United States
Environmental Protection
Agency
Enforcement Aod
(222-1 A)
Profile Of The
Cleaning Industry
NOTEBOOKS
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE ADMINISTRATOR
Message from the Administrator
Over the past 25 years, our nation has made tremendous progress hi protecting public health and
our environment while promoting economic prosperity. Businesses as large as iron and steel
plants and businesses as small as the dry cleaner on the corner have worked with EPA to find
ways to operate cleaner, cheaper, and smarter. As a result, we no longer have rivers catching on
fire. Our skies are clearer. American environmental technology and expertise are hi demand
throughout the world.
The Clinton Administration recognizes that to continue this progress, we must move beyond the
pollutant-by-pollutant approaches of the past to comprehensive, facility-wide approaches for the
future. Industry by industry and community by community, we must build a new generation of
environmental protection.
Within the past two years, the Environmental Protection Agency undertook its Sector Notebook
Project to compile, for a number of key industries, information about environmental problems and
solutions, case studies and tips about complying with regulations. We called on industry leaders,
state regulators, and EPA staff with many years of experience in these industries and with their
unique environmental issues. Together with notebooks for 17 other industries, the notebook you
hold in your hand is the result.
These notebooks will help business managers to better understand their regulatory requirements,
learn more about how others hi their industry have undertaken regulatory compliance and the
innovative methods some have found to prevent pollution in the first instance. These notebooks
will give useful information to state regulatory agencies moving toward industry-based programs.
Across EPA we will use this manual to better integrate our programs and improve our compliance
assistance efforts.
I encourage you to use this notebook to evaluate and improve the way that together we achieve
our important environmental protection goals. I am confident that these notebooks will help us to
move forward in ensuring that ~ in industry after industry, community after community —
environmental protection and economic prosperity go hand in hand.
Carol M. Brownor
Recycled/Recyclable • Printed with Vegetable Based Inks on Recycled Paper (20% Postconsumer)
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Sector Notebook Project
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EPA/310-R-95-018
EPA Office of Compliance Sector Notebook Project
Profile of the Transportation Equipment Cleaning Industry
September 1995
Office of Compliance
Office of Enforcement and Compliance Assurance
U.S. Environmental Protection Agency
401 M St., SW (MC 2221-A)
Washington, DC 20460
For sale by the U.S. Government Printing Office
Superintendent of Documents, Mail Stop: SSOP, Washington, DC 20402-9328
ISBN 0-16-048285-2
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Sector Notebook Project
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This report is one in a series of volumes published by the U.S. Environmental Protection Agency
(EPA) to provide information of general interest regarding environmental issues associated with
specific industrial sectors. The documents were developed under contract by Abt Associates
(Cambridge, MA), and Booz-Allen & Hamilton, Inc. (McLean, VA). This publication may be
purchased from the Superintendent of Documents, U.S. Government Printing Office. A listing of
available Sector Notebooks and dpcument numbers are included on the following page.
All telephone orders should be directed to:
Superintendent of Documents
U.S. Government Printing Office
Washington, DC 20402
(202) 512-1800
FAX (202) 512-2250
9:00 a.m. to 4:30 p.m., ET, M-F
Using the form provided at the end of this document, all mail orders should be directed to:
U.S. Government Printing Office
P.O. Box 371954
Pittsburgh, PA 15250-7954
Complimentary volumes are available to certain groups or subscribers, such as public and academic
libraries, Federal, State, local, and foreign governments, and the media. For further information, and
for answers to questions pertaining to these documents, please refer to the contact names and
numbers provided within this volume.
Electronic versions of all Sector Notebooks are available on the EPA Enviro$en$e Bulletin Board
and via the internet on the Enviro$en$e World Wide Web. Downloading procedures are described
in Appendix A of this document.
Cover photograph by Steve Delaney, EPA.
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Contacts for Available Sector Notebooks
The Sector Notebooks were developed by the EPA Office of Compliance. Particular questions
regarding the Sector Notebook Project in general can be directed to the EPA Work Assignment
Managers:
Michael Barrette
US EPA Office of Compliance
401 M St., SW (2223-A)
Washington, DC 20460
(202) 564-7019
Gregory Waldrip
US EPA Office of Compliance
401 M St., SW (2223-A)
Washington, DC 20460
(202) 564-7024
Questions and comments regarding the individual documents can be directed to the appropriate
specialists listed below.
Document Number Industry
EPA/310-R-95-001. Dry Cleaning Industry
EPA/310-R-95-002. Electronics and Computer Industry
EPA/310-R-95-003. Wood Furniture and Fixtures Industry
EPA/310-R-95-004. Inorganic Chemical Industry
EPA/310-R-95-005. Iron and Steel Industry
EPA/310-R-95-006. Lumber and Wood Products Industry
EPA/310-R-95-007. Fabricated Metal Products Industry
EPA/310-R-95-008. Metal Mining Industry
EPA/310-R-95-009. Motor Vehicle Assembly Industry
EPA/310-R-95-010. Nonferrous Metals Industry
EPA/310-R-95-011. Non-Fuel, Non-Metal Mining Ind.
EPA/310-R-95-012. Organic Chemical Industry
EPA/310-R-95-013. Petroleum Refining Industry
EPA/310-R-95-014. Printing Industry
EPA/310-R-95-015. Pulp and Paper Industry
EPA/310-R-95-016. Rubber and Plastic Industry
EPA/310-R-95-017. Stone, Clay, Glass and Concrete Ind.
EPA/310-R-95-018. Transportation Equip. Cleaning Ind.
Contact
Joyce Chandler
Steve Hoover
Bob Marshall
Walter DeRieux
Maria Malave
Seth Heminway
Greg Waldrip
Keith Brown
Suzanne Childress
Jane Engert
Keith Brown
Walter DeRieux
Tom Ripp
Ginger Gotliffe
Maria Eisemann
Maria Malave
Scott Throwe
Virginia Lathrop
Phone
564-7073
564-7007
564-7021
564-7067
564-7027
564-7017
564-7024
564-7124
564-7018
564-5021
564-7124
564-7067
564-7003
564-7072
564-7016
564-7027
564-7013
564-7057
A Federal Facilities Profile is under development and will be completed later in 1995
(Contact: Sarah Walsh, 202-260-6118)
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Industry Sector Notebook Contents: Transportation Equipment Cleaning
Exhibits Index iii
List of Acronyms iv
I/INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT 1
A. Summary of the Sector Notebook Project 1
B. Additional Information 2
II. INTRODUCTION TO THE TRANSPORTATION EQUIPMENT CLEANING INDUSTRY .. 3
A. Introduction, Background, and Scope of the Notebook 3
B. Characterization of the Transportation Equipment Cleaning Industry 4
1. Product Characterization -4
2. Industry Size and Geographic Distribution 6
3. Economic Trends 11
III. INDUSTRIAL PROCESS DESCRIPTION 13
A. Industrial Processes in the Transportation Equipment Cleaning Industry 13
1. Tank Interior Cleaning 14
2 Rail Car Refurbishing and Maintenance 15
3. Aircraft Cleaning and Deicing 16
B. Raw Material Inputs and Pollution Outputs 17
1. Tank Cleaning 17
2. Rail Car Refurbishing and Maintenance 21
3. Aircraft Cleaning and Deicing 22
IV. CHEMICAL RELEASE AND TRANSFER PROFILE 23
A. EPA Toxic Release Inventory for the Transportation Equipment Cleaning Industry 23
B. Summary of Selected Chemicals Released 24
C. Other Data Sources 24
V. POLLUTION PREVENTION OPPORTUNITIES 25
VI. SUMMARY OF APPLICABLE FEDERAL STATUTES AND REGULATIONS 29
A. General Description of Major Statutes 29
B. Industry Specific Requirements 40
C. Pending and Proposed Regulatory Requirements 42
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VII. COMPLIANCE AND ENFORCEMENT HISTORY , 45
A. Transportation Equipment Cleaning Industry Compliance History 45
B. Review of Major Legal Actions 45
1. Review of Major Cases 46
