United States
Environmental Protection
Agency
Office of Water (4303)
Washington, DC 20460
EPA-821-R-01-021
March 2001
&EPA Permit Guidance Document
Transportation Equipment
Cleaning Point Source
Category (40 CFR § 442)
> Printed on paper containing at least 30% postconsumer recovered fiber.
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Table of Contents
1 Introduction 1
2 Scope of 40 CFR Part 442 2
3 Overview of NPDES Program and National Pretreatment Program 9
4 What are the Effluent Limitations Guidelines and Standards for
Subparts A through D? 12
5 What is the Pollutant Management Plan and How Can It Be Used To
Demonstrate Compliance With the TEC Effluent Limitations Guidelines
and Standards? 18
6 How are Permits Developed for Numerical Limitations? 29
7 Case Studies 39
8 Where to Get Additional Help 49
Appendix A - Glossary A-l
Appendix B - Guidance on the Requirements of the Baseline Monitoring Report
(BMR) for Facilities Electing the Pollution Prevention Compliance
Option B-l
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List of Tables and Figures
2-1 Determining Applicability of the Rule 8
4-1 Model Technologies as the Regulatory Bases for the TEC Industry 13
4-2 Subpart A - Tank Trucks and Intermodal Tank Containers Transporting
Chemical and Petroleum Cargos: BPT, BCT, BAT, and NSPS Concentration-
Based Limitations for Discharges to Surface Waters 14
4-3 Subpart B - Rail Tank Cars Transporting Chemical and Petroleum Cargos:
BPT, BCT, BAT and NSPS Concentration-Based Limitations for Discharges
to Surface Waters 15
4-4 Subpart C - Tank Barges and Ocean/Sea Tankers Transporting Chemical
and Petroleum Cargos: BPT, BCT, BAT, and NSPS Concentration-Based
Limitations for Discharges to Surface Waters 15
4-5 Subpart D - Tanks Transporting Food Grade Cargos: BPT, BCT, and NSPS
Concentration-Based Limitations for Discharges to Surface Waters 16
4-6 Subpart A - Tank Trucks and Intermodal Tank Containers Transporting
Chemical and Petroleum Cargos: PSES and PSNS Concentration- Based
Limitations for Discharges to POTWs 16
4-7 Subpart B - Rail Tank Cars Transporting Chemical and Petroleum
Cargos: PSES and PSNS Concentration-Based Limitations for
Discharges to POTWs 16
4-8 Subpart C - Tank Barges and Ocean/Sea Tankers Transporting Chemical
and Petroleum Cargos: PSES and PSNS Concentration-Based Limitations
for Discharges to POTWs 17
6-1 Median Wastewater Flows for the TEC Industry 31
6-2 Average Volume of Interior Cleaning Wastewater Generated per
Tank Cleaning by Cargo Group and Tank Type -
Discharging Facilities Only 32
7-1 Final Limits for Facility A 42
7-2 Final Limits for Facility B 44
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Disclaimer
This guidance is designed to help implement national policy on effluent limi-
tations guidelines and standards for the Transportation Equipment Cleaning
(TEC) Point Source Category. This document does not, however, substitute for
the Clean Water Act or EPA's regulations, nor is it a regulation itself. Thus, the
guidance does not modify in any way the TEC guidelines and pretreatment
standards which EPA has issued. This guidance cannot impose legally binding
requirements on EPA, states, or the regulated community and may not apply to
a particular situation based upon these circumstances. If there appears to be any
difference between this guidance and the TEC rule, the TEC rule provisions pre-
vail. EPA and state decision-makers retain the discretion to adopt approaches on
a case-by-case basis that differ from this guidance where appropriate. EPA may
change this guidance in the future.
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Section 1: Introduction
On August 14, 2000, the U.S. Environmental Protection Agency (EPA) promul-
gated final effluent limitations guidelines, pretreatment standards and new source
performance standards under the Clean Water Act (CWA) (65 FR 49666) for the
following subparts of the Transportation Equipment Cleaning (TEC) Industry:
Subpart A Tank Trucks and Intermodal Tank Containers Transporting Chemical and
Petroleum Cargos
Subpart B Rail Tank Cars Transporting Chemical and Petroleum Cargos
Subpart C Tank Barges and Ocean/Sea Tankers Transporting Chemical and Petroleum
Cargos
Subpart D Tanks Transporting Food Grade Cargos (direct discharging facilities only)
These guidelines and standards are codified at 40 CFR Part 442. Permit writers
and control authorities are required to issue permits and individual control mech-
anisms to ensure that affected facilities are complying with the new regulations.
This document is specifically written to provide guidance to permitting and
pretreatment control authorities in issuing NPDES and POTW permits and
individual control mechanisms to TEC facilities that fall within the four sub-
parts mentioned above. The permitting or pretreatment control authority will
need to determine which facilities fall under 40 CFR Part 442 and how to write
the permits/individual control mechanisms for these facilities to ensure their
compliance under the new regulations. EPA has provided information in Sections
2 through 8 of this document to help in this process.
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Section 2: Scope of 40 CFR Part 442
Transportation equipment cleaning (TEC) facilities are those facilities that gen-
erate 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 materi-
als or cargos that come into direct contact with the tank or container interior.
Operations that may be subject to the rule are generally reported under one or
more of the following Standard Industrial Classification (SIC) codes: SIC 7699, SIC
4741, or SIC 4491 (1987 SIC Manual).
How Has the TEC Point Source Category Been Subcategorized?
EPA divided the TEC Point Source Category into the following seven subcate-
gories based on types of cargos carried and transportation mode. EPA has chosen
to regulate four of these subcategories:
• Truck/Chemical & Petroleum Subcategory;
• Rail/Chemical & Petroleum Subcategory;
• Barge/Chemical & Petroleum Subcategory; and
• Food Subcategory.
EPA has chosen not to regulate the remaining three subcategories:
• Truck/Hopper Subcategory;
• Rail/Hopper Subcategory; and
• Barge/Hopper Subcategory.
The effluent limitations guidelines and standards promulgated on August 14,
2000 apply to only the Truck/Chemical & Petroleum, Rail/Chemical & Petroleum,
Barge/Chemical & Petroleum, and Food Subcategories. The subparts of the rule
that correspond to these subcategories are:
• Subpart A - Tank Trucks and Intermodal Tank Containers Transporting
Chemical & Petroleum Cargos (40 CFR Part 442.10-16);
• Subpart B - Rail Tank Cars Transporting Chemical & Petroleum Cargos (40
CFR Part 442.20-26);
• Subpart C - Tank Barges and Ocean/Sea Tankers Transporting Chemical &
Petroleum Cargos (40 CFR Part 442.30-36); and
• Subpart D - Tanks Transporting Food Grade Cargos (40 CFR Part 442.40-44).
Tank trucks and intermodal tank containers covered under Subpart A may be
confused with each other, and with intermediate bulk containers (wastewater gen-
erated by cleaning intermediate bulk containers is excluded from this rule). These
tanks and containers are defined in Section 442.2(a) as follows:
• Tank truck means a motor-driven vehicle with a completely enclosed storage
vessel used to transport liquid, solid, or gaseous materials over roads and high-
ways. The storage vessel may be detachable, as with tank trailers, or permanent-
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Scope of 40 CFR Part 442
ly 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 com-
monly referred to as cargo tanks or tankers.
• Intermodal tank container means 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 capac-
ity are considered intermodal tank containers.
• Intermediate bulk container ("IBC" or "Tote") means a completely
enclosed storage vessel used to hold liquid, solid, or gaseous commodities
or cargos which are in direct contact with the container interior. IBCs 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 or tote bins.
What Operations Are Performed at TEC Facilities?
Tank and container interiors are cleaned for two primary purposes: (1) to pre-
vent contamination of materials from one cargo shipment to the next and (2) to
facilitate inspection and repair. A typical sequence for a cleaning process is as fol-
lows:
• 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;
• 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.
Tanks are typically cleaned using spinner nozzles and/or hand-held wands,
and operating cycles may range from a few seconds to 20 minutes.
The wastewater generated at TEC facilities varies depending upon tank type
cleaned and the various commodities cleaned. Many TEC facilities have on-site
wastewater treatment. Although most TEC facilities are indirect dischargers, a few
facilities (predominantly barge/chemical & petroleum facilities) discharge directly
to surface waters.
The language that discusses general applicability of the rule, gives general defi-
nitions, and discusses the general pretreatment standards is presented at 40 CFR
Part 442.1-3.
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This rule excludes:
S Facilities that do NOT clean the interiors of tanks.
S Facilities that clean tank interiors solely for the purposes of repair and maintenance. These facilities may be
subject to the Metal Products & Machinery (MP&M) rule (to be listed in 40 CFR 438 when promulgated).
Wastewater generated from cleaning tank interiors for the purpose of shipping products (i.e., cleaned for
purposes other than maintenance and repair) is considered TEC process wastewater and is covered under
the TEC rule. Only facilities that discharge 100,000 gallons or more per year of TEC process wastewater
are covered under the TEC rule. (It is possible that a facility may be subject to both the TEC regulations
and the MP&M regulations. If a facility generates wastewater from MP&M activities that are subject to the
MP&M regulations 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 rules.)
S Wastewaters 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.
S Facilities that discharge less than 100,000 gallons per year of TEC process wastewater (only wastewater
generated from a regulated TEC subcategory).
S Wastewater generated from cleaning the interiors of drums, intermediate bulk containers, or closed-top
hoppers.
S Wastewater generated from a non-regulated TEC subcategory.
What Wastewaters Are Covered by the Guideline?
Figure 2-1 (at the end of this section) is a logic chart that shows the applicabili-
ty of the August 14, 2000 TEC effluent limitations guidelines and standards. The
rule covers all wash waters that have come into direct contact with the tank or
container interior, including prerinse cleaning solutions, chemical cleaning solu-
tions, and final rinse solutions. Additionally, for regulated facilities, the rule cov-
ers wastewater generated from washing vehicle exteriors, equipment and floor
washings, and TEC-contaminated wastewater at facilities that clean tank interiors.
How Does the Low Flow Exclusion Apply to a Facility?
Section 442.1(b)(3) specifies that wastewater from a facility that discharges less
than 100,000 gallons per year of TEC process wastewater is excluded from the
TEC regulation.
In the calculation of the total facility flow, the following Wastewaters are
defined in Section 442.2 as TEC process wastewater:
• Interior cleaning wastewater;
• Exterior cleaning wastewater;
• Equipment and floor washings;
• TEC-contaminated stormwater;
• Wastewater prerinse cleaning solutions;
• Chemical cleaning solutions; and
• Final rinse solutions.
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Scope of 40 CFR Part 442
The following wastewaters are NOT considered TEC process wastewater and
are not included in the calculation of total facility flow:
• Drum, IBC, and closed-top hopper cleaning wastewater (excluded per Section
442.1(b)(2));
• Wastewater generated from tank cleaning for the purposes of maintenance and
repair (excluded per definition of TEC process wastewater in Section 442.2);
• Wastewater generated from tank cleaning associated with other industrial,
commercial, or POTW operations (as defined in Section 442.1(b)(l));
• Tank cleaning wastewater generated from a non-regulated subcategory
(excluded per definition of TEC process wastewater in Section 442.2); and
• Bilge and ballast water.
For example, a chemical manufacturing facility cleans rail cars on site. The
facility discharges 200,000 gallons per year of tank cleaning wastewater, but 90%
of the tank cars previously contained raw materials, by-products, or finished
products that are associated with the facility's on-site processes.
Total regulated process wastewater = 200,000 gal/yr x 10% = 20,000 gal/yr
Therefore, the facility qualifies for the low flow exclusion because it discharges
only 20,000 gallons per year of wastewater defined as "TEC process wastewater."
For another example, a facility not associated with any other industrial or com-
mercial activity discharges 400,000 gallons per year of tank cleaning wastewater
to the POTW. The facility discharges 60,000 gallons generated by cleaning truck
hoppers, 90,000 gallons generated by cleaning tank trucks that have last contained
food grade products, 50,000 gallons generated by cleaning intermodal tank cars
that last contained chemical products, and 200,000 gallons generated by cleaning
tank trucks that last contained chemical and petroleum products.
Total regulated process wastewater = Intermodal wastewater + Tank truck wastewater
Total regulated process wastewater = 50,000 gal/yr + 200,000 gal/yr
Total regulated process wastewater = 250,000 gal/yr
The 90,000 gallons generated from cleaning food grade products is not consid-
ered TEC regulated process wastewater because EPA did not establish pretreat-
ment standards for Subpart D: Tanks Transporting Food Grade Cargos. Therefore,
the facility discharges 250,000 gallons of TEC process wastewater per year and is
subject to Subpart A: Tank Trucks and Intermodal Tank Containers Transporting
Chemical and Petroleum Products.
What Are Examples of Interior Cleaning Wastewater Generated
At Other Industrial or Commercial Facilities?
The focus of EPA's exclusion is manufacturing, industrial, or commercial facili-
ties which clean their own transportation equipment and treat the interior clean-
ing wastewater in their treatment system. These include, for example, facilities
covered, or proposed to be covered, under other Clean Water Act categorical stan-
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dards. Note, however, that EPA is not providing a blanket exclusion for all manu-
facturing, industrial, and commercial facilities. EPA believes that a facility which
cleans tanks last containing off-site cargos not associated with on-site activities
should be regulated as TEC because the wastewater generated from these cargos
may not be compatible with the treatment system in place and may not be com-
patible with the existing discharge limitations established for that facility.
