United States
 Environmental Protection
 Agency
Office of Water
WH-552
Washington, DC 20460
EPA 440/1-89/104
September, 1989
Preliminary Data Summary for the

Transportation Equipment Cleaning

Industry

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           PRELIMINARY DATA SUMMARY
                   FOR THE
      TRANSPORTATION EQUIPMENT CLEANING
                   INDUSTRY
  Office of Water Regulations and Standards
               Office of Water
United States Environmental Protection Agency
              Washington,  D.C.

                September  1989

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                             PREFACE


     This is one of a series of Preliminary Data Summaries
prepared by the Office of Water Regulations and Standards of the
U.S. Environmental Protection Agency.  The Summaries contain
engineering, economic and environmental data that pertain to
whether the industrial facilities in various industries discharge
pollutants in their wastewaters and whether the EPA should pursue
regulations to control such discharges.  The summaries were
prepared in order to allow EPA to respond to the mandate of
section 304(m) of the Clean Water Act, which requires the Agency
to develop plans to regulate industrial categories that
contribute to pollution of the Nation's surface waters.

     The Summaries vary in terms of the amount and nature of the
data presented.  This variation reflects several factors,
including the overall size of the category (number of
dischargers), the amount of sampling and analytical work
performed by EPA in developing the Summary, the amount of
relevant secondary data that exists for the various categories,
whether the industry had been the subject of previous studies  (by
EPA or other parties), and whether or not the Agency was already
committed to a regulation for the industry.  With respect to the
last factor, the pattern is for categories that are already the
subject of regulatory activity (e.g., Pesticides, Pulp and Paper)
to have relatively short Summaries.  This is because the
Summaries are intended primarily to assist EPA management in
designating industry categories for rulemaking.  Summaries for
categories already subject to rulemaking were developed for
comparison purposes and contain only the minimal amount of data
needed to provide some perspective on the relative magnitude of
the pollution problems created across the categories.

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                         ACKNOWLEDGEMENTS


Preparation of this Preliminary Data Summary was directed by
Robert Southworth, Project Officer, of the Industrial Technology
Division.  Alison Greene of the Assessment and Watershed
Protection Division was responsible for preparation of the
environmental assessment analysis.  Support was provided under
EPA Contract Nos. 68-03-6302 and 68-03-3339.

Additional copies of this document may be obtained by writing to
the following address:

          Industrial Technology Division (WH-552)
          U.S. Environmental Protection Agency
          401 M Street, S.W.
          Washington, D.C. 20460

          Telephone  (202) 382-7131

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                     TABLE OF CONTENTS

SECTION	TITLE	     PAGE NO.

        EXECUTIVE SUMMARY	i

I       INTRODUCTION  	       1

        A.  Background	      1
        B.  Purpose and Authority	       1
        C.  Regulatory Status	       3
        D.  Summary of Methodology 	      4
             1.   Review and Assessment	       4
            2.   Supplementary  Data Gathering   ....      4
            3.   Sampling  and Analytical  Program.  .  .       6

II      DESCRIPTION OF THE INDUSTRY	       13

        A.  Summary	       13
        B.  Cleaning  Procedures	       15
            1.   Rail  Tank Car  Cleaning	       17
            2.   Tank  Barge Cleaning	       17
            3.   Aircraft  Exterior Cleaning  	       17

III     WATER USE AND WASTE CHARACTERIZATION  ....       18

        A.  Water Use	       18
        B.  Wastewater Characteristics 	      18
            1.   Tank  Truck Cleaning Facility A  ...      20
            2.   Tank  Truck Cleaning  Facility  B .  .  .       21
            3.   Tank  Truck Cleaning  Facility  C .  .  .       29
            4.   Rail  Tank Car  Cleaning  Facility A.  .       53
            5.   Rail  Tank Car  Cleaning  Facility B.  .       59
            6.   Tank  Barge Cleaning  Facility  A ...       63
            7.   Tank  Barge Cleaning  Facility  B .  .  .       69
            8.   Aircraft  Exterior Cleaning
                 Facility  A .	       82

IV      SUBCATEGORIZATION 	        86

        A.  Existing  Subcategories  	       86
        B.  Preliminary Subcategorization Scheme  .  .       86

V       RAW WASTE  POLLUTANT LOADS	       88

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                      TABLE OF CONTENTS (cont.)

 SECTION	TITLE	 PAGE NO.



 VI       CONTROL AND TREATMENT TECHNOLOGY 	     89

         A.  Control and Treatment Needs	     94
         B.  Current Practices	     94
         C.   Applicable  Control  and Treatment
             Technologies 	     96
             1.   In-Plant Controls	     96
             2.   Oil-Water Separation 	     96
             3.   Equalization	     98
             4.   pH Adjustment	     98
             5.   Air and Steam Stripping	     98
             6.   Dissolved Air Floatation	     99
             7.   Coagulation-Sedimentation	     99
             8.   Hydroxide/Sulfide Precipitation.  .  .     99
             9.   Biological Treatment 	     99
             10.   Wet Air Oxidation	     100
             11.   Activated  Carbon Adsorption  ....      100

 ENVIRONMENTAL IMPACT ANALYSIS  	       101

 VII      ENVIRONMENTAL IMPACTS	     102

         A.   Pollutant Impacts	     102
         B.   Pollutant Persistence	      110
Appendices are available from the Industrial Technology Division
at the address listed on the Acknowledgements page.

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                        LIST OF TABLES

TABLE     	TITLE		PAGE NO.

       ESTIMATED ANNUAL RAW WASTE POLLUTANT LOADS
       TRANSPORTATION EQUIPMENT CLEANING INDUSTRY.  ...   ii

1-1   SUMMARY OF ANALYTICAL PROGRAM  	    7

1-2   LIST OF ANALYTES	•    8

III-l  WATER USED TO CLEAN AIRCRAFT  EXTERIORS	19

III-2  ESTIMATED AVERAGE UNIT FLOWS	19

II1-3  SUMMARY OF ANALYTICAL RESULTS - TANK TRUCK
       CLEANING FACILITY A	23

III-4  SUMMARY OF MATERIALS LAST CONTAINED, AUGUST  4,
       1986 - TANK TRUCK CLEANING FACILITY A	27

III-5  SUMMARY OF MATERIALS LAST CONTAINED, AUGUST  5-8,
       1986 - TANK TRUCK CLEANING FACILITY A	28

III-6  SUMMARY OF ANALYTICAL RESULTS - TANK TRUCK
       CLEANING FACILITY B  	   31

III-7  SUMMARY OF MATERIALS LAST CONTAINED, SEPTEMBER 23,
       1986 - TANK TRUCK CLEANING FACILITY B	35

III-8  SUMMARY OF MATERIALS LAST CONTAINED, SEPTEMBER 24,
       1986 - TANK TRUCK CLEANING FACILITY B	36

III-9  SUMMARY OF MATERIALS LAST CONTAINED SEPTEMBER 25,
       1986 - TANK TRUCK CLEANING FACILITY B	37

111-10 PROPOSED TOXICITY CHARACTERISTIC  CONTAMINANTS
       AND REGULATORY LEVELS  	   38

III-11 SUMMARY OF ANALYTICAL RESULTS - TANK TRUCK
       CLEANING FACILITY C  	   42

111-12 SUMMARY OF MATERIALS LAST CONTAINED, JANUARY 21,
       1987 - TANK TRUCK CLEANING FACILITY C	45

111-13 SUMMARY OF MATERIALS LAST CONTAINED, JANUARY 22,
       1987 - TANK TRUCK CLEANING FACILITY C	46

111-14 SUMMARY OF MATERIALS LAST CONTAINED, JANUARY 23,
       1987 - TANK TRUCK CLEANING FACILITY C	47

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                     LIST OF TABLES  (cont.)

TABLE	TITLE	PAGE NO.


111-15 SUMMARY  OF MATERIALS LAST CONTAINED,  JANUARY 24,
       1987  - TANK  TRUCK CLEANING FACILITY  C.  .....    48

I11-16 SUMMARY  OF MATERIALS LAST CONTAINED,  JANUARY 26,
        1987 -  TANK TRUCK CLEANING FACILITY  C	    49

111-17 SUMMARY  OF MATERIALS LAST CONTAINED,  JANUARY 27,
        1987 -  TANK TRUCK CLEANING FACILITY  C	    50

111-18 SUMMARY  OF MATERIALS LAST CONTAINED,  JANUARY 28,
        1987 -  TANK TRUCK CLEANING FACILITY  C	    51

111-19 SUMMARY  OF MATERIALS LAST CONTAINED,  JANUARY 29,
        1987 -  TANK TRUCK CLEANING FACILITY  C	    52

111-20 SUMMARY  OF ANALYTICAL RESULTS  - RAIL  TANK CAR
        CLEANING FACILITY A	    55

111-21 SUMMARY  OF MATERIALS LAST CONTAINED,  SEPTEMBER,
        29, 1986 -  RAIL TANK CAR CLEANING FACILITY  A .  .    60

111-22 SUMMARY  OF MATERIALS LAST CONTAINED,  SEPTEMBER,
        30, 1986 -  RAIL TANK CAR CLEANING FACILITY  A .  .    61

111-23 SUMMARY  OF MATERIALS LAST CONTAINED,  OCTOBER 1,
        1986 - RAIL TANK  CAR CLEANING FACILITY A  ....    62

111-24 SUMMARY  OF ANALYTICAL RESULTS  - RAIL  TANK CAR
        CLEANING FACILITY B	    66

II1-25 SUMMARY  OF MATERIALS LAST CONTAINED - RAIL TANK
        CAR CLEANING FACILITY B	    68

111-26 SUMMARY OF ANALYTICAL RESULTS  - TANK  BARGE
        CLEANING FACILITY A	    71

111-27 SUMMARY OF MATERIALS LAST CONTAINED - TANK BARGE
        CLEANING FACILITY A	    75

II1-28 SUMMARY OF ANALYTICAL RESULTS  - TANK  BARGE
        CLEANING FACILITY B	    78

111-29 SUMMARY OF MATERIALS LAST CONTAINED - TANK BARGE
        CLEANING FACILITY B	    81

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                      LIST OF TABLES (cont.)

TABLE	TITLE      	PAGE NO.

111-30 SUMMARY OF ANALYTICAL RESULTS - AIRCRAFT
        CLEANING FACILITY A	    84

V-l     ESTIMATED ANNUAL RAW WASTE POLLUTANT LOADS -
        TANK TRUCK INTERIOR CLEANING FACILITIES	    90

V-2     ESTIMATED ANNUAL RAW WASTE POLLUTANT LOADS -
        RAIL TANK CAR CLEANING FACILITIES	    91

V-3     ESTIMATED ANNUAL RAW WASTE POLLUTANT LOADS -
        TANK BARGL CLEANING FACILITIES 	    92

V-4     ESTIMATED ANNUAL RAW WASTE POLLUTANT LOADS -
        AIRCRAFT EXTERIOR CLEANING FACILITIES	    93

VI-1   OBSERVED TREATMENT TECHNOLOGIES 	      95

VI-2   APPLICABILITY  OF TREATMENT TECHNOLOGIES  ....      97

VII-1  POLLUTANT EVALUATION  CRITERIA	     103

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                          LIST OF FIGURES

FIGURE	TITLE    	PAGE NO.

III-l    WASTEWATER TREATMENT SCHEMATIC - TANK TRUCK
         CLEANING FACILITY A 	       22

III-2    WASTEWATER TREATMENT SCHEMATIC - TANK TRUCK
         CLEANING FACILITY B 	       30

III-3    WASTEWATER TREATMENT SCHEMATIC - TANK TRUCK
         CLEANING FACILITY C 	       41

III-4    WASTEWATER TREATMENT SCHEMATIC - RAIL TANK CAR
         CLEANING FACILITY A 	       54

III-5    WASTEWATER TREATMENT SCHEMATIC - RAIL TANK CAR
         CLEANING FACILITY B 	       64

III-6    WASTEWATER TREATMENT SCHEMATIC - TANK BARGE
         CLEANING FACILITY A 	       70

III-7    WASTEWATER TREATMENT SCHEMATIC - TANK BARGE
         CLEANING FACILITY B 	       77

III-8    WASTEWATER TREATMENT SCHEMATIC - AIRCRAFT
         EXTERIOR CLEANING FACILITY A	       83

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                        EXECUTIVE SUMMARY

The   industrial   Technology   Division    (ITD)   of   the   U.S.
Environmental  Protection Agency  (EPA)  conducted a  preliminary
study ™f the  transportation  equipment  cleaning  industry  as  a
result of the evaluation of the findings from the Domestic Sewage
cM-nrtv  mssi    The purpose  of the DSS  was to  obtain technical
fnrormatfon '   for  use*  in   determining  if  additional  effluent
limitSi™  guidelines and  standards  need to  be developed and
punished for this point source category, and to provide a source
of  current  information  about  priority  and hazardous pollutant
discharges  from this  industry for  permit writers  and publicly
owned treatment works  (POTWs) managers and operators.

As part  of the study,  EPA identified approximately 400 tank  truck
cleaning facilities,  approximately  90  rail  tank  «r cleaning
facilities,  and approximately  200 tank barge cleaning  facilities.
These  are  believed to represent nearly complete coverage of  for-
hire  cleaning facilities in  the  United States.   The Agency was
not  able  to  identify  specific  facilities  where   cleaning of
aircraft exteriors takes place.

in  addition, the  Agency collected   samples of  raw and  treated
effluent and sludges  at eight transportation equipment cleaning
facilities.     A  total  of  111  "List  of  Analytes"   organic
pollutants,  52  of which  are priority pollutants,  were detected  in
the  samples.  All thirteen priority pollutant metals  were  found.
Review  of   environmental   impact  data  indicates  that  in  many
instances  the concentrations of pollutants in  raw wastewater from
individual  facilities within this  industry  exceed EPA criteria
for  protection of human  health and aquatic life.

The  total  discharge of priority pollutants from  transportation
equipment  cleaning  processes  is estimated to  be  approximately
 22,000,000  pounds per  year.   This  amount is  greater than the
untreated  priority pollutant  load from  all  industries except the
Organic  Chemicals,   Plastics,   and  Synthetic   Fibers   (OCPSF)
 industries.   It  is  twice  the loading projected  to  be discharged
 by regulated industries at BAT technology.  The table on the next
 page summarizes the estimated annual raw waste pollutant loads by
 subcategory for the transportation equipment cleaning industry.

 An economic assessment  of the transportation  equipment cleaning
 industry was not conducted.

 An environmental  impact analysis was  conducted,  however.  A  total
 of  111  organic pollutants  (including pesticides and herbicides)
 were detected in wastewaters at transportation equipment cleaning
 facilities.   Of  these,  50 are on EPA's Priority Pollutant  List,
 52  are RCRA Hazardous Constituents,  72  are   CERCLA  Hazardous
 Substances, and five  are known or suspected human carcinogens.

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TRANSPORTATION EQUIPMENT CLEANING POLLUTANT LOADINGS






          Raw Pollutant Loadings  fibs/day)
Priority
Subcategory Oraanics
Tank Truck Cleaning 6000
Rail Tank Car Cleaning 100
Tank Barge Cleaning 74500
Aicraft Cleaning 400
81000
Hiah Priority Pol
Priority
Inorganics
8000
3900
1000
13000
lutant Loadings
Total Priority
Pollutants
14000
4000
75500
500
94000
fibs/day)
Organic
 Acro           3°'000   (Tank Barae Cleaning)

 Ben^ni        41'°°°   (Tank Barae Cleaning
 Benzene         2,000   (Tank Barge Cleaning)
Inorganic
                5'°°°  (Tank Truck Cleaning)

                 /0°°  (Tank Truck Cleaning
                4 ,000  (Rail Tank Car Cleaning)

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                           SECTION I

                           INTRODUCTION

A.  BACKGROUND

This document  summarizes the most  current  information available
regarding the discharge of wastewater and solid wastes containing
priority and hazardous nonpriority pollutants by the transportation
equipment  cleaning  industry  (TECI).    The  objectives  of  this
document  are to  (1)  provide a  technical basis  for determining
whether  additional  national  regulations  should  be  developed
pursuant  to the  Clean  Water Act  (CWA) ,  and  (2)  make available
preliminary  information regarding the discharge  of  priority and
hazardous nonpriority pollutants by the TECI.

A profile and description of the  transportation equipment cleaning
industry  are presented  in Section II.   Section III characterizes
TECI wastewater in terms of the presence  of priority and hazardous
nonpriority  pollutants  and  provides additional  information   on
these and other pollutant discharges  from TECI facilities.  Section
IV discusses potential  subcategorization of the TECI and Section
V presents summaries of raw waste loading information derived from
the  sampling efforts.  Section VI discusses control and treatment
technology which may be applicable to this industry and  Section VII
presents  the results of the  environmental impact  analysis.

B.   PURPOSE  AND AUTHORITY

The  purpose  of  this   study was  to develop a  basic  level  of
familiarity  with  TECI;  to determine  the  practices and procedures
used to clean  the interior of  tanks  on trucks,  rail cars, and
barges,   and the cleaning of the exteriors  of  aircraft,  and to
develop   an  estimate  of  the  pollutant  loadings   from   those
operations.

The  U.S.  Environmental  Protection  Agency  (EPA)  is  required by
Section   301(d)   of the  Federal  Water Pollution  Control  Act
Amendments of  1972 and  1977  (the CWA),  to review and revise, if
necessary,  effluent limitation and  standards  promulgated pursuant
to Sections  301,  304 and  306, within five years of promulgation of
these  regulations.  In conjunction with this  review program, and
as   a  result of  a  court settlement with  several  environmental
groups,  EPA has undertaken a major examination of toxic pollutants
discharged by  industrial sources.

To  achieve these goals,  the Industrial  Technology Division  (ITD)
 is   responsible  for (1)  developing,  proposing,   and promulgating
 effluent limitation guidelines,   new source  performance  standards
 (NSPS),  pretreatment standards (PSES and PSNS), and best management
 practices  (BMPs)   for  industrial  point source  discharges;  (2)
 assuring the  adequacy  and  validity  of  scientific,  economic  and
 technical  data  and   findings   used  to   support   the   effluent
 limitations and standards; (3) gathering, developing and  analyzing
 data and  background information basic  to  the annual review  and
 periodic  revision  of  the  limitations  and   standards;  and  (4)

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 developing technical information required for the judicial review
 of effluent limitations guidelines and standards.
 In addition  to its responsibilities  under  the CWA,  EPA is also
 charged  by the Resource  Conservation and  Recovery Act  of 1976
 (RCRA) with oversight  of  cradle to grave management of hazardous
 solid wastes.   Section 3018 (a)  of RCRA, as amended  by the 1984
 Hazardous and Solid Waste Amendments (HSWA) ,  directed EPA to submit
 a report  to  Congress concerning wastes  discharged  through sewer
 systems to POTWs that are exempt from RCRA regulation as a result
 of the  Domestic Sewage  Exclusion  (DSE)   of  RCRA.    The Domestic
  ?Wl;£ Exclusi.on was established by  Congress in section 1004(27)
 of RCRA,  provides  that solid  or dissolved material  in domestic
 sewage is  not solid waste as  defined in RCRA.   Therefore,  such
 £™*rial* ar%n0t  considered  a  hazardous waste for  purposes  of
 RCRA.    The   Domestic  Sewage  Exclusion applies  to  industrial
 wastewater discharged  to  municipal sewers that  contain domestic
 The report  to Congress  (the  Domestic Sewage  Study or  DSS)  was
 prepared by  EPA's  Office of Water  and submitted tY0  Congress on
 h^H^ ?'  I986',- The  °SS examined  the  nature and  sources o?
 o? ?£??   wastes discharged to POTWs,  measured the  effectiveness
 of EPA's program in dealing with  such discharges, and recommended
 Implicit in the Domestic Sewage Exclusion is the  assumption that
 oo^Prf  f*- *,en 4. p.r°9ram mandated by the CWA can  ensure adequate
 control of industrial discharges to sewers.  This program, detailed
 under section 307 (b) of the CWA and implemented in 40 CFR Part 40?
 requires EPA to  establish  pretreatment standards for  pollutant
 discharged  to POTWs by industrial  facilities  for those  pollutants
  •Jx  ^terfere  Wlth, Pass through, or  otherwise are  incompatible
 with  the operation  of  POTWs.                               faL.j.wj.e

 Section  3018 (b)  of  RCRA  directs the  Administrator  to  revise
 existing regulations  and promulgate pretreatment  standards  for
 specific hazardous  pollutants  when  necessary to   ensure  that
 hazardous wastes  discharged to  POTWs  are controlled adequately.
 5e^f s*;andards are to be promulgated pursuant to RCRA, section 307
 of the  CWA,  or  any  appropriate authority possessed by EPA.

 The DSS concluded  that  the Domestic Sewage  Exclusion  should  be
 retained at the  present time  and  recommended  ways to  improve
 various  EPA programs under the  CWA to obtain better control  of
 r^*,^5 ?aSt?S fnt,e.rAng. POTWS'   In addition, the DSS recommended
 research efforts to fill  information gaps, and indicated  that other
 stftutes (such as RCRA and the  Clean Air Act) should be considered
 with the CWA when establishing  controls  for either hazardous waste
 dischargers  or receiving  POTWs or both.

 One of the recommendations of the DSS was that EPA review and amend
 categorical pretreatment standards  to achieve better control of the
 pollutants  in  hazardous  wastes.   The  DSS  recommended  that the
Agency  modify  existing standards  to improve control of organic

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priority  pollutants  and  non-priority  pollutants,  and that  EPA
promulgate  categorical  pretreatment  standards  for  industrial
categories not included  in the  Natural  Resources Defense Council
consent decree (NRDC v. Train, 8 ERC 2120, D.C.C. 1976).

This study was  conducted under the authority  of Sections 301 (d)
and 304 (m) of the CWA, which require periodic review and revision
of limitations promulgated pursuant to Sections 301, 304, and 306
of the CWA.

    Section 301
    Any effluent  limitation  required  by paragraph (2)  of subsec-
    tion  (b) of this section shall be  reviewed at  least every five
    years and,  if appropriate,  revised pursuant to the procedure
    established under such paragraph.
    Section 304

    Schedule  for Review of Guidelines -

     (1)  Publication.   Within 12  months  after  the date  of the
         enactment of the Water Quality Act of 1987,  and biennially
         thereafter, the Administrator shall publish in the Federal
         Register a  plan which shall:

         (A)  establish a   schedule  for   the annual  review and
             revision  of  promulgated  effluent  guidelines,   in
             accordance with subsection (b)  of this section;

         (B)  identify categories of  sources discharging toxic  or
             nonconventional pollutants for which guidelines under
             subsection (b) (2) of this section and Section 306 have
             not previously been published; and

         (C)  establish a  schedule  for promulgation  of effluent
             guidelines for categories identified  in subparagraph
              (b) , under which promulgation of such guidelines shall
             be no  later  than  four  years after  such  date   of
             enactment for  categories  identified  in  the  first
             published plan  or three years after the publication
             of  the  plan  for  categories  identified   in  later
             published plans.

     (2)  Public Review.  The Administrator shall provide for public
         review and  comment on the plan prior to final publication.

 C.   REGULATORY STATUS

 This  study   constitutes   the  second  wastewater  study  of  the
 transportation equipment  cleaning  industry which consists  of
 facilities that clean  the interiors of tank trucks, rail tank
 cars,  tank barges,  and the exteriors of aircraft. An earlier study
 of  this  industry  was performed  during the  1973-74  period and,
 although reports concerning various segments of the industry were
 made available, no regulations  were proposed  for  this  category.

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EPA  does not currently  have the detailed  information needed  to
develop  a  comprehensive  industry  profile,  subcategorize  the
industry,   or  characterize   completely  wastewater   from  the
transportation  equipment  cleaning  industry.     To obtain this
information,   the  Agency  must   first  identify   all   of  the
transportation equipment cleaning facilities and then  send
a 308 questionnaire  (data collection portfolio) to  them.

3.  Sampling and Analytical Program

A program was undertaken to  obtain wastewater and  sludge samples
at  eight  transportation  equipment cleaning  facilities.    Raw
wastewater samples,  and, where appropriate,  treated effluent and
sludge samples,  were also collected at each facility. In addition
EPA's Tpxicity Characteristic  Leaching  Procedure  (TCLP)  was used
to obtain sludge sample leachate for analysis.

The  samples  obtained  were  analyzed for  analytes  on the 1987
Industrial  Technology Division List  of  Analytes.   This list
contains conventional  pollutants  and  EPA's Priority  Pollutants
(excluding fecal  coliform  bacteria and  asbestos)  as well  as 285
other organic and inorganic nonconventional pollutants or pollutant
characteristics.   These  additional pollutants were derived from
other EPA lists,  including the  Superfund Hazardous Substance List,
RCRA Appendix  VIII  and  Appendix  IX,  and the  list of  analytes
?foPll    ° be added to RCRA APPendix VII by the Michigan Petition
(49 FR 49793).   Table I-l  summarizes the  analytical program and
Table 1-2 presents the list of analytes.