2. Supplementary Environmental Projects 46
Vffl. COMPLIANCE ASSURANCE ACTIVITIES AND INITIATIVES 47
A. Sector-related Environmental Programs and Activities 47
B. EPA Voluntary Programs 48
C. Trade Association/Industry Sponsored Activity 50
1. Environmental Programs 50
2. Summary of Trade Associations 52
IX. CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS/BIBLIOGRAPHY .... 59
APPENDIX A A-l
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Exhibits Index
Exhibit 1: Number and Size of Facilities with Tank Cleaning Services 6
Exhibit 2. Primary Location of Facilities Cleaning Tanks and Deicing Aircraft 9
Exhibit 3: Geographic Distribution of Tank and Interior Cleaning Facilities
in the TEC Screener Questionnaire Database 10
Exhibit 4: Tank Volumes Vary Significantly 14
Exhibit 5: Tank Heel and Wastewater Volumes 18
Exhibit 6: Typical Wastewater Treatment System Treating A Wide Range of Contaminants .... 19
Exhibit 7: Typical Oily Wastewater Treatment System 20
Exhibit 8: Hazardous Wastes from Rail Car Refurbishing and Maintenance Operations 21
Exhibit 9: Aircraft Cleaning and/or Deicing Wastewater Treatment 22
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List of Acronyms
AFS - AIRS Facility Subsystem (CAA database)
AIRS - Aerometric Information Retrieval System (CAA database)
BIFs - Boilers and Industrial Furnaces (RCRA)
BOD - Biochemical Oxygen Demand
CAA - Clean Air Act
CAAA - Clean Air Act Amendments of 1990
CERCLA - Comprehensive Environmental Response, Compensation and Liability Act
CERCLIS - CERCLA Information System
CFCs - Chlorofluorocarbons
CO - Carbon Monoxide
COD - Chemical Oxygen Demand
CSI - Common Sense Initiative
CWA -' Clean Water Act
D&B - Dun and Bradstreet Marketing Index
ELP - Environmental Leadership Program
EPA - United States Environmental Protection Agency
EPCRA - Emergency Planning and Community Right-to-Know Act
FIFRA - Federal Insecticide, Fungicide, and Rodenticide Act
FINDS - Facility Indexing System
HAPs - Hazardous Air Pollutants (CAA)
HSDB - Hazardous Substances Data Bank
IDEA - Integrated Data for Enforcement Analysis
LDR - Land Disposal Restrictions (RCRA)
LEPCs- Local Emergency Planning Committees
MACT - Maximum Achievable Control Technology (CAA)
MCLGs - Maximum Contaminant Level Goals
MCLs - Maximum Contaminant Levels
MEK. - Methyl Ethyl Ketone
MSDSs - Material Safety Data Sheets
NAAQS - National Ambient Air Quality Standards (CAA)
NAFTA - North American Free Trade Agreement
NCDB - National Compliance Database (for TSCA, FIFRA, EPCRA)
NCP - National Oil and Hazardous Substances Pollution Contingency Plan
NEIC - National Enforcement Investigation Center
NESHAP - National Emission Standards for Hazardous Air Pollutants
NO2 - Nitrogen Dioxide
NOV - Notice of Violation
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NOX - Nitrogen Oxide
NPDES - National Pollution Discharge Elimination System (CWA)
NPL - National Priorities List
NRC - National Response Center
NSPS - New Source Performance Standards (CAA)
OAR- Office of Air and Radiation
OECA - Office of Enforcement and Compliance Assurance
OPA - Oil Pollution Act
OPPTS - Office of Prevention, Pesticides, and Toxic Substances
OSHA - Occupational Safety and Health Administration
OS W - Office of Solid Waste
OS WER - Office of Solid Waste and Emergency Response
OW- Office of Water
P2 - Pollution Prevention
PCS - Permit Compliance System (CWA Database)
POTW - Publicly Owned Treatments Works
RCRA - Resource Conservation and Recovery Act
RCRIS - RCRA Information System
SARA - Superfund Amendments and Reauthorization Act
SDWA - Safe Drinking Water Act
SEPs - Supplementary Environmental Projects
SERCs - State Emergency Response Commissions
SIC - Standard Industrial Classification
SO2 - Sulfur Dioxide
SOX - Sulfur Oxides
TOC - Total Organic Carbon
TRI - Toxic Release Inventory
TRIS - Toxic Release Inventory System
TCRIS - Toxic Chemical Release Inventory System
TECI - Transportation Equipment Cleaning Industry
TSCA - Toxic Substances Control Act
TSS - Total Suspended Solids
UIC - Underground Injection Control (SDWA)
UST - Underground Storage Tanks (RCRA)
VOCs - Volatile Organic Compounds
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I. INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT
I.A. Summary of the Sector Notebook Project
Environmental policies based upon comprehensive analysis of air, water and
land pollution (such as economic sector, and community-based approaches)
are becoming an important supplement to traditional single-media
approaches to environmental protection. Environmental regulatory agencies
are beginning to embrace comprehensive, multi-statute solutions to facility
permitting, compliance assurance, education/outreach, research, and
regulatory development issues. The central concepts driving the new policy
direction are that pollutant releases to each environmental medium (air, water
and land) affect each other, and that environmental strategies must actively
identify and address these inter-relationships by designing policies for the
"whole" facility. One way to achieve a whole facility focus is to design
environmental policies for similar industrial facilities. By doing so,
environmental concerns that are common to the manufacturing of similar
products can be addressed in a comprehensive manner. The desire to move
forward with this "sector-based" approach within the EPA Office of
Compliance led to the creation of this document.
The Sector Notebook Project was initiated by the Office of Compliance to
provide its staff and managers with summary information for eighteen
specific industrial sectors. As other EPA offices, states, the regulated
community, and the public became interested in this project, the Office of
Compliance expanded the scope of the original project. The ability to design
comprehensive, common sense environmental protection measures for
specific industries is dependent on knowledge of several inter-related topics.
For the purposes of this project, the key elements chosen for inclusion are:
general industry information (economic and geographic); a description of
industrial processes; pollution outputs; pollution prevention opportunities;
Federal statutory and regulatory framework; compliance history; and a
description of partnerships that have been formed between regulatory
agencies, the regulated community and the public.
For any given industry, each topic listed above could alone be the subject of
a lengthy volume. However, in order to produce a manageable document,
this project focuses on providing summary information for each topic. This
format provides the reader with a synopsis of each issue, and references
where more in-depth information is desired. Text within each profile was
researched from a variety of sources, and was usually condensed from more
detailed sources pertaining to specific topics. This approach allows for a
wide coverage of activities that can be further explored based upon the
references listed at the end of this profile. As a check on the information
included, each notebook went through an external document review process.
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The Office of Compliance appreciates the efforts of all those that participated
in this process and enabled us to develop more complete, accurate and up-to-
date summaries. Many of those who reviewed this notebook are listed as
contacts in Section DC and may be sources of additional information. The
individuals and groups on this list do not necessarily concur with all
statements within this notebook.
I.B. Additional Information
Providing Comments
The Office of Compliance plans to periodically review and update notebooks
and will make these updates available both in hard copy and electronically.
If you have any comments on the existing notebook, or if you would like to
provide additional information, please send a hard copy and computer disk
to the EPA Office of Compliance, Sector Notebook Project, 401 M St., SW
(2223-A), Washington, DC 20460. Comments can also be uploaded to the
Enviro$en$e Bulletin Board or the Enviro$en$e World Wide Web for general
access to all users of the system. Follow instructions in Appendix A for
accessing these data systems. Once you have logged in, procedures for
uploading text are available from the on-line Enviro$en$e Help System.