Product stewardship activities, tolling or contract manufacturing operations,
and manufacturing agreements that are part of divestitures, partnerships, or joint
ventures are all examples where interior cleaning wastewater is generated at other
industrial or commercial facilities. Wastewater generated by these activities are
excluded from this rule, provided the tanks and containers cleaned last contained
raw materials, by-products, or finished products that are associated with the facil-
ity's on-site processes.
Product stewardship activities are intended to promote recycling and reuse of
products, and to reduce the environmental impact of chemical products. Product
stewardship activities may include recovering: spent, used, or unused products;
containers (i.e., those used for shipping) with product residues; off-specification
products; and waste materials from use of products. Where possible, these materi-
als are recovered and reused in chemical processes at the manufacturing plants.
Returned materials that are not reusable, or residues that remain after reuse, are
treated or disposed in the existing on-site wastewater treatment system, incinera-
tor, or placed in an appropriately regulated landfill.
Tolling or contract manufacturing operations are used in the chemical industry to
enable a company to contract with a second company (i.e., a "toller") to engage in
specified production activities on behalf of the first company. Tollers often per-
form one step in a primary manufacturer's multistep production process (e.g.,
produce an intermediate). The primary manufacturer often provides the raw
materials used by tollers who return the intermediate along with any by-products
and waste materials.
Manufacturing facilities that have individual operating units or have created joint ven-
ture partnerships under separate legal ownership are considered "on site" under this
rule provided the facilities continue to manufacture the same products and gener-
ate the same wastewater destined for the same on-site treatment system, including
TEC wastewater. Any infrastructure operations, such as waste treatment and TEC
operations, continue to be provided to the new company per an agreement estab-
lished at the time of divestiture or formation of the joint venture partnership.
What Are Examples of Interior Cleaning Wastewater Generated
At POTW Facilities?
POTW facilities may clean Vactor®, biosolids, or septage tank trucks that are
used to haul wastewater and solids. Wastewater generated from these cleanings is
excluded from this rule.
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Scope of 40 CFR Part 442
Are Garbage Trucks Covered by the TEC Regulation?
Garbage trucks and similar vehicles are not considered to be tanks and are
therefore not included within the scope of the rule.
Are Facilities that Clean Tanks to Perform Repair and
Maintenance Covered by the TEC Regulation?
Wastewater generated from cleaning tank interiors for purposes of repair and
maintenance is not considered TEC process wastewater and therefore is not sub-
ject to the TEC regulation. 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. (See definition of TEC process
wastewater in Section 442.2.)
Are Facilities Subject to the Centralized Waste Treatment
(CWT) Point Source Category (40 CFR Part 437) Covered by the
TEC Regulation?
A facility covered by CWT that also cleans tank interiors is subject solely to the
CWT regulation. At a CWT facility, tank cleaning wastewater is considered
"wastewater generated from tank cleaning associated with other industrial, com-
mercial, or POTW operations" and is thus excluded from the TEC regulation. (See
Section 442.1 (b)(l).) At a CWT facility, tank cleaning wastewater is considered a
process wastewater and is subject to the guidelines established under the CWT
point source category. (See Section 437.2(d) and 437.1(b)(10).)
If A Facility Does Not Meet Any of The Exclusion Criteria Listed
Above, Is It Necessarily Subject To This Rule?
EPA believes that its exclusion for other industrial, commercial, or POTW facili-
ties allows considerable discretion in determining if the tank cleanings are per-
formed as part of, or in addition to, the facility's on-site processes.
For guidance in exercising this discretion, the permitting or pretreatment con-
trol authority should consider EPA's rationale for the exclusion for tank cleanings
operated in conjunction with other industrial, commercial, or POTW operations.
This rationale includes: 1) the wastewater generated from tank cleaning opera-
tions at these facilities is typically a very small percentage of the total flow, 2) that
tank cleaning wastewater is typically included in the coverage of other categorical
standards that may apply, and 3) that the characteristics of the tank cleaning
wastewater are similar in treatability to the wastewater generated at the rest of
the facility.
Case studies further illustrating the applicability of the TEC effluent limitations
guidelines and standards are included in Section 7 of this document.
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Section 2
Identify facility and cargo information
Does the facility clean the interiors of tank
trucks, rail tank cars, intermodal tank cars, tank
barges, or ocean/sea tankers?
Yes
Is all tank cleaning performed for
purposes of repair and/or maintenance
of the tank?
No
Is all tank cleaning performed in conjunction
with other industrial, commercial, or publicly
owned treatment works (POTW) operations
and is the cleaning limited to tanks that are
associated with the facility's on-site processes?
No
Does the facility discharge 100,000 gallons or
more per year of TEC process wastewater (not
including wastewater generated for purposes of
repair and/or maintenance and not including
wastewater generated from tanks associated
with the facility's on-site processes)?
Yes
Does the facility clean only tanks
that transport food grade products?
No
Facility
is covered by
regulation
No
Yes
Yes
Facility
is not covered
by regulation
No
Yes
Does the facility discharge to a POTW?
Yes
No
Figure 2-1. Determining Applicability of the Rule
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Section 3: Overview of NPDES Program and
National Pretreatment Program
This section presents a brief overview of the NPDES Program and the National
Pretreatment Program. For more background information regarding EPA's pro-
grams to develop national standards for point source categories, refer to the U.S.
EPA NPDES Permit Writer's Manual (EPA-833-B-96-003) and to the U.S. EPA
Industrial User Permitting Guidance Manual (EPA 833/R-89-001).
What is the NPDES Program?
Section 301(a) of the Clean Water Act prohibits the discharge of pollutants
except in compliance with CWA Section 402, among other sections. Section 402
authorizes the issuance of NPDES permits for direct dischargers (i.e., existing or
new industrial facilities that discharge process wastewaters from any point
sources into receiving waters). Permit writers must develop NPDES permits to
control these discharges using effluent limitations guidelines and water-quality-
based effluent limitations.
What are Effluent Limitations Guidelines?
EPA establishes effluent limitations guidelines to require a minimum level of
process control and treatment for industrial point sources. They are based on the
demonstrated performance of model process and treatment technologies that are
within the economic means of an industrial category. Although effluent limita-
tions guidelines are based on the performance of model process and treatment
technologies, EPA does not require the use of specific technologies; therefore, dis-
chargers are free to use any available control technique to meet the limitations.
What are Water-Quality-Based Effluent Limitations (WQBELs)?
All receiving waters have ambient water quality standards established by the
states or EPA to maintain and protect designated uses of the receiving water (e.g.,
aquatic life- warm water habitat, public water supply, primary contact recreation).
Permit writers may find that applying effluent limitations guidelines results in
pollutant discharges that exceed the water quality standards in particular receiv-
ing waters. In such cases, permit writers are required by the CWA and federal
guidelines to develop more stringent WQBELs for the pollutant to ensure that the
water quality standards are met. States can use the total maximum daily load
(TMDL) process as one way of quantifying the allowable pollutant loadings in
receiving waters, based on the relationship between pollution sources and in-
stream water quality standards.
Because EPA and state permitting authorities are familiar with their respective
water quality standards and knowledgeable in waste load allocations and other
procedures to maintain water quality standards, these issues are not addressed in
this document. To learn more about how TMDLs are developed, refer to Guidance
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for Water-Quality-Based Decisions: The TMDL Process (EPA 440/4-91-001). To learn
how to apply water quality standards in NPDES permits, refer to the Technical
Support Document for Water Quality-Based Toxics Control (EPA 505/2-90-001).
What is the National Pretreatment Program?
Section 402 (b) (8) of the CWA requires that permits for certain publicly owned
treatment works (POTWs) (i.e., those receiving pollutants from significant indus-
trial sources subject to pretreatment standards under CWA Section 307(b)) estab-
lish a pretreatment program to ensure compliance with these standards. EPA has
published national regulations to define the requirements of this POTW pretreat-
ment control program.
What are National Pretreatment Standards?
40 CFR Part 403.5(a)(l) generally prohibits users of a POTW (indirect discharg-
ers) from discharging pollutants that pass through or interfere with the POTW's
operation. Pass- through is a discharge that exits the POTW into waters of the
United States in quantities or concentrations that, alone or in conjunction with a
discharge or discharges from other sources, violates any requirements of the
POTW's NPDES permit. Interference is defined as a discharge that, alone or in
conjunction with a discharge or discharges from other sources, both: (1) inhibits or
disrupts the POTW, its treatment processes, or its operations, or its sludge
processes, use or disposal; and (2) causes the POTW to violate any requirement of
its NPDES permit, or prevents sewage sludge use, or disposal (40 CFR Part 403.3).
40 CFR Part 403.5(c) and 40 CFR Part 403.8 specify that POTWs that have
design flows greater than 5.0 million gallons per day (mgd) and that receive pol-
lutants that pass through or interfere with their operations, or are otherwise sub-
ject to categorical pretreatment standards must develop and enforce local limits to
comply with the National Pretreatment Standards.
How are Effluent Limitations Guidelines and
Standards Applied?
With the August 14, 2000 promulgation of the regulation, EPA established BPT,
BCT, BAT, NSPS, PSES, and PSNS for the Transportation Equipment Cleaning
Point Source Category, which are summarized in the following table.
10
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Overview of NPDES Program and National Pretreatment Program
Program
NPDES Permit
Program
National
Pretreatment
Program
Type of Discharger
Direct Discharger
Indirect Discharger
Existing or New
Source
Existing Source
New Source
Existing Source
New Source
Applicable Effluent
Limitations
Guidelines and
Standards
BPT
BCT
BAT
NSPS
PSES
PSNS
TEC facilities that discharge waters to receiving streams or POTWs may be
required to meet one (or more) of the following effluent limitations guidelines and
standards established by the CWA. For the TEC Point Source Category, effluent
limitations for BPT, BCT, BAT, and NSPS are equivalent. Similarly, pretreatment
standards for existing sources and new sources are equivalent.
Acronym
BPT
BCT
BAT
NSPS
PSES
PSNS
Is:
Best practicable control
technology currently available
Best conventional pollutant
control technology
Best available technology
economically achievable
New source performance
standards
Pretreatment standards for
existing sources
Pretreatment standards for
new sources
Guideline or standard for the control of:
Toxic, nonconventional, and conventional
pollutants at an existing direct discharger
Conventional pollutants at an existing direct
discharger
Toxic and nonconventional pollutants at an
existing direct discharger
Toxic, nonconventional, and conventional
pollutants at a new source, direct discharger
Toxic and nonconventional pollutants at an
existing indirect discharger
Toxic and nonconventional pollutants at a
new source, indirect discharger
11
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Section 4: What are the Effluent Limitations
Guidelines and Standards for Subparts A
through D?
This section presents the numerical effluent limitations guidelines and stan-
dards for TEC facilities in Subparts A through D and the technologies on which
they are based. This section also discusses where facilities are required to demon-
strate compliance.
Indirect dischargers in Subparts A and B (tank trucks, intermodal tank contain-
ers, and rail tank cars transporting chemical and petroleum cargos) have the
option of complying with a Pollutant Management Plan in place of meeting the
numeric pretreatment standards presented in this section. See Section 5 for more
information on the Pollutant Management Plan.
What are the Regulatory Bases for Effluent
Limitations Guidelines and Standards for
Subparts A through D?
EPA established numerical effluent limitations guidelines and pretreatment
standards for Subparts A through D based on model process technologies and
wastewater treatment technologies. Although effluent guidelines and pretreat-
ment standards must be applied in the NPDES permit or pretreatment control
agreement, facilities in these subcategories are not required to implement the spe-
cific technologies upon which the limitations are based. Facility owners and oper-
ators may use any combination of process technologies and in-process or
end-of-pipe wastewater treatment technologies to comply with the numeric efflu-
ent limitations guidelines and pretreatment standards. EPA also established a reg-
ulatory compliance option for indirect dischargers in Subparts A and B to comply
with a pollution prevention option (based on development and implementation of
a Pollutant Management Plan).
What are the Model Process Technologies and Treatment
Systems?
Table 4-1 lists the model technologies used to form the regulatory bases of BPT,
BCT, BAT, NSPS, PSES, and PSNS. Refer to the Technical Development Document for
Effluent Limitations Guidelines and Standards for the Transportation Equipment
Cleaning Point Source Category (EPA-821-R-00-012, June 2000, http://www.epa.gov/
ost/guide) for a complete description of each technology element.
12
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Effluent Limitations Guidelines and Standards for Subparts A through D
Table 4-1. Model Technologies as the Regulatory Bases for the TEC Industry
Subpart
Subpart A — Tank
Trucks and Intermodal
Tank Containers
Transporting Chemical
and Petroleum Cargos
Subpart B— Rail
Tank Cars
Transporting Chemical
and Petroleum Cargos
Subpart C — Tank
Barges and
Ocean/Sea Tankers
Transporting Chemical
and Petroleum Cargos
Subpart D — Tanks
Transporting Food
Grade Cargos
Regulation
BPT, BCT,
BAT, and
NSPS
PSES and
PSNS
BPT, BCT,
BAT, and
NSPS
PSES and
PSNS
BPT, BCT,
BAT, and
NSPS
PSES and
PSNS
BPT, BCT,
and NSPS
Technology Basis
Equalization, Oil/Water Separation, Chemical
Oxidation, Neutralization, Coagulation, Clarification
Biological Treatment, Activated Carbon Adsorption,
and Sludge Dewatering.