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                                   TABLE 1-1

                         SUMMARY OF ANALYTICAL PROGRAM


                                          Tap
Pollutant              Trip    Sampler   Water  Wastewater  Sludge     TCLP
Group	Blanks   Blanks   Samples   Samples   Samples    Extract

Volatile Organic         X       —        X         X         X         X
 Pollutants

Semivolatile Organic    —        XX         X         X         X
 Pollutants

Pesticides and          —       —        X         X         X
 Herbicides

Dioxins and Furans      —       —       —        "         x

Metals1                 ....        X         X         X         X

Cyanide                 —       —       —         x         x

Classical Pollutants2   —       —       —         x

Classical Pollutants3   —       —       "        —         x
 1  Quantitative Analysis for Ag, Al, As, B, Ba, Be, Ca, Cd, Co, Cu, Fe, Hg,
   Mg, Mn, Mo, Na, Ni, Pb, Sb, Se, Sn, Ti, Tl, V, Y, Zn

 2  Classical pollutants for liquid samples:  biochemical oxygen demand, total
   suspended solids,  total dissolved solids, fluoride, chemical oxygen demand,
   nitrate-nitrite, total phosphorus,  total organic carbon, total Kjeldahl
   nitrogen, ammonia,  total cyanide, total sulfide, oil and grease,
   temperature, pH, settleable solids

 3  Classical pollutants for sludge samples:  total solids, volatile solids,
   nitrate-nitrite, total Kjeldahl nitrogen, ammonia,  total sulfide,
    ignitability,  corrosivity.

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                                    TABLE 1-2

                                LIST OF ANALYTES
 Volatile Organic Pollutants

 1,1,2,2-tetrachloroethane
 1,1,1-trichloroethane
 1,1,2,2-tetrachloroethane
 1,1,2-trichloroethane
 1,1-dichloroethane
 1,1-dichloroethene
 1,2,3-trichloropropane
 1,2-dibromoethane
 1,2-dichloroethane
 1,2-dichloropropane
 1,3-dichloropropane
,1,3-dichloropropylene
 1,3-dichloro-2-propanol
 1,4-dioxane
 l-bromo-2-chlorobenzene
 l-bromo-3-chlorobenzene
 2-butenal
 2-chloroethyl vinyl ether
 2-hexanone
 2-picoline
 3-chloropropene
 4-methyl-2-pentanone
 acetone
 acrolein
 acrylonitrile
 allyl  alcohol
 benzene
 bromoform
 bromodichloromethane
 bromomethane
 carbon disulfide
 carbon tetrachloride
 chlorobenzene
 chloroethane
 chloroform
 chloromethane
 chloroprene
 cis-1,3-dichloropropene
 dibromochloromethane
 dibromochloropropane
 dibromomethane
 dichlorofluoromethane
 diethyl  ether
 dimethyl sulfone
 ethyl  benzene
 ethyl  cyanide
 ethyl  methacrylate
 isobutyl alcohol
 methacrylonitrile
 methyl ethyl  ketone
 methyl iodide
 methyl methacrylate
 methylene  chloride
 N,N-dimethylformamide
 tetrachloroethane
 toluene
 trans-1,2-dichloroethene
 trans-1,3-dichloropropene
 trans-1,4-dichloro-2-butene
 trichloroethene
 trichlorofluoromethane
 vinyl  acetate
 vinyl  chloride
Semivolatile Organic Pollutants

1,2,3-trichlorobenzene
1,2,3-trimethoxybenzene
1,2,4,5-tetrachlorobenzene
1,2,4-trichlorobenzene
1,2-dichlorobenzene
1,2-diphenylhydrazine
1,3,5-trithiane
1,3-dichlorobenzene
1,3-dichloro-2-propanol
1,4-dichlorobenzene
1,4-dinitrobenzene
1,4-naphthoquinone
1,5-naphthalenediamine
l-chloro-3-nitrobenzene
1-methylfluorene
1-methylphenanthrene
1-naphthylamine
                                   8

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                               TABLE 1-2 (cont.)
Semivolatile Organic Pollutants (cont.)

2,3-dichloroaniline
2,3-dichloronitrobenzene
2,4,5-trichlorophenol
2,4,5-trimethylaniline
2,4-dimethylphenol
2,4-dinitrophenol
2,4-dinitrotoluene
2,6-dichlorophenol
2,6-dinitrotoluene
2,6-di-tert-butyl-p-benzoquinone
2-chloronapthalene
2-chlorophenol
2-isopropylnaphthalene
2-methylbenzothiazole
2-methylnaphthalene
2-nitroaniline
2-naphthylamine
2-nitrophenol
2-phenylnaphthalene
2-(methylthio)benzothiazole
3,3-dichlorobenzidine
3,3,-dimethoxybenzidine
3,6-dimethylphenanthrene
3-methylcholanthrene
3-nitroaniline
4,4'-methylene bis(2-chloroaniline)
4,5-methylene phenanthrene
4-aminobiphenyl
4-bromophenyl phenyl ether
4-chlorophenyl phenyl ether
4-chloro-2-nitroaniline
4-chloro-3-methylphenol
4-nitrobiphenyl
4-nitrophenol
5-chloro-o-toluidine
5-nitro-o-toluidine
7,12-dimethylbenz(a)anthracene
acenaphthene
acenaphthylene
acetophenone
alpha-terpineol
aniline
anthracene
aramite
benzanthrone
benzidine
benzole acid
benzo(a)anthracene
benzyl alcohol
biphenyl
bis(2-chloroethoxy)methane
bis(chloroethyl)ether
bis(2-chloroisopropyl)ether
bis(2-ethylhexyl)phthalatebenzo(a)pyrene
benzo(b)fluoranthene
benzo(ghi)perylene
benzo(k)fluoranthene
benzyl alcohol
biphenyl
bis(2-chloroethoxy)methane
bis(chloroethyl)ether
bis(2-chloroisopropyl)ether
bis(2-ethylhexyl)phthalate
bis(chloromethyl)ether
bromoxynil
butyl benzyl phthalate
carbazole
chloroacetonitrile
chrysene
dibenzothiophene
dibenzo(a,h)anthracene
dichloran
diethyl phthalate
dimethyl phthalate
dinitrocresol
diphenyl ether
diphenyl sulfide
diphenylamine
di-n-butyl phthalate
di-n-octyl phthalate
di-n-propylnitrosamine
erythritol anhydride
ethylenethiourea
ethylmethane sulfonate
fluoranthene
fluorene
hexachlorobenzene
hexachlorobutadiene
hexachlorocyclopentadiene
hexachloroethane
hexachloropropene
hexanoic  acid
indeao(l,2,3-cd)pyrene
isophorone
isosafrole
longifolene

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                                TABLE 1-2 (coot.)
 Semivolatile Organic Pollutants (coat.")
 nitrobenzene
 N,N-dime thy1fo nnamide
 N-decane
 N-docosane
 N-dodecane
 N-eicosane
 N-hexacosane
 N-hexadecane
 N-nitrosodiethylamine
 N-nitrosodimethylamine
 N-nitrosodiphenylamine
 N-nitrosodi-n-butylamine
 N-nitrosomethylethylamine
 N-nitrosomethylphenylamine
 N-nitrosomorpholine
 N-nitrosopiperidine
 n-octacosane
 n-octadecane
 n-tetracosane
 n-tetradecane
 n-triacontane
 o-anisidine
 o-cresol
 o-toluidine
 pentachlorobenzene
 pentachloroethane
 pentachlorophenol
 pentamethylbenzene
 perylene
 phenacetin
 phenanthrene
 phenol
 phenothiazine
 pronamide
 pyrene
pyridine
p-chloroaniline
p-cresol
p-cymene
p-dime thylaminoazobenzene
p-nitroaniline
 resorcinol
 safrole
squalene
 styrene
 thianaphthene
thioacetaroide
thiophenol
 azinphos-ethyl
 azinpbos-methyl
 beta-BHC
 captafolthioxanthone
 triphenylene
 tripropylene glycol methyl ether
 Pesticides  and  Herbicides

 2,4,5-T
 2,4,5-TP
 2,4-D
 4,4'-DDD
 4,4'-DDE
 4,4'-DDT
 aldrin
 alpha-BHC
 azinphos-ethyl
 azinphos-methyl
 beta-BHC
 captafol
 captan
 carbophenothion
 chlordane
 chlorfenvinphos
 chlorobenzilate
 chlorpyrifos
 coumaphos
 crotoxyphos
 cygon
 delta-BHC
 demeton
 diallate
 diazinon
 dichlone
 dichlorvos
 dicrotophos
 dieldrin
 dinoseb
 dioxathion
disulfoton
endosulfan I
endosulfan II
endosulfan sulfate
endrin
endrin aldehyde
                                  10

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                               TABLE 1-2 (cont.)
Pesticides and Herbicides (cont.)

ethylenebisdithiocarbamic acid,
 salts, and esters
famphur
fensulfothion
fenthion
gamma-BHC
heptachlor
heptachlor epoxide
hexamethylphosphoramide
isodrin
kepone
leptophos
malathion
ma neb
methoxychlor
methyl parathion
mevinphos
mirex
monocrotophos
nab am
naled
nitrofen
parathion ethyl
PCB-1016
PC3-1221
PCB-1232
PCB-1242
PCB-1248
PCB-1254
PCB-1260
PCNB
phorate
phosmet
phosphamidon
sulfotepp
TEPP
terbufos
tetrachlorvinphos
thiram
toxaphene
trichlorofon
tricresylphosphate
trifluralin
 trimethylphosphate
zineb
ziram
Dibenzo-P-Dioxins and Dibenzofurans

2,3,7,8-TCDD
dibenzofuran
heptachlorodibenzofurans
heptachlorodibenzo-p-dioxins
hexachlorodibenzofurans
hexachlorodibenzo-p-dioxins
octachlorodibenzofurans
octachlorodibenzo-p-dioxins
pentachlorodibenzofurans
pentachlorodibenzo-p-dioxins
tetrachlorodibenzofurans
tetrachlorodibenzo-p-dioxins
Elements

aluminum
antimony
arsenic
barium
beryllium
bismuth
boron
cadmium
calcium
cerium
chromium
cobalt
copper
dysprosium
erbium
europium
gadolinium
gallium
germanium
gold
hafnium
holnium
indium
iodine
iridium
iron
lanthanum
lead
                                   11

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                               TABLE 1-2  (cont.)
 Elements  (cont.)

 lithium
 lutetium
 magnesium
 manganese
 mercury
 molybdenum
 neodymium
 niobium
 osmium
 palladium
 phosphorus
 platinum
 potassium
 praseodymium
 rhenium
 rhodium
 ruthenium
 samarium
 scandium
 selenium
 silicon
 silver
 sodium
 strontium
 sulfur
 tantalum
 tellurium
 terbium
 thallium
 thorium
 thulium
 tin
 titanium
 tungsten
 uranium
 vanadium
 ytterbium
 yttrium
 zinc
 zirconium

 Conventional Pollutants

 BOD5
 oil and grease, total recoverable
pH
TSS
Classical Nonconventional Pollutants

ammonia, as N
COD
conductivity*
corrosivity
cyanides
flash point
fluoride
nitrate/nitrite
nitrogen, Kjeldahl, total
reactivity*
residue, filterable
salinity (with calcium)
salinity (with sodium)
sulfide
total organic carbon
total phosphorus
*Analytes not monitored during 1986-1987 sampling.
                                12

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                           SECTION II

                  DESCRIPTION OF THE INDUSTRY

A.  SUMMARY

The transportation industry includes establishments that provide,
as their principal business,  for-hire conveyance service to others
for the  movement of materials  and people  between predetermined
points.   The  industry  includes four  principal  modes:    truck
transportation,  rail  transportation,  waterborne  transportation,
and air  transportation.   All of these segments  are addressed in
this report.

Together, these   four  transportation  modes  are  responsible  for
movement of nearly all materials and  goods  in the United States.
A notable exception is the use of pipelines to move crude petroleum
and refined petroleum products.  Nonetheless, crude petroleum is
often delivered to pipelines by  ships and barges, and final local
distribution  is  usually by  truck  or  rail.    The transportation
equipment  cleaning  industry  is  a   service  industry  that  has
developed to  clean the  interior of truck tanks,  rail tanks,  and
barge tanks used  in the distribution process.

The cleaning  of  aircraft  exteriors  is believed to be primarily a
vertically integrated fleet maintenance function,  rather than part
of a well-defined service industry.

Three major  reasons  exist for cleaning of  truck, rail and barge
tanks.

    o    to  prevent contamination of materials from one cargo to
         the  next;

    o    to  allow or  facilitate  inspections;  and

    o    to  allow vehicle  or  vessel  repair.

There  are literally hundreds  of different  products  that can be
carried  in tanks moved by trucks, rail and barges.  Tanks  that are
not  in dedicated  service  (i.e., tanks  that  carry  a variety of
different  products)  must   be  cleaned  frequently  to  prevent
contamination  of new cargos with  residues  from previous loads.
Even tanks in dedicated service may need cleaning at some frequency
to prevent contamination of subsequent cargo if cargo purity is an
overriding concern,  as  is the case for certain process chemicals
or for certain food stuffs.

A second  reason  for  cleaning  transportation  equipment  is  to
facilitate  inspection  of tanks, and  inspection  of fittings and
valves.   Such  inspections may be part of  a routine inspection and
maintenance  program  or part of  a  mandatory  program, such as the
biennial  certification  program  conducted by the Coast Guard for
tank barges that carry hazardous materials.


                                 13

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 The third reason for tank cleaning is to provide a safe environment
 for  performing  "hot work"  (i.e.  welding  or  cutting).    To be
 considered  safe  for  "hot  work,"   the  tank  must  be  rendered
 nonexplosive  and nonflammable through  a  cleaning process  called
 "gas-freeing".

 The tank truck cleaning industry can be divided into two categories
 based on the relationship of the washing facility to its customers.
 The first  category  comprises "for-hire" facilities.   At for-hire
 facilities, truckers drive in from the highway and  pay a  fee to
 have  their tanks cleaned.   Payment  may  be  on a cash  basis or
 billing arrangements may  be made.  Often the arrival of the truck
 is scheduled beforehand.  However, a  major segment of the business
 at for-hire facilities  may come  from "drive-in" customers.   For-
 hire  facilities  may  be operated  by  shippers,  carriers,  or
 independent owners.   The second category includes  shipper-operated
 and carrier-operated facilities  that provide cleaning facilities
 to support in-house operations.  These facilities  are "private" in
 the sense  that  non-affiliated trucks  cannot  drive  in  from the
 highway to have a tank cleaned.

 Approximately 400 facilities that fit into the  first category  have
 been identified as part of this study.   While other facilities may
 exist, EPA believes that  those identified represent 80 percent or
 better of facilities in the for-hire group.

 EPA was not  able to identify  any listing of shipper-operated or
 carrier-operated  facilities  as  part  of  this  study.    Based on
 available  information,  EPA believes  such lists  probably  do not
 exist.  Representatives of the  National Tank Truck Carriers  (NTTC)
 have said that the number of shipper-operated and carrier-operated
 facilities exceeds the number of  for-hire  facilities, but that the
 total number of washings performed is  substantially less.  Because
 of this statement,  EPA believes that  the estimates  of pollutant
 loads presented later in  this  document are  representative of the
 total discharge for this  subcategory.

 Truck tank cleaning  facilities  are  concentrated in  five areas
 corresponding to major petrochemical or manufacturing regions and
 population centers of the United States:  (l) California;  (2) the
 Texas-Louisiana Gulf coast; (3) the Mississippi, Missouri, and  Ohio
 Rivers;  (4) Southern Lake Michigan, Lake Erie,  and Lake Huron; and
 (5) eastern Pennsylvania  and  New Jersey.    There are only a few
 facilities located in the New England  and the Western States (with
 the exception of California).

 To best serve  their  customers, for-hire   tank  truck  cleaners
 typically  operate  24 hours per  day  on weekdays.   Depending on
 demand,  a  reduced cleaning schedule may be maintained on weekends.
 For-hire facilities that  perform  only cleaning operations  are
believed typically to employ  three to  five people  per shift and to
 clean 10 to 40 tank trucks per day.   Shipper-operated or carrier-
operated facilities that  are a part  of a  maintenance or shipping
depot  could employ many more workers.
                               14

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Eighty-nine facilities that clean the  interior  of rail car tanks
were identified during this study.  All of them are believed to be
part  of an  inspection,  maintenance,  and repair shop  for  both
freight and tank cars.   In addition, all  of  them are believed to
be available on a for-hire basis.

A typical facility is estimated to clean four to 10 tanks per day
and to employ 10 to 15 workers associated directly with cleaning.
Rail  tank  cleaning facilities  are  located predominantly  in the
industrialized  areas  of  the  central  and  south central  United
States.  None were identified in New England and only four were
found in the Western states of Arizona, Colorado, Idaho, Montana,
Nebraska, Nevada, New Mexico, North Dakota, Oregon, South Dakota,
Utah, Washington, and Wyoming.  Five are located in California.

One  hundred  ninety-six  tank  barge  cleaning  facilities  were
identified as part of  this  study.  Available information indicates
that ship/barge construction,  maintenance, or  repair are usually
also  conducted  at  these  facilities.   Tank  barge  cleaners  are
located primarily along  the Gulf  Coast and along the Mississippi
River and its tributaries.  Relatively few are  located along the
East  and West  coasts.    Available  information  indicates  these
facilities operate eight to 24 hours  per day, five to six days per
week.   Work  schedules are flexible, and  the  cleaning facilities
will often remain open longer than usual  to  complete a rush job.
Typical facilities are thought to employ 60 to 70 people of which
about  10  are involved in  cleaning activities  and  50 to  60 are
involved in repair  activities.   The  estimated average management
and clerical staff includes five people.

Aircraft exteriors are cleaned to  facilitate inspection and repair
and to maintain an attractive appearance.

In March  1987,  there were approximately 274,000  civil  aircraft
registered in  the United  States.   All  are subject  to  exterior
washing, either for appearance purposes or  to facilitate mechanical
inspections or maintenance.  Available information indicates that
major air carriers perform aircraft cleaning at their maintenance
centers.  The ground  support and maintenance center  for a major
airline may employ several  thousand people, of which only  a few are
directly involved in  cleaning aircraft  exteriors.  Some cleaning
is also believed done on a for-hire basis by fixed base operators
(FBOs)  located  at  airports.    The majority  of  aircraft,  small
private planes,  are probably cleaned by their pilots or owners.

The only way  known to document all  locations where  aircraft are
cleaned is to contact  all individual aircraft owners.  No listings
of facilities engaged  in aircraft exterior  cleaning were identified
during this study.

B.  CLEANING PROCEDURES

Although some variations exist,  procedures  for truck,  rail  and
barge tank cleaning are similar at most facilities and include the
following steps:
                                15

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 o    check shipping papers  to determine the cargo  last  carried;

 o    determine  what the  next cargo will be; if possible,

 o    drain the  tank heel and,  if need be,  segregate it for off-site
     disposal;

 o    rinse the  tank;

 o    wash  the tank;

 o    rinse the  tank;  and

 o    dry the tank.

 Determination  of  what  cargo  was last  carried in  a  tank  is an
 important  first  step in the cleaning procedure.    It  allows the
 cleaner:  (l) to assess  his ability to clean the tank efficiently;
 (2)  to  evaluate  if  the residue cleaned from  the tank will be
 compatible with  his treatment  system and with  the conditions of
 his  discharge permit; and (3) to establish an appropriate level of
 health protection  for employees who will clean the tank.
 Identifying the next cargo  is necessary for determining  whether the
 available  level  of  cleaning at a  facility  will  be adequate to
 prevent contamination of the next cargo.  The cleaning facility may
 decide not to clean a tank  based on  any of the preceding concerns.

 Once a tank has  been accepted  for cleaning, the  next  step is to
 check the volume  of residual cargo (heel)  in the  tank and determine
 how to dispose  of it.  Water soluble heels that are compatible with
 the  facility's  treatment  system  and  the  conditions  of  its
wastewater  discharge  permit   are   usually  combined  with  other
wastewaters for  treatment  and  disposal.   Incompatible heels are
 segregated in  drums or tanks  for disposal by  alternative  means,
which can include being sold to a reclaimer or landfilling.   Heels
 comprised of soaps, detergents,  solvents, acids, or alkalis can be
 salvaged  for future use as a  cleaning  fluid  for tanks or  as  a
 neutralizer for future heels.

 Cleaning  steps  vary among  individual  facilities  depending on
 available cleaning equipment and cargo residues to be cleaned.
Certain cargos may  need only   a  water  rinse,  while  others  may
require washing  with detergent or  with  strong caustic solution
 followed by rinsing.  A typical facility might offer hot and cold
water  rinses,  detergent washing,   and  caustic washing.    Other
possibilities include solvent washing, steam cleaning,  and  forced
air drying.

Washing is  typically performed by  one  of two  means:    (1)  high
pressure spinner  nozzles, or (2) hand held wands and nozzles.
Spinner nozzles are designed to be  inserted  through the main tank
hatch.   Operating  at pressures  of 100 p.s.i. to 600  p.s.i.,  they
rotate about both  vertical and  horizontal axes.   This  creates an
overlapping spray  pattern  that  cleans the entire  interior  of the
tank.   The nozzles  can deliver hot or cold  rinses,  detergent
solution,  or caustic solution.   Operating cycles  vary  from rinse

                                16

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bursts  of  a   few  seconds  to  detergent  or  caustic  washes  of
20 minutes or longer for caked or crystallized residues.  Washing
with hand held wands  and nozzles  is done by manually directing the
wash solution across the interior surface of the tank.

1.  Rail Tank Car Cleaning

The steps  followed during  rail car tank cleaning  are  similar to
those followed during truck tank  cleaning.  An additional concern,
however, is the need to prevent  damage  to  the tank lining during
the cleaning process.  Many rail car tanks are  lined to protect the
tank wall from corrosion by the tank contents, and the cleaning of
the tank must  be  carefully completed, in  order  to eliminate, or
minimize damage to the tank lining.

The discussion of  residual  cargo,  as presented on page 17, applies
also to rail car tank cleaning.

2.  Barge Tank Cleaning

The steps followed during barge tank cleaning are similar to those
followed in truck tank and rail tank cleaning operations with the
exception of the stripping  process. This process  is used to remove
heels from  a  tank  barge .  Stripping consists of pumping as much
residual cargo as possible  from the barge using either the vessel's
cargo transfer piping,  a built-in vessel stripping  system, or with
stripping  pumps supplied  by  the cleaning  facility.    In  some
instances, stripping is  facilitated by adding water ballast to tilt
the barge.

After stripping the next step is tank washing.  Cleaning steps vary
among  individual  facilities  depending  on  available  cleaning
equipment and  cargo  residues  to be cleaned.   Certain  cargos may
need only  a water rinse,  while  others may require  washing with
detergent or with strong caustic solution followed by rinsing.  A
typical facility might offer hot and cold water rinses, detergent
washing, and caustic washing.   Other possibilities include solvent
washing, steam cleaning, and forced air drying.

3.  Aircraft Exterior Cleaning

As part  of this study,  the washing  of aircraft wheel  wells and
landing gear  was  observed at  the maintenance center of  a major
commercial airline.  The cleaning methods used are believed to be
representative of the methods used by other major air carriers in
cleaning the  exterior  of aircraft.  Washing  an  aircraft at this
facility involves first moving it to  a  "wash rack."  The wash rack
is paved to direct contaminated wash water to a catch basin.  The
washing operation consisted of two steps:  spraying a solution of
butyl cellosolve and water  onto the aircraft with hand held wands;
followed by water rinsing.   This  procedure  may have to be repeated
to achieve  the desired result.   Scrubbing with  brushes was also
necessary.  The cleaning of small private aircraft is believed done
primarily with pails, hand sponges, and garden hoses.
                                17

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                           SECTION III

                      WASTE CHARACTERIZATION

A.  WATER USE

The primary  water use  at  truck,  rail   and barge  tank cleaning
facilities is  for  cleaning tank interiors.   Other secondary uses
include exterior cleaning,  make-up  water for cleaning solutions,
and sanitary wastewater.   Wastewater  from exterior cleaning is a
small  portion  of  the  total  water   used   at   tank  cleaning
facilities,  and,   the  amount   of  water  coming   from  these
operations  has  not  been   quantified as part  of  this  study.
Similarly,  sanitary  wastewaters have   not  been  considered  in
estimating facility water use.

The amount of  water  required  to clean an individual truck, rail,
or barge  tank  is highly variable and depends  on  several factors
including:

o   tank  size;

o   cleaning method;  and

o   the presence of  caked,  solidified,  or crystallized residues.

At facilities  that clean  aircraft  exteriors,  the  primary water
uses  are  exterior  cleaning  and  make-up  water  for  cleaning
solutions.    The  wastewater  volume  associated  with  aircraft
exterior cleaning depends on:

o   aircraft size;

o   the amount of  surface washed;

o   the cleaning method; and

o   the difficulty encountered in cleaning the surface.

The estimated  amount  of water used by the aircraft industry for
washing aircraft,  depending on aircraft  size  and  water control,
is given in Table III-l.

Table III-2 presents the average unit flow estimates for the four
preliminary  subcategories  of   the   transportation   equipment
cleaning industry.