Adapting Notebooks to Particular Needs
The scope of the existing notebooks reflect an approximation of the relative
national occurrence of facility types that occur within each sector. In many
instances, industries within specific geographic regions or states may have
unique characteristics that are not fully captured in these profiles. For this
reason, the Office of Compliance encourages state and local environmental
agencies and other groups to supplement or re-package the information
included in this notebook to include more specific industrial and regulatory
information that may be available. Additionally, interested states may want
to supplement the "Summary of Applicable Federal Statutes and
Regulations" section with state and local requirements. Compliance or
technical assistance providers may also want to develop the "Pollution
Prevention" section in more detail. Please contact the appropriate specialist
listed on the opening page of this notebook if your office is interested in
assisting us in the further development of the information or policies
addressed within this volume.
If you are interested in assisting in the development of new notebooks for
sectors not covered in the original eighteen, please contact the Office of
Compliance at 202-564-2395.
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H. INTRODUCTION TO THE TRANSPORTATION EQUIPMENT CLEANING INDUSTRY
This section provides background information on the size, geographic
distribution, employment, production, sales, and economic condition of the
transportation equipment cleaning industry. The type of facilities described
within most of the notebooks are also described in terms of their Standard
Industrial Classification (SIC) codes. The transportation equipment cleaning
sector, however, is not classified under the SIC system and therefore, does
not have a designated SIC code number.
The Office of Water (OW) currently has the most extensive amount of data
on tank interior cleaning. OW has done over 35 site visits and has performed
wastewater sampling at 18 TEC facilities. The site visit reports are available
and sampling data are available for all but four facilities. OW has also
administered a screener questionnaire (3,240 potential TEC facilities) and a
detailed questionnaire to the industry. The detailed questionnaire was mailed
in April 1995 to 275 facilities. At the time that this document went to print,
results were being received and entered into a database for analysis by EPA.
Information is being collected on the following: TEC operations, cargos
cleaned out of the tanks and containers, cleaning solutions used, types and
sizes of tanks and containers cleaned, wastewater treatment technologies
employed by the facility, wastewater sampling data, pollution prevention
activities, water conservation activities, air emissions data and air emissions
controls, solid waste and heels generation and disposal, and revenues, assets,
liabilities, operating and maintenance costs, and employees. All of the data
from these two questionnaires will be used to develop survey weights from
which to determine the total population characteristics for tank cleaning
facilities in the U.S.
II.A. Introduction, Background, and Scope of the Notebook
Because there are no SIC codes that apply only to transportation equipment
cleaning, the use of SIC codes to identify the characteristics of these facilities
is not possible. A large number of industries with many different SIC codes
carry out transportation equipment cleaning activities. For example,
transportation equipment cleaning facilities can be located within the
petroleum refining industry (SIC 2911) and the marine cargo handling sector
of the transportation industry (SIC 4491). Although facilities within both
industries clean transportation equipment, the petroleum refining industry
predominantly refines crude oil to petroleum products and the marine cargo
handling industry by SIC code predominantly loads and unloads cargo from
ships and barges. Furthermore, trade associations are also unable to
adequately characterize the industry. Facilities providing transportation
equipment cleaning services usually provide numerous other services all of
which are of concern to the trade associations, and those associations that
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represent transportation equipment cleaners do not exclusively represent
these facilities.
H.B. Characterization of the Transportation Equipment Cleaning Industry
II.B.l. Product Characterization
The transportation industry moves people and materials between
predetermined points using four principal transportation modes: truck, train,
vessel, and airplane. Almost all materials and goods in the U.S. are
distributed by one of these four modes. Pipelines for crude oil and refined
petroleum products are one significant exception. Delivery to pipelines and
local distribution from pipelines, however, is by truck, train or vessel. The
majority of domestic cargo is bulk freight transported in tank trucks, rail tank
cars, and ocean/sea tankers. It is estimated that over 700 different
commodities are transported in this manner throughout the U.S., including:
petroleum products, coal, organic chemicals, inorganic chemicals,
compressed gases, fertilizers, pesticides, food products, paints, inks, glues,
and soaps. The transportation equipment cleaning industry (TECI) is a
service industry for the cleaning of the interiors of trucks, rail cars, and
barges, intermodal tank containers, and intermediate tank containers, and the
exterior of aircraft. An important segment of this industry, in terms of wastes
generated, deals with the cleaning of tank interiors. In the past, the deicing
of aircraft and runways has also been regarded by EPA as part of the
transportation equipment cleaning industry. It is important to note that the
industry as it is described above, and throughout this notebook, is not meant
to reflect the industry as it is defined in a transportation equipment cleaning
rule being developed by the Office of Water.
Most truck, barge and ship tanks are in dedicated service (i.e., carries one
commodity only), however, a significant number are non-dedicated and must
be cleaned after every trip to prevent contamination of materials from one
cargo to the next. A recent incident underscoring the importance of proper
tank cleaning resulted in over 400 cases of salmonella poisoning. Tank
trucks carrying raw eggs were not adequately cleaned before carrying ice
cream mix which was subsequently made into ice cream without additional
pasteurization. Truck, barge and ship tanks also must be cleaned prior to
inspections and repairs. Almost all rail tank cars are in dedicated service
and, therefore, are only cleaned prior to inspection, repairs and refurbishing.
Rail car refurbishing operations, in part, involve the disassembly and
cleaning of parts using a number of different cleaning methods prior to
reassembly. Aircraft exteriors are cleaned for a variety of reasons including:
aesthetics; as part of a routine inspection and maintenance program; and to
facilitate repairs. Aircraft deicing is conducted to remove ice from aircraft
wings and other areas that may adversely affect the operation of the aircraft.
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intermodal tank containers and intermediate bulk containers (IBCs) or "totes"
are transportable containers that can be transferred between trucks, barges,
ships and rail cars. They are used to transport liquid, solid or gaseous
materials. Intermodal tank containers typically hold between 6,000 - 9,000
gallons and are considerably larger than IBCs which are typically between
500 and 800 gallons.
Between 1973 and 1974 a study was conducted by EPA's Industrial
Environmental Research Laboratory assessing the environmental impact of
air emissions and water pollutants from cleaning rail tank cars, tank trucks,
and drums. This initial study found air emissions and wastewater discharges
from these operations to be relatively low. Therefore, no regulations were
proposed for tank and drum cleaning facilities at that time. A preliminary
study conducted in 1985 by EPA's Office of Water examined the wastewater
generated by the transportation equipment cleaning industry (which did not
include aircraft deicing) to determine whether regulations should be
developed for the industry pursuant to the Clean Water Act. As a result of
the study, EPA decided to develop effluent guidelines (wastewater
regulations) for the TECI. As part of the consent decree with NRDC in
January 1992, EPA is under a court-ordered deadline, however, to propose
and promulgate effluent guidelines for the industry's wastewater (including
aircraft deicing) by the end of 1996 and 1998, respectively. The Office of
Water is currently collecting more extensive and up-to-date industry data,
through mandatory surveys (CWA §308), site visits to facilities, and
sampling, which will be used as a basis for developing the effluent
limitations guidelines. Effluent limitation guidelines for aircraft cleaning and
deicing will be developed separately, after additional studies specific to
aircraft deicing can be conducted.
For the development of the TECI effluent guidelines, in 1993, EPA Office of
Water administered about 3,240 screener questionnaires to potential tank
interior cleaning facilities. The results of this screener questionnaire and the
development of the survey weights will be used to estimate the number and
types of facilities in the scope of the industry. From the screener
questionnaire, approximately 740 TECI facilities were identified. Some
preliminary results, before the development of the survey weights, are
presented below. It is important to note that this data may change
significantly depending on the survey weights used. In addition to the
screener questionnaire, EPA has sent out approximately 300 detailed
questionnaires to obtain information relating to transportation equipment
cleaning activities, wastewater treatment technology efficiencies, wastewater
treatment technology costs, and various financial and economic data.
Based on the 1993 screener questionnaire, EPA estimates that about 2,729
facilities providing tank interior cleaning services will be affected by the
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wastewater effluent guidelines. Transportation equipment cleaning facilities
are often part of much larger manufacturing, maintenance, depot, or terminal
facilities. For this reason economic and pollutant release data specific to
transportation equipment cleaning operations is not readily available.