Equalization, Oil/Water Separation, Chemical
Oxidation, Neutralization, Coagulation, Clarification,
and Sludge Dewatering.
Oil/Water Separation, Equalization, Dissolved Air
Flotation (with Flocculation and pH Adjustment),
Biological Treatment, and Sludge Dewatering.
Oil/Water Separation, Equalization, Dissolved Air
Flotation (with Flocculation and pH Adjustment),
and Sludge Dewatering.
Oil/Water Separation, Dissolved Air Flotation, Filter
Press, 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.
What are the Pollution Prevention Elements Incorporated Into
the Regulatory Bases?
EPA considered pollution prevention controls and water conservation practices
when designing the regulatory bases. EPA incorporated good heel removal and
management practices into all technology options. (Heel is residual cargo remain-
ing in tanks following unloading.) TEC facilities incur significant environmental
and economic benefits by implementing an effective heel minimization program.
To achieve these benefits, TEC facilities should use appropriate heel reduction
techniques, such as performing a hot or cold water prerinse, or steaming the tank
to improve heel removal.
In addition, TEC facilities can benefit from reducing the volume of wastewater
they discharge. EPA did not include flow reduction in the regulatory bases; how-
ever, EPA believes that facilities will incorporate flow reduction in their compli-
ance strategy. Section 7.0 of the Technical Development Document for Effluent
Limitations Guidelines and Standards for the Transportation Equipment Cleaning Point
Source Category (EPA- 821-R-00-012, June 2000, http://www.epa.gov/ost/guide) dis-
cusses heel reduction techniques and water conservation practices in detail.
13
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Section 4
Numerical Effluent Limitations Guidelines and
Standards
Tables 4-2 through 4-5 present the BPT, BCT, BAT, and NSPS limitations for
existing and new direct dischargers with operations in Subparts A through D,
respectively. EPA has reserved BAT limitations for Subpart D (Tanks Transporting
Food Grade Cargos).
Note that EPA proposed effluent limitations and pretreatment standards for
chromium in Subpart A; however, EPA did not promulgate effluent limitations
and pretreatment standards for chromium for reasons described in the Preamble
for the TEC rule. EPA sampling of raw wastewater at TEC facilities found a maxi-
mum concentration of 18.6 mg/L (although the average concentration was 2.4
mg/L). Exterior acid washing is a common service that tank truck facilities pro-
vide to their customers to brighten and remove the tarnish from the chrome parts
of a tank truck. This service may leach chromium from the external truck parts.
Best management practices or adequate pretreatment may be required to control
pollutants generated by such washings.
Table 4-2. Subpart A—Tank Trucks and Intermodal Tank Containers
Transporting Chemical and Petroleum Cargos: BPT, BCT, BAT,
and NSPS Concentration-Based Limitations for Discharges to
Surface Waters
Pollutant or Pollutant Property
BOD5
TSS
Oil and grease (HEM)
PH
Copper
Mercury
[mg/L]
Maximum for Any
One Day
61
58
36
(a)
0.84
0.0031
Monthly Average
22
26
16
(a)
NA
NA
(a) Within 6 to 9 at all times.
NA - Not applicable.
14
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Effluent Limitations Guidelines and Standards for Subparts A through D
Table 4-3. Subpart B—Rail Tank Cars Transporting Chemical and Petroleum
Cargos: BPT, BCT, BAT, and NSPS Concentration-
Based Limitations for Discharges to Surface Waters
Pollutant or Pollutant Property
BOD5
TSS
Oil and grease (HEM)
PH
Fluoranthane
Phenanthrene
[mg/L]
Maximum for Any
One Day
61
58
36
(a)
0.076
0.34
Monthly Average
22
26
16
(a)
NA
NA
(a) Within 6 to 9 at all times.
NA - Not applicable.
Table 4-4. Subpart C— Tank Barges and Ocean/Sea Tankers Transporting
Chemical and Petroleum Cargos: BPT, BCT, BAT, and NSPS
Concentration-Based Limitations for Discharges to Surface
Waters
Pollutant or Pollutant Property
BOD5
TSS
Oil and grease (HEM)
PH
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Zinc
[mg/L]
Maximum for Any
One Day
61
58
36
(a)
0.020
0.42
0.10
0.14
0.0013
0.58
8.3
Monthly Average
22
26
16
(a)
NA
NA
NA
NA
NA
NA
NA
(a) Within 6 to 9 at all times.
NA - Not applicable.
15
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Table 4-5. Subpart D—Tanks Transporting Food Grade Cargos: BPT, BCT,
and NSPS Concentration-Based Limitations for Discharges to
Surface Waters
Pollutant or Pollutant Property
BOD5
TSS
Oil and grease (HEM)
PH
[mg/L]
Maximum for Any
One Day
56
230
20
(a)
Monthly Average
24
86
8.8
(a)
(a) Within 6 to 9 at all times.
Tables 4-6 and 4-7 present the concentration-based limitations for existing and
new indirect dischargers in Subparts A and B, respectively, that choose not to use
the pollution prevention compliance option (see Section 5 for more information).
Table 4-8 shows the concentration-based limitations for those facilities in Subpart
C.
Table 4-6. Subpart A—Tank Trucks and Intermodal Tank Containers
Transporting Chemical and Petroleum Cargos: PSES and PSNS
Concentration-Based Limitations for Discharges to POTWs
Note! Indirect dischargers
in Subparts A and B have the
option of complying with a
Pollutant Management Plan
in lieu of numeric limits. See
Section 5 for details.
Pollutant or Pollutant Property
Nonpolar material
(SGT-HEM)
Copper
Mercury
Maximum for Any One
Day (mg/L)
26
0.84
0.0031
Note! Indirect dischargers
in Subparts A and B have the
option of complying with a
Pollutant Management Plan
in lieu of numeric limits. See
Section 5 for details.
Table 4-7. Subpart B—Rail Tank Cars Transporting Chemical and
Petroleum Cargos: PSES and PSNS Concentration-Based
Limitations for Discharges to POTWs
Pollutant or Pollutant Property
Nonpolar material (SGT-HEM)
Fluoranthene
Phenanthrene
Maximum for Any One
Day (mg/L)
26
0.076
0.34
16
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Effluent Limitations Guidelines and Standards for Subparts A through D
Table 4-8. Subpart C—Tank Barges and Ocean/Sea Tankers Transporting
Chemical and Petroleum Cargos: PSES and PSNS
Concentration-Based Limitations for Discharges to POTWs
Pollutant or Pollutant Property
Nonpolar material (SGT-HEM)
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Zinc
Maximum for Any One Day (mg/L)
26
0.020
0.42
0.10
0.14
0.0031
0.58
8.3
Where Are Facilities Required to Demonstrate
Compliance with the Numerical Limitations and
Standards?
BPT, BCT, BAT, and NSPS for the TEC industry are end-of-pipe limitations that
apply to the process wastewater fraction of the final effluent at the point of dis-
charge to waters of the United States. PSES and PSNS are applicable to the final
effluent at the point of discharge to the POTW sewer system.
17
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Section 5: What is the Pollutant Management
Plan and How Can It Be Used To Demonstrate
Compliance With the TEC Effluent
Limitations Guidelines and Standards?
Note! Only indirect dis-
chargers in Subparts A and B
have the option of comply-
ing with a Pollutant
Management Plan in lieu of
numeric limits.
When developing the rule, EPA identified and evaluated a number of pollution
prevention controls applicable to the TEC industry, including the use of dedicated
tanks, heel minimization, water conservation practices, and reduction in the toxic-
ity and amount of chemical cleaning solutions. These controls are also described
in more detail in Section 7.0 of the Technical Development Document for the
Transportation Equipment Cleaning Point Source Category (EPA-821-R-00-012,
http://www.epa.gov/ost/guide). EPA identified these controls as voluntary prac-
tices that many facilities in the industry were already implementing as environ-
mental controls. POTWs have also required such practices as part of their local
pretreatment requirements.
EPA believes that pollution prevention and effective pollutant management are
appropriate and effective ways of reducing pollutant discharges from Subparts A
and B facilities (tank trucks, intermodal tank containers, and rail tank cars trans-
porting chemical and petroleum cargos). Therefore, for indirect dischargers in
these two subparts, EPA provided two compliance options to allow owners and
operators maximum flexibility to meet these standards: comply with a pollution
prevention option (based on development and implementation of a Pollutant
Management Plan (PMP)), or meet a set of numeric limits at the discharge point.
The PMP is described below.
EPA has determined that a PMP is an appropriate compliance alternative to the
numeric pretreatment standards. Therefore, a facility using the PMP option does
not have to conduct numeric pollutant monitoring in order to demonstrate com-
pliance. A pretreatment authority may still establish local limits where necessary
to prevent pass-through or interference. However, EPA considers compliance with
the components of the PMP sufficient to demostrate compliance with PSES and
PSNS.
Facilities that elect the pollution prevention compliance option must also meet
the paperwork requirements under the General Pretreatment Regulation (40 CFR
403), such as submittal of a baseline monitoring report (BMR) (40 CFR 403.12(b)).
Guidance on the requirements of the BMR for TEC facilities electing the pollution
prevention compliance option is included in Appendix B.
Overview of the Pollutant Management Plan
The PMP is an effective alternative for indirect dischargers in Subparts A and B
to reduce pollutant discharges. The PMP consists of 10 provisions that a facility is
to meet to achieve an allowable discharge. A PMP may be a less costly method of
compliance than meeting numeric standards for these subcategories due to sav-
ings of additional monitoring and treatment costs. Each facility subject to the final
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Pollutant Management Plan
TEC rule will need to choose how to comply with the regulation (i.e., comply with
the numeric pretreatment standards or agree to develop and implement a PMP).
Facilities will also need to agree to make the PMP enforceable, meaning the facili-
ty would agree to include it in its individual control mechanism or POTW permit.
Facilities should work closely with permit writers to develop a plan that effec-
tively protects the environment, results in pollutant source reduction and waste
minimization, and adequately prevents POTW pass-through and interference.
How Does a Facility Demonstrate Compliance
with the Plan?
If a facility chooses to develop and implement a PMP, it must notify the appro-
priate control authority of its intent to achieve the pollution prevention allowable
discharge pretreatment standard1 prior to obtaining, renewing, or modifying its
individual control mechanism or POTW permit. To do this, a facility should sub-
mit to the control authority a statement of its intent to implement a PMP, which
must be certified by the responsible corporate officer as defined in 40 CFR
403.12(1). A responsible corporate officer is defined as "(i) a president, secretary,
treasurer, or vice-president of the corporation in charge of a principal business
function, or any other person who performs similar policy- or decision-making
functions for the corporation, or (ii) the manager of one or more manufacturing,
production, or operation facilities employing more than 250 persons or having
gross annual sales or expenditures exceeding $25 million (in second-quarter 1980
dollars), if authority to sign documents has been assigned or delegated to the
manager in accordance with corporate procedures." The certification should state
that the facility intends to develop and implement a PMP to comply with the rule.
The facility will submit a copy of its PMP, as described below, to the control
authority at the time the facility applies to obtain, renew, or modify the individual
control mechanism or POTW permit. The facility must maintain a copy of the
PMP on site and make it available for inspection. This paperwork must be avail-
able to the control authority and enforcement officials, and must document the
compliance option chosen by the facility.
Components of the Pollutant Management Plan
According to 40 CFR 442, the PMP (Plan) will include the following compo-
nents:
(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 treatment at the POTW, the
Plan shall provide that heels be fully drained, segregated from other waste-
waters, and handled in an appropriate manner;
1 40 CFR 442, pollution prevention allowable discharge means the quantity of/concentrations of pollutants in wastewaters being discharged
to POTWs after a facility has demonstrated compliance with the PMP provisions.
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(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 pre-
solve 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, deter-
gents, or other cleaning or brightening solutions);
(vii) provisions for appropriate recycling or reuse of segregated wastewaters
(including heels and prerinse/presteam wastes);
(viii) provisions for off-site treatment or disposal, or effective pretreatment of
segregated wastewaters (including heels, prerinse/presteam wastes, spent
cleaning solutions);
(ix) information on the volumes, content, and chemical characteristics of clean-
ing agents used in cleaning or brightening operations; and
(x) provisions for maintaining appropriate records of heel management proce-
dures, prerinse/presteam management procedures, cleaning agent manage-
ment procedures, operator training, and proper operation and maintenance of
any pretreatment system.
These components are described in detail below.
(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
The PMP will outline these procedures; however, the POTW should work with
the facility to identify which pollutants may not be compatible with its sewer lines
or treatment system so that the facility can appropriately manage cargos contain-
ing these pollutants. It is critical that the facilities identify these pollutants before
the cargos are cleaned. Rinse waters that contain pesticides, herbicides, hazardous
waste, priority pollutants, heavy metals, or dioxins may not be compatible with
biological treatment or sludge management at a POTW.
Based on responses to EPA's TECI 1994 Detailed Questionnaire, facilities poten-
tially have methods available to identify the commodities or cargos transported in
tanks accepted for cleaning. These methods include:
• Bill of lading;
• Material Safety Data Sheet (MSDS);
• Hazardous waste manifest;
20
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Pollutant Management Plan
• Verbal description;
• Placards; and
• Facility cleaning certifications.
Most facilities use both the bill of lading and MSDSs to identify the cargo and
its chemical components.