B.  WASTEWATER CHARACTERIZATION

The purpose of this section is to describe the characteristics of
wastewaters  and  sludges  generated by   transportation  equipment
cleaning processes.   The data  presented  were derived exclusively
from  samples  and  information collected  during  this  study.   A
literature review to identify additional data revealed that very


                                18

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                                  TABLE III-l

                    WATER USED TO CLEAN AIRCRAFT EXTERIORS
 Aircraft Type
          Average   Flow
              (gal.)
B-747, DC-10, L-1011
DC-8
B-727
B-737, DC-9, BAC-111
Small two-engine aircraft
Single-engine private aircraft
           10,000
            7,500
            5,000
            4,000
          200-500
           50-100
Source: Development Pocument  for Proposed Effluent  Limitations  Guidelines  and
        New Source Performance  Standards  for the Air Transportation Segment o_f
        the Transportation Industry Point Source Category, May 1975.
                                  TABLE III-2

                         ESTIMATED AVERAGE UNIT FLOWS
 Subcategory
   Average Unit Flow
Tank Truck Cleaning

Rail Tank Car Cleaning

Tank Barge Cleaning

Aircraft Exterior Cleaning
  500 gal. per truck

3,000 gal. per rail car

3,500 gal. per barge

5,000 gal. per aircraft*
*Estimated average for large multi-passenger aircraft.
                                        19

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little historical data have been published and much of those data
are dated and of limited value.

The Agency  conducted sampling  episodes  at eight  transportation
equipment cleaning facilities in 1986 and 1987:  three tank truck
cleaners; two rail tank  car cleaners; two tank barge cleaners; and
one aircraft cleaner.   In  all  cases,  raw wastewater samples were
collected,  and,  where  appropriate,  treated  effluent  and  sludge
samples were also  collected.   Following  preservation the samples
were  packed in  ice  and forwarded  by overnight  air  freight  to
prearranged laboratories for analysis.

Analytical data summaries  for  each  facility are  presented  in the
following pages, along with a schematic showing sample locations,
a list of cargos last contained in the equipment that was cleaned,
and a brief description of the facility.   The  results of analysis
are included  in Appendix  A.   To maintain confidentiality,  each
facility has been assigned a code letter.

1.  Truck Tank Cleaning Facility A

This  facility,  which is located near a  major  metropolitan area,
usually cleans  between  20  and  30  truck  tank  interiors  per day.
Most  truck  tanks  are accepted for cleaning; however,  tanks that
have  contained  phenols, heavy metals,   and poisons  are usually
rejected.  The  tanks  are generally  empty when  they arrive  at the
facility, reportedly  containing  less than five gallons  of heel.
If the heel is soluble in water and compatible with the treatment
process, it is drained to the wastewater treatment system.   Other
heels are drummed for either subsequent off site disposal or return
to the shipper.

Facility A has the capability to wash truck tanks with cold water,
hot water, steam,  and caustic solution. The cleaning solutions are
recycled  within a  closed  system  and drained  to the  treatment
process periodically.   Water washes  and  rinses drain directly to
the treatment process.   Average  daily  wastewater flow  for this
cleaning operation is about 15,000 gallons.

Wastewater  treatment at this  facility  consists of  equalization
followed by batch  pH adjustment with  sulfuric  acid and dissolved
air flotation.  Alum is used to coagulate wastewater solids prior
to the wastewater entering the dissolved air flotation clarifier.
Polymer is not used in conjunction with the alum.  The effluent is
discharged to the municipal sewer.

Two samples of  raw wastewater  and one of treated wastewater were
obtained at this facility.   The influent samples were grab samples
collected  from  a  tap  installed  on  the  7,000-gallon  batch  pH
adjustment  tank.   The  effluent  sample  was also  a  grab  sample
collected approximately one hour  after collection of the  second
influent sample.   A  mechanical  breakdown of the treatment  system
prevented collection  of an effluent sample corresponding  to the
first influent  sample.   (During the period that  operations were
interrupted, the  facility  manager  had  the untreated wastewater
trucked away to  allow repair of the treatment system.)  A schematic

                                20

-------
of  the wastewater  treatment  system  showing  sample  collection
locations is shown in  Figure III-l.   A summary of the analytical
results for this sampling episode are presented in Table III-3.

Concentrations  of  the  organic  pollutants  varied  considerably
between the two raw wastewater  samples.  Concentrations of metals,
conventional, and nonconventional pollutants were much more
consistent.   There  is no apparent  correlation between  the raw
wastewater and materials last contained in the trucks as listed in
Tables  III-4 and  III-5.   This  may  be  because  of  a  lack  of
specificity in the description of tank cargoes.

Concentrations of some  pollutants were less in the treated effluent
than  in  the raw  wastewater,  others  were  higher in  the  treated
wastewater  than in the raw wastewater.

2.  Tank Truck Cleaning Facility B

This tank truck cleaning  facility  typically  cleans  about  40 tank
interiors  per  day.    Most  trucks  are accepted  for  cleaning;
exceptions  are  ones containing  highly odiferous residues  about
which neighboring residents have complained,  residues that have a
high  biochemical  oxygen  demand  that might  upset the  POTW,  and
highly colored residues.

The  tank  trucks  are   generally  empty  when  they  arrive  at  the
facility,  containing only a couple  of gallons or less of heel.  If
this heel  is  soluble  in water and compatible  with  the treatment
process,  it is  drained  into  the  wastewater  treatment  system.
Phenols,  fatty acids,  waxes,  and  residues  that  tend  to  plug
pipelines  are  segregated  to  a   holding  tank.    Non-flammable
solvents,  resins, and  oils are segregated to a dumpster.   These
containers are emptied by a vacuum  truck every two to three weeks,
and the contents are taken to a disposal facility.

All interior washing at this facility is done with spinner nozzles
inserted through  the   main  tank  hatch.   Facility  employees  can
choose among hot and cold water rinses/washes, caustic washes, and
presolve steps.  Caustic solution is captured for reuse.  Average
water use ranges between 20,000 to 22,000 gallons per day.

Wastewater treatment at this facility consists of initial settling
and equalization in  an old tank truck followed by coagulation and
settling in a Dorr-Oliver reactor clarifier.   Ferric chloride and
lime are used as coagulants.  Sludge from the clarifier is stored
                               21

-------
                                               KXYMtH
   MFIUENT FROM
    F i o«fl CHAINS'
                        8 000 UAI

                      HOLDING IANK
  DISSCMVtD AIH
FIOIAFION Cl AHIfttR
                                                                 MXMG TANKS
                                                       RAW WASTEWATER
                                                       SAMI'U I OCA I ION
                                                                             800 GAt
                                                                             SIUOGE  I—
                                                                             s ion AGE
WASTEWATEH
ropoiw

EFFLUENT
SAMPlt I OCA! (ON
             	k SIUOGE rOlANDFH
                                                                                          FIGURE MM
                                                           WASTEWATER TREATMENT SCHEMATIC
                                                               TANK TRUCK CLEANING FACILITY A
b.107 06

-------
N3
LO
                                                                  TABLE  III-3


                                                         SUMMARY OF ANALYTICAL RESULTS
                                                        TANK TRUCK CLEANING FACILITY  A
Pollutant
or Pollutant
Characteristic Units
Volatile Organic Pollutants
acetone |jg/£
benzene Mg/£
chlorobenzene H8/£
ethylbenzene M8/^
methylene chloride Hg/2
tetrachloroethene M8/-&
toluene M8/^
trichloroethene H8/^
1 , 1 , 1-trichloroethane M8/^
2-butanone M8/^
Semivolatile Organic Pollutants
biphenyl M8/^
bis(2-ethylhexyl)
phthalate M8/£
di-n-octyl phthalate M8/^
fluorene M8/£
n-eicosane Mg/^
n-hexacosane M8/£
n-hexadecane M8/^
naphthalene M8/£
phenol H8/£
styrene M8/^
thioxanthone H8/£
1-methylf luorene Mg/JK
1-methylphenanthrene Mg/£
2-chloronapthalene Mg/^
Day 1
Tap Raw
Water Waste
(15205) (15203)

-
6,961
—
3,257
--
—
4,884
—
—
—

4,452

5,403
3,433
--
—
—
14,859
8,024
5,484
22,325
275
1,488
2,514
4,481
Day 2
Raw
Waste
(15204)

124
4,574
53
3,184
98
573
1,082
39
83
814,700

43

31
24
10
215
—
44
54
—
277
--
—
—
37
Effluent
(15209)


5,566
._
1,064
._
__
534
__
..
7,699



--
.-
—
__
14,107
2,426
1,939
—
5,231
_-
._
—
3,850

-------
                                                TABLE  III-3  (cont.)

Pollutant
or Pollutant
Characteristic

Tap
Water
Units (15205)
Day 1
Raw
Waste
(15203)
Day 2
Raw
Waste
(15204)


Effluent
(15209)
Semivolatile  (cont.)

2-methylnaphthalene
2,3,6-1 richlo ropheno1
2,4-dinitrotoluene
4-nitrophenol

Pesticides and Herbicides

leptophos
2,4,-dichlorophenoxyaceti c
     acid
dichlorprop
coumaphos
azinphos methyl
MCPA
dioxathion

Dioxins/Furans

Metals

calcium
magnesium
sodium
aluminum
manganese
lead
vanadium
boron
barium
beryllium
cadmium
                              7,261

                              2,574
                            20,527
                               838t
                               990

                               110
                  NA
NA
MS/*
31,000
9,200
4,800
150
—
—
—
23
19
—
—
110,000
75,000
1,900,000
39,000
160
210
10
330
190
1
6
                  11
               1,920

                 350
                 359t
2,752

   NA
              75,000
              40,000
           3,000,000
              27,000
                 130
                 180
                   7
                 200
                 160
                   1
                  12
                    l,020t
                    1,380

                      240

                    2,130
                      260
NA
                  47,000
                  25,000
                2,400,000
                  93,000
                      55
                      80
                       3
                     220
                      69

-------
                                                            TABLE II1-3 (cont.)
NJ
             Pollutant
             or  Pollutant
             Characteristic
                                   Units
Metals  (cont.)

molybdenum                          Hg/£
cobalt                              pg/£
chromium                            Mg/£
copper                              (jg/£
iron                                |jg/£
nickel                              pg/£
titanium                            Hg/£
zinc
arsenic
antimony

Conventional Pollutants

Residue, non-filterable             mg/£
BOD 5-Day                           mg/£
Oil and grease,
 total recoverable                  mg/£
pH                                  S.U.

Classical Nonconventional Pollutants

Residue, filterable                 mg/£
Fluoride                            mg/A
Ammonia, as N                       mg/£
Nitrogen, Kjeldahl, total           mg/£
Nitrate-nitrite, as N               mg/£
Total phosphorus, as P              mg/£
Chemical oxygen demand              mg/£
Total organic carbon                mg/£
Sulfide, total (iodometric)         mg/£
  Tap
 Water
(15205)
 Day I
  Raw
 Waste
(15203)
                                                                   10
                                                                   NA
                                                                   NA

                                                                   NA
                                                                   NA
                                                                   NA
                                                                   NA
                                                                   NA

                                                                   NA
                                                                   NA
                                                                   NA
                                                                   NA
                                                                   NA
                 30
                 38
                260
              9,300
                 41
                440
              5,700
                137
              8,700
              1,400

              1,000
               11.2
             10,000
                  2
                 11
                 33
               0.96
                6.0
             22,000
              5,600
                 12
 Day 2
  Raw
 Waste
(15204)
                     23
                     37
                    470
                  6,800
                     41
                    270
                  3,700
                     69
                  2,600
                 4,200q

                    230
                   12.4
                 16,000
                    1.9
                    7.7
                    9.2
                    1.0
                    3.2
                 12,000
                  5,900
                    4.3
Effluent
 (15209)
                       12
                        6
                       16
                      210
                    2,200
                       22
                      170
                    2,400
                    2,020
                       30
                    8,300
                   3,800q

                       59
                      9.6
                   13,000
                     0.65
                       10
                       NR
                     0.85
                     0.22
                   12,000
                    5,300
                      2.4

-------
                                                              TABLE III-3 (cont.)
Pollutant
or Pollutant
Characteristic Units
Cyanide, total pg/£

NOTES:
Indicates pollutant concentration below
NA Indicates not analyzed
q "Qualified" value. The check sample run
NR Matrix interference
t Tentative identification below detection
Tap
Water
(15205)
NA
detection limit
concurrently with
limit.
Day 1
Raw
Waste
(15203)
--
the sample
Day 2
Raw
Waste
(15204)
20
did not meet specified
Effluent
(15209)
--
criteria.
to

-------
                                TABLE III-4

            SUMMARY OF MATERIALS LAST CONTAINED,  AUGUST 4,  1986
                      TANK TRUCK CLEANING FACILITY A
    Material Last                                           Number of
   Contained In Tank        	Tanks

Acetate                                                          3

Acid                                                             l

Dipotassium phosphate                                            1

Glue                                                             1

Latex                                                            2

Lube oil                                                         1

Petroleum naptha                                                 1

Resin/resin solution                                             2

Soap                                                             *
                                        27

-------
                                TABLE III-5

           SUMMARY OF MATERIALS LAST CONTAINED, AUGUST 5-8, 1986
                      TANK TRUCK CLEANING FACILITY A
    Material Last                                           Number of
   Contained In Tank	Tanks

Acid                                                             4
Acrylate                                                         1
Alcohol                                                          i
Butyl acetate, acetate n.o.s.                                    1
Cleaning compound                                                1
Coil liquid                                                      1
Cutting fluid                                                    j
Fatty acid                                                       1
Formaldehyde                                                     2
Glycol(s)                                                        3
Latex                                                            9
Naptha                                                           }
Oil                                                              4
Oil additive                                                     1
Plasticizer                                                      1
Polypropylene glycol                                             2
Resin                                                            1
Wine                                                             i
Xylene                                                           1

-------
in the tank truck mentioned above and removed on a periodic basis
for disposal.

Twenty-four hour composite samples of raw wastewater and effluent
were collected on two days at this  facility.   The raw wastewater
samples were collected  from  a  small  sump  in  the  floor  trench
system  upstream  of   the  initial  wastewater   settling   tank.
Effluent samples were  collected  from the effluent  trough  of the
primary clarifier.   A sludge sample was collected on one day from
the discharge of the sludge transfer pump.  Figure III-2 presents
a  schematic  of  the  treatment  system  and  shows  the  sample
collection points.

Table  III-6  summarizes  the  results  of  analysis  for  samples
collected  at this  facility.   As can be seen,  several  organic
pollutants were found at high levels in raw wastewater.  For some
of    the    pollutants,    acetone,     methylene    chloride,
orthodichlorobenzene,  2-butanone,  isobutyl  alcohol,  and  methyl
methacrylate,  there is  a correlation between  detection  in raw
wastewater  and  the  cargos last  contained in the  truck  tanks as
listed  in  Tables  III-7  through   III-9.     In   other  cases,
correlation   is  not   evident.      The   detection   of   several
semivolatile organic pollutants  in effluent sample 15179, but net
in  raw  sample 15178  is possibly attributable to  the laboratory
dilution of  the  raw wastewater  sample  which raised the pollutant
detection  limits.

Comparison  of  the  analytical   data  for  the  sludge with  the
criteria  for hazardous  waste  characteristics indicates that it
would be  considered hazardous,   based  on  the RCRA characteristic
of  ignitability.    In  addition,  the concentration  of methylene
chloride  in the  TCLP  leachate  exceeds  the  proposed regulatory
level for  that  pollutant shown  in Table  111-10.   The  unextracted
sludge  contains several  organic pollutants at high levels that
did not appear  in the TCLP leachate.

3.  Tank Truck Cleaning Facility C

This  tank truck cleaning facility cleans  approximately  40 tank
truck interiors per day as well as an occasional tank exterior.
Several  petrochemical  refineries  are located  nearby,  and the
facility cleans tanks that have  carried a wide variety of organic
compounds.   Most tanks  are accepted  for cleaning.

Trucks  are usually  empty when  they  arrive at the facility and
contain  only  a small  amount  of heel.    If  the heel  is  water
soluble and compatible with the wastewater treatment  process, it
is  drained  to  the  treatment   system.    Non-water  soluble and
incompatible  heels  are  segregated   for  subsequent  off-site
disposal.

Cleaning   is  accomplished  using combinations  of  hot  and  cold
water,  detergent,  caustic,  and  solvent  applied  with  spinner
nozzles and hand hoses.   In addition,  many  tanks  are steam
                                29

-------
            INFLUENT FROM
            FIOOH DRAMS
HAW WASTEWAHH
SAMPIE IOCATION
                                                                  fLRHIC CttORIOEx

                                                                         LIME.
                                                                                 PRIMARY
                                                                                 HtACIOR
                                                                                 ClARIMEH
                                                   CONTRACT IUSPOSAI
                                                      Of SOI IDS
                                                  \
                                                                  WASTE WAI EH
                                                                  fO PO1W
                                                                                             EFFLUENT
                                                                                             SAMPIE IOCATION
                                                                                      SlUOGE
                                                                                      SAMPtE IOCATION
                               HKJ»*Y COIORI D WASIES
              PHENOIIC WASltS
                  AC«>S. WAX»;S
                           CON I MAC I DISf'OSAI
                                                                                            FIGURE 111-2
                                                            WASTEWATER TREATMENT SCHEMATIC
                                                                TANK TRUCK CLEANING FACILITY B
1)6

-------
                                                       TABLE  III-6

                                               SUMMARY OF ANALYTICAL RESULTS
                                              TANK TRUCK CLEANING FACILITY  B
                                                              Dav  1
                                                                                    Day 2
Pollutant
or Pollutant
Characteristic

Units
Liquid (Sludge)
Tap
Water
(15182)
Raw
Waste
(15178)

Effluent
(15179)
Raw
Waste
(15180)

Effluent
(15181)

Sludge
(15177)
TCLP
Extract
(15177)
Volatile Organic Pollutants

acetone
alpha-picoline
benzene
chloroform
diethyl ether
ethylbenzene
methylene chloride
toluene
trichloroethene
1 , 1 , 1-trichloroethane
1,2-dichloroethane
2-butanone
isobutyl alcohol
methyl methacrylate
1 ,2,3-trichloropropane
                           pg/£(ug/kg)
                           Mg/*(Pg/kg)
                           Hg/*(Mg/kg)
                           Mg/*(Mg/kg)
                           Pg/£(pg/kg)
                           pg/*(Mg/kg)
                           Mg/*(Mg/kg)
                           JJg/£(|Jg/kg)
                           pg/J&(jJg/kg)
                           Mg/*(Mg/kg)
Senivolatile Organic Pollutants
acenaphthene
acenaphthylene
anthracene
benzidine
benzoic acid
biphenyl
bis(2-ethylhexyl)
 phthalate
butyl benzyl phthalate
—
--
96
_-
_ _
10,144
116,649
169,000
86
1,407
__
86,072
5,626
1,232
186
140,526
54
29
_-
	
685
13,730
15,295
79
582
--
19,477
1,148
--
—
9,169
—
32
12
._
1,414
2,854
10,246
93
599
12
—
137
11
--
--
—
19
--
—
1,102
7,474
25,869
68
284
— •
12,600
614
--
—
—
--
670
--
585
7,798
514,117
164,032
660
5,723
702
—
26,862
~"
--
1,543
--
42
--
—
313
14,176
7,448
58
305
--
--
742
" —
72
                                                                     17
                                                                     81
                                                                     164
                                                                      13
                                                                               39
                                                                              913
                                                                                            15
 8,511
53,479
23,287

-------
                                                                 TABLE  III-6  (cont.)
N3
Pollutant
or Pollutant
Characteristic
Semivolatile (cont.)
di-n-butyl phthalate
di-n-octyl phthalate
f luoranthene
f luorene
hexanoic acid
isophorone
n-docosane
n-eicosane
n-tetradecane
naphthalene
phenanthrene
phenol
pyrene
styrene
1 ,2-dichlorobenzene
1 ,4-dichlorobenzene
2-chloronaphthalene
2,4-dichlorophenol
2 ,6-dinitrotoluene
4-chloro-3-methylphenol

Units
Liquid (Sludge)

Mg/*(Mg/kg)
Mg/*(Mg/kg)
|jg/£((jg/kg)
Mg/*(Mg/kg)
Mg/£(Mg/kg)
Mg/£(Mg/kg)
Mg/*(Mg/kg)
Mg/£(Mg/kg)
Mg/*(Mg/kg)
Mg/*(Mg/kg)
Mg/*(Mg/kg)
Mg/£(pg/kg)
Mg/*(Mg/kg)
Mg/£(Mg/kg)
ug/£(pg/kg)
Mg/*(Mg/kg)

Mg/*(Mg/kg)

Pesticides and Herbicides

Dioxins/Furans
Metals
calcium
magnesium



ug/£(mg/kg)
(Jg/£(mg/kg)
Tap
Water
M5182)

--
--
--
— _
62
-_
::
--
—
--
•-- .
__
__
—
NA
NA

12,000
960

Raw
Waste
(15178)

--
__
-_
::
__
__
4,538
—
--
10,790
_..
_—
» _
—
NA
NA

42,000
3,100
Day 1

Effluent
f 15179)

27
114
17

295
47
195
39
81
20

__
91
159
29


-------
                                                                TABLE  III-6  (cont.)
OJ
OJ
Day 1
Pollutant
or Pollutant
Ctid rsctcristic
Metals (cont.)
sodium
aluminum
manganese
lead
vanadium
boron
barium
cadmium
molybdenum
tin
cobalt
chromium
copper
iron
nickel
titanium
zinc
silver
arsenic
antimony
mercury
Units
Liquid (Sludge)

ug/£(mg/kg)
Mg/£(mg/kg)
ug/£(mg/kg)
ug/£(mg/kg)
Mg/£(«g/kg)
ug/£(mg/kg)
Mg/£(mg/kg)
Hg/£(«g/kg)
ug/£(mg/kg)
Mg/£(mg/kg)
ug/£(mg/kg)
Mg/£(nig/kg)
Mg/£(ng/kg)
ug/£(mg/kg)
Mg/£(mg/kg)
Mg/£(mg/kg)
ug/£(ing/kg)
Tap
Water
I 15182)

2,000
40
1.0
11
in
1 J
--
•• ~
110
20
17
--
--
—
Raw
Waste
(15178)

260,000
240,000
350
2,100
12
1,500
680
210
43
96
1,200
2,200
53,000
140
1 **w
5,200
2,300
19
120
0.9
Effluent
(15179)

230,000
1,400
120
120
2,200
80
12
17
54
44
41
12,000
29
61
150
1.0
n A
28
Day 2
Raw
Waste
(15180)

200,000
110,000
93
780
280
190
56

2,300
610
8,900
59
3,200
1,500
10
. 0
e,i\
ou
0.7
Effluent
(15181)

300,000
840
320
260
3,500
100
16
1Q
1 7
140
55
30,000
28
63
1,000

19
Lf,
Sludge
(15177)

4,610
6,040
115
571
276
364
152
212
2,000
442
14,700
55
202
1,030
4.5

	
1.5
TCLP
Extract
(15177)

1,430,000
947
1,740
214
1,160
2,180
57
104
92
234
312,000
210
3,240
— —
— —
--
Conventional Pollutants

Residue, non-filterable
BOD 5-Day
Oil and grease,
 total recoverable
pH
                                           mg/£
NA
NA
9,600
1,400
230
900
8,100
1,600
                                           mg/£
                                           s.u.
NA       310c
NA  6.2-10.6
               92c      310c
         6.2-10.9  8.0-10.7
     250
   1,600

      86c
7.2-10.8
NA
NA

NA
NA
NA
NA

NA
NA

-------
                                                                TABLE II1-6 (cont.)
OJ
Pollutant
or Pollutant Units
Characteristic Liquid (Sludge)
Classical Nonconventional
Residue, filterable
Fluoride
Ammonia, as N
Nitrogen, Kjeldahl, total
Nitrate-nitrite, as N
Total phosphorus, as P
Chemical oxygen demand
Total organic carbon
Pollutants
mg/£
mg/£
mg/£(mg/kg)
mg/£(rog/kg)
mg/£(mg/kg)
»g/£
mg/£
mg/£
Sulfide, total (iodometric) mg/£
Flash point
pH, soil
Residue, total
Residue, total volatile
Sulfide, total
(Monier-Williams)
Cyanide, total

(°C)
(s.u.)
(%)
(%)

(mg/£)
Mg/£(mg/kg)
Tap
Water
(15182)

NA
NA
NA
NA
NA
MA
NA
NA
NA
NA
NA
NA
NA

NA
NA
Raw
Waste
(15178)

8,700
2.1
49
0.11
__
4,600
1,600
1.2c
NA
NA
NA
NA

NA
--
Raw
Effluent Waste
(15179) (15180)

2,400
0.38
1.9
24
0.12
0.87
2,700
830
2.2c
NA
NA
NA
NA

NA
47

9,800
1.4
29
0.44

4,600
780
2.3c
NA
NA
NA
NA

NA
190
Effluent
(15181)

2,800
0.28
4.0
23
0.21
0.38
3,300
1,000
1.4c
NA
NA
NA
NA

NA
22
Sludge
(15177)

NA
NA
11 n
2,000
NA
11 n
NA
NA
iin
NA
53
8-1
. j
9.4
6 3
M • J
34
17
TCLP
Extract
(15177)

NA
MA
HA
NA
NA
ii n
NA
11 XI
NA
nn
NA
NA
nn
NA
11 n
NA
nn
NA
NA
           NA   Indicates  not  analyzed
           c    Average  of six grab  sample  results

-------
                                TABLE III-7

          SUMMARY OF MATERIALS LAST CONTAINED, SEPTEMBER 23, 1986
                      TANK TRUCK CLEANING FACILITY B


         . ,  T  .                                            Number of
    Material Last                                              Tanks
   Contained In Tank
NBA (n-butyl alcohol)                                            1
Citral                                                           ,
ECH (Epichlorohydrin)                                            ^
Flammable liquid                                                 2
Glue                                                             2
Isopropal alcohol                                                _
Latex                                                            2
Methylene chloride  (crude)
Methyl ethyl ketone
ODCB  (Orthodichloro benzene)
Oil                                                               i
Paranox                                                           ^
Plasticizer                                                       .
SD-40  alcohol  (food grade)
Shell  Flex  (plasticizer)                                          2
Solvent                                                           ,
Triethanolamine,  methanol,  methyl ethyl ketone                   *
Waste                                                             j
Wastewater
                                         35

-------
                                  TABLE III-8

            SUMMARY OF MATERIALS  LAST CONTAINED,  SEPTEMBER 24  1986
                        TANK  TRUCK CLEANING FACILITY B


      Material  Last                                          Number   f
	Contained  In Tank	Tanks/Compart..