H.B.2. Industry Size and Geographic Distribution
Based on the results of 3,240 EPA screener questionnaires sent out to
potential transportation tank interior cleaning facilities, initial estimates of
the total number of facilities actually conducting tank interior cleaning
activities is approximately 2,729 (before scale-up analysis based on survey
weights) (Exhibit 1). The number of aircraft exterior cleaning and/or
deicing facilities has not yet been determined. Aircraft cleaning and deicing
facilities are expected to approximate the number of commercial airports in
the U.S. because almost all airports conduct cleaning and/or deicing
activities.
Exhibit 1: Number and Size of Facilities with Tank Cleaning Services
Type of Tank
Truck, Land1
Rail, Intermodal Tank Carrier,
Intermediate Bulk Container
Barge
Land-Water2
Tanker, Water3
Combination Facilities
Total
Number
of Facilities
1,841
809
49
16
14
162
2,891
Source: Based on U.S. EPA Office of Water, Engineering Analysis Division, screener
questionnaire data before scale-up, 1994.
1 Land facilities are those that clean any combination of the following equipment: tank trucks, rail
tank cars, intermediate bulk containers, intermodal tank containers.
2 Land-water facilities are those that clean a combination of the following types of equipment with
no one type of equipment predominating: tank trucks, rail tank cars, intermediate bulk containers,
intermodal tank carriers, tank barges, and ocean sea tankers.
3 Water facilities are those that perform cleaning of both tank barges and ocean/sea tankers with
neither type of equipment predominating.
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The characteristics of transportation equipment cleaning facilities differ
significantly among the various modes of transportation and the forms of
ownership. There are four types of facility ownership: independent
owner/operators, carriers, builders/leasers, and shippers.
Independent Owner/Operators
Independent owner/operators make up about 33 percent of transportation
equipment cleaning (not including aircraft cleaning/deicing) facilities.
Independent owner/operators are typically "for-hire" facilities which provide
services to any users for a fee. Such facilities are found in all modes of
transportation, however, they are most common in the trucking sector of the
industry and least common in the aircraft cleaning and deicing sector.
Independently owned and operated facilities are much more likely to be
dedicated to only tank cleaning than carrier, shipper, and builder/leaser
owned facilities which usually provide other services (i.e., depots, repairs,
maintenance, fuel, etc.) to their users.
Carrier Owned Facilities
Carrier facilities make up about 27 percent of transportation equipment
cleaning facilities. Such facilities are owned and operated by transporting
companies and provide services to their own vehicles. Carrier operated
facilities are usually located at shipping and receiving terminals and provide
maintenance and repair services as well as tank cleaning. Many carrier
facilities also operate as "for-hire" facilities to outside transporters. Carrier
owned facilities are found in all transportation modes and are the most
common form of ownership for rail tank car and tank truck cleaning
facilities. In the aircraft sector, cleaning and deicing is almost exclusively
carried out by the carrier companies.
Shipper Owned Facilities
Shipper facilities make up about 20 percent of transportation equipment
cleaning facilities and are owned by large manufacturing companies (i.e.,
petroleum and chemical companies) that ship their own or other companies'
products and clean and repair their own equipment. Shipper operated
facilities are typically located at the manufacturer's shipping and receiving
terminals. The facilities provide maintenance and repair services as well as
tank cleaning. Some shipper facilities also operate as "for-hire" facilities to
outside transporters. Shipper owned facilities are found in the rail, and
barges sectors, however, they are most common in the trucking sector.
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Builder/Leaser Owned Facilities
Builder/leaser facilities are owned by those transportation equipment
manufacturers (i.e., rail car manufacturers and leasers, barge manufacturers
and leasers, etc.) and leasing companies that also provide repairs and
cleaning services for the equipment that they sell or lease. Such facilities
make up about six percent of transportation equipment cleaning facilities.
Some builder/leaser facilities also operate as "for-hire" facilities to outside
transporters. Equipment cleaning services provided by builders/leasers are
usually part of an inspection, maintenance and repair facility. Builder/leaser
tank cleaning facilities are found in the barges and trucks sectors, however,
they are most common in the rail transport sector. Another 14 percent of
transportation equipment cleaning facilities are combinations of two or more
of the four types ownership described above.
The distribution of transportation equipment cleaning facilities across the
U.S. varies depending on the mode of transportation. Tank truck cleaning
facilities are concentrated in five major petrochemical and manufacturing
regions, and population centers of the U.S.: 1) 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. Rail tank cleaning facilities are located
primarily in the industrialized central, south central and eastern regions of the
U.S. Tank barge cleaners are located predominantly along the Gulf Coast
and along the Mississippi River and its tributaries (Exhibit 2). Aircraft
cleaning and deicing operations are carried out at most airports and,
therefore, follow population distributions closely with deicing facilities more
common and used more frequently in the northern regions (Exhibit 2).
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Exhibit 2. Primary Location of Facilities Cleaning Tanks
and Deicing Aircraft
Tank Type
Tank Truck
Rail Tank Car
Barge/Tanker
Aircraft Cleaning/Deicing
Primary Areas of Operation
California; Texas-Louisiana Gulf coast;
Mississippi, Missouri, and Ohio Rivers;
Southern Lake Michigan, Lake Erie, and Lake
Huron; eastern Pennsylvania and New Jersey
Industrialized central, south central and eastern
regions
Gulf Coast and along the Mississippi River and
its tributaries
Follows population distributions with deicing
facilities more common in the northern regions
Source: U.S. EPA Office of Water, Engineering Analysis Division, 1994.
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II.B.3 Economic Trends
The economic health of the transportation equipment cleaning industry is
highly dependent on the health of the industries it serves. The railroads,
trucking, and water transportation sectors are expected to have modest
growth in the next few years as the economy continues to grow. The North
American Free Trade Agreement (NAFTA) is also expected to have a
positive impact on the industry by increasing international freight traffic,
especially between the U.S. and Mexico.
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III. INDUSTRIAL PROCESS DESCRIPTION
This section describes the major industrial processes within the transportation
equipment cleaning industry, including the materials and equipment used,
and the processes employed. The section is designed for those interested in
gaining a general understanding of the industry, and for those interested in
the inter-relationship between the industrial process and the topics described
in subsequent sections of this profile -- pollutant outputs, pollution
prevention opportunities, and Federal regulations. This section does not
attempt to replicate published engineering information that is available for
this industry. Refer to Section IX for a list of reference documents that are
available.
This section specifically contains a description of commonly used production
processes, associated raw materials, the byproducts produced or released, and
the materials either recycled or transferred off-site. This discussion, coupled
with schematic drawings of the identified processes, provide a concise
description of where wastes may be produced in the process. This section
also describes the potential fate (via air, water, and soil pathways) of these
waste products.
III.A. Industrial Processes in the Transportation Equipment Cleaning Industry
Tank trucks, rail tank cars, barges, tankers, IBCs, and intermodal tank
containers all differ significantly in volume (Exhibit 4). In addition, the
configuration, mean distances traveled, and types of materials transported
vary among the various container types. Therefore, the volumes of water
used, the types of wastes generated, and the cleaning time can vary widely
depending on the mode of transport. The basic steps of the tank cleaning
process, however, do not vary substantially regardless of the transportation
mode or type of container. The process used can differ significantly
depending on the residues to be cleaned and the extent to which a tank needs
to be cleaned prior to reuse. Exterior cleaning of rail cars and aircraft
cleaning and deicing differ considerably from tank cleaning in both method
and wastes generated and are described separately below. Pollutant outputs
from each of the processes is described in Section III.C.
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Exhibit 4: Tank Volumes Vary Significantly
Type of Tank
Tank Truck
Rail Tank Car
Barge
Ocean/Sea Tanker
Intermodal Tank Container
Intermediate Bulk Container
Typical Volume in Gallons
3,500-8,000
20,000-30,000
420,000-1,470,000
3-147 million
2,500-10,000
500-800
Source: American Waterways Operators Fact Sheet, 1994, and U.S. EPA Office of Water,
Engineering Analysis Division.