As an example, several facilities have implemented computer tracking systems
to streamline the identification process. Such systems typically store information
in a comprehensive database about a particular fleet or carrier, the cargos cleaned,
and the chemical content of the cargos. The database stores historical records and
documents the appropriate management of incompatible cargos.
However, based on information that EPA obtained during facility site visits,
MSDSs are not required and may not be available. In some cases, drivers may
know the cargo hazard class, but may not have a proper cargo shipping name,
which identifies chemical contents. In other cases, shipping names such as "Not
otherwise indicated" or "Not otherwise specified" are used, which are not suffi-
cient to identify the chemical contents of the cargo. The PMP for facilities that
accept tanks that contain such unidentified cargos should provide a basis for
determining whether cleaning would result in discharges of pollutants that would
be incompatible with treatment at a POTW.
(ii) For cargos identified as being incompatible with treatment at the POTW,
the Plan shall provide that heels be fully drained, segregated from other waste-
waters, and handled in an appropriate manner
Facilities that identify incompatible cargos in item (i) are required to implement
the item (ii) provisions. As required by component (ii), after draining and segre-
gating heels from other wastewater, facilities must handle these heels appropriate-
ly, as discussed below.
Incompatible heels can be segregated into drums or tanks either for disposal by
landfilling or incineration, or for reuse by alternative means (which may include
reuse on site, return to the consignee, or sale to a reclamation facility) or for on-
site pretreatment. Facilities may reuse heels comprising soaps, detergents, sol-
vents, acids, or alkalis as tank cleaning solutions or as neutralizers for future heels
and for wastewater treatment.
According to the TECI 1994 Detailed Questionnaire, the largest volumes of
heels are reused or recycled off site. The largest percentage of reused or recycled
heel consists of food grade products, petroleum and coal products, organic and
inorganic chemicals, and chemical products. Heel from food grade products is
often reused as animal feed; heel from petroleum and coal products is typically
sold for product recovery.
The most common methods of heel disposal reported in the Detailed
Questionnaire include:
• Discharge with tank cleaning wastewater;
• Discharge or haul separately from tank cleaning wastewater to a centralized
waste treater (CWT);
21
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• Discharge or haul separately from tank cleaning wastewater to a hazardous
waste treatment, storage, and disposal facility (TSDF);
• Evaporation;
• On-site or off-site land disposal;
• On-site or off-site land application;
• On-site or off-site incineration;
• On-site or off-site heat recovery;
• On-site or off-site reuse or recycle; and
• Deep-well injection.
(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 treat-
ment at the POTW
Facilities that identify incompatible cargos in item (i) are required to carry out
the item (iii) provisions. Appropriate handling of prerinse/presteam wastewaters
typically includes recycle/reuse, off-site treatment or disposal, or on-site pretreat-
ment that has been demonstrated to sufficiently reduce the pollutant level to pre-
vent pass-through or interference (as described in item (viii)).
During or after heel removal and before cleaning the tank, TEC facilities rinse
the tank interior with a short burst of water (e.g., 5 to 10 seconds) to remove addi-
tional heel that adheres to the tank's interior, or apply steam to the tank interior
and collect the steam condensate that contains residual heel. Purposes of the pre-
rinse or presteam include: (1) enhancing heel removal; (2) minimizing the amount
of heel ultimately contained in tank cleaning wastewater (pollution prevention);
(3) extending the service life of tank cleaning solutions by reducing solution con-
tamination from tank heel; and (4) protecting the facility and POTW wastewater
treatment system, which may not be designed to treat residual heel. Incompatible
prerinse/presteam wastewater may be segregated into drums or tanks for appro-
priate handling.
(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 han-
dled 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
Appropriate handling of spent cleaning solutions typically includes regenera-
tion of the solutions, off-site treatment or disposal, or pretreatment that has been
demonstrated to sufficiently reduce the pollutant level to prevent pass-through or
interference (as described in item (viii)).
For many cargo types, facilities may have to use chemical cleaning solutions in
the tank cleaning process. Responses to the TECI 1994 Detailed Questionnaire
22
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Pollutant Management Plan
indicate that facilities typically use four types of cleaning solutions: (1) acid solu-
tion; (2) caustic solution; (3) detergent solution; and (4) presolve solution.
Acid solutions most commonly used by TEC facilities are composed of hydroflu-
oric and/or phosphoric acid and water. Facilities use these acid solutions for tank
interior washing and for tank exterior washing to brighten aluminum and stainless
steel tank exteriors. Best management practices or adequate pretreatment may be
required to control pollutants generated by such washings.
Caustic solutions typically are a mixture of sodium hydroxide and water in dif-
ferent proportions. The most common ingredients in detergent solutions are sodium
metasilicate and phosphate-based surfactants. Some facilities use off-the-shelf
brands of detergent solutions such as Tide®, Arm & Hammer®, and Pine Power®.
Often, concentrated detergents ("boosters") such as glycol ethers or esters are added
to acid and caustic solutions to improve their effectiveness.
Presolve solutions usually consist of diesel fuel, kerosene, or some other petrole-
um-based solvent. Other miscellaneous chemical cleaning solutions include passiva-
tion 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 TECI 1994 Detailed Questionnaire indicate no obvious trends
between the chemical cleaning solutions used and the cargo types cleaned (i.e., facil-
ities reported using each chemical cleaning solution category to clean all types of
cargos). The chemical cleaning solutions used depend on facility preference, cus-
tomer preference, wastewater treatment system compatibility, and/or POTW limita-
tions.
Facilities may haul spent cleaning solutions off site for treatment or disposal or
discharge them to their on-site wastewater treatment system, if compatible. Most
facilities currently reuse their cleaning solutions and then discharge one or more
spent cleaning solutions to their on-site wastewater treatment system.
(v) Provisions for appropriate recycling or reuse of cleaning agents
The PMP is to include provisions for recycle or reuse of cleaning agents. As men-
tioned in item (iv), many facilities currently reuse or recycle their cleaning solutions.
The facilities generally reuse chemical cleaning solutions until they are no longer
effective, as determined by cleaning personnel based either on experience or chemi-
cal testing (e.g., titration). Facility personnel periodically add make-up solution to
replace solution lost in the final rinse or to boost efficacy. Once cleaning solutions
have become spent, or are no longer effective, they must be either treated in on-site
wastewater treatment systems or hauled off site for treatment or disposal.
Most TEC facilities that discharge chemical cleaning solutions with their tank
cleaning wastewater recycle and reuse the solutions at least once prior to discharge.
Facilities usually use automated cleaning systems or cleaning solution recirculation
loops to reuse the cleaning solutions until their efficacy diminishes below accepted
levels. This reduces the amount of additional chemical cleaning solution required
for each tank cleaned; instead, smaller amounts of make-up solution are periodical-
ly added to replace solution lost in the final rinse or to boost efficacy. Recycle and
reuse of heated cleaning solutions also reduces energy requirements.
23
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(vi) Provisions for minimizing the use of toxic cleaning agents (solvents,
detergents, or other cleaning or brightening solutions)
To minimize the use of toxic cleaning agents, facilities could include provisions
such as recycling/reusing the toxic cleaning agents (see item (v)); reducing the
volume of cleaning solution used per tank; and/or substituting less toxic cleaning
agents.
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 caus-
tic solutions to which detergent "boosters" (e.g., glycol ethers or esters) are added
to improve their effectiveness.
Other toxic and hazardous cleaning agents that may be used by a few TEC
facilities include chlorinated organic solvents and hydrofluoric acid brighteners.
Facilities could look for potential substitutes for these cleaning agents, such as
nonchlorinated solvents and detergents. Detergent "boosters" or alkaline bright-
eners additives can improve effectiveness.
Some facilities may reduce or eliminate their use of chemical cleaning solutions
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.
Facilities can reduce the amount of toxicity of chemical cleaning solutions by
having written cleaning process standard operating procedures and pollution pre-
vention plans that their cleaning personnel carefully follow. Facilities could con-
duct ongoing training to ensure that their cleaning personnel practice the
procedures contained in these resources at all times.
(vii) Provisions for appropriate recycling or reuse of segregated wastewaters
(including heels and prerinse/presteam wastes)
Facilities should initially assess whether recycling or reuse of these wastewaters
is appropriate. As discussed in item (ii), most segregated heels are reused or
recycled on or off site.
Facilities do not generally reuse prerinse or presteam wastewater on site
because of the high water content and high pollutant loadings associated with
these streams. However, they should evaluate their wastewater to determine
whether it is feasible to reuse or recycle any or all wastewaters, either in tank
cleaning operations, or for some other purpose.
There are several ways to reuse and recycle heel. One method is to return the
heel to the consignee. Another method is to reuse heels at the facility. For exam-
ple, facilities can use fuel and fuel oil heels in their on-site boilers or in their own
transportation equipment. They can also reuse heels comprising soaps, detergents,
solvents, acids, or alkalis for tank cleaning, neutralization, or wastewater treat-
ment. Many food grade heels can be recycled as animal feed. Some heels, such as
24
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Pollutant Management Plan
fertilizers, can be segregated, stored, and sold as product. The PMP will identify
appropriate procedures for heel reuse and recycling processes.
(viii) Provisions for off-site treatment or disposal, or effective pretreatment
of segregated wastewaters (including heels, prerinse/presteam wastes, spent
cleaning solutions)
As described in items (ii), (ill), and (iv), the PMP should specify that the facility
will appropriately handle segregated wastewaters and spent cleaning solutions by
means such as off-site treatment or disposal, or demonstrate that pretreatment has
sufficiently reduced pollutant levels to prevent pass-through or interference.
The most common method of heel disposal is land disposal, which is used
most frequently for petroleum and coal product heels and for dry-bulk cargo
heels. Land application, deep-well injection, and incineration are possible meth-
ods, but rarely used. Facilities may also haul heels to a privately owned treatment
works, federally owned treatment works, centralized waste treater, ballast water
treatment facility, or hazardous waste treatment, storage, and disposal facility, all
of which may be better equipped to treat these wastes.
Facilities may dispose of prerinse/presteam waste off site because it is not easi-
ly pretreated or reused on site. Facilities can also haul prerinse/presteam waste-
water to a facility that may be better equipped to treat these wastes.
Spent cleaning solutions may be hauled off site for disposal, discharged to the
on-site wastewater treatment system if compatible, or hauled off site to a facility
that is better equipped to treat these concentrated chemical wastes. Facilities can
combine off-site disposal with recirculating and reusing of chemical cleaning solu-
tions to reduce the need for fresh cleaning solution and to minimize the amount
of cleaning solutions that enter their wastewater treatment system.
Facilities may also choose to pretreat segregated wastewaters on site, and dis-
charge these wastewaters with other TEC process wastewater. In this case, the
facility would have to demonstrate that the pretreatment is effective for the pre-
vention of pass through and interference. On-site wastewater pretreatment may
include any one or a combination of physical, chemical, and biological processes
as needed to remove pollutants from TEC wastewater prior to discharge to a
POTW. Some technologies for pretreatment include:
• Equalization;
• Gravity settling;
• pH adjustment;
• Oil/water separation;
• Dissolved air flotation;
• Coagulation/flocculation; and
• Clarification.
Section 7.0 of the Technical Development Document for the Transportation
Equipment Cleaning Point Source Category (EPA-821-R-00-012,
http://www.epa.gov/ost/guide) describes these technologies in greater detail.
25
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Facilities choosing to pretreat and discharge segregated wastewaters must
include a description of the treatment system in their PMP sufficient to demon-
strate effective pretreatment. Information about treatment systems typically avail-
able at a facility may include:
• Process flow diagram;
• Operating conditions;
• Chemical usage;
• Maintenance and inspection schedules;
• Past effluent monitoring data.
Facilities choosing to implement EPA's technology bases for PSES and PSNS
may state that the technology bases were demonstrated by EPA to reduce pollu-
tant levels to prevent pass-through or interference.
(ix) Information on the volumes, content, and chemical characteristics of
cleaning agents used in cleaning or brightening operations
Each PMP will specify its own record-keeping requirements for this informa-
tion. For example, facilities may develop and maintain a cleaning agents use log
which includes chemical purchase records and corresponding material safety data
sheets (MSDSs). The log may also describe chemical solution preparation steps
performed on site, such as dilution or use of additives not included in the original
formulation. Facilities can use the data stored in records to analyze trends in their
use of cleaning or brightening agents as well as to identify alternative agents and
minimize use.
(x) Provisions for maintaining appropriate records of heel management pro-
cedures, prerinse/presteam management procedures, cleaning agent manage-
ment procedures, operator training, and proper operation and maintenance of
any pretreatment system.
Each PMP will specify its own record-keeping requirements for this informa-
tion. For example, facilities may develop and maintain log entries for each of
these operations. As in item (ix), facilities can use data stored in records to analyze
trends and compliance in heel management procedures, prerinse/presteam man-
agement procedures, cleaning agent management procedures, operator training,
and proper operation and maintenance of any pretreatment system.
Heel Management Procedures
Most facilities currently do not maintain heel management logs. Some facilities
maintain waste heel disposal logs (e.g., drum disposal logs), but do not record
specific cargos and heel volumes removed from tanks. Therefore, EPA anticipates
that two log entries could be kept to document heel management procedures.
First, a facility heel removal log may record the following information for cargos
identified as incompatible with treatment at the POTW (items (i) and (ii) of the
PMP): date, cargo, volume drained, and on-site storage (e.g., drum number).