 Acetone, methanol                                                ,
 Acetone  (waste)
 Diethylamine                                                     ?
 Diethylene glycol, isopropyl alcohol                             j
 ECH  (Epichlorohydrin)                                            ,
 Formaldehyde
 Glue
 Glycol                                                           :
 Igepal
 Isobutyl alcohol                                                 ,
 Isopropyl alcohol, butanol                                       •,
 Latex                                                            *
 Methyl methacrylate                                              2
 Methylene chloride (crude)                                       j
 Mixed alcohol                                                    ,
 Naptha                                                           f
 VM and P naptha                                                  ,
 Plastic pellets                                                  j
 Resin, paint                                                     ,
 Slurry                                                           1
 Tank bottoms                                                     ,
 Wastewater                                                        ,
                                         36

-------
                                 TABLE III-9

          SUMMARY OF MATERIALS LAST CONTAINED, SEPTEMBER  25,  1986*
                       TANK TRUCK CLEANING FACILITY B


     Material Last                                            »«•*« °f
     Contained In Tank	.	Tanks

  ABS (plastic pellets)                                             J
  Carbitol acetone                                                  *
  Chromate                                                          j
  Ethanol                                                           *
  Igepal                                                            }
  Isopropyl  alcohol                                                 i
  Laquer solvent                                                   ;f
  Latex                                                            *
  Methyl ethyl ketone                                               1
  Methyl isobutyl  ketone                                            1
  Myrcene                                                           *
  o-Cresol                                                          J
  Paint thinner                                                     |
  Paranox                                                           ;
  Resin, RCI                                                       1
  SD-40 alcohol  (food  grade)                                        *
  Slurry                                                           \
  Soap                                                             \
  Tolu-Sol                                                          A
  Sodium Tripolyphosphate (Tripoly)                                 1
  Waste                                                            3
  Waste solvents                                                   ^
  VM and P  naptha                                                  1
*Includes several tanks cleaned from 0000 to 0700 hours on September 26, 1986.
                                     37

-------
                                 TABLE 111-10

                 PROPOSED TOXICITY CHARACTERISTIC CONTAMINANTS
                             AND REGULATORY LEVELS
Contaminants
                                                             Regulatory Level
Acrylonitrile
Arsenic
Barium
Benzene
Bis(2-chloroethyl)ether
Cadmium
Carbon disulfide
Carbon tetrachloride
Chlordane
Chlorobenzene
Chloroform
Chromium
o-Cresol
m-Cresol
p-Cresol
2,4-D
1 ,2-Dichlorobenzene
1 , 4-Dichlorobenzene
1 ,2-Dichloroethane
1 , 1-Dichloroethylene
2,4-Dinitrotoluene
Endrin
Heptachlor (and its hydroxide)
Hexa chlorobenzene
Hexachlorobutadiene
Hexa chlo roe thane
Isobutanol
Lead
Lindane
Mercury
Methoxychlor
Methylene chloride
Methyl ethyl ketone
Nitrobenzene
Pentachlorophenol
Phenol
Pyridine
Selenium
Silver
1,1,1, 2-Tetrachloroethane
1,1,2, 2-Tetrachlorethane
Tetrachloroethylene
2,3,4, 6-Tetrachlorophenol
Toluene
Toxaphene
1,1, 1-Trichloroethane
107-13-1
7440-38-2
7440-39-3
71-43-2
111-44-4
7440-43-9
75-15-0
56-23-5
57-74-9
108-90-7
67-66-3
1333-82-0
95-48-7
108-39-4
106-44-5
94-75-7
95-50-1
106-46-7
107-06-2
75-35-4
121-14-2
72-20-8
76-44-2
118-74-1
87-68-3
67-72-1
78-83-1
7439-92-1
58-89-9
7439-97-6
72-43-5
75-09-2
78-93-3
98-95-3
87-86-5
108-95-2
110-86-1
7782-49-2
7440-22-4
630-20-6
79-34-5
127-18-4
58-90-2
108-86-3
8001-35-2
71-55-6
. 	 img/i;
5 0
•J • w
S 0
•J • w
100
±\J\J
0.07
One.
• Uj
i n
1 • U
14 4
A *T • *T
0.07
0.03
i /,
i . <+
0 07
*/ • w /
S 0
•J • \J
inn
i. \j . \j
inn
X \J * \J
10 0
±\J f \J
1 L
A . H
L ~\
•» • J
10 R
i\J . o
0 40
\J • *T W
n i
u . j.
n i ?
\j . i o
0.003
0.001
0 1 "}
U . 13
0 79
VJ . / t.
U "\
H . J
36
*J V/
5 0
J • \J
0.06
00
. ^
1 4
A « ^T
8.6
7 p
/ . ^
0 1 ?
U . i J
3.6
14.4
S 0
*J . V/
1.0
5 0
*J • \J
10.0
1 1
A * -J
0. 1
1 5
JL • J
14.4
0.07
30

-------
                           TABLE 111-10 (continued)





                                                             Regulatory Level
Contaminants 	 	
1 , 1 ,2-Trichloroethane
Trichloroethylene
2,4,5-Trichlorophenol
2,4, 6-Trichlorophenol
2,4,5-TP (Silvex)
Vinyl chloride
CAS No.
79-00-5
79-01-6
95-95-4
88-06-2
93-76-5
75-01-4
(•g/L)
1.2
0.07
5n
.8
0.30
01 /
. 14
0.05
Source: 51 FR 21648, June 13, 1986
                                            39

-------
 cleaned.   The detergent and  caustic  solutions  are recycled in  a
 closed system until  they are  too dirty to be effective,  then they
 are drained  to  the  treatment system.    The  cleaning  solvent
 contains  30  to  40  percent volatile  compounds  such  as  acetone,
 methyl ethyl ketone,  and  methyl  isobutyl  ketone, and  60 to 70
 percent xylenes and mineral  spirits.   It  is  recycled until too
 contaminated  for  further  use and  is  then disposed  off-site.
 Average water use  is about  25,000  gallons per day.

 The wastewater treatment system at this  facility consists of pH
 adjustment   with   sulfuric  acid,   equalization,  coagulation-
 sedimentation in  a rectangular  clarifier baffled  to  create   a
 serpentine  flow path,  and filtration through a 40  m paper filter.
 Ferric chloride  is  used  to  coagulate  wastewater   solids  and
 powdered  activated carbon  is  added  to  the influent well of the
 clarifier to  improve removal  of organic compounds.   Both the pH
 adjustment  tank (7,000-gallon volume) and  the  equalization tank
 (240,000-gallon  volume)  rely  on  aeration  for  mixing,  and  in
 these,  air  stripping of volatile pollutants probably occurs.

 Operating day composite samples were  collected  of raw wastewater
 and treatment process  effluent on  two days at this facility.  The
 raw wastewater samples were collected from a collection  sump that
 received  all  raw  wastewater   from floor drains.   The   effluent
 samples  were  collected  from  a  small  diameter  drop  manhole
 following the 40m  filter.    Grab  samples of clarifier   influent
 were collected from  the pipeline connecting the equalization tank
 and clarifier.   A sample of  dewatered sludge was collected from
 the discharge of the belt filter press.   Figure III-3  presents a
 schematic of the treatment system  and shows the sample collection
 points.

 The analytical results for samples collected at this facility are
 summarized  in  Table  III-ll.    Review  of  the  data   shows  that
 approximately 30 organic pollutants were  reported in  the various
 samples   and   that,   with  the  exception  of   pesticides   and
 herbicides,  volatile pollutants were detected  more   often  than
 semivolatile  pollutants.  More semivolatile pollutants  may  have
 been   present,  but  were   not  reported  because  of   the  high
 analytical  detection   limits   for   those   pollutants.     The
 semivolatile pollutant detection limit, excluding those  for TCLP
 extract,  were seldom  less  than 1,000 micrograms per liter  and
 ranged as high as  500,000 micrograms  per  liter  because of sample
dilution by the laboratories during sample analysis.   Tables III-
 12 through 111-19 list the cargos last contained in tanks cleaned
during the sampling period and the preceding five days.  The only
 readily apparent correlations between cargos and wastewater  were
the  detection of  2,4-diaminotoluene  in  raw wastewater  on  the
 second day of sampling and chromium in the sample of equalization
tank effluent.
                               40

-------
    RAW WASTEWATER

    SAMPLE LOCATION
                                                            IN 11 IIMt IXAI f WASTEWATER
                                                            SAMI'll I <>C,A! ION
                           POWDERED ACTIVAIH) CAfWON
          MFLIJEN1 FROM
          FLOUR DRAINS
                                                                                   EFFLUENT
                                                                                   SAMPlE IOCAIION
WAS1EWAIER
 IO POTW
                                                                                      OF. WATERED SI ULXJE
                                                                                        lOlANDFtl

                                                                                      SLUDGE SAMPLE LOCATION
                                                            POIYMHI-
                                                                                               FIGURE 111-3
                                                                WASTEWATER TREATMENT SCHEMATIC
                                                                   TANK TRUCK CLEANING FACILITY C
V10/ 06

-------
                                                                                             TABLE 111-II

                                                                                     SUMMARY OF ANALYTICAL RESULTS
                                                                                    TANK TRUCK CLEANING  FACILITY C
                                                                                                        Day  I
                                                                                                                                           Day 2
K>
Pollutant
or Pollutant
Characteristic
Volatile Organic Pollutants
acetone
benzene
chlo robenzeoe
ethylbenzene
isobutyl alcohol
•ethacrylonitrile
•ethylene chloride
n.a-diBetbylforumde
toluene
trichloroethene
1,1, 1-trichloroethane
2-butanone
SesiiTolatile Organic Pollutants
bis(2-ethylbeiyl)
phtkalate
bis(2-chloroethyl)
ether
diethyl phtbaUte
naphthalene
atyrene
2.4-diasiinotol«eae
2,4-diaethylpheaol
Pesticides and Herbicides
beptachlor «poxide
propachlor
azinphos ethyl
azinphoe Bethy!
deMton (Mixed)
diazinon
dioxathion
HMPA
leptopbot
naled
Units
Liquid (Sludge)

Mg/«(Mg/kg)
Mg/«(Mg/kg)
Mg/«Mg/kg)
t>g/>(Mg/k()
Mg/t(Mg/kg)

Mg/t(Mg/kg)
Mg/t(Mg/kg)
Mg/»(Mg/kg)
Mg/*(Mg/kg)
Mg/Ufg/kg)
Mg/*(Mg/kg)


Mg/*(Mg/kg)

M8/«MI/kg)
M(/((MI/kg)
Mg/t(Mg/kg)
Mg/*
-------
                                                                                         1'ABI.E 111-II  (cone.)
                                                                                                         Day 1
                                                                                                                                             Day  2
to
Pollutant
or Pollutant
Characteristic
HetaU
calcine)
•agnesius)
sodiun
aluaimtt)
•anganese
lead
vanadium
boron
barium
beryllium
cadmium
•solybdenum
tin
cobalt
chromium
copper
iron
nickel
titanium
zinc
silver
arsenic
antimony
mercury
Conventional Pollutanta
Residue, non-filterable
BOO 5-Day
Oil and grease,
total recoverable
P«
Hints
Liquid (Sludge)

Mg/t(.g/kg)
ug/«(«g/kg)
Mg/Zf.g/kg)
Mg/*("g/kg)
Mg/*(»g/kg)
Hg/tdg/kg)
Mg/i(ng/kg)
pg/C(sjg/kg)
|ig/f(ng/kg)
Mg/*<-g/kg)
ug/Kng/kg)
pg/«(ng/kg)
Mg/*<»8/kg)
Hg/i(ng/kg)
(ig/K-g/kg)
|lg/t(ng/kg)
pg/t(»g/kg)
Mg/((ng/kg)
Mg/Kmg/kg)
»ig/t(.g/kg)
ug/«(ng/kg)
ug/i(ug/kg)
Mg/*(«g/«g)
M8/«(-8/kg)

•s/t
•g/t

•l/<
s.u.
Tap
Water
(15602)

9.670
2,550
175.000
280
J9
—
—
225
191
--
--
—
--
—
«
--
«
--
28
--
454
--
--

NA
NA

NA
7.2
Raw
Waste
(15597)

104,000
4,150
1 .900,000
^55,000
227
—
•)6
4,350
342
6
.
--
—
58
1.170
314
4,880
117
112
787
•-
446,000
--
--

2,300
3,900

3,100C
9.5-12.4
Equalization
Tjnk
Effluent
(15606)

249,000
8,530
3,890,000
517,000
484
719
126
7,580
476
13
16
133
--
248
1,120
825
16,100
1,860
299
2,310
—
16,800
--
— —

9,000
7.200

2,600
7.7-8.5
Effluent
(15598)

405,000
4,480
3,440,000
2,930
241
--
--
5,200
--
--
5
—
--
86
—
8,000
275
--
425
—
2,200
—
"

ISO
3,000

89d
7.4
Equalization
Raw Tank
Waste Effluent Effluent
(15599) (15607) (15600)

130,000
5,970
1,700,000
294.000
340
500
110
4,040
655
10
21
--
--
76
7,190
1.160
8,510
244
232
1,240
3.1
985
--
"

4,000
1,500

980c
8.0-9.3

196,000
6,610
3,370,000
368,000
349
520
103
6,050
240
10
9
--
--
170
969
597
12,100
1,180
216
1,660
--
31,800
--
0.3

6,500
4,700

3,000
6.6

506,000
4,640
3,070,000
1,040
307
*~
--
5,370
-•
•"
•~
••
~"
82
--
5,740
353
—
443
--
2,100
140


100
2,400

56d
7.2-7.3
Sludge
(15601)

7,610
306
6.270
21,300
41.8
~ —
6.0
40
82
0.5
1.8
--
4.5
4.0
41.4
28.4
8,370
69
26.8
77.8
24
19
"™


NA
NA

NA
NA
TCLP
Extract
(15601)

213,000
4.820
1,350.000
1,810
1,060
™~
""
644
97
--
8
~~
~™
51
256
5.130
1,660
"•
700
"•
634
™*


NA
NA

NA
NA
Classical Honconventional Pollutants
Residue, filterable
Fluoride
Amaonia, aa H
Nitrogen, Kjeldahl, total
Nitrate-nitrite, aa N
Total phosphorus, aa P
Cbentical oxygen demand
Total organic carbon
Sulfide, total (iodonetric)
•g/<
•s/t
•g/t(s>g/kg)
•g/t(ng/kg)
•g/l(s>g/kg)
•g/t
•g/£
•g/t

NA
NA
NA
NA
NA
NA
NA
NA
NA
7,600
9.1 NR
1.4
llx
0.64
6.6
9,300
970
12
13,000
21 NR
--
290
--
3.5
13,000
1,300
6.6
13,000
0.79
2.6
200
--
4.6
5.760
910
--
7,700
5.1
8.4
230
~"
8.5
18,000
2,800
6.0c
12,000
8.0
--
210
"~
6.2
10,000
1,300
7.7
12,000
0.76
3.1
180
"•
3.9
5,700
760
~"
NA
NA
660
S.800
1.5
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

-------
                                                                        TABLE  III-ll (coat.)
                                                                                      Day 1
                                                                                                                         Day 2
Pollutant
or Pollutant
Characteristic
CUsiical (cont.)
Flash poiot
pH, toil
Residue, total
Residue, total volatile
Sulfide, total
(Modified Hooier-Williaan)
Corrosivity
Cyaaide. total
Cyaoide, total
Units
Liquid (Sludge)
Tjp
Water
(15602)
c
Raw
Waste
(15597)
qualization
Tank
Effluent
(15606)
Equalization
Raw Tank
Effluent Waste Effluent Effluent
(15598) (15599) (15607) (15600)
TCLP
Sludge Extract
(15601) r 11601 t

(°C)
(s.u.)
(1)
(t)
<•«/«*)
(•its per year)

Mg/£(.g/«g)
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

35
NA
NA
NA
NA
NA
NA

110
NA
NA
NA
NA
NA
NA

39
NA
NA
NA
NA
NA
NA

23
NA
NA
NA
NA
NA
NA

100
NA
NA
NA
NA
NA
NA

36
56
7.5
19
10
9.0 NR
R

10
NA
NA
NA
NA
NA

NA
Hotel:

—  Indicate! pollutant concentration below detection Unit
NA  Indicates not analyzed
c   Average of sis grab aasiple  results
d   Average of two grab sanple  results
R   Mot reported at this tin.  Refer to Report of Analysis
MR  Potential awtri* interference
z   Upon receipt by lab, pH was not within the specified range for preservation

-------
                               TABLE 111-12

           SUMMARY OF MATERIALS LAST CONTAINED, JANUARY 21, 1987
                      TANK TRUCK CLEANING FACILITY C


    Material Last                                           Number of
   Contained In Tank      	   Tanks

Alkyldimethylamines (ADMA)                                       1
Ammonia sulfate                                                  1
ANZK (drilling additive)                                         1
Bihexylmethylene triamine (BHMT)                                 1
Calcium stearate                                                 1
Caustic                                                          3
Chromate                                                         1
Diethylamine                                                     1
Deicing fluid                                                    1
Diethyltoluenediamine                                            1
Formaldehyde                                                     1
Furfural                                                         2
Gasoline                                                         1
Glycol                                                           1
HAN (ammonia and water)                                          1
Herbicide                                                        *
Lard                                                             l
Latex                                                            *
Methanol                                                         3
Oil                                                              3
Oil, casting                                                     1
Oil, heavy                                                       1
Oil, soybean                                                     1
Oil, white                                                       1
Oil, 4843                                                        1
Petroleum treating compound                                      1
Phosphoric  acid                                                  1
Propylene glycol                                                 1
Propylene oxide                                                  !
Resin                                                            2
Solvent                                                          !
Steam  coils                                                     1
Styrene                                                          *
Toluene diisocyanate                                             1
Waste  turpentine                                                 1
Wastewater                                                       3
Wax                                                               1
Weed killer                                                     2

-------
                                TABLE 111-13

            SUMMARY OF MATERIALS LAST CONTAINED,  JANUARY 22,  1987
                       TANK TRUCK CLEANING FACILITY C
     Material Last                                          Number  of
    Contained In Tank 	^^         Tanks

 Acetic acid                                                      1
 ADMA                                                             j
 Alcohol                                                          2
 Alum                                                             I
 Animal feed                                                      j
 Bicep  - 61  (non-hazardous herbicide)                              1
 Calgon                                                           j
 Catalyst                                                         j
 Caustic                                                          5
 Cleaning compound                                                2
 Cresol                                                           j
 Defoamer                                                         1
 Diesel additive                                                   j
 Di-n-butylamine                                                   j
 Ethanolamine                                                      j
 Gas                                                               1
 Glycine                                                          j
 Glycol                                                           3
 Latex                                                             1
 Limonene                                                          i
 Oil                                                               !
 Oil, heavy                                                        2
 Oil, light                                                        2
 Oil, lube                                                         a
 Oil, synthetic                                                    1
 Parapol  (light oil)                                               1
 Phosphoric acid                                                   2
 Plastic pellets                                                  2
 Polypropylene glycol                                              1
 Pot ash                                                           i
 Resin                                                            2
 Rosin                                                             1
 Rosin,  sizing                                                    2
 Solvent                                                           i
 Sulfuric acid (spent)                                            3
 Toluene diisocyanate                                              1
Triethanolamine                                                   1
Vinegar                                                          1
Wastewater                                                       j
Weed killer wastewater                                           1
Wax
                                    46

-------
                               TABLE 111-14

           SUMMARY OF MATERIALS LAST CONTAINED,  JANUARY 23,  1987
                      TANK TRUCK CLEANING FACILITY C
    Material Last                                           Number of
   Contained In Tank	Tanks

Acrylonitrile                                                    !
Ammonia                                                          1
Calcium                                                          1
Caustic                                                          1
Clay slurry                                                      1
Cresol                                                           1
Ethanolamine                                                     1
Ethylene/dibromide                                               3
Ethylene/glycol                                                  1
Fatty acid                                                       1
Formaldehyde                                                     1
Gasoline additive                                                1
Glycol                                                           3
HAB (drilling additive)                                          1
Herbicide                                                        1
HME-500 (drilling additive)                                      1
Indapol                                                          1
Latex                                                            1
Methanol                                                         1
Myco Curb (animal food supplement)                               1
Neodecanoic acid                                                 1
Oil                                                              *
Oil, cooking                                                     !
Oil, motor                                                       1
Oil, waste                                                       1
Oil, white                                                       1
Oil, 30 w                                                        1
Phenol                                                           1
Phosphoric acid                                                  1
Resin                                                            2
Solvent                                                          1
Tallow                                                           1
Transmission fluid                                               1
Triisopropanolamine                                              1
Wax                                                              !
Weed killer                                                      3
Well aids                                                        1
White weed killer                                                1

-------
                               TABLE III-15

           SUMMARY OF MATERIALS LAST CONTAIKED, JANUARY 24, 1987
                      TANK TRUCK CLEANING FACILITY C
    Material Last                                           Number of
   Contained In Tank	Tanks

Animal feed                                                      1
Coline chloride                                                  1
Distillate solvent                                               1
Gasoline additive, OBA 480                                       1
Glycol                                                           1
Latex                                                            1
Oil, 10 w 30                                                     1
Oil, lube                                                        i
Polymer                                                          1
Resin                                                            2
Titanium dioxide                                                 1
Wastewater                                                       2
Wax, petroleum                                                   1
Wax, slack (candle wax)                                          1
                                      48

-------
                                TABLE  111-16

            SUMMARY OF MATERIALS LAST  CONTAINED,  JANUARY 26,  1987
                      TANK TRUCK  CLEANING FACILITY C
    Material Last                                            Number of
    Contained In Tank	Tanks

Acetonitrile                                                      1
Alcohol                                                           1
Alfol  1214                                                        1
Antifreeze                                                        1
ASOL  (blended  solvent)                                            2
Black  liquor                                                      1
Caustic                                                           1
Cleaning  compound                                                 2
Choline chloride                                                  1
Cresol                                                           1
Triethylenediamine  (Dabco APC-5)                                  1
Diesel additive                                                   1
Epoxy  resin                                                       1
Gasoline  additive                                                 1
'Hamp-ene  100 (chelating agents)                                   1
Latex                                                             1
Naptha                                                           1
Nonyl  phenol                                                      1
Oil                                                              3
Oil, light                                                        1
Palacyene                                                        1
Petroleum treating  compound                                       1
Phosphoric acid                                                   2
Pot ash                                                           1
Resin                                                             2
Roto solvent (blended solvent)                                    1
Shell  resin                                                       1
Soap                                                              1
Sodium sulfate                                                    1
Sodium sulfide                                                    1
Solvent                                                           1
Toluene diisocyanate                                              1
Water                                                             1
                                    49

-------
                               TABLE 111-17

           SUMMARY OF MATERIALS LAST CONTAINED, JANUARY 27,  1987
                      TANK TRUCK CLEANING FACILITY C
    Material Last                                           Number of
   Contained In Tank	Tanks

Alcohol                                                          2
Aniline oil                                                      1
ANZR (drilling additive)                                         1
Catalyst                                                         1
Chelating compound                                               1
Cleaning compound                                                1
Dibasic esters                                                   1
Dicyclopentadiene                                                1
Diesel                                                           2
Diethyltoluenediamine                                            1
Furfural                                                         2
Hab 500 (drilling additive)                                      1
Hydroxyacetic acid                                               1
Latex                                                            1
Mineral spirits                                                  1
Oil, heavy                                                       1
Oil, soybean                                                     1
Petroleum treating compound                                      1
Phosphoric acid                                                  2
Pot ash                                                          1
Soap                                                             1
Sodium sulfide                                                   1
Styrene        -                                                  1
Sulfonic acid                                                    1
Tallow                                                           1
Tetrahydrofuran                                                  1
Turpentine                                                       1
Vinegar                                                          1
Wastewater                                                       1
Water treating compound                                          1
Weed killer                                                      1
                                     50

-------
                               TABLE 111-18

           SUMMARY OF MATERIALS LAST CONTAINED, JANUARY 28, 1987
                      TANK TRUCK CLEANING FACILITY C
    Material Last                                           Number of
   Contained In Tank	Tanks

Acetic acid                                                      1
Aniline oil                                                      3
Catalyst                                                         1
Caustic                                                          1
Choline chloride                                                 1
Cleaning compound                                                3
p-Cresol                                                         1
Diethyltoluenediamine                                            1
Dirt                                                             3
Ethylene dibromide                                               2
Formaldehyde                                                     1
Glycol                                                           1
Insecticide                                                      1
Latex                                                            1
Liquid                                                           1
Mineral spirits                                                  2
Oil                                                              1
Oil, heavy                                                       1
Oil, light                                                       1
Oxysolve 80                                                      2
Phenol                                                           2
Phosphoric acid                                                  1
Pine oil                                                         1
Resin                                                            1
Retar                                                            1
Rosin sizing                                                     1
Soap                                                             4
Solvent                                                          1
Solvent Lf-9                                                     1
Spent caustic                                                    1
STP                                                              1
Styrene                                                          1
Tallow                                                           1
Transformer oil                                                  1
W/A 8508                                                         1
Wax                                                              1
                                   51

-------
                                 TABLE 111-19

            SUMMARY OF MATERIALS LAST CONTAINED, JANUARY 29, 1987*
                        TANK TRUCK CLEANING FACILITY C
      Material Last                                           Number of
	Contained In Tank	Tanks

Aniline oil                                                        1
Diethylamine                                                       1
Fatty alcohol                                                      1
Oil                                                                1
Pep. set (steel foundry core resin)                                1
Polymer                                                            1
Toluenediamine                                                     2
Water Treating compound                                            1
Wax, TT3655                                                        1
^Represents tanks cleaned during sampling period on January 29.
                                         52

-------
Review  of the  analytical data  for  the sludge  shows that  the
sludge  would   be  classified   as   hazardous  because   of  the
characteristic of ignitability.

