5,500
780,000
500
1,000
500
24
500
500
Number
of Times
Detected
10
6
1
1
8
5
8
2
o
J
4
6
1
4
o
J
9
o
J
10
10
8
4
o
J
2
2
1
1
Number of
Times
Analyzed
10
10
10
10
8
10
8
10
10
10
10
10
10
10
10
10
10
10
8
10
10
10
10
10
10
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-9 (Continued)
Priority
Pollutant
Code
P128
Analyte
Tin
Titanium
Tungsten
Uranium
Vanadium
Ytterbium
Yttrium
Zinc
Zirconium
Units
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mean
Concentration
(a)
12,000
190
220
610
31
22
2.1
830
27
Minimum
Concentration
(b)
23
6.1
1.0
1.0
1.9
0.10
0.30
35
0.10
Maximum
Concentration
(c)
85,000
1,000
500
1,000
150
100
5.0
3,500
100
Number
of Times
Detected
7
10
3
1
7
4
1
10
1
Number of
Times
Analyzed
10
10
10
10
10
10
10
10
10
Dioxins and Furans
1,2,3, 4,6,7, 8-Heptachlorodibenzop-dioxin
1,2,3, 4,6,7, 8-Heptachlorodibenzofur an
1,2, 3,6,7, 8-Hexachlorodibenzofur an
1,2,3,7,8,9-Hexachlorodibenzo-p-dioxin
Octachlorodibenzop-dioxin
Octachlorodibenzofuran
Pg/L
Pg/L
Pg/L
Pg/L
Pg/L
Pg/L
690
220
120
97
6,100
560
50
50
50
50
200
99
2,400
1,100
500
500
21,000
1,900
7
5
3
1
10
2
10
10
10
10
10
10
Classical Pollutants
Adsorbable Organic Halides (AOX)
Amenable Cyanide
Ammonia as Nitrogen
BOD 5-day
Chemical Oxygen Demand (COD)
Chloride
Fluoride
Hexane Extractable Material
Mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
5,100
0.0033
79
2,300
6,600
900
21
1,300
1,200
S.OxlO-6
0.29
320
830
83
0.30
6.0
19,000
0.010
650
6,000
16,000
4,800
180
5,300
10
1
10
10
10
10
10
38
10
17
10
10
10
10
10
38
to
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-9 (Continued)
Priority
Pollutant
Code
P121
Analyte
Nitrate/Nitrite
SGT-HEM
Surfactants (MBAS)
Total Cyanide
Total Dissolved Solids
Total Organic Carbon (TOC)
Total Phenols
Total Phosphorus
Total Sulfide (lodometric)
Total Suspended Solids
Volatile Residue
Units
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
Mean
Concentration
(a)
2.6
150
16
0.020
5,000
1,500
2.6
22
0.92
1,600
2,900
Minimum
Concentration
(b)
0.26
5.0
0.85
0.0050
1,700
160
0.0059
0.37
0.83
38
1,900
Maximum
Concentration
(c)
9.5
450
33
0.077
11,000
3,200
6.8
53
1.0
4,800
6,400
Number
of Times
Detected
10
29
10
13
10
10
9
10
1
10
4
Number of
Times
Analyzed
10
38
10
29
10
10
10
10
3
10
4
(a) For samples in which individual pollutants were not detected, the sample detection limit was used in calculating the mean concentration.
(b) Minimum value of detected amounts or detection limits (for samples in which individual pollutants were not detected) from all analyses.
(c) Maximum value of detected amounts or detection limits (for samples in which individual pollutants were not detected) from all analyses.
(d) EPA conducted a rigorous analytical data review of all detects in Sampling Episodes 4676 and 4677. Based on this review, EPA determined that the two of the
detected dieldrin samples are questionable.
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-10
Summary of Raw Wastewater Characterization Data for Rail/Chemical Facilities
Priority
Pollutant
Code
Analyte
Units
Mean
Concentration
(a)
Minimum
Concentration
(b)
Maximum
Concentration
(c)
Number of
Times
Detected
Number of
Times
Analyzed
Volatile Organics
P004
P038
P086
Acetone
Benzene
Carbon Bisulfide
Ethylbenzene
m-Xylene
Methyl Ethyl Ketone
Methyl Isobutyl Ketone
o- + p-Xylene
Toluene
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
390
27
10
70
120
130
51
87
97
50
10
10
10
10
50
50
10
19
930
44
11
180
390
310
58
240
170
4
1
1
4
4
4
1
4
5
5
5
5
5
5
5
5
5
5
Semivolatile Organics
POOS
P031
P034
P035
P036
1 ,2,4-Trichlorobenzene
1 -Methylfluorene
1 -Methylphenanthrene
2,3-Benzofluorene
2,4-Diaminotoluene
2,4-Dichlorophenol
2,4-Dimethylphenol
2,4-Dinitrotoluene
2,6-Dinitrotoluene
2-Isopropylnaphthalene
2-Methylnaphthalene
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
80
37
61
23
1,100
310
25
3,400
940
87
59
10
10
10
10
99
10
10
10
10
10
10
130
230
350
110
6,200
590
100
27,000
7,300
140
400
1
1
2
1
3
1
3
1
1
1
1
5
5
5
5
5
5
5
5
5
5
5
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-10 (Continued)
Priority
Pollutant
Code
P001
P078
P072
P018
P066
P076
P039
P080
Analyte
5-Nitro-o-toluidine
7, 1 2-Dimethy lbenz(a)anthracene
Acenaphthene
Anthracene
Benzo (a) anthracene
Benzoic Acid
Biphenyl
Bis (2-chloroethyl) Ether
Bis (2-ethylhexyl) Phthalate
Carbazole
Chrysene
Dimethyl Sulfone
Diphenyl Ether
Fluoranthene
Fluorene
Hexanoic Acid
n-Decane
n-Docosane
n-Dodecane
n-Eicosane
n-Hexacosane
n-Hexadecane
n-Octacosane
n-Octadecane
n-Tetracosane
Units
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mean
Concentration
(a)
430
24
41
82
22
1,700
51
25
22
69
27
50
28
69
46
2,300
31
170
260
740
130
1,500
55
790
180
Minimum
Concentration
(b)
10
10
10
10
10
50
10
10
10
20
10
10
10
10
10
10
10
10
10
17
10
10
10
15
10
Maximum
Concentration
(c)
3,300
120
260
500
100
6,500
330
100
100
370
150
170
100
480
300
9,300
100
1,200
1,400
4,800
420
8,300
330
5,700
780
Number of
Times
Detected
1
1
1
o
J
I
3
1
1
1
3
1
2
1
2
1
4
2
3
4
5
3
4
2
5
4
Number of
Times
Analyzed
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-10 (Continued)
Priority
Pollutant
Code
P055
P081
P065
P084
Analyte
n-Tetradecane
n-Triacontane
Naphthalene
p-Cresol
Perylene
Phenacetin
Phenanthrene
Phenol
Pyrene
Styrene
Units
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mean
Concentration
(a)
940
75
47
35
35
21
150
370
56
32
Minimum
Concentration
(b)
10
10
10
10
10
10
10
10
10
10
Maximum
Concentration
(c)
6,400
270
290
110
210
100
1,100
1,900
380
100
Number of
Times
Detected
4
2
4
2
1
1
3
4
2
2
Number of
Times
Analyzed
5
5
5
5
5
5
5
5
5
5
Phenoxy-Acid Herbicides
2,4,5-T
2,4,5-TP
2,4-D
2,4-DB (Butoxon)
Dalapon
Dicamba
Dichloroprop
Dinoseb
MCPP
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
13
13
73
130
17
630
70
32
42,000
0.20
0.20
1.0
2.2
0.20
0.54
8.4
0.50
50
20
20
180
200
53
1,300
100
52
82,000
2
2
1
3
1
4
3
3
2
5
5
5
5
5
5
5
5
5
Organo-Phosphorous Pesticides
Chlorpyrifos
Dioxathion
Disulfoton
Tetrachlorvinphos
Mg/L
Mg/L
Mg/L
Mg/L
2.0
5.8
2.0
2.1
2.0
5.0
2.0
2.0
2.0
8.0
2.0
3.0
1
1
1
1
5
4
5
5
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-10 (Continued)
Priority
Pollutant
Code
Analyte
Tokuthion
Trichlorfon
Trichloronate
Trimethylphosphate
Units
Mg/L
Mg/L
Mg/L
Mg/L
Mean
Concentration
(a)
2.5
7.2
2.1
2.8
Minimum
Concentration
(b)
2.0
5.0
2.0
2.0
Maximum
Concentration
(c)
4.0
18
2.4
5.0
Number of
Times
Detected
1
1
1
2
Number of
Times
Analyzed
4
4
5
4
Organo-Halide Pesticides
P094
P092
P102
P091
P103
P105
P090
P095
4,4'-DDD
4,4'-DDT
Acephate
Alachlor
alpha-BHC
alpha-Chlordane
Atrazine
Benefluralin
beta-BHC
Butachlor
Captafol
Carbophenothion
Chlorobenzilate
Chloroneb
Dacthal (DCPA)
delta-BHC
Diallate
Dicofol
Dieldrin
Endosulfan I
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
0.21
0.25
730
0.25
0.19
0.099
84
2.2
26
0.48
1.9
1.0
1.1
22
0.40
0.46
77
1.4
1.7
0.11
0.050
0.10
20
0.20
0.050
0.080
1.0
0.20
0.10
0.30
1.2
0.50
0.25
0.30
0.050
0.050
2.2
1.0
0.040
0.10
0.44
1.3
5,500
0.60
0.27
0.11
630
12
200
0.53
2.0
1.2
2.7
170
1.8
3.0
580
3.4
12
0.14
1
1
2
1
2
1
1
2
3
1
1
1
1
1
2
4
3
1
3
1
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
4
5
5
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-10 (Continued)
Priority
Pollutant
Code
P097
P099
P104
P091
Analyte
Endosulfan Sulfate
Endrin Aldehyde
Endrin Ketone
Ethalfluralin
gamma-BHC
gamma-Chlordane
Isodrin
Isopropalin
Metribuzin
Mirex
Nitrofen
Pendimethalin
Pentachloronitrobenzene (PCNB)
Perth ane
Propachlor
Propazine
Simazine
Strobane
Terbacil
Terbuthylazine
Triadimefon
Trifluralin
Units
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mean
Concentration
(a)
0.26
0.28
0.13
4.2
0.28
0.085
0.16
0.56
0.15
0.69
0.92
0.71
0.10
41
13
18
24,000
46
19
2,100
1.0
1.6
Minimum
Concentration
(b)
0.070
0.10
0.080
0.050
0.050
0.050
0.10
0.20
0.050
0.20
0.20
0.30
0.050
10
0.10
1.0
0.80
5.0
2.0
5.0
0.50
0.10
Maximum
Concentration
(c)
1.3
1.6
0.33
33
1.9
0.26
0.52
3.1
0.20
4.0
6.0
2.4
0.46
250
100
39
190,000
170
140
13,000
1.6
12
Number of
Times
Detected
2
1
1
1
1
2
1
1
1
1
1
1
2
1
3
3
1
1
2
3
1
1
Number of
Times
Analyzed
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
4
5
5
5
5
Metals
P114
Aluminum
Antimony
Mg/L
Mg/L
12,000
16
2,200
4.7
64,000
61
5
3
5
5
oo
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-10 (Continued)
Priority
Pollutant
Code
P115
P117
P119
P120
P122
P123
P124
Analyte
Arsenic
Barium
Beryllium
Bismuth
Boron
Calcium
Cerium
Chromium
Cobalt
Copper
Europium
Gold
Iron
Lanthanum
Lead
Lithium
Magnesium
Manganese
Mercury
Molybdenum
Nickel
Niobium
Phosphorus
Platinum
Potassium
Units
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mean
Concentration
(a)
39
590
0.64
84
2,100
31,000
390
50
28
110
52
120
16,000
98
32
76
14,000
750
0.24
33
81
290
8,200
300
970,000
Minimum
Concentration
(b)
12
100
0.20
67
460
18,000
280
28
18
81
3.8
46
6,700
96
12
39
6,200
540
0.20
10
36
71
2,100
110
4,500
Maximum
Concentration
(c)
120
1,800
1.3
100
5,500
56,000
500
150
60
180
100
200
26,000
100
59
150
28,000
1,400
0.38
72
120
500
33,000
500
2,800,000
Number of
Times
Detected
5
5
1
1
5
5
1
5
5
5
1
1
5
1
2
2
5
5
2
4
5
1
5
1
5
Number of
Times
Analyzed
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
vo
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-10 (Continued)
Priority
Pollutant
Code
P125
P127
P128
Analyte
Selenium
Silicon
Sodium
Strontium
Sulfur
Tantalum
Thallium
Tin
Titanium
Tungsten
Uranium
Vanadium
Ytterbium
Yttrium
Zinc
Zirconium
Units
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mean
Concentration
(a)
11
13,000
1,700,000
340
440,000
310
7.9
28
67
310
880
48
51
2.2
550
60
Minimum
Concentration
(b)
1.6
5,500
290,000
210
53,000
110
1.3
25
8.3
130
760
10
2.7
0.50
77
19
Maximum
Concentration
(c)
20
26,000
6,100,000
600
1,200,000
500
28
34
400
500
1,000
80
100
6.4
1,200
100
Number of
Times
Detected
1
5
5
5
5
1
1
1
5
1
1
3
1
1
5
1
Number of
Times
Analyzed
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
Dioxins and Furans
1,2,3, 4,6,7, 8-Heptachlorodibenzo-p-dioxin
1,2,3, 4,6,7, 8-Heptachlorodibenzofur an
1,2,3, 6,7, 8-Hexachlorodibenzo-p-dioxin
2,3 ,7,8-Tetrachlorodibenzofuran
Octachlorodibenzo-p-dioxin
Octachlorodibenzofuran
Pg/L
Pg/L
Pg/L
Pg/L
Pg/L
Pg/L
2,600
330
190
21
8,200
1,500
50
50
50
10
100
100
20,000
1,800
720
100
61,000
7,500
1
1
1
1
3
3
5
5
5
5
5
5
Classical Pollutants
Adsorbable Organic Halides (AOX)
Mg/L
1,400
150
1,900
5
5
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-10 (Continued)
Priority
Pollutant
Code
P121
Analyte
Ammonia as Nitrogen
BOD 5-day
Chemical Oxygen Demand (COD)
Chloride
Fluoride
Hexane Extractable Material
Nitrate/Nitrite
SGT-HEM
Surfactants (MBAS)
Total Cyanide
Total Dissolved Solids
Total Organic Carbon (TOC)
Total Phenols
Total Phosphorus
Total Suspended Solids
Volatile Residue
Units
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
Mean
Concentration
(a)
25
1,700
4,000
1,200
1.8
810
5.8
210
2.5
0.019
7,900
970
0.43
9.5
530
480
Minimum
Concentration
(b)
8.0
260
810
280
0.90
56
0.050
18
1.7
0.0050
980
150
0.021
1.4
230
480
Maximum
Concentration
(c)
48
4,200
20,000
3,900
2.2
5,200
40
750
5.0
0.10
26,000
3,300
1.5
45
1,400
480
Number of
Times
Detected
5
5
5
5
5
14
4
14
5
1
5
5
5
5
5
1
Number of
Times
Analyzed
5
5
5
5
5
14
5
14
5
6
5
5
5
5
5
1
(a) For samples in which individual pollutants were not detected, the sample detection limit was used in calculating the mean concentration.
(b) Minimum value of detected amounts or detection limits (for samples in which individual pollutants were not detected) from all analyses.
(c) Maximum value of detected amounts or detection limits (for samples in which individual pollutants were not detected) from all analyses.
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-11
Summary of Raw Wastewater Characterization Data for Barge/Chemical & Petroleum Facilities
Priority
Pollutant
Code
Analyte
Units
Mean
Concentration
(a)
Minimum
Concentration
(b)
Maximum
Concentration
(c)
Number of
Times
Detected
Number of
Times
Analyzed
Volatile Organics
P013
P010
POOS
P004
P023
P038
P044
P085
P086
P087
P088
1 , 1 -Dichloroethane
1 ,2-Dichloroethane
Acetone
Acrylonitrile
Benzene
Carbon Bisulfide
Chloroform
Ethylbenzene
Isobutyl Alcohol
m-Xylene
Methyl Ethyl Ketone
Methyl Isobutyl Ketone
Methyl Methacrylate
Methylene Chloride
o- + p-Xylene
Tetrachloroethene
Toluene
Trichloroethene
Vinyl Chloride
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
11
450
87,000
41,000
11,000
12
55
4,500
180
3,200
110,000
48,000
47
38
2,500
120
13,000
13
13
10
10
780
50
45
10
10
89
10
10
50
50
10
10
150
10
410
10
10
20
11,000
500,000
120,000
110,000
31
1,100
16,000
2,100
25,000
600,000
1,100,000
910
570
21,000
1,400
51,000
55
77
1
1
10
3
10
1
2
10
1
9
8
8
1
5
10
1
10
4
1
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
Semivolatile Organics
P025
1 ,2-Dichlorobenzene
Mg/L
9,400
10
56,000
1
10
to
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-11 (Continued)
Priority
Pollutant
Code
P034
P001
P077
P078
P066
P069
P039
P080
P009
P012
Analyte
1 -Methylfluorene
1 -Methylphenanthrene
1 -Phenylnaphthalene
2,3-Benzofluorene
2,4-Dimethylphenol
2-Methylnaphthalene
2-Phenylnaphthalene
3 ,6-Dimethy Iphenanthrene
Acenaphthene
Acenaphthylene
Aniline
Anthracene
Benzoic Acid
Benzyl Alcohol
Biphenyl
Bis (2-ethylhexyl) Phthalate
Di-n-Octyl Phthalate
Fluoranthene
Fluorene
Hexachlorobenzene
Hexachloroethane
Hexanoic Acid
n-Decane
n-Docosane
n-Dodecane
Units
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mean
Concentration
(a)
360
1,400
63
100
98
7,800
80
200
660
610
59
390
800
66
2,500
700
790
62
970
67
65
130
75,000
2,600
34,000
Minimum
Concentration
(b)
10
17
10
10
10
130
10
10
10
10
10
10
50
10
29
12
10
10
10
10
10
10
10
34
450
Maximum
Concentration
(c)
1,300
13,000
200
580
470
81,000
590
870
9,500
13,000
200
7,400
1,900
200
26,000
7,500
12,000
200
13,000
390
200
570
1,200,000
49,000
360,000
Number of
Times
Detected
4
9
1
o
J
I
10
1
5
6
3
1
2
4
1
9
8
4
1
6
1
1
1
9
10
10
Number of
Times
Analyzed
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-11 (Continued)
Priority
Pollutant
Code
P055
P081
P065
P084
Analyte
n-Eicosane
n-Hexacosane
n-Hexadecane
n-Octacosane
n-Octadecane
n-Tetracosane
n-Tetradecane
n-Triacontane
Naphthalene
o-Cresol
p-Cresol
p-Cymene
Pentachloroethane
Pentamethy Ibenzene
Phenanthrene
Phenol
Pyrene
Styrene
Thianaphthene
Units
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mean
Concentration
(a)
7,700
140
34,000
82
14,000
1,400
84,000
340
74,000
110
120
6,400
120
1,600
1,500
170
520
96,000
60
Minimum
Concentration
(b)
93
10
110
10
95
33
630
10
530
10
10
11
20
10
10
10
10
570
10
Maximum
Concentration
(c)
110,000
550
370,000
290
170,000
15,000
1,100,000
1,500
1,100,000
620
740
150,000
400
6,700
16,000
990
4,200
630,000
200
Number of
Times
Detected
10
7
10
5
10
9
10
2
10
1
1
5
1
4
7
3
7
10
1
Number of
Times
Analyzed
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
Phenoxy-Acid Herbicides
2,4-D
Dalapon
MCPA
Mg/L
Mg/L
Mg/L
150
33
9,700
1.9
0.20
1,200
1,000
200
50,000
1
2
2
6
6
6
Organo-Phosphorous Pesticides
Malathion
Mg/L
3.6
2.2
5.1
2
2
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-11 (Continued)
Priority
Pollutant
Code
Analyte
Parathion (Ethyl)
Sulfotep
Trichlorfon
Units
Mg/L
Mg/L
Mg/L
Mean
Concentration
(a)
6.6
2.2
7.1
Minimum
Concentration
(b)
2.2
2.0
5.0
Maximum
Concentration
(c)
11
2.3
9.2
Number of
Times
Detected
2
1
1
Number of
Times
Analyzed
2
2
2
Organo-Halide Pesticides
P094
P089
P102
P090
P091
4,4'-DDD
Aldrin
alpha-BHC
Chlorobenzilate
Dieldrin
Ethalfluralin
gamma-Chlordane
Metribuzin
Propachlor
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
1.2
1.4
0.30
7.8
0.37
2.7
0.28
1.6
2.1
0.45
0.20
0.10
5.6
0.040
0.10
0.050
1.1
1.0
2.0
2.6
0.50
10
0.70
5.3
0.50
2.0
3.3
1
1
1
1
1
1
1
1
1
2
2
2
2
2
2
2
2
2
Metals
P114
P115
P117
P118
P119
Aluminum
Antimony
Arsenic
Barium
Beryllium
Bismuth
Boron
Cadmium
Calcium
Cerium
Chromium
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
25,000
9.8
11
260
1.4
120
910
43
140,000
400
330
100
1.6
1.1
66
0.20
46
550
1.0
60,000
170
2.6
360,000
30
94
1,400
15
900
1,500
390
320,000
1,700
2,600
6
4
3
6
2
1
6
5
6
2
4
6
6
6
6
6
6
6
6
6
6
6
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-11 (Continued)
Priority
Pollutant
Code
P120
P122
P123
P124
Analyte
Cobalt
Copper
Europium
Germanium
Gold
Hafnium
Hexavalent Chromium
Iodine
Indium
Iron
Lanthanum
Lead
Lithium
Lutetium
Magnesium
Manganese
Mercury
Molybdenum
Neodymium
Nickel
Niobium
Osmium
Phosphorus
Platinum
Potassium
Units
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mean
Concentration
(a)
37
880
18
280
100
240
0.19
39,000
390
610,000
170
370
170
23
70,000
4,100
5.4
330
59
1,900
210
800
15,000
380
31,000
Minimum
Concentration
(b)
2.1
76
2.9
78
34
100
0.070
2,000
42
3,000
24
12
31
3.2
19,000
140
0.10
20
19
58
32
36
690
66
22,000
Maximum
Concentration
(c)
280
6,000
200
1,000
400
1,000
0.27
210,000
2,400
6,600,000
2,000
1,800
390
200
240,000
38,000
81
860
400
14,000
1,600
12,000
56,000
1,000
65,000
Number of
Times
Detected
2
6
1
2
2
1
3
1
4
6
1
4
4
2
6
6
3
5
1
6
3
2
5
3
6
Number of
Times
Analyzed
6
6
6
6
6
6
3
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
Oi
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-11 (Continued)
Priority
Pollutant
Code
P125
P126
P128
Analyte
Praseodymium
Rhenium
Ruthenium
Scandium
Selenium
Silicon
Silver
Sodium
Strontium
Sulfur
Tantalum
Thorium
Tin
Titanium
Tungsten
Uranium
Vanadium
Ytterbium
Yttrium
Zinc
Zirconium
Units
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mean
Concentration
(a)
160
97
3,400
14
4.0
21,000
5.7
1,700,000
4,700
460,000
300
440
56
38
300
1,200
43
22
5.5
19,000
35
Minimum
Concentration
(b)
38
19
110
0.80
1.0
28
1.8
990,000
980
96,000
50
120
22
1.6
120
610
1.7
1.1
0.40
630
11
Maximum
Concentration
(c)
1,000
1,000
40,000
200
20
130,000
34
5,800,000
12,000
2,100,000
1,700
3,400
220
300
1,200
6,100
410
200
56
79,000
260
Number of
Times
Detected
3
1
4
1
1
4
3
6
6
6
4
2
1
5
2
1
3
5
2
6
2
Number of
Times
Analyzed
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
Dioxins and Furans
1,2,3, 4,6,7, 8-Heptachlorodibenzofur an
Octachlorodibenzo-p-dioxin
Octachlorodibenzofuran
Pg/L
Pg/L
Pg/L
320
9,400
960
50
100
100
4,100
100,000
8,200
1
4
3
10
10
10
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-11 (Continued)
Priority
Pollutant
Code
Analyte
Units
Mean
Concentration
(a)
Minimum
Concentration
(b)
Maximum
Concentration
(c)
Number of
Times
Detected
Number of
Times
Analyzed
Classical Pollutants
P121
Adsorbable Organic Halides (AOX)
Amenable Cyanide
Ammonia as Nitrogen
BOD 5-day
Chemical Oxygen Demand (COD)
Chloride
Fluoride
Hexane Extractable Material
Nitrate/nitrite
SGT-HEM
Surfactants (MBAS)
Total Cyanide
Total Dissolved Solids
Total Organic Carbon (TOC)
Total Phenols
Total Phosphorus
Total Sulfide (lodometric)
Total Suspended Solids
Volatile Residue
Mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
940
0.092
54
5,700
44,000
1,100
1.4
14,000
22
6,300
9.0
0.11
3,100
10,000
0.48
6.4
4.6
2,200
350
82
0.0020
0.60
120
130
40
0.74
37
0.16
21
0.12
0.0040
1.0
30
0.018
0.080
4.6
55
1.0
3,500
0.18
150
26,000
200,000
2,800
3.9
220,000
55
98,000
13
0.21
17,000
53,000
2.5
31
4.6
15,000
710
10
1
10
10
10
10
9
27
10
25
6
5
9
10
10
10
1
10
1
10
8
10
10
10
10
9
27
10
25
6
8
10
10
10
10
1
10
2
oo
(a) For samples in which individual pollutants were not detected, the sample detection limit was used in calculating the mean concentration.
(b) Minimum value of detected amounts or detection limits (for samples in which individual pollutants were not detected) from all analyses.
(c) Maximum value of detected amounts or detection limits (for samples in which individual pollutants were not detected) from all analyses.
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-12
Summary of Raw Wastewater Characterization Data for Truck/Food Facilities
Priority
Pollutant
Code
Analyte
Units
Mean
Concentration
(a)
Minimum
Concentration
(b)
Maximum
Concentration
(c)
Number
of Times
Detected
Number of
Times
Analyzed
Volatile Organics
P023
Acetone
Chloroform
Methyl Ethyl Ketone
Trichlorofluoromethane
Mg/L
Mg/L
Mg/L
Mg/L
97
93
55
1,500
50
10
50
10
140
180
60
2,900
1
1
1
1
2
2
2
2
Semivolatile Organics
Benzoic Acid
Dimethyl Sulfone
Hexanoic Acid
n-Hexacosane
n-Octacosane
n-Tetracosane
n-Triacontane
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
210
21
380
85
74
53
88
180
10
110
10
10
10
10
230
33
660
160
140
96
170
2
1
2
1
1
1
1
2
2
2
2
2
2
2
Phenoxy-Acid Herbicides
MCPA
Mg/L
170
50
300
1
2
Organo-Halide Pesticides
Diallate A
Mg/L
2.9
2.4
3.5
1
2
Metals
P114
Aluminum
Antimony
Barium
Bismuth
Boron
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
190
21
12
1.5
300
28
18
6.3
0.10
170
360
25
18
2.8
420
1
1
2
1
2
2
2
2
2
2
VO
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-12 (Continued)
Priority
Pollutant
Code
P120
P123
P125
Analyte
Calcium
Copper
Erbium
Europium
Gadolinium
Gallium
Germanium
Hafnium
Hexavalent Chromium
Indium
Indium
Iron
Lanthanum
Lithium
Magnesium
Manganese
Mercury
Neodymium
Niobium
Palladium
Platinum
Praseodymium
Rhenium
Ruthenium
Samarium
Selenium
Units
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mean
Concentration
(a)
2,900
170
4.5
4.8
1.9
2.0
46
7.6
0.020
20
24
670
1.4
4.7
2,900
26
1.8
6.7
150
1.3
67
10
1.1
6.6
16
18
Minimum
Concentration
(b)
1,300
34
0.10
0.10
0.50
0.50
0.50
1.0
0.010
1.0
1.0
7.0
0.10
0.10
370
2.0
0.71
0.50
150
0.50
35
1.0
1.0
1.0
7.2
4.6
Maximum
Concentration
(c)
4,400
300
8.9
9.5
3.2
3.5
91
14
0.030
38
46
1,300
2.7
9.2
5,400
50
2.8
13
150
2.0
98
20
1.2
12
25
31
Number
of Times
Detected
2
2
1
1
1
1
1
1
1
1
1
2
1
1
2
2
2
1
2
1
2
1
1
1
2
1
Number of
Times
Analyzed
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-12 (Continued)
Priority
Pollutant
Code
P128
Analyte
Silicon
Sodium
Strontium
Tantalum
Tellurium
Terbium
Thorium
Titanium
Tungsten
Uranium
Zinc
Zirconium
Units
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mean
Concentration
(a)
9,500
280,000
19
17
6.3
18
3.4
11
7.9
270
66
3.8
Minimum
Concentration
(b)
2,900
220,000
4.5
10
1.0
16
1.0
10
1.0
1.0
18
0.10
Maximum
Concentration
(c)
16,000
340,000
33
25
12
21
5.8
12
15
540
120
7.4
Number
of Times
Detected
2
2
2
2
1
2
1
2
1
1
2
1
Number of
Times
Analyzed
2
2
2
2
2
2
2
2
2
2
2
2
Dioxins and Furans
Octachlorodibenzo-p-dioxin
Pg/L
380
100
650
1
2
Classical Pollutants
Adsorbable Organic Halides (AOX)
Amenable Cyanide
Ammonia as Nitrogen
BOD 5-day
Chemical Oxygen Demand (COD)
Chloride
Fluoride
SGT-HEM
Nitrate/Nitrite
Hexane Extractable Material
Surfactants (MBAS)
Mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
2,000
0.0068
0.035
2,700
3,000
76
0.57
9.0
1.9
130
10
190
0.0050
0.010
160
380
68
0.28
5.0
0.050
5.2
0.49
3,900
0.016
0.060
5,200
5,600
83
0.85
26
3.7
270
20
2
1
1
2
2
2
2
2
1
7
2
2
7
2
2
2
2
2
7
2
7
2
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-12 (Continued)
Priority
Pollutant
Code
P121
Analyte
Total Cyanide
Total Dissolved Solids
Total Organic Carbon (TOC)
Total Phenols
Total Phosphorus
Total Sulfide (lodometric)
Total Suspended Solids
Volatile Residue
Units
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
Mean
Concentration
(a)
0.0068
3,400
1,300
0.038
67
3.5
420
4,300
Minimum
Concentration
(b)
0.0050
810
86
0.0050
11
1.0
28
310
Maximum
Concentration
(c)
0.016
6,000
2,500
0.070
120
6.0
800
8,300
Number
of Times
Detected
1
2
2
1
2
1
2
2
Number of
Times
Analyzed
7
2
2
2
2
2
2
2
to
(a) For samples in which individual pollutants were not detected, the sample detection limit was used in calculating the mean concentration.
(b) Minimum value of detected amounts or detection limits (for samples in which individual pollutants were not detected) from all analyses.
(c) Maximum value of detected amounts or detection limits (for samples in which individual pollutants were not detected) from all analyses.
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-13
Summary of Raw Wastewater Characterization Data for Rail/Food Facilities
Priority
Pollutant
Code
Analyte
Units
Mean
Concentration
(a)
Minimum
Concentration
(b)
Maximum
Concentration
(c)
Number of
Times
Detected
Number of
Times
Analyzed
Semivolatile Organics
P065
Benzoic Acid
Phenol
Mg/L
Mg/L
78
58
78
58
78
58
1
1
1
1
Organo-Phosphorous Pesticides
Diazinon
Mg/L
31
31
31
1
1
Metals
P118
P124
Aluminum
Barium
Boron
Cadmium
Calcium
Europium
Gadolinium
Holmium
Iridium
Iron
Lutetium
Magnesium
Manganese
Molybdenum
Neodymium
Nickel
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
150
18
39
2.4
31,000
10
54
140
81
270
4.5
10,000
4.8
34
61
9.8
150
18
39
2.4
31,000
10
54
140
81
270
4.5
10,000
4.8
34
61
9.8
150
18
39
2.4
31,000
10
54
140
81
270
4.5
10,000
4.8
34
61
9.8
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-13 (Continued)
Priority
Pollutant
Code
Analyte
Niobium
Phosphorus
Rhenium
Silicon
Sodium
Strontium
Sulfur
Tantalum
Thulium
Tungsten
Units
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mean
Concentration
(a)
81
1,800
26
680
6,400
110
6,700
50
23
320
Minimum
Concentration
(b)
81
1,800
26
680
6,400
110
6,700
50
23
320
Maximum
Concentration
(c)
81
1,800
26
680
6,400
110
6,700
50
23
320
Number of
Times
Detected
1
1
1
1
1
1
1
1
1
1
Number of
Times
Analyzed
1
1
1
1
1
1
1
1
1
1
Dioxins and Furans
1,2,3, 4,6,7, 8-Heptachlorodibenzofur an
Octachlorodibenzofuran
Pg/L
Pg/L
300
490
300
490
300
490
1
1
1
1
Classical Pollutants
P121
Adsorbable Organic Halides (AOX)
Ammonia as Nitrogen
Chemical Oxygen Demand (COD)
Chloride
Fluoride
Nitrate/nitrite
Surfactants (MBAS)
Total Cyanide
Total Dissolved Solids
Total Organic Carbon (TOC)
Total Phenols
Mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
15
0.040
34,000
10
0.39
0.16
0.011
0.0043
25,000
13,000
0.018
15
0.040
34,000
10
0.39
0.16
0.011
0.0026
25,000
13,000
0.018
15
0.040
34,000
10
0.39
0.16
0.011
0.0061
25,000
13,000
0.018
1
1
1
1
1
1
1
2
1
1
1
1
1
1
1
1
1
1
4
1
1
1
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-13 (Continued)
Priority
Pollutant
Code
Analyte
Total Phosphorus
Total Sulfide (lodometric)
Total Suspended Solids
Units
mg/L
mg/L
mg/L
Mean
Concentration
(a)
1.8
11
27
Minimum
Concentration
(b)
1.8
11
27
Maximum
Concentration
(c)
1.8
11
27
Number of
Times
Detected
1
1
1
Number of
Times
Analyzed
1
1
1
(a) For samples in which individual pollutants were not detected, the sample detection limit was used in calculating the mean concentration.