Second, a facility may record information such as on-site storage (as a link to the
heel removal log), storage container capacity, accumulation start and end date,
ultimate disposition and date, and manifest number (if hazardous waste).
26
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Pollutant Management Plan
Facilities should ensure that heel management records demonstrate compliance
with provisions for heel recycling or reuse and ultimate disposition discussed in
items (vii) and (viii) of the PMP.
Many facilities implement measures to reduce the amount of heel received. The
most commonly practiced of these measures is to refuse or reject tanks for clean-
ing if they contain excessive heel. 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 that the product is completely
offloaded, and to eliminate the need to reject tanks for cleaning or to assess extra
fees. Heel removal log entries may also record the shipper, consignee, and driver
to help target heel reduction efforts.
Prerinse/Presteam Management Procedures
Appropriate records for prerinse/presteam management procedures may
include a log entry to record information similar to that recorded for heel manage-
ment. Because prerinse/presteam is required for cargos identified as being incom-
patible with treatment at a POTW, records should include a one-to-one
correspondence between heel removal and prerinse/presteam to document com-
pliance. Records should also demonstrate compliance with provisions for pre-
rinse/presteam waste recycling and reuse and ultimate disposition discussed in
items (vii) and (viii) of the PMP.
Cleaning Agent Management Procedures
Appropriate records for cleaning agent management procedures may include a
log entry to document compliance with provisions for appropriate recycling or
reuse of cleaning agents (items (v) of the PMP), minimizing use of toxic cleaning
solutions (item (vi) of the PMP), and appropriate management of spent solutions
(item (viii) of the PMP). Information recorded may include: cleaning agent, titra-
tion or other test results and date, makeup volume and date, volume when spent,
on-site storage, ultimate disposition and date, and manifest number (if hazardous
waste).
Operator Training
Operators will require training to understand and implement the provisions
and procedures of the PMP. In particular, tank cleaning personnel should be
appropriately trained to identify cargos, the cleaning of which is likely to result in
discharges of pollutants that would be incompatible with treatment at the POTW.
Wastewater treatment operators should be appropriately trained to operate the
system, use the correct treatment chemicals in appropriate quantities, and operate
the system within the stated design parameters (e.g., pH and flow rate).
Appropriate records for operator training may include log entries to document
operator training on heel management, prerinse/presteam waste management,
cleaning agent management, wastewater treatment operation and maintenance,
information collection, and record-keeping.
27
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Proper Operation and Maintenance of Any Pretreatment System
Examples of appropriate records for pretreatment systems include operating,
inspection, and maintenance and repair documents. Operating log entries may
record data for key operating parameters for each treatment unit. For example,
key operating parameters for chemical treatment units include typical wastewater
flow rate, chemicals used and chemical addition rates, and wastewater pH.
Inspection logs document inspections performed each operating shift to identify
spills and leaks and monitor equipment function (e.g., wastewater and sludge
pumps, chemical addition pumps, and pH monitors). Maintenance and repair log
entries may document system cleanout and residue management, parts replace-
ment, equipment repair and adjustment, and meter calibration.
Based on its knowledge of the industry, EPA believes that improper pretreat-
ment system operation and maintenance can significantly reduce pretreatment
efficiency. For example, during site visits and sampling episodes, EPA observed
pretreatment systems with excessive accumulation of settled solids and floating
oil and grease. Excessive settled solids and floating oil and grease can significantly
reduce treatment system capacity and wastewater detention times in treatment
units such as equalization, chemical treatment, and settling tanks. Excessive set-
tled solids can impede or interfere with treatment mechanisms such as air lines in
dissolved air flotation units. Excessive floating oil and grease can significantly
reduce the effective surface area of tubes and corrugated and/or inclines plates in
coalescing-type oil/water separators.
How Does a Facility Determine Whether to
Implement a Pollutant Management Plan or to
Comply With Numeric Limitations?
A facility subject to the TEC regulation must choose to comply with either the
PMP or with numeric limitations. EPA acknowledges that costs for some facilities
to comply with numeric limitations may be high relative to removals. In consider-
ing the wide variety of tanker cargos accepted for cleaning and the potentially
high cost of compliance with numeric limitations, EPA recognizes that one of the
most successful means of reducing the discharge of pollutants in wastewater may
be pollution prevention and source reduction. The pollution prevention compli-
ance option may be more cost-effective for those facilities already using good pol-
lution prevention practices and/or operating in accordance with a PMP. On the
other hand, it may be more cost-effective for facilities that already have extensive
wastewater treatment in place to comply with the numeric limitations.
Each facility may want to fully explore the costs associated with both compli-
ance options and then determine which option is more cost-effective. EPA has pro-
vided detailed cost estimates and cost equations for the treatment technologies
evaluated for BPT, BAT, and PSES. These cost equations can be found in Section
9.0 of the Technical Development Document for Effluent Limitations Guidelines and
Standards for the Transportation Equipment Cleaning Point Source Category (EPA-821-
R-00-012, June 2000, http://www.epa.gov/ost/guide).
28
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Section 6: How are Permits Developed for
Numerical Limitations?
This section describes the step-by-step process of establishing numerical permit
limits using effluent limitations guidelines and standards for facilities in Subparts
A through D. This discussion will help in establishing permits for these facilities.
Note that this discussion does not apply to facilities choosing to demonstrate
compliance using a PMP. See Section 5 for information on how to demonstrate
compliance using a PMP.
Reviewing Permit Applications
Direct dischargers (new and existing) must submit the following forms when
applying for an NPDES permit:
Form 1: Requests basic facility information and the SIC codes for the products manufactured.
Form 2C (existing sources) or Form 2D (new sources): Requests information on outfall locations, flow
characteristics, sources of pollutants, influent and effluent characteristics, pollutants expected to be present,
treatment technologies, and production information.
These forms, if completed properly, should provide the permit writer most of
the background information necessary to establish an NPDES permit. The permit
writer may wish to also visit facilities to gather more information.
Indirect dischargers or POTWs may request written certification from EPA on
whether they are subject to new pretreatment standards. New indirect dischargers
must request written certification from EPA prior to commencing discharge. Each
request describes which subcategories might be applicable along with evidence
and reasons why a particular subcategory is applicable and why others are not.
EPA will send the written certification to the facility and the POTW.
Indirect discharging facilities must meet the paperwork requirements under the
General Pretreatment Regulation (40 CFR 403), such as submittal of a baseline
monitoring report (BMR) (40 CFR 403.12(b)). The BMR, if completed properly,
should provide most of the background information necessary to establish an
individual control mechanism or POTW permit. The control authority may wish
to also visit facilities to gather more information.
Developing Permit Limits
Permit writers and control authorities must apply the effluent limitations
guidelines and standards developed by EPA to establish numerical permit limits
for facilities. Note that permits may also include WQBELs (see Section 2); howev-
er, this document focuses on developing permit limits based on effluent limita-
tions guidelines and standards for the TEC Point Source Category.
29
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The effluent limitations guidelines and standards for the TEC industry are con-
centration-based and adhere to the "building block" concept. Each regulated
wastestream in an outfall is typically assigned a mass-based discharge allowance
based on a calculation of its applicable concentration-based limitation and annual
average flow. The sum of the allowances is the total mass discharge allowance for
the outfall. In other words, the applicable permit limitations for facilities in more
than one subcategory is the sum of the mass loadings based upon production in
each subcategory and the respective subcategory effluent limitations guidelines.
Mass-based limitations for unregulated or dilution wastewater streams at direct
discharging facilities are established using best professional judgement.
Indirect dischargers are subject to mass-based limitations or alternative concen-
tration-based limitations. The permit writer may use the combined wastestream
formula (CWF) to establish pretreatment standards. The CWF (40 CFR 403.6(e)) is
a method for calculating alternative pollutant limits at industrial facilities where
regulated process effluent is mixed with other wastewaters (either regulated or
nonregulated) prior to treatment.
Permit limits are generally expressed in terms of allowable mass (in units of
pounds or kilograms) of pollutant per day. However, the TEC industry regula-
tions are concentration-based. To convert the concentration-based limitations to
mass-based limitations, the permit writer or control authority will need to accu-
rately determine the annual average process wastestream flow. The permit writer
or control authority may elect to include unregulated waste streams, which are
not regulated on a national level, in a facility permit. The permit writer or control
authority also decides if a facility may discharge an unregulated waste stream and
the conditions at which the facility may discharge the waste.
How are Annual Average Process Wastewater
Discharges Calculated?
When establishing the final limitations and standards, permit writers and con-
trol authorities must account for the facility's dilution and unregulated waste-
water contained in the discharged effluent to develop either mass-based or
concentration-based permit limits.
"Process wastewater" is defined, in general, by 40 CFR Part 122.2. TEC process
wastewater includes all wastewaters associated with cleaning the interiors of
tanks including: tank trucks, rail tank cars, intermodal tank containers, tank
barges, and ocean/sea tankers used to transport commodities or cargos 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 prerinse cleaning solutions, chemical cleaning solutions,
and final rinse solutions. Permit writers and control authorities must determine,
on a case-by-case basis, the appropriate process wastewater stream to be used in
developing mass-based limitations.
30
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How are Permits Developed for Numerical Limitations?
The annual average flow is defined as the average of daily flow measurements
calculated over at least a year; data from multiple years may be useful to calculate
a more representative average daily flow. It may be difficult to determine the
appropriate flow rate, since often TEC facilities may not know how many tanks
they will clean and, as a result, how much wastewater they will generate. In addi-
tion, it is difficult to know the types of cargos that will be cleaned, which may
vary the amount of wastewater generated. However, permit writers and control
authorities have flexibility when determining a facility's annual average flow rate.
For example, if a facility is expecting significant changes in production as evi-
denced by previous years' data, the permit writer or control authority may estab-
lish a flow rate expected to be representative during the permit term.
If no historical data or actual process wastewater flow data exist (such as for a
new source), permit writers and control authorities should reasonably estimate
the facility's projected flow. This may include a request for the facility to measure
process wastewater flows for a representative period of time to establish a flow
basis. Permit writers and control authorities are advised to establish a flow rate
that is expected to be representative during the entire term of the permit.
In cases where the wastewater discharge flow claimed by the facility appears to
be excessive, a more appropriate process wastewater discharge flow may be
developed to compute the mass-based limitations. Permit writers and control
authorities should review the following items to evaluate whether the facility's
process wastewater discharge flow is excessive.
• For the proposed rule, the Agency considered good water conservation prac-
tices to be represented by the median tank interior cleaning wastewater volume
discharged per tank cleaning (including non-TEC waste streams not easily seg-
regated) for each subcategory Table 6-1 presents these median wastewater
flows. While the median flow per tank may not be appropriate for some facili-
ties (because of variation due to
cargo cleaned, tank type and con Table 6-1. Median Wastewater Flows for the TEC Industry
struction, and tank condition),
most facilities should be able to
attain it.
• Table 6-2 provides wastewater gen-
eration rates for various cargo and
tank types.
EPA envisions that permit writers
and control authorities will compare
the wastewater flow discharged by a
specific facility to the industry aver-
ages presented in these tables. If a
facility discharges an excessive
amount of water, permit writers and
control authorities can then determine
if those flows are warranted by
reviewing records of the types of car-
gos and tanks cleaned at that facility.
Facility Type
Truck/Chemical
Rail/Chemical
Barge/Chemical & Petroleum
Truck/Food
Rail/Food
Barge/Food
Truck/Petroleum
Rail/Petroleum
Truck/Hopper
Rail/Hopper
Barge/Hopper
Median Flow
(gallons/tank)
605
2,091
4,857
790
4,500
4,500
193
193
144
267
712
31
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How are Permits Developed for Numerical Limitations?
How are Mass-Based Permit Limitations
Calculated?
After determining the facility's annual average process wastewater discharge
flow, permit writers and control authorities can use the annual average process
wastewater discharge flow or other established flow rate to convert concentration-
based limitations into mass-based limitations, using the following equation:
Lm = LC x Q x k
where: Lm = mass-based effluent limitation (Ibs/day)
Lc = concentration-based limitation (mg/L)
Q = average process wastewater discharge (gal/day)
k = unit conversion factor
In this example, the unit conversion factor, k, is used to convert from [(mg/L) x
(gal/day)] to (Ibs/day), as follows:
k =
0.264 gal
1'000mg
453.59 g
= 8.35 x
Ib
gal x mg
Should the Permit Include Limits Based on
Effluent Limitations Guidelines or WQBELs?
All receiving waters have water quality standards established by the states or
EPA that protect the designated uses of the receiving water. The effluent limita-
tions guidelines established by EPA cannot be less stringent than WQBELs. After
determining the allowable limits based on effluent limitations guidelines, permit
writers must compare them to the receiving water's WQBELs. If limits based on
effluent limitations guidelines for a particular pollutant result in discharges that
exceed the WQBELs for the receiving water, permit writers must establish permit
limits that are based on WQBELs (see Section 2 for more information regarding
WQBELs). Therefore, if upon reviewing the effect of a discharge on a receiving
water it is determined that technology-based permit limits are not sufficient to
meet these water quality standards, then permit writers have the authority to
require more stringent effluent limits.
Developing Monitoring Requirements
Permit writers and control authorities must also establish monitoring require-
ments for regulated facilities. NPDES permits require dischargers to monitor their
effluent to ensure that they are complying with permit limitations. As specified in
40 CFR Parts 122.41, 122.44, and 122.48, all NPDES permits must specify require-
ments for using, maintaining, and installing (if appropriate) monitoring equip-
ment, monitoring frequencies, analytical methods, and reporting and
record-keeping. Control authorities must generally require similar monitoring
techniques and frequencies for indirect dischargers.