4.  Rail Tank Car Cleaning Facility A

This  facility  is authorized  by its  state  regulatory  agency  to
clean tank cars that contained any of approximately 500 different
materials.    If  a  tank  car last  contained  a  non-authorized
material,  this  facility  often  attempts  to  obtain  a  permit  to
clean the non-authorized material.   This facility has a permit to
discharge treated wastewaters to an adjacent  surface water body
and  to  dispose  of  specific hazardous wastes  in  an  on-site
underground injection well.

Most  cleaning  is done with  hot water,  cold water,  and steam.
Caustic  or detergent  are used  as  needed,  but  no  solvents  are
utilized.  There  is no reuse/recycle of wastewaters or caustic.
Cleaning  is  done with spinners inserted through the  main tank
hatch.   This  facility usually cleans  250 to 300 rail  tank cars
per  month.   The  average  water  use is  between  2,500  and  3,300
gallons per car.

Tank heels are  disposed  of by one of several means  depending on
composition.    Storage tanks  are available for  segregation  and
recovery  of  products  with salvage  or  fuel  value.    Heels  and
washwaters that are treatable biologically go to the wastewater
treatment  facility,  which consists  of equalization  followed  by
extended   aeration   activated   sludge.   Remaining   wastes  are
considered hazardous  and go  to  the injection well.   Washwaters
from  approximately  25-30  percent  of  tank  cars  cleaned  are
disposed of in the  injection  well.   Solid wastes  are disposed of
as hazardous or non-hazardous wastes as appropriate.

Samples of the raw  wastewater routed to biological  treatment and
samples  of the  raw  waste routed  to  the  injection well  were
collected  on  two days at  this  facility.    The  samples of  raw
wastewater routed to  the  biological  treatment system  were grab
samples obtained  from a  flow-proportioning sample  tank  located
adjacent to the wash  rack.  Samples of  raw wastewater routed to
the underground injection well were grab samples collected from
the hazardous wastewater  sump  located at the  wash rack.  Samples
of effluent were  not  collected  from the  activated  sludge system
because  the   influent includes  wastewater  from  several  other
sources in addition to rail car washing wastewater.

Figure III-4  presents a  schematic  of  the  wastewater  treatment
system at  this  facility; wastewater sample collection locations
are  indicated  on the schematic.   A summary of the analytical
results for samples collected at this  facility is  presented  in
Table 111-20.
                                53

-------
   "HAZARDOUS:
   WASHWATERS
                                 RAW WASTE WAI EH
                                 , SAMHIE IOCATION
                                                                              WASTEWATEH TO
                                                                              INJECTION WELL
   'NON HAZARDOUS*
     WASHWATERS
                                                           2 300000 GAI
                                                           EO«JAI I?ArION
                                                            I 3 IANKS )
DISCHARGE TO
SURFACE WAI EH
                                                     RAW WASlEWAftll
                                                     SAMPLE I OCA I ION
                                                                                             FIGURE HI-4
                                                              WASTEWATER TREATMENT SCHEMATIC
                                                                      RAILCAR CLEANING FACILITY A
5307 06

-------
                 TABLE I11-20

         SUMMARY OF ANALYTICAL RESULTS
           RAIL TANK CAR FACILITY A


Pollutant
or Pollutant
Characteristic Units
Volatile Organic Pollutants
acetone Mg/£
benzene Mg/£
chloroform Mg/£
ethylbenzene pg/£
methylene chloride Hg/£
t-1, 3-dichloropropene jJg/£
toluene Mg/^
trichloroethene Mg/*
1,1,1-trichloroethane Jig/*
1,2-dichloroethane Mg/£
1,2-dichloropropane pg/£
cis-1, 3-dichloropropene Mg/*


Tap
Water
(15235)

«•»
—
—
—
-—
__
—
—
—
—
--
Raw
Waste
to Bio.
Treatment
(15233)

12,757
768
428
—
— —
2,127
29
19
—
—
— —

Raw
Waste to
Inj. Well
(15234)

—
210
--
-—
100
242
38
29
—
41
194
317
Raw
Waste
to Bio.
Treatment
(15236)

—
164
49
— —
""
254
-—
-—
-—
— —


Raw
Waste to
Inj. Well
(15237)

—
100
~ —
12
IOC
125
f~f
o7
64
44
22
35
™"

Semivolatile Organic Pollutants

acenaphthene
acenaphthylene
alpha- terpineol
anthracene
benzo (a) anthracene
biphenyl
bis(2-chloroethyl)ether
chrysene
diphenylamine
fluorene
isobutyl alcohol
isophorone
Mg/£
Mg/£
Hg/£
pg/£
M8/^
Mg/£
21
110

 58

 34

 19
 40
 44
                            1,032
                                              134
                                                             65
                                                             74
                                                             83
224

111

 63



137


 97

-------
TABLE 111-20 icont.)
Pollutant
or Pollutant
Characteristic
Semi volatile (cont.)
n-nitrosodiphenylamine
naphthalene
nitrobenzene
p-cymene
phenanthrene
pyrene
2 - chlo ronaphtha 1 ene
2 , 4-dichlorophenol
2 , 4-dinitrotoluene
2 , 4 ,5-trichlorophenol
2,4, 6- trichlorophenol
Pesticides and Herbicides
Dioxins/Furans
Metals
calcium
magnesium
sodium
aluminum
manganese
lead
boron
barium
cadmium
chromium
copper
Tap
Water
Units (15235)

«/*
ug/,2 --
Ug/£ --
Ug/£ ~~
ug/£ -~
(Jg/£ -—
ug/£ --
pg/£
Mg/A ~~
ug/£
ug/.£ --
NA
NA

Mg/£ 7,910
(jg/£ 2,180
pg/£ 136,000
Mg/£ 718
Mg/* 51
MgM
M&/£ ""
Mg/£ VH
Ug/£ **"
ug/£
Mg/£ 29
Raw
Waste
to Bio.
Treatment
(15233)

w
164
—
—
151
40
45
61
--
37
61
NA
NA

38,400
77,200
2,460,000
688
397
231
836
--
20
49
320
Raw
Waste to
Inj. Well
(15234)

„
276
1,867
--
—
—
--
--
_-
._
—
NA
NA

10,300
2,750
143,000
662
469
—
—
Ill
27
—
87
Raw
Waste
to Bio.
Treatment
(15236)

..
-_
—
77
—
--
__
__
49

—
NA
NA

35,100
76,200
884,000
260
1,760
—
432
116
20
--
36
Raw
Waste to
Inj. Well
(15237)

112
114
—
_-
220
--
..
._
__
» —
—
NA
NA

13,600
2,740
153,000
863
211
--
192
136
15
--
63

-------
                                              TABLE  111-20  (cont.)
Pollutant
or Pollutant
Characteristic
Units
  Tap
 Water
(15235)
  Raw
 Waste
 to Bio.
Treatment
 (15233)
   Raw
Waste to
Inj. Well
 (15234)
   Raw
  Waste
 to Bio.
Treatment
 (15236)
   Raw
Waste to
Inj. Well
 (15237)
Metals (cont.)

iron
nickel
zinc
silver
arsenic
antimony

Conventional Pollutants

Residue, non-filterable
BOD 5-Day
Oil and grease,
 total recoverable
pH
MS/*
Mg/«
Hg/*
M8/«
mg/£
ing/*

mg/£
s.u.
Classical Honconventional Pollutants

Residue, filterable              mg/£
Fluoride                         "g/£
Ammonia, as N                    mg/£
Nitrogen, Kjeldahl, total        mg/£
Nitrate-nitrite, as N            mg/£
Total phosphorus, as P           mg/£
Chemical oxygen demand           mg/£
Total organic carbon             mg/£
Sulfide, total (iodometric)      mg/£
 281
 2.1
  NA
  NA

  NA
  NA
                NA
                NA
                NA
                NA
                NA
                NA
                NA
                NA
                NA
29,800
   125
 2,720
                                 60
                5,800
                  1.0

                  4.2
                  1.2
                   NR
                  560
                   97
                  1.0
8,570
—
9,360
1.5
342
—
52,700
411
342
1.4
—
—
17,100
—
924
—
74
51
580
>24si
150
11.7
65
>24si
34c
8.0-8.3
                                40
                               280

                                36
                               5.6
                               120
                                42

                               24d
                           7.3-7.4
830
0.86
9.7
79
0.08
2.6
9,600
3,500
4.7c
3,600
0.55
—
ht
0.089
0.081
410
150
2.8c
590
0.92
—
40ht
0.080
0.052
750
300
3.9c
Cyanide, total
                NA
                   56

-------
                                                          TABLE 111-20 (cont.)
           Notes:
                Indicates pollutant concentration was below detection limit
           NA   Indicates not analyzed
           ht   Analysis performed after expiration of analytical hold-time
           NR   Matrix interference
           si   Sample inhibition indicated
           c    Average of  five grab sample results
           d    Average of  four grab sample results
CD

-------
Review  of  the  data  shows  moderate  levels  of  volatile  and
semivolatile pollutants  in both  raw  wastewaters.   Although the
detection  of  acetone  in  the raw  wastewater corresponds  to the
cleaning of a  rail car that carried  acetone,  a correlation with
the  cargos of  other  rail cars  is not  evident.    Tables  111-21
through 111-23 list the materials last contained in the rail cars
cleaned  during  the  sampling episode   and  the  materials  last
contained  in the rail cars cleaned on the preceding day.

5.  Rail Tank Car Cleaning Facility B

This facility usually  cleans  about 120  to 160 rail tank cars per
month.  In addition, the facility performs repairs and also  lines
tank  interiors.    Most  rail  cars  are  accepted  for  cleaning.
Exceptions are  determined  on  a  case-by-case  basis.  Although the
facility is not located in a major manufacturing or petrochemical
area,  several  small petrochemical plants are  located nearby and
much of the facility's business  is associated with those plants.

Cars are routinely cleaned with  only  hot or  cold water.  Caustic
solution   is  used  only  if  necessary.    Cleaning  is  done with
spinners inserted  through  the main tank hatch.  No detergents or
solvents are  used for cleaning  tank interiors. Average water use
is 3,500 gallons per car.

Wastewater from tank washing  is collected in trenches beneath the
cars and is piped to  a pretreatment holding  tank.  It then  flows
to a  sump  and is pumped to  an  aerated surge tank  (approximately
20,000-gallon volume).  Sanitary wastewater and filtrate from the
sludge  press  combine  with wash  water in the surge tank.   The
combined   wastewater  is  then pumped to  a   Dorr-Oliver  primary
clarifier  (90,000-gallon volume)  before  discharging to a  series
of two aeration basins, each with about a 10,000-gallon volume.
After  final clarification, wastewater is discharged to the  local
municipal  treatment system.

Sludge  from  the final clarifier  is either returned to the  first
of   the  activated sludge units  or  returned  to  the  primary
clarifier. Sludge from the primary clarifier  is  dewatered  with  a
Duriron  plate-and-frame  filter  press.    To  enhance  dewatering
characteristics,   ferric   chloride  and  lime  are  used.    The
dewatered  sludge  is  being  stored   on-site   until  a disposal
agreement  is  reached with  state officials.

Two  operating  day composite samples of raw  wastewater  and one
sludge grab  sample were  collected  at  this  facility.    The raw
wastewater samples were collected  from the  sump  located  between
the  pretreatment  tank and  surge tank.   A  sample of dewatered
sludge was collected  from the sludge  filter  press as it was being
unloaded.   Effluent samples  were not collected because the long
detention  times in the treatment  system prevented a meaningful
                                59

-------
                               TABLE 111-21

          SUMMARY OF MATERIALS LAST CONTAINED, SEPTEMBER 29, 1986
                     RAIL TANK CAR CLEANING FACILITY A
    Material Last                                           Number of
   Contained In Railcar	  	Railcars

Wastewater Routed to
Injection Well

Metam-Sodium (Sodium                                             j
  dimethyldithiocarbamate)

Aniline oil                                                      1

Phenol
                                      60

-------
                                TABLE  111-22

            SUMMARY OF MATERIALS LAST CONTAINED,  SEPTEMBER 30,  1986
                       RAIL TANK CAR CLEANING FACILITY A


      Material Last                                          Number  of
    Contained In Railcar	Railcars	

  Wastewater Routed to
  Injection Well

  Epichlorohydrin                                                 -
  Pesticide wastewater*                                            *

  Wastevater Routed to
  Biological Treatment System

  Naptha                                                           l
  Acetone                                                          *
  Vegetable oil                                                    1
  Chlorine**                                                       *
  Vinyl chloride monomer***                                        1


* Distributed as follows:

  99.5% water
  0.003% Furadan
  0.4% PCNB
  0.001% Heptachlor
  0.01% Thiodan I
  0.006% Thiodan II
  0.001% Ethion
  0.009% Malathion

** Approximately 400  gallons 26% NaOH added to each unit for neutralization.
   Both units filled  completely with water.

*** Purged  to non-explosive level through flare  system prior to cleaning.
                                        61

-------
                                 TABLE 111-23

             SUMMARY OF MATERIALS LAST CONTAINED, OCTOBER 1, 1986
                       RAIL TANK CAR CLEANING FACILITY A
      Material Last                                           Number of
    Contained In Railcar	Rail cars

  Vastewater Routed to
  Injection Well

  Cumene hydroperoxide                                             1
  Hexamethylene diisocyanate                                       1

  Wastewater Routed to
  Biological Treatment System

  Chlorine*                                                        1
  Glycerine                                                        1
  Lube oil additive                                                1
  Naptha                                                           2
  Phthalic anhydride                                               1
  Sulfur dioxide*                                                  1
* Approximately 400 gallons 26% NaOH added to each unit for neutralization.
  Both units fully filled with water.
                                     62

-------
comparison  of   influent  and  effluent   concentration  values.
Figure III-5  presents  a  schematic of  the wastewater  treatment
system at this facility showing sample collection locations.

Table  111-24  summarizes  the  analytical  results  for  samples
collected at  this  facility  and  Table  111-25  lists materials last
contained in tank cars cleaned during the sampling period and the
material last contained in the tank cars cleaned on the preceding
day.  A  total of 23 organic pollutants were  reported  in the two
raw wastewater samples with no correlation evident to the limited
number of  cargos  last  carried  in the  rail   cars  cleaned either
during  the  sampling  episode  or the  preceding day.    It  is
theorized that on  the  first day of sampling,  the large number of
pollutants  observed in  the sample were  associated with solids
washed out  of the pretreatment  tank  by wash water  as  it flowed
through  the tank.   A similar theory  is put  forth for  the second
day  when a large  amount of  solids  was  suspended  by  mechanical
mixing associated  with neutralization of  several hundred gallons
of acetic acid with sodium hydroxide  in the pretreatment tank.

6.  Tank Barae Cleaning Facility A

This facility cleans and repairs both tank and hopper barges.  Of
the  900  barges cleaned at this  facility in 1985, the predominant
number were  tank  barges.    The facility  is  located in  an area
where   extensive   petrochemical  production  occurs    and  has
opportunity to clean barges that have contained a wide variety of
bulk  cargos.   Based on experience,   the  company  has developed a
list of  about 80 compounds that it will not  accept  for cleaning.
These include highly odoriferous compounds.

After stripping  residual cargo  from  the  barges  and venting with
blowers,  workers enter  the  barges to clean  interior  piping and
pumps  with   hot  water.    High  pressure  spinner  nozzles  are
sometimes used.   No solvents or caustic are  used, but  degreasing
detergent, disinfectant,  or both are  used if  necessary.

This facility has  a  state permit to discharge  wastewaters  from
cleaning petroleum barges  to  the adjacent river.  The permit  does
not  allow  discharge  of  wastewaters  from cleaning of  chemical
barges;  those wastewaters are  handled  separately.    Wastewater
from cleaning of petroleum barges first  goes to an intermediate
barge  for  several days  of  settling and  oil-water separation.
Following that,  the water fraction is pumped  through aim  filter
and  a coalescing plate  filter prior  to storage  in  a holding
barge.   When approximately 1,000 barrels  (42,000 gallons)  have
accumulated,  the wastewater is  tested (COD,   TSS, O+G,   pH)  and if
in  compliance with discharge  permit conditions,  discharged  to the
river.

Wastewater  from  cleaning of chemical  barges  is filtered through a
1 m filter  before going to a  holding  barge.   When the barge is
                                63

-------
MFLUENT FROM
  DRAINS
SLUDGE SAMPLE
LOCATION
                    SAMTARY WASTEWA TEH
                      RAW WASTEWATER
                      SAMPLE LOCATION
  PRETREATMENT
n HOLDNG TANK
                                             PIPELINE LENGHiat 1/2 MME
                                                                                   WASTEWATER
                                                                                    IOPO1W
                                                     ACTIVATED
                                                      SI IMKif
                                                     1ANK NO I
                                  FERRIC CHLORIDE AND LIME
                  ^—y
                                                                                            FIGURE 111-5
                                                            WASTEWATER TREATMENT SCHEMATIC
                                                                     RAILCAR CLEANING FACILITY B

-------
                                                            TABLE 111-24
                                                    SUMMARY OF ANALYTICAL RESULTS
                                                       RAIL TANK CAR FACILITY B
ui
Pollutant
or Pollutant
Characteristic
Units
Liquid (Sludge)
Tap
Water
(15775)
Day 1
Raw
Waste
(15777)
Day 2
Raw
Waste
(15778)
Sludge
(15776)
TCLP
Extract
(15776)
Volatile Organic Pollutants

acetone
benzene
bromoform
ethylbenzene
•ethylene chloride
tetrachloroethene
toluene
vinyl chloride
1, 1-dichloroethane
2-butanone

Seaivolatile Organic Pollutants

acenaphthene
acenaphthylene
anthracene
benzyl alcohol
biphenyl
bis(2-ethylhexyl) phthalate
carbazole
chrysene
di-n-octyl phthalate
dibenzofuran
fluoranthene
fluorene
naphthalene
phenanthrene
phenol
pyrene
styrene
                                             fg/£(|jg/kg)
                                             Mg/£(pg/kg)
                                             Mg/£(MgAg)
                                             Mg/£(Mg/kg)
                                             pg/£(Mg/kg)
                                             Mg/£(pg/kg)
                                             Hg/£(pg/kg)
                                             pg/*(Mg/kg)
                                             Mg/*(MgAg)
                                             Mg/*(pg/kg)
                                             Mg/£(MgAg)
                                             Hg/*(Mg/kg)
                                             pg/£(pg/kg)
                                             Hg/£(pgAg)
                                             Mg/*(MgAg)
                                             pg/£(pg/kg)
                                             Mg/*(Mg/kg)
                                             Mg/£(Mg/kg)
                                             Mg/£(Mg/kg)
                                             Mg/*(Mg/kg)
                                             Hg/£(Mg/kg)
                                             pg/A(Mg/kg)
24
31
  134
1,764
   20
   20

   33
  420
   42
            13

            34

            10
            36
            20
            35
           341
            58
            65
            13
            26
5,571


   15

  476
 50
 45
184

 45
163
300
106
1,996
801
230
—
754
151
—
836
506
806
—
1,436
572
340
625
3,711
--
8,900
—
6,450
15,342
5,029
1,253
8,289
7,339
2,929
5,305
13,453
8,297
3,237
2,289
2,582
21
                                                150
                                        19

                                        50

-------
TABLE 111-24 (cont.)
Pollutant
or Pollutant
Characteristic
Pesticides and Herbicides
Dioxins/Furans
Metals
calcium
magnesium
sodium
aluminum
manganese
lead
vanadium
boron
barium
cadmium
tin
cobalt
chromium
copper
iron
nickel
titanium
zinc
silver
mercury
Conventional Pollutants
Residue, non-filterable
BOD 5-Day
Oil and grease,
total recoverable
PH
Units
Liquid (Sludge)



Mg/£(mg/kg)
Hg/£(mg/kg)
Mg/£(mg/kg)
ug/£(mg/kg)
Mg/£(o>g/kg)
Hg/£(mg/kg)
Mg/£(mg/kg)
Mg/£(mg/kg)
Mg/£(mg/kg)
Hg/£(mg/kg)
Hg/£(mg/kg)
Mg/£(mg/kg)
Mg/£(mg/kg)
Mg/£(ng/kg)
Hg/£(mg/kg)
ug/£(mg/kg)
Mg/£(ng/kg)
Mg/£(mg/kg)
Mg/£(mg/kg)

1/1
mg/£

mg/£
s.u.
Tap
Water
(15775)
NA
NA

61,700
5,200
7,940
— —
__
--
—
—
__
__
—
—
—
—
—
148
—
--

NA
NA

NA
NA
Day 1
Raw
Waste
(15777)
NA
NA

87,700
6,260
41,900
568
619
__
159
68
10
_ —
__
--
40
5,140
__
—
412
--
3.7

200
180

79c
7.0-7.8
Day 2
Raw
Waste
(15778)
NA
NA

43,400
505
17,000,000
179
— —
__
..
«.*
. iv
_ —
_-
26
184*
98*

734*
._
52.2

750
16,000

540c
12.0-12.9
Sludge
(15776)

NA

84,900
1,050
3,490 1
3,570
774
64
17
217
172

35
7
108
426
206,000
66
41
577
1.0
1.1

NA
NA

NA
NA
TCLP
Extract
(15776)
VA
JIA
NA

924,000
7,510
,070,000
1,280
6,650

1,710
2,250
5


*•
104
246
187

1,730

--

NA
NA

NA
NA

-------
TABLE 111-24 (cont.)

Pollutant
or Pollutant Units

Tap
Water
Characteristic Liquid (Sludge) (15775)
Classical Nonconventiona 1 Pollutants
Residue, filterable mg/£
Fluoride mg/£
Ammonia, as N mg/£(mg/kg)
Nitrogen, Kjeldahl, total mg/£(mg/kg)
Nitrate-nitrite, as N mg/£(mg/kg)
Total phosphorus, as P mg/£
Cheaical oxygen demand mg/£
Total organic carbon ng/£
Sulfide, total (iodometric) mg/£
Flash point (°C)
pH, soil (s.u.)
Residue, total (%)
Residue, total volatile (%)
Sulfide, total
(Modified Monier-Williams) («g/kg)
Corrosivity (mils/year)
Cyanide, total Mg/£(mg/kg)

Indicates pollutant concentration was below
NA Indicates not analyzed
NR Matrix interference
c Average of three grab sample results

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA

detection limit



Day 1
Raw
Waste
(15777)

430
0.37
—
1.9
0.28
25
480
78
— "
NA
NA
NA
NA

NA
NA
73





* Indicates sample duplicate analyses were not within specified control
s Low bias associated with sulfide analysis,
x Upon receipt by lab, pH was not within the
refer to Report
specified range
of Analysis
Day 2
Raw
Waste
(15778)

6,000
7.7NR
5.8
7.6x
0.27
180
33,000
13,000
25c
NA
NA
NA
NA

NA
NA
1,200





limits



Sludge
(15776)

NA
NA
1,000
17,000
--
NA
NA
NA
NA
55
8.0
38
17

4.3s
20
5.3








TCLP
Extract
(15776)

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA







for preservation

-------
                                 TABLE 111-25

                      SUMMARY OF MATERIALS LAST CONTAINED
                       RAIL TANK CAR CLEANING FACILITY B
    Date
   Number of
Railcars Cleaned
                                                   Product Cleaned
Monday, April 20
Tuesday, April 21
Wednesday, April 22
        2
        1
        1
Vegetable oil
Corn starch
Latex (rinse only)

Chemical Leaman trailers (food
  grade plasticizer)
PVC resin
Vinyl acetate monomer
Ethyl acetate

Acetic acid
Latex (held in separate tank - did
  not drain to treatment system)
TDTC - Monsanto Triallate Technical
  Avadex BW Herbacide
  CAS Active Ing. 2303-17-5.
Vegetable oil
                                    68

-------
filled   it  is  moved to  an underground  injection facility  for
disposal of the contents.   Sludge generated during the settling
and filtering steps is stored in drums and disposed at an approved
off-site facility.