(b) Minimum value of detected amounts or detection limits (for samples in which individual pollutants were not detected) from all analyses.
(c) Maximum value of detected amounts or detection limits (for samples in which individual pollutants were not detected) from all analyses.
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-14
Summary of Raw Wastewater Characterization Data for Barge/Food Facilities
Priority
Pollutant
Code
Analyte
Units
Mean
Concentration
(a)
Minimum
Concentration
(b)
Maximum
Concentration
(c)
Number
of Times
Detected
Number of
Times
Analyzed
Volatile Organics
Acetone
Methyl Ethyl Ketone
Mg/L
Mg/L
180
130
180
130
180
130
1
1
1
1
Semivolatile Organics
P065
1,3,5-Trithiane
Benzoic Acid
Hexanoic Acid
n-Tetradecane
o-Cresol
Phenol
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
280
2,200
64,000
55
79
200
50
50
2,000
10
10
10
500
4,100
150,000
100
200
540
1
3
5
1
1
3
5
5
5
5
5
5
Phenoxy-Acid Herbicides
2,4-D
Mg/L
7.5
7.5
7.5
1
1
Organo-Halide Pesticides
Diallate A
Mg/L
21
21
21
1
1
Metals
P118
P119
P120
Aluminum
Barium
Cadmium
Calcium
Chromium
Cobalt
Copper
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
1,700
88
4.6
21,000
47
19
100
1,700
88
4.6
21,000
47
19
100
1,700
88
4.6
21,000
47
19
100
1
1
1
1
1
1
1
1
1
1
1
1
1
1
Oi
i
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-14 (Continued)
Priority
Pollutant
Code
P122
P123
P124
Analyte
Europium
Gadolinium
Gallium
Germanium
Hafnium
Hexavalent Chromium
Iron
Lead
Lithium
Lutetium
Magnesium
Manganese
Mercury
Molybdenum
Neodymium
Nickel
Niobium
Osmium
Palladium
Platinum
Rhenium
Ruthenium
Samarium
Scandium
Silicon
Units
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mean
Concentration
(a)
12
36
170
290
29
0.31
42,000
150
8.5
1.8
17,000
410
0.41
18
5.4
210
150
12
9.4
520
18
120
29
0.26
7,400
Minimum
Concentration
(b)
12
36
170
290
29
0.31
42,000
150
8.5
1.8
17,000
410
0.41
18
5.4
210
150
12
9.4
520
18
120
29
0.26
7,400
Maximum
Concentration
(c)
12
36
170
290
29
0.31
42,000
150
8.5
1.8
17,000
410
0.41
18
5.4
210
150
12
9.4
520
18
120
29
0.26
7,400
Number
of Times
Detected
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
Number of
Times
Analyzed
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-14 (Continued)
Priority
Pollutant
Code
P126
P128
Analyte
Silver
Sodium
Strontium
Terbium
Thulium
Uranium
Vanadium
Zinc
Units
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mean
Concentration
(a)
20
550,000
110
5.6
17
940
12
330
Minimum
Concentration
(b)
20
550,000
110
5.6
17
940
12
330
Maximum
Concentration
(c)
20
550,000
110
5.6
17
940
12
330
Number
of Times
Detected
1
1
1
1
1
1
1
1
Number of
Times
Analyzed
1
1
1
1
1
1
1
1
Dioxins and Furans
2,3 ,7,8-Tetrachlorodibenzofuran
Octachlorodibenzo-p-dioxin
Pg/L
Pg/L
11
110
11
110
11
110
1
1
1
1
Classical Pollutants
Ammonia as Nitrogen
BOD 5-day
Chemical Oxygen Demand (COD)
Chloride
Fluoride
Hexane Extractable Material
Nitrate/Nitrite
SGT-HEM
Surfactants (MBAS)
Total Dissolved Solids
Total Organic Carbon (TOC)
Total Phenols
Total Phosphorus
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
3.0
4,600
7,300
150
0.34
720
0.093
52
2.8
3,000
2,500
0.50
92
0.77
890
540
88
0.28
75
0.050
5.0
2.8
1,800
1,600
0.26
51
9.3
6,800
12,000
180
0.46
1,100
0.30
140
2.8
3,700
3,300
1.2
180
5
5
5
5
5
5
3
3
1
5
5
5
5
5
5
5
5
5
5
5
5
1
5
5
5
5
oo
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-14 (Continued)
Priority
Pollutant
Code
Analyte
Total Sulfide (lodometric)
Total Suspended Solids
Volatile Residue
Units
mg/L
mg/L
mg/L
Mean
Concentration
(a)
16
1,300
2,500
Minimum
Concentration
(b)
16
260
2,500
Maximum
Concentration
(c)
16
2,000
2,500
Number
of Times
Detected
1
5
1
Number of
Times
Analyzed
1
5
1
(a) For samples in which individual pollutants were not detected, the sample detection limit was used in calculating the mean concentration.
(b) Minimum value of detected amounts or detection limits (for samples in which individual pollutants were not detected) from all analyses.
(c) Maximum value of detected amounts or detection limits (for samples in which individual pollutants were not detected) from all analyses.
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-15
Summary of Raw Wastewater Characterization Data for Truck/Petroleum Facilities
Priority
Pollutant
Code
Analyte
Units
Mean
Concentration
(a)
Minimum
Concentration
(b)
Maximum
Concentration
(c)
Number of
Times
Detected
Number of
Times
Analyzed
Volatile Organics
P086
Acetone
m-Xylene
Toluene
Mg/L
Mg/L
Mg/L
180
10
20
99
10
10
310
12
43
5
1
2
5
5
5
Semivolatile Organics
P066
P065
Biphenyl
Bis (2-ethylhexyl) Phthalate
Diphenyl Ether
n-Decane
n-Docosane
n-Dodecane
n-Eicosane
n-Hexacosane
n-Hexadecane
n-Octacosane
n-Octadecane
n-Tetracosane
n-Tetradecane
n-Triacontane
Phenol
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
410
110
11
10
26
20
53
26
36
64
45
40
40
93
18
10
68
10
10
10
10
22
10
10
43
21
10
12
10
10
2,000
150
16
11
47
34
87
37
79
110
94
100
69
140
35
1
5
1
1
4
3
5
3
4
5
5
3
5
4
2
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
Metals
Aluminum
Mg/L
500
180
850
5
5
Oi
O
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-15 (Continued)
Priority
Pollutant
Code
P114
P115
P118
P119
P120
P123
Analyte
Antimony
Arsenic
Barium
Bismuth
Boron
Cadmium
Calcium
Cerium
Chromium
Copper
Erbium
Europium
Holmium
Iron
Lanthanum
Lutetium
Magnesium
Manganese
Mercury
Molybdenum
Neodymium
Phosphorus
Potassium
Praseodymium
Samarium
Units
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mean
Concentration
(a)
4.2
4.9
73
81
430
2.0
30,000
210
9.1
5.8
25
6.3
60
1,400
27
3.3
2,900
150
0.29
110
21
2,500
5,200
44
96
Minimum
Concentration
(b)
3.8
3.3
42
46
320
1.6
12,000
170
4.4
2.8
24
2.9
39
860
24
3.2
1,300
65
0.20
68
19
1,500
4,100
38
87
Maximum
Concentration
(c)
5.9
11
96
120
540
3.0
58,000
320
28
18
28
16
78
2,200
38
3.8
4,900
280
0.63
200
26
5,900
7,200
52
130
Number of
Times
Detected
1
1
5
4
5
2
5
2
2
1
1
4
5
5
1
1
5
5
1
5
2
5
5
3
1
Number of
Times
Analyzed
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-15 (Continued)
Priority
Pollutant
Code
P128
Analyte
Silicon
Sodium
Strontium
Sulfur
Tantalum
Titanium
Tungsten
Uranium
Vanadium
Ytterbium
Zinc
Zirconium
Units
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mean
Concentration
(a)
8,800
500,000
100
6,700
72
6.4
190
640
3.8
1.1
350
11
Minimum
Concentration
(b)
4,100
380,000
59
3,300
57
1.2
130
610
3.3
0.90
190
11
Maximum
Concentration
(c)
13,000
730,000
140
17,000
98
18
440
750
6.0
1.8
490
14
Number of
Times
Detected
5
5
5
5
5
3
2
1
1
1
5
1
Number of
Times
Analyzed
5
5
5
5
5
5
5
5
5
5
5
5
Classical Pollutants
Ammonia as Nitrogen
BOD 5-day
Chemical Oxygen Demand (COD)
Chloride
Fluoride
Hexane Extractable Material
SGT-HEM
Total Dissolved Solids
Total Organic Carbon (TOC)
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
0.30
67
660
530
1.5
260
130
1,300
110
0.16
48
580
400
1.1
22
5.0
950
28
0.48
110
740
800
2.0
1,200
410
1,900
210
5
5
5
5
5
60
59
5
5
5
5
5
5
5
60
60
5
5
Oi
to
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-15 (Continued)
Priority
Pollutant
Code
Analyte
Total Phosphorus
Total Suspended Solids
Units
mg/L
rng/L
Mean
Concentration
(a)
2.9
230
Minimum
Concentration
(b)
2.0
130
Maximum
Concentration
(c)
6.5
360
Number of
Times
Detected
5
5
Number of
Times
Analyzed
5
5
(a) For samples in which individual pollutants were not detected, the sample detection limit was used in calculating the mean concentration.
(b) Minimum value of detected amounts or detection limits (for samples in which individual pollutants were not detected) from all analyses.
(c) Maximum value of detected amounts or detection limits (for samples in which individual pollutants were not detected) from all analyses.
Oi
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-16
Summary of Raw Wastewater Characterization Data for Barge/Hopper Facilities
Priority
Pollutant
Code
Analyte
Units
Mean
Concentration
(a)
Minimum
Concentration
(b)
Maximum
Concentration
(c)
Number of
Times
Detected
Number of
Times
Analyzed
Semivolatile Organics
P066
Bis (2-ethylhexyl) Phthalate
Mg/L
43
43
43
1
1
Metals
P115
P117
P118
P119
P120
Aluminum
Arsenic
Barium
Beryllium
Bismuth
Boron
Cadmium
Calcium
Cerium
Chromium
Copper
Erbium
Europium
Gadolinium
Gold
Hexavalent Chromium
Holmium
Iridium
Iron
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
mg/L
Mg/L
Mg/L
Mg/L
15,000
51
150
4.9
46
160
11
280,000
380
130
62
27
2.9
67
54
0.046
45
240
87,000
15,000
51
150
4.9
46
160
11
280,000
380
130
62
27
2.9
67
54
0.046
45
240
87,000
15,000
51
150
4.9
46
160
11
280,000
380
130
62
27
2.9
67
54
0.046
45
240
87,000
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
Oi
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-16 (Continued)
Priority
Pollutant
Code
P124
P126
Analyte
Lanthanum
Lithium
Lutetium
Magnesium
Manganese
Molybdenum
Nickel
Osmium
Phosphorus
Platinum
Potassium
Praseodymium
Ruthenium
Samarium
Silicon
Silver
Sodium
Strontium
Sulfur
Tantalum
Titanium
Tungsten
Vanadium
Ytterbium
Yttrium
Units
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mean
Concentration
(a)
50
50
3.6
31,000
2,900
54
110
440
610,000
66
31,000
79
1,300
87
2,800
6.9
150,000
380
150,000
65
450
130
180
7.2
72
Minimum
Concentration
(b)
50
50
3.6
31,000
2,900
54
110
440
610,000
66
31,000
79
1,300
87
2,800
6.9
150,000
380
150,000
65
450
130
180
7.2
72
Maximum
Concentration
(c)
50
50
3.6
31,000
2,900
54
110
440
610,000
66
31,000
79
1,300
87
2,800
6.9
150,000
380
150,000
65
450
130
180
7.2
72
Number of
Times
Detected
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
Number of
Times
Analyzed
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-16 (Continued)
Priority
Pollutant
Code
P128
Analyte
Zinc
Zirconium
Units
Mg/L
Mg/L
Mean
Concentration
(a)
250
33
Minimum
Concentration
(b)
250
33
Maximum
Concentration
(c)
250
33
Number of
Times
Detected
1
1
Number of
Times
Analyzed
1
1
Classical Pollutants
Ammonia as Nitrogen
BOD 5-day
Chemical Oxygen Demand (COD)
Chloride
Fluoride
Nitrate/Nitrite
Total Dissolved Solids
Total Organic Carbon (TOC)
Total Phosphorus
Total Suspended Solids
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
520
17
640
190
20
3.0
2,900
61
540
1,400
520
17
640
190
20
3.0
2,900
61
540
1,400
520
17
640
190
20
3.0
2,900
61
540
1,400
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
ON
ON
(a) For samples in which individual pollutants were not detected, the sample detection limit was used in calculating the mean concentration.
(b) Minimum value of detected amounts or detection limits (for samples in which individual pollutants were not detected) from all analyses.
(c) Maximum value of detected amounts or detection limits (for samples in which individual pollutants were not detected) from all analyses.
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-17
Summaries of the Raw Wastewater Characterization Data
for Each Facility Type
Facility Type
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
9
9
Number of Pollutants Detected
202
180
159
67
76
45
68
57
Facility Type
Truck/Chemical
Rail/Chemical
Barge/Chemical
& Petroleum
Truck/Petroleum
Truck/Food
Rail/Food
Barge/Food
Barge/Hopper
Range of Pollutant Concentrations (mg/L)
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
COD
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
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
SGT-HEM
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.
6-67
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-18
Pollutants Of Interest By Subcategory
Analyte
Subcategory
Truck/Chemical
& Petroleum
Rail/Chemical
«& Petroleum
Barge/Chemical
«& Petroleum
Food
Truck/Hopper,
Rail/Hopper, and
Barge/Hopper
Volatile Organics
1,1,1 -Trichloroethane
1 ,2-Dichloroethane
Acetone
Acrylonitrile
Benzene
Chloroform
Ethylbenzene
M-Xylene
Methyl Ethyl Ketone
Methyl Isobutyl Ketone
Methylene Chloride
O- + P-Xylene
Tetrachloroethene
Toluene
Tricloroethene
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
Semivolatile Organics
1-Methylfluorene
1 -Methylphenanthrene
1 ,2-Dichlorobenzene
/
/
/
/
OO
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-18 (Continued)
Analyte
2-Chlorophenol
2-Isopropylnaphthalene
2-Methylnaphthalene
2,3-Benzofluorene
2,4-Diaminotoluene
2,4,6-Trichlorophenol
3 ,6-Dimethy Iphenanthrene
Acenaphthene
Acenaphthylene
Alpha-terpineol
Anthracene
Benzoic Acid
Benzyl Alcohol
Biphenyl
Bis(2-ethylhexyl) Phthalate
Carbazole
Di-n-octyl Phthalate
Dimethyl Sulfone
Fluoranthene
Fluorene
Hexanoic Acid
N-Decane
N-Docosane
Subcategory
Truck/Chemical
& Petroleum
/
/
/
/
/
/
/
/
/
/
/
/
Rail/Chemical
& Petroleum
/
/
/
/
/
/
/
/
Barge/Chemical
& Petroleum
/
/
/
/
/
/
/
/
/
/
/
/
/
Food
/
Truck/Hopper,
Rail/Hopper, and
Barge/Hopper
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-18 (Continued)
Analyte
N-Dodecane
N-Eicosane
N-Hexacosane
N-Hexadecane
N-Octacosane
N-Octadecane
N-Tetracosane
N-Tetradecane
N-Triacontane
Napthalene
O-Cresol
P-Cresol
P-Cymene
Pentamethy Ibenzene
Phenanthrene
Phenol
Pyrene
Styrene
Subcategory
Truck/Chemical
& Petroleum
/
/
/
/
/
/
/
/
/
/
/
/
/
/
Rail/Chemical
& Petroleum
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
Barge/Chemical
«& Petroleum
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
Food
/
/
Truck/Hopper,
Rail/Hopper, and
Barge/Hopper
Phenoxy-Acid Herbicides
2,4,5-T
2,4,5-TP
2,4-D
2,4-DB (Butoxon)
/
/
/
/
/
/
/
/
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-18 (Continued)
Analyte
Dalapon
Dicamba
Dichlorprop
Dinoseb
MCPA
MCPP
Subcategory
Truck/Chemical
& Petroleum
/
/
/
Rail/Chemical
& Petroleum
/
/
/
/
Barge/Chemical
& Petroleum
/
Food
Truck/Hopper,
Rail/Hopper, and
Barge/Hopper
Organo-Phosphorous Pesticides
Azinophos Methyl
Leptophos
/
/
Organo-Halide Pesticides
Acephate
alpha-BHC
Benefluralin
beta-BHC
Dacthal (DCPA)
delta-BHC
Diallate (a)
Dieldrin
Endosulfan Sulfate
Endrin Aldehyde
gamma-BHC
gamma-Chlordane
Pentachoronitrobenzene (PCNB)
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-18 (Continued)
Analyte
Propachlor
Propazine
Terbacil
Terbuthylazine
Subcategory
Truck/Chemical
& Petroleum
Rail/Chemical
& Petroleum
/
/
/
/
Barge/Chemical
«& Petroleum
Food
Truck/Hopper,
Rail/Hopper, and
Barge/Hopper
Metals
Aluminum
Arsenic
Barium
Boron
Cadmium
Calcium
Chromium
Copper
Hexavalent Chromium
Iron
Lead
Magnesium
Manganese
Mercury
Molybdenum
Nickel
Osmium
Phosphorus
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
to
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-18 (Continued)
Analyte
Potassium
Ruthenium
Silicon
Sodium
Strontium
Sulfur
Tin
Titanium
Yttrium
Zinc
Dioxins and Furans
1. 2,3,4,6,7, 8-Heptachorodibenzo-p-dioxin
1.2,3, 4,6,7, 8-Heptachlorodibenzo-fur an
Octachlrodibenzo-p-dioxin
Octachlrodibenzofuran
Classical Pollutants
Adsorbable Organic Halides (AOX)
Ammonia as Nitrogen
BOD 5-day
Chemical Oxygen Demand (COD)
Chloride
Fluoride
Hexane Extractable Material
Truck/Chemical
& Petroleum
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
Rail/Chemical
«& Petroleum
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
Subcategory
Barge/Chemical
& Petroleum
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
Food
/
/
/
/
/
/
/
/
Truck/Hopper,
Rail/Hopper, and
Barge/Hopper
/
/
/
/
/
/
/
/
/
/
/
/
-------
Section 6.0 - Water Use and Wastewater Characterization
Table 6-18 (Continued)
Analyte
Nitrate/Nitrite
SGT-HEM
Surfactants (MBAS)
Total Dissolved Solids
Total Organic Carbon (TOC)
Total Phenols
Total Phosphorus
Total Sulfide (lodometric)
Total Suspended Solids
Subcategory
Truck/Chemical
& Petroleum
/
(b)
/
/
/
/
/
/
Rail/Chemical
& Petroleum
/
/
/
/
/
/
/
/
Barge/Chemical
& Petroleum
/
/
/
/
/
/
/
/
Food
/
/
/
/
/
/
/
/
Truck/Hopper,
Rail/Hopper, and
Barge/Hopper
/
/
/
/
/
(a) Diallate represents diallate and/or diallate A and/or diallate B.
(b) EPA does not believe the SGT-HEM treatment performance data to be representative of the subcategory. EPA considers SGT-HEM a pollutant of interest for this
subcategory based on the average raw wastewater concentration for this subcategory.
-------
Section 6.0 - Water Use and Wastewater Characterization
Key:
-Primary Path
Secondary Path
Recycle & Reuse Stream
Solution
Make-Up
i
*
Source
Water
I
Fr
L
esh
TEC Interior
Cleaning:
Chemical Solution
A
T
TEC Interior
Cleaning: Water
A
Exterior Cleaning
Water
D
Si
t
Contract Haul to
Treatment Works
i
*. wr
1
k
Treatment
T
Discharge to
Treatment Works
Discharge to U.S.
Surface Waters
Water
I j
Hydrotesting Water
Disposal by:
Evaporation
Land Application
Deep-Well Injection
Incineration
Figure 6-1. Water Use Diagram for TEC Operations
6-75
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Section 7.0 - Pollution Prevention and Wastewater Treatment Technologies
7.0 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 effluent limitations guidelines and standards for the industry (see Section 8.0).
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 7.1: Pollution prevention controls used by the TECI;
• Section 7.2: Flow reduction technologies used by the TECI;
• Section 7.3: End-of-pipe wastewater treatment technologies used by the
TECI; and
• Section 7.4: References used in this section.
7.1 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
environment associated with the release of such pollutants. Data gathered from the Detailed
7-1
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Section 7.0 - Pollution Prevention and Wastewater Treatment Technologies
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.
7.1.1 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. Most TEC facilities cannot implement the use of dedicated tanks since it is only
the shipper or carrier offering the container for cleaning that can exercise the use of dedicated
tanks. 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).
7-2
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Section 7.0 - Pollution Prevention and Wastewater Treatment Technologies
7.1.2 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;
7-3
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Section 7.0 - 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 techniques in
7-4
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Section 7.0 - Pollution Prevention and Wastewater Treatment Technologies
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 to facilitate draining. 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. Many food
7-5
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Section 7.0 - Pollution Prevention and Wastewater Treatment Technologies
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.
7.1.3 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 solution required for
each tank cleaned; instead, smaller amounts of make-up solution are periodically added to replace
7-6
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Section 7.0 - Pollution Prevention and Wastewater Treatment Technologies
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 (both interior and exterior cleaning 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, or 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.
7-7
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Section 7.0 - Pollution Prevention and Wastewater Treatment Technologies
7.2 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 show 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.
7.2.1 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.
7-8
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Section 7.0 - Pollution Prevention and Wastewater Treatment Technologies
7.2.2 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.
7.2.3 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.
7.2.4 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. Mechanical
devices may be used to vibrate hoppers to improve heel removal. Some dry cleaning processes,
particularly applicable to hopper or tank barges, include manual operations to shovel or sweep
dry-bulk cargos, or mop or squeegee liquid cargos to remove as much residual material as
possible. (Physically entering a tank may not be advisable in many circumstances. Personnel
must be trained in health and safety procedures and a confined entry space entry permit may be
required.) 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.
7-9
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Section 7.0 - Pollution Prevention and Wastewater Treatment Technologies
7.2.5 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.
7.2.6 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
7-10
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Section 7.0 - 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.
7.3
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
Gravity Settling
pH Adjustment
Equalization
Oil/Water Separation
Sludge Dewatering
Dissolved Air Flotation
Number of Facilities (% of Discharging Facilities) That Utilize
the Treatment Technology
393 (57%)
303 (44%)
289 (42%)
251 (36%)
195(28%)
175 (25%)
7-11
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Section 7.0 - Pollution Prevention and Wastewater Treatment Technologies
Treatment Technology
Coagulation/Flocculation
Filtration
Clarification
Biological Oxidation
Chemical Precipitation/Separation
Grit Removal
Chemical Oxidation
Activated Carbon Adsorption
Membrane Filtration
Number of Facilities (% of Discharging Facilities) That Utilize
the Treatment Technology
169 (24%)
166 (24%)
157(23%)
60 (9%)
43 (6%)
30 (4%)
16 (2%)
4 (<1%)
1 (<1%)
7.3.1
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.
7-12
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Section 7.0 - Pollution Prevention and Wastewater Treatment Technologies
7.3.2 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.
7.3.3 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.
7-13
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Section 7.0 - Pollution Prevention and Wastewater Treatment Technologies
7.3.4 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 7-1 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 tubes 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
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Section 7.0 - Pollution Prevention and Wastewater Treatment Technologies
tubes, they coalesce into a layer of oil that flows or is pumped from the unit. Figure 7-2 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.
7.3.5 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.
7.3.5.1 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 7.0 - 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.
7.3.5.2 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 7-3 presents a diagram of a
plate-and-frame filter press.
7.3.5.3 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 through
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Section 7.0 - Pollution Prevention and Wastewater Treatment Technologies
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 7-
4 presents a diagram of a rotary vacuum filter.
7.3.5.4 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.
7.3.6 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,
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Section 7.0 - 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 7-5 presents a diagram of a DAF unit with pressurized recycle.
7.3.7 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 floe which
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Section 7.0 - Pollution Prevention and Wastewater Treatment Technologies
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 7.3.9).
7.3.8 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 7.3.15)
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 7.3.5) 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 (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).
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Section 7.0 - Pollution Prevention and Wastewater Treatment Technologies
7.3.9 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 7.3.10). Secondary clarification may include the addition of chemicals to aid in the
coagulation and agglomeration of suspended solids following biological treatment. Polymers are
typically used as coagulant aids, but other coagulants (e.g., alum) may also be used. Figure 7-6
presents a diagram of a clarifier.
7.3.10 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.
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Section 7.0 - 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 7-7 presents a diagram of an activated sludge system.
7.3.11 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.
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Section 7.0 - 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 7-8 presents a diagram of a batch chemical precipitation unit.
7.3.12 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).
7.3.13 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
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Section 7.0 - Pollution Prevention and Wastewater Treatment Technologies
hydrogen peroxide. Other oxidants used in industry include chlorine, ozone, and potassium
permanganate.
7.3.14 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.
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Section 7.0 - 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.
7.3.15 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 in 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 7-9
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.
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Section 7.0 - Pollution Prevention and Wastewater Treatment Technologies
7.3.15.1 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.
7.3.15.2 Ultrafiltration
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.
7.3.15.3 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.
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Section 7.0 - Pollution Prevention and Wastewater Treatment Technologies
7.4 References1
1. 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).
2. Viessman, Warren, Jr. and Mark J. Hammer. Water Supply and Pollution Control.
Fifth Edition. Harper Collins College Publishers. New York, NY, 1993.
3. Reynolds, Tom and Paul Richards. Unit Operations and Processes in
Environmental Engineering. PWS Publishing. Boston, MA, 1996.
Tor those references included in the administrative record supporting the TECI rulemaking, the document control
number (DCN) is included in parentheses at the end of the reference.
7-26
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Section 7.0 - Pollution Prevention and Wastewater Treatment Technologies
Figure 7-1. API Oil/Water Separator
-------
Section 7.0 - Pollution Prevention and Wastewater Treatment Technologies
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Figure 7-2. Coalescing Oil/Water Separator
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Figure 7-3. Plate-and-Frame Filter Press
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Section 7.0 - Pollution Prevention and Wastewater Treatment Technologies
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Section 7.0 - Pollution Prevention and Wastewater Treatment Technologies
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Figure 1-5. Dissolved Air Flotation Unit with Pressurized Recycle
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Section 7.0 - Pollution Prevention and Wastewater Treatment Technologies
Figure 7-6. Clarifier
-------
Section 7.0 - Pollution Prevention and Wastewater Treatment Technologies
Figure 7-7. Activated Sludge System
-------
Section 7.0 - Pollution Prevention and Wastewater Treatment Technologies
Figure 7-8. Batch Chemical Precipitation Unit
-------
Section 7.0 - Pollution Prevention and Wastewater Treatment Technologies
Figure 7-9. Membrane Filtration Unit
-------
Section 8.0 - Development of Control and Treatment Options
8.0 DEVELOPMENT OF CONTROL AND TREATMENT OPTIONS
This section describes the combinations of pollution prevention 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. (Note that water conservation practices, which are not part of EPA's technology
bases, are incorporated into EPA's costing methodology for several subcategories. See Section
9.2.7 for additional information.) EPA developed technology options for the following:
• 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 7.0. Sections
8.2 through 8.7 discuss the regulatory options that were considered for each of the regulations
listed above.
8.1 Introduction
The final regulations establish quantitative limits on the discharge of pollutants
from industrial point sources. The applicability of the various limitations for the TECI is
summarized below:
8-1
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Section 8.0 - Development of Control and Treatment Options
BPT
BAT
BCT
NSPS
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 control pollutants that pass through or interfere with
POTWs.
EPA incorporated the following pollution prevention element into all technology
options.
Good Heel Removal and Management Practices. The benefits of good heel
removal and management practices include the following:
— Prevention of pollutants from entering the wastewater stream (i.e.,
maximum removal of heel prior to tank cleaning minimizes the
pollutant loading in the tank interior cleaning wastewater stream);
— Potential to recover/reuse valuable product; and
— Reduced wastewater treatment system capital and annual costs due
to reduced wastewater pollutant loadings.
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Section 8.0 - Development of Control and Treatment Options
The components of good heel removal and management practices are discussed in detail in
Section 7.1.2.
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.
8.2 Best Practicable Control Technology Currently Available (BPT1
The BPT effluent limitations 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).
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Section 8.0 - Development of Control and Treatment Options
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
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 final
limitations. 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.
8.2.1 BPT Options for the Truck/Chemical & Petroleum Subcategory
BPT options for the Truck/Chemical & Petroleum Subcategory include the
following technology bases in addition to good heel removal as discussed in Section 8.1.
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 7.3.
8-4
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Section 8.0 - Development of Control and Treatment Options
Equalization
Purpose: Reduce wastewater variability and accumulate wastewater to optimize subsequent
treatment system size and operating costs.
Design Basis: Minimum of 24-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 8.0 - 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.
All existing direct discharging facilities in this subcategory currently employ
equalization, coagulation/clarification, biological treatment, and activated carbon adsorption. All
existing direct discharging facilities also operate simple oil/water separators, such as gravity
separators or oil skimmers, followed by chemical/physical treatment (e.g., coagulation/
clarification).
8.2.2 BPT Options for the Rail/Chemical & Petroleum Subcategory
BPT options for the Rail/Chemical & Petroleum Subcategory include the following
technology bases in addition to good heel removal as discussed in Section 8.1.
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 7.3.
Oil/Water Separation
Purpose: Removal of entrained oil and grease.
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Section 8.0 - Development of Control and Treatment Options
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.
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-Cl ay/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 ft3/gpm/vessel and carbon charge of 1.44 ft3/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.
Includes sludge storage tank.
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Section 8.0 - Development of Control and Treatment Options
All existing direct discharging facilities in this subcategory currently employ
equalization, pH adjustment, biological treatment and sludge dewatering. All existing direct
discharging facilities also operate simple oil/water separators such as gravity separators or oil
skimmers.
8.2.3 BPT Options for the Barge/Chemical & Petroleum Subcategory
BPT options for the Barge/Chemical & Petroleum Subcategory include the
following technology bases in addition to good heel removal as discussed in Section 8.1.
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 7.3.
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.
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.
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Section 8.0 - Development of Control and Treatment Options
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 with polymer addition for
additional solids removal, 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.
Note that following the proposed rule, EPA obtained additional treatment
performance data for conventional pollutants from two facilities that EPA determined also
operated BPT treatment. The technologies operated by these facilities include:
Facility 1: Gravity separation (1.25-day residence time), equalization and solids settling
(1.85-day residence time), sand filtration (2-hour residence time), biological
treatment with chemically assisted clarification (4-day residence time), and batch
flocculation (1.8-day residence time).
Facility 2: Gravity separation (61-day residence time), equalization (30-day residence time),
biological treatment with chemically assisted clarification (21-day residence time),
and sand filtration (less than 10-minute residence time).
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Section 8.0 - Development of Control and Treatment Options
EPA considers the level of pollutant control demonstrated by these facilities to be
equivalent to Option 1.
8.2.4 BPT Options for the Food Subcategory
BPT options for the Food Subcategory include the following technology bases in
addition to good heel removal as discussed in Section 8.1.
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 7.3.
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.
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.
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Section 8.0 - Development of Control and Treatment Options
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 Food Subcategory. However, EPA's survey of the TECI did not
identify any direct discharging facilities through the Detailed Questionnaire sample population.
The wastewater generated by the Food Subcategory contains high loadings of
biodegradable organics, and few toxic pollutants. EPA conducted sampling at a direct
discharging barge/food facility which EPA believes to be representative of the entire Subcategory
population.
8.2.5 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 good heel removal as
discussed in Section 8.1.
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 7.3.
Gravity Separation
Purpose: Removal of suspended solids.
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Section 8.0 - Development of Control and Treatment Options
Design Basis: Gravity separator with 4-day residence time for wastewater equalization and solids
separation. Includes two separation tanks in series.
8.3 Best Conventional Pollutant Control Technology (BCT>
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
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).
In developing BCT limits, EPA considered whether there are technologies that
achieve greater removals of conventional pollutants than for BPT, and whether those technologies
are cost-reasonable according to the BCT Cost Test. In each subcategory, EPA considered the
same technologies and technology options when developing BCT options as were developed for
BPT.