III.A.l. Tank Interior Cleaning
Most tank cleaning facilities will handle all types of tank residues. Some
facilities, however, will not accept certain residues (i.e., highly odorous
residues or materials not compatible with the on-site wastewater treatment
system), and others will only accept certain types of tank residues (i.e.,
petroleum products or food grade products). Regardless of the type of tank
or last cargo transported, the following tank cleaning procedures are typically
carried out at tank cleaning facilities.
shipping papers are checked to identify the cargo last carried;
next cargo is determined, if possible;
residual cargo heel is removed and segregated for off-site disposal;
tank is rinsed;
tank is washed;
tank is rinsed; and
tank is dried.
Identification of the last cargo carried is necessary to determine the
appropriate level of health protection for those employees cleaning the tank
and to determine the appropriate cleaning method and materials, hi addition,
it is important to understand the characteristics of the wastewater that will be
generated in order to determine the appropriate treatment or disposal method.
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Determination of the next cargo to be transported is useful for deciding the
level of cleaning that is needed. Certain cargos, such as foods and highly
pure chemicals, will require a much cleaner container than most cargos.
Before beginning the rinsing and washing of the tank, any residual cargo, or
heel, must be removed and segregated. Heels can be removed using the
vehicle's own cargo transfer piping, pumps supplied by the cleaning facility,
or manually. Heel volumes vary significantly between modes of transport
(Exhibit 5). In barges and ships, volumes can be relatively large and their
removal, called "stripping," is often carried out using a built-in vessel
stripping system. Stripping of heels from barges and ships can be facilitated
by pumping ballast water into some of the tank compartments to tilt the
vessel.
Washing, rinsing and drying methods vary depending on the facility's
equipment, the last cargo carried, and the next cargo to be carried. Some
cargos may require only a water rinse, and other cargoes may require a series
of washing and rinsing cycles using different wash solutions. Washing
solution may consist of: detergent solution, caustic solution, organic solvents,
or steam. Tanks can be rinsed with hot or cold water, and drying can be
passive or with forced air.
Washing is performed either manually with hand held sprayers, or
automatically with high pressure spinner nozzles or "butterworths." Any
wash solution can be used with either method, however, worker safety is a
concern when manually spraying solvent and caustic wash solutions. High
pressure spinner nozzles are inserted through the main tank hatch, and wash
solution and rinse water is automatically sprayed onto the tank surface at
100-600 psi while rotating around vertical and horizontal axes. Some
facilities have the capability to recycle washing solutions within a closed
system and periodically change to fresh wash solution. Wastewater is then
either treated in the facility wastewater treatment system, discharged to a
publicly-owned treatment works (POTW) via a sewer system, discharged
directly to surface waters, or piped to an underground injection well.
Hazardous wastewater is disposed of off-site or treated separately on-site.
»
III.A.2 Rail Car Refurbishing and Maintenance
The processes used to clean rail car (tank and freight) interiors and exteriors
prior to repairs and refurbishing, and to clean certain parts during repairs and
refurbishing, are significantly different from those used to clean tank
interiors. At a typical rail car refurbishing or maintenance facility, the initial
cleaning of the cars involves two steps: a mechanical cleaning and water
wash. Both steps remove dirt and other residues prior to removal of the
damaged parts and systems to be replaced. Mechanical cleaning consists of
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the physical shaking and vibrating of the rail cars to loosen dirt and debris.
Dirt and debris may fall through a steel grate in the floor and are
intermittently collected for disposal. The wash step consists of a high
pressure water cleaning, collection of wastewater, and treatment at an on-site
wastewater treatment facility. Refurbishing operations usually start with
paint removal using a steel grit blast system or other methods. The paint
chips and grit are typically collected through a steel grate in the floor and the
mixture is conveyed to a cyclone and filter system for separation of reusable
grit and paint. Next, the cars are disassembled and wheel sets and air brakes
are rebuilt. Axles from wheel sets that can be reused are first washed in a
caustic solution to remove grease and dirt. External debris is removed from
the air brakes using a grit or bead blast system or other methods. The brakes
are then disassembled and cleaned with solvents or caustic solutions.
Finally, the cars are reassembled and repainted using spray guns.
Maintenance and repair operations consist of disassembly, cleaning, and
repair; or the disassembly and replacement, of damaged parts. Parts cleaning
may include the removal of paints, cleaning with solvents or caustics, and
repainting.
III.A.3. Aircraft Cleaning and Deicing
Aircraft cleaning is carried out using hand held spray nozzles, hoses and
brushes. Exterior cleaning typically consists of washing with detergent
solutions and a water rinse. For large aircraft, wet cleaning is usually limited
to wheel wells and landing gear and is conducted to facilitate inspections. It
is more economical to dry polish aircraft fuselages rather than wash them
with water and cleaning solutions. Aircraft deicing is carried out at the gate
area and occasionally additional deicer is applied just prior to take-off while
the aircraft is on the runway. Airport runways and gate areas are also
sprayed with deicer to prevent the build-up of ice and snow. Deicers are
usually one, or a mixture of two or more, of: ethylene glycol, urea, potassium
acetate, and sand (for runway deicing only). Some airports are using or
planning remote deicing areas away from the gate areas. Remote deicing
areas facilitate collection to deicing fluids for reuse, recycling, and treatment.
Deicing is almost exclusively performed using hand held nozzles and hoses.
However, automatic deicer spray machines, called "deicing gantries," have
been developed in recent years. Deicing gantries are large structures holding
numerous spray nozzles which pass over the aircraft spraying deicer. The
deicing gantries are computer controlled and, depending on the type of
aircraft, spray specific amounts of deicer over particular areas with very little
wasted material.
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III.B. Raw Material Inputs and Pollution Outputs
III.B.1. Tank Cleaning
Tank Heels
The primary pollutant output of tank cleaning operations is wastewater
contaminated with tank residues and cleaning solutions. More specifically,
outputs include: spent cleaning fluids, fugitive volatile organic compound
(VOC) emissions, water treatment system sludges, and tank residues. The
quantities of these outputs will vary widely from facility to facility depending
on the mode of transport, types of cargoes, and cleaning methods. For
example, an independent owner/operator tank truck cleaning facility serving
a large number of different users will generate a much greater volume of
wastewater containing many more different contaminants, than a shipper
operated facility serving fewer trucks all carrying the same cargo.
Tank heels volumes vary substantially depending on the size and
configuration of the tank, and on the nature of the last cargo carried (Exhibit
5). Disposal and treatment of tank heels can pose a problem for tank
cleaning facilities. Tank heels of hazardous waste greater than 0.3 percent
by weight of the tank capacity continue to be regulated by RCRA after the
discharge of the waste at a TSDF. Under these regulations, the use of
solvents (including water) could be viewed as treatment, and therefore, may
not be allowed to remove these heels. Under such conditions, the only means
available to remove the heels may be manually (e.g., scooping, shoveling,
scraping) A facility's wastewater treatment system may be adversely affected
by, and may not adequately treat, a slug of concentrated tank residue. In
addition, the heel material may be inconsistent with the facility's wastewater
discharge permit. Water soluble heels that are compatible with the facility's
treatment system and the conditions of its wastewater discharge permit are
sometimes combined with other wastewaters for treatment and disposal.
Incompatible heels are typically segregated and, depending on the volumes
generated at the facility and the value of product, the heel can be either sold
back to a reclaimer or shipped off-site for disposal. The resale of tank heels
is more common at facilities that generate large volumes of a small number
of products, as is often the case at tank barge cleaning facilities. Heels that
are comprised of detergents, solvents, acids, or alkalis can be stored on-site
and used as a tank cleaning fluid or to neutralize other tank heels.