Grab  samples  of  filtered  wastewater  were  collected  from  both
petroleum wastewater  and chemical wastewater storage  barges.   In
addition, a  sludge sample  was collected from  one of  the drums
awaiting disposal.   Figure  III-6  presents  a wastewater treatment
schematic showing sample collection locations.

Results of sample analyses are summarized in Table 111-26.  Review
of the  data  shows only low  levels of  five  organic pollutants in
the filtered  petroleum wastewater.   In comparison, 18 pollutants
were reported in the filtered chemical wastewater, several  at very
high levels.

Review of the analytical data for the sludge shows that  the sludge
contains high levels of several organic pollutants.  Comparison of
the  analytical  data  for   the TCLP  extract with the proposed
regulatory levels  (see  Table V-10) shows that the sludge would be
considered hazardous:  benzene, chloroform, toluene, and  2-butanone
all  exceed  their  individual threshold  levels.   Although  the
flashpoint  of  the  sludge was  less  than 60'C,  it would  not be
classified as hazardous based on the characteristic of  ignitability
because  it did  not  contain  free liquid.

A  summary of cargos  last  contained  in  tank barges from which
wastewater was  routed to the storage barges is presented in Table
111-27.   With  the  exception of  benzene,  chloroform, and 1,1,1-
trichloroethane  in  chemical  barge wastewater,  the  analytical
results do not  correspond to the cargos last carried in  the barges
that were cleaned.

7.  Tank Barae  Cleaning Facility  B

The second tank barge cleaning facility to be sampled  cleans eight
to ten  tank barges per week.  It  also  is located in an  area where
extensive  petrochemical production occurs  and barges are  cleaned
that  carry many different  chemicals.   However,  barges that  last
contained  chlorinated  hydrocarbons are  seldom cleaned  at  this
facility;  no barges  are  cleaned that  last carried  concentrated
acid.

Wastewaters  from barges that last contained edible oils, petroleum
based products, and  hazardous substances  are pumped to  separate
barges. Each of these wastewaters are handled separately.  Average
water use  at the facility is estimated to  be about 3,000 to  4,000
gallons per  barge.

 During  treatment,  wastewater  from the  petroleum-based  product
wastewater storage barge  is transferred to the  first  (Tank 1)  of
                                 69

-------
       PETROLEUM BARGE
       VWASTEWATER
                                            WASTEWATER
                                            SAMPLE LOCATION
                                                                             WASTEWATER
                                                                             SAMPLE IOC AT ION
                 aCMCAL BARGE
                 WASTEWATER
                                SLUDGE W
                                55 GALLON
                                 DRUMS
                                                                                                  WASIEWAIER IO
                                                                                                  SURFACE WATER
                                      WASIFWATER TO
                                      INJECTION WEll
	^ CON IR AC I OlSf'O-SAI
                                            SI UDGE SAMPLE LOCATION
                                                                                              FIGURE 111-6
                                                               WASTEWATER TREATMENT SCHEMATIC
                                                                   TANK BARGE CLEANING FACILITY A
530706

-------
           WASTEWATER FROM
           .EDBlE 01 BARGES
 WASTEWATER
"SAMTIf IOCAIION
.SANnmtn INMIHNI
 SAMPIE IOCAIH)N
COAIESV4G Fl IER
       SAMPIE IOCAIION
                                          I
                         RECYCLED WASHWATERJ
                         ,            .—j
                                                  .WASTEWATER
                                                   SAMPLE LOCATION
                     PETROLEUM 1	

                      BARGES
                                                   MIL AltL) PETROLEUM WASTEWATER
                                                                                 -Oft
                                              INGIKY CONIAMINAIED WASTEWATER
                                     J
                                                                                                      TREATED EDaiEOI.
                                                                                                      WASTE WATER IO
                                                                                                      SURFACE WATER
                                                                                        tMfSIIE IHEAIMENT
                                                                                        AMI) DISPOSAL
                WASTEWATER FROM
                HAZARDOUS MATERIAL
                BARGES
                                                         SOIVENIS/MOA1AHIIS

                                                         IO INCINI RAMON
                                                        WASIEWAIKI IO
                                                        INJtCIION WEIL
                                                  WASTEWATER
                                                  SAMPLE LDCATKJN
                                                                                                      FIGURE 111-7
                                                                    WASTEWATER TREATMENT SCHEMATIC
                                                                         TANK BARGE CLEANING FACILITY B
5307 06

-------
                                                          TABLE 111-26

                                             SUMMARY OF REPORTED ANALYTICAL RESULTS
                                                 TANK BARGE CLEANING FACILITY A
--J
N>


Pollutant
or Pollutant
Characteristic



Units
Liquid (Sludge)


Tap
Water
(15217)

Filtered
Petroleum
Wastewater
(15214)
Filtered
Petroleum
Wastewater
Duplicate
(15218)

Filtered
Chemical
Wastewater



Sludge
(15216)


TCLP
Extract
(15216)
       Volatile Organic Pollutants
acetone
benzene
chloroform
ethylbenzene
methylene chloride
toluene
trichloroethene
1,1,1-trichloroethane
1,2-dichloroethane
2-butanone
                                      (Mg/kg)
(Mg/kg)
(Mg/kg)
(Mg/kg)
(Mg/kg)
(Mg/kg)
(Mg/kg)
(Mg/kg)
      Semivolatile Organic Pollutants
      alpha-terpineol
      benzidine
      carbazole
      dibenzofuran
      dimethyl  phthalate
      isophorone
      n-docosane
      n-eicosane
      n-hexacosane
      n-octadecane
      n-triacontane
      p-cymene
      thioxantbone
      1-methylphenanthrene
                               (Mg/kg)
                               (Mg/kg)
                               (Mg/kg)
                          Mg/« (Mg/kg)
                               (Mg/kg)
                               (Mg/kg)
                               (Mg/kg)
                          Mg/« (Mg/kg)
                          Mg/£ (Mg/kg)
                               (Mg/kg)
                               (Mg/kg)
                               (Mg/kg)
                               (Mg/kg)
                               (Mg/kg)
                                                                    67
                                                                    39
121
—
13,497
148
—
1,446
996
31
725
137,689
1,477,250
114
101,899
27,555
1,921
18,280
14,400
—
—
57,587
1,097,915
57
111,132
17,546
1,364
4,079
15,312
—
—
16,174
170,257
                              39
                             152
 19
 45

 18
                                                     161
                                                      30
                                                     463
                                                     184
                                                     199
                                                      12
                                                               2,269
                                                           1,664,990
                                                           1,226,930
                                                                           234
                                                                            22
89

-------
                     TABLE 111-26 (cont.)
Pollutant
or Pollutant
Characteristic
Units
Liquid (Sludge)
Tap
Water
(15217)
Filtered
Petroleum
Wastewater
(15214)
Filtered
Petroleum
Wastewater
Duplicate
(15218)
Filtered
Chemical
Wastewater
(15215)
Sludge
(15216)
TCLP
Extract
(15216)
        Semivolatile (cont.)

        2-methylnapthalene
        2,6-dinitrotoluene
        3,6-dimethylphenanthrene
        4-chlo ro-3-methyIpheno1
        4-nitrophenol

        Pesticides and Herbicides

        etridazone
^       BHC, beta
u>       BHC, gamma
        trifluralin

        Dioxin/Furans

           2,3,7,8   TCDF
           2,3,7,8   TCDD

        Metals

        calcium
        magnesium
        sodium
        aluminum
        manganese
        lead
        vanadium
        boron
        barium
        cadmium
     (Mg/kg)
     (Mg/kg)
     (Mg/kg)
     (Mg/kg)
     (Mg/kg)
     (Mg/kg)
     (Mg/kg)
Mg/« (Mg/kg)
     (Mg/kg)
   (ng/kg)
   (ng/kg)
                                          3,346,300
                                     74
                                     16
                                     28
                                    428
NA
NA
            2.8
            1.5t
NA
NA
           4.It
           2.2
NA
NA
                                    3.7
                                     NA
NA
NA
ug/£ (mg/kg)
pg/£ (mg/kg)
Mg/£ (mg/kg)
pg/£ (mg/kg)
Mg/£ (mg/kg)
|jg/£ (mg/kg)
ujr/£ (mg/kg)
pg/£ (mg/kg)
llo/A (ma/tta)
95,200
24,800
11,600
31
154
— ~
55
463
76,700
22,300
13,800
178
• *
54
207
74,100
21,800
13,700
174
»
52
205
11,500
11,900
306,000
18,500
193
66
59
568
122
16,300
10,800
49,700
60,000
3,580
1,450
277
16,700
2,240
502
36,100
5,760
1,690,000
10,700
1,280
__
—
1,340
14

-------
                                                TABLE 111-26  (cont.)


Pollutant
or Pollutant
Characteristic


Units
Liquid (Sludge)


Tap
Water
(15217)

Filtered
Petroleum
Wastewater
(15214)
Filtered
Petroleum
Wastewater
Duplicate
(15218)

Filtered
Chemical
Wastewater
(15215)


Sludge
(15216)


TCLP
Extract
(15216)
Metals  (cont.)

molybdenum
tin
cobalt
chromium
copper
iron
nickel
titanium
zinc
silver
arsenic
antimony
mercury

Conventional Pollutants

Residue, non-filterable
BOD 5-Day
Oil and grease,
 total recoverable
pg/£ (mg/kg)
Mg/* (mg/kg)
Mg/£ (mg/kg)
Mg/£ (mg/kg)
Mg/£ (mg/kg)
Mg/£ (mg/kg)
M8/« (mg/kg)
Mg/A (mg/kg)
Hg/£ (mg/kg)
Mg/£ (mg/kg)
Mg/4 (mg/kg)
Mg/A (mg/kg)
Mg/« (mg/kg)
    mg/£
    mg/£

    mg/£
Classical Nonconventiona1 Pollutants

Residue, filterable           mg/£
Fluoride                      tag/8.
Ammonia, as N              mg/£(mg/kg)
Nitrogen, Kjeldahl, total  mg/£(mg/kg)
Nitrate-nitrite, as N      mg/£(mg/kg)
Total phosphorus, as P        mg/£
Chemical oxygen demand        mg/£
   51
  3.9
2,460

   18
   12

   17
   NA
   NA

   NA
                       NA
                       NA
                       NA
                       NA
                       NA
                       NA
                       NA
4.4

4.4
153

 18
4.9
               460
               1.4
               1.0
150

 19
3.8
            9.2
            460
           0.20

            4.9
           0.72
345
20
17
14
156
140
87
35
210
~
69
16
0.3
595
832
526
1,870
3,190
581,000
2,270
411
1,340
0.1
80
8.1
0.8
—
129
--
—
29
904
95
--
221
—
--
—
1.7
            280
         10,000

           250C
          5,600
           0.22
            2.9
             22
            6.8
            5.7
         13,000
 NA
 NA

 NA
 NA
 NA

770
1.5
 NA
 NA
NA
NA

NA
NA
NA
NA
NA
NA
NA
NA

-------
TABLE 111-26 (cont.)


Pollutant
or Pollutant Units
Characteristic Liquid (Sludge)
Classical (cont.)
Total organic carbon mg/£
Sulfide, total (iodometric) mg/2
Flash point (°C)
pH, soil (s.u.)
Residue, total (%)
Residue, total volatile (%)
Sulfide, total
(Modified Monier-Williaras) (mg/kg)
Corrosivity (mils per year)
Cyanide, total M8/£(mg/kg)

Notes :
Indicates pollutant concentration below
NA Indicates not analyzed
c Average of five grab sample results


Tap
Water
(15217)

NA
—
NA
NA
NA
NA

NA
NA
NA


detection



Filtered
Petroleum
Wastewater
(15214)

.*
--
NA
NA
NA
NA

NA
NA
__


limit


Filtered
Petroleum
Wastewater
Duplicate
(15218)

__
3.6c
NA
NA
NA
NA

NA
NA
__






Filtered
Chemical
Wastewater Sludge
(15215) (15216)

3,400 NA
NA NA
NA
NA 12.7s
NA 71
NA 9

NA 7.0
NA
22







TCLP
Extract
(15216)

NA
NA
NA
NA
NA
NA

NA
NA
NA





s pH of sludge supernatant following centrifugation
t Tentative identification below detection
limit





-------
 two tanks  mounted  in  the  treatment barge, and then pumped through
 a sand filter and a coalescing filter into the second tank  (Tank
 2) .   The  filtered wastewater  is  recycled  until it is considered
 too dirty to reuse.   Then it is stored and barged  to a private
 contractor for  treatment  and disposal.

 After  gravity separation  in the initial storage barge, wastewater
 from  edible  oil  barges  is  routed  to  Tank  1  for  additional
 clarification.    Wastewater  is  then  routed   through  the  same
 treatment  equipment,  but  not at the  same  time  as the petroleum-
 based  wastewaters,  and discharged to the  river.  Only wastewater
 generated  from  the  washing  of  barges carrying  edible oil   is
 discharged to the  river.

 Wastewater from cleaning  of barges that last carried cargos other
 than edible oils ^r petroleum products  is considered "hazardous",
 and  is  routed   to  a  separate storage  barge   where  gravimetric
 separation occurs.   Flotables  are recovered for incineration and
 the  remaining  barge  contents are  barged  to  an  injection  well
 facility for  disposal.

 Grab wastewater samples were  collected from this facility at the
 following  locations:     (1)  from  a   tap   in  the  piping  system
 connecting the  edible  oils  wastewater storage barge  to Tank  1;
 (2)  from  a tap in the piping system connecting the  petroleum
 wastewater storage  barge  to  Tank  1 during treatment of petroleum
 wastewaters;  (3) from the compartment containing the solvent-wash
 water  mixture in the  hazardous waste storage barge;  (4)  from the
 influent  line to the sand filter during treatment  of  petroleum
 wastewater; and (5)  from  the discharge of  the  coalescing filter
 during  the  treatment  of petroleum  wastewater.    Figure III-7
 presents  a schematic of  the  wastewater  handling and  treatment
 system showing  sample collection locations.

 The  results of  analysis of samples collected at this facility are
 summarized in Table 111-28.  Review of the data suggests that the
 raw  edible  oils  wastewater  may have been  contaminated  with
wastewater  from petroleum or  hazardous product  barges at  some
point,   because   the   reported  organic pollutants  should not  be
 found  in  edible products.   Both  the raw edible  oils  wastewater
and  raw  petroleum   wastewater   showed   moderate  levels   of
contamination  with several  organic  pollutants.   As  would  be
expected, the raw hazardous wastewater showed very high levels of
several pollutants.

A  summary  of cargos  last contained in tank  barges from  which
wastewater was  routed the storage barges,  is presented  in  Table
111-29.   A  clear  relationship  is  evident  between cleaning  of
barges  containing  acrylonitrile,  benzene,  and  toluene,  and  the
composition of  the  hazardous  wastewater.   A relationship is  not
clear between cargos  and  wastewater  for the petroleum  and edible
oils raw wastes.
                               76

-------
                            TABLE 111-27

                 SUMMARY OF MATERIALS LAST CONTAINED
                   TANK BARGE CLEANING FACILITY A
Wastewater Sent to
Petroleum Washwater Barge

     Diesel Oil
     Lube Oil
Wastewater Sent to
Chemical Washwater Barge

     Benzene
     Chloroform
     Chlorothane (1,1,1-trichloroethane)
     Ethanol
     Glycol
     Methanol ~
     Mineral Spirits Mixture
     Resin Oil
     Styrene
                                 77

-------
                                                             TABLE 111-28

                                                     SUMMARY OF ANALYTICAL RESULTS
                                                    TANK BARGE CLEANING FACILITY B
                                                                                              Raw
oo
Pollutant
or Pollutant
Characteristic
Volatile Organic Pollutants
acetone
acrolein
acrylonitrile
benzene
ethylbenzene
ethyl nethacrylate
toluene
2-butanone
2-chloroethyl vinyl ether
2-hexanone
Semivolatile Organic Pollutants
acenaphthylene
anthracene
benzyl alcohol
biphenyl
isophorone
naphthalene
n-tetracosane
n-tetradecane
nitrobenzene
squalene
styrene
2-chlorophenol
2,4-dichlorophenol
Units

Mg/£
ug/£
M8/«
M8/*
M8/*
MS/*
H8/A
M8/£
M8/A
M8/A

M8/«
M8/*
H8/«
Ug/Jfc
Ug/£
J4g/£
Ug/Jt
Ug/Ji
Ug/Jt
M8/«
pg/£
M8/*
H8/A
Tap
Water
(15613)

1,434
—
—
—
—
75
—
—
—
--

__
—
—
—
—
—
—
--
--
—
—
—
—
Raw
Hazardous
Wastewater
(15608)

21,825,100
17,906,000
13,359,600
1,048,920
—
—
23,506
16,973
32
--

_„
—
—
—
—
—
—
--
--
—
—
—
—
Raw
Petroleum
Wastewater
(15609)

970
572
61
4,703
2,217
—
6,300
—
—
218

__
—
—
—
—
2,827
--
--
--
—
—
—
--
Edible
Oils
Wastewater
(15610)

1,728
—
1,362
1,060
30
—
1,516
—
—
-—

11
72
—
16
—
86
77
162
--
—
199
—
—
Sand
Filter
Influent
(15615)

_ —
—
—
—
48
—
—
539
—
—

_«
— •
241
--
25
—
--
—
74,
—
165
1,773
1,544
Coalescing
Filter
Effluent
(15611)

52
—
—
80
29
—
169
120
—
—

__
—
— •
--
—
—
--
--
—
—
--
—
2,038

-------
                                               TABLE 111-28 I'cont.)
Pollutant
or Pollutant
Characteristic
Units
Semivolatile Organic Pollutants (cont.)
2,6-dinitrotoluene
4-chloro-3-methylphenol

Pesticides and Herbicides

Dioxins/Furans

Metals

calcium
magnesium
sodium
aluminum
manganese
lead
vanadium
boron
barium
cadmium
molybdenum
 chromium
 copper
 iron
 nickel
 titanium
 zinc
 mercury
Mg/«

Tap
Water
s (15613)
nt.)


NA
NA
I 39,800
I 12,700
I 23,800
I 2,690
I 955
I 274


4 133
£ 6

£ 58
£ 25
£ 4,160

X
£ 175


Raw
Hazardous
Wastewater
(15608)


--
NA
NA
35,900
11,600
55,900
542
1,080
—
__
100
62
11
__
21
268
20,400
61
• ••
4,000
—

Raw
Petroleum
Wastewater
(15609)

__
—
—
NA
24,400
13,600
5,590,000
11,500
226
--
178
249
161
6
1,270
56
63
15,100
118
52
451
3.7
Raw
Edible
Oils
Wastewater
(15610)

__
—
NA
NA
44,900
19,400
53,300
1,080
620
— ™
- —
210
92
9
--
103
60,400
"~
--
393
--

Sand
Filter
Influent
(15615)

25
2,168
NA
NA
42,300
18,200
50,200
669
384

~ —
129
55

•>•
31,100

••
369
™ ""

Coalescing
Filter
Effluent
(15611)

—
2,208
NA
NA
42,900
22,000
60,100
562
379


199
55


110
28,200

~~
330


-------
                                                TABLE 111-28 (cont.)
Pollutant
or Pollutant
Characteristic Units
Conventional Pollutants
Residue, non-filterable mg/£
BOD 5 -Day mg/£
Oil and grease,
total recoverable mg/£
pH s.u.
Classical Nonconventional Pollutants
Residue, filterable mg/£
Fluoride mg/£
Ammonia, as N mg/£
Nitrogen, Kjeldahl, total mg/£
Nitrate-nitrite, as N mg/£
Total phosphorus, as P mg/£
Chemical oxygen demand mg/£
Total organic carbon mg/£
Sulfide, total (iodometric) mg/£
Cyanide, total Mg/£

Tap
Water
(15613)

NA
NA

NA
7.0

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Raw
Hazardous
Wastewater
(15608)

21
17,000b

—
5.7

403
0.81
2.7
43
0.48
—
64,000
11,000
15c
370
Raw
Petroleum
Wastewater
(15609)

610
SnOsi

1,300
11.5

13,000
4.6
2.6
23
0.12
3.3
3,800
670
12c
66
Raw
Edible
Oils
Wastewater
(15610)

1,100
1,200

430
5.6

760
0.77
3.7
18
0.071
1.8
3,200
910
9.3c
—
Sand
Filter
Influent
(15615)

420
1,300

250
5.4

790
1.1
2.5
14
0.068
6.7
2,600
920
2.5c
—
Coalescing
Filter
Effluent
(15611)

340
990

170
5.5

740
0.50
2.6
14
0.050
3.1
3,100
880
2.5c
—
    Indicates pollutant concentration below detection limit.
NA  Indicates not analyzed
b   BOD result calculated from limiting value
si  sample inhibition of seed indicated

-------
                            TABLE 111-29

                 SUMMARY OF MATERIALS LAST CONTAINED
                   TANK BARGE CLEANING FACILITY B
Wastewater Sent to
Edible Oils Barge

     Coconut oil
     Corn oil
     Fish oil
     Molasses
     Palm oil
     Soybean oil
     Sodium hydroxide
     Tallow

Wastewater Sent to
Petroleum Oils Barge

     Bunker C oil
     Crude oil
     #2 Fuel oil
     #6 Fuel oil
     Gasoline
     Jet fuel
     Lube oil
     Naptha
     Sodium hydroxide  - #2  fuel  oil mixture

Wastewater Sent to
Hazardous Waste Barge

     Acrylonitrile
     Benzene
     Ethanol
     Hexane
     Methanol
     Methyl-tert-butyl ether
     n-Nonyl alcohol
     Resin oil
      Styrene monomer
      Toluene
     Xylenes
                                     81

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8_.—Aircraft Exterior Cleaning Facility A

Samples  of raw wastewater  from the washing  of the  exterior of
aircraft were collected on  two  days  at the maintenance center of
a major U.S. air  carrier.   This facility washes a maximum of one
aircraft per day.  The washing  is  usually limited to wheel wells
and landing gear and is conducted to facilitate inspection.  This
carrier dry-polishes  aircraft fuselages rather than  wet washing
them as other carriers are believed to do.

Washing an aircraft at this facility involves first moving it to
a wash area that is paved to facilitate drainage to a catch basin
located at one corner.  The actual washing consists of spraying a
mixture of water and detergent, butyl cellosolve, onto the aircraft
with hand-held wands.  The aircraft is then rinsed with water using
a  high pressure  spray.    Two  or  three  applications and  some
scrubbing with brushes are necessary  to clean  soiled areas.  Water
use  is  estimated  to  be  about  2,000  gallons  per  airplane.
Wastewater from cleaning aircraft exteriors is combined with other
wastewater including sanitary and  electroplating  wastewaters for
treatment  and  disposal to  surface  waters.   At  this  facility,
located near the United States East coast,  cleaning wastewater wac
collected and conveyed along  with  other wastewater to an on-site
treatment  facility.     Available   information   indicates  that
facilities operating in the southwestern United States where the
climate  is dryer would  likely  not  collect the wastewater,  but
instead would let it runoff either to  infiltrate  into the ground
or to evaporate.

Figure  III-8  presents  a  schematic  of  the  aircraft  wastewater
handling  and treatment   system showing  the  sample  collection
location.