8.4 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
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Section 8.0 - Development of Control and Treatment Options
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
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.
In each subcategory, EPA considered the same technologies and technology
options when developing BAT options as were developed for BPT.
8.5 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. 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.
In each subcategory, EPA considered the same technologies and technology
options when developing NSPS options as were developed for BPT.
8.6 Pretreatment Standards for Existing Sources (PSES1
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
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Section 8.0 - Development of Control and Treatment Options
specified in Section 307(b) of the CWA. PSES are technology-based and analogous to BAT
limitations for direct dischargers.
8.6.1 PSES Options for the Truck/Chemical & Petroleum Subcategory
PSES options for the Truck/Chemical & Petroleum Subcategory include the
following technology bases in addition to good heel removal as discussed in Section 8.1.
Option A: Equalization and Oil/Water Separation
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 7.3.
Equalization
Purpose: Reduce wastewater variability and accumulate wastewater to optimize subsequent
treatment system size and operating costs.
Design Basis: Minimum 24-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.
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Section 8.0 - Development of Control and Treatment Options
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.
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.
8.6.2 PSES Options for the Rail/Chemical & Petroleum Subcategory
PSES options for the Rail/Chemical & Petroleum Subcategory include the
following technology bases in addition to good heel removal as discussed in Section 8.1.
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-Cl ay/Activated Carbon Adsorption, and Sludge
Dewatering
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Section 8.0 - 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 7.3.
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-Cl ay/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 ft3/gpm/vessel and carbon charge of 1.44 ft3/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.
Includes sludge storage tank.
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Section 8.0 - Development of Control and Treatment Options
8.6.3 PSES Options for the Barge/Chemical & Petroleum Subcategory
PSES options for the Barge/Chemical & Petroleum Subcategory include the
following technology bases in addition to good heel removal as discussed in Section 8.1.
Option 1: Oil/Water Separation, Dissolved Air Flotation, and Filter Press
Option 2: Oil/Water Separation, Dissolved Air Flotation, Filter Press, Biological Treatment,
and Sludge Dewatering
Option 3: 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 7.3.
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 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.
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Section 8.0 - 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 preaeration tanks in series, a clarifier with polymer addition for
additional solids removal, 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.
8.6.4 PSES Options for the Food Subcategory
PSES options for the Food Subcategory include the following technology bases in
addition to good heel removal as discussed in Section 8.1.
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 7.3.
Oil/Water Separation
Purpose: Removal of low to moderate amounts of insoluble oil.
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Section 8.0 - Development of Control and Treatment Options
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.
8.6.5 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 good heel removal as
discussed in Section 8.1.
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 7.3.
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Section 8.0 - Development of Control and Treatment Options
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.
8.6.6 Pollution Prevention Alternative
EPA also considered an enforceable pollution prevention alternative, referred to as
the Pollutants Management Plan. The ten components of this plan include:
(i) procedures for identifying cargos, the cleaning of which is likely to result in
discharges of pollutants that would be incompatible with treatment at the
POTW;
(ii) for cargos identified as being incompatible with treament at the POTW, the
plan shall provide that heels be fully drained, segregated from other
wastewaters, and handled in an appropriate manner;
(iii) for cargos identified as being incompatible with treatment at the POTW,
the Plan shall provide that the tank be prerinsed or presteamed as
appropriate and the wastewater segregated from wastewaters to be
discharged to the POTW and handled in an appropriate manner, where
necessary to ensure that they do not cause or contribute to a discharge that
would be incompatible with treatment at the POTW;
(iv) all spent cleaning solutions, including interior caustic washes, interior
presolve washes, interior detergent washes, interior acid washes, and
exterior acid brightener washes shall be segregated from other wastewaters
and handled in an appropriate manner, where necessary to ensure that they
do not cause or contribute to a discharge that would be incompatible with
treatment at the POTW;
(v) provisions for appropriate recycling or reuse of cleaning agents;
(vi) provisions for minimizing the use of toxic cleaning agents (solvents,
detergents, or other cleaning or brightening solutions);
(vii) provisions for appropriate recycling or reuse of segregated wastewaters
(including heels and prerinse/pre-steam wastes);
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Section 8.0 - Development of Control and Treatment Options
(viii) provisions for off-site treatment or disposal, or effective pre-treatment of
segregated wastewaters (including heels, prerinse/pre-steam wastes, spent
cleaning solutions);
(ix) information on the volumes, content, and chemical characteristics of
cleaning agents used in cleaning or brightening operations; and
(x) provisions for maintaining appropriate records of heel management
procedures, prerinse/pre-steam management procedures, cleaning agent
management procedures, operator training, and proper operation and
maintenance of any pre-treatment system.
8.7 Pretreatment Standards for New Sources (PSNS1
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.
In each subcategory, EPA considered the same technologies and technology
options when developing PSNS options as were developed for PSES.
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Section 9.0 - Costs of Technology Bases for Regulations
9.0 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 8.0 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 10.0, provide a basis for
evaluating the regulatory options and determining the economic impact of the final regulation on
the TECI. The results of the economic impact assessment for the regulation are found in the
Economic Assessment (EA) for the TECI final 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 81 facilities that responded to the
questionnaire 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 9.1.2).
EPA collected and analyzed field sampling data to determine the pollutant
concentrations in untreated TEC-process wastewater (discussed in
Section 6.0).
EPA identified candidate pollution prevention and wastewater treatment
technologies and grouped appropriate technologies into regulatory options
(discussed in Section 8.0). 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
10.0).
EPA developed cost equations for capital and operating and maintenance
(O&M) costs for water conservation practices (discussed in Section 9.2.7)
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Section 9.0 - Costs of Technology Bases for Regulations
and each technology included in the regulatory options (discussed in
Section 9.2.4) based on information gathered from TEC facilities,
wastewater treatment system vendors, technical literature, and on
engineering judgement.
• EPA developed and used an electronic cost model to estimate compliance
costs (discussed in Section 9.3) and pollutant loadings (discussed in
Section 10.0) 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 facility compliance costs for 19 unique technology options.
Table 9-1 at the end of this section lists the number of technology options for which EPA
estimated facility compliance costs.
The following information is discussed in this section:
• Section 9.1: Development of model sites;
• Section 9.2: Methodology used to estimate compliance costs;
• Section 9.3: Design and cost elements for pollutant control technologies;
• Section 9.4: Summary of estimated compliance costs by regulatory
option; and
• Section 9.5: References.
EPA also evaluated a pollution prevention alternative as discussed in Section 8.6.6. Because EPA
is considering the pollution prevention plan as an alternative to meeting the numeric standards,
EPA believes that the costs of this plan will be less than the costs of any of EPA's selected
options because a facility will choose to adopt the most cost effective option available to it.
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Section 9.0 - Costs of Technology Bases for Regulations
9.1 Development of Cost Model Inputs
This section describes the development of the key inputs to the TECI cost model:
model sites and pollutant control technologies.
9.1.1 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 81 facilities were used as model sites for the cost analysis because
each meets the following criteria:
The facility discharges 100,000 gallons or more per year of 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 regulations. Ninety-five facilities would not
incur costs because:
The facility is subject to other Clean Water Act final or proposed
categorical standards and, therefore, meets EPA's exclusion for industrial
and commercial facilities (34 facilities);
The facility discharges less than 100,000 gallons per year of TEC process
wastewater (12 facilities); or
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Section 9.0 - Costs of Technology Bases for Regulations
The facility is a zero or alternative discharging facility (i.e., does not
discharge TEC wastewater either directly or indirectly to a surface water)
and thus would not be subject to the limitations and standards for this
guideline (49 facilities).
Each of the 81 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.
9.1.2 Supplemental Model Site Development
EPA reviewed the 81 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 & Petroleum (three facilities in sample population);
Rail/Chemical & Petroleum (one facility in sample population); and
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Section 9.0 - Costs of Technology Bases for Regulations
• Food (three facilities in sample population).
EPA decided to estimate compliance costs for direct dischargers in the
Truck/Chemical & Petroleum and Rail/Chemical & Petroleum 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 81 model sites (described in Section 9.1) to obtain industry-wide
cost estimates. Statistically, compliance costs for these direct dischargers are included within the
industry-wide cost estimates based on the 81 model facilities. Therefore, EPA used estimated
compliance costs for these direct dischargers only to assess in greater detail the impact of the
limitations on these facilities.
EPA estimates that the compliance costs for direct dischargers in the Food
Subcategory will be zero or insignificant for the following reasons:
All of these facilities identified by EPA currently operate biological
treatment and are believed to currently achieve the final limitations; and
EPA assumes that current NPDES permits for these facilities require
frequent monitoring for pollutant parameters regulated by this guideline
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Section 9.0 - Costs of Technology Bases for Regulations
(i.e., BOD5, TSS, and oil and grease). Therefore, these facilities will not
incur additional monitoring costs as a result of this rulemaking.
Based on this assessment, EPA believes that developing model sites in the TECI
cost model for direct discharging food grade facilities is not necessary.
9.1.3 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 44 engineering site
visits at 43 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. EPA also collected treatment performance data from two additional
Barge/Chemical & Petroleum facilities operating BAT/BPT treatment (see Section 3.5). 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 and PSES Options 1 and 2 for the Truck/Chemical &
Petroleum Subcategory include chemical oxidation, neutralization, coagulation, and clarification
and are specifically based on a turn-key system characterized during wastewater sampling.
Therefore, EPA's estimated compliance costs are based upon implementation of a turn-key
chemical oxidation, neutralization, coagulation, clarification system. EPA chose this approach to
ensure that the technology bases of the regulatory options can achieve the 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
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Section 9.0 - Costs of Technology Bases for Regulations
likely achieve the 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 9.2.5 for more detail on
treatment-in-place credits).
EPA emphasizes that the 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.
9.1.4 Model Sites with Production 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 & Petroleum and Rail/Chemical & Petroleum
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 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 regulations. Therefore, EPA rejected this alternative approach.
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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 &
Petroleum Subcategory technology bases in treating Rail/Chemical & Petroleum Subcategory
wastewater. However, EPA believes that the costed technology for the Truck/Chemical &
Petroleum Subcategory option will control all pollutants of interest 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 for these facilities.
9.2 Costing Methodology
To accurately determine the impact of the 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. However, EPA did not use the cost model to estimate compliance costs for the
Barge/Chemical & Petroleum Subcategory, rather EPA used a site-specific approach to assign
compliance costs (see Section 9.2.9). Again, the regulations do not require that a facility install
and possess these technologies but only that the appropriate facility effluent limitations and
standards be achieved.
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Section 9.0 - Costs of Technology Bases for Regulations
In addition, EPA included water conservation in its costing methodology.
Although water conservation technologies are not included in EPA's technology options, EPA
retained these technologies as a cost-effective compliance strategy for several subcategories (see
Section 9.2.7).
9.2.1 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 stream 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:
• 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 waterway) or
that clean both tanks and closed-top hoppers are considered to have multiple wastewater streams.
However, as discussed in Section 9.1.4, 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.
Wastewater considered in developing compliance costs 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
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Section 9.0 - Costs of Technology Bases for Regulations
cleaning wastewater, equipment and floor washings, TEC-contaminated stormwater, boiler
blowdown, 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 do not fall
within the scope of the TECI rulemaking (e.g., they fall under the scope of another rulemaking)
and they are generally easily segregated from TEC wastewaters.
9.2.2 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 10.0 describes these calculations in more detail.
9.2.3 Cost Model Development
EPA developed a computerized design and cost model to estimate compliance
costs and pollutant reductions for the TECI technology options for the following subcategories:
Truck/Chemical & Petroleum;
Rail/Chemical & Petroleum;
Barge/Chemical & Petroleum (indirect dischargers only);
Food;
Truck/Hopper;
Rail/Hopper; and
Barge/Hopper.
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Section 9.0 - Costs of Technology Bases for Regulations
(The costing methodology developed for direct dischargers in the Barge/Chemical & Petroleum
Subcategory is discussed in Section 9.2.9.)
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 components 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 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.
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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-pi ace data from Detailed Questionnaire responses from each facility (and
other data sources for supplemental facilities, as discussed in Section 9.1.2). 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 days per year, flows, and costs for use in subsequent modules.
9.2.4 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
operating and maintaining the treatment system for a period of one year, including the estimated
costs for compliance monitoring of wastewater discharges. These compliance costs components
are described in detail in the following subsections.
9.2.4.1 Capital Costs
The TECI cost model uses the cost equations listed in Table 9-2 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:
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Section 9.0 - Costs of Technology Bases for Regulations
• Purchase of treatment equipment and any accessories;
• Purchase of treatment equipment instrumentation (e.g., pH probes and
control systems);
• Installation costs (e.g., labor and rental fees for equipment such as cranes);
• 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, and lighting and
electricity hook-ups); and
• Purchase of necessary pumps (e.g., for wastewater transfer, chemical
addition, and sludge handling).
Indirect capital costs are not technology-specific and are instead represented as a
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);
Secondary containment and land costs;
Excavation and site work (e.g., site clearing, landscaping, fences,
walkways, roads, parking areas);
Engineering costs (e.g., administrative, process design and general
engineering, communications, consultant fees, legal fees, travel,
supervision, and inspection of installed equipment);
Construction expenses (e.g., construction tools and equipment,
construction supervision, permits, taxes, insurance, interest);
Contractors' fees; and
Contingency (e.g., allocation for unpredictable events such as foul weather,
price changes, small design changes, and errors in estimates).
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Total capital investment (direct and indirect capital costs) is obtained by
multiplying the direct capital cost by various indirect capital cost factors, summing them, and then
adding start-up costs as shown in Table 9-3.
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 \ —} = INFGPM x 1.3 (1)
where:
DAFGPM = DAF unit nominal capacity (gpm)
INFGPM = 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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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.
9.2.4.2 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 1,000 gallons to
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the 1994 rate of $2.98 per 1,000 gallons using the capital investment index discussed later in this
section.
Table 9-4 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):
AC = OC . (2)
OCI
where:
AC = Adjusted cost, 1994 dollars
OC = Original cost, dollars
OCI = Original cost year index
9.2.5 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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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, bag filters are not considered equivalent to activated
carbon adsorption. Site-specific determinations regarding treatment in place at model sites are
included in the administrative record for this rulemaking.
In some cases, EPA evaluated facility treatment-in-place to determine whether
existing technologies, although not identical to EPA's technology bases, may be sufficient to meet
EPA's effluent limitations. For example, Option 1 for the Truck/Chemical & Petroleum
Subcategory includes oil/water separation (coalescing-type) and chemical/physical treatment
(coagulation/clarification). Several model facilities currently operate simple oil/water separators
such as gravity separators or oil skimmers, followed by chemical/physical treatment (coagulation
or dissolved air flotation). EPA believes both treatment approaches can achieve equivalent
performance; therefore, the Agency assessed treatment-in-place credit for these facilities. This
belief is based on two assumptions. First, EPA assumes that facilities are operating oil/water
separation technologies that are appropriate for the specific amount and type of oils and greases
generated by their facility. Second, EPA assumes that subsequent chemical/physical treatment
will be adequate to handle any minor aberrations in anticipated oil and grease characteristics.
EPA used this same approach for assigning oil/water separation (API) treatment-in-place credit
for the Rail/Chemical & Petroleum Subcategory.
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.
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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 determined 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 regulatory
options for an additional unit to treat the wastewater flow that is above the existing unit's
capacity.
EPA also analyzed technologies that are not considered equivalent, and for which
no credit for treatment in place is given, to see if these facilities currently generate significant
volumes of settled sludge that are disposed off site. Although operation of these units is not
considered equivalent treatment, the sludge currently generated by these units is considered
similar to the sludge that would be generated by the technology bases if the non-equivalent
technology were not operated. If these treatment units continue to be operated after
implementation of the technology bases, they will significantly reduce the amount of sludge that
would be generated by the technology bases. Therefore, EPA credited baseline sludge generation
and disposal from non-equivalent equipment.
9.2.6 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
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• 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.
9.2.7 Good Water Conservation Practices and Flow Reduction
As discussed in Section 7.2, the reduction in the volume of wastewater discharged
from TEC facilities offers several benefits, including the following:
• Reduced water usage and sewage fees;
• Improved wastewater treatment 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.
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.
PNPL = CXPNF (3)
264,170
where:
PNPL = Production normalized pollutant load, g/tank
C = Concentration, |ig/L
PNF = Production normalized flow, gallons/tank
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Equation (3) 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, EPA
included good water conservation practices as a cost-effective compliance strategy for most
subcategories. Although EPA did not include flow reduction in the technology bases for all
subcategories, EPA retained flow reduction in the cost model for most subcategories. Flow
reduction results in significant compliance cost savings and consequently EPA assumed facilities
will incorporate flow reduction in their compliance strategy.
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 facility type. This wastewater volume is
referred to as the "target flow" for each facility type. Table 9-5 presents target flows for existing
facilities by facility type. Development of the target flows is described in Section 9.2.7.2.
EPA did not include water conservation practices as a costing strategy for the
Barge/Chemical & Petroleum Subcategory because of the high variability in wastewater volumes
required for barge cleaning. For example, tanks with an interior frame require more water to
clean, and some barges are only cleaned every few years and may accumulate significant amounts
of residue which require greater volumes of water to clean.
9.2.7.1 Flow Reduction Control Technologies
Since good water conservation practices are defined by median wastewater
volumes per tank cleaned, 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 applicable target flow. For the truck and rail subcategories, except for hoppers, the
control technologies include the following:
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For facilities with current flow to target 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 target 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.
For facilities with current flow to target 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 target flow ratios greater than 1:
— Facility water use monitoring, and
— Personnel training in water conservation.
In calculating compliance cost estimates (see Section 9.3.2), EPA assumed that the
flow reduction technologies are sufficient to achieve the target 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.
'New tank interior cleaning system(s) include(s) solution tanks, controls, pumps, piping, catwalks, stairways, rails, and
spinners.
spinners.
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Section 9.0 - Costs of Technology Bases for Regulations
9.2.7.2 Development of Target Flows
Waste streams considered in developing the target flows include TEC process
wastewater. TEC process wastewater includes the following waste streams:
• Water and steam used to clean tank and container interiors;
• Prerinse cleaning solutions;
• Chemical cleaning solutions;
• Final rinses;
• Tank or trailer exterior cleaning wastewater;
• Equipment and floor washings; and
• TEC-contaminated stormwater.
The following waste streams were not considered in developing the target flows:
• Bilge and ballast waters;
• Non-TEC process wastewaters;
• Sanitary wastewater;
• Tank hydrotesting water; and
• Wastewater generated from rebuilding or maintenance activities.
Target 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 process 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 target
flows, these facilities were assigned a primary subcategory, and the flow contribution of any
secondary subcategory was not considered in the analysis.
For each facility type, using the facility-specific production-normalized flows and
the corresponding facility-specific survey weighting factors, EPA performed a statistical analysis
to determine the median wastewater volume generated per tank cleaned. Detailed information
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concerning calculation of the target flows is included in the Statistical Support Document for the
final rule (2).
9.2.8 Contract Haul in Lieu of Treatment
For some facilities, particularly those with lower 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 for off-site treatment 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 wastewater storage tank, repair labor, O&M materials, and transport and
off-site disposal of the wastewater.
9.2.9 Costing Methodology for Direct Dischargers in the Barge/Chemical &
Petroleum Subcategory
EPA did not use the cost model to estimate compliance costs for direct dischargers
in the Barge/Chemical & Petroleum Subcategory. Due to the small number of model facilities, the
fact that all of the direct dischargers currently operate biological treatment, and the addition of
new wastewater characterization data for the Subcategory, EPA believed that it would be more
appropriate to consider each model facility on an individual basis rather than use the cost model.
EPA gathered information from the Detailed Questionnaire to determine technologies currently in
place (Table L) and current discharge limits (Table P) for each model facility. In general, facilities
supplied discharge data for only conventional and classical pollutants, and some metals; however,
there are several semi-volatile pollutants that are considered pollutants of interest for the
Subcategory. EPA used BOD and/or COD data to assess current treatment performance for these
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facilities and to determine if the semi-volatile limitations are currently achieved. For model
facilities whose effluent data do not meet the BOD and/or COD long term averages, additional
capacity was added to existing biological treatment systems to increase the residence time and/or
aeration of biological treatment. Additional capacity and additional aeration are also assumed to
achieve the long-term averages for BOD and COD as well as organics. For model facilities whose
effluent data do not meet the TSS long term averages, polymer-assisted clarification costs and
additional sludge handling costs were added. Additional operator training costs were also
included in any costed upgrade.
9.3 Design and Cost Elements for Pollutant Control Technologies
This section presents detailed information regarding cost model components and
specific technologies modeled in the cost model.
9.3.1 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:
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• Flow, 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 9.2.5).
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.
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 9.3.2 through 9.3.20 discuss the technology modules.
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Cost Module
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)
Filter Press (For Wastewater Clarification and Sludge Dewatering)
Biological Treatment
Biological Treatment with Extended Aeration and Polymer-Assisted Clarification
Activated Carbon Adsorption (Vessels)
Organo-Clay /Activated Carbon Adsorption
Reverse Osmosis
Sludge Dewatering
Contract Haul of Wastewater in Lieu of Treatment
Compliance Monitoring
Waste Hauling
Section Number
9.3.2
9.3.3
9.3.4
9.3.5
9.3.6
9.3.7
9.3.8
9.3.9
9.3.10
9.3.11
9.3.12
9.3.13
9.3.14
9.3.15
9.3.16
9.3.17
9.3.18
9.3.19
9.3.20
9.3.2
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 discussed in Section 9.2.7. The module compares the
target 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 target 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
target flow of wastewater per tank cleaned) are not costed in the flow reduction module.
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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. EPA did not include flow reduction
costs for the Barge/Chemical & Petroleum Subcategory due to the wide variation in wastewater
volumes generated per cleaning.
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 & Petroleum,
Rail/Chemical & Petroleum, and Food Subcategories (except barge/food
facilities));
Two spinners - one high flow for cleaning solution and one low flow for
rinse (Truck/Chemical & Petroleum, Rail/Chemical & Petroleum, and Food
Subcategories (except barge/food facilities)); and
Cleaning crew training and wastewater flow rate monitoring for all
subcategories (except Barge/Chemical & Petroleum facilities).
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Annual costs include tank cleaning crew training and wastewater flow rate monitoring. 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 additional annual costs are
calculated in the cost module for implementing these technologies.
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 target flow (described in Section 9.2.7) 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 = Water savings (gallons/year)
CWG = Current wastewater generated per tank cleaned (gallons)
NT = Number of tanks cleaned per year
RFWG = Target flow wastewater generated per tank cleaned
(gallons) (see Table 9-5 for specific target flows)
The volume of water saved is then multiplied by the cost of fresh water (as described in Section
9.2.4.2) to estimate monetary savings from reductions in wastewater use.
9.3.3 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
residence times vary by subcategory (details provided in Section 8.0) based on the ratio of
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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.
9.3.4 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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• 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 average 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 and sludge storage tank are sized to hold the volume of oil and
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, based on observations made during site visits and sampling episodes. Waste disposal
costs are calculated separately in the waste haul module (see Section 9.3.20). The oil/water
separator module calculates the amount of oil to be disposed using the difference between the
influent and effluent average total oil and grease concentrations. The oil/water separator module
calculates the amount of sludge to be disposed using the difference between the influent and
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effluent average total suspended solids concentrations. 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.
9.3.5 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 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
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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 not 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 9.3.20). 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 (see Section 9.3.17)). 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.
9.3.6 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 Subcategory, no oil
disposal costs are incurred because EPA assumes oil will be recycled to animal feed and/or soap
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 Subcategory but not for the Barge/Chemical & Petroleum Subcategory because EPA
assumes gravity oil/water separators at Barge/Chemical & Petroleum facilities will generate a
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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 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
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.
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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 Food Subcategory, 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 9.3.20). 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.
9.3.7 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 by settling 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:
• A gravity separator tank;
• Two wastewater transfer pumps; and
• A sludge transfer pump (if sludge generation is less than 1,265 gallons per
month).
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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 9.3.20). 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.
9.3.8 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.
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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 for subsequent 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.
9.3.9 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
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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.
Capital and annual costs for the following equipment are included in the DAF
module:
• 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 motor 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.
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
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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 a sludge storage tank
designed to collect sludge over the period of a month were estimated for facilities currently
operating a DAF unit without sludge dewatering.) Costs for sludge dewatering are estimated in
the sludge dewatering module (see Section 9.3.17). The DAF unit sludge generation rates are
based on information gathered from the Detailed Questionnaire from facilities operating DAF
units with chemical addition.
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.
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.
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9.3.10 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 9.3.20). 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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9.3.11 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 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 either one of the operations
(since they are assumed to generate equal volumes). Waste disposal costs are calculated
separately in the waste haul module (see Section 9.3.20) 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.
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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.
9.3.12 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:
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.
9-41
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Section 9.0 - Costs of Technology Bases for Regulations
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.
9.3.13 Biological Treatment with Extended Aeration and/or Polymer-Assisted
Clarification
These treatment technologies only apply to the Barge/Chemical & Petroleum
Subcategory; therefore, no electronic cost module was developed. EPA estimates costs for a
facility to install and operate additional aerators and polymer-assisted clarification for those
facilities not currently meeting the BOD, COD, and/or TSS long term averages. These
9-42
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Section 9.0 - Costs of Technology Bases for Regulations
technologies are applicable to waste streams following primary treatment, such as oil/water
separation or equalization.
Capital and annual costs for the following equipment are included in the treatment
technology estimates:
• Polymer addition system (e.g., feed pump); and
• Aeration diffusers and blowers.
Annual costs include operational labor, maintenance and repair labor, O&M materials, chemical
costs, electricity, and residual disposal. The polymer feed pump capital and annual costs are
based on a Garratt-Callahan Polymer 7622 metering pump which can accommodate 0.02 to 0.6
gallons per hour of polymer. The aeration diffusers and blowers capital and annual costs are
based on the additional oxygen requirement at each facility.
The polymer metering pump cost is the same for every facility. Polymer addition
rates are based on the ratio of polymer addition to wastewater flow rate based on data from the
Pharmaceutical Manufacturing Industry cost model. Residual disposal costs are based on the
incremental volume of solids removed by subtracting the TSS treatment effectiveness
concentration from the current effluent TSS concentration and converting the difference to either
an incremental filter cake volume or raw sludge volume.
Aeration diffusers and blowers costs are based on the additional volume of oxygen
required based on a facility's influent BOD concentration and assuming the treatment
effectiveness concentration is achieved. In addition to operational and repair labor, costs for
materials, electricity, and labor training are included to optimize biological treatment performance.
9-43
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Section 9.0 - Costs of Technology Bases for Regulations
9.3.14 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 regeneration once per month.
Capital and annual costs for the following equipment are included in the granular
activated carbon module:
• Two wastewater transfer pumps;
• Two bag filters operated in series;
• A backwash tank; and
• Two carbon adsorption filters.
Annual costs include operational labor, maintenance and repair labor, O&M materials, electricity,
chemicals (media changeout), weekly COD monitoring, 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 pumps are based on influent
wastewater flow rate. Electricity costs are based on motor horsepower necessary to operate the
carbon adsorption system.
The costs associated with the bag filters are based on two carbon steel 2-inch
housings with 5-micron bag filters. Bag costs are based on using one bag per operating day, and
labor costs are based on operating days per year. The backwash tank volume is based on the
volume required to hold 30 minutes worth of daily wastewater flow at the facility. Operational
labor to backwash the system is included.
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Section 9.0 - Costs of Technology Bases for Regulations
EPA assumes that one column of spent activated carbon is changed out once per
month. Media change-out costs include costs for labor and fresh media. Weekly COD
monitoring of influent and effluent from the carbon vessels is included to test the effectiveness of
the carbon. Spent carbon is assumed to be sent off site for regeneration. Media change-out costs
include costs for labor and fresh media. 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 than 265 days per year by multiplying "typical" residual regeneration costs by a
factor consisting of actual operating days divided by 265.
9.3.15 Organo-Clay/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
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
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Section 9.0 - Costs of Technology Bases for Regulations
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.
9.3.16 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
9-46
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Section 9.0 - Costs of Technology Bases for Regulations
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.
9.3.17 Sludge Dewatering (Plate-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 & Petroleum 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 pump in the oil/water separator module (see Section 9.3.4),
costs are not included for an additional pump in the sludge dewatering module for the
Truck/Chemical & Petroleum 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 & Petroleum and Food
Subcategory);
• Sludge storage tank (PSES Option 1 for the Rail/Chemical & Petroleum
Subcategory);
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Section 9.0 - Costs of Technology Bases for Regulations
• 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. Materials costs include annual
replacement of filter press cloths. 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 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 & Petroleum and Rail/Chemical & Petroleum 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 9.3.20) 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. A one-time sludge profile fee and roll-off box
delivery fee are also included.
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.
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Section 9.0 - Costs of Technology Bases for Regulations
9.3.18 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.
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.
9.3.19 Compliance Monitoring
Compliance monitoring costs are included in all of the regulatory options for all
subcategories.
In this module, EPA estimates annual compliance monitoring costs for all TEC
facilities. The annual cost calculated by the model for compliance monitoring includes laboratory
costs to analyze wastewater semivolatile organics, metals, and classical pollutants. For indirect
dischargers, EPA estimates costs for facilities to monitor monthly for all regulated pollutants (see
Section 12.3). For direct dischargers, EPA estimates costs for facilities to monitor weekly for
classical pollutants and monthly for semivolatile organics and metals. However, for direct
dischargers in the Food Subcategory, EPA estimates costs for facilities to monitor weekly for only
classical pollutants because EPA is regulating only these pollutants in the Food Subcategory.
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.
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Section 9.0 - Costs of Technology Bases for Regulations
Analytical Method
Method 625 - Semi- Volatile Organic Compounds
Method 1620 - Metals
Method 1664 -HEM
Method 1664 - SGT-HEM
Method 401. 5 -BOD
Method 410.4 -COD
Method 160.2 - TSS
Laboratory Fee
($1994)
$350
$598
$35
$56.67
$16
$20
$6.50
Reference
(39)
(8)
(8)
(39)
(8)
(8)
(40)
9.3.20
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 national vendors. Undewatered
sludge disposal costs are based on using either a vacuum-truck or multiple drums, depending on
the volume to be disposed. Dewatered sludge costs include an annual roll-off box rental.
9.4
Summary of Costs by Regulatory Option
Table 9-6 summarizes estimated BPT, BCT, and BAT compliance costs by
regulatory option. Table 9-7 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 9-6 and 9-7 represent the direct capital
costs estimated by the technology modules plus the indirect capital costs discussed in Section
9.2.4.1. The annual costs shown in Tables 9-6 and 9-7 represent the direct annual costs estimated
by the technology modules plus the compliance monitoring and waste hauling costs discussed in
Sections 9.3.19 and 9.3.20, respectively.
9-50
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Section 9.0 - Costs of Technology Bases for Regulations
9.5 References2
1. U.S. Environmental Protection Agency, Office of Water. Economic Analysis for
the Final Effluent Limitations Guidelines for the Transportation Equipment
Cleaning Industry. EPA 821-R-00-013, June 2000.
2. U.S. Environmental Protection Agency, Office of Water. Statistical Support
Document for the Final Effluent Limitations Guidelines for the Transportation
Equipment Cleaning Industry. EPA-821-B-98-014, May 1998.
3. The Richardson Rapid System Process Plant Construction Estimating Standards.
Volume 4: Process Equipment, 1994.
4. 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).
5. Eastern Research Group, Inc. Flow Reduction Cost Module Documentation for
the Transportation Equipment Cleaning Cost Model. May 1998 (DCN T09753).
6. "Economic Indicators." Chemical Engineering. September 1995, page 168.
7. Eastern Research Group, Inc. Contract Haul Cost Module Documentation for the
Transportation Equipment Cleaning Cost Model. May 1998 (DCN T09754).
8. Eastern Research Group, Inc. Monitoring Cost Module Documentation for the
Transportation Equipment Cleaning Cost Model. May 1998 (DCN T09852).
9. Eastern Research Group, Inc. Equalization Cost Module Documentation
Transportation Equipment Cleaning Cost Model Truck/Chemical Subcategory.
May 1998 (DCN T09730).
10. Eastern Research Group, Inc. Oil/Water Separation Cost Module Documentation
for the Transportation Equipment Cleaning Cost Model Truck/Chemical
Subcategory (Direct Dischargers! May 1998 (DCN T09734).
11. Eastern Research Group, Inc. Oil/Water Separation Cost Module Documentation
for the Transportation Equipment Cleaning Cost Model Truck/Chemical
Subcategory (Indirect Dischargers! May 1998 (DCN T09731).
2For those references included in the administrative record supporting the TECI rulemaking, the document control
number (DCN) is included in parentheses at the end of the reference.
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Section 9.0 - Costs of Technology Bases for Regulations
12. Eastern Research Group, Inc. Chemical Oxidation/Neutralization/Coagulation/
Clarification Cost Module Documentation for the Transportation Equipment
Cleaning Cost Model Truck/Chemical Subcategory (Direct Dischargers). May
1998(DCNT09735).
13. Eastern Research Group, Inc. Chemical Oxidation/Neutralization/Coagulation/
Clarification Cost Module Documentation for the Transportation Equipment
Cleaning Cost Model Truck/Chemical Subcategory (Indirect Dischargers). May
1998(DCNT09732).