33
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The NPDES program requires permittees to monitor pollutant mass (or other
applicable unit of measure), measure effluent volume, provide other measure-
ments (as appropriate), and use the test methods established at Part 136. It also
requires permittees (with certain specific exceptions) to monitor for limited pollu-
tants and report data at least once per year. Finally, it requires that all permits
specify requirements for the proper use, maintenance, and installation of monitor-
ing equipment or methods. All permits must also specify the required monitoring,
including the type, intervals, and frequency that will provide representative data.
Note! Permit writers should be aware that EPA has finalized revisions to 40 Part CFR 122.44(a), which
could be particularly relevant to the development of NPDES permits for the TEC Point Source Category
(see FR 30989, May 15, 2000). The revision requires that permits have limitations for all applicable guide-
line-listed pollutants but allows sampling requirements for guideline-listed pollutants to be waived on a
case-by-case basis if the dischargers can certify that the pollutant is not present in the discharge or pres-
ent in only background levels from intake water with no increase due to the activities of the dischargers.
New sources and new dischargers are not eligible for this waiver for their first permit term, and a permit
writer can re-establish monitoring through a minor modification to the permit if the discharger expands or
changes its process. Further, the permittee must notify the permit writer of any modifications that they
have implemented during the permit term and, if necessary, the permit writer can re-establish monitoring
through a minor modification. In specific cases, the permit writer may also elect to establish technology-
based permit limits for pollutants not covered by this regulation.
What are the Monitoring Locations?
Permit writers and control authorities are responsible for determining the most
appropriate monitoring location and specifying this in the permit. Permit writers
and control authorities must also select locations that are representative of the
expected wastewater discharge. The BPT, BCT, BAT, and NSPS effluent limitations
are end-of-pipe limitations that apply to the final effluent at the point of discharge
to waters of the United States. PSES and PSNS are applicable to an end-of-pipe
discharge at a point prior to discharge to the POTW sewer system.
The permit writer or control authority may need to establish internal monitor-
ing locations if a facility combines process and nonregulated wastewater prior to
discharge through a common outfall. There may be cases where, by combining
process and nonregulated wastewater, a facility may dilute a regulated pollutant
to the point where it is not detectable using approved analytical methods. By
establishing an internal monitoring point for the pollutant, the permit writer or
control authority will enable the facility to characterize the wastewater pollutant
before it is diluted with other wastewater. Permit writers and control authorities
also need to consider whether a facility should monitor the influent to a particular
wastewater treatment unit to determine influent wastewater characteristics and
treatment performance of the unit.
What are the Monitoring Frequencies?
Permit writers and control authorities are also responsible for determining an
appropriate frequency for compliance monitoring of all pollutants. EPA's monitor-
34
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How are Permits Developed for Numerical Limitations?
ing costs for this regulation assumed compliance monitoring four times per
month for conventional pollutants and once per month for priority and noncon-
ventional pollutants. These monitoring frequencies may be lower than those gen-
erally set by some permitting authorities; however, monitoring four times per
month for conventional pollutants should ensure that TEC processes and waste-
water treatment systems are properly operated to achieve the associated pollutant
long term averages. Monitoring once per month for toxic pollutants should be less
costly for regulated facilities while ensuring their processes and wastewater treat-
ment systems are designed and operated to control the discharge of toxic pollu-
tants.
Permit writers and control authorities should consider the nature of facility dis-
charges when determining appropriate sampling protocols for compliance moni-
toring. Twenty-four-hour composite samples are most appropriate for continuous
dischargers. For facilities with batch treatment or batch discharges, composite
samples collected during the discharge period are most appropriate. Facilities can
obtain the composite samples by collecting four or more grab samples and com-
positing the samples under chilled conditions, or by analyzing each grab sample
separately, and then calculating the composite as the mean of the individual grab
samples.
What are the Appropriate Analytical Methods?
Dischargers must use the test methods promulgated at 40 CFR Part 136.3 or
incorporated by reference in the tables at 40 Part CFR 136.3 to monitor their pollu-
tant discharges, unless otherwise specified by the permit writer or control authori-
ty. Regulated pollutants for the TEC Point Source Category include BOD5, TSS, oil
and grease (HEM), nonpolar material (SGT-HEM), cadmium, chromium, copper,
lead, mercury, nickel, zinc, fluoranthene, phenanthrene, and pH. (Not all pollu-
tants are regulated in all subparts.) EPA has approved test methods for all these
pollutants at 40 CFR Part 136.3.
EPA promulgated Method 1664, the analytical method for HEM and SGT-HEM,
on May 14, 1999 (see FR 26315) to support phasing out the of use of CFC-113. This
rulemaking revised 40 CFR Part 136 to list Method 1664 as an approved method
to analyze oil and grease and non-polar material (i.e., HEM and SGT-HEM). Note
that EPA, by extending the laboratory use exemption of CFC-113 through 2005,
will allow continued use of methods that use CFC-113; however, EPA strongly
encourages dischargers/generators/industrial users and permit authorities to
substitute use of Method 1664 for CFC-113 methods. EPA will use Method 1664 in
its wastewater program for regulation development, permit applications, and
compliance monitoring. Anticipating the promulgation of Method 1664, EPA ana-
lyzed all data in support of the TECI effluent limitations guidelines and standards
using Method 1664. Therefore, all effluent limitations promulgated for oil and
grease and nonpolar material in this effluent limitations guidelines and standards
are to be measured by Method 1664.
EPA analyzed metals in this rulemaking by EPA Method 1620. This method is a
consolidation of the EPA 200 series methods for the quantitative determination of
35
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27 trace metals by inductively coupled plasma (ICP) and graphite furnace atomic
adsorption (GFAA), and determination of mercury by cold vapor atomic adsorp-
tion (CVAA). (The method also provides a semiquantitative 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.
EPA analyzed semivolatile organics in this rulemaking using Method 1625C.
EPA recently published an amendment to EPA Methods 625 and 1625 that
expands the list of analytes that can be measured using these methods (see
Landfills final rule, 65 FR 3008, January 19, 2000). In 1998, EPA also proposed to
amend Methods 625 and 1625 to include additional pollutants to be measured
under effluent guidelines for the Centralized Waste Treatment Point Source
Category (64 FR 2345). Since then, EPA has gathered data on the capacity of these
methods to measure the additional pollutants. The modifications to Methods 625
and 1625 consist of text, performance data, and quality control (QC) acceptance
criteria for the additional analytes. EPA validated the QC acceptance criteria for
the additional analytes in single-laboratory studies that included TEC wastewater.
EPA approved the use of EPA Method 1625 (published at 40 CFR Part 136.3,
Appendix A) for fluoranthene and phenanthrene in the final TEC rule (65 FR 157).
Method 625 (also published at 40 CFR Part 136.3, Appendix A) may also be used
to monitor for fluoranthene and phenanthrene, since these two analytes are listed
in that method for general application.
What is the Minimum Level of Detection?
The minimum level (ML) specified for each method is the lowest level at which
laboratories calibrate their equipment. To achieve this, laboratories use standards
(i.e., samples at several known concentrations). Calibration is necessary because
laboratory equipment does not measure concentration directly, but generates sig-
nals or responses from analytical instruments that must be converted to concen-
tration values. The calibration process establishes a relationship between the
signals and the known concentration values of the standards. This relationship is
then used to convert signals from the instruments for samples with unknown con-
centrations. In the calibration process, one of the standards will have a concentra-
tion value at the ML for the pollutant analyzed. Because the ML is the lowest level
for which laboratories calibrate their equipment, measurements below the ML are
to be reported as
-------
How are Permits Developed for Numerical Limitations?
What are Reporting and Record-Keeping Requirements?
In accordance with Section 122.44(1) (2), the permit writer must require direct
dischargers to report the results of compliance monitoring at least once per year.
However, facilities may be required to submit the results more frequently. Indirect
dischargers must report the results of compliance monitoring twice per year (in
June and December), unless the control authority requires them to report more
frequently, in accordance with Section 403.12(e).
Developing Compliance Schedules
When Must Existing Facilities Comply With the August 14, 2000 Promulgated
Rule?
Permit writers should establish, for direct dischargers, pollutant limits based
on the newly promulgated BPT, BCT, and BAT effluent limitations guidelines on
the date the NPDES permit is issued. Under the Clean Water Act, the NPDES per-
mit requires immediate compliance with those new limitations (see CWA Section
301(b)(2)(C)- (F)). Therefore, as a matter of law, NPDES permits cannot include a
compliance schedule.
For indirect dischargers, however, the Clean Water Act imposes different com-
pliance requirements. Under CWA Section 307(b)(l), existing indirect dischargers
must comply with applicable pretreatment standards by the date specified in
those standards, with the time for compliance not to exceed three years from the
date of promulgation. As specified in the TEC rule, existing indirect dischargers
subject to Subparts A through C must comply with pretreatment control limits
based on the newly promulgated PSES on or before August 14, 2003.
What if Existing Direct Dischargers Cannot Meet the August 14, 2000
Promulgated Rule Immediately?
NPDES rules require facilities to meet permit limits for all pollutants on the
date the NPDES permit is issued. Some facilities are capable of demonstrating
compliance within this timeframe. In fact, some facilities already use several (or
all) of the model pollution prevention and treatment technologies that form the
basis of BPT, BCT, and BAT. Some facilities, however, may determine that they
need additional time to implement the pollution prevention and treatment tech-
nologies to comply with the new effluent limitations guidelines. For these facili-
ties, the permit writers may exercise discretion and issue an administrative order
in the permit authorizing additional time for compliance (see 40 CFR Part 122).
When Must New Sources Comply With the August 14, 2000 Promulgated
Rule?
The owner or operator of a new source subject to Subpart A, B, C, or D must
install and have in operating condition, at "start-up," all pollution controls neces-
sary to meet the applicable NSPS/PSNS before discharging. The facility must
meet permit limitations based on those standards within 90 days of commencing
discharge (see 40 CFR Part 122.29(d)(4)).
37
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Indirect dischargers considered to be new sources prior to August 14, 2000
must meet the applicable PSNS within 90 days of the effective date of the rule.
(The effective date of the rule is September 13, 2000.) In accordance with Section
403.12(d) for indirect dischargers, new sources must submit their initial report of
compliance within 90 days following commencement of the introduction of waste-
water into the POTW.
38
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Section 7: Case Studies
Because there are complex permitting issues associated with 40 CFR Part 442,
this section presents six case studies showing the development of NPDES and
pretreatment permits for facilities subject to the TEC rule under Subparts A, B, C,
and D. The case studies present the following situations:
Case Study
1
2
3
4
5
6
Description
Direct discharger with TEC process wastewater
Indirect discharger with nonprocess and TEC process wastewater
Indirect discharger with wastewater generated from maintenance
Indirect discharger with wastewater generated from cleaning tank
trucks, closed-top hoppers, and intermediate bulk containers
Direct discharger with wastewater associated with other industrial
operations
Direct discharger with wastewater associated with other industrial
operations
Each case study presents the following:
General site description;
Information about facility operations relevant to establishing permit limits;
Step-by-step approach to determining limits for each regulation (e.g., BPT,
BAT); and
Final limits as they would appear in each example facility's permit.
39
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Case Study #1
Facility A is a direct discharging TEC facility that cleans tank barges that last contained chemical cargos,
which discharges into the New River. The facility has submitted an application for an NPDES permit.
General Site Description
Facility A cleans approximately three tank barges per day. On average, the facil-
ity discharges 20,000 gallons of TEC process wastewater per tank barge cleaned.
The facility operates 260 days per year.
What type of discharger is the facility?
Under which subparts do the facility's
operations fall?
Which effluent limitation guideline and
standard is the facility subject to?
Does the facility discharge 1 00,000
gallons or more per year of TEC process
wastewater?
Direct
Tank Barges and Ocean/Sea Tankers
Transporting Chemical and
Petroleum Cargos (Subpart C)
BPT (40 CFR§ 442.31)
BCT (40 CFR § 442.32)
BAT (40 CFR § 442.33)
Yes (see following calculation)
Developing Permit Limits for Pollutants Regulated Under
BPT/BCT/BAT
The effluent limitations guidelines are concentration-based and, as such, do not
regulate wastewater flow. The permit writer must use a reasonable estimate of
process wastewater discharge flow and the concentration-based limitations to
develop mass- based limitations for the NPDES permit using the following three
steps. Tables 4-2 through 4-5 present the maximum daily and monthly average
BPT effluent limitations for Subparts A through D, respectively.
40
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Case Studies
Step 1. Determine Allowable Wastewater Discharge Flow
The first step in establishing permit limitations is to determine the types of waste streams (i.e., regulated
process, unregulated process, and dilute waste streams) at the facility. The following shows the flow
breakdown at Facility A:
Average daily Subpart C flow:
Tank barge wastewater = 3 tank barges/day x 20,000 gallons/tank = 60,000 gallons/day
Total regulated process wastewater = 60,000 gallons/day x 260 days/yr
Total regulated process wastewater = 15,600,000 gallons/yr*
*Total regulated process wastewater exceeds 100,000 gallons per year; therefore, Facility A is subject
to the TEC rule.