Results of analyses  for samples collected at this  facility are
summarized in Table 111-30.  As can be seen,  relatively few organic
pollutants were reported for these samples.  Pollutants that were
reported had high concentrations,  however.   The  wastewaters did
contain high levels  of many  metals.   The  source of those metals is
thought to be the many special alloys  used in aircraft manufacture.
                               82

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                         CATCH BASMV
oo
u>
                    SLOPED WASH AREA
                                              OTHER WASTEWATERS
                                           AtnCRAFI WASTEWATER
                                       > WASTEWATER
                                        SAMPlfc IOCATION
                                                                                    EFFLUENT TO SINIFACE WAIER
                                                                                          FIGURE 111-8
                                                             WASTEWATER TREATMENT SCHEMATIC
                                                        AIRCRAFT EXTERIOR CLEANING FACILITY A
  530706

-------
                                 TABLE 111-30

                         SUMMARY OF ANALYTICAL RESULTS
                         AIRCRAFT CLEANING FACILITY A
                                                      Day 1             Day  2
Pollutant                                Tap           Raw               Raw
or Pollutant                            Water       Wastewater        .Wastewater
Characteristic	Units   (15219)	(15221)	(15220)

Volatile Organic Pollutants

acetone                        pg/£      --              —             8,505
chloroform                     pg/£     112
ethylbenzene                   |jg/£      —             824
2-chloroethylvinyl ether       |jg/£      --         160,326

Semi-Volatile Organic Pollutants

alpha-terpineol                [jg/£      —              —             20,602
dibenzofuran                   M8/£      —           1,681
naphthalene                    H8/4      —              —             45,649
2-chloronaphthalene            Hg/£      —              —             53,034

Pesticides and Herbicides

coumaphos                      |jg/£      --              NA                55t
leptophos                      pg/£      —              NA                  6t
tetrachlorvinphos              H8/£      —              NA             4,851

Dioxins/Furans                           NA              NA                NA

Metals

calcium                        |Jg/£   7,100           31,800             20,200
magnesium                      |jg/£     847           9,520             9,220
sodium                         yg/£   2,480         211,000           629,000
aluminum                       |Jg/£      39           5,180             2,350
manganese                      |jg/£     3.1             182                153
lead                           [J8/£      "             574                411
vanadium                       M8/£      —              35                22
boron                          pg/£      17             120                73
barium                         |jg/£     6.7             520                341
beryllium                      M8/£      —             4.4                4.6
cadmium                        |jg/£      —           2,830             1,760
molybdenum                     jjg/2      --           11,500             13,800
tin                            pg/2      --              77                26
cobalt                         jjg/£      --             9.1                8.9
chromium                       |jg/£     4.4             471                193
copper                         M8/£      ~           13,300             8,450
iron                           Mg/£     112           11,300             5,700
nickel                         H8/£      ~             570                304
titanium                       pg/£      18             234                109
zinc                           Mg/£      38           2,430             1,800
                                           84

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                             TABLE 111-30 (cont.)
Pollutam.
or Pollutan^
Characteristic
Units
  Tap
 Water
(15219)
  Day 1
   Raw
Wastewater
 (15221)
  Day 2
   Raw
Wastewater
 (15220)
Metals (cont.)

selenium
silver
antimony

Conventional Pollutants

Residue, non-filterable
BOD 5-Day
Oil and grease,
 total recoverable
pH
mg/2
s.u.
  NA
  NA

  NA
 6.5
Classical Non-conventional Pollutants
                         7.7
                         6.1
                          84
  1,100
  4,200b

  4,800
     NA
                                   3.3
    430
 20,000

 10,000
   10.6
Residue, filterable
Fluoride
Ammonia, as N
Nitrogen, Kjeldahl, total
Nitrate-nitrite, as N
Total phosphorus , as P
Chemical oxygen demand
Total organic carbon
Sulfide, total (iodomeric)
mg/£
mg/£
mg/£
mg/£
mg/2
mg/2
mg/2
mg/£
mg/2
NA
NA
NA
NA
NA
NA
NA
NA
NA
19,000
—
NR
NR
1.7
230
99,000
31,000
5.9
9,400
1.0
NR
14
2.9
140
60,000
9,700
4.2
      Indicates that pollutant concentration was below detection limit
NA    Indicates not analyzed
NR    Matrix interference
t     Denotes tentative indentification below the detection limit
b     BOD calculated from limiting value
                                           85

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                            SECTION  IV

                        SUBCATEGORIZATION
A.  EXISTING SUBCATEGORIES

EPA  has never  promulgated effluent  limitations guidelines  and
standards for the transportation equipment cleaning industry.  For
this reason, the industry has never been subcategorized.

B. PRELIMINARY SUBCATEGORIZATION SCHEME

Section  304(b)  of the Clean Water  Act requires EPA  to consider
several factors ir the process of developing effluent limitations
and guidelines for industrial dischargers.  Factors that are to be
taken into  account  include the age of  equipment and facilities,
processes employed, engineering aspects of application of various
types of control technology, process changes,  the cost of achieving
effluent reductions, and non-water quality environmental impacts.
The division of an industrial category into subcategories provides
a mechanism for addressing these factors and others that may impact
a facility's compliance with effluent  limitations  guidelines and
standards.

Based on  available  information, the tentative  subcategories  for
the transportation equipment cleaning industry are as follows:

o   tank truck cleaning;

o   rail tank car cleaning;

o   tank barge cleaning; and

o   aircraft exterior cleaning.

This grouping is based on differences in wastewater characteristics
which could impact  control  technologies and  on  the potential for
different economic impacts on the groups.  Because cargo tanks are
not  being  cleaned,  the  wastewater  from  cleaning  of  aircraft
exteriors has different characteristics than wastewaters from the
other three tentative subcategories.  This difference justifies a
separate subcategory for cleaning aircraft exteriors.

The wastewaters from the  remaining  three  tentative subcategories
exhibit some similarity; however, the number of units cleaned per
day  is  distinctly  different   among  the  subcategories.    This
difference will affect wastewater characteristics and variability
and consequently control technologies and potentially the cost of
control.  Because of this, separate subcategories are recommended.
At the present  time  insufficient data  are  available  to recommend
subcategorization based on any of the following criteria:

o   equipment age;
                                86

-------
o   facility age;

o   processes employed; or

o   non-water quality impacts.

The four  subcategories  identified represent the  most reasonable
subcategorization for this industry based  on what is known about
operations at transportation  equipment cleaning facilities as well
as the sampling results presented in the previous section.
                                87

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                             SECTION V

                     RAW WASTE  POLLUTANT LOADS

 This section presents  raw waste  pollutant loads by  subcategory.
 Within each subcategory,  loads  are presented  for the  following
 groups of  pollutants:

 o    volatile organics  (EPA analytical  Method  1624);

 o    semivolatile organics (EPA analytical  Method 1625);

 o    pesticides  and herbicides  (EPA analytical Method  1618);

 o    priority pollutant metals;

 o    conventional pollutants; and

 o    cyanide.

 The  loadings are presented for pollutant  groups rather than for
 individual  pollutants  because of  the  limited  amount  of  data
 available for individual pollutants.  The composition of wastewater
 generated   by  transportation  equipment   cleaning  facilities,
 particularly those that clean cargo tanks, can vary widely from day
 to  day  and  from facility  to facility.    The  analytical  data
 generated  during this  study  are not  adequate to account for this
 variability.  Therefore, EPA  believes that  estimates for pollutant
 groups  are better.

 Three  methods were  used  to  estimate pollutant loads  for  each
 subcategory.      Each   method   involved   calculating   average
 concentrations of individual  pollutants and summing the individual
 averages to obtain a total concentration for each pollutant group.
 The group totals were then used to estimate annual mass loadings.
 The estimates take into account only pollutants that were reported
 above detection  limits  in at least one raw waste sample for each
 subcategory.

 The  difference   among  the methods  is  in   the  approach  used  to
 estimate individual  pollutant  average  concentrations.  In Method
 A, the concentration of individual pollutants is assumed to be zero
 if  a   specific  value  is  not  reported.     In  Method  B,   the
 concentration of  individual pollutants is  assumed to  be equal to
 the detection limit if  a specific value is not  reported.  In Method
 C, only pollutant concentrations above the detection limit are used
 to calculate average pollutant concentrations.

 Based on available data,  Methods  A and B  provide  an  estimate of
 the range of mass loads within which the actual industry discharge
 could  be  expected  fall.   Method A  assumes  that if a  specific
 concentration value was not reported for a pollutant, the pollutant
was not present.  Method B assumes  that  if a  specific concentration
value was not reported  for a  pollutant, the pollutant was present
 at a  concentration  just  below the detection  limit.   Method  C,

                               88

-------
because it ignores the fact that pollutants are not always present
at  reportable  concentrations,  overestimates  pollutant  loads.
Because of this overestimation, Method C can be viewed as a "worst
case" approach.   Based on available  data there is no  reason to
believe that the Method C estimates of pollutant loads are accurate
or representative.

The reader should remember, however,  that  the mass loads are based
on a  limited amount  of data.   If  samples  were collected  at a
greater  number of  facilities over  an extended  period  of  time
additional pollutants would be detected and the mass loadings could
change.

Tables V-l through V-4 present the estimated (Method B)  raw waste
pollutant loads by  subcategory.   Appendix B contains information
used to calculate individual and group pollutant averages.
                                89

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                                   TABLE V-l

                  ESTIMATED ANNUAL RAW WASTE POLLUTANT LOADS
                    TANK TRUCK INTERIOR CLEANING FACILITIES
Pollutant Group
Volatile Organics
Priority Pollutants
Nonconventional Pollutants
Semivolatile Organics
Priority Pollutants
Nonconventional Pollutants
Pesticides and Herbicides
Priority Pollutants
Nonconventional Pollutants
Elements
Priority Pollutant Metals
Nonconventional Pollutants
Method A1'2
Ibs/year
950,000
6^960,000
7,910,000
220,000
2,570^000
2,790,000
0
1,050,000
1,050,000
1,260,000
27,710,000
28,970,000
Method B1'3
Ibs/year
950,000
6,990,000
7,940,000
620,000
3,100,000
3,720,000
0
1,070,000
1,070,000
1,260,000
27,710,000
28,970,000
Method C1'4
. Ibs/year
1,300,000
12,100,000
13,400,000
750,000
14,590,000
15,340,000
0
2,240,000
2,240,000
1,260,000
27,710,000
28,970,000
Cyanide

Conventional Pollutants
        700            800          1,000

143,710,000    143,710,000    143,710,000
     Based on 400 facilities each operating 312 days per year and discharging
     15,000 gallons per day of wastewater.

     During calculations, the concentration of individual pollutants was
     assumed to be zero if a specific value was not reported.

     During calculations, the concentration of individual pollutants was
     assumed to be equal to the detection limit if a specific value was not
     reported.

     During calculations, only pollutant concentrations above detection limits
     were considered.
                                          90

-------
                                   TABLE V-2

                  ESTIMATED ANNUAL RAW WASTE POLLUTANT LOADS
                  RAIL TANK CAR INTERIOR CLEANING FACILITIES
Pollutant Group
Volatile Organics
Priority Pollutants
Nonconventional Pollutants
Semivolatile Organics
Priority Pollutant?
Nonconventional Pollutants
Method A1'2
Ibs/year
9,000
9^600
18,600
7,400
3,400
10,800
Method B1'3
Ibs/year
9,200
10,000
19,200
9,400
4,700
14,100
Method C1'4
"Ibs/year
10,200
30,100
40,300
21,200
14,000
35,200
Pesticides and Herbicides
   Priority Pollutants
   Nonconventional Pollutants

Elements
   Priority Pollutant Metals
   Nonconventional Pollutants
Cyanide

Conventional Pollutants
         —NOT ANALYZED—•
         —NOT ANALYZED--
    12,000
14.730.000
14,742,000
    13,000
14.730.000
14,743,000
    14,000
14,730.000
14,744,000
       923            965          1,850

13,320,000     13,320,000     13,320,000
   Based on 89 facilities each operating 312 days per year and discharging
   18,000 gallons per day of wastewater.

   During calculations, the concentration of individual pollutants was
   assumed to be zero if a specific value was not reported.

   During calculations, the concentration of individual pollutants was
   assumed to be equal to the detection limit if a specific value was not
   required.

   During calculations, only pollutant concentrations above detection limits
   were considered.
                                          91

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                                    TABLE V-3

                   ESTIMATED ANNUAL RAW WASTE POLLUTANT LOADS
                     TANK BARGE INTERIOR CLEANING FACILITIES
Pollutant Group
Volatile Organics
Priority Pollutants
Nonconventional Pollutants
Semivolatile Organics
Priority Pollutants
Nonconventional Pollutants
Pesticides and Herbicides
Priority Pollutants
Nonconventional Pollutants
Elements
Priority Pollutant Metals
Nonconventional Pollutants
Method A1'2
Ibs/year
19,340,000
13,880,000
33,220,000
2,400
800
3,200
10
10
20
3,700
3,890,000
3,893,700
Method B1'3
Ibs/year
19,340,000
13,880,000
33,220,000
18,600
16,500
35,100
10
1,300
1,310
4,300
3,890,000
3,894,300
Method C1'4
-Ibs/year
48,830,000
28,640,000
77,470,000
9,000
4.200
13,200
20
20
40
4,400
3^900,000
3,904,400
Cyanide

Conventional Pollutants
                                       270            310            540


                                19,660,000     19,680,000     29,720,000
     Based on 196 facilities each operating 312 days per year and discharging
     7,000 gallons per day of wastewater.
2



3
During calculations, the concentration of individual pollutants was
assumed to be zero if a specific value was not reported.

During calculations, the concentration of individual pollutants was
assumed to be equal to the detection limit if a specific value was not
required.


During calculations, only pollutant concentrations above detection limits
were considered.
                                         92

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                             TABLE V-4

            ESTIMATED ANNUAL RAW WASTE POLLUTANT LOADS
               AIRCRAFT EXTERIOR CLEANING FACILITIES
Pollutant Group
Volatile Organics
Priority Pollutants
Nonconventional Pollutants
Semivolatile Organics
Priority Pollutants
Nonconventional Pollutants
Pesticides and Herbicides
Priority Pollutants
Nonconventional Pollutants
Elements
Priority Pollutant Metals
Nonconventional Pollutants
Cyanide
Conventional Pollutants
Method A1'2
Ibs/year
57,800
3.100
60,900
35,400
8,000
43,400
0
3.500
3,500
11,900
345,000
356,900
0
14,530,000
Method B1'3
Ibs/year
58,500
3.200
61,700
36,100
11,900
48,000
0
3.500
3,500
11,900
345,000
356,900
14
14,530,000
Method C1'4
-Ibs/year
115,600
6.100
121,700
70,800
16,000
86,800
0
3.500
3,500
11,900
345,000
356,900
0
14,530,000
Based on 4,300 commercial passenger aircraft, washed four times per year.
Each wash uses 5,000 gallons.

During calculations, the concentration of individual pollutants was
assumed to be zero if a specific value was not reported.

During calculations, the concentration of individual pollutants was
assumed to be equal to the detection limit if a specific value was not
required.

During calculations, only pollutant concentrations above detection limits
were considered.
                                     93

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                             SECTION VI

                 CONTROL AND  TREATMENT TECHNOLOGIES

 A.  CONTROL AND TREATMENT
 Analytical results for samples collected as part of this study show
 that wastewaters from transportation equipment cleaning processes
 are  a complex  mixture  of  many pollutants.    The  wastewaters
 typically have BOD5 and TSS levels of several thousand milligrams
 per liter and oil and grease levels ranging from  less than 100 to
 over i 000 milligrams per liter.  They also tend to be alkaline and
 5SV*J?n .    -V°f  ", ^.^her.  The wastewater typically contains
 3L ?TO rTT1?? v?1itlle and semivolatile organic pollutants from
 the ITD List  of An*lytes.  Priority pollutant metals may be present
 at  individual  concentrations of several  milligrams per  liter
 liS?.°SnSi; HS^tS °f * review of  Cleaning  log  sheets,  there is
 little doubt that many  other pollutants  not  on the  ITD  list  are
 also present.  Treatment or  pretreatment of these wastewaters to
 levels normally associated with  effluent  limitations for  other
 industries requires  a  well-run multi-step treatment system.    A
 complicating factor  is  that the wastewater  from transportation
 equipment cleaning processes is  highly variable,  both in  strength
 and composition, and treatment needs  can vary dramatically from day
 to day as well as  from  facility  to facility.
 B.   CURRENT  PRACTICES

 At the present time, limited  information is available on the  type
 ™^tXte+nt1°f  .wast;ew^e.r . treatment provided  at transportation
 equipment cleaning  facilities.  The  type of treatment provided by
 the  facilities sampled as part of this study is summarized in Table
 V JL~«L •

 In general,  the  facilities relied on physical-chemical treatment
 methods  rather  than biological  treatment.   Three of  the eight
 facilities used biological treatment, however.  All the facilities
 made an effort to segregate wastewaters that were incompatible  with
 their treatment systems for off-site treatment  and disposal.

 Review of the analytical data for the  facilities with physical-
 chemical treatment  indicates that none of the systems provided
 consistent or high levels of treatment.  This  is attributed  to  both
 the  limited ability of the systems to remove dissolved pollutants
 and, to a limited extent, the need for improved system operation.
 To achieve a higher level of treatment, improved operation,  and
 integration with additional treatment steps would likely be needed.
 Samples of effluent were  not  collected  from  the three biological
 treatment systems because long treatment  system detention times
prevented correlation of effluent samples with influent samples and
because other wastewaters were combined with  cleaning wastes for
treatment .
                               94

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                                 TABLE VI-1

                        OBSERVED TREATMENT TECHNOLOGIES
     Facility
                                                  Type  of  Treatment
Tank Truck Cleaner
Rail Tank Car Cleaner
Tank Barge Cleaner
Aircraft Cleaner
A


B
B

A

B.

A
Equalization, pH  adjustment,  coagu-
lation,   dissolved  air  -flotation

Equalization, pH  adjustment,  coagu-
lation, sedimentation

Equalization, pH  adjustment,  coagu-
lation,   sedimentation,   activated
carbon adsorption, filtration

Combined  with other wastewaters for
equalization,  and  activated  sludge
treatment

Equalization, activated sludge

Gravity  separation,  bag  filtration

Gravity  separation,  bag  filtration

Combined  with other wastewaters for
biological  treatment
                                            95

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 c.
APPLICABLE CONTROL AND TREATMENT TECHNOLOGIES
 This section discusses several control  and treatment technologies
 believed applicable  to treat  transportation equipment  cleanina
 wastewaters.    Table VI-2  lists  these  control   and  treatment
 technologies  and  indicates  their  applicability  by  pollutant
 category.  A model treatment system for a transportation equipment
 cleaning facility  would probably  require a  combination of  the
 treatment steps  based on site specific factors to achieve complete
 control.

 is	In-Plant Controls

 In-plant controls are measures that a facility can take to  reduce
 the  quantity  or strength of  its wastewater  and  thus reduce  or
 simplify treatment  needs.   At transportation equipment  cleaning
 facilities,  applicable in-house controls include:

 o    refusal  to  clean tanks that last  carried  certain  specific
     cargos;

 o    refusal  to accept large  volumes of  heel;

 o    drumming of  heels  for disposal at  approved off-site facilities
     or for return to  carriers/shippers;

 o    capture  of  concentrated  rinses  for  separate  treatment  or
     disposal;

 o    recycle  of cleaning solutions;

 o    cascading  water use; and

 o    use  of high-pressure,  low-volume  spray nozzles.

All of these  are  used currently at facilities in the transportation
 equipment cleaning industry.

£*	Oil-Water Separation

Wastewaters  from  transportation  equipment  cleaning  processes
 frequently contain high levels of free oil and grease that can be
removed by gravity separation in an oil-water separator.  Because
of the complex nature of cleaning wastewaters and the presence of
detergents  and  high-pH  chemicals,  however,  oils  may  become
emulsified and not separate well in a gravity device.  A coalescing
plate separator may provide improved performance for
                               96

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                                TABLE VI-2

                  APPLICABILITY OF TREATMENT  TECHNOLOGIES
In Plant Controls
Gravity Oil-Water
Separation
Equalization
pH Adjustment
Air Stripping
Steam Stripping
Dissolved Air
Flotation
Coagulation-
Sedimentation
Hydroxide/Sulfide
Precipitation
Biological Treatment
Activated Carbon
Adsorption
Wet Air Oxidation
(X)
X










(X)





X
X

X


(X)

X
X








(X)



X
X
(X)


X
X
X
(X)




X
(X)
X

X
X
X
(X)





(X)
(X)

X

X
(X)





X
X




(X)






(X)
X



X   = Technology is applicable to pollutant category.
(X) = Technology is applicable but additional treatment will likely be needed.
                                      97

-------
 treatment of  emulsified  oil,  but additional treatment  processes
 will probably be required for removal of emulsified oil.

 Use of gravity oil-water separators  is most beneficial  when they
 are placed at  the  beginning of the  wastewater treatment  system!
 A problem with placement there is, however, that settleable solids
 may accumulate in the separator and  require frequent removal
 3.   Equalization
 Tanks or basins that provide  several  hours or more of  detention
 are  useful  for  equalizing variations  in  wastewater  flow  and
 composition.   This allows facilities to reduce the size  and cost
 of treatment systems, while at  the same time improving performance.
 To be most effective equalization tanks should have their contents
 mixed with  aerators or  mechanical mixers.

 4.   PH  Adjustment

 The need for adjustment of wastewater pH at a  facility depends on
 the treatment  process used, the initial pH of  the wastewater,  and
 effluent limitations.  The performance of treatment processes such
 as coagulation,  metal  hydroxide or  metal  sulfide  precipitation
 biological  treatment,  and  carbon  adsorption is  pH-dependent.
 Discharges  to  a POTW must generally have a pH greater than  5.0.
 Discharges to  surface waters generally must  be within the  pH  range
 Of 6.0  to 9.0.

 Adjustment of pH is usually done by metering an acid or alkali into
 the wastewater in a well-mixed  reaction tank.  Common pH adjustment
 chemicals include  sulfuric acid, sodium hydroxide, and lime.

 5.  Air and Steam  Stripping

 Air and steam  stripping take advantage of the high vapor pressure
 and limited water  solubility of many organic pollutants to remove
 those pollutants from wastewater.  Air stripping  is performed by
 purging wastewater with finely  diffused air bubbles  or by allowing
 a wastewater to cascade down through porous media contained in a
 tank while air is  forced upward through the media.  Air to liquid
 ratios between 50:1 and  200:1 are common.  The effectiveness of air
 stripping varies  among  volatile pollutants and is  influenced by
 other wastewater characteristics.

 Steam   stripping   is  performed  by  purging  steam  through  the
wastewater to  be treated.  The steam raises both  the  temperature
 of  the  wastewater  and  the vapor  pressure of many  pollutants,
 increasing their removal,  steam stripping  is  effective  for many
volatile and some semivolatile  pollutants.
                               98

-------
6.  Dissolved Air Flotation

Dissolved air  flotation (DAF)  is  useful for  removing suspended
solids and finely dispersed or emulsified oil and grease from many
wastewaters.     For  optimum  performance,  pH   adjustment  and
coagulation  usually  precede  DAF.    Floe  resulting  from  the
coagulation  of  particles  then  attach  to  tiny  bubbles of  air
released from solution,  and float to the top of  the treatment unit.
The float or sludge is skimmed off, dewatered,  and disposed.  Some
volatile  and semivolatile  organic pollutants,  as  well  as some
BOD/COD, are also removed.

7.  coagulation-Sedimentation

If a  wastewater contains a large  amount of settleable solids in
addition  to suspended solids and dispersed oils, or if the floe
particles generated during  coagulation settle rapidly, coagulation-
sedimentation  can be used to remove the  solids A well-operated
coagulation-sedimentation system should be able to reduce suspended
solids  to  levels  of 50  mg/1   or less.   Semivolatile organic
pollutants  tend to  adsorb  or  partition to wastewater solids; thus
their  concentrations  tend  to  be  reduced  by  coagulation-
sedimentation.   Dissolved  volatile pollutants and dissolved BOD5.
are  not  removed.    Depending  on  the pH  used  for coagulation,
dissolved metals may  precipitate and be  removed.

8.  Hvdroxide/Sulfide Precipitation

The   alkaline   precipitation  of   dissolved metals  is  a  well-
established process used  widely for  wastewater treatment.   Many
dissolved metals form a hydroxide  precipitate, which is removable
by  settling.   Optimum removal  corresponds to the  pH  of minimum
metal hydroxide  solubility and varies  among  individual metals.
Generally,  best removals occur within the pH range of 7.0 to 11.0.
Hydroxide  precipitation  is  useful   for   control   of  dissolved
aluminum,  arsenic,  cadmium, chromium,  copper,  iron,  lead, nickel,
and  zinc.   Residual metal  concentrations of 1  milligram per liter
or  less are theoretically  attainable.

Hydroxide precipitation can be combined with  addition of sulfide
 ions to precipitate  metal sulfides.   Most metal sulfides  have  a
solubility less than that  of their corresponding hydroxide;  thus
better removal  rates  are theoretically possible.  In practice, this
does not always occur.  Increased removals should  be  achievable,
however,  for arsenic, cadmium,  mercury,  nickel,  and zinc.

 9.   Biological Treatment

 Properly  acclimated  biological  treatment   systems   offer  the
 potential  to  treat  or remove most  of the  pollutants  found  in
 transportation  equipment  cleaning wastewaters.   The  process  can
 biodegrade many volatile and semivolatile organic pollutants, oils,
 and  BOD.   Some volatile  pollutants  are air-stripped during  the
 aeration process  and semivolatile pollutants adsorb  onto  sludge
 particles.    Adsorption onto sludge  also   removes  some dissolved
                                 99

-------
 metals.  Extensive adsorption may  result,  however,  in generation
 of a hazardous sludge that requires special disposal steps.