14. Eastern Research Group, Inc. Sludge Dewatering Cost Module Documentation
for the Transportation Equipment Cleaning Cost Model Truck/Chemical
Subcategory TDirect Dischargers! May 1998 (DCN T09726).
15. Eastern Research Group, Inc. Sludge Dewatering Cost Module Documentation
for the Transportation Equipment Cleaning Cost Model Truck/Chemical
Subcategory (Indirect Dischargers! May 1998 (DCN T09723).
16. Eastern Research Group, Inc. Biological Treatment Cost Module Documentation
for the Transportation Equipment Cleaning Cost Model Truck/Chemical
Subcategory TDirect Dischargers! May 1998 (DCN T09736).
17. Eastern Research Group, Inc. Activated Carbon Adsorption Cost Module
Documentation for the Transportation Equipment Cleaning Cost Model
Truck/Chemical Subcategory. May 1998 (DCN T09733).
18. Eastern Research Group, Inc. Oil/Water Separation Cost Module Documentation
for the Transportation Equipment Cleaning Cost Model Rail/Chemical
Subcategory TDirect Dischargers! May 1998 (DCN T09741).
19. Eastern Research Group, Inc. Oil/Water Separation Cost Module Documentation
for the Transportation Equipment Cleaning Cost Model Rail/Chemical
Subcategory (Indirect Dischargers! May 1998 (DCN T09737).
20. Eastern Research Group, Inc. Equalization Cost Module Documentation for the
Transportation Equipment Cleaning Cost Model Rail/Chemical Subcategory. May
1998(DCNT09738).
21. Eastern Research Group, Inc. pH Adjustment/Dissolved Air Flotation Cost
Module Documentation for the Transportation Equipment Cleaning Cost Model
Rail/Chemical Subcategory TDirect Dischargers! May 1998 (DCN T09742).
9-52
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Section 9.0 - Costs of Technology Bases for Regulations
22. Eastern Research Group, Inc. pH Adjustment/Dissolved Air Flotation Cost
Module Documentation for the Transportation Equipment Cleaning Cost Model
Rail/Chemical Subcategory (Indirect Dischargers! May 1998 (DCN T09739).
23. Eastern Research Group, Inc. Sludge Dewatering Cost Module Documentation for
the Transportation Equipment Cleaning Cost Model Rail/Chemical Subcategory
rPirect Dischargers! May 1998 (DCN T09727).
24. Eastern Research Group, Inc. Sludge Dewatering Cost Module Documentation for
the Transportation Equipment Cleaning Cost Model Rail/Chemical Subcategory
rindirect Dischargers! May 1998 (DCN T09724).
25. Eastern Research Group, Inc. Biological Treatment Cost Module Documentation
for the Transportation Equipment Cleaning Cost Model Rail/Chemical
Subcategory TDirect Dischargers! May 1998 (DCN T09743).
26. Eastern Research Group, Inc. Organo-Cl ay/Granular Activated Carbon Cost
Module Documentation for the Transportation Equipment Cleaning Cost Model
Rail/Chemical Subcategory. May 1998 (DCN T09740).
27. Eastern Research Group, Inc. Primary Oil/Water Separation and Dissolved Air
Flotation Cost Module Documentation for the Transportation Equipment Cleaning
Cost Model Barge/Chemical Subcategory. May 1998 (DCN T09744).
28. Eastern Research Group, Inc. Filter Press Cost Module: Sludge Dewatering
Documentation for the Transportation Equipment Cleaning Cost Model
Barge/Chemical Subcategory TBaseline! May 1998 (DCN T09851).
29. Eastern Research Group, Inc. Filter Press Cost Module: Wastewater and Sludge
Documentation for the Transportation Equipment Cleaning Cost Model
Barge/Chemical Subcategory (Indirect Dischargers! May 1998 (DCN T09725).
30. Eastern Research Group, Inc. Biological Treatment Cost Module Documentation
for the Transportation Equipment Cleaning Cost Model Barge/Chemical
Subcategory. May 1998 (DCN T09745).
31. Eastern Research Group, Inc. Reverse Osmosis Cost Module Documentation for
the Transportation Equipment Cleaning Cost Model Barge/Chemical Subcategory.
May 1998 (DCN T09746).
32. Eastern Research Group, Inc. Equalization Cost Module Documentation for the
Transportation Equipment Cleaning Cost Model Food Subcategories. May 1998
(DCN T09748).
9-53
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Section 9.0 - Costs of Technology Bases for Regulations
33. Eastern Research Group, Inc. Oil/Water Separation Cost Module Documentation
for the Transportation Equipment Cleaning Cost Model Food Subcategories. May
1998(DCNT09749).
34. Eastern Research Group, Inc. Biological Treatment Cost Module Documentation
for the Transportation Equipment Cleaning Cost Model Food Subcategories. May
1998(DCNT09750).
35. Eastern Research Group, Inc. Sludge Dewatering Cost Module Documentation
for the Transportation Equipment Cleaning Cost Model Food Subcategories. May
1998(DCNT09729).
36. Eastern Research Group, Inc. Gravity Separator Cost Module Documentation for
the Transportation Equipment Cleaning Cost Model Hopper Subcategories. May
1998(DCNT09747).
37. 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).
38. 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).
39. Eastern Research Group, Inc. TECI Cost Model Revision Documentation. June
1999 (DCN T20322).
40. Eastern Research Group, Inc. Barge/Chemical & Petroleum (Direct Dischargers)
Costing Calculation Sheets. May 1999 (DCN T20379).
41. Eastern Research Group, Inc. Costs for Filter Press Cloths. July 1998 (DCN
T20487).
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Section 9.0 - Costs of Technology Bases for Regulations
Table 9-1
Number of Costed Technology Options for Each TECI Subcategory
Subcategory
Truck/Chemical & Petroleum
Rail/Chemical & Petroleum
Barge/Chemical & Petroleum
Food
Truck/Hopper
Rail/Hopper
Barge/Hopper
Number of Unique
Technology Options
5
6
3
2
1
1
1
Number of
BPT/BCT/BAT/
NSPS Options
2
O
2
2
NA
NA
1
Number of
PSES/PSNS
Options
3
O
3
2
1
1
1
NA - Not Applicable
9-55
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Section 9.0 - Costs of Technology Bases for Regulations
Table 9-2
Direct Capital Costs Used by the TECI Cost Model
Capital Costs
Item
Cleaning bays
Spinners and covers (2)
Equalization tank
Equalization tank
mixer/aerator
Demulsifier pump
Oil/water separator
(vertical tube coalescing)
Oil storage tank
Sludge transfer pump
Sludge storage tank
Chemical
oxidation/coagulation/
clarification system
Cost Equation ($1994)
C = 65,000 - 74,928 for 1 bay (based on tank type)
C = 80,000 - 82,798 for 2 bays (based on tank type)
C = 150,000 - 165,596 for 4 bays (based on tank type)
C = 10,000
C = 1.002(V) + 4,159.944
C = 463forV<16,667
C = 573forV<33,333
C = 804 for V> 33,333
C = 1,634
C = -0.926(GPM)2 + 247.9(GPM) + 6,209
C = 0.874(V) + 202.45
C = 2,102forGPM<2
C =1,602 for GPM>2
C = 0.846(V) + 355.163
C = -3.885(GPM)2 + 1,374.588(GPM) + 49,978.01
Subcategory(ies)
Truck/Chemical & Petroleum
Rail/Chemical & Petroleum
Truck/Chemical & Petroleum
Rail/Chemical & Petroleum
Truck/Chemical & Petroleum
Food
Truck/Chemical & Petroleum
Food
Truck/Chemical & Petroleum
Truck/Chemical & Petroleum
Truck/Chemical & Petroleum
Barge/Chemical & Petroleum
Truck/Chemical & Petroleum
Truck/Hopper
Rail/Hopper
Barge/Hopper
Food
Truck/Chemical & Petroleum
Truck/Chemical & Petroleum
Technology(ies)
Flow Reduction
Flow Reduction
Equalization
Equalization
Oil/Water Separator
Oil/Water Separator
Oil/Water Separator
Oil/Water Separator,
Gravity Separation
Oil/Water Separator
Chemical Oxidation,
Neutralization,
Coagulation,
Clarification
Reference
(5)
(5)
(9, 32)
(9, 32)
(10,11)
(10,11)
(10, 11,27)
(10, 11,33,
36)
(10,11)
(12,13)
VO
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Section 9.0 - Costs of Technology Bases for Regulations
Table 9-2 (Continued)
Capital Costs
Item
Poly alum chloride storage
tank
Plate-and-frame filter press
Dewatered sludge profile
fee and roll-off box drop-off
fee
Un-dewatered sludge
profile fee
Wastewater pumps (for
carbon adsorption system)
Activated carbon
adsorption vessels (2
vessels)
Bag filters
Backwash tank
Cost Equation ($1994)
C = 6,698
C = -6.244(FCV)2 + 1,527.685(FCV) + 10,379.655
C = 487
C = 200
C = -0.1 l(GPM)2 + 31.706(GPM) + 562.079
C = 12.237(ACV)L026
C = 649.69
C = 0.9047(V) + 328.65
Subcategory(ies)
Truck/Chemical & Petroleum
Truck/Chemical & Petroleum
Rail/Chemical & Petroleum
Barge/Chemical & Petroleum
Food
Truck/Chemical & Petroleum
Rail/Chemical & Petroleum
Barge/Chemical & Petroleum
Food
Truck/Chemical & Petroleum
Rail/Chemical & Petroleum
Barge/Chemical & Petroleum
Food
Truck/Hopper
Rail/Hopper
Barge/Hopper
Truck/Chemical & Petroleum
Truck/Chemical & Petroleum
Truck/Chemical & Petroleum
Truck/Chemical & Petroleum
Technology(ies)
Chemical Oxidation,
Neutralization,
Coagulation,
Clarification
Filter Press,
Sludge Dewatering
Sludge Dewatering,
Filter Press
Oil/Water Separation,
Dissolved Air
Flotation,
Chemical Oxidation,
Neutralization,
Coagulation,
Clarification
Biological Treatment,
Gravity Separation
Activated Carbon
Adsorption
Activated Carbon
Adsorption
Activated Carbon
Adsorption
Activated Carbon
Adsorption
Reference
(12,13)
(14, 15,23,
24, 28, 29,
35)
(7)
(7)
(17)
(17)
(39)
(39)
VO
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Section 9.0 - Costs of Technology Bases for Regulations
Table 9-2 (Continued)
Capital Costs
Item
Wastewater transfer pump
Oil transfer pump
Oil/water separator (API)
Oil storage tank
Sludge storage tank
Equalization tank
Equalization tank agitator
Chemical addition tank and
polymer mixing tank
Chemical addition tank
mixer
pH probe
Acid addition pump
Caustic addition pump
Polymer mixing tank mixer
Polymer pump
Polymer dilution tank
Polymer dilution tank mixer
Cost Equation ($1994)
C = 0.0124(GPM)3 - 0.985(GPM)2 + 23.352(GPM) +
847.032
C = 0.0124(GPM)3 - 0.985(GPM)2 + 23.352(GPM) +
847.032
C = -0.312(GPM)2 + 277.123(GPM) + 38,266.407
C = 1.949(V) + 573.468 for V>185 gallons
C = 970 for V< 185 gallons
C = 2.668(V) + 154.792 for V>55 gallons
C =193 for V< 55 gallons
C = -0.000017(V)2 + 1.185(V) + 673.73
C = 2827.932LOG10(HP) + 4,604.077
C = 4.27(V) + 684.194
C = 1.162(V) + 622.232
C = 1,177. 70
C = 316.8
C = 3 16.8 for V <450 gallons
C = 371 .8 for V >450 gallons
C = 1.071(V) + 610.915
C = 697.2 for polymers 7622 and 7181
C = 686 for polymer 7032
C = 0.00038(V)3 - 0. 18828(V)2 + 32.308(V) - 554.286
C = 3. 38(V) + 566.510
Subcategory(ies)
Rail/Chemical & Petroleum
Barge/Chemical & Petroleum
Truck/Hopper
Rail/Hopper
Barge/Hopper
Rail/Chemical & Petroleum
Barge/Chemical & Petroleum
Rail/Chemical & Petroleum
Rail/Chemical & Petroleum
Rail/Chemical & Petroleum
Rail/Chemical & Petroleum
Rail/Chemical & Petroleum
Rail/Chemical & Petroleum
Rail/Chemical & Petroleum
Rail/Chemical & Petroleum
Rail/Chemical & Petroleum
Rail/Chemical & Petroleum
Rail/Chemical & Petroleum
Rail/Chemical & Petroleum
Barge/Chemical & Petroleum
Rail/Chemical & Petroleum
Rail/Chemical & Petroleum
Technology(ies)
Oil/Water Separation,
pH Adjustment,
Gravity Separation,
Organo-
Clay/Activated
Carbon Adsorption
Oil/Water Separation
Oil/Water Separation
Oil/Water Separation
Oil/Water Separation
Equalization
Equalization
pH Adjustment,
DAF
pH Adjustment
pH Adjustment
pH Adjustment
pH Adjustment
DAF
DAF
Polymer-Assisted
Coagulation
DAF
DAF
Reference
(18, 19,21,
22, 26, 36)
(18, 19,27)
(18, 19)
(18,19)
(18,19)
(20)
(20)
(21,22)
(21,22)
(21,22)
(21,22)
(21,22)
(21,22)
(21,22,39)
(21,22)
(21,22)
VO
I
-------
Section 9.0 - Costs of Technology Bases for Regulations
Table 9-2 (Continued)
Capital Costs
Item
DAF unit
DAF compressor
Sludge storage tank
Pre-engineered building
Sludge transfer pump
Sludge storage tank
Organo-clay /activated
carbon vessels
Oil/water separator(gravity
separation)
Oil/water separator effluent
pump, precoat pump, and
filter press influent pump
DAF unit
Sludge storage tank
Filter press wastewater
effluent storage tank
Precoat storage tank
Cost Equation ($1994)
C = -1.357(GPM)2 + 291.471(GPM) + 68,163. 591
C = 245. 317(HP) + 1,998.279
C = 2.587(V)+ 159.528
C = 19,450.08
C = -22.288(HP)2 + 327.219(HP) + 1,827.999
C = 15,678.49LOG10(V) - 40,333.095
C = 2.922(FMC)2 + 169.642(FMC) + 3,825.433
C = 0.234(V)+ 16,153
C= 1,928.46 for GPM<2
C = 2,015.98forGPM<4
C = 2,226.1 for GPM<7. 5
C = 3,371. 21 for GPM<15
C = 4,784.05 for GPM<30
C = 6,696.73 for GPM> 30
C = 46,000 for GPM<53
C = 68,500 for GPM> 53
C = 0.917(V) + 322.7
C = 0.526(V) + 3,246. 142
C = 4,160 for FPV<10
C = 4,544 for FPV <30
C = 5,078 for FPV<50
C = 6,980 FPV<1 00
C =10,284 for FPV > 100
Subcategory(ies)
Rail/Chemical & Petroleum
Rail/Chemical & Petroleum
Rail/Chemical & Petroleum
Rail/Chemical & Petroleum
Rail/Chemical & Petroleum
Rail/Chemical & Petroleum
Rail/Chemical & Petroleum
Barge/Chemical & Petroleum
Truck/Chemical & Petroleum
Rail/Chemical & Petroleum
Barge/Chemical & Petroleum
Food
Barge/Chemical & Petroleum
Barge/Chemical & Petroleum
Barge/Chemical & Petroleum
Truck/Chemical & Petroleum
Rail/Chemical & Petroleum
Barge/Chemical & Petroleum
Food
Technology(ies)
DAF
DAF
DAF
DAF
Oil/Water Separation,
Sludge Dewatering
Sludge Dewatering
Organo-
Clay/Granular
Activated Carbon
Oil/Water Separation
Oil/Water Separator,
Filter Press,
Sludge Dewatering
DAF
DAF
Filter Press
Filter Press,
Sludge Dewatering
Reference
(21,22)
(21,22)
(21,22)
(21,22)
(18,23,24)
(24)
(26)
(27)
(14, 23, 27,
28, 29, 35)
(27)
(27)
(29)
(14, 23, 28,
29, 35)
VO
-------
Section 9.0 - Costs of Technology Bases for Regulations
Table 9-2 (Continued)
Capital Costs
Item
Wastewater transfer
pump/oil transfer pump
(operating at maximum
capacity)
Preaeration tank
Diffusers/blowers
Biological reactor tank
Clanfier
Biological treatment
optimization labor
Sludge storage and reverse
osmosis storage tank
Sludge transfer pump
Cost Equation ($1994)
C = O.OOIS(GPM)3 - 0.2463(GPM)2 + 1 1.6758(GPM)
+ 847.0323
C = 0.578(V) + 2,142. 109
C = 23.443(FT3M) + 787.24
C = -0.371(V/1,000)2 + 475.133(V/1,000) +
2,3000.696
C = 0.331(GPM)2 + 143.329(GPM) + 21,838.385
C = 1,036
C = 0.733(V)+ 12,170.856
C = 209.82(HP) + 1,888.2
Subcategory(ies)
Truck/Chemical & Petroleum
Rail/Chemical & Petroleum
Barge/Chemical & Petroleum
Food
Truck/Chemical & Petroleum
Rail/Chemical & Petroleum
Barge/Chemical & Petroleum
Food
Truck/Chemical & Petroleum
Rail/Chemical & Petroleum
Barge/Chemical & Petroleum
Food
Truck/Chemical & Petroleum
Rail/Chemical & Petroleum
Barge/Chemical & Petroleum
Food
Truck/Chemical & Petroleum
Rail/Chemical & Petroleum
Barge/Chemical & Petroleum
Food
Barge/Chemical & Petroleum
Truck/Chemical & Petroleum
Rail/Chemical & Petroleum
Barge/Chemical & Petroleum
Food
Truck/Chemical & Petroleum
Rail/Chemical & Petroleum
Barge/Chemical & Petroleum
Food
Technology(ies)
Oil/Water Separation,
Biological Treatment
Biological Treatment
Biological Treatment
Biological Treatment
Biological Treatment
Biological Treatment
Biological Treatment,
Reverse Osmosis
Biological Treatment,
Sludge Dewatering
Reference
(16, 25, 30,
33,34)
(16, 25, 30,
34)
(16, 25, 30,
34)
(16, 25, 30,
34)
(16, 25, 30,
34)
(40)
(16, 25, 30,
31,34)
(16, 25, 30,
34,35)
VO
ON
O
-------
Section 9.0 - Costs of Technology Bases for Regulations
Table 9-2 (Continued)
Capital Costs
Item
Wastewater pump (effluent
from biological treatment)
Flooded suction tank
Reverse osmosis unit
Gravity separator
Cost Equation ($1994)
C = 3.383(HP)2 + 64.263(HP) + 1,024.71 1
C = -0.0003(V)2 + 2.9356(V) + 1 18.68 for V>55
C=193forV<55
C = -13.578(GPM)2 + 2,600. 9(GPM) + 4,773.9
C = -0.00002(V)2 + 1. 165(V) + 4748.36 for V<2 1,808
C = 0.00000006(V)2 + 0.2849(V) + 10,738 for
V> 2 1,808
Subcategory(ies)
Truck/Chemical & Petroleum
Rail/Chemical & Petroleum
Barge/Chemical & Petroleum
Food
Barge/Chemical & Petroleum
Barge/Chemical & Petroleum
Truck/Hopper
Rail/Hopper
Barge/Hopper
Food
Technology(ies)
Biological Treatment
Reverse Osmosis
Reverse Osmosis
Oil/Water Separator,
Gravity Separation
Reference
(16, 25, 30,
34)
(31)
(31)
(33, 36)
VO
ACV - Activated carbon vessel volume (cubic feet).
API - American Petroleum Institute.
C - Direct capital equipment costs ($1994).
DAF - Dissolved Air Flotation.
FC V - Filter cake volume (cubic feet per day).
FMC - Filter media vessel volume (cubic feet).
FT3M - Flow rate (cubic feet per minute).
GPM - Flow rate (gallons per minute).
HP - Motor horsepower (hp).
FPV - Filter press volume (cubic feet).
V - Tank volume (gallons).
-------
Section 9.0 - Costs of Technology Bases for Regulations
Table 9-3
Components of Total Capital Investment
Item
1
2
3
4
5
6
7
8
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
Direct + Indirect Costs
Start-up costs
Total Capital Investment
Cost
Direct Capital Cost
10%ofiteml
10%ofiteml
3. 5% of item 6
30% of item 6
Sum of items 1 through 5 =
1.80 x Direct Capital Cost
$207.2
Sum of items 6 and 7 =
(1.80 x Direct Capital Cost) + 207.2
Source: Reference (39).
9-62
-------
Section 9.0 - Costs of Technology Bases for Regulations
Table 9-4
Operation and Maintenance Unit Costs Used by the TECI Cost Model
Item
Cost ($1994)7
Cost Equation ($1994)
Practice/
Technology
Reference
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 HEM
Laboratory fee for SGT-HEM
Laboratory fee for BOD5
Laboratory fee for COD
Laboratory fee for TSS
$0.44/gallon
$0.37/gallon
$141.01/yd3 + $4,176/yrfor
roll-off box rental
$0.53-$3.58/gallon
(based on volume)
$459/analysis
$350/analysis
$598/analysis
$35/analysis
$56.67/analysis
$16/analysis
$20/analysis
$6/analysis
Contract Haul
Contract Haul
Contract Haul
Contract Haul
Compliance Monitoring
Compliance Monitoring
Compliance Monitoring
Compliance Monitoring
Compliance Monitoring
Compliance Monitoring
Compliance Monitoring
Compliance Monitoring
(7)
(7)
(7)
(7)
(8)
(39)
(8)
(8)
(39)
(8)
(8)
(40)
Chemicals
Activated carbon (annual media
change-out and regeneration)
Biological treatment microbes
Demulsifier
Diatomaceous earth
Organo-clay /activated carbon
adsorption (annual media
change-out)
Organo-clay /activated carbon
disposal (organo-clay
incineration and activated
carbon regeneration)
Hydrogen peroxide
A = 0.00112(ACV)2 +
11.663(ACV) + 11058.543
$2.84/lb
$33.36/gallon
$0.76/lb
A = -1.785(FMV)2 +
946.009(FMV) - 450.496
A= 161. 429(FMV) + 8464.083
$0.45-$0.69/lb
Activated Carbon Adsorption
Biological Treatment
Oil/Water Separator
Filter Press, Sludge
Dewatering
Organo-Clay /Activated
Carbon Adsorption
Organo-Clay /Activated
Carbon Adsorption
Chemical Oxidation,
Neutralization, Coagulation,
Clarification
(17)
(16, 25, 30,
34)
(10,11)
(14, 23, 28,
29, 35)
(25)
(26)
(12,13)
9-63
-------
Section 9.0 - Costs of Technology Bases for Regulations
Table 9-4 (Continued)
Item
Magnesium hydroxide
Poly alum chloride
Polymer
Polymer 7032
Polymer 7181
Polymer 7622
Sodium hydroxide (50%)
Sulfunc acid (93%)
Cost ($1994)7
Cost Equation ($1994)
$0.26-$0.36/lb
$2.53-$4.28/gallon
$2.44-$3.00/lb
$1.10/lb
$4.45/lb
$1.25/lb
$1.689/gallon
$0.095-$0.28/lb
$1.091/gallon
Practice/
Technology
Chemical Oxidation,
Neutralization, Coagulation,
Clarification
Chemical Oxidation,
Neutralization, Coagulation,
Clarification
Chemical Oxidation,
Neutralization, Coagulation,
Clarification, Biological
Treatment
DAF
DAF
DAF
pH Adjustment
Chemical Oxidation,
Neutralization, Coagulation,
Clarification, and
pH Adjustment
Reference
(12,13)
(12,13)
(12, 13,
40)
(21,22)
(21,22)
(21,22)
(21,22)
(12, 13,21,
22)
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
Tanks with mixers maintenance
labor
Tanks without mixers
maintenance labor
Tank(all) repair labor
A = (FPT-REG)(0.5)(25.9) for
truck tank type
A=(FPT-REG)(0.5)(25. 9)7(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))
A =103. 6 -207.2
(based on tank volume)
A = 414.4 -828.8
(based on tank volume)
A = (0.01)(C)
Flow Reduction
All
All
Oil/Water Separator
Oil/Water Separator
Equalization,
pH Adjustment,
Filter Press,
DAF,
Biological Treatment,
Sludge Dewatering
All
All
(5)
(37)
(37)
(10,11)
(10,11)
(9, 14,20,
21,22,23,
28, 29, 30,
32,35,38)
(38)
(38)
9-64
-------
Section 9.0 - Costs of Technology Bases for Regulations
Table 9-4 (Continued)
Item
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
Activated carbon operational
labor
Bag filter operational labor
Bag filter maintenance and
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
Cost ($1994)7
Cost Equation ($1994)
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 = (0.5)(DPY)(25.9) + 1,295
A = (0.5)(DPY)(25.9)
A = (0.01)(C)
A = (2)(0.01)(C)
A = (0.01)(C)
A = (DPY)(25.9)
A = 414.4
A = 414.4
Practice/
Technology
Filter Press,
Sludge Dewatering
DAF
DAF
Chemical Oxidation,
Neutralization, Coagulation,
Clarification
Chemical Oxidation,
Neutralization, Coagulation,
Clarification
Activated Carbon Adsorption
Activated Carbon Adsorption
Activated Carbon Adsorption
Activated Carbon Adsorption
pH Adjustment
Organo-Clay /Activated
Carbon Adsorption
Reverse Osmosis
Reverse Osmosis
Oil/Water Separation
Reference
(14, 15,23,
24, 28, 29,
35)
(21, 22,
27)
(21, 22,
27)
(12, 13)
(12,13)
(17)
(39)
(39)
(39)
(21,22)
(25)
(31)
(31)
(18, 19)
Material and Replacement Costs
Pump materials
Chemical oxidation/
neutralization/coagulation/
clarification materials
Demulsifier pump materials
Oil/water separator (vertical
tube coalescing) materials
Bag filters
A = (0.01)(C)
A = (0.01)(C)
A=15
A = 8-25
(based on wastewater flow)
A = (2.30)(DPY)
All
Chemical Oxidation,
Neutralization, Coagulation,
Clarification
Oil/Water Separation
Oil/Water Separation
Activated Carbon Adsorption
(37)
(12, 13)
(10,11)
(10,11)
(39)
9-65
-------
Section 9.0 - Costs of Technology Bases for Regulations
Table 9-4 (Continued)
Item
Filter press cloths
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)7
Cost Equation ($1994)
A = 245-8, 100
(based on filter press volume)
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
Practice/
Technology
Filter Press
Sludge Dewatering
Filter Press
Sludge Dewatering
DAF
DAF
pH Adjustment
Filter Press,
Sludge Dewatering
Reverse Osmosis
Reference
(41)
(14, 15,23,
24, 28, 29,
35)
(21,22)
(21,22)
(21,22)
(14, 23, 28,
29, 35)
(31)
General Costs
Electricity usage fee
O&M labor rate
Water usage fee
$0.0477 kilo watt-hour
$25.90/hour
$2. 98/1,000 gal of water
All
All
Flow Reduction
(4)
(3)
(5)
A - Annual costs ($1994/year).
ACV - Activated carbon vessel volume (cubic feet).
BP Y - 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).
FJPD - Operating hours per day.
REG - Subcategory median flow per tank (gallons).
9-66
-------
Section 9.0 - Costs of Technology Bases for Regulations
Table 9-5
Target Wastewater Flow by Facility Type
Facility Type
Truck/Chemical & Petroleum
Rail/Chemical & Petroleum
Truck/Food
Rail/Food
Barge/Food
Truck/Hopper
Rail/Hopper
Barge/Hopper
Target Flow
(gallons/tank)
605
2,091
790
4,500
4,500
144
267
712
Source: Reference (2).
9-67
-------
Section 9.0 - Costs of Technology Bases for Regulations
Table 9-6
Cost Summary of Regulatory Options for BPT/BAT/BCT (a)
Subcategory
Barge/Chemical & Petroleum
Barge/Chemical & Petroleum
Rail/Chemical & Petroleum
Rail/Chemical & Petroleum
Rail/Chemical & Petroleum
Truck/Chemical & Petroleum
Truck/Chemical & Petroleum
Food (b)
Food (b)
Barge/Hopper (c)
Option
1
2
1
2
o
3
i
2
1
2
1
Capital Cost
(Thousand $1994)
$85
$1,800
$0
$184
$199
$77
$77
$0
$0
$160
O&M Cost
(Thousand $/yr (in $1994))
$126
$316
$7
$35
$61
$(28)
$(28)
$0
$0
$480
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 regulated
conventional pollutants.
(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.
9-68
-------
Section 9.0 - Costs of Technology Bases for Regulations
Table 9-7
Cost Summary of Regulatory Options for PSES (a)
Subcategory
Barge/Chemical & Petroleum
Barge/Chemical & Petroleum
Barge/Chemical & Petroleum
Rail/Chemical & Petroleum
Rail/Chemical & Petroleum
Rail/Chemical & Petroleum
Truck/Chemical & Petroleum
Truck/Chemical & Petroleum
Truck/Chemical & Petroleum
Food
Food
Barge/Hopper
Rail/Hopper
Truck/Hopper
Option
1
2
o
6
i
2
3
A
1
2
1
2
1
1
1
Capital Cost
(Thousand $1994)
$0
$0
$430 (b)
$3,190
$7,040
$7,540
$19,300
$51,400
$65,400
$18,100 (c)
$96,400 (c)
$0(c)
$0(c)
$310(c)
O&M Cost
(Thousand $/yr (in $1994))
$61
$61
$220 (b)
$496
$659
$1,500
$5,480
$8,030
$23,600
$30.6 (c)
$61. 6 (c)
$26 (c)
$28 (c)
$390 (c)
Source: Output from the Transportation Equipment Cleaning Design and Cost Model.
(a) Costs are based on monthly monitoring of all regulated pollutants.
(b) Costs are based on one facility; however, since proposal, EPA has identified four facilities that previously discharged
directly to surface waters and have since either switched or plan to switch discharge status. EPA did not consider
Option 3 for PSES or PSNS at proposal; therefore, EPA did not revise compliance costs for this option for the final rule.
(c) EPA did not consider these options for PSES or PSNS at proposal; therefore, EPA did not revise compliance costs
for these options for the final rule.
9-69
-------
Section 10.0 - Pollutant Reduction Estimates
10.0 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 8.0. The Agency estimated pollutant loadings and pollutant
reductions at 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 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 pollutants of interest that were treated by the
technology bases. The selection of pollutants included in the load removal estimates is discussed
below. 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 10.1 presents the methodology used to identify pollutants included
in the load removal estimates;
10-1
-------
Section 10.0 - Pollutant Reduction Estimates
• Section 10.2 presents the general methodology used to calculate TECI
pollutant loadings and pollutant reductions;
• Section 10.3 presents the general methodology used to estimate untreated
pollutant loadings in TEC wastewaters;
• Section 10.4 presents the methodology used to estimate untreated
production normalized pollutant loadings (PNPLs) in TEC wastewaters for
multiple subcategory facilities;
• Section 10.5 presents the estimated untreated pollutant loadings for the
TECI;
• Section 10.6 presents the estimated baseline pollutant loadings for the
TECI;
• Section 10.7 presents the estimated post-compliance pollutant loadings for
the TECI;
• Section 10.8 presents the estimated pollutant loading reductions achieved
by the TECI following implementation of each regulatory option; and
• Section 10.9 presents references for this section.
EPA has not directly evaluated pollutant removals for the pollution prevention alternative. EPA
believes that pollutant reductions would be equivalent to or exceed the load removals from EPA's
regulatory options.
10.1 Methodology Used to Identify Pollutants Included in the Load Removal
Estimates
After determining pollutants of interest for each subcategory (discussed in Section
6.6), EPA selected treatment technologies and composed technology options that control the
pollutants of interest for each subcategory. Next, EPA gathered influent and effluent sampling
data to characterize treatment performance for the options. EPA evaluated the sampling data and
determined if a pollutant of interest was treated by one or more of the wastewater treatment
technology options evaluated for each subcategory and discharge type (i.e., indirect or direct) by
analyzing the percent reduction achieved by the technology option. (The technology options
10-2
-------
Section 10.0 - Pollutant Reduction Estimates
considered for each subcategory are discussed in Section 8.0.) EPA included all pollutants of
interest in the load removal estimates that had a removal efficiency greater than 0% by at least one
technology option considered by the Agency. The criterion was applied to the base technology
option and to each incremental technology option individually. This criterion insures that EPA
does not select for regulation pollutants that are not removed or controlled by the technology
options considered by the Agency.
If a given pollutant of interest met this criterion, treatment effectiveness
concentrations and/or percent removal efficiencies were also calculated. Additional information
on identifying pollutants included in the load removal estimates and their corresponding removal
rates for each TECI subcategory can be found in reference 1 and reference 2.
10.2 General Methodology Used to Calculate Pollutant Loadings and Pollutant
Reductions
In 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 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 9.0) to
estimate the loading of each pollutant in each model facility untreated TEC
wastewater stream.
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.
10-3
-------
Section 10.0 - Pollutant Reduction Estimates
6. For each pollutant of interest (see Section 6.6), pollutant removal
efficiencies achieved by the treatment technologies that comprise each
TECI regulatory option were developed using analytical data collected
during EPA's TECI sampling program.
7. 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.