Step 2. Determine Maximum Effluent Limitations for Any One Day
The maximum daily limitation for oil and grease (HEM) for Subpart C is 36 mg/L. Below is an example
for calculating the HEM limit:
ML = Mass limit of HEM in tank barge cleaning wastewater
= 36 mg/L x 60,000 gal/day x [8.345 x 10'6 ((L x lb)/(gal x mg))] = 18 Ibs/day
Step 3. Determine Monthly Average Effluent Limitations
The monthly average limitation for oil and grease (HEM) for Subpart C is 16 mg/L. Below is an example
for calculating the HEM limit:
ML = Mass limit of HEM in tank barge cleaning wastewater
= 16 mg/L x 60,000 gal/day x [8.345 x 10'6 ((L x lb)/(gal x mg))] = 8.0 Ibs/day
Compare this monthly average limitation to the average of all daily mass discharge amounts in a calen-
dar month to determine facility compliance.
41
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Final Limits as They Would Appear in a Permit for Facility A
Table 7-1 presents the final limits as they would appear for Facility A on a mass
basis. The permit writer can choose to show limits on a concentration basis in
addition to the mass-based limits.
Table 7-1. Final Limits for Facility A
Pollutant or Pollutant Property
BOD5
TSS
Oil and grease (HEM)
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Zinc
pH(a)
Maximum for Any
One Day (Ibs/day)
31
29
18
0.010
0.21
0.050
0.070
0.00065
0.29
4.2
NA
Monthly Average
(Ibs/day)
11
13
8.0
NA
NA
NA
NA
NA
NA
NA
NA
NA - Not applicable.
(a) Within 6 to 9 at all times.
Case Study #2
Facility B is an indirect discharging TEC facility that discharges to a POTW.
General Site Description
Facility B cleans approximately 20 tank trucks and two rail cars per day. A wide
range of cargos is cleaned, but all cargos are classified as chemical or petroleum
(as defined in §442.2). On average, the facility discharges 800 gallons of TEC
process wastewater per tank truck cleaned and 2,500 gallons of TEC process
wastewater per rail tank car cleaned. The facility also commingles into its treat-
ment system approximately 100 gallons per day of equipment and floor-washing
wastewater and approximately 100 gallons per day of boiler blowdown. The facil-
ity operates approximately 300 days per year.
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Case Studies
What type of discharger is the facility?
Under which subparts do the facility's
operations fall?
Which effluent limitation guideline and
standard is the facility subject to?
Does the facility discharge 1 00,000
gallons or more per year of TEC process
wastewater?
Indirect
Tank Trucks and Intermodal Tank
Containers Transporting Chemical
and Petroleum Cargos (Subpart A)
Rail Tank Cars Transporting Chemical
and Petroleum Cargos (Subpart B)
PSES (40 CFR § 442.15 and 442.25)
Yes (see following calculation)
Developing Permit Limits for Pollutants Regulated Under PSES
The final effluent limitation standards are concentration-based and, as such, do
not regulate wastewater flow. The limitations apply at the end of pipe. Tables 4-5
through 4-7 presents the maximum daily PSES effluent limitations for Subparts A
through C, respectively.
Step 1. Determine Allowable Wastewater Discharge Flow
The first step in establishing permit limitations is to determine the types of wastestreams (i.e., regulated
process, unregulated process, and dilute) at the facility. The following shows the process wastewater
flow breakdown at Facility B:
Average daily Subpart A flow:
Tank truck wastewater = 20 tank trucks/day x 800 gallons/tank truck = 16,000 gallons/day
Average daily Subpart B flow:
Rail car wastewater = 2 rail tank cars/day x 2,500 gallons/rail tank car = 5,000 gallons/day
Equipment and floor washing wastewater = 100 gallons/day
Total regulated process wastewater = 21,100 gallons/day x 300 days/yr
Total regulated process wastewater = 6,330,000 gallons/yr*
"Total regulated process wastewater exceeds 100,000 gallons per year; therefore, Facility B is subject to
the TEC rule.
Step 2. Determine PSES Maximum Limitations for Any One Day
Use the combined waste stream formula (40 CFR 403.6(e)) in Equation 1 to establish effluent limita-
tions. Note that boiler blowdown is the only dilute waste stream at this facility.
CF;
(1)
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Step 2. Determine Maximum Limitations for Any One Day (CONTINUED)
where:
Cj = Alternative concentration limit for the combined wastestream (mg/L)
Cj = Concentration limit for a pollutant in the regulated stream i (mg/L)
Fj = Average daily flow (at least a 30-day average) of regulated stream i (gallons/day)
ED = Average daily flow (at least a 30-day average) of dilute waste stream(s) (gallons/day)
Fj = 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
Below is an example for calculating the mercury limit:
The average daily flow through the combined treatment system is 21,200 gallons/day. The maximum
daily concentration limitation for mercury for Subpart A is 0.0031 mg/L (from §442.15). Mercury is not
regulated for Subpart B and this flow is considered an unregulated process flow. Cj for mercury is calculat-
ed as:
0.0031 x 16,000
16,000
K 21,200-100 j
21,200 /
= 0.0031 mg/L
Use the same methodology to establish pretreatment standards for all pollutants regulated under
§442.15 and/or §442.25 (SGT-HEM, copper, fluoranthene, and phenanthrene). SGT-HEM is the only pol-
lutant regulated under both Subparts A and B. Because the SGT-HEM limitation is the same in both sub-
parts (26 mg/L), Cj for SGT-HEM for this example facility is calculated as:
f(26x 16,000)+ (26x5,000)
L 21,000
j| 21,200- 100 |
/\ 21,200 /
= 26 mg/L
Final Limits as They Would Appear in a Permit for Facility B
Table 7-2 presents the final limits as they would appear for Facility B. The con-
trol authority can choose to show limits on a mass basis in addition to the concen-
tration-based limits.
Table 7-2. Final Limits for Facility B
Note! Only indirect dis-
chargers in Subparts A and B
have the option of comply-
ing with a Pollutant
Management Plan in lieu of
numeric limits.
Pollutant or Pollutant Property
Nonpolar material (SGT-HEM)
Copper
Mercury
Fluoranthene
Phenanthrene
Maximum for Any One
Day (mg/L)
26
0.84
0.0031
0.076
0.34
44
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Case Studies
Case Study #3
Facility C is an indirect discharging TEC facility that cleans rail cars that last contained chemical cargos.
General Site Description
Facility C cleans rail tank cars for both shipping products and repair. The facili-
ty discharges an average of 200,000 gallons of tank cleaning wastewater per year
and performs an average of 100 cleanings per year. All tanks last transported
chemical and petroleum cargos. According to facility records, approximately 80%
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.
What type of discharger is the facility?
Under which subparts do the facility's
operations fall?
Which effluent limitation guideline and
standard is the facility subject to?
Does the facility discharge 100,000
gallons or more per year of TEC process
wastewater?
Indirect
Rail Tank Cars Transporting
Chemical and Petroleum Cargos
(Subpart B)
PSES (40 CFR § 442.25)
No (see calculation below)
Step 1. Determine Allowable Wastewater Discharge Flow
By definition, only 20% of the facility's total average annual wastewater flow is considered TEC process
wastewater.
Average daily Subpart B flow:
Total regulated process wastewater = 200,000 gallons/yr x 0.20 = 40,000 gallons/yr
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 estab-
lished by its permitting authority using best professional judgement on a case-by-
case basis.
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Case Study #4
Facility D is an indirect discharging TEC facility that cleans tank trucks, closed-top hoppers, and
intermediate bulk containers.
General Site Description
Facility D cleans tank trucks, closed-top hoppers, and intermediate bulk con-
tainers. The tank trucks and intermediate bulk containers last contained chemical
products. The closed-top hoppers last contained dry bulk cargos. The facility dis-
charges an average of 200,000 gallons of tank and container cleaning wastewater
per year.
What type of discharger is the facility?
Under which subparts do the facility's
operations fall?
Which effluent limitation guideline and
standard is the facility subject to?
Does the facility discharge 1 00,000
gallons or more per year of TEC process
wastewater?
Indirect
None (see below)
Not Applicable
Not Applicable
Step 1. Determine Allowable Wastewater Discharge Flow
As described in §442.1 (b)(2), the TEC effluent guidelines do not apply to "wastewater resulting from
cleaning the interiors of drums, intermediate bulk containers, or closed-top hoppers."
This facility is covered by the TEC rule if the facility discharges 100,000 gallons or more per year of TEC
process wastewater from cleaning tank trucks. Wastewater discharged from cleaning closed-top hopper
trucks and intermediate bulk containers is not regulated by this rule and is not considered when deter-
mining whether this facility meets the low-flow exclusion.
46
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Case Studies
Case Study #5
Facility E is an international chemical manufacturer that cleans tank trucks that transport chemicals sup-
plied by a contract manufacturer.
General Site Description
Facility E has an agreement with a contractor who provides propylene glycol,
which Facility E then uses to formulate aircraft deicing fluid. The contractor sup-
plies the propylene glycol, along with the manufacturing waste, in tank trucks to
the chemical manufacturer. The chemical manufacturer cleans the tank trucks and
combines the wastewater from the cleaning and manufacturing waste for treat-
ment in its on-site treatment system, followed by discharge to a river.
What type of discharger is the facility?
Under which subparts do the facility's
operations fall?
Which effluent limitation guideline and
standard is the facility subject to?
Does the facility discharge 100,000
gallons or more per year of TEC process
wastewater?
Direct
None (see below)
Not Applicable
Not Applicable
Step 1. Determine Allowable Wastewater Discharge Flow
As described in §442.1(b)(1), the TEC 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."
This facility is not covered by the TEC rule since the wastewater is generated at a facility that cleans only
tanks that have contained raw materials, by-products, and finished products that are associated with the
facility's on-site processes. Note that this exclusion also applies to the waste from the contractor, since
that waste is considered part of the chemical manufacturer's on-site processes.
47
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Case Study #6
Facility F is a direct discharging chemical manufacturing facility that cleans tank trucks that last contained
chemical cargos.
General Site Description
This chemical manufacturer operates a distribution center 50 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 between changes of cargo. The wastewater generated from tank clean-
ing is not currently covered by a point source category. The distributor cleans an
average of 500 tank trucks per year and discharges 250,000 gallons of tank clean-
ing wastewater per year to surface waters. The facility has no other significant
sources of process wastewater. The facility operates year-round.
What type of discharger is the facility?
Under which subparts do the facility's
operations fall?
Which effluent limitation guideline and
standard is the facility subject to?
Does the facility discharge 1 00,000
gallons or more per year of TEC process
wastewater?
Direct
Tank Trucks and Intermodal Tank Con-
tainers Transporting Chemical and
Petroleum Cargos (Subpart A)*
BPT (40 CFR§ 442.11)
BCT(40CFR§442.12)
BAT(40CFR§442.13)
Yes
Step 1. Determine Allowable Wastewater Discharge Flow
As described in §442.1 (b)(1), the TEC 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 believes that product distribution centers may be covered by the TEC regulation if they discharge
100,000 or more gallons of TEC process wastewater and the tank and container cleanings are not asso-
ciated with other industrial, commercial, or POTW activities. EPA believes its exclusion for other industri-
al, commercial, or POTW facilities allows the permit writer considerable discretion in determining if the
tank cleanings are performed as part of, or in addition to, the facility's on-site processes. In this example,
the permit writer may consider EPA's rationale for the exclusion for tank cleanings operated in conjunc-
tion with other industrial, commercial, or POTW operations discussed in Section 2 of this document.
Because Facility D does not meet the intended focus of EPA's exclusion, the permit writer may exercise
discretion to determine that the TEC pretreatment standards would be appropriate for use as the basis
of the permit.
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Section 8: Where to Get Additional Help
This section presents additional sources of information, including EPA contacts,
that may help permit writers and control authorities obtain additional informa-
tion related to implementation of the final TEC effluent limitations guidelines and
standards for Subparts A, B, C, and D. Specifically, this section presents a list of
selected documents and web sites relating to the August 14, 2000 promulgated
rule. These lists also include information on how to reach EPA program personnel
and how to access these information sources.
Specific questions related to the effluent limitations guidelines and standards
for the TEC Point Source Category should be directed to:
John Tinger
Engineering and Analysis Division
Office of Water
U.S. EPA
401 M Street, SW
Washington, D.C. 20460
Phone: (202) 260-4992
Fax: (202) 260-7185
E-mail: tinger.john@epamail.epa.gov
Documents Supporting the Promulgated Rule
• Final Development Document for Effluent Limitations Guidelines and Standards for
the Transportation Equipment Cleaning Point Source Category, EPA-821-R-00-012
• Final Economic Analysis of Effluent Limitations Guidelines and Standards for the
Transportation Equipment Cleaning Point Source Category, EPA-821-R-00-0013
• Final Cost-Effectiveness Analysis of Effluent Limitations Guidelines and Standards for
the Transportation Equipment Cleaning Point Source Category, EPA-821-R-00-0014
General Information About Permits and NPDES Program
• NPDES Permit Writer's Manual (EPA-833-B-96-003). This 1996 EPA manual
was prepared to provide the basic regulatory framework and technical consid-
erations that support the development of wastewater discharge permits as
required under the National Pollutant Discharge Elimination System (NPDES)
program.
• NPDES Compliance Inspection Manual (EPA-300-B-94-014). This 1994 EPA
manual was developed to support wastewater inspection personnel in conduct-
ing NPDES field inspections, and to provide standardized inspection proce-
dures. The manual encourages a consolidated inspection approach, and is
organized into two parts. The first part addresses basic inspection components,
including technical information on documentation, record-keeping and report-
ing, sampling, and laboratory procedures. The second part provides informa-
tion on specific types of inspections, concluding with a discussion of
multimedia concerns.