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Exhibit 5: Tank Heel and Wastewater Volumes
Type of Tank
Tank Truck
Rail Tank Car
Tank Barge
Typical Heel Volume
(gallons/tank)
5-10
10-30
5-500
Estimated Average
Wastewater Generated
(gallons/tank)
500-1,000
3,000-5,000
10,000-12,000
Source: EPA Office of Water and Preliminary Data Summary for the Transportation
Equipment Cleaning Industry, U.S. EPA, 1989 and EPA Office of Water, Engineering
Analysis Division 1995.
Wastewater
The primary source of wastewater from equipment cleaning facilities is from
the cleaning of tank interiors. Relatively small amounts of wastewater are
generated from exterior washing of vehicles. Wastewater volumes and
characteristics vary depending on the last cargo transported, the cleaning
solution used, the tank size, and the presence of caked, solidified, or
crystallized residues. The volumes of wastewater generated per tank
cleaning will vary substantially depending on the cleaning solution, the
residues present and the degree of cleanliness needed. For example, the
cleaning of a tank coated with a viscous, water insoluble residue will require
more washing and rinsing time than a tank that last carried a water soluble
material. In addition, washing with a detergent solution will, in general,
generate more wastewater than a steam wash (Exhibit 5).
Washing and rinsing wastewater compatible with facility treatment systems
or discharge permits is pumped or drained from the tank or recycling system
to wastewater storage tanks. Cleaning solutions that are not compatible with
the treatment systems or discharge permits, such as solvent washing
solutions, are stored in drums for off-site disposal.
Information on the types and extent of wastewater treatment at transportation
equipment cleaning facilities is limited. EPA's Office of Water has
information on wastewater treatment at 700 facilities. Each wastewater
treatment plant is designed for certain types of wastewater and to meet the
requirements of a downstream treatment works and/or a National Pollutant
Discharge Elimination System (NPDES) permit. Approximately 90 percent
of transportation equipment cleaning facilities discharge wastewater to
POTWs or combined treatment works (privately owned by multiple facilities)
after some amount of treatment. Some facilities discharge directly to surface
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WASTEWATER
(WIDE RANGE OF
CONTAMINANTS)
EQUALIZATION TANK
pH ADJUSTMENT
BIOLOGICAL TREATMENT
PRIMARY CLARIFICATION
SECONDARY
CLARIFICATION
BAG OR SAND
FILTRATION
SLUDGE
DISCHARGE TO POTW
SURFACE WATER, OR
UNDERGROUND
INJECTION
FILTRATE
DEWATERED SLUDGE TO
OFF-SITE DISPOSAL
SLUDGE DEWATERING
Exhibit 6: Typical Wastewater Treatment System Treating
A Wide Range of Contaminants
waters under NPDES permits or to underground injection wells under Safe
Drinking Water Act Permits. Wastewater treatment, therefore, ranges from
no treatment to a simple settling tank for removal of suspended solids and oil
and grease, to elaborate treatment systems to remove biological oxygen
demand, and metals. Most facilities rely on physical-chemical treatment
methods rather than biological treatment, however, biological treatment
methods are becoming more and more common. Wastewater treatment
systems that treat a wide range of contaminants will, in general, be more
complex. A typical system could consist of pH adjustment, an equalization
or aerated equalization tank, primary clarification, activated sludge,
secondary clarification, and bag or sand filtration. Sludges are dewatered
and shipped off-site for disposal (Exhibit 6). Typical wastewater treatment
for facilities that primarily treat oily wastes may consist of a holding or
equalization tank, gravitational oil water separation, bag or sand filtration,
and coalescing filtration. Sludges are then removed from the equalization
tank, oil-water separator, and bag or sand filters; and disposed of off-site
(Exhibit 7). To reduce the volume of hazardous waste generated, some
facilities dewater sludges in a sludge press prior to disposal off-site. The
water generated is typically recycled back to the equalization tank, hi
addition, some facilities with very stringent local limits have such advanced
treatment as carbon absorption with steam or air stripping for removal of
organic chemicals.
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EQUALIZATION TANK
OIL-WATER SEPARATION
OILY WASTEWATEH ,.
DISCHARGE TO POTW
SURFACE WATER, OR
UNDERGROUND
INJECTION
.; DEWATERED SLUDGE TO OFF-SITE DISPOSAL
Exhibit 7: Typical Oily Wastewater Treatment System
Air Emissions
Air emissions from transportation equipment cleaning facilities arise from
fugitive emissions through tank hatches of VOCs from the tank heels and
residues, from solvent cleaning solutions, and from wastewater treatment
facility tanks. Closed, recycled washing systems for tank trucks, tank cars,
and barges, have very low air emissions. Emissions of VOCs are higher in
the case of manual cleaning methods. The specific VOCs emitted will
depend on the cargo last carried and the cleaning solution used. A source
assessment study for rail tank car, tank truck and drum cleaning conducted
in 1973 and 1974 by the U.S. EPA Industrial Environmental Research
Laboratory found that air emissions from rail car and tank truck cleaning are
relatively low.
Residual Waste
Residual wastes are generated as sludges from residues removed from the
inside of tanks and from wastewater treatment systems. Sludges are typically
drummed and shipped off-site as hazardous wastes. Sludge from a primary
clarifier at a truck tank cleaning facility was analyzed for the 1989
preliminary study of transportation equipment cleaning facilities. The sludge
was found to be RCRA hazardous due to high concentrations of organic
compounds and metals.
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III.B.2. Rail Car Refurbishing and Maintenance
Pollutant outputs from the rail car refurbishing and maintenance sector are
generally in the form of wastewater from preliminary cleaning of interiors
and exteriors and hazardous wastes generated from painting, paint removal,
and cleaning of parts. Typical hazardous wastes generated include: spent
solvents and solvent sludges from solvent cleaning operations; spent caustics
and caustic sludges from caustic washing operations; paint chips; and paint
sludges (Exhibit 8). VOC air emissions are also generated during the use of
solvents and paints. Wastewater from preliminary cleaning of the rail cars
and spent caustic solution is treated in an on-site wastewater treatment
system and then discharged to a POTW. Hazardous wastes are typically
drummed and shipped off-site as RCRA hazardous waste. Spent solvents,
however, can be sent off-site for reclaiming.
Exhibit 8: Hazardous Wastes from Rail Car Refurbishing and
Maintenance Operations
Typical Process/
Operation
Oil and grease
removal
Engine, parts and
equipment
cleaning
Rust removal
Paint preparation
Painting
Spray booth, spray
guns, and brush
cleaning
Paint removal
Typical Materials Used
Degreasers, carburetor cleaners,
engine cleaners, varsol, solvents,
acids/alkalies
Degreasers, carburetor cleaners,
engine cleaners, solvents,
acids/alkalies, cleaning fluids
naval jelly, strong acids, strong
alkalies
paint thinners, enamel reducers,
white spirits
enamels, lacquers, epoxys,
alkyds, acrylics, primers
paint thinners, enamel reducers,
solvents, white spirits
solvents, paint thinners, enamel
reducers, white spirits
Types of Waste
Generated
ignitable wastes, spent solvents,
combustible solids, waste
acid/alkaline solutions
ignitable wastes, spent solvents,
combustible solids, waste
acid/alkaline solutions
waste acids, waste alkalies
spent solvents, ignitable wastes,
ignitable paint wastes, paint wastes
with heavy metals
ignitable paint wastes, spent
solvents, paint wastes with heavy
metals, ignitable wastes
ignitable paint wastes, heavy metal
paint wastes, spent solvents
ignitable paint wastes, heavy metal
paint wastes, spent solvents
Source: U.S. EPA Office of Solid Waste, 1993.
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III.B.3. Aircraft Cleaning and Deicing
The primary pollutant output from aircraft cleaning and deicing is wastewater
from the cleaning of aircraft exteriors and spent deicer from deicing
operations. Wastewater from cleaning operations usually drains to catch
basins and is mixed with other airport wastewater and treated in an on-site
treatment facility. Water use in cleaning is estimated to be approximately
2,000 gallons per aircraft. Analysis of wash water from one cleaning
operation showed only a few organic pollutants at relatively low levels and
high concentrations of metals. The source of the metals was thought to be
from the many special alloys used hi aircraft manufacturing.