8. 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 and percent
removal efficiency achieved by existing treatment, and determined the
pollutant reductions achieved by the existing treatment.
9. The baseline pollutant concentrations were converted to baseline pollutant
loadings using facility flow rates and a conversion factor.
10. 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.
11. The TECI cost model calculated the post-compliance pollutant loadings
and pollutant reductions achieved by each regulatory option. As discussed
in Section 8.0, each TECI regulatory option is comprised of a set of
pollutant control technologies. For each facility and for each treatment
unit, the cost model compared the pollutant concentrations in the
wastewater influent to the treatment effectiveness concentration and/or the
pollutant percent removal efficiency achieved by the treatment unit, and
then determined the pollutant reductions achieved.
12. The post-compliance pollutant concentrations were converted to post-
compliance pollutant loadings using facility flow rates and a conversion
factor.
13. 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.
14. 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.
10-4
-------
Section 10.0 - Pollutant Reduction Estimates
10.3
15. TECI and TECI subcategory pollutant reductions achieved by each
regulatory option were calculated using the model facility pollutant
reductions and statistically generated weighting factors.
General Methodology Used to Estimate Untreated Pollutant Loadings
The Agency used analytical data collected during EPA's TECI sampling program
„,. 4. ^~+.,,—. remove(j by the regulatory
to calculate untreated PNPLs for pollutants of interest that were icmuvcu uy me icguicuuiy
options evaluated for each TECI subcategory. The following table lists the number of untreated
wastewater characterization samples collected and analyzed for each TECI subcategory:
Subcategory
Truck/Chemical & Petroleum
Rail/Chemical & Petroleum
Barge/Chemical & Petroleum
Food
Truck/Hopper
Rail/Hopper
Barge/Hopper
Number of Untreated Wastewater
Characterization Samples Collected
10
5
10
7
0
0
1
Number of Facilities
Sampled
5
2
o
J
3
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
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. No untreated wastewater characterization data were submitted in
comments on the proposed rule and notice of availability.
10-5
-------
Section 10.0 - Pollutant Reduction Estimates
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 x cf x F
L; =
where:
T (1)
i = Pollutant / in waste stream
L; = Pollutant loading generated per tank cleaned (milligram/tank or
microgram/tank, depending on the pollutant)
Q = Pollutant concentration in TEC wastewater characterization sample
(milligram/liter or microgram/liter, depending on the pollutant)
cf = Conversion factor (liters per gallon)
F = 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
T = 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
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.
10-6
-------
Section 10.0 - Pollutant Reduction Estimates
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:
where:
DL;
N
N
DL; =
j=Sample 1
N
(2)
Daily average pollutant loading generated per tank cleaned
(milligram/tank or microgram/tank, depending on the pollutant)
Pollutant /' in waste stream
Pollutant loading generated per tank cleaned for sample
(milligram/tank or mi crogr am/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
where:
FL;
FL; =
j=Day 1
N
(3)
Facility-specific average pollutant loading generated per tank
cleaned (milligram/tank or microgram/tank, depending on the
pollutant)
Pollutant /' in waste stream
Pollutant loading generated per tank cleaned on Day j
(milligram/tank or microgram/tank, depending on the pollutant)
10-7
-------
N
Section 10.0 - Pollutant Reduction Estimates
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 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 were weighted equally in calculating the subcategory PNPLs,
regardless of the number of wastewater samples collected at each facility.
Facility N
where:
PNPL; =
N
PNPL; =
.
j= Facility 1
N
(4)
Subcategory average production normalized pollutant loading
generated per tank cleaned (milligram/tank or microgram/tank,
depending on the pollutant)
Pollutant /' 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
Additional information on the calculation of untreated PNPLs for each TECI
subcategory can be found in reference 3.
10-8
-------
Section 10.0 - Pollutant Reduction Estimates
10.4 Multiple Subcategory 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 & Petroleum and the Rail/Chemical &
Petroleum 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 of interest for the primary subcategory. Estimation of pollutant reductions for multiple
subcategory facilities is described in greater detail in the rulemaking record.
10.5 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 &
Petroleum 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
entire TECI. Tables 10-1 through 10-10 present total industry untreated pollutant loadings by
pollutant and discharge status for each subcategory.
10-9
-------
Section 10.0 - Pollutant Reduction Estimates
10.6 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 9.2.5 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 10.5 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 10-1 through 10-10 present the total industry baseline pollutant loadings by
pollutant and discharge status for each subcategory.
10.7 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 10.6. 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
with the facility flow and an appropriate conversion factor to determine the model facility post-
compliance pollutant loadings for each regulatory option.
10-10
-------
Section 10.0 - Pollutant Reduction Estimates
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 10-1 through 10-10 present the total industry post-
compliance pollutant loadings by pollutant and discharge status for each subcategory.
10.8 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 10-1 through 10-10.
10.8.1 BPT
Table 10-11 summarizes pollutant loading reductions for each TECI regulatory
option considered for BPT. 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.
Tables 10-1 through 10-4 present the BPT pollutant loading reduction estimates
for all pollutants and regulatory options for the following subcategories:
• Truck/Chemical & Petroleum Subcategory (Table 10-1);
• Rail/Chemical & Petroleum Subcategory (Table 10-2);
• Barge/Chemical & Petroleum Subcategory (Table 10-3); and
• Barge/Hopper Subcategory (Table 10-4).
As discussed in Section 9.2.9, EPA did not use the cost model to estimate
compliance costs for direct dischargers in the Barge/Chemical & Petroleum Subcategory. In
10-11
-------
Section 10.0 - Pollutant Reduction Estimates
addition, EPA did not use the cost model to estimate pollutant loadings and reductions for this
subcategory for the same reasons discussed in Section 9.2.9. Because EPA used BOD and/or
COD baseline concentrations as indicators for treatment of other pollutants of interest, EPA did
not estimate baseline loadings and removals for other pollutants of interest.
Furthermore, EPA did not re-evaluate Option 2 pollutant loadings and removals
for the Barge/Chemical & Petroleum Subcategory because this option was determined to not
represent the average of the best treatment (because it is not commonly used in the industry) for
the proposed rule. The Proposed Technical Development Document presents baseline and option
loadings and removals for all options considered at proposal, including Option 2 (4). Note that
these loadings are not representative of the current state of the industry (because several facilities
have changed discharge status) and EPA's available sampling data; however, the loadings
demonstrate the pollutant reduction capacity of Option 2.
10.8.2 BCT
BCT options developed and evaluated by EPA are identical to those developed
and evaluated for BPT. Therefore, BCT pollutant loading reductions are identical to the BPT
pollutant loading reductions for conventional pollutants discussed in Section 10.8.1.
10.8.3 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 10.8.1.
10-12
-------
Section 10.0 - Pollutant Reduction Estimates
10.8.4 PSES
Table 10-12 summarizes pollutant loading reductions for each TECI regulatory
option considered for PSES.
Tables 10-5 through 10-10 present the PSES pollutant loading reduction estimates
for all pollutants and regulatory options for the following subcategories:
• Truck/Chemical & Petroleum Subcategory (Table 10-5);
• Rail/Chemical & Petroleum Subcategory (Table 10-6);
• Food Subcategory (Table 10-7);
• Truck/Hopper Subcategory (Table 10-8);
• Rail/Hopper Subcategory (Table 10-9); and
• Barge/Hopper Subcategory (Table 10-10).
As discussed in Section 9.2.9, based on a review of current operating and
discharge monitoring data (e.g., BOD and/or COD) for EPA's model facilities in the
Barge/Chemical & Petroleum Subcategory, EPA believes that all model indirect discharging
facilities are meeting levels of control that would be established under PSES Options 1 and 2.
Consequently, EPA estimates zero load reductions associated with these options. EPA believes
there may be some additional removals associated with PSES Option 3; however, EPA believes
that this option would not result in a significant reduction of toxic pollutants because most
pollutants are already treated to very low levels based on the Option 2 level of control. EPA did
not re-evaluate Option 3 pollutant loadings and removals for this Subcategory because this option
was rejected for the proposed rule because of small incremental removals achieved by this option.
The Proposed Development Document presents baseline and option loadings and removals for all
options considered at the proposal, including Option 3 (4). Note that these loadings are not
representative of the current state of the industry (because several facilities have changed
discharge status) and EPA's available sampling data; however, the loadings demonstrate the
pollutant reduction capacity of Option 2 and Option 3.
10-13
-------
Section 10.0 - Pollutant Reduction Estimates
10.9 References1
1. Eastern Research Group, Inc. Development of Final Removal Efficiencies and
Treatment Effectiveness Concentrations for Regulated Subcategories.
Memorandum from Melissa Cantor, Eastern Research Group, Inc. to the TECI
Rulemaking Record. March 28, 2000 (DCN T20513).
2. Eastern Research Group, Inc. Development of Treatment Effectiveness
Concentrations and Percent Removals. Memorandum from Grace Kitzmiller,
Eastern Research Group, Inc. to the TECI Rulemaking Record. April 29, 1998
(DCN T09764).
3. 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).
4. U.S. Environmental Protection Agency, Office of Water. Development Document
for Proposed Effluent Limitations Guidelines and Standards for the Transportation
Equipment Cleaning Category. EPA-821-B-98-011, May 1998.
For those references included in the administrative record supporting the TECI rulemaking, the document control
number (DCN) is included in parentheses at the end of the reference.
10-14
-------
Section 10.0 - Pollutant Reduction
Table 10-1
Truck/Chemical & Petroleum Subcategory - Direct Dischargers
Summary of Pollutant Loadings and Reductions by Technology Option (a)
Pollutant Name
CAS
Number
Untreated
Wastewater
Pollutant
Loading
(Ib/yr)
Baseline
Wastewater
Pollutant
Loading
(Ib/yr)
Option 1
Wastewater
Pollutant
Loading
(Ib/yr)
Option 2
Wastewater
Pollutant
Loading
(Ib/yr)
Option 1
Pollutant
Reduction
from Baseline
(Ib/yr)
Option 2
Pollutant
Reduction
from Baseline
(Ib/yr)
Bulk Conventionals
5-Day Biochemical Oxygen Demand
Oil and Grease (HEM)
Total Suspended Solids
NA
NA
NA
420,000
250,000
230,000
930
700
3,400
920
700
3,400
920
700
3,400
8.6
6.5
32
8.6
6.5
32
Bulk Nonconventionals
Chemical Oxygen Demand
Total Organic Carbon
Total Petroleum Hydrocarbons (SGT-HEM)
NA
NA
NA
1,000,000
240,000
23,000
36,000
27,000
640
35,000
27,000
640
35,000
27,000
640
330
250
6.0
330
250
6.0
Nonconventional Metals
Aluminum
Boron
Iron
Manganese
Phosphorus
Silicon
Tin
Titanium
7429905
7440428
7439896
7439965
7723140
7440213
7440315
7440326
TOTAL Nonconventional Metals
1,100
580
3,300
170
9,800
2,300
2,100
34
19,000
25
35
120
27
2,800
660
830
2.5
4,500
25
35
120
27
2,700
660
820
2.4
4,400
25
35
120
27
2,700
660
820
2.4
4,400
<1
<1
1.1
<1
26
6.2
7.7
<1
41
<1
<1
1.1
<1
26
6.2
7.7
<1
41
-------
Section 10.0 - Pollutant Reduction
Table 10-1 (Continued)
Pollutant Name
CAS
Number
Untreated
Wastewater
Pollutant
Loading
(Ib/yr)
Baseline
Wastewater
Pollutant
Loading
(Ib/yr)
Option 1
Wastewater
Pollutant
Loading
(Ib/yr)
Option 2
Wastewater
Pollutant
Loading
(Ib/yr)
Option 1
Pollutant
Reduction
from Baseline
(Ib/yr)
Option 2
Pollutant
Reduction
from Baseline
(Ib/yr)
Nonconventional Organics
1,2,3, 4,6,7, 8-Heptachlorodibenzo-p-dioxin
1,2,3,4,6,7,8-Heptachlorodibenzofuran
2,4,5-T
2-Methylnaphthalene
2-Isopropylnaphthalene
2,4-DB (Butoxon)
2,4,5-TP
Acetone
Adsorbable Organic Halides (AOX)
alpha-Terpineol
Azinphos Methyl
Benzoic Acid
Benzyl Alcohol
Dalapon
Diallate
Dimethyl Sulfone
Leptophos
m-Xylene
MCPA
Methyl Ethyl Ketone
Methyl Isobutyl Ketone
35822469
67562394
93765
91576
2027170
94826
93721
67641
59473040
98555
86500
65850
100516
75990
2303164
67710
21609905
108383
94746
78933
108101
<1
<1
<1
13
33
1.3
<1
5,100
810
45
<1
4,300
49
<1
3.8
1,300
1.0
360
100
920
350
<1
<1
<1
1.3
1.3
1.2
<1
300
79
1.3
<1
270
2.5
<1
<1
1.3
<1
1.3
34
18
21
<1
<1
<1
1.3
1.3
1.2
<1
300
79
1.3
<1
270
2.5
<1
<1
1.3
<1
1.3
34
18
21
<1
<1
<1
1.3
1.3
1.2
<1
300
79
1.3
<1
270
2.5
<1
<1
1.3
<1
1.3
34
18
21
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
-------
Section 10.0 - Pollutant Reduction
Table 10-1 (Continued)
Pollutant Name
n-Octadecane
n-Triacontane
n-Tetradecane
n-Decane
n-Docosane
n-Dodecane
n-Eicosane
n-Hexacosane
n-Hexadecane
n-Tetracosane
o-Cresol
o+p-Xylene
Octachlorodibenzo-p-dioxin
p-Cresol
p-Cymene
Pentachloronitrobenzene
Styrene
Total Phenols
CAS
Number
593453
638686
629594
124185
629970
112403
112958
630013
544763
646311
95487
136777612
3268879
106445
99876
82688
100425
NA
TOTAL Nonconventional Organics
Untreated
Wastewater
Pollutant
Loading
(Ib/yr)
71
39
89
63
19
200
55
26
130
33
13
180
<1
13
10
1.4
570
390
15,000
Baseline
Wastewater
Pollutant
Loading
(Ib/yr)
1.3
1.3
1.3
1.3
1.3
1.3
1.3
1.3
1.3
1.3
1.7
1.3
<1
1.7
1.3
<1
1.7
230
990
Option 1
Wastewater
Pollutant
Loading
(Ib/yr)
1.3
1.3
1.3
1.3
1.3
1.3
1.3
1.3
1.3
1.3
1.7
1.3
<1
1.7
1.3
<1
1.7
230
990
Option 2
Wastewater
Pollutant
Loading
(Ib/yr)
1.3
1.3
1.3
1.3
1.3
1.3
1.3
1.3
1.3
1.3
1.7
1.3
<1
1.7
1.3
<1
1.7
230
990
Option 1
Pollutant
Reduction
from Baseline
(Ib/yr)
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
2.2
3.7
Option 2
Pollutant
Reduction
from Baseline
(Ib/yr)
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
2.2
3.7
-------
Section 10.0 - Pollutant Reduction
Table 10-1 (Continued)
Pollutant Name
CAS
Number
Untreated
Wastewater
Pollutant
Loading
(Ib/yr)
Baseline
Wastewater
Pollutant
Loading
(Ib/yr)
Option 1
Wastewater
Pollutant
Loading
(Ib/yr)
Option 2
Wastewater
Pollutant
Loading
(Ib/yr)
Option 1
Pollutant
Reduction
from Baseline
(Ib/yr)
Option 2
Pollutant
Reduction
from Baseline
(Ib/yr)
Other Nonconventionals
Fluoride
Nitrate/Nitrite
Total Phosphorus
Surfactants (MBAS)
16984488
NA
14265442
NA
TOTAL Other Nonconventionals
3,600
320
4,600
3,000
12,000
2,400
90
1,200
130
3,800
2,300
89
1,200
130
3,800
2,300
89
1,200
130
3,800
22
<1
12
1.2
35
22
<1
12
1.2
35
Priority Metals
Chromium
Copper
Mercury
Zinc
7440473
7440508
7439976
7440666
TOTAL Priority Metals
350
43
<1
100
490
2.5
11
<1
2.6
16
2.5
11
<1
2.5
16
2.5
11
<1
2.5
16
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
Priority Organics
1 ,2-Dichloroethane
1,1,1 -Trichloroethane
1 ,2-Dichlorobenzene
2-Chlorophenol
Benzene
beta-BHC
Bis (2-ethylhexyl) Phthalate
Chloroform
107062
71556
95501
95578
71432
319857
117817
67663
98
130
18
11
6.4
<1
92
12
1.6
1.3
1.3
1.7
1.3
<1
1.3
1.3
1.6
1.3
1.3
1.7
1.3
<1
1.3
1.3
1.6
1.3
1.3
1.7
1.3
<1
1.3
1.3
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
o
oo
-------
Section 10.0 - Pollutant Reduction
Table 10-1 (Continued)
Pollutant Name
Di-n-Octyl Phthalate
Ethylbenzene
Methylene Chloride
Naphthalene
Tetrachloroethylene
Toluene
Trichloroethylene
CAS
Number
117840
100414
75092
91203
127184
108883
79016
TOTAL Priority Organics
Untreated
Wastewater
Pollutant
Loading
(Ib/yr)
30
81
2,000
55
200
310
3.6
3,100
Baseline
Wastewater
Pollutant
Loading
(Ib/yr)
1.3
1.3
220
1.3
1.3
1.3
1.8
230
Option 1
Wastewater
Pollutant
Loading
(Ib/yr)
1.3
1.3
210
1.3
1.3
1.3
1.8
230
Option 2
Wastewater
Pollutant
Loading
(Ib/yr)
1.3
1.3
210
1.3
1.3
1.3
1.8
230
Option 1
Pollutant
Reduction
from Baseline
(Ib/yr)
<1
<1
2.0
<1
<1
<1
<1
2.2
Option 2
Pollutant
Reduction
from Baseline
(Ib/yr)
<1
<1
2.0
<1
<1
<1
<1
2.2
o
VO
(a) All data are presented with two significant digits. Apparent inconsistencies in sums and differences are due to rounding.
NA - Not applicable.
Note: EPA did not revise the pollutant loadings and reductions to include 18 additional pollutants of interest and the final pollutant removal methodology because these
additional pollutant removals would have an insignificant impact on the total load removals.
-------
Section 10.0 - Pollutant Reduction
Table 10-2
Rail/Chemical & Petroleum Subcategory - Direct Dischargers
Summary of Pollutant Loadings and Reductions by Technology Option (a)
Pollutant Name
CAS Number
Untreated
Wastewater
Pollutant
Loading
(Ib/yr)
Baseline
Wastewater
Pollutant
Loading
(Ib/yr)
Option 1
Wastewater
Pollutant
Loading
(Ib/yr)
Option 2
Wastewater
Pollutant
Loading
(Ib/yr)
Option 3
Wastewater
Pollutant
Loading
(Ib/yr)
Option 1
Pollutant
Reduction
from
Baseline
(Ib/yr)
Option 2
Pollutant
Reduction
from
Baseline
(Ib/yr)
Option 3
Pollutant
Reduction
from Baseline
(Ib/yr)
Bulk Conventional
5-Day Biochemical Oxygen Demand
Oil and Grease (HEM)
Total Suspended Solids
NA
NA
NA
8,200
3,600
2,400
62
50
85
62
50
85
62
28
85
55
28
23
0
0
0
0
22
0
7.5
22
62
Bulk Nonconventionals
Chemical Oxygen Demand
Total Dissolved Solids
Total Organic Carbon
Total Petroleum Hydrocarbons
^SGT-HEM)
NA
NA
NA
NA
19,000
37,000
4,500
860
770
34,000
770
87
770
34,000
770
87
770
25,000
540
28
760
21,000
510
28
0
0
0
0
0
9,200
230
59
15
13,000
260
59
Nonconventional Metals
Aluminum
Barium
Boron
Calcium
Iron
Magnesium
Manganese
Phosphorus
Potassium
Silicon
7429905
7440393
7440428
7440702
7439896
7439954
7439965
7723140
7440097
7440213
55
3.4
8.6
170
70
69
3.5
56
4,500
57
23
3.3
7.6
130
70
57
2.9
45
4,200
57
23
3.3
7.6
130
70
57
2.9
45
4,200
57
12
1.1
6.3
130
<1
55
1.9
8.5
3,300
39
<1
1.1
5.5
130
<1
55
1.9
5.7
3,100
39
0
0
0
0
0
0
0
0
0
0
10
2 2
1.4
2.7
69
1.7
<1
36
890
18
22
2.2
2.1
2.7
69
1.7
<1
39
1,100
18
to
o
-------
Section 10.0 - Pollutant Reduction
Table 10-2 (Continued)
Pollutant Name
Sodium
Sulfur
Titanium
CAS Number
7440235
7704349
7440326
TOTAL Nonconventional Metals
Untreated
Wastewater
Pollutant
Loading
(Ib/yr)
7,800
2,200
<1
15,000
Baseline
Wastewater
Pollutant
Loading
(Ib/yr)
6,900
2,000
<1
13,000
Option 1
Wastewater
Pollutant
Loading
(Ib/yr)
6,900
2,000
<1
13,000
Option 2
Wastewater
Pollutant
Loading
(Ib/yr)
4,900
1,500
<1
10,000
Option 3
Wastewater
Pollutant
Loading
(Ib/yr)
4,800
1,300
<1
9,500
Option 1
Pollutant
Reduction
from
Baseline
(Ib/yr)
0
0
0
0
Option 2
Pollutant
Reduction
from
Baseline
(Ib/yr)
1,900
450
<1
3,400
Option 3
Pollutant
Reduction
from Baseline
(Ib/yr)
2,100
620
<1
3,900
Nonconventional Organics
1 -Methylphenanthrene
2,4-Diaminotoluene
2,4,5-TP
2,4,5-T
2,4-DB (Butoxon)
Acephate
Acetone
Adsorbable Organic Halides (AIX)
Benefluralin
Benzoic Acid
Carbazole
Dacthal (DCPA)
Diallate
Dicamba
Dichloroprop
Dimethyl Sulfone
Dinoseb
Gamma-chlordane
Hexanoic Acid
832699
95807
93721
93765
94826
30560191
67641
59473040
1861401
65850
86748
1861321
2303164
1918009
120365
67710
88857
5103742
142621
<1
7.3
<1
<1
<1
3.0
2.1
5.3
<1
7.8
<1
<1
1.3
2.0
<1
<1
<1
<1
11
<1
7.3
<1
<1
<1
2.9
<1
1.7
<1
<1
<1
<1
<1
1.9
<1
<1
<1
<1
11
<1
7.3
<1
<1
<1
2.9
<1
1.7
<1
<1
<1
<1
<1
1.9
<1
<1
<1
<1
11
<1
6.9
<1
<1
<1
2.5
<1
1.6
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
6.0
<1
<1
<1
<1
<1
<1
<1
1.2
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
6.0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
<1
<1
<1
<1
<1
<1
0
<1
<1
0
<1
<1
<1
1.9
<1
<1
<1
<1
4.9
<1
6.7
<1
<1
<1
2.8
0
<1
<1
<1
<1
<1
<1
1.9
<1
<1
<1
<1
4.9
-------
Section 10.0 - Pollutant Reduction
Table 10-2 (Continued)
Pollutant Name
m-Xylene
MCPP
Methyl Ethyl Ketone
n-Triacontane
n-Tetracosane
n-Tetradecane
n-Octadecane
n-Docosane
n-Octacosane
n-Dodecane
n-Eicosane
n-Hexadecane
n-Hexacosane
o+p-Xylene
Octachlorodibenzo-p-dioxin
Octachlorodibenzofuran
3-Cresol
Dentachloronitrobenzene
Dropachlor
Dropazine
3tyrene
Ferbacil
Ferbuthylazine
CAS Number
108383
7085190
78933
638686
646311
629594
593453
629970
630024
112403
112958
544763
630013
136777612
3268879
39001020
106445
82688
1918167
139402
100425
5902512
5915413
Untreated
Wastewater
Pollutant
Loading
(Ib/yr)
<1
130
<1
<1
1.0
6.5
5.7
1.2
<1
1.7
4.9
9.4
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
9.4
Baseline
Wastewater
Pollutant
Loading
(Ib/yr)
<1
130
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
9.3
Option 1
Wastewater
Pollutant
Loading
(Ib/yr)
<1
130
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
9.3
Option 2
Wastewater
Pollutant
Loading
(Ib/yr)
<1
15
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
6.7
Option 3
Wastewater
Pollutant
Loading
(Ib/yr)
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
Option 1
Pollutant
Reduction
from
Baseline
(Ib/yr)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Option 2
Pollutant
Reduction
from
Baseline
(Ib/yr)
0
110
<1
<1
<1
0
0
0
<1
0
0
0
<1
0
<1
<1
0
<1
0
0
0
0
2.6
Option 3
Pollutant
Reduction
from Baseline
(Ib/yr)
0
130
<1
<1
<1
0
0
0
<1
0
0
0
<1
0
<1
<1
<1
<1
0
<1
0
0
9.3
to
to
-------
Section 10.0 - Pollutant Reduction
Table 10-2 (Continued)
Pollutant Name
Total Phenols
CAS Number
NA
TOTAL Nonconventional Organics
Untreated
Wastewater
Pollutant
Loading
(Ib/yr)
2.5
220
Baseline
Wastewater
Pollutant
Loading
(Ib/yr)
1.8
170
Option 1
Wastewater
Pollutant
Loading
(Ib/yr)
1.8
170
Option 2
Wastewater
Pollutant
Loading
(Ib/yr)
1.2
43
Option 3
Wastewater
Pollutant
Loading
(Ib/yr)
<1
11
Option 1
Pollutant
Reduction
from
Baseline
(Ib/yr)
0
0
Option 2
Pollutant
Reduction
from
Baseline
(Ib/yr)
<1
130
Option 3
Pollutant
Reduction
from Baseline
(Ib/yr)
1.6
160
Other Nonconventionals
Ammonia as Nitrogen
Chloride
'luoride
Nitrate/Nitrite
Surfactants (MBAS)
Total Phosphorus
7664417
16887006
16984488
NA
NA
14265442
TOTAL Other Nonconventionals
180
5,700
10
27
11
57
6,000
33
5,400
10
9.7
11
41
5,500
33
5,400
10
9.7
11
41
5,500
33
3,900
6.9
9.7
4.2
7.8
4,000
28
3,900
3.1
5.3
2.0
3.0
4,000
0
0
0
0
0
0
0
0
1,500
3.4
0
6.8
33
1,500
4.6
1,500
7.2
4.5
8.9
38
1,500
Priority Metals
Arsenic
Chromium
Copper
Line
7440382
7440473
7440508
7440666
TOTAL Priority Metals
<1
<1
<1
2.1
3.0
<1
<1
<1
1.5
2.4
<1
<1
<1
1.5
2.4
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
0
0
0
0
0
<1
<1
<1
1.4
1.9
<1
<1
<1
1.4
2.0
Priority Organics
alpha-BHC
Anthracene
beta-BHC
delta-BHC
Dieldrin
indosulfan Sulfate
ithylbenzene
319846
120127
319857
319868
60571
1031078
100414
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
0
0
0
0
0
0
0
<1
<1
<1
<1
<1
<1
0
<1
<1
<1
<1
<1
<1
0
o
to
-------
Section 10.0 - Pollutant Reduction
Table 10-2 (Continued)
Pollutant Name
Fluoranthene
Sfaphthalene
Phenanthrene
Phenol
Pyrene
CAS Number
206440
91203
85018
108952
129000
TOTAL Priority Organics
Untreated
Wastewater
Pollutant
Loading
(Ib/yr)
<1
<1
1.1
1.8
<1
5.0
Baseline
Wastewater
Pollutant
Loading
(Ib/yr)
<1
<1
<1
<1
<1
<1
Option 1
Wastewater
Pollutant
Loading
(Ib/yr)
<1
<1
<1
<1
<1
<1
Option 2
Wastewater
Pollutant
Loading
(Ib/yr)
<1
<1
<1
<1
<1
<1
Option 3
Wastewater
Pollutant
Loading
(Ib/yr)
<1
<1
<1
<1
<1
<1
Option 1
Pollutant
Reduction
from
Baseline
(Ib/yr)
0
0
0
0
0
0
Option 2
Pollutant
Reduction
from
Baseline
(Ib/yr)
<1
0
<1
<1
<1
<1
Option 3
Pollutant
Reduction
from Baseline
(Ib/yr)
<1
0
<1
<1
<1
<1
to
(a) All data are presented with two significant digits. Apparent inconsistencies in sums and differences are due to rounding.
NA - Not applicable.
-------
Section 10.0 - Pollutant Reduction
Table 10-3
Barge/Chemical & Petroleum Subcategory - Direct Dischargers
Summary of Pollutant Loadings and Reductions by Technology Option (a)
Pollutant Name
CAS
Number
Untreated
Wastewater
Pollutant
Loading
(Ib/yr)
Baseline
Wastewater
Pollutant
Loading
(Ib/yr)
Option 1
Wastewater
Pollutant
Loading
(Ib/yr)
Option 2
Wastewater
Pollutant
Loading
(Ib/yr)
Option 1
Pollutant
Reduction
from Baseline
(Ib/yr)
Option 2
Pollutant
Reduction
from Baseline
(Ib/yr)
Bulk Conventional
5-Day Biochemical Oxygen Demand
Total Suspended Solids
NA
NA
2,300,000
760,000
22,000
5,400
6,200
2,100
< 6,200
< 2,100
16,000
3,300
> 16,000
> 3,300
Bulk Nonconventionals
Chemical Oxygen Demand
NA
14,000,000
150,000
77,000
< 77,000
69,000
> 69,000
to
(a) All data are presented with two significant digits. Apparent inconsistencies in sums and differences are due to rounding.
NA - Not applicable.
-------
Section 10.0 - Pollutant Reduction
Table 10-4
Barge/Hopper Subcategory - Direct Dischargers
Summary of Pollutant Loadings and Reductions by Technology Option (a)
Pollutant Name
CAS Number
Untreated
Wastewater
Pollutant
Loading
(Ib/yr)
Baseline
Wastewater
Pollutant
Loading
(Ib/yr)
Option 1
Wastewater
Pollutant
Loading
(Ib/yr)
Option 1
Pollutant Reduction
from Baseline
(Ib/yr)
Bulk Conventional
Total Suspended Solids
NA
28,000
19,000
10,000
8,600
Bulk Nonconventionals
Chemical Oxygen Demand
NA
44,000
8,700
6,000
2,700
Nonconventional Metals
Aluminum
Calcium
Iron
Manganese
Titanium
7429905
7440702
7439896
7439965
7440326
TOTAL Nonconventional Metals
300
5,400
1,800
55
8.6
7,600
210
3,800
1,200
38
6.0
5,200
95
2,100
500
18
1.8
2,700
110
1,700
670
20
4.2
2,500
Priority Metals
Beryllium
Chromium
Zinc
7440417
7440473
7440666
TOTAL Priority Metals
<1
2.5
15
18
<1
1.7
3.4
5.2
<1
1.5
1.8
3.4
<1
<1
1.6
1.8
o
to
(a) All data are presented with two significant digits. Apparent inconsistencies in sums and differences are due to rounding.
NA - Not applicable.
Note: Load reductions include a high bias because some facilities included in the pollutant reduction analysis would be excluded because of low flow. In addition, EPA did not revise the pollutant
loadings to include additional pollutants of interest and the final pollutant removal methodology because these additional pollutant removals would have an insignificant impact on the total load
removals.