49
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Section 8
• Guidance for Water Quality-Based Decisions: The TMDL Process (EPA-440-4-
91). This document is intended to define and clarify the requirements under
Section 303(d) of the Clean Water Act. Its purpose is to aid state water-quality
program managers in understanding the application of total maximum daily
loads within the water-quality-based approach to establish pollution control
limits for waters not meeting water quality standards.
• Technical Support Document for Water Quality-Based Toxics Control
(EPA/505/2-90-001). This document was prepared as technical guidance for
assessing and regulating the discharge of toxic substances to waters of the
United States.
• Industrial User Permitting Guidance Manual: (A Training Manual for Control
Authorities to Develop Industrial User Permits) (EPA 833/R-89-001). This doc
ument assists permit writers and legal and administrative personnel involved
in implementing industrial user permitting program in preparing effective and
enforceable industrial permits. (This document may be obtained on EPA's web
site. See below.) This document also references the following EPA documents,
which may be helpful: Guidance Manual for the Use of Production-Based
Pretreatment Standards and the Combined Wastestream Formula (September 1985),
Guidance Manual on the Development and Implementation of Local Discharge
Limitations Under the Pretreatment Program (December 1987), and Pretreatment
Compliance Monitoring and Enforcement Guidance (September 1986).
Web Sites
EPA's web server is the primary public access mechanism on the Internet for
EPA. The web server provides a range of EPA-generated information in electronic
format, and also offers access to EPA's Online Library Service (OLS), the national
online catalog of the EPA library network. It includes the catalogs of the
Headquarters Information Resource Center and all the Regional libraries.
EPA's homepage:
http://www.epa.gov
EPA's TEC rulemaking actions for TEC:
http://www.epa.gov/OST/guide/teci
50
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Where to Get Additional Help
Other Sources
EPA Headquarters Information Resource Center
The EPA Headquarters Information Resource Center provides information sup-
port services to EPA staff and maintains a varied collection of environmental
resources, including CD-ROMs, an online catalog, and other program-specific
services. The library provides services to the general public and develops several
publications, including newsletters and brochures. Library hours are 8:00 a.m. to
5:00 p.m. ET, Monday through Friday. EPA's OLS is available on the Internet:
http://www.epa.gov/natlibra/ols.htm
National Technical Information Service (NTIS)
Located in the U.S. Department of Commerce, the National Technical
Information Service (NTIS) is the U.S. Government's central source for distribut-
ing scientific, technical, engineering, and related business information. It is also a
central source of federally generated machine-processible data files. NTIS contains
reports on air pollution, acid rain, water pollution, marine pollution, marine
ecosystems, land use planning, fisheries management, solar energy, offshore oil
drilling, solid wastes, traffic noise, and radiation monitoring.
For more information, contact:
U.S. Department of Commerce
National Technical Information Service
5285 Port Royal Road
Springfield, VA 22161
Phone: (703) 605-6000
http://www.ntis.gov
51
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Appendix A - Glossary
BODg - Five-day biochemical oxygen demand. A measure of biochemical decom-
position 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 com-
bustion.
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 hopper barge, or ocean/sea tanker that comes in direct
contact with the chemical, material, or substance. A cargo may also be referred to
as a commodity.
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 com-
modities 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 cov-
ers.
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 liq-
uid commodities or cargos and are typically used to transport grain, soybeans,
soy meal, soda ash, lime, fertilizer, plastic pellets, flour, sugar, and similar com-
modities 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 simi-
lar 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.
A-1
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Glossary
COD - Chemical oxygen demand. A nonconventional bulk parameter that meas-
ures the oxygen-consuming capacity of refractory organic and inorganic matter
present in water or wastewater. COD is expressed as the amount of oxygen con-
sumed from a chemical oxidant in a specific test (see Methods 410.1 through
401.4).
Commodity - Any chemical, material, or substance transported in a tank truck,
closed-top hopper truck, intermodal tank container, rail tank car, closed-top hop-
per 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 commodi-
ty may also be referred to as a cargo.
Consignee - Customer or agent to whom commodities or cargos are delivered.
Conventional pollutants - The pollutants identified in Sec. 304(a)(4) of the CWA
and the regulations thereunder (biochemical oxygen demand (BODg), total sus-
pended solids (TSS), oil and grease, fecal coliform, and pH).
Daily discharge - The discharge of a pollutant measured during any calendar day
or any 24-hour period that reasonably represents a calendar day. For pollutants
with limitations expressed as mass, the daily discharge is calculated as the total
mass of the pollutant discharged over the day. For pollutants with limitations
expressed in other units of measurement, the daily discharge is calculated as the
average measurement of the pollutant over the day.
Direct discharger - A facility that conveys or may convey untreated or facility-
treated process wastewater or nonprocess wastewater directly into waters of the
United States, such as rivers, lakes, or oceans (also called receiving waters). (See
United States surface waters definition.)
Discharge - The conveyance of wastewater: (1) to United States surface waters
such as rivers, lakes, and oceans, or (2) to a publicly owned, privately owned, fed-
erally 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.
Effluent limitation - Any restriction, including schedules of compliance, estab-
lished 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).)
End of the pipe - The point at which final effluent is discharged to waters of the
United States or introduced to a POTW.
Food grade cargo - Food grade cargos include edible and nonedible food prod-
ucts. Specific examples of food grade products include but are not limited to: alco-
holic 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 suit-
A-2
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Appendix A
able for human consumption, fruit juices, honey, lard, molasses, nonalcoholic bev-
erages, salt, sugars, sweeteners, tallow, vegetable oils, and vinegar.
Heel - Any material remaining in a tank or container following unloading, deliv-
ery, or discharge of the transported cargo. Heels may also be referred to as con-
tainer 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.
Indirect discharger - A facility that discharges or may discharge pollutants into a
publicly owned treatment works or treatment works not owned by the discharg-
ing facility.
Intermediate bulk container (IBC or tote) A completely enclosed storage vessel
used to hold liquid, solid, or gaseous commodities or cargos that are in direct con-
tact with the tank interior. Intermediate bulk containers may be loaded onto flat
beds for either truck or rail transport, or onto ship decks for water transport. IBCs
are portable containers with 450 liters (119 gallons) to 3000 liters (793 gallons)
capacity. IBCs are also commonly referred to as totes or tote bins.
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.
Maximum daily discharge limitation - The highest allowable daily discharge of a
pollutant measured during a calendar day or any 24-hour period that reasonably
represents a calendar day.
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).
Nonpolar material - A method-defined parameter that measures the presence of
mineral oils that are extractable in the solvent n-hexane and not absorbed by silica
gel (see Method 1664). Nonpolar material is also referred to as SGT-HEM.
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.
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.
NSPS - New Source Performance Standards, under Sec. 306 of the CWA.
A-3
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Glossary
Ocean/sea tanker - A self- or non-self-propelled vessel constructed or adapted to
transport commodities or cargos in bulk in cargo spaces (or tanks) through oceans
and seas, where the commodity or cargo carried comes in direct contact with the
tank interior. There are no maximum or minimum vessel or tank volumes.
Off site - Outside the established boundaries of the facility.
Oil and grease - A method-defined parameter that measures the presence of rela-
tively 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 TEC effluent guideline utilized
Method 1664.
On site - Within the established boundaries of the facility.
Outfall - The mouth of conduit drains and other conduits from which a facility
effluent discharges into receiving waters.
Petroleum cargo - Petroleum cargos include the products of the fractionation or
straight distillation of crude oil, redistillation of unfinished petroleum derivatives,
cracking, or other refining processes. For purposes of this rule, petroleum cargos
also include products obtained from the refining or processing of natural gas and
coal. For purposes of this rule, specific examples of petroleum products include
but are not limited to: asphalt; benzene; coal tar; crude oil; cutting oil; ethyl ben-
zene; diesel fuel; fuel additives; fuel oils; gasoline; greases; heavy, medium, and
light oils; hydraulic fluids, jet fuel; kerosene; liquid petroleum gases (LPG) includ-
ing butane and propane; lubrication oils; mineral spirits; naphtha; olefin, paraffin,
and other waxes; tall oil; tar; toluene; xylene; and waste oil.
POTW - Publicly owned treatment works, as defined at 40 CFR 403.3(0).
Pretreatment standard - A regulation that establishes industrial wastewater efflu-
ent quality required for discharge to a POTW (CWASection 307(b)).
Priority pollutants - The pollutants designated by EPA as priority in 40 CFR Part
423 Appendix A.
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, by-product, or waste product.
Specifically, TEC process wastewater includes all wastewaters associated with
cleaning the interiors of tanks including: tank trucks; rail tank cars; intermodal
tank containers; tank barges; and ocean/sea tankers used to transport commodi-
ties or cargos that come into direct contact with the tank or container interior. At
those facilities subject to the TEC guidelines and standards, TEC process waste-
waters also include wastewater generated from washing vehicle exteriors, equip-
ment and floor washings, and TEC-contaminated stormwater.
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 compart-
A-4
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Appendix A
ments and the stored commodities or cargos come in direct contact with the tank
interior. There are no maximum or minimum vessel or tank volumes.
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 nonpolar material.
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, and ocean/sea tankers. Containers used to
transport prepackaged 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 com-
modities 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.
Totes or tote bins - A completely enclosed storage vessel used to hold liquid,
solid, or gaseous commodities or cargos which come in direct contact with the
vessel interior. Totes may be loaded onto flat beds for either truck or rail trans-
port, or onto ship decks for water transport. There are no maximum or minimum
values for tote volumes, although larger containers are generally considered to be
intermodal tank containers. Totes or tote bins are also referred to as intermediate
bulk containers or IBCs. Fifty-five gallon drums and pails are not considered totes
or tote bins.
Waters of the United States - The same meaning set forth in 40 CFR 122.2.
United States 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.
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 is the discharge of
pollutants by way of evaporation, deep-well injection, off-site transfer to a treat-
ment facility, and land application.
A-5
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Appendix B: Guidance on the Requirements of
the Baseline Monitoring Report (BMR) for
Facilities Electing the Pollution Prevention
Compliance Option
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C 20460
MEMORANDUM
OFFICE OF
WATER
Februitrv 15. 2001
SUBJECT: Baseline Monitoring Report Requirements for Transportation Equipment
Cleaning Facilities.
: ' • v, r J.
FROM: Sheila Frace, Director
Engineering and Analysis Division
TO:
Water Perrm^s Division
Water Management Division Directors
Regions 1-10
Background
The Transportation Equipment Cleaning (TEC) final effluent limitations guidelines and
pretreatment standards were published in the Federal Register on August 14, 2000 (65 FR
49666) and became effective on September 13, 2000. The pretreatment regulations at 40 CFR
403.12(b) require TEC facilities discharging to Publicly Owned Treatment Works (POTWs) to
submit a Baseline Monitoring Report (BMR) within 180 days of the effective date of the rule
(March 12, 2001). One of the requirements of the BMR is for the facility to "submit the
results of sampling and analysis identifying the nature and concentration...of regulated
pollutants in the Discharge from each regulated process."
The final TEC regulation provides certain TEC facilities a choice between meeting
numerical discharge limitations or establishing a "Pollutant Management Plan" (PMP) as an
alternative pollution prevention (P2) option. This P2 option is available only for facilities
discharging to POTWs in two subcategories: Subpart A - Tank Trucks and Intermodal Tank
Containers Transporting Chemical and Petroleum Cargos and Subpart B - Rail Tank Cars
Transporting Chemical and Petroleum Cargos.
The PMP does not include numerical standards and therefore, does not specifically
Internet Address (URL) • http://www.epa.gov
R«cycled/R«cyclable 'Printed with vegetaDle Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer)
B-1
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Appendix B
include discharge monitoring requirements.
Issues
The BMR requirements in 40 CFR 403.12 do not directly address a situation where
compliance is measured through a P2 alternative rather than a numeric standard and
corresponding monitoring. This situation was similarly encountered for the final Pesticide
Formulating, Packaging and Repackaging (PFPR) effluent limitations and pretreatment
standards.
Recently, POTW pretreatment personnel have requested guidance on how to comply
with the BMR requirements for those facilities choosing the PMP alternative.
We recognize that in order to address this situation, ultimately, the regulation requiring
submittal of the BMR (403.12(b)) will need to be modified. We plan to make this
modification as part of the larger streamlining initiative that is currently underway.
However, such modifications may not be finalized prior to the BMR submittal date of
March 12, 2001. Therefore, we have developed the following guidance in order to assist these
facilities prior to the modification of the Pretreatment Regulations. This guidance is based on
the guidance that was developed for the PFPR regulation in a April 3, 1997 memo to the
Water Management Division Directors.
Guidance
In order to comply with the requirements of 40 CFR 403.12(b)5, an Industrial User
(IU) subject to the TEC pretreatment standards (40 CFR 442) intending to prepare a PMP
should submit a BMR that contains a list of pollution prevention practices (e.g., those
incorporated in the TEC P2 alternative) currently employed by the IU. The IU is not required
to submit analytical monitor data in the BMR. Note that the IU must still comply with the
other sections of 403.12(b).
For additional information, contact John Tinger at (202) 260-4992 or Jan Piclcrel at
(202) 564-7904.
cc: Regional Pretreatment Coordinators (Regions 1-10)
B-2
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