Deicing operations generate waste deicer fluids that drain from the aircraft
surfaces or from the runway surfaces to storm drains. The deicing fluids are
often mixed with storm water runoff and then either treated in the facility
wastewater treatment system or discharged directly to surface waters (Exhibit
9). Deicing fluid can also be released directly to the environment through
runoff to surface waters or infiltration to groundwater. Some airports have
constructed deicing fluid collection systems which segregate used deicer
from other wastewater for reuse, recycling, on-site treatment or disposal off-
site.
CATCH BASIN
I
SLOPED WASH
OR DEICE
AREA
WAS?EWATER\ EFFLUENT TO POTW
TREATMENT
SYSTEM , OR SURFACE WATER
OTHER WASTEWATER
Exhibit 9: Aircraft Cleaning and/or Deicing Wastewater Treatment
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IV. CHEMICAL RELEASE AND TRANSFER PROFILE
This section is designed to provide background information on the pollutant
releases that are reported by this industry. The best source of comparative
pollutant release information is the Toxic Release Inventory System (TRI).
Pursuant to the Emergency Planning and Community Right-to-Know Act,
TRI includes self-reported facility release and transfer data for over 600 toxic
chemicals. Facilities within SIC Codes 20 through 39 (manufacturing
industries) that have more than ten employees, and that are above weight-
based reporting thresholds are required to report TRI on-site releases and off-
site transfers. The transportation equipment cleaning industry, therefore, is
not required to report to TRI and no TRI data for the industry is presented in
this sector notebook.
Although this sector notebook does not present historical information
regarding TRI chemical releases over time, please note that in general, toxic
chemical releases have been declining. In fact,, according to the 1993 Toxic
Release Inventory Data Book, reported releases dropped by 43 percent
between 1988 and 1993. Although on-site releases have decreased, the total
amount of reported toxic waste has not declined because the amount of toxic
chemicals transferred off-site has increased. Transfers have increased from
3.7 billion pounds in 1991 to 4.7 billion pounds in 1993. Better management
practices have led to increases in off-site transfers of toxic chemicals for
recycling. More detailed information can be obtained from EPA's annual
Toxics Release Inventory Public Data Release book (which is available
through the EPCRA Hotline at 800-535-0202), or directly from the Toxic
Release Inventory System database (for user support call 202-260-1531).
IV.A. EPA Toxic Release Inventory for the Transportation Equipment Cleaning Industry
Information on the amounts and types of toxic chemicals released and
transferred from facilities conducting transportation equipment cleaning
operations is extremely limited. Transportation equipment cleaning facilities
are not required to report to the Toxic Release Inventory (TRI) under
Emergency Planning and Community Right-to-Know Act (EPCRA) Section
313. Although many large manufacturing facilities (which do report to the
TRI) carry out transportation equipment cleaning activities, it is impossible
to determine from TRI data what portions of releases and transfers are
generated from transportation equipment cleaning. Of the two previous EPA
studies identified, both examined a small number of facilities, making any
extrapolation of toxic chemical releases to the industry as a whole extremely
inaccurate. In addition, data from the EPA Source Assessment Study of 1978
covered only a portion of the industry (tank car and truck tank cleaning) as
it is now regarded, and the EPA Preliminary Data Summary of 1989
examined only wastewater discharges. Information on the total releases and
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transfers from aircraft deicing and rail car refurbishing is especially limited
due to the lack of previous studies.
IV.B. Summary of Selected Chemicals Released
The top toxic chemical releases from transportation equipment cleaning
facilities could not be characterized due to the limited availability of
pollutant release data for the industry.
IV.C. Other Data Sources
The primary source of toxic chemicals released and transferred from the
transportation equipment cleaning industry are dissolved or suspended in
wastewater generated during cleaning of tank interiors. The contaminant
loading of tank cleaning wastewater can vary from a few different toxic
chemicals to a mixture of many toxic chemicals depending upon what liquid
is used to clean the tank and the cargo last carried. The EPA preliminary
study of transportation equipment cleaning facilities performed in 1985 and
1986, analyzed wastewater samples from eight truck tank, rail tank, tank
barge and aircraft cleaning facilities. A total of 111 organic priority
pollutants and all 13 priority pollutant metals were detected. In addition to
priority CWA pollutants, the raw wastewaters were found to contain high
levels of oil and grease, suspended solids, and chemical oxygen demand
(COD). The study concluded that the tank barge cleaning sector was the
largest contributor of toxic chemicals followed by the tank truck cleaning
sector and then the rail tank car cleaning sector.
Based on data in the 1985 and 1986 EPA study, the Agency estimated that
22 million pounds of priority pollutants are released or transferred from the
transportation equipment cleaning industry per year in the form of
wastewater. The EPA Source Assessment Study of 1978 estimated total
VOC emissions from tank car and rail car cleaning (barges not included) was
1.25 million pounds per year. Ignoring the contribution of VOC emissions
that arise from cleaning tank barges, which make up a relatively small
portion of the total toxic chemicals generated by the industry, and ignoring
any changes in VOC emissions since 1978, the total amount of toxic
chemicals released or transferred from tank truck, rail tank car, and tank
barge cleaning can be estimated at about 23 million pounds per year. In
comparison, the iron and steel industry, and the pulp and paper industry
released and transferred approximately 469 million, and 249 million pounds
of TRI toxic chemicals in 1992, respectively.
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V. POLLUTION PREVENTION OPPORTUNITIES
The best way to reduce pollution is to prevent it in the first place. Industries
have creatively implemented pollution prevention techniques that improve
efficiency and increase profits while at the same time minimize
environmental impacts. This can be done in many ways such as reducing
material inputs, re-engineering processes to reuse by-products, improving
management practices, and employing substitute toxic chemicals. Some
smaller facilities are able to actually get below regulatory thresholds just by
reducing pollutant releases through aggressive pollution prevention policies.
In order to encourage these approaches, this section provides both general
and company-specific descriptions of some pollution prevention advances
that have been implemented within the transportation equipment cleaning
industry. While the list is not exhaustive, it does provide core information
that can be used as the starting point for facilities interested in beginning
their own pollution prevention projects. When possible, this section provides
information from real activities that can, or are being implemented by this
sector ~ including a discussion of associated costs, time frames, and expected
rates of return. This section provides summary information from activities
that may be, or are being implemented by this sector. When possible,
information is provided that gives the context in which the technique can be
effectively used. Please note that the activities described in this section do
not necessarily apply to all facilities that fall within this sector. Facility-
specific conditions must be carefully considered when pollution prevention
options are evaluated, and the full impacts of the change must examine how
each option affects air, land and water pollutant releases.
Pollution prevention opportunities for the transportation equipment cleaning
industry are primarily aimed at reducing the release of pollutants through
reducing the amounts of wastewater generated, recycling/reusing cleaning
solution and heels, and effectively removing heels from tanks. However,
these efforts also often reduce the amounts of hazardous wastes and air
emissions generated. Because TECI is a service industry, and facilities
receive what the customers send, source reduction is limited. Pollution
prevention data is being collected in the Office of Water's detailed
questionnaire for the TECI rule development. Brief descriptions of some of
the more widespread pollution prevention opportunities for the industry are
provided below. Because the basic steps of the tank cleaning process do not
differ substantially between tank trucks, rail tank cars, barges, IBCs and
intermodal bulk carriers, the pollution prevention opportunities for these
different transportation modes are interchangeable. Pollution prevention
techniques for exterior rail car cleaning and refurbishing and aircraft deicing
differ considerably from tank cleaning and are described separately.
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Tank Cleaning Facilities
Pollution prevention opportunities for tank cleaning operations are primarily
directed at reducing wastewater contaminated with tank residues and
cleaning solutions. Data are not available on the extent to which pollution
prevention techniques are being implemented in these operations however,
it is likely that pollution prevention opportunities currently being carried out
are driven by the costs to treat or dispose of contaminated wastewater and the
costs of cleaning solutions. Because many tank cleaning operations are small
businesses, or are small segments of medium to large businesses, many of the
acceptable pollution prevention opportunities for the industry will be
somewhat limited to the less costly options, such as minor process
modifications, operational changes and wastes recycling. In the future,
pollution prevention may be driven by the upcoming wastewater effluent
guidelines if provisions for pollution prevention control technologies or
practices are included.