-------
Section 10.0 - Pollutant Reduction
Table 10-5
Truck/Chemical & Petroleum Subcategory - Indirect Dischargers
Summary of Pollutant Loadings and Reductions by Technology Option (a)
Pollutant Name
CAS
Number
Untreated
Wastewater
Pollutant
Loading
(Ib/yr)
Baseline
Wastewater
Pollutant
Loading
(Ib/yr)
Option A
Wastewater
Pollutant
Loading
(Ib/yr)
Option 1
Wastewater
Pollutant
Loading
(Ib/yr)
Option 2
Wastewater
Pollutant
Loading
(Ib/yr)
Option A
Pollutant
Reductions
from Baseline
(Ibs/yr)
Option 1
Pollutant
Reduction
from Baseline
(Ib/yr)
Option 2
Pollutant
Reduction
from Baseline
(Ib/yr)
Bulk Conventional
5-Day Biochemical Oxygen
Demand
Oil and Grease (HEM)
Total Suspended Solids
NA
NA
NA
18,000,000
11,000,000
9,800,000
9,900,000
6,400,000
5,300,000
8,200,000
190,000
4,000,000
790,000
170,000
350,000
790,000
170,000
130,000
1,800,000
6,200,000
1,300,000
9,100,000
6,300,000
5,000,000
9,100,000
6,300,000
5,200,000
Bulk Nonconventionals
Chemical Oxygen Demand
Total Dissolved Solids
Total Organic Carbon
Total Petroleum Hydrocarbons
^SGT-HEM)
NA
NA
NA
NA
45,000,000
30,000,000
11,000,000
1,000,000
29,000,000
30,000,000
9,100,000
620,000
28,000,000
30,000,000
8,900,000
63,000
12,000,000
30,000,000
7,600,000
60,000
5,000,000
20,000,000
1,200,000
60,000
1,600,000
73,000
250,000
560,000
17,000,000
73,000
1,500,000
560,000
24,000,000
10,000,000
8,000,000
560,000
Nonconventional Metals
Aluminum
Boron
Calcium
Iron
Magnesium
Manganese
Molybdenum
Phosphorus
Potassium
Silicon
7429905
7440428
7440702
7439896
7439954
7439965
7439987
7723140
7440097
7440213
48,000
25,000
1,900,000
140,000
450,000
4,000
600
430,000
200,000
100,000
27,000
22,000
1,700,000
81,000
270,000
1,900
530
260,000
180,000
62,000
15,000
21,000
1,700,000
41,000
180,000
920
510
210,000
180,000
51,000
2,600
18,000
1,500,000
5,100
58,000
570
450
79,000
160,000
20,000
550
1,500
1,200,000
1,000
56,000
570
450
54,000
160,000
16,000
12,000
66
22,000
40,000
92,000
970
24
52,000
470
11,000
25,000
3,500
240,000
76,000
210,000
1,300
81
180,000
17,000
42,000
27,000
20,000
520,000
80,000
210,000
1,300
81
210,000
17,000
46,000
to
-------
Section 10.0 - Pollutant Reduction
Table 10-5 (Continued)
Pollutant Name
5odium
strontium
5ulfur
Tin
Titanium
CAS
Number
7440235
7440246
7704349
7440315
7440326
TOTAL Nonconventional Metals
Untreated
Wastewater
Pollutant
Loading
(Ib/yr)
6,600,000
15,000
3,000,000
93,000
1,500
13,000,000
Baseline
Wastewater
Pollutant
Loading
(Ib/yr)
6,400,000
13,000
3,000,000
69,000
840
12,000,000
Option A
Wastewater
Pollutant
Loading
(Ib/yr)
6,300,000
12,000
3,000,000
64,000
430
12,000,000
Option 1
Wastewater
Pollutant
Loading
(Ib/yr)
6,100,000
11,000
3,000,000
43,000
91
11,000,000
Option 2
Wastewater
Pollutant
Loading
(Ib/yr)
4,200,000
11,000
2,200,000
6,400
52
7,800,000
Option A
Pollutant
Reductions
from Baseline
(Ibs/yr)
16,000
680
7,300
4,700
410
260,000
Option 1
Pollutant
Reduction
from Baseline
(Ib/yr)
210,000
1,900
7,300
26,000
750
1,000,000
Option 2
Pollutant
Reduction
from Baseline
(Ib/yr)
2,200,000
1,900
850,000
62,000
790
4,200,000
Vonconventional Organics
1,2,3,4,6,7,8-Heptachlorodibenzo-
3-dioxin
1,2,3,4,6,7,8-
Septachlorodibenzofuran
2,4-D
2,4,5-T
2-Methylnaphthalene
2-Isopropylnaphthalene
>,4-DB (Butoxon)
2,4,5-TP
Acetone
Adsorbable Organic Halides
^AOX)
alpha- Terpineol
Azinphos Methyl
3enzoic Acid
3enzyl Alcohol
Dalapon
Diallate
35822469
67562394
94757
93765
91576
2027170
94826
93721
67641
59473040
98555
86500
65850
100516
75990
2303164
<1
<1
22
6.8
550
1,400
50
4.8
220,000
35,000
2,000
33
190,000
2,100
7.1
150
<1
<1
18
3.8
330
790
39
3.2
190,000
21,000
1,400
19
170,000
1,200
7.1
87
<1
<1
18
3.8
160
540
39
3.2
190,000
20,000
1,300
19
170,000
940
7.1
86
<1
<1
15
1.1
55
55
30
1.8
160,000
6,600
770
5.9
150,000
110
7.1
29
<1
<1
15
<1
55
55
14
1.8
40,000
3,000
55
5.9
64,000
84
2.5
13
<1
<1
<1
<1
170
240
<1
<1
590
1,300
33
<1
470
230
<1
<1
<1
<1
3.3
2.7
280
730
9.3
1.4
34,000
15,000
610
14
16,000
1,100
<1
58
<1
<1
3.3
3.1
280
730
25
1.4
150,000
18,000
1,300
14
100,000
1,100
4.6
73
to
oo
-------
Section 10.0 - Pollutant Reduction
Table 10-5 (Continued)
Pollutant Name
Dimethyl Sulfone
3inoseb
^eptophos
m-Xylene
MCPA
Methyl Ethyl Ketone
Vlethyl Isobutyl Ketone
n-Octadecane
n-Triacontane
n-Tetradecane
n-Decane
n-Docosane
n-Dodecane
n-Eicosane
n-Hexacosane
n-Hexadecane
n-Tetracosane
Octachlorodibenzo-p-dioxin
o-Cresol
o+p-Xylene
3-Cresol
3-Cymene
Dentachloronitrobenzene
3tyrene
CAS
Number
67710
88857
21609905
108383
94746
78933
108101
593453
638686
629594
124185
629970
112403
112958
630013
544763
646311
3268879
95487
136777612
106445
99876
82688
100425
Untreated
Wastewater
Pollutant
Loading
(Ib/yr)
58,000
17
45
16,000
4,500
40,000
15,000
3,000
1,700
3,800
2,800
830
8,800
2,300
1,100
5,600
1,400
<1
580
8,000
550
450
60
25,000
Baseline
Wastewater
Pollutant
Loading
(Ib/yr)
31,000
15
29
8,100
2,900
35,000
11,000
1,600
900
2,100
1,400
470
4,400
1,300
620
3,100
780
<1
320
4,200
510
270
30
15,000
Option A
Wastewater
Pollutant
Loading
(Ib/yr)
19,000
15
28
8,000
950
35,000
11,000
1,000
730
940
1,400
310
4,300
910
460
1,400
500
<1
310
4,200
510
260
30
13,000
Option 1
Wastewater
Pollutant
Loading
(Ib/yr)
55
13
11
720
790
30,000
7,400
55
55
55
55
55
55
140
55
55
55
<1
56
450
470
81
<1
4,400
Option 2
Wastewater
Pollutant
Loading
(Ib/yr)
55
13
11
55
570
3,600
1,700
55
55
55
55
55
55
55
55
55
55
<1
55
55
57
55
<1
150
Option A
Pollutant
Reductions
from Baseline
(Ibs/yr)
11,000
<1
<1
48
2,000
100
38
610
170
1,200
8.7
160
28
400
170
1,600
280
<1
1.9
25
1.4
8.9
<1
1,600
Option 1
Pollutant
Reduction
from Baseline
(Ib/yr)
31,000
1.9
18
7,300
2,200
5,000
3,700
1,600
850
2,000
1,300
420
4,300
1,200
570
3,000
720
<1
260
3,700
39
190
30
11,000
Option 2
Pollutant
Reduction
from Baseline
(Ib/yr)
31,000
1.9
18
8,000
2,400
31,000
9,500
1,600
850
2,000
1,300
420
4,300
1,200
570
3,000
720
<1
260
4,100
460
220
30
15,000
to
VO
-------
Section 10.0 - Pollutant Reduction
Table 10-5 (Continued)
Pollutant Name
Total Phenols
CAS
Number
NA
TOTAL Nonconventional Organics
Untreated
Wastewater
Pollutant
Loading
(Ib/yr)
17,000
660,000
Baseline
Wastewater
Pollutant
Loading
(Ib/yr)
13,000
520,000
Option A
Wastewater
Pollutant
Loading
(Ib/yr)
13,000
500,000
Option 1
Wastewater
Pollutant
Loading
(Ib/yr)
8,800
370,000
Option 2
Wastewater
Pollutant
Loading
(Ib/yr)
6,900
120,000
Option A
Pollutant
Reductions
from Baseline
(Ibs/yr)
53
23,000
Option 1
Pollutant
Reduction
from Baseline
(Ib/yr)
4,000
150,000
Option 2
Pollutant
Reduction
from Baseline
(Ib/yr)
6,000
400,000
Other Nonconventionals
Ammonia as Nitrogen
Chloride
'luoride
Nitrate/Nitrite
Total Phosphorus
Surfactants (MBAS)
7664417
16887006
16984488
NA
14265442
NA
TOTAL Other Nonconventionals
800,000
4,500,000
160,000
14,000
200,000
130,000
5,800,000
730,000
4,500,000
120,000
13,000
120,000
89,000
5,600,000
630,000
4,500,000
110,000
13,000
120,000
79,000
5,500,000
630,000
4,500,000
79,000
13,000
46,000
44,000
5,300,000
450,000
3,000,000
43,000
3,700
24,000
5,400
3,600,000
100,000
11,000
14,000
34
4,900
10,000
140,000
100,000
11,000
42,000
570
79,000
45,000
280,000
280,000
1,500,000
78,000
9,400
100,000
84,000
2,100,000
Priority Metals
Cadmium
Chromium
Copper
Mercury
Nickel
Line
7440439
7440473
7440508
7439976
7440020
7440666
TOTAL Priority Metals
140
15,000
1,900
12
1,800
4,500
23,000
98
7,800
1,200
6.6
1,500
2,500
13,000
92
6,800
790
6.5
1,400
1,500
11,000
54
110
420
1.1
1,100
110
1,800
53
74
300
1.1
880
110
1,400
5.5
1,000
420
<1
110
930
2,500
44
7,700
800
5.5
380
2,400
11,000
45
7,700
910
5.5
620
2,400
12,000
Priority Organics
1 ,2-Dichloroethane
1,1,1-Trichloroethane
1 ,2-Dichlorobenzene
2-Chlorophenol
2,4,6-Trichlorophenol
107062
71556
95501
95578
88062
4,300
5,500
780
480
1,500
2,400
3,000
410
280
1,100
2,400
3,000
410
250
980
620
500
55
63
780
66
55
55
55
420
14
18
2.5
29
160
1,800
2,500
360
220
360
2,400
3,000
360
220
730
o
o
-------
Section 10.0 - Pollutant Reduction
Table 10-5 (Continued)
Pollutant Name
Benzene
beta-BHC
Bis (2-ethylhexyl) Phthalate
Chloroform
Di-n-Octyl Phthalate
indosulfan Sulfate
indrin Aldehyde
ithylbenzene
jamma-BHC
Vfethylene Chloride
Sfaphthalene
r'henol
fetrachloroethylene
Toluene
rrichloroethylene
CAS
Number
71432
319857
117817
67663
117840
1031078
7421934
100414
58899
75092
91203
108952
127184
108883
79016
TOTAL Priority Organics
Untreated
Wastewater
Pollutant
Loading
(Ib/yr)
280
3.9
4,000
530
1,300
2.8
35
3,500
1.8
88,000
2,400
12,000
8,800
14,000
160
150,000
Baseline
Wastewater
Pollutant
Loading
(Ib/yr)
170
1.9
2,100
350
690
2.6
35
1,900
1.8
65,000
1,300
11,000
5,200
8,200
110
100,000
Option A
Wastewater
Pollutant
Loading
(Ib/yr)
170
1.9
1,900
330
680
2.6
35
1,800
1.8
58,000
1,000
9,800
130
8,100
110
89,000
Option 1
Wastewater
Pollutant
Loading
(Ib/yr)
58
<1
84
170
55
2.5
35
210
1.8
39,000
110
9,200
55
2,700
57
54,000
Option 2
Wastewater
Pollutant
Loading
(Ib/yr)
55
<1
55
85
55
2.5
35
55
1.0
6,300
55
7,300
55
55
55
15,000
Option A
Pollutant
Reductions
from Baseline
(Ibs/yr)
<1
<1
160
24
4.2
<1
<1
77
<1
6,800
270
800
5,000
46
<1
14,000
Option 1
Pollutant
Reduction
from Baseline
(Ib/yr)
110
1.4
2,000
180
630
<1
<1
1,700
<1
25,000
1,200
1,400
5,100
5,900
56
48,000
Option 2
Pollutant
Reduction
from Baseline
(Ib/yr)
110
1.4
2,000
270
630
<1
<1
1,800
<1
58,000
1,200
3,400
5,100
8,100
58
88,000
(a) All data are presented with two significant digits. Apparent inconsistencies in sums and differences are due to rounding.
NA - Not applicable.
-------
Section 10.0 - Pollutant Reduction
Table 10-6
Rail/Chemical & Petroleum Subcategory - Indirect Dischargers
Summary of Pollutant Loadings and Reductions by Technology Option (a)
Pollutant Name
CAS
Number
Untreated
Wastewater
Pollutant
Loading
(Ib/yr)
Baseline
Wastewater
Pollutant
Loading
(Ib/yr)
Option 1
Wastewater
Pollutant
Loading
(Ib/yr)
Option 2
Wastewater
Pollutant
Loading
(Ib/yr)
Option 3
Wastewater
Pollutant
Loading
(Ib/yr)
Option 1
Pollutant
Reduction
from
Baseline
(Ib/yr)
Option 2
Pollutant
Reduction
from
Baseline
(Ib/yr)
Option 3
Pollutant
Reduction
from
Baseline
(Ib/yr)
Bulk Conventional
Biochemical Oxygen Demand
Oil and Grease (HEM)
Total Suspended Solids
NA
NA
NA
1,300,000
590,000
370,000
990,000
440,000
360,000
970,000
19,000
130,000
800,000
8,200
25,000
700,000
6,600
4,600
23,000
420,000
230,000
190,000
430,000
340,000
290,000
430,000
360,000
Bulk Nonconventionals
Chemical Oxygen Demand
Total Dissolved Solids
Total Organic Carbon
Total Petroleum Hydrocarbons (SGT-HEM)
NA
NA
NA
NA
3,000,000
5,700,000
710,000
130,000
2,700,000
5,600,000
700,000
100,000
1,400,000
4,300,000
530,000
6,800
1,200,000
3,800,000
460,000
2,500
1,200,000
3,200,000
430,000
2,500
1,300,000
1,300,000
170,000
95,000
1,500,000
1,800,000
240,000
100,000
1,500,000
2,400,000
270,000
100,000
Nonconventional Metals
Aluminum
Barium
Boron
Calcium
Iron
Magnesium
Manganese
Phosphorus
Potassium
Silicon
7429905
7440393
7440428
7440702
7439896
7439954
7439965
7723140
7440097
7440213
8,300
540
1,400
30,000
11,000
12,000
510
7,600
680,000
9,000
6,600
320
1,400
29,000
4,000
12,000
490
7,200
670,000
7,300
2,100
240
1,100
24,000
3,600
9,900
330
2,800
550,000
7,100
1,700
92
1,000
24,000
98
9,800
290
920
510,000
6,200
46
92
890
24,000
46
9,800
290
580
480,000
6,200
4,600
76
270
4,900
390
1,800
160
4,400
120,000
140
5,000
220
340
5,100
3,900
1,900
200
6,300
160,000
1,100
6,600
220
460
5,100
4,000
1,900
200
6,600
190,000
1,100
o
to
-------
Section 10.0 - Pollutant Reduction
Table 10-6 (Continued)
Pollutant Name
Sodium
Sulfur
Titanium
CAS
Number
7440235
7704349
7440326
TOTAL Nonconventional Metals
Untreated
Wastewater
Pollutant
Loading
(Ib/yr)
1,200,000
340,000
75
2,300,000
Baseline
Wastewater
Pollutant
Loading
(Ib/yr)
1,200,000
330,000
67
2,200,000
Option 1
Wastewater
Pollutant
Loading
(Ib/yr)
860,000
260,000
17
1,700,000
Option 2
Wastewater
Pollutant
Loading
(Ib/yr)
760,000
230,000
2.3
1,500,000
Option 3
Wastewater
Pollutant
Loading
(Ib/yr)
740,000
210,000
2.3
1,500,000
Option 1
Pollutant
Reduction
from
Baseline
(Ib/yr)
300,000
70,000
50
500,000
Option 2
Pollutant
Reduction
from
Baseline
(Ib/yr)
400,000
94,000
65
680,000
Option 3
Pollutant
Reduction
from
Baseline
(Ib/yr)
420,000
120,000
65
760,000
Nonconventional Organics
1 -Methylphenanthrene
2,4-Diaminotoluene
2,4,5-TP
2,4,5-1
2,4-DB (Butoxon)
Acephate
Acetone
Adsorbable Organic Halides
Benefluralin
Benzoic Acid
Carbazole
Dacthal (DCPA)
Diallate
Dicamba
Dichloroprop
Dimethyl Sulfone
Dinoseb
gamma-Chlordane
832699
95807
93721
93765
94826
30560191
67641
59473040
1861401
65850
86748
1861321
2303164
1918009
38120365
67710
88857
5103742
61
1,100
6.8
6.8
68
460
1,100
920
1.4
1,800
68
<1
200
300
38
40
17
<1
47
1,100
2.8
6.7
31
450
1,000
880
1.3
1,700
56
<1
180
110
35
33
17
<1
4.8
1,100
2.5
2.6
29
400
660
750
<1
1,200
21
<1
58
100
14
12
6.0
<1
4.6
1,000
<1
<1
8.6
380
660
730
<1
1,200
20
<1
23
<1
6.2
11
<1
<1
4.6
46
<1
<1
3.0
21
570
540
<1
37
11
<1
23
<1
1.6
11
<1
<1
43
8.1
<1
4.1
1.9
53
360
140
<1
500
35
<1
120
9.7
22
21
11
<1
43
30
2.5
6.1
22
76
360
160
1.1
500
35
<1
150
110
29
22
16
<1
43
1,000
2.5
6.3
28
430
460
340
1.3
1,600
45
<1
150
110
34
22
16
<1
-------
Section 10.0 - Pollutant Reduction
Table 10-6 (Continued)
Pollutant Name
Hexanoic Acid
m-Xylene
MCPP
Methyl Ethyl Ketone
n-Hexacosane
n-Triacontane
n-Docosane
n-Hexadecane
n-Octadecane
n-Tetradecane
n-Dodecane
n-Tetracosane
n-Eicosane
n-Octacosane
o+p-Xylene
Octachlorodibenzo-p-dioxin
Octachlorodibenzofuran
p-Cresol
Pentachloronitrobenzene
Propachlor
Propazine
Styrene
Terbacil
CAS
Number
142621
108383
7085190
78933
630013
638686
629970
544763
593453
629594
112403
646311
112958
630024
136777612
3268879
39001020
106445
82688
1918167
139402
100425
5902512
Untreated
Wastewater
Pollutant
Loading
(Ib/yr)
1,700
140
20,000
240
96
63
180
1,400
880
1,000
280
160
750
59
95
<1
<1
30
<1
8.7
9.3
110
14
Baseline
Wastewater
Pollutant
Loading
(Ib/yr)
1,200
110
8,900
240
74
50
140
1,000
640
730
220
120
550
46
75
<1
<1
30
<1
6.4
7.2
110
10
Option 1
Wastewater
Pollutant
Loading
(Ib/yr)
1,200
100
7,500
210
5.7
6.1
6.8
7.0
10
10
15
7.3
12
5.5
72
<1
<1
30
<1
<1
2.3
4.7
<1
Option 2
Wastewater
Pollutant
Loading
(Ib/yr)
910
73
1,200
210
5.1
4.8
4.8
4.7
4.6
4.6
4.6
4.8
4.6
4.6
59
<1
<1
30
<1
<1
2.3
4.6
<1
Option 3
Wastewater
Pollutant
Loading
(Ib/yr)
910
4.6
62
26
5.1
4.8
4.8
4.7
4.6
4.6
4.6
4.8
4.6
4.6
4.6
<1
<1
4.6
<1
<1
1.6
4.6
<1
Option 1
Pollutant
Reduction
from
Baseline
(Ib/yr)
29
5.5
1,400
23
68
44
130
1,000
630
720
200
110
540
41
2.6
<1
<1
<1
<1
6.0
5.0
100
9.5
Option 2
Pollutant
Reduction
from
Baseline
(Ib/yr)
280
33
7,700
23
69
45
130
1,000
630
730
210
110
540
42
16
<1
<1
<1
<1
6.0
5.0
100
9.5
Option 3
Pollutant
Reduction
from
Baseline
(Ib/yr)
280
100
8,900
210
69
45
130
1,000
630
730
210
110
540
42
70
<1
<1
26
<1
6.0
5.7
100
9.5
-------
Section 10.0 - Pollutant Reduction
Table 10-6 (Continued)
Pollutant Name
Terbuthylazine
Total Phenols
CAS
Number
5915413
NA
TOTAL Nonconventional Organics
Untreated
Wastewater
Pollutant
Loading
(Ib/yr)
1,400
430
35,000
Baseline
Wastewater
Pollutant
Loading
(Ib/yr)
1,200
400
22,000
Option 1
Wastewater
Pollutant
Loading
(Ib/yr)
1,100
250
15,000
Option 2
Wastewater
Pollutant
Loading
(Ib/yr)
1,000
210
7,900
Option 3
Wastewater
Pollutant
Loading
(Ib/yr)
2.3
42
2,400
Option 1
Pollutant
Reduction
from
Baseline
(Ib/yr)
18
150
6,600
Option 2
Pollutant
Reduction
from
Baseline
(Ib/yr)
150
190
14,000
Option 3
Pollutant
Reduction
from
Baseline
(Ib/yr)
1,200
360
19,000
Other Nonconventionals
Ammonia as Nitrogen
Chloride
Fluoride
Nitrate/Nitrite
Total Phosphorus
Surfactants (MBAS)
7664417
16887006
16984488
NA
142654462
NA
TOTAL Other Nonconventionals
19,000
880,000
1,700
4,100
7,400
2,100
910,000
19,000
870,000
1,400
3,800
6,800
1,300
900,000
19,000
680,000
1,400
3,000
2,400
1,200
710,000
19,000
610,000
1,100
3,000
900
680
630,000
16,000
610,000
340
1,600
350
330
620,000
110
180,000
44
750
4,400
110
190,000
110
260,000
260
750
5,900
670
270,000
2,800
260,000
1,100
2,100
6,500
1,000
270,000
Priority Metals
Arsenic
Chromium
Copper
Zinc
7440382
7440473
7440508
7440666
TOTAL Priority Metals
34
83
79
330
530
32
83
45
310
470
21
37
35
88
180
19
4.6
12
9.2
44
13
4.6
12
9.2
38
10
46
10
220
290
13
78
34
300
420
19
78
34
300
420
Priority Organics
alpha-BHC
Anthracene
beta-BHC
delta-BHC
Dieldrin
319846
120127
319857
319868
60571
<1
80
18
<1
1.1
<1
62
13
<1
<1
<1
8.8
<1
<1
<1
<1
4.7
<1
<1
<1
<1
4.7
<1
<1
<1
<1
53
13
<1
<1
<1
57
13
<1
<1
<1
57
13
<1
<1
-------
Section 10.0 - Pollutant Reduction
Table 10-6 (Continued)
Pollutant Name
Endosulfan Sulfate
Ethylbenzene
Fluoranthene
Naphthalene
Phenanthrene
Phenol
Pyrene
CAS
Number
1031078
100414
206440
91203
85018
108952
129000
TOTAL Priority Organics
Untreated
Wastewater
Pollutant
Loading
(Ib/yr)
<1
64
74
55
160
310
58
830
Baseline
Wastewater
Pollutant
Loading
(Ib/yr)
<1
47
57
50
120
310
45
710
Option 1
Wastewater
Pollutant
Loading
(Ib/yr)
<1
46
5.7
20
9.0
230
5.5
330
Option 2
Wastewater
Pollutant
Loading
(Ib/yr)
<1
35
4.9
11
5.3
190
4.9
260
Option 3
Wastewater
Pollutant
Loading
(Ib/yr)
<1
4.6
4.9
5.0
4.9
4.6
4.9
34
Option 1
Pollutant
Reduction
from
Baseline
(Ib/yr)
<1
1.7
51
30
110
76
39
380
Option 2
Pollutant
Reduction
from
Baseline
(Ib/yr)
<1
12
52
39
120
110
40
440
Option 3
Pollutant
Reduction
from
Baseline
(Ib/yr)
<1
43
52
45
120
300
40
670
(a) All data are presented with two significant digits. Apparent inconsistencies in sums and differences are due to rounding.
NA - Not applicable.
-------
Section 10.0 - Pollutant Reduction
Table 10-7
Food Subcategory - Indirect Dischargers
Summary of Pollutant Loadings and Reductions by Technology Option (a)
Pollutant Name
CAS
Number
Untreated
Wastewater
Pollutant
Loading
(Ib/yr)
Baseline
Wastewater
Pollutant
Loading
(Ib/yr)
Option 1
Wastewater
Pollutant
Loading
(Ib/yr)
Option 2
Wastewater
Pollutant
Loading
(Ib/yr)
Option 1
Pollutant
Reduction
from Baseline
(Ib/yr)
Option 2
Pollutant
Reduction
from Baseline
(Ib/yr)
Bulk Conventional
5-Day Biochemical Oxygen Demand
Oil and Grease (HEM)
Total Suspended Solids
NA
NA
NA
22,000,000,000
2,200,000,000
4,900,000,000
22,000,000,000
68,000,000
4,900,000,000
22,000,000,000
360,000
4,900,000,000
29,000
11,000
81,000
3,000,000
67,000,000
670,000
22,000,000,000
68,000,000
4,900,000,000
Bulk Nonconventionals
Chemical Oxygen Demand
Total Dissolved Solids
Total Organic Carbon
Total Petroleum Hydrocarbons
(SGT-HEM)
NA
NA
NA
NA
110,000,000,000
78,000,000,000
41,000,000,000
140,000,000
110,000,000,000
78,000,000,000
41,000,000,000
140,000,000
110,000,000,000
78,000,000,000
41,000,000,000
140,000,000
95,000
740,000
110,000
11,000
15,000,000
11,000,000
5,600,000
19,000
110,000,000,000
78,000,000,000
41,000,000,000
140,000,000
Nonconventional Organics
Benzoic Acid
Hexanoic Acid
65850
142621
TOTAL Nonconventional Organics
5,900,000
140,000,000
140,000,000
5,900,000
140,000,000
140,000,000
5,900,000
140,000,000
140,000,000
110
51
160
52
1,200
1,200
5,900,000
140,000,000
140,000,000
Other Nonconventionals
Ammonia as Nitrogen
7664417
7,900,000
7,800,000
7,800,000
580
1,100
7,800,000
Priority Organics
Phenol
108952
600,000
600,000
600,000
22
5.4
600,000
(a) All data are presented with two significant digits. Apparent inconsistencies in sums and differences are due to rounding.
NA - Not applicable.
Note: EPA did not revise the pollutant loadings to include additional pollutants of interest and the final pollutant removal methodology because these additional pollutant removals would have an
insignificant impact on the total load removals.
-------
Section 10.0 - Pollutant Reduction
Table 10-8
Truck/Hopper Subcategory - Indirect Dischargers
Summary of Pollutant Loadings and Reductions by Technology Option (a)
Pollutant Name
CAS
Number
Untreated
Wastewater
Pollutant
Loading
(Ib/yr)
Baseline
Wastewater
Pollutant
Loading
(Ib/yr)
Option 1
Wastewater
Pollutant
Loading
(Ib/yr)
Option 1
Pollutant
Reduction
from Baseline
(Ib/yr)
Bulk Conventional
Total Suspended Solids
NA
17,000
15,000
8,200
6,700
Bulk Nonconventionals
Chemical Oxygen Demand
NA
7,600
6,800
4,800
2,000
Nonconventional Metals
Aluminum
Calcium
Iron
Manganese
Titanium
7429905
7440702
7439896
7439965
7440326
TOTAL Nonconventional Metals
180
3,300
1,000
34
5.4
4,600
160
3,000
920
30
4.8
4,100
76
1,700
400
15
1.5
2,200
88
1,300
520
16
3.3
2,000
Priority Metals
Beryllium
Chromium
Zinc
7440417
7440473
7440666
TOTAL Priority Metals
<1
1.5
3.0
4.5
<1
1.3
2.7
4.1
<1
1.2
1.5
2.7
<1
<1
1.2
1.4
o
oo
(a) All data are presented with two significant digits. Apparent inconsistencies in sums and differences are due to rounding.
NA - Not applicable.
Note: Load reductions include a high bias because some facilities included in the pollutant reduction analysis would be excluded because of low flow. In addition, EPA did not revise the pollutant
loadings to include additional pollutants of interest and the final pollutant removal methodology because these additional pollutant removals would have an insignificant impact on the total load
removals.
-------
Section 10.0 - Pollutant Reduction
Table 10-9
Rail/Hopper Subcategory - Indirect Dischargers
Summary of Pollutant Loadings and Reductions by Technology Option (a)
Pollutant Name
CAS
Number
Untreated
Wastewater
Pollutant
Loading
(Ib/yr)
Baseline
Wastewater
Pollutant
Loading
(Ib/yr)
Option 1
Wastewater
Pollutant
Loading
(Ib/yr)
Option 1
Pollutant
Reduction
from Baseline
(Ib/yr)
Bulk Conventional
Total Suspended Solids
NA
890
160
160
0
Bulk Nonconventionals
Chemical Oxygen Demand
NA
5,100
96
96
0
Nonconventional Metals
Aluminum
Calcium
Iron
Manganese
Titanium
7429905
7440702
7439896
7439965
7440326
TOTAL Nonconventional Metals
17
100
36
1.5
<1
160
1.5
33
8.0
<1
<1
43
1.5
33
8.0
<1
<1
43
0
0
0
0
0
0
Priority Metals
Beryllium
Chromium
Zinc
7440417
7440473
7440666
TOTAL Priority Metals
<1
<1
<1
1
<1
<1
<1
<1
<1
<1
<1
<1
0
0
0
0
o
VO
(a) All data are presented with two significant digits. Apparent inconsistencies in sums and differences are due to rounding.
NA - Not applicable.
Note: Load reductions include a high bias because some facilities included in the pollutant reduction analysis would be excluded because of low flow. In addition, EPA did not revise the pollutant
loadings to include additional pollutants of interest and the final pollutant removal methodology because these additional pollutant removals would have an insignificant impact on the total load
removals.
-------
Section 10.0 - Pollutant Reduction
Table 10-10
Barge/Hopper Subcategory - Indirect Dischargers
Summary of Pollutant Loadings and Reductions by Technology Option (a)
Pollutant Name
CAS
Number
Untreated
Wastewater
Pollutant
Loading
(Ib/yr)
Baseline
Wastewater
Pollutant
Loading
(Ib/yr)
Option 1
Wastewater
Pollutant
Loading
(Ib/yr)
Option 1
Pollutant
Reduction
from Baseline
(Ib/yr)
Bulk Conventional
Total Suspended Solids
NA
8,500
5,500
4,500
940
Bulk Nonconventionals
Chemical Oxygen Demand
NA
3,900
3,200
2,700
550
Nonconventional Metals
Aluminum
Calcium
Iron
Manganese
Titanium
7429905
7440702
7439896
7439965
7440326
TOTAL Nonconventional Metals
94
1,700
530
17
2.7
2,400
51
1,100
270
9.7
<1
1,400
42
920
220
8.1
<1
1,200
8.7
190
46
1.7
<1
250
Priority Metals
Beryllium
Chromium
Zinc
7440417
7440473
7440666
TOTAL Priority Metals
<1
<1
1.5
2
<1
<1
<1
2
<1
<1
<1
1
<1
<1
<1
<1
o
o
(a) All data are presented with two significant digits. Apparent inconsistencies in sums and differences are due to rounding.
NA - Not applicable.
Note: EPA did not revise the pollutant loadings to include additional pollutants of interest and the final pollutant removal methodology because these additional pollutant removals would have an
insignificant impact on the total load removals.
-------
Section 10.0 - Pollutant Reduction
Table 10-11
BPT Pollutant Loading Reductions
Subcategory
Truck/Chemical &
Petroleum
Rail/Chemical &
Petroleum
Barge/Chemical &
Petroleum
Food
Barge/Hopper (c)
Option
1
2
1
2
3
1
2
1
2
1
BOD5 Loading
Reduction
(pounds/year)
8.6
8.6
0
0
7.5
16,000
NC
0(b)
0(b)
NR
TSS Loading
Reduction
(pounds/year)
32
32
0
0
62
3,300
NC
0(b)
0(b)
8,600
Oil and Grease
(HEM) Loading
Reduction
(pounds/year)
6.5
6.5
0
22
22
NA
NC
0(b)
0(b)
NR
Priority
Pollutant
Loading
Reduction
(pounds/year)
2.3
2.3
0
2.2
2.3
NA
NC
0(b)
0(b)
1.8
Nonconventional
Pollutant Loading
Reduction
(pounds/year) (a)
81
81
0
5,000
5,600
NA
NC
0(b)
0(b)
2,500
(a) The loading reductions presented exclude reduction of COD, IDS, TOC, and SGT-HEM.
(b) Pollutant reductions determined to be zero because all facilities identified by EPA currently meet the regulatory option.
(c) Load reductions include a high bias because some facilities included in the pollutant reduction analysis would be excluded because of low
flow.
BOD5 - Biochemical oxygen demand (five-day).
TSS - Total suspended solids.
HEM - Hexane extractable material.
NR - Pollutant loading reductions not calculated because pollutant is not removed by this regulatory option.
NC - Not calculated because the regulatory option was not fully evaluated by EPA following the proposed rule.
NA - Not available because EPA did not have sufficient data to fully evaluate these pollutant removals.
10-41
-------
Section 10.0 - Pollutant Reduction
Table 10-12
PSES Pollutant Loading Reductions
Subcategory
Truck/Chemical & Petroleum
Rail/Chemical & Petroleum
Barge/Chemical & Petroleum
Food
Truck/Hopper (b)
Barge/Hopper (b)
Option
A
1
2
1
2
3
1
2
3
1
2
1
1
Priority Pollutant Loading
Reduction (pounds/year)
16,000
60,000
99,000
670
870
1,100
0
0
NC
5.5
600,000
1.4
<1
Nonconventional Pollutant Loading
Reduction (pounds/year) (a)
420,000
1,500,000
6,700,000
700,000
960,000
1,100,000
0
0
NC
2,300
150,000,000
2,200
250
(a) The loading reductions presented exclude reduction of COD, IDS, TOC, and SGT-HEM.