 One  concern  when  treating  transportation  equipment  cleaning
 *afuewal:er 1S, the variability of  wastewaters in this industry?
 Although acclimated biological systems can treat a  wide range of
 organic pollutants, some organic pollutants exhibit toxic effects
 especially when  discharged to the  treatment system  at variable
 rates or on an intermittent basis.  Dissolved metals  may also be
 toxic  to  biological   treatment  systems.   Successful  biological
 treatment of  transportation equipment  cleaning wastewater  will
 require flow  equalization  to  reduce wastewater variability.   In
 addition,  the treatment system operator will  need to  pay careful
 attention to daily system  operation to minimize  toxic  upsets.

 10^ _ Wet Air Oxidation
 Wet air oxidation of  wastewater is not known  to  be used at  any
 transportation equipment cleaning facilities.  In theory,  however,
 it would be applicable either alone or in conjunction with another
 treatment  process, such as  activated  sludge  biological  treatment.
 The process can chemically oxidize BOD, COD,  and many biologically
 refractive chemical  compounds  to  simpler compounds,  or in SOK«
 cases  to CO2 and water.  Because wet air oxidation does not rely on
 a  living  biomass  as do biological  systems, the  process is  not
 subject to upset by  toxic chemicals.

 The wet  air  oxidation  process  consists  of  pumping preheated
 wastewater into a pressurized reaction vessel along  with compressed
 air.  Once in the vessel,  oxidizable materials combine with oxygen
 in the air and are  converted  to simpler  oxidation  products.   A
 supplemental heat source is necessary to treat low  strength wastes
 and to initiate treatment of high strength wastes.  Once  initiated
 the reaction is self sustaining in wastes with  a COD  greater than
 approximately  15,000 mg/1.   Following treatment,  the  wastewater
 enters a heat exchanger to preheat  the influent  stream.  Depending
 on the extent  of treatment  required, the effluent may be  suitable
 for discharge,  or may require polishing with subsequent treatment
 steps such as  activated sludge.

i!_! _ Activated  Carbon Adsorption

Activated  carbon can be  used to remove  medium  to  high molecular
weight  organic pollutants   from  water  by  sorption  mechanisms.
Activated carbon has a finite adsorption capability,   however, and
must be replenished  as it becomes exhausted.   The spent carbon  is
either disposed or regenerated for reuse.

Because of the high  concentration of  many organic pollutants   in
transportation  equipment  cleaning wastewater,  use  of  activated
carbon by itself is probably not economical.   However, either use
of  granular  carbon  to pretreat  wastewaters  prior to biological
treatment or the addition of powdered carbon to biological aeration
basins should both  be economically viable.  Activated  carbon could
also be  used  to remove  refractory organic  pollutants  from  the
effluent of biological treatment processes.
                               100

-------
ENVIRONMENTAL IMPACT ANALYSIS
          101

-------
                           SECTION VII

                      ENVIRONMENTAL IMPACTS

A.   POLLUTANT  IMPACTS

The  transportation equipment cleaning industry discharges numerous
pollutants that are harmful to human and aquatic life.  Table VII-
1  lists  the  organic  and  inorganic  pollutants   identified   in
wastewaters from this industry during this study that EPA believes
are  of particular concern.  These are  pollutants  that are on  at
least  one of the  following lists:

o    EPA Priority  Pollutant List;

o    RCRA Hazardous Constituent List;

o    CERCLA Hazardous Substance List;  and

o    Confirmed  Human  Carcinogens  and Suspected Human Carcinogens,
     published   by  the   American  Conference   of  Governmental
     Industrial Hygienists.


A  total  of  111  organic  pollutants  (including pesticides  and
herbicides)  were  detected   in   wastewaters  at  transportation
equipment cleaning facilities. Of these,  50  are on EPA's Priority
Pollutant List, 52 are RCRA Hazardous Constituents, 72 are CERCLA
Hazardous  Substances,   and  five  are  known  or suspected  human
carcinogens.   All 13 priority pollutant metals were found.

Information obtained  during this study indicates that  the tank
barge cleaning subcategory is the largest contributor of pollutants
causing exceedances of EPA criteria  for  protection of human health
and aquatic life.  The combined untreated discharge of acrolein and
of the carcinogen  acrylonitrile is estimated to be greater that the
untreated organic priority pollutant loads from  all  industries
except the Organic Chemicals  Manufacturing Industry and the Iron
and  Steel Industry.   Twelve pollutants are  discharged  at levels
that exceed  aquatic  acute toxicity  criteria.    The discharge  of
acrolein would require 1,800 million gallons per  day  (MGD) or twice
the  mean  flow in  the Rappahanock  River at  is mouth to  dilute
concentrations below  fish toxicity levels.  The carcinogens benzene
and  1,2-dichlorethane  are also  discharged in  amounts  requiring
large receiving water flows to meet EPA criteria.

Wastewater generated by the  tank truck cleaning subcategory  has
the largest potential to harm aquatic life.  Twenty-one
                               102

-------
         TABLE VII-1



POLLUTANT EVALUATION CRITERIA
Pollutants 	 	 	 __ 	
Priority
CAS No. Pollutant
RCRA
Appendix IX
Hazardous
Constituent
CERCLA
CERCLA Extremely
Hazardous Hazardous
Substance Substance
Carcinogen
Volatile Organic Pollutants
acetone
acrolein
acrylonitrile
benzene
bromoform
chlorobenzene
chloroform
cis-l,2-dichloropropene
diethyl ether
ethylbenzene
ethyl methacrylate
isobutyl alcohol
methacrylonitrile
methylene chloride
methyl methacrylate
N,N-dimethylformamide
tetrachloroethene
toluene
trans-1 ,3-dichloropropene
trichloroethene
vinyl chloride
1 , 1 , 1-trichloroethane
1 ,2-dichloroethane
1 ,2,3-trichloropropane
2-butanone
2-chloroethyl vinyl ether
2-hexanone
2-methyl pyridine
4-methyl-2-pentanone
67-6A-1
107-02-8
107-13-1
71-43-2
75-25-2
108-90-7
67-66-3
10061-01-5
60-29-7
100-41-4
97-63-2
78-83-1
126-98-7
75-09-2
80-62-6
68-12-2
127-18-4
108-88-3
10061-02-6
79-01-6
75-01-4
71-55-6
107-06-2
96-18-4
78-93-3
110-75-8
591-78-6
109-06-8
108-10-1

X
X
X
X
X
X


X



X


X
X

X
X
X
X


X



X
X
X
X
X
X
X
X

X
X
X
X
X
X

X
X
X
X
X
X
X
X
X

X
X
X
X
X X
X X

X
X
X X
X
X
X

X
XV
X



X
X
X
X
X
X
X

X
X

X
X


X



X























-------
TABLE VII-1 (cont.)
Pollutants
CAS No.
Priority
Pollutant
RCRA
Appendix IX
Hazardous
Constituent
Semivolatile Organic Pollutants
acenapthene
acenaphthylene
alpha-terpineol
anthracene
benzidine
benzo(a)anthracene
benzoic acid
benzyl alcohol
biphenyl
bis(2-chloroethyl)ether
bis(2-ethylhexyl)
phthalate
butyl benzyl phthalate
carbazole
chrysene
dibenzofuran
diethyl phthalate
dimethyl phthalate
di-n-butyl phthalate
di-n-octyl phthalate
diphenylamine
fluoranthene
fluorene
hexanoic acid
isophorone
naphthalene
n-decane
n-docosane
n-eicosane
n-hexacosane
n-hexadecane
83-32-9
208-96-8
98-55-5
120-12-7
92-87-5
56-55-3
65-85-0
100-51-6
92-52-4
111-44-4
117-81-7

85-68-7
86-74-8
218-01-9
132-64-9
84-66-2
131-11-3
84-74-2
117-84-0
122-39-4
206-44-0
86-73-7
146-62-1
78-59-1
91-20-3
124-18-5
629-97-0
112-95-8
630-01-3
544-76-3
X
X

X
X
X




X

X

X

X
X
X
X

X
X

X
X





X
X

X

X

X

X
X

X

X
X
X
X
X
X
X
X
X

X
X





CERCLA
CERCLA Extremely
Hazardous Hazardous
Substance Substance Carcinogen

X
X

X
X X
" f\
X
X


x
X

X

X

X
X X
X X
X X

X
X

X
X






-------
                                                            TABLE VII-1 (cont.)
o
tn
Pollutants
Semivolatile (cont.)
nitrobenzene
N-nitrosodiphenylamine
n-octacosane
n-octadecane
n-tetracosane
n-tetradecane
n-triacontane
p-cymene
phenanthrene
phenol
pyrene
squalene
styrene
thioxanthone
1-methylfluorene
1 -methyl phenanthrene
1 ,2-dichlorobenzene
1 ,2-dichloropropane
1 ,4-dichlorobenzene
2-chloronaphthalene
2-chlorophenol
2-methylnaphthalene
2,3,6-trichlorophenol
2 , 4-diaminotoluene
2,4-dichlorophenol
2,4-dimethylphenol
2,4-dinitrotoluene
2,4,5-trichlorophenol
2, 4,6-trichlorophenol
2, 6-dinitro toluene
3,6-dimethylphenanthrene
CAS No.

98-95-3
86-30-6
630-02-4
593-45-3
646-31-1
629-59-4
638-68-6
99-87-6
85-01-8
108-95-2
129-00-0
7683-64-9
100-42-5
492-22-8
1730-37-6
832-69-9
95-50-1
78-87-5
106-46-7
91-58-7
95-57-8
91-57-6
933-75-5
95-80-7
120-83-2
105-67-9
121-14-2
95-95-4
88-06-2
606-20-2
1576-67-6
Priority
Pollutant

X
X






X
X
X





X
X
X
X
X



X
X
X

X
X

RCRA
Appendix IX
Hazardous
Constituent

X
X






X
X
X





X
X
X
X
X
X


X
X
X
X
X
X

CERCLA
CERCLA Extremely
Hazardous Hazardous
Substance Substance Carcinogen

X X
X






X
X X
X X

X



X
X
X
X
X

X
X
X
X
X
X
X
X


-------
TABLE VII-1 (cont.)
Pollutants
Semivolatile (cont.)
4-chloro-3-methylphenol
4-nitrophenol
Pesticides and Herbicides
azinphos ethyl
azinphos methyl
beta-BHC
coumaphos
demeton
diazinon
dichlorprop
dioxathion
etridazone
gamma -BHC
heptachlor epoxide
HMPA
leptophos
naled
propachlor
tetrachlorvinphos
trifluralin
2-methyl-4-
chlorophenoxyacetic acid
2,4-dichlorophenoxyacetic
acid
Priority Pollutant Metals
antimony
arsenic
Priority
CAS No. Pollutant

59-50-7 X
100-02-7 X

2642-71-9
86-50-0
319-85-7
56-72-4
8065-48-3
333-41-5
120-36-5
78-34-2
**
58-89-9 X
1024-57-3 X
680-31-9
21609-90-05
300-76-5
1918-16-7
961-11-5
1582-09-8

94-74-6

94-75-7

7440-36-0 X
7440-38-2 X
RCRA
Appendix IX CERCI.A
Hazardous Hazardous
Constituent Substance

X X
X X


X
X X
X

X



X X
X X









X

X X
X X
CERCLA
Extremely
Hazardous
Substance Carcinogen
	 • — • 	 & 	



X
X

x
x


X

x


x












-------
                                                TABLE V1I-1 (cont.)
Pollutants
 CAS No.
Priority
Pollutant
                                                         RCRA
                                                      Appendix IX
                                                       Hazardous
                                                      Constituent
             CERCLA
            Hazardous
            Substance
                                                             CERCLA
                                                            Extremely
                                                            Hazardous
                                                            Substance
                          Carcinogen
Priority Pollutant Metals (cont.)
beryllium
cadmium
chromium
copper
lead
mercury
nickel
selenium
silver
thallium
zinc

Common Ions

calcium
iron
magnesium
sodium

Other Elements

aluminum
barium
boron
cobalt
manganese
molybdenum
7440-41-7
7440-43-9
7440-47-3
7440-50-8
7439-92-1
7439-97-5
7440-02-0
7782-49-2
7440-22-4
7440-28-0
7440-66-6
7440-70-2
7439-89-6
7439-95-4
7440-23-5
7429-90-5
7440-39-3
7440-42-8
7440-48-4
7439-96-5
7439-98-7
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
    X
X
X
X
X
X
X
X
X
X
X
X
                    X

                    X
X
X
X
X
X
X
X
X
X
X
X

-------
                                                           TABLE VII-1 (cont.)
o
oo


Pollutants
Other Elements (cont.)
osmium
tin
titanium
vanadium
cyanide


Priority
CAS No. Pollutant

7440-04-2
7440-31-5
7440-32-6
7440-62-2
57-12-5 X
RCRA
Appendix IX CERCLA
Hazardous Hazardous
Constituent Substance


X

X
X X
CERCLA
Extremely
Hazardous
Substance 	 Carcinogen






CAS No.
Priority Pollutants
RCRA Hazardous Constituent
CFRCLA Hazardous Substances
CERCLA Extremely Hazardous Substances
Carcinogens
Chemical Abstracts Service Registry Number
EPA-identified 126 Priority Pollutants
RCRA Appendix IX Hazardous Constituents (52 FR 25942)
CERCLA List of Reportable Quantities of Hazardous Substances (51 FR 42178)
CERCLA List of Extremely Hazardous Substances (52 FR 13397)
1986 Threshold Limit Values for Chemical Substances in the Work Environment;
Appendix A:  Carcinogens
CAS Number Does Not Exist

-------
pollutants in wastewater from the tank truck cleaning subcategory
exceeded aquatic acute toxicity criteria.  Aquatic life, sensitive
to pesticides, would be exposed to discharges (without treatment)
which require  a larger flow  than  the Delaware River  at Trenton
(9,000 MGD)  to dilute the discharges below long-term effect levels.
Untreated discharges  of  benzene,  methylene  chloride,  and 1,2-
dichlorethane  would require flows as  high  as 1,200 MGD,  a flow
equivalent to  that of  the  Rappahanock River,  to meet criteria to
protect human health.

Rail tank car cleaning processes discharge the carcinogens benzene
and bis (2-chloroethyl) ether in concentrations that require flows
as high  as  Rock  Creek (41 MGD)  to meet human  health criteria.
Seven  pollutants  are  discharged  above  aquatic acute  toxicity
criteria  by   facilities   in  the  subcategory.     Mercury  and
benzo(a)anthracene   are   of   most   concern,   although   their
concentrations appear close to treatability levels.

Wastewater  from   the   aircraft  exterior  cleaning  subcategory
contained 12 pollutants at concentrations that exceed aquatic acute
toxicity criteria. The untreated discharge of pesticides, cadmium,
copper, and molybdenum would present  substantial risk to aquatic
life.

The most significant of the observed pollutants were evaluated to
determine their  fate  in receiving waters.  Acrolein would pose  a
risk  to  aquatic  life during its  reduction  by  hydration  and
biotransformation   (half-life  -   96  hours).      The  reported
concentration  levels pose a significant risk because aquatic life
criteria are  based on  96-hour LC^s;  this means that aquatic life
exposure would be  at  toxic levels for enough time to cause harm.
Acrylonitrile  has  less risk to human health and aquatic life than
calculated because it volatilizes quickly (half-life of 4 hours);
however, a persistent residue could remain in surface waters which
leaves  some   potential   for  exposure.     Cadmium  has  a  high
bioaccumulation potential in addition to its toxicity.  It is more
soluble in  acidic  waters  than under alkaline conditions where it
partitions to sediments.  1,2-Dichloroethane and methylene chloride
pose less risk than calculated due to high volatilization  rates  (28
minutes   and   27   minutes,    respectively)   and   their  low
bioconcentration factors (BCF = 1.2 and 5.0,  respectively).   Bis(2-
chloroethyl) ether is very soluble (10,200 mg/1)  and has  a low log
P  of  1.5; it  is inferred  to pose little  risk for bioaccumulation
or for  absorption  to  sediments, although it could present  a risk
to humans if discharged near water supplies.  The same  is possible
for benzene, which is discharged by three of the  four subcategories
but  poses  little  risk  to  aquatic  life  because  of  its  low
bioaccumulation potential  (BCF = 50)  and  high volatility in water
(half-life  of 5  hours).    Copper  may  sorb   to  sediment  and
bioaccumulate  (BCF = 200 -  2,400), but it is not biomagnified.
                                109

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B.  POLLUTANT PERSISTENCE

o   Benzene;  The primary transport process of benzene from water
    is  volatilization  (t,/2  =  5  hours) .    The  log  octanol/water
    partition  coefficients  (log P)  of 2.12 indicates  that some
    adsorption  to  sediments  could  occur.    Benzene  has  a  low
    bioaccumulative  potential  (BCF  =  5.0), and  is  expected  to
    biodegrade in water at a slow rate.

o   Methylene Chloride:  Volatilization  is  the primary transport
    process  of methylene chloride  from  water with  an estimated
    half-life   of  27  minutes.     Hydrolysis,  sorption,  and
    bioaccumulation  (BCF = 5)  are  expected  to have negligible
    impact on the removal or transport of methylene chloride from
    water.   Biodegradation  is expected  to  occur at  a  very slow
    rate.

o   2.4-Dinitrotoluene:       2,4-Dinitrotoluene   may   undergo
    photolysis,  oxidation,  and  biodegradation  in  water.    The
    relative importance of these processes  is,  however, unknown.
    An  overall removal half-life  from water  is  estimated  at  6
    hours.  Adsorption to sediments could be significant, but the
    bioaccumulative potential  for  2,4-dinitrotoluene is low (BCF
    = 4).

o   1.2-Dichlorethane:   The  primary  and  most  likely  the only
    important  transport/fate  process of 1,2-dichloroethane from
    water is volatilization, with a half-life of about 28 minutes.
    Bioaccumulation is not expected  (BCF = 1.2).

o   Pvrene:     Pyrene  is  degraded  by  microbes   and  readily
    metabolized by higher life forms; biodegradation is therefore
    most likely the ultimate fate  process.  Dissolved pyrene may
    be  rapidly photolyzed.   However,  most  of the chemical will
    partition  to  sediments based  on its low solubility and high
    adsorption potential (1^= 38,000).   Bioaccumulation of pyrene
    may be high (BCF = 10,000), but the process is short-term and
    highly reversible.

o   Bisf2-Chloroethvll Ether!   The primary fate/transport process
    of  bis(2-chloroethyl)  ether   cannot  be  determined   from
    available information.  An estimated volatilization half-life
    from  water   is   estimated  at  6  days.    Adsorption  and
    bioaccumulation are inferred to be minimal  based on the high
    solubility (10,200 mg/1) and relatively  low log P  (1.5) of the
    compound.

o   Acrvlonitrile:   A  significant  portion of acrylonitrile  is
    expected to be removed from water  by volatilization based on
    its moderate Henry's law constant  (8.8  x 10').   Transport and
    transformation  by   other  processes   is   expected  to   be
    unimportant.   An  overall  removal  half-life  from  water  is
    estimated  at  about  4   hours.    A  persistent  residue  of
    acrylonitrile may remain in surface waters.
                               110

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Cadmium;  Cadmium  is more mobile in  the  aquatic environment
that  other  heavy  metals,  and  sorption  is  most likely  the
controlling transport process in natural  waters.   This metal
will  partition  to inorganic and  organic sediments  with  the
ratio  depending on  the condition  of  the  water.   As  with
other  metals,  alkaline  conditions  favor  partitioning  to
sediments  and   reduced  mobility.      Cadmium   has   a  high
bioaccumulative  potential  in   most   aquatic  organisms  with
bioaccumulation  factors  varying  from  1,000  to  4,000  in
freshwater biota.

Acetone;   Acetone is  miscible in   water  and,  based on  a
Henry's  Law  constant  of 2  x   10',  would be  expected to  be
moderately   volatile    from   water.      Adsorption   and
bioaccumulation  are  believed to  be  minimal  based  on a  low
log P(-0.24) *nd a low  BCF  value  (0.4).  Biodegradation will
remove any acetone that is not volatilized.

Azinphos ethvl;  An estimated Henry's Law constant of  2  x  10
indicates  that  azinphos  ethyl  is  essentially  non-volatile
from water.  The compound has solubility  of  4 to 5  mg/1,  and
is  rapidly  hydrolyzed under  alkaline   conditions.     Its
persistence following application may indicate that  it could
be  long  lived  in   an  acidic  aquatic   environment.    An
estimated  BCF of  250  indicates  that  azinphos  ethyl has  a
potential for bioacummulation.

Coumaphos;  Coumaphos  is  essentially  non-volatile from water
based  on  its  estimated Henry's Law constant  of 3 x 10',  and
has a  solubility of  about 2 mg/1.   A high log P value (5.1)
and a BCF  of  4,270 indicates that coumaphos  would  partition
to  sediments  and  aquatic  biota.    No  information  regarding
other  fate/transport processes was  found  in  the  available
literature.

Diazinon;   Diazinon is  predicted  to  be  essentially  non-
volatile from water  (Henry's Law Constant of  7  x 10"),  with a
solubility of  40 mg/1.   At pH  7.4, diazinon  hydrolyzes with
a  half-life  of  about  185  days.   Hydrolysis  products  may
include    the   extremely    toxic   compound    tetraethyl-
monothiopyrophosphate.    A moderate  log   P  value  (3.02)
suggests  that diazinon  would  partition  to  sediments.   BCF
values  ranging  up   to  206   indicate   some  potential  for
bioaccumulation.

Dioxathion;   Dioxathion is  practically  insoluble in  water,
but it  hydrolyzes  under alkaline conditions.   A log P value
of  2.99 indicates that partitioning to  sediments  could  be
significant.   An  estimated  BCF  value of  47  denotes  that
dioxathion bioaccumulation should be  minor.

Phosvel;  Phosvel  is slightly  soluble  in water (0.005 mg/1)
and strongly  sorbed  to sediments (log  P  = 6.31).   Estimated
BCF  values  are  greater than  10,000  indicating  a  strong
bioaccumulative  potential.   Closed  jar  studies  using river
water  have demonstrated 57  percent degradation  in  16  weeks.

                           Ill

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    Photolysis  of a thin dry  film of phosvel has  been shown to
    occur.

o   Mercury:  Mercury  is  strongly sorbed to sediments, and has a
    solubility  of 0.03 mg/1.   Some  forms of mercury  (dimethyl
    mercury) may  volatilize.   Methylation of mercury by microbes
    in  the  sediment  may  remobilize  the metal  into  the water
    column.  Mercury  is highly bioaccumulative (BCF = 5,500) and
    persistent  in fish and other biota.

o   Acrolein;   Acrolein is believed  to be rapidly removed from
    water by hydration and biotransformation  with a half-life of
    less than  4  days.   Photolysis,  and  volatilization may also
    occur.      Other   fate   processes   are  believed   to   be
    insignificant.

o   Benzo(a)Anthracene;     Benzo(a)anthracene  is   degraded  by
    microbes  and readily  metabolized  by  higher  life  forms;
    biodegradation  is,  therefore,  most likely the  ultimate fate
    process.     Dissolved  benzo(a)anthracene  may  be   rapidly
    photolyzed, however,  most  of the  chemical will partition to
    sediments   based  on  its  high  sorption  (K,,,.  =  1,380,00).
    Bioaccumulation  of benzo(a)anthracene may  be  high  (BCF  =
    29,000),   but  the   process   is   short-term  and  highly
    reversible.

o   Parachlorometacresol;  Photolysis  is  the  most likely  fate of
    parachlormetacresol   in   ambient   surface  water   with  an
    estimated   half-life  of  49  hours.    Other  fate/transport
    processes   are   believed   to   have   a  lesser    role   in
    parachlormetacresol degradation.

o   2-Chloronaphthalene;   Based on  data  from related compounds
    biodegradation  is  most   likely   the  primary  fate  of  2-
    chloronaphthalene  in  water.    A  log  P  of  4.01   and  an
    estimated   BCF  of  580  also   indicate that  adsorption  and
    bioaccumulation   could    be   significant,    although   the
    bioaccumulation of such compounds  is believed to  be short-
    term.    A   half-life  from  water   is  estimated  at  about  22
    hours.

o   Copper;   Sorption in  copper is  expected  to  be  the  most
    important  fate/ transport  process  in ambient  waters.    In
    unpolluted  waters copper will  tend to partition to inorganic
    sediments.     In   pollutant  waters,   sorption  to   organic
    sediment will be  most significant.   Copper  is  an essential
    nutrient,   and   is   actively   bioaccumulated  by    aquatic
    organisms.   Bioconcentration factors  have been shown to be
    as  high  as 200  and  2,400  for  freshwater  fish  and  algae,
    respectively.  Copper is,  however, not biomagnified.

o   Molybdenum;   Molybdenum is insoluble in water, and a trace
    nutrient for  plants.   No other information was available on
    the  fate  or  transport of  this  metal  within  an   aquatic
    environment.


                               ]_]_2      *U S GOVERNMENT PRINTING OFFICE I 99 3 -7 1 5 • 0 0 3« 70 5"t

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