Closed loop washing and rinsing systems. Recycling of wash and rinse
water within a closed loop system can substantially reduce the volumes of
wastewater generated, fugitive emissions and water use. Such systems can
reduce wastewater generation by using the same washing or rinsing solution
many times before it is finally discharged to the treatment system or POTW.
In addition, contaminated solutions used in a wash or rinse step of one tank
can later be reused in a wash or rinse step of another tank which does not
require a clean solution, (e.g., the final rinse solution of one tank can be used
as the initial rinse of the next tank). Through the elimination of open tank
washing and continuous discharging to storage tanks and wastewater
treatment systems, the potential for fugitive emissions of volatile
contaminants is lowered. Closed loop systems have the potential to reduce
a facility's operating costs through reduced wastewater treatment costs,
reduced cleaning solution use, and reduced water use. Capital costs,
potential savings, and pollutant reductions are all site specific.
Rinse and wash solution reuse. Improved management of wash and rinse
solutions can reduce wastewater generation with little or no equipment or
process modifications. Washing and rinsing solutions can be stored
temporarily onsite to be used later in a wash or rinse step that does not
require fresh solution, such as the first wash or rinse step of a highly
contaminated tank, hi addition, tank heels of caustics, detergents or solvents
can be stored for later use as cleaning solutions for other tanks. Some cost
savings could be realized through reduced wastewater treatment costs and
reduced cleaning solution costs. Capital costs may arise from increasing
storage capacity.
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Improved heel removal. The effectiveness of the tank heel removal step has
significant impacts on the volumes and degree of contamination of
wastewater generated in later steps. The removal of tank heels can be
enhanced through a number of techniques, including: pumping ballast water
into some tank barge compartments to tilt the vessel to facilitate residual
removal, using suction or vacuum pumps, and using squeegees to remove
residual from tank walls. Depending on the volumes of tank heels generated
and the value of the product, it may be possible to store tank heels and, after
sufficient volume has been collected, sell the product to a reclaimer or back
to the manufacturer. Tank heels consisting of caustics, detergents, and
solvents can be used as cleaning fluids, and acids and alkali solutions can be
used to neutralize other tank heels or wastewater prior to further treatment.
Segregation of waste streams. Wastewater segregation can be an effective
pollution prevention opportunity that often does not require significant
process or equipment modifications. Many wastewater streams can be more
effectively and economically treated if they are segregated from other
streams which do not require the same degree of treatment. Highly
contaminated wastewater streams, oily wastewater streams and wastewater
streams containing contaminants requiring a specific treatment method (e.g.,
metals removal) can be segregated to reduce the volumes of wastewater
receiving certain treatment steps. Wastewater treatment can also be
improved by adding stages to existing wastewater treatment systems.
Additional stages, such as, biological treatment, chemical precipitation,
filtration, ion exchange and sludge dewatering improve system effectiveness
and treatment costs through reduced sludge generation, recovery of metals
for resale, and replacement of more costly treatment stages.
Rail Car Refurbishing and Maintenance
An EPA Risk Reduction Engineering Laboratory waste minimization project
examined pollution prevention options for a typical rail car refurbishing and
maintenance operation. The project identified a number of pollution
prevention opportunities that would reduce the volume of spent solvents,
spent caustics, paint chips and paint sludges shipped off-site. Some pollution
prevention options that could be transferred to most facilities include: using
electrostatic spray paint systems to reduce over spray losses; using ultrasonic
part wash systems to reduce the need for caustic and solvent cleaners; and
reclaiming and reusing spent solvents. Capital costs are site specific. Cost
savings could be realized through reduced hazardous waste disposal costs
and reduced materials use.
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Aircraft Deicing
Pollution prevention opportunities for aircraft deicing operations primarily
focus on the collection of deicing fluid to prevent direct discharges to
surrounding surface water and groundwater along with facility storm water.
The most widespread collection method involves the collection of deicer
through separate drainage areas around aircraft deicing operations which
minimize the mixing of storm water and deicing fluid. The collection
systems can either be located at the gate area or at a remote deicing area.
Deicer fluid on runway and gate area surfaces can also be collected using
vacuum sweeping machines, sponge rollers, and pumps. Other pollution
prevention opportunities include the use of alternative, less polluting deicers,
and the use of deicing gantries which carefully control the quantity of deicer
fluid used.
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VI. SUMMARY OF APPLICABLE FEDERAL STATUTES AND REGULATIONS
This section discusses the Federal regulations that may apply to this sector.
The purpose of this section is to highlight and briefly describe the applicable
Federal requirements, and to provide citations for more detailed information.
The three following sections are included:
• Section VI. A contains a general overview of major statutes
• Section VLB contains a list of regulations specific to this industry
• Section VI.C contains a list of pending and proposed regulations
The descriptions within Section VI are intended solely for general
information.' Depending upon the nature or scope of the activities at a
particular facility, these summaries may or may not necessarily describe all
applicable environmental requirements. Moreover, they do not constitute
formal interpretations or clarifications of the statutes and regulations. For
further information, readers should consult the Code of Federal Regulations
and other state or local regulatory agencies. EPA Hotline contacts are also
provided for each major statute.
VI.A. General Description of Major Statutes
Resource Conservation and Recovery Act (RCRA)
RCRA of 1976 which amended the Solid Waste Disposal Act, addresses solid
(Subtitle D) and hazardous (Subtitle C) waste management activities. The
Hazardous and Solid Waste Amendments (HSWA) of 1984 strengthened
RCRA's waste management provisions and added Subtitle I, which governs
underground storage tanks (USTs).
Regulations promulgated pursuant to Subtitle C of RCRA (40 CFR Parts
260-299) establish a "cradle-to-grave" system governing hazardous waste
from the point of generation to disposal. RCRA hazardous wastes include
the specific materials listed in the regulations (commercial chemical
products, designated with the code "P" or "U"; hazardous wastes from
specific industries/sources, designated with the code "K"; or hazardous
wastes from non-specific sources, designated with the code "F") or materials
which exhibit a hazardous waste characteristic (ignitibility, corrosivity,
reactivity, or toxicity and designated with the code "D").
Regulated entities that generate hazardous waste are subject to waste
accumulation, manifesting, and record keeping standards. Facilities that
treat, store, or dispose of hazardous waste must obtain a permit, either from
EPA or from a State agency which EPA has authorized to implement the
permitting program. Subtitle C permits contain general facility standards
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such as contingency plans, emergency procedures, record keeping and
reporting requirements, financial assurance mechanisms, and unit-specific
standards. RCRA also contains provisions (40 CFR Part 264 Subpart S and
§264.10) for conducting corrective actions which govern the cleanup of
releases of hazardous waste or constituents from solid waste management
units at RCRA-regulated facilities.
Although RCRA is a Federal statute, many States implement the RCRA
program. Currently, EPA has delegated its authority to implement various
provisions of RCRA to 46 of the 50 States.
Most RCRA requirements are not industry specific but apply to any company
that transports, treats, stores, or disposes of hazardous waste. Here are some
important RCRA regulatory requirements:
Identification of Solid and Hazardous Wastes (40 CFR Part 261)
lays out the procedure every generator should follow to determine
whether the material created is considered a hazardous waste, solid
waste, or is exempted from regulation.
Standards for Generators of Hazardous Waste (40 CFR Part 262)
establishes the responsibilities of hazardous waste generators
including obtaining an ID number, preparing a manifest, ensuring
proper packaging and labeling, meeting standards for waste
accumulation units, and record keeping and reporting requirements.
Generators can accumulate hazardous waste for up to 90 days (or 180
days depending on the amount of waste generated) without obtaining
a permit.
• Land