(b) Load reduction include a high bias because some facilities included in the pollutant reduction analysis would be excluded because of low
flow.
NC - Not calculated because the regulatory option was not fully evaluated by EPA following the proposed rule.
10-42
-------
Section 11.0 - Non-Water Quality Impacts
11.0 NON-WATER QUALITY ENVIRONMENTAL 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) final
regulatory options on energy consumption, air pollution, and solid waste generation. Sections
11.1 through 11.3 discuss these impacts and Section 11.4 lists references for this section.
Reference 1 summarizes the results of these analyses. In addition to these non-water quality
environmental impacts, EPA considered the impacts of the final rule on noise pollution and water
and chemical use and determined these impacts to be negligible.
EPA did not directly evaluate non-water quality environmental impacts of the
pollution prevention alternative. However, considering pollution prevention and source reduction
techniques in the alternative, EPA believes that the non-water quality environmental impacts will
be less than estimated from the technology options.
11.1 Energy Impacts
Energy impacts resulting from the 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 all regulatory options for most
subcategories) 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.
11-1
-------
Section 11.0 - Non-Water Quality Impacts
Based on EPA's regulatory options (see Section 8.0), the Agency estimates a net
increase in electricity use for the TECI as a result of the final rule would be approximately 5
million kilowatt hours per year. In 1990, the total U.S. industrial electrical energy purchase was
approximately 756 billion kilowatt hours (2). EPA's technology options would increase U.S.
industrial electrical energy purchase by 0.0007 percent. Therefore, the Agency concludes that the
effluent pollutant reduction benefits from the technology options exceed the potential adverse
effects from the estimated increase in energy consumption.
11.2 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.
In order to quantify the impact of the regulation on air emissions at proposal, EPA
performed a WATERS (3) model analysis to determine the quantity of air emissions that would
result from the treatment technology options. Reference 4 describes EPA's model analysis in
detail. EPA estimated that the maximum increase in air emissions would be 153,000 kilograms
per year of organic pollutants (volatile and semivolatile organics), which represented
approximately 35 percent of the total organic pollutant wastewater load of raw TEC wastewater.
11-2
-------
Section 11.0 - Non-Water Quality Impacts
Since the final technology options are fairly similar to the proposed technology options, EPA
estimates that these estimates would not change significantly.
EPA's estimate of air emissions reflects the increase in emissions at TEC facilities,
and does not account for baseline air emissions that are currently being released to the atmosphere
at the POTW or as the wastewater is conveyed to the POTW. It is expected that much of the
increased emissions at indirect TEC facilities calculated for this rule are currently being released at
POTWs or during conveyance to the POTW. To a large degree, this rule will merely shift the
location at which the air emissions are released, rather than increasing the total air emissions from
TEC wastewater. As a result, air emission from TEC wastewater at POTWs are expected to be
reduced somewhat following implementation of this rule. EPA's model analysis was performed
based on the most stringent regulatory options considered for each subcategory in order to create
a "worst case scenario" (i.e., the more treatment technologies used, the more chance of
volatilization of compounds to the air). For some subcategories, air emission impacts are
overestimated (see Section 12.0).
In addition, to the extent that facilities currently operate treatment in place, the
results overestimate air emission impacts from the regulatory options. Additional details
concerning EPA's model analysis to estimate air emission impacts are included in "Estimated Air
Emission Impacts of TEC Industry Regulatory Options" in the rulemaking record.
Based on the sources of air emissions in the TEC industry and limited data
concerning air pollutant emissions from TEC operations provided in response to the 1994
Detailed Questionnaire (most facilities did not provide air pollutant emissions estimates), EPA
estimates that the incremental air emissions resulting from the regulatory options are a small
percentage of air emissions generated by TEC operations.
11-3
-------
Section 11.0 - Non-Water Quality Impacts
11.3 Solid Waste Impacts
Solid waste impacts resulting from the regulatory options include additional solid
wastes generated by wastewater treatment technologies. These solid wastes consist of
wastewater treatment residuals, including sludge, and waste oil. These impacts are discussed
below in Sections 11.3.1 through 11.3.2 respectively.
EPA also analyzed options containing activated carbon adsorption and organo
clay. EPA did not select any options containing these technologies, with the exception of BPT
Option 2 for the Truck/Chemical & Petroleum Subcategory (see Section 12.1.1). EPA does not
expect any incremental solid waste impacts from selecting this option because all known facilities
in this subcategory currently operate activated carbon adsorption.
11.3.1 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, 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.
11-4
-------
Section 11.0 - Non-Water Quality Impacts
EPA estimates that the rule will result in a decrease in wet sludge generation of
approximately 17 million gallons per year, which represents an estimated 98 percent decrease
from current wet sludge generation. In addition, EPA estimates that the rule will result in an
increase in dewatered sludge generation of approximately 35 thousand cubic yards per year,
which represents an estimated 120 percent increase from current dewatered sludge generation.
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.
The Agency concludes that the effluent benefits and the reductions in wet sludge
from the technology options exceed the potential adverse effects from the estimated increase in
wastewater treatment sludge generation.
11.3.2 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. EPA estimates that this increase in waste oil generation will be approximately
667,000 gallons per year, which represents no more than an estimated 330 percent increase from
current waste oil generation. 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.
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Section 11.0 - Non-Water Quality Impacts
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 increased waste oil generation.
11.4 References1
Eastern Research Group, Inc. Summary of the Results of Non-Water Quality
Impacts Analyses. April 2000 (DCN T20537).
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).
'For those references included in the administrative record supporting the TECI rulemaking, the document control
number (DCN) is included in parentheses at the end of the reference.
11-6
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Section 12.0 - Option Selection and Regulated Pollutants
12.0 OPTION SELECTION AND REGULATED POLLUTANTS
After EPA established technology options for each subcategory (see Section 8.0),
EPA estimated the cost of compliance for each option (see Section 9.0); the priority,
conventional, and non-conventional pollutant removals associated with each option (see Section
10.0); and the non-water quality environmental impacts associated with each option (see Section
11.0). EPA used the results of these analyses along with other factors identified in the Clean
Water Act to select the technology bases from which to base the final effluent limitations
guidelines and standards. This section discusses the factors considered and EPA's rationale in
selecting technology options for BPT, BAT, BCT, NSPS, PSES, and PSNS. Owners or
operators of facilities subject to these regulations are not required to use the specific pollution
prevention and wastewater treatment technologies selected by EPA to establish effluent
limitations. Rather, a facility can choose to use any combination of pollution prevention and
wastewater treatment to comply with the limitations provided they are not achieved through
dilution.
All supporting economic and financial analyses can be found in the Final Economic
Analysis of Effluent Limitations Guidelines and Standards for the Transportation Equipment
Cleaning Category (1). Cost-effectiveness analyses can be found in the Final Cost-Effectiveness
Analysis of Effluent Limitations Guidelines and Standards for the Transportation Equipment
Cleaning Category (2).
EPA selected pollutants to regulate from the list of pollutants of interest that are
removed by each selected regulatory option (see Section 6.6). EPA also considered publicly-
owned treatment works (POTW) pass through when selecting regulated pollutants for indirect
dischargers. The following topics are discussed in this section:
• Section 12.1: Option Selection for Direct Dischargers;
• Section 12.2: Option Selection for Indirect Dischargers;
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Section 12.0 - Option Selection and Regulated Pollutants
• Section 12.3: Rationale for Selecting Regulated Pollutants;
• Section 12.4: Regulated Pollutants for Direct Dischargers;
• Section 12.5: Regulated Pollutants for Indirect Dischargers (Including the
POTW Pass-Through Analysis); and
• Section 12.6: References.
12.1 Option Selection for Direct Dischargers
EPA analyzed BPT, BCT, BAT, and NSPS options for all subcategories. EPA's
option selection rationale is provided in the following subsections. Note that all costs are
presented in 1998 dollars.
12.1.1 Truck/Chemical & Petroleum
EPA evaluated two options for the Truck/Chemical & Petroleum Subcategory as
discussed in Section 8.2.1. EPA established BPT limits for the Truck/Chemical & Petroleum
Subcategory based on Option 2. EPA's decision to base BPT limitations on Option 2 treatment
primarily reflects on two factors: 1) the degree of effluent reductions attainable, and 2) the total
cost of the treatment technologies in relation to the effluent reductions achieved.
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 the removal of residual
organics represents the average of the best treatment in the industry. EPA also selected Option 2
because all of the model facilities have equalization, coagulation/clarification, biological treatment,
and activated carbon adsorption in place. Two of the three model facilities in the cost model have
sufficient treatment in place; therefore, compliance costs for these facilities include only additional
monitoring. The third facility was costed for flow reduction, sludge dewatering, and monitoring,
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Section 12.0 - Option Selection and Regulated Pollutants
which results in a net cost savings for the facility's entire treatment train. These net cost savings
for the third facility are greater than the monitoring costs incurred by the other two facilities.
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.
EPA determined that Option 2 is economically achievable because it will result in a
net cost savings to the industry, and will not cause any facility closures, revenue impacts, or
employment impacts. Therefore, EPA based BAT on Option 2.
EPA did not identify any technologies beyond BPT/BAT that can achieve greater
removals of conventional or toxic pollutants. Therefore, EPA established BCT and NSPS
equivalent to BPT and BAT.
12.1.2 Rail/Chemical & Petroleum
EPA evaluated three options for the Rail/Chemical & Petroleum Subcategory as
discussed in Section 8.2.2. EPA established BPT limits for the Rail/Chemical & Petroleum
Subcategory based on Option 2. EPA's decision to base BPT limitations on Option 2 treatment
primarily reflects on two factors: 1) the degree of effluent reductions attainable, and 2) the total
cost of the treatment technologies in relation to the effluent reductions achieved.
EPA evaluated the costs, loads, and impacts of the one model direct discharging
facility which currently operates oil/water separation, equalization, pH adjustment, biological
treatment, and a filter press. EPA estimates that the cost of implementing Option 1 is for
monitoring costs only (i.e., zero capital costs), totaling approximately $4,900 annually post-tax
($7,600 pre-tax). Option 2 costs $40,800 annualized post-tax ($59,000 pre-tax), and Option 3
costs $60,600 annualized post-tax ($89,000 pre-tax).
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Section 12.0 - Option Selection and Regulated Pollutants
EPA did not have sampling data for direct dischargers in this subcategory. EPA
has therefore relied on treatment data transferred from the Barge/Chemical & Petroleum
Subcategory to establish limits for conventionals (see Section 12.4.2), and treatment data from
indirect dischargers in the Rail/Chemical & Petroleum Subcategory to establish limits for toxic
pollutants (see Section 12.4.2). Furthermore, all toxic parameters considered for regulation were
treated to the same level at Options 1, 2, and 3. Although EPA believes that the treatment in
place at the one rail direct discharging facility identified by EPA is sufficient to meet the final
limitations (see Section 2.0), EPA has decided to establish BPT based on Option 2, which
includes dissolved air flotation (DAF). EPA believes that this is the most appropriate technology
because the data set used to transfer limits (from both the rail indirect discharging facilities and
the barge direct discharging facilities) includes DAF treatment.
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.
EPA determined that Option 2 is economically achievable because it will not cause
the facility to close or any revenue or employment impacts. Therefore, EPA based BAT on
Option 2.
EPA evaluated Option 3 as a BCT candidate technology to determine whether it
was cost-reasonable according to the BCT Cost Test. The option did not pass the BCT Cost
Test; therefore, EPA established BCT equivalent to BPT.
Due to the incremental economic impacts projected at Option 3 (see reference 1
for additional information), EPA believes that Option 3 may create a barrier to entry for new
sources. In addition, few additional pollutant removals are achieved by Option 3. Therefore,
EPA decided to establish NSPS equivalent to BPT, BAT, and BCT.
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Section 12.0 - Option Selection and Regulated Pollutants
12.1.3 Barge/Chemical & Petroleum
EPA evaluated two options for the Barge/Chemical & Petroleum Subcategory as
discussed in Section 8.2.3. EPA established BPT limits for the Barge/Chemical & Petroleum
Subcategory based on Option 1. EPA's decision to base BPT limitations on Option 1 treatment
primarily reflects on two factors: 1) the degree of effluent reductions attainable, and 2) the total
cost of the treatment technologies in relation to the effluent reductions achieved.
EPA estimates that the annualized costs for Option 1 are $89,500 ($146,300 pre-
tax) and Option 2 are $345,700 ($540,900 pre-tax). EPA estimates that both Option 1 and
Option 2 remove 19,300 pounds of BOD and TSS. Based on the treatment technologies in place
at the model facilities, coupled with the biological treatment system upgrades estimated by EPA
to achieve Option 1 performance levels (see Section 9.2.9), EPA predicts that Option 2 would not
result in any additional removal of toxic pounds because most pollutants are already treated to
very low levels, often approaching or below non-detect levels.
Additionally, the Agency concluded that reverse osmosis is not commonly used in
the industry. Therefore, Option 2 does not represent the average of the best treatment.
No basis could be found for identifying 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 TEC wastewaters.
EPA also analyzed the costs of all options to determine the economic impact that
this regulation would have on the TECI. EPA's assessment showed that implementation of
Option 1 is projected to result in no facility closures and no employment losses (see reference 1
for additional information). Therefore, EPA based BAT on Option 1.
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Section 12.0 - Option Selection and Regulated Pollutants
EPA evaluated Option 2 as a BCT candidate technology to determine whether it
was cost-reasonable according to the BCT Cost Test. The option did not pass the BCT Cost
Test; therefore, EPA established BCT equivalent to BPT.
EPA also established NSPS equivalent to BPT, BAT, and BCT because few
additional pollutant removals are achieved by Option 2.
12.1.4 Food
EPA evaluated two options for the Food Subcategory as discussed in Section
8.2.4. EPA established BPT limitations for the Food Subcategory based on Option 2. EPA's
decision to base BPT limitations on Option 2 treatment primarily reflects on two factors: 1) the
degree of effluent reductions attainable, and 2) the total cost of the treatment technologies in
relation to the effluent reductions achieved.
The wastewater generated by the Food Subcategory contains high loadings of
biodegradable organics and few toxic pollutants. Based on the data collected by EPA, raw
wastewater contained significant levels of organic material, 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. All
existing facilities that responded to the Screener Questionnaire indicated that they have a
biological treatment system in place. Accordingly, EPA considers Option 2 to represent the
average of the best treatment and based BPT on Option 2.
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 selected technology in place.
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Section 12.0 - Option Selection and Regulated Pollutants
EPA did not establish BAT for the Food Subcategory because EPA found that
food grade facilities discharge very few pounds of toxic pollutants not amenable to treatment by a
biological treatment system.
EPA did not identify any technologies beyond BPT that can achieve greater
removals of conventional pollutants. Therefore, EPA established BCT equivalent to BPT.
Finally, for the same reasons EPA established BCT equivalent to BPT, and did not
establish BAT for this subcategory, EPA established NSPS equivalent to BPT.
12.1.5 Truck/Hopper and Rail/Hopper
EPA was not able to identify any direct discharging facilities in the Truck/Hopper
and Rail/Hopper subcategories; therefore, EPA has not established effluent limitations for direct
dischargers for these subcategories. Permit writers can more appropriately control discharges
from these facilities, if any, using best professional judgement.
12.1.6 Barge/Hopper
EPA evaluated one option for the Barge/Hopper Subcategory as discussed in
Section 8.2.5. EPA did not establish BPT, BCT, BAT, or NSPS regulations for this subcategory
because hopper facilities discharge very few pounds of conventional or toxic pollutants. EPA
sampling data showed that very little wastewater is generated from cleaning the interiors of
hopper tanks due to the dry nature of bulk materials transported. Therefore, EPA determined that
nationally applicable regulations are unnecessary for this subcategory. Direct dischargers will
remain subject to limitations established by permit writers on a case-by-case basis using best
professional judgement.
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Section 12.0 - Option Selection and Regulated Pollutants
12.2 Indirect Discharging Options
EPA analyzed PSES and PSNS options for all subcategories. EPA's option
selection rationale is provided in the following subsections. Note that all costs are presented in
1998 dollars.
12.2.1 Truck/Chemical & Petroleum
EPA evaluated three options for the Truck/Chemical & Petroleum Subcategory as
discussed in Section 8.6.1. EPA also considered a pollution prevention approach as a compliance
option as discussed in Section 8.6.6. EPA established PSES for the Truck/Chemical & Petroleum
Subcategory based on a pollution prevention compliance option as well as a traditional
compliance option (i.e., a set of numeric pretreatment standards) based on Option 1. EPA
believes that pollution prevention and effective pollutant management is an appropriate and
effective way of reducing pollutant discharges from this Subcategory. Further, the Agency
believes that providing a pollution prevention compliance option may be less costly than the
technology options considered for regulation. Therefore, EPA provided both a pollution
prevention option based on development and implementation of a Pollutant Management Plan
(PMP) and a set of numeric limits allowing facility owners and operators to choose the less
expensive compliance alternative. For the portion of the industry that already has extensive
treatment in place, it may be more cost effective to comply with the numeric limits. Conversely,
for those facilities already utilizing good pollution prevention practices and/or operating in
accordance with a PMP, it may be more cost effective to use the pollution prevention compliance
alternative.
For establishing numeric pretreatment standards, EPA's decision to base PSES
limitations on Option 1 treatment primarily reflects on three factors: 1) the degree of effluent
reductions attainable, 2) the total cost of the treatment technologies in relation to the effluent
reductions achieved, and 3) economic impacts.
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Section 12.0 - Option Selection and Regulated Pollutants
Option A would have a post-tax annualized cost of $5.2 million ($8.1 million pre-
tax) for 286 facilities. Option 1 would cost $9.2 million ($14.4 million pre-tax) and Option 2
would cost $20.9 million ($32.9 million pre-tax) annualized. Option A is projected to remove
1,500 toxic pound-equivalents, while Option 1 removes 11,700 and Option 2 removes 20,900
toxic pound-equivalents. EPA predicts that, if selected, Option 2 would not result in any
significant additional benefits incremental to Option 1 because the additional toxic pound-
equivalents removed by Option 2 are mainly due to pollutants that would not be selected for
regulation (see Section 12.5).
These toxic pound-equivalents estimates do not include any credit for reductions
of a number of pesticides, herbicides, or other toxic agents that may be present in TEC
wastewater at some facilities but that were not found at the time of EPA's sampling. According
to the detailed questionnaire responses, EPA found that over 3,000 types of cargos are cleaned at
tank truck facilities. However, absent better estimates, EPA based its analysis on those toxic
substances that were confirmed present by its sampling protocols.
EPA projects that there will be no adverse economic impacts for any option when
a positive cost pass through assumption is made. However, EPA has also looked at the
assumption of no cost pass through, which indicated that 14 facilities may experience financial
stress at Option 1, and that 22 facilities may experience financial stress at Option 2. At Option 1,
none of the 14 facilities experiencing financial stress are small businesses; at Option 2, 7 of the 22
facilities are small businesses (see reference 1 for additional information).
EPA does not believe that the lower cost of Option A demonstrated significant
removals of toxics to justify its selection as a regulatory option. Option A was considerably less
cost effective than Option 1 (see reference 2 for additional information). Additionally, EPA
agrees with a pretreatment authority that accepts TEC wastewater who has argued that oil/water
separation alone is not effective for achieving concentration standards for the pollutants that may
be discharged by tank cleaning operations. The pretreatment authority also indicated its support
for effective pollution prevention practices as an alternative to numeric limits for these facilities.
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Section 12.0 - Option Selection and Regulated Pollutants
EPA believes that a dual approach, which offers facilities a choice between
pollution prevention and compliance with numeric limits based on Option 1, is economically
achievable and will significantly reduce pollutant loadings. EPA has also made a finding of no
barrier to entry associated with Option 1 level of control for new sources; therefore, EPA
established PSES and PSNS based on a dual approach involving a pollution prevention
compliance option and traditional limits based on Option 1 technologies.
12.2.2 Rail/Chemical & Petroleum
EPA evaluated three options for the Rail/Chemical & Petroleum Subcategory as
discussed in Section 8.6.2. EPA also considered a pollution prevention approach as a compliance
option as discussed in Section 8.6.6. EPA established PSES for the Rail/Chemical & Petroleum
Subcategory based a pollution prevention compliance option as well as a traditional compliance
option based on Option 2. EPA has determined that a Pollutant Management Plan is an
appropriate compliance alternative to the numerical pretreatment standards for the Rail/Chemical
and Petroleum Subcategory. EPA believes this Pollutant Management Plan alternative is
consistent with the CWA and the Pollution Prevention Act of 1990; it is comparable to the
numerical standards in terms of pollutant removal and costs incurred by facilities; is economically
achievable; and will allow an appropriate level of flexibility to facility owners and operators on
how to best achieve a reduction in pollutants being discharged to the POTW. For establishing
numeric pretreatment standards, EPA's decision to base PSES limitations on Option 2 treatment
primarily reflects on three factors: 1) the degree of effluent reductions attainable, 2) the total cost
of the treatment technologies in relation to the effluent reductions achieved, and 3) economic
impacts.
EPA estimates that Option 1 would have an annualized cost of $0.60 million
($0.90 million pre-tax), Option 2 would cost $1.0 million ($1.5 million pre-tax), and Option 3
would cost $1.6 million ($2.5 million pre-tax). EPA also considered the cost effectiveness to
evaluate the relative efficiency of each option in removing toxic pollutants. Option 1 is projected
to remove 6,600 toxic-pound equivalents, Option 2 removes 7,300 toxic-pound equivalents, and
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Section 12.0 - Option Selection and Regulated Pollutants
Option 3 removes 7,800 toxic-pound equivalents. EPA predicts that, if selected, Option 3 would
not result in significant additional benefits incremental to Option 2 because the additional toxic
pound-equivalents removed by Option 3 are due to pollutants that would not be selected for
regulation (see Section 12.5).
EPA considered selecting Option 1; however, EPA shares the concerns of a
pretreatment authority that accepts TEC wastewater that oil/water separation alone is not
sufficient pretreatment for the pollutants in Rail/Chemical & Petroleum Subcategory wastewaters.
Additionally, EPA is concerned about any discrepancy in selected options for the rail and truck
facilities because treatment options should be similar for facilities that potentially compete with
each other.
Option 2, which is analogous to PSES Option 1 in the Truck/Chemical &
Petroleum Subcategory, achieves a significant reduction in toxic loadings and results in no
closures, financial stress, or revenue impacts.
EPA established PSNS equivalent to PSES because EPA does not predict
significant additional pollutant removals by Option 3, and EPA does not believe that the higher
costs for Option 3 justify its selection for pretreatment standards for new sources.
12.2.3 Barge/Chemical & Petroleum
EPA evaluated three options for the Barge/Chemical & Petroleum Subcategory as
discussed in Section 8.6.3. EPA did not propose PSES for this Subcategory, but is promulgating
PSES for the Barge/Chemical & Petroleum Subcategory based on Option 2 for the reasons
discussed below.
EPA proposed Option 2 for PSNS. EPA did not propose PSES for the
Barge/Chemical & Petroleum Subcategory because EPA identified only one facility discharging to
a POTW. However, since the proposal, EPA has identified four facilities that previously
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Section 12.0 - Option Selection and Regulated Pollutants
discharged directly to surface waters and have since either switched or plan to switch discharge
status. EPA now estimates that there are five facilities that discharge wastewater to a POTW.
EPA evaluated the treatment in place and levels of control currently achieved by
the model indirect discharging Barge/Chemical & Petroleum facilities. EPA was able to evaluate
effluent discharge concentrations of BOD and oil & grease from all of these model facilities and
TSS from two model facilities (EPA did not have the data to evaluate the discharge
concentrations of other parameters). Based on the discharge concentrations of these conventional
pollutants, EPA believes that all model indirect discharging facilities are meeting the levels of
control that would be established under PSES at Option 2. Although EPA does not establish
technology-based pretreatment standards for conventional pollutants, EPA believes that these
parameters demonstrate a level of control similar to the technology options for PSES at Option 2,
and that the effluent concentrations of other pollutants of interest also would be controlled
similarly.
Therefore, EPA estimates that the cost of implementing PSES standards equivalent
to Option 2 would be solely for increased monitoring costs, totaling approximately $67,000
annually. EPA believes that all indirect discharging facilities have sufficient treatment in place to
prevent pass through or interference and are predicted to meet standards that would be
established under PSES. EPA predicts that there would be no incremental removals or benefits
associated with establishing PSES standards.
In addition, EPA evaluated the pass through of pollutants regulated under BAT.
As was discussed at proposal for establishment of PSNS, and in the Notice of Availability for
SGT-HEM, EPA found that a number of pollutants would in fact pass through a POTW based on
BAT treatment. Due to the pass through of a number of pollutants, and due to the number of
facilities that have switched discharge status since proposal, EPA concluded that it should
establish PSES based on Option 2. EPA believes that PSES is necessary in order to establish
similar levels of control for direct and indirect dischargers, and especially to establish similar levels
of control for those facilities that may decide to switch discharge status.
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Section 12.0 - Option Selection and Regulated Pollutants
As noted under NSPS for the Barge/Chemical & Petroleum Subcategory, EPA
believes that Option 3, which includes reverse osmosis treatment, would not result in a significant
reduction of toxic pollutants because most pollutants are already treated to very low levels based
on Option 2 level of control. Option 2 was demonstrated to treat many regulated pollutants to
effluent levels approaching the detection limit. EPA has therefore decided to establish PSNS
based on Option 2.
12.2.4 Food
EPA evaluated two options for PSES for the Food Subcategory as discussed in
This evaluation also considered the types and concentrations of pollutants found in
Section 8.6.4.
raw
significant . ,
in the wastewater were found at concentrations that are amenable to treatment at a POTW. As
result, EPA did not establish PSES or PSNS for the Food Subcategory due to the low levels of
toxic pollutants discharged by facilities in this Subcategory.
...
wastewaters in this Subcategory. As expected, food grade facilities do not discharge
ificant quantities of toxic pollutants to POTWs. In addition, conventional pollutants present
he wastewater were found at concentrations that are amenable to treatment at a POTW. As a
12.2.5 Truck/Hopper, Rail/Hopper, and Barge/Hopper
EPA evaluated one option for PSES for the Truck/Hopper, Rail/Hopper, and
Barge/Hopper Subcategories as discussed in Section 8.6.5. This evaluation also considered the
types and concentrations of pollutants found in raw wastewaters for these subcategories. EPA
estimates that 42 indirect discharging hopper facilities discharge a total of 3.5 toxic-pound
equivalents to the nation's waterways, or less than one toxic-pound equivalent per facility.
Additionally, EPA estimates that the total cost to the industry to implement PSES would be
greater than $350,000 annually. EPA did not consider the estimated costs to control the
discharge of these small amounts of pound equivalents to be reasonable.
EPA also evaluated the levels of pollutants in raw wastewaters and determined that
none were present at levels expected to cause inhibition of the receiving POTW.
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Section 12.0 - Option Selection and Regulated Pollutants
Based on these factors, EPA did not establish PSES or PSNS for the
Truck/Hopper, Rail/Hopper, or Barge/Hopper Subcategories.
12.3 Rationale for Selecting Regulated Pollutants
EPA selected a subset of pollutants for which to establish numerical effluent
limitations from the list of pollutants of interest for each regulated subcategory (see Section 6.6
for details on the pollutants of interest). Due to the wide range of cargos transported in tanks
cleaned by TEC facilities it would be very difficult to establish numerical limitations for all of the
pollutants that may be found in TECI wastewaters. Additionally, monitoring for all pollutants of
interest 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 chosen to be representative of the various groups of compounds found to be
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,
convent!onals, 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, special consideration was given to priority
pollutants that were detected at treatable levels and were demonstrated to be effectively removed
were selected for regulation.
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Section 12.0 - Option Selection and Regulated Pollutants
Pollutants 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 & Petroleum and Barge/Chemical & Petroleum
Subcategories, and at least three times in the Rail/Chemical & Petroleum
Subcategory. Priority pollutants that 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 dioxins or furans for regulation.
• EPA did not select chemicals that are used in wastewater treatment
operations of the selected treatment technology option.
• EPA did not select pollutant parameters that were not considered toxic.
• EPA selected pollutants that were removed by the selected treatment
technology option by at least 50 percent.
EPA did not select pesticides, herbicides, dioxins, or furans for regulation in any
subcategory for three reasons. First, these pollutants were generally found at very low levels in
raw wastewater. Second, the treatment technologies sampled by EPA were found to remove
these pollutants from the wastewater. The treatment technologies in each subcategory treated
most pesticides, herbicides, dioxins, and furans to low levels in the effluent. Third, compliance
monitoring costs for these pollutants are prohibitively expensive for the TECI. Therefore, EPA
has determined that it is unnecessary to set nationally-applicable discharge standards for specific
pesticides, herbicides, dioxins, and furans.
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Section 12.0 - Option Selection and Regulated Pollutants
EPA also did not 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 POTW.
EPA determined that COD from TEC wastewater is adequately treated in a POTW
and does not pass through. Therefore, EPA did not select COD for regulation for indirect
dischargers. EPA also believes that COD regulation is unnecessary for direct dischargers due to
the control of other conventionals, including BOD, TSS, and oil and grease.
For direct discharging facilities, EPA is regulating the conventional pollutant oil
and grease (FIEM) but is not regulating the nonconventional pollutant non-polar material (SGT-
HEM). The analysis for HEM quantifies both petroleum-based oils and greases as well as edible
oils from vegetables or fish. SGT-HEM, however, quantifies only the petroleum-based fraction.
EPA believes it is unnecessary to select both FIEM and SGT-FIEM for regulation 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 SGT-FIEM 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 that will provide adequate control of the wide range
of pollutants that may be found in TECI wastewaters.
12.4 Regulated Pollutants for Direct Dischargers
EPA selected regulated pollutants for the Truck/Chemical & Petroleum
Subcategory, Rail/Chemical & Petroleum Subcategory, Barge/Chemical & Petroleum
Subcategory, and Food Subcategory. The specific regulated pollutants for each subcategory are
HiH in thf> fnllnwina rtinn
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Section 12.0 - Option Selection and Regulated Pollutants
12.4.1 Truck/Chemical & Petroleum
EPA established BPT, BCT, BAT, and NSPS limitations for the Truck/Chemical
& Petroleum Subcategory. The following pollutants and pollutant parameters were not selected
for regulation because they are not present at treatable concentrations or are not likely to cause
toxic effects: adsorbable organic halides (AOX), fluoride, nitrate/nitrite, total phosphorus, total
phenols, surfacants (MBAS), total organic carbon (TOC), total dissolved solids (TDS), alpha-
terpineol, benzene, benzoic acid, benzyl alcohol, chloroform, 1,2-dichlorobenzene, dimethyl
sulfone, n-decane, n-triacontane, o-cresol, p-cresol, p-cymene, trichloroethene, 2-
methylnaphthalene, 2-chlorophenol, 2-isopropylnaphthalene, boron, 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
selected 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 pollutant was determined to be present in TEC wastewater due to
source water contamination, and was therefore not selected as a pollutant to regulate: zinc.
The following pollutant was not selected for regulation because EPA believes that
its sampling data is not representative of the practices that may be performed by tank truck
facilities and because EPA has insufficient data to evaluate the effectiveness of industry-supplied
sampling data: chromium.
12-17
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Section 12.0 - Option Selection and Regulated Pollutants
The following pollutants were not selected for regulation because they are
controlled through the regulation of other pollutants: bis(2-ethylhexyl)phthalate, di-n-octyl
phthalate, n-docosane, n-dodecane, n-eicosane, n-hexacosane, n-hexadecane, n-octadecane, n-
tetracosane, n-tetradecane, and styrene.
The following pollutants were not selected for regulation because the treatment
system did not demonstrate removals of at least 50%: 2,4,6-trichlorophenol, cadmium, calcium,
magnesium, molybdenum, nickel, potassium, sodium, strontium, sulfur, ammonia as nitrogen, and
chloride.
EPA is regulating BOD5, TSS, oil and grease (HEM), pH, copper, and mercury.
12.4.2 Rail/Chemical & Petroleum
EPA established BPT, BCT, BAT, and NSPS limitations for the Rail/Chemical &
Petroleum Subcategory. The following pollutants and pollutant parameters were not selected for
regulation because they are not present at treatable concentrations or are not likely to cause toxic
effects: adsorbable organic halides (AOX), ammonia as nitrogen, nitrate/nitrite, surfacants
(MBAS), total dissolved solids (TDS), total organic carbon (TOC), total phenols, total
phosphorus, acetone, anthracene, barium, benzoic acid, carbazole, chromium, copper, dimethyl
sulfone, ethylbenzene, fluoride, o-+p-xylene, 1-methylphenanthrene, naphthalene, n-octacosane,
p-cresol, phosphorus, pyrene, styrene, titanium, n-triacontane, zinc, and 2,4-diaminotoluene.
The following pollutants were not selected for regulation because they are
commonly used in the industry as wastewater treatment chemicals: aluminum and iron.
The following pollutant was not selected for regulation because it is likely to be
volatilized in the treatment system and is therefore not considered to be treated by the selected
technology: m-xylene.
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Section 12.0 - Option Selection and Regulated Pollutants
The following pollutants were not selected for regulation because they are
controlled through the regulation of other pollutants: n-docosane, n-dodecane, n-eicosane, n-
hexacosane, n-hexadecane, n-octadecane, n-tetracosane, and n-tetradecane.
The following pollutants were not selected for regulation because the treatment
systems did not demonstrate removals of at least 50%: arsenic, boron, calcium, chloride, hexanoic
acid, magnesium, manganese, potassium, silicon, sodium, and sulfur.
EPA is regulating BOD5, TSS, oil and grease (HEM), pH, fluoranthene, and
phenanthrene.
12.4.3 Barge/Chemical & Petroleum
EPA established BPT, BCT, BAT, and NSPS limitations for the Barge/Chemical
& Petroleum Subcategory. The following pollutants and pollutant parameters 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: adsorbable organic halides (AOX),
ammonia as nitrogen, nitrate/nitrite, surfacants (MBAS), total dissolved solids, total organic
carbon (TOC), total phenols, total phosphorus, acenaphthylene, acrylonitrile, anthracene, benzoic
acid, calcium, chloride, chloroform, fluoride, hexavalent chromium, methylene chloride,
molybdenum, 2,3-benzofluorene, n-octacosane, osmium, ruthenium, phosphorus, potassium,
silicon, sodium, strontium, sulfur, 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
selected technology: acetone, benzene, ethylbenzene, methyl ethyl ketone, methyl isobutyl ketone,
12-19
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Section 12.0 - Option Selection and Regulated Pollutants
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: bis(2-ethylhexyl)phthalate, 3,6-
dimethylphenanthrene, n-hexacosane, n-hexadecane, 1-methylfluorene, 2-methylnaphthalene, 1-
methylphenanthrene, pentamethylbenzene, di-n-octyl phthalate, n-decane, n-docosane, n-
dodecane, n-eicosane, n-octadecane, n-tetracosane, n-tetradecane, p-cymene, and pyrene.
The following pollutant was not selected for regulation because the treatment
system did not demonstrate removals of at least 50%: boron.
EPA is regulating BOD5, TSS, oil and grease (HEM), pH, cadmium, chromium,
copper, lead, mercury, nickel, and zinc.
12.4.4 Food
EPA established BPT, BCT, and NSPS limitations for the Food Subcategory for
BOD5, TSS, oil and grease (HEM), and pH.
12.5 Regulated Pollutants 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 regulating priority and nonconventional pollutants. In determining
whether a pollutant is expected to pass through a POTW, the Agency compared the nation-wide
12-20
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Section 12.0 - Option Selection and Regulated Pollutants
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 selected BAT technology.
The approach to the definition of pass-through satisfies two competing objectives
set by Congress: 1) the 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.
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.
To perform the TEC pass-through analysis, EPA used percent removal rates
generated for the rulemaking efforts from the Metal Products and Machinery (MP&M) Industry
12-21
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Section 12.0 - Option Selection and Regulated Pollutants
(3), the Centralized Waste Treatment (CWT) Industry (4), the Industrial Laundries Industry (5),
and the Pesticide Manufacturing Industry (6). EPA used POTW removal data from the 50 POTW
study, the RREL database, and the rulemaking efforts listed above to compile the POTW
removals used for the TECI (7).
For indirect dischargers, EPA did not conduct the pass through analysis on the
conventional pollutant oil and grease because of a POTW's 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 SGT-HEM. SGT-HEM 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 order to determine removal rates for SGT-HEM, EPA used data submitted by the
County Sanitation Districts of Los Angeles County resulting in a percent removal estimate of 74
percent (8). EPA established pretreatment standards for SGT-HEM in cases where EPA
demonstrated that the selected BAT treatment technology will achieve greater removals of SGT-
HEM than a POTW. In these cases, EPA believes that SGT-HEM has been demonstrated to pass
through and that it is a good indicator parameter for a number of nonconventional pollutants.
Based on the criteria described above, EPA selected pollutants for regulation for
indirect dischargers for each of the regulated subcategories. Note that the Agency has chosen not
to regulate indirect dischargers in the Food, Truck/Hopper, Rail/Hopper, and Barge/Hopper
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) that are 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 selected for
regulation. The results of the pass-through analysis for the Truck/Chemical & Petroleum,
Rail/Chemical & Petroleum, and Barge/Chemical & Petroleum Subcategories are listed in Tables
12-1, 12-2, and 12-3.
12-22
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Section 12.0 - Option Selection and Regulated Pollutants
12.5.1 Truck/Chemical & Petroleum
EPA established PSES and PSNS limitations for the Truck/Chemical & Petroleum
Subcategory. Based on the pass-through analysis, EPA determined that the following pollutants
passed through a POTW and were therefore selected for regulation: copper, mercury, and SGT-
HEM.
12.5.2 Rail/Chemical & Petroleum
EPA established PSES and PSNS limitations for the Rail/Chemical & Petroleum
Subcategory. Based on the pass-through analysis, EPA determined that the following pollutants
passed through a POTW and were therefore selected for regulation: SGT-HEM, phenanthrene,
and fluoranthene.
12.5.3 Barge/Chemical & Petroleum
EPA established PSES and PSNS limitations for the Barge/Chemical & Petroleum
Subcategory. Based on the pass-through analysis, EPA determined that the following pollutants
passed through a POTW and were therefore selected for regulation: SGT-HEM, cadmium,
chromium, copper, lead, mercury, nickel, and zinc.
12.6 References
U.S. Environmental Protection Agency. Final Economic Analysis of Effluent
Limitations Guidelines and Standards for the Transportation Equipment Cleaning
Category. EPA 821-R-00-013, June 2000.
U.S. Environmental Protection Agency. Final Cost-Effectiveness Analysis of
Effluent Limitations Guidelines and Standards for the Transportation Equipment
Cleaning Category. EPA 821-R-00-014, June 2000.
12-23
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Section 12.0 - Option Selection and Regulated Pollutants
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. EPA 821-R-95-021, April 1995.
U.S. Environmental Protection Agency. Development Document 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.
U.S. Environmental Protection Agency. Final POTW Pass-Through Analysis for
the TECI. April 2000 (DCN T20534).
64 FR 38870 (DCN 20477).
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Section 12.0 - Option Selection and Regulated Pollutants
Table 12-1
Pass-Through Analysis for the Truck/Chemical & Petroleum Subcategory
Pollutant
Copper
Mercury
Average BAT
Percent Removal
87
94
Average POTW
Percent Removal
84
90
Pass Through
Yes
Yes
Table 12-2
Pass-Through Analysis for the Rail/Chemical & Petroleum Subcategory
Pollutant
Fluoranthene
Phenanthrene
Average BAT
Percent Removal
92
97
Average POTW
Percent Removal
42
95
Pass Through
Yes
Yes
Table 12-3
Pass-Through Analysis for the Barge/Chemical & Petroleum Subcategory
Pollutant
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Zinc
Average BAT
Percent Removal
97
98
98
95
98
96
93
Average POTW
Percent Removal
90
80
84
77
90
51
80
Pass Through
Yes
Yes
Yes
Yes
Yes
Yes
Yes
12-25
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Section 13.0 - Implementation of Effluent Limitations Guidelines and Standards
is.o IMPLEMENTATION OF EFFLUENT LIMITATIONS GUIDELINES AND
STANDARDS
A permit writer must first determine if a facility is subject to the Transportation
Equipment Cleaning (TEC) regulation by evaluating its tank cleaning operations, including the
tank types cleaned, cargo types cleaned, and annual wastewater discharge volume. This section is
intended to provide guidance to permit writers and TEC facilities on how the TEC rule will be
applied and implemented.
Indirect discharging facilities in the Truck/Chemical and Petroleum and
Rail/Chemical and Petroleum subcategories subject to the TECI regulation will need to make an
initial choice on how to comply with the regulation. They will need to choose to either comply
with numerical effluent limitations guidelines and standards or agree to develop and comply with
an enforceable pollution prevention alternative, referred to as the Pollutant Management Plan.
Direct discharging facilities must comply with numerical effluent limitations guidelines and
standards.
Section 13.1 discusses and provides examples of facilities that are excluded from
the TEC rule. Section 13.2 discusses implementation of numerical effluent limitations and
pretreatment standards and provides examples of how these are applied. Section 13.3 discusses
implementation of the Toxics Management Plan.
In addition, EPA is preparing a Permit Guidance Document to provide further
assistance to the industry and the permitting/control authorities implementing this rule. (A copy
may be obtained by writing to the EPA Office of Water Resource Center (RC-4100), 401 M
Street, SW, Washington, DC, 20460, or by calling 202-260-7786.)
13-1
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Section 13.0 - Implementation of Effluent Limitations Guidelines and Standards
13.1 Facilities Excluded from the TECI Regulation
EPA has provided in the rule a low-flow exclusion for facilities that generate less
than 100,000 gallons per year of TEC process wastewater (§442.1(b)(3)). Section 13.1.1
provides an example of how the low flow exclusion is applied. Note that the definition of TEC
process wastewater (§442.2) specifically excludes wastewater generated from cleaning tank
interiors for the purposes of maintenance and repair.
EPA has provided an exclusion for wastewaters associated with tank cleanings
operated in conjunction with other industrial, commercial, or publicly-owned treatment works
(POTW) operations, provided that the cleaning is limited to tanks that previously contained raw
materials, by-products and finished products that are associated with the facility's on-site
processes. On-site means the contiguous and non-contiguous established boundaries of a facility.
Sections 13.1.2 and 13.1.3 provide examples of application of this exclusion.
A TEC facility may accept wastewater from off site and still be considered a TEC
facility as long as the wastewater from off site also meets the definition of TEC process
wastewater. If a TEC facility accepts wastewater from off site that is not generated from other
tank cleaning activities, that facility may be considered a centralized waste treater (CWT) and may
have to meet limitations applicable to the CWT industry.
The TEC effluent limitations are not applicable to wastewater generated from
cleaning drums and intermediate bulk containers; however, EPA recognizes that many facilities
that will be subject to the TEC effluent limitations also clean these types of containers. Section
13.1.4 provides guidance in applying the TEC effluent limitations for these facilities.
13.1.1 Low Flow Exclusion - Unregulated Wastewater
Example 1: An indirect discharging TEC facility cleans rail tank cars for both
shipping products and repair. The facility discharges an average of 360,000 gallons of wastewater
13-2
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Section 13.0 - Implementation of Effluent Limitations Guidelines and Standards
per year and performs an average of 360 cleanings per year. All tanks last transported chemical
and petroleum cargos. According to facility records, approximately 75% of all cleanings are
performed for the purpose of maintenance and repair on the tank, with the remainder performed
for the purpose of shipping. The facility operates year round.
By definition, only 25% of the facility's total average annual wastewater flow,
90,000 gallons per year, is considered TEC process wastewater. This facility qualifies for the low
flow exclusion because it discharges less than 100,000 gallons per year of TEC process
wastewater, and is therefore not subject to TEC effluent limitations. Facilities discharging less
than 100,000 gallons per year of TEC process wastewater will remain subject to limitations and
standards established on a case-by-case basis using Best Professional Judgement by the permitting
authority.
13.1.2 Manufacturing Facility Covered by Another Point Source Category
Example 2: A chemical manufacturer, subject to the Organic Chemicals, Plastics,
and Synthetic Fibers (OCPSF) effluent guideline (40 CFR 414), manufacturers bulk organic
chemicals for sale and distribution. The facility holds a NPDES permit with limitations based on
40 CFR 414.71 and 414.73. In addition to manufacturing chemicals, the facility transports
chemicals in tank trucks and occasionally cleans the interiors of tank trucks when changing cargos
for delivery. Based on data collected over the previous five years, the greatest number of tank
trucks cleaned in a given year is 200 tanks, and the average is 178 tanks. The average annual
volume of tank cleaning wastewater discharged is 140,000 gallons. Tank cleaning wastewater is
combined with chemical manufacturing wastewater (14 millions gallons per year) for treatment in
the facility's on-site treatment facility. The facility operates 365 days per year.
As specified in §442.1(b)(l), the TECI effluent guidelines do not apply to
"wastewater associated with tank cleanings operated in conjunction with other
industrial...operations, provided that the cleaning is limited to tanks that previously contained raw
materials, by-products, or finished products that are associated with the facility's on-site
13-3
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Section 13.0 - Implementation of Effluent Limitations Guidelines and Standards
processes." Although this facility is not subject to 40 CFR 442, wastewater discharges from tank
truck cleaning may be permitted under 40 CFR 414 or any other applicable point source category.
13.1.3 Manufacturing Facility Not Covered by Another Point Source Category
Example 3: A grape juice processing facility cleans tank trucks that contained
processed juice. The facility discharges to a local POTW and is not required to monitor their
effluent discharges. The facility cleans (on average) 350 tank trucks per year and discharges
1,000 gallons of wastewater per tank cleaning. Wastewater is generated from interior, exterior,
and equipment and floor washings. The facility also discharges over 5,000 gallons per day of
wastewater from juice processing. All waste streams are commingled prior to discharge, without
pretreatment. The facility operates 350 days per year.
This facility is not currently subject to another point source category, but generates
a significant volume of tank cleaning wastewater, 350,000 gallons per year. However, as
described in §442.1(b)(l), the TECI effluent guidelines do not apply to "wastewater associated
with tank cleanings operated in conjunction with other industrial...operations, provided that the
cleaning is limited to tanks that previously contained raw materials, by-products, or finished
products that are associated with the facility's on-site processes." Therefore, this facility is not
subject to 40 CFR 442. The facility may be subject to local pretreatment limits as necessary to
prevent pass-through or interference.
Example 4: An inorganic chemical manufacturer operates a distribution center
100 miles from its main facility where all chemicals are manufactured. The facility mainly
operates as a chemical distributor (e.g., unloading and loading products), but it also cleans tank
trucks for change of cargo. The wastewater generated from tank cleaning is not currently
covered by a point source category, and is discharged to a local POTW without pretreatment.
The distributor cleans an average of 600 tank trucks per year and discharges 210,000 gallons of
tank cleaning wastewater per year. The facility has no other significant sources of process
wastewater. The distributor operates 180 days per year.
13-4
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Section 13.0 - Implementation of Effluent Limitations Guidelines and Standards
As described in §442.1(b)(l), the TECI effluent guidelines do not apply to
"wastewater associated with tank cleanings operated in conjunction with other industrial,
commercial, or POTW operations, provided that the cleaning is limited to tanks that previously
contained raw materials, by-products, or finished products that are associated with the facility's
on-site processes." EPA has provided a revised definition for "on-site" that includes contiguous
and non-contiguous property within the established boundary of a facility.
EPA believes its exclusion for other industrial, commercial, or POTW facilities
allows the permitting authority a considerable amount of discretion in determining if the tank
cleanings are performed as part of, or in addition to, the facilities on-site processes. In this
example, the permit writer may exercise flexibility in setting local limitations and may determine
that the TEC effluent limitations would be appropriate for use as the basis of the permit.
13.1.4 Facility That Cleans Tanks and IBCs
Example 5: A direct discharging TEC facility cleans tank trucks and intermediate
bulk containers (IBCs) last containing chemical or petroleum cargos. The facility cleans 4,500
tank trucks per year and 1,800 IBCs per year. The facility discharges an average of 270 gallons
of wastewater per tank truck or IBC cleaned. The facility operates 350 days per year.
Discharges from this facility are subject to §442.11, §442.12, and §442.13 for the
Truck/Chemical & Petroleum Subcategory. As stated under §442.1(b)(2), wastewater resulting
from the cleaning of IBCs is not covered by 40 CFR 442; however, permit writers, using Best
Professional Judgement, may provide a pollutant discharge allowance for non-categorical
wastewater discharges such as IBC cleaning. EPA assumes that a permit writer would give this
facility an allowance for the IBC cleanings since the facility cleans a significant number of IBCs
each day and they may contribute significant pollutant loadings in the raw and treated wastewater.
As a conservative estimate, a permit writer could assume that the wastewater characteristics from
cleaning a tank truck are similar to that of cleaning an IBC.
13-5
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13.2
Section 13.0 - Implementation of Effluent Limitations Guidelines and Standards
Numerical Effluent Limitations
Using the effluent limitations guidelines and standards, 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 POTW. This section
provides guidance and examples on how the TECI effluent guidelines will be implemented.
Compliance monitoring should be performed on a frequency basis established by
the permitting authority. EPA's monitoring costs for this regulation assumed compliance
monitoring for conventional pollutants four times per month, and for priority and non-
conventional pollutants once per month.
13.2.1
Single Subcategory Facility
Example 6: An indirect discharging TEC facility cleans rail tank cars that last
transported fuel oil, lube oil, and sulfuric acid. The facility cleans 20 tanks per day and discharges
an average of 10.4 million gallons of TEC process wastewater per year. The facility operates 260
days per year.
This facility's wastewater discharges are subject to Subpart B - Rail Tank Cars
Transporting Chemical & Petroleum Cargos, Pretreatment Standards for Existing Sources (PSES)
(§442.25). This facility would be required to monitor for SGT-HEM, fluoranthene, and
phenanthrene and must comply with the following end-of-pipe discharge limitations:
Pollutant
SGT-HEM
Fluoranthene
Phenanthrene
Maximum Daily Concentration (mg/L)
26
0.076
0.34
13-6
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13.2.2
Section 13.0 - Implementation of Effluent Limitations Guidelines and Standards
Multiple Subcategory Facility
Example 7: An indirect discharging TEC facility cleans the interiors of tank
trucks and rail tank cars. A wide range of cargos is cleaned, but all cargos are classified as
chemical or petroleum (as defined in §442.2). The facility cleans, on average, 10 tank trucks and
3 rail cars per day. On average, the facility discharges 500 gallons of TEC process wastewater
per tank truck cleaned and 2,000 gallons of TEC process wastewater per rail tank car cleaned.
The facility also commingles into its treatment system 20 gallons per day of boiler blowdown.
The facility operates 300 days per year.
This facility's wastewater discharge is subject to both Subpart A - Tank Trucks
and Intermodal Tank Containers Transporting Chemical & Petroleum Cargos, PSES (§442.15)
and Subpart B - Rail Tank Cars Transporting Chemical & Petroleum Cargos, PSES (§442.25). A
permit writer would use the combined waste stream formula in Equation 1, set forth in 40 CFR
403.6(e), to establish effluent limitations. Note that the boiler blowdown waste stream is the only
dilute waste stream at this facility.
CT =
N
E CF,
i = l
N
T.F,
i = l i
(FT-FD
( FT
(1)
where:
CT
Q
F;
Alternative concentration limit for the combined wastestream,
(mg/L)
Concentration limit for a pollutant in the regulated stream i, (mg/L)
Average daily flow (at least a 30-day average) of regulated stream i,
(gallons/day)
Average daily flow (at least 30-day average) of dilute waste
stream(s), (gallons/day)
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Section 13.0 - Implementation of Effluent Limitations Guidelines and Standards
FT = Average daily flow (at least a 30-day average) through the
combined treatment facility (including regulated, unregulated, and
dilute waste streams), (gallons/day)
N = Total number of regulated streams
An example for calculating the copper limit is provided:
Average daily Subpart A flow:
FA = TPDA * GPT = 10 * 500 = 5,000 gallons/day
Average daily Subpart B flow:
FB = TPDB * GPT = 3 * 2,000 = 6,000 gallons/day
where:
F = Average daily flow (at least a 30-day average) of regulated stream,
(gallons/day)
TPD = Number of tanks cleaned per day, (tanks/day)
GPT = Gallons of TEC process wastewater generated per tank cleaned,
(gallons/tank)
The average daily flow through the combined treatment system is the sum of FA and FB plus the
boiler blowdown flow, or 11,020 gallons/ day. The maximum daily concentration limitation for
copper for Subpart A is 0.84 mg/L (from §442.15). Copper is not regulated for Subpart B and
this flow is considered an unregulated process flow. CT for copper is calculated as:
= 0.84 * 5,000 11.020-20 = QM
T 5,000 / 11,020 I
The same methodology would be used to establish pretreatment standards for all
pollutants regulated under §442.15 and/or §442.25 (SGT-HEM, mercury, fluoranthene, and
phenanthrene). SGT-HEM is the only pollutant regulated under both Subparts A and B. Because
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Section 13.0 - Implementation of Effluent Limitations Guidelines and Standards
the SGT-HEM limitation is the same in both subparts (26 mg/L), CT for SGT-HEM for this
example facility is calculated as:
c - (26 * 5,000) + (26 * 6,000)] 11,020 - 20 _ ^
T 11,000 I 11,020 I
13.2.3 Regulated and Unregulated Wastewater at a Facility
Example 8: An indirect discharging TEC facility cleans tank barges containing a
variety of cargos, including petroleum and products such as gasoline, mineral spirits and xylene.
The facility also cleans barge hoppers containing dry bulk cargos. The facility cleans a total of
165 tank barges per year and 1,120 hoppers per year. The facility discharges an average of 700
gallons of wastewater per barge hopper cleaned and 4,700 gallons of wastewater per chemical and
petroleum barge cleaned. The facility operates 280 days per year.
This facility's wastewater discharge is subject to Subpart C - Tank Barges and
Ocean/Sea Tankers Transporting Chemical & Petroleum Cargos, PSES (§442.35). EPA has not
established PSES for the cleaning of barge hoppers. By definition, wastewater generated from
cleaning closed-top hoppers is not considered TEC process wastewater and is not covered by 40
CFR 442. This flow will remain subject to limitations and standards established on a case-by-case
basis using Best Professional Judgement by the permitting authority.
EPA found that hopper wastewater contains low levels of conventional and toxic
pollutants. Permit writers should evaluate unregulated streams to determine whether they actually
are acting as dilution. A local or state control authority can use its own legal authority to
establish a limit more stringent than would be derived using the combined waste stream formula.
In this example, EPA assumes that a permit writer would not give this facility an allowance for
hopper cleanings and would consider it a dilution flow.
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Section 13.0 - Implementation of Effluent Limitations Guidelines and Standards
The annual volume of TEC process wastewater discharged by this facility is
calculated as follows:
ANN = TPY * GPT = 165 * 4,700 = 775,500 gallons/year
where:
ANN = Annual TEC process wastewater flow, (gallons/year)
TPY = Number of tank barges cleaned per year (chemical and petroleum
only), (tanks/year)
GPT = Gallons of TEC process wastewater generated per tank cleaned,
(gallons/tank)
This facility does not qualify for the low flow exclusion because it discharges more than 100,000
gallons per year of TEC process wastewater.
The annual volume of wastewater generated from cleaning hoppers is:
ANN = TPY * GPT = 1,120 * 700 = 784,000 gallons/year
A permit writer would use the combined waste stream formula (see Equation (1))
to establish PSES since only a portion of the facility's discharge is subject to this rule. An
example for calculating CT for zinc is provided below. The maximum daily concentration
limitation for zinc for Subpart C is 8.3 mg/L (from §442.35).
Average daily Subpart C flow:
j-, ANN 775,500 _ __. „ ,,
F. = = = 2,770 gallons/day
1 DPY 280
Average daily hopper flow (considered a dilution waste stream in this example):
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Section 13.0 - Implementation of Effluent Limitations Guidelines and Standards
ANN 784,000 . OAA „ ,,
= = 2,800 gallons!day
DPY 280
where:
F = Average daily flow (at least a 30-day average) of stream,
(gallons/day)
ANN = Annual wastewater flow, (gallons/year)
DPY = Number of operating days per year
The average daily flow through the combined treatment facility:
j-, ( (165 * 4,700) + (1,120 * 700)"l . ._. „ . ,
FT = - — '- =5,570 gallons/day
T 280 } , & s
Alternative concentration limit:
= 8.3*2,770 5,570-2,800 =
T 2,770 5,570
The same methodology would be used to establish pretreatment standards for all pollutants
regulated under §442.35 (SGT-HEM, cadmium, chromium, copper, lead, mercury, nickel, and
zinc).
13.3 Pollutant Management Plan
The permitting authority will establish a pollution prevention allowable discharge
of wastewater pollutants, as defined in §442.2, if the facility agrees to a control mechanism or
pretreatment agreement as specified in the applicable subpart(s).
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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 submitting 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
CFR 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.
EPA promulgated Method 1664, the analytical method for HEM and SGT-HEM,
on May 14, 1999 (see 64 FR 26315) to support phaseout of use of CFC-113. This rulemaking
revised 40 CFR 136 to list Method 1664 as an approved method to analyze oil and grease and
non-polar material (i.e., FIEM and SGT-HEM). Note that EPA will allow continued use of
methods that use CFC-113 through the extension to the laboratory use exemption of CFC-113
through 2005; however, EPA strongly encourages dischargers/generators/industrial users and
permit authorities to substitute use of Method 1664 for CFC-113 methods. Method 1664 will be
used in EPA's wastewater program for regulation development, permit applications, and
compliance monitoring. 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
'For example, the American Public Health Association publishes Standard Methods for the Examination of Water and
Wastewater.
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Section 14.0 - Analytical Methods
promulgated for oil and grease (HEM) and non-polar material (SGT-HEM) in this effluent
guideline are to be measured by Method 1664.
For this final rule, EPA is regulating certain conventional, priority, and
nonconventional pollutants as identified in Section 12.0. The methods proposed for monitoring
the regulated pollutants are briefly discussed in the following sections:
• 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: Biochemical Oxygen Demand; and
• Section 14.5: Total Suspended Solids.
Section 14.6 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
separately 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 jig/L (ppb) can be achieved, depending upon the specific
compound.
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Section 14.0 - Analytical Methods
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 semi quantitative
ICP screen for 42 additional elements. The ICP technique measures atomic 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 //g/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) are analyzed by EPA Method 1664 (3). In
this method, a 1-L sample is acidified and serially extracted three times with n-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 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
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Section 14.0 - Analytical Methods
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).
14.5 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).
14.6 References2
1. U.S. Environmental Protection Agency. Method 1625. Revision C: Semivolatile
Organic Compounds by Isotope Dilution GCMS. June 1989 (DCN T10220).
2. U.S. Environmental Protection Agency. Method 1620: Metals by Inductively
Coupled Plasma Atomic Emission Spectroscopy and Atomic Absorption
Spectroscopy. September 1989 (DCN T10224).
3. U.S. Environmental Protection Agency. Method 1664. Revision A: n-Hexane
Extractable Material (HEM: Oil and Grease) and Silica Gel Treated n-Hexane
Extractable Material (SGT-HEM: Non-polar Material) by Extraction and
Gravimetry. EPA-821-R-98-002. February 1999. (DCN T20485).
4. U.S. Environmental Protection Agency. Methods for Chemical Analysis of Water
and Wastes. EPA-600/4-79-020, March 1983. (DCN T10228).
2 For those references included in the administrative record supporting the 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
is.o 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, 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, tank barge, closed-top
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Section 15.0 - Glossary
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.
Centralized Waste Treaters Effluent Guideline - see proposed 40 CFR Part 437, 60 FR 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.
Chemical Cargo - Chemical cargos include, but are not limited to, the following cargos: latex;
rubber; plastic; plasticizers; resins; soaps; detergents; surfactants; agricultural chemicals and
pesticides; hazardous waste; organic chemicals including: alcohols, aldehydes, formaldehydes,
phenols, peroxides, organic salts, amines, amides, other nitrogen compounds, other aromatic
compounds, aliphatic organic chemicals, glycols, glycerines, and organic polymers; refractory
organic compounds including: ketones, nitriles, organo-metallic compounds containing chromium,
cadmium, mercury, copper, zinc; and inorganic chemicals including: aluminum sulfate, ammonia,
ammonium nitrate, ammonium sulfate, and bleach. Cargos which are not considered to be
foodgrade, petroleum, or dry bulk goods are considered to be chemical cargos.
Classical Pollutants - A general term for parameters, including conventional pollutants, that are
commonly analyzed by a wet chemistry laboratory. Classical pollutants may also be referred to as
classical wet chemistry parameters.
Classical Wet Chemistry Parameters- A general term for parameters, including conventional
pollutants, that are commonly analyzed by a wet chemistry laboratory. Classical wet chemistry
parameters may also be referred to as classical pollutants.
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, lime, 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.
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Section 15.0 - Glossary
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, lime, 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, carry 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 non-self-propelled vessel constructed or adapted primarily to
carry dry commodities or cargos in bulk 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. Closed-top 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 in direct
contact with the hopper interior. The basic types of tops on closed-top 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 Methods 410.1 through 401.4.
Commercial TEC Facility - A TEC 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 truck, closed-top hopper
truck, intermodal tank container, rail tank car, closed-top hopper rail car, tank barge, closed-top
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).
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Section 15.0 - Glossary
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.)
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
grain, soybeans, soy meal, soda ash, lime, fertilizer, plastic pellets, flour, sugar, and similar
commodities or cargos.
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.
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Section 15.0 - Glossary
EPA - The U.S. Environmental Protection Agency.
Facility - A facility is all contiguous and non-contiguous property within established boundaries
owned, operated, leased, or under the control of the same corporation or business entity. The
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 corn 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 pool water.
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. See Method 1664. HEM is also
referred to as oil and grease.
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 40 CFR Part 444, FR 6518, January
27, 2000.
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Section 15.0 - Glossary
In-house TEC Facility - A TEC 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.
Inorganic Chemicals Manufacturing Effluent Guidelines - see 40 CFR Part 415.
Intermediate Bulk Container (IBC 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 3,000 liters (793 gallons) capacity. IBCs are also commonly referred to as totes.
Intermodal 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 3,000 liters capacity are considered intermodal tank
containers. Containers smaller than 3,000 liters capacity are considered IBCs.
MP&M - Metal Products & Machinery Effluent Guidelines, new regulation to be proposed in
2000 (designated as 40 CFR Part 438).
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 other than those specifically defined as conventional
pollutants (identified in Section 304(a)(4) of the Clean Water Act) or priority pollutants
(identified in 40 CFR Part 423, Appendix A).
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.
Non-Polar Material - 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. See Method 1664.
Non-polar material is also referred to as SGT-HEM.
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.
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Section 15.0 - Glossary
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.
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 established boundaries 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 either n-hexane (referred to as HEM, see Method 1664) or Freon 113
(l,l,2-trichloro-l,2,2-trifluoroethane, see Method 413.1). Data collected by EPA in support of
the TECI effluent guideline utilized Method 1664.
On Site - "On site" means within the established boundaries 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. 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; olefm, paraffin, and other waxes; tall oil; tar; toluene; xylene; and
waste oil.
Petroleum Refining Effluent Guidelines - see 40 CFR Part 415
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Section 15.0 - Glossary
PNPL - Production Normalized Pollutant Loading. Untreated wastewater pollutant loading
generated per tank cleaning.
Point Source Category - A category of sources of water pollutants.
Pollutants of Interest - Pollutants that meet the following criteria are considered pollutants of
interest: detected two or more times in the subcategory raw wastewater characterization data or
one time for the Food, Truck/Hopper, Rail/Hopper, and Barge/Hopper Subcategories, and an
average treatment technology option influent concentration greater than or equal to five times
their analytical method detection limit. All pollutants of interest that were removed by the
technology bases 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 (i.e., heel) 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).)
Priority Pollutants - The pollutants designated by EPA as priority in 40 CFR Part 423, Appendix
A.
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.
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Section 15.0 - Glossary
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 - U. S. Environmental Protection Agency, Office of Research and Development, 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. See Method 1664. SGT-HEM is also referred to as non-polar material.
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.
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Section 15.0 - Glossary
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:
tank trucks, closed-top hopper trucks, intermodal tank containers, rail tank cars, closed-top
hopper rail cars, tank barges, closed-top hopper barges, ocean/sea tankers, and similar tanks.
Containers used to transport pre-packaged materials are not considered tanks, nor are 55-gallon
drums or pails or intermediate bulk containers.
Tank Barge - A 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.
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.
TEC Process Wastewater - All wastewaters associated with cleaning the interiors of tanks
including: tank trucks; tank rail cars; intermodal tank containers; tank barges; and ocean/sea
tankers used to transport commodities or cargoes that come into direct contact with the interior
of the tank or container. At those facilities that clean tank interiors, TEC process wastewater
includes wastewater generated from washing vehicle exteriors, equipment and floor washings,
TEC-contaminated stormwater, wastewater pre-rinse cleaning solutions, chemical cleaning
solutions, and final rinse solutions. TEC process wastewater is defined to include only
wasterwater generated from a regulated TEC subcategory. Therefore, TEC process wastewater
does not include wastewater generated from cleaning hopper cars, or from food grade facilities
discharging to a POTW. Wastewater generated from cleaning tank interiors for purposes of
shipping products (i.e., cleaned for purposes other than maintenance and repair) is considered
TEC process wastewater. Wastewater generated from cleaning tank interiors for the purposes of
maintenance and repair on the tank is not considered TEC process wastewater. Facilities that
clean tank interiors solely for the purposes of repair and maintenance are not regulated under the
TEC rule.
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Section 15.0 - Glossary
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).
Tote - 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 are also referred to as intermediate bulk containers or IBCs.
Fifty-five gallon drums and pails are not considered totes.
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, tank barges, closed-top hopper barges, ocean/sea tankers,
and (excluding drums and intermediate bulk containers).
Treatment Effectiveness Concentration - Treated effluent pollutant concentration that can be
achieved by each treatment technology that is part of a TECI regulatory option. Treatment
effectiveness concentrations for each pollutant were developed for each treatment technology that
removed the pollutant by 50 percent or greater.
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 paniculate matter that is suspended in
a water sample. The measure is obtained by filtering a water sample of known volume. The
paniculate 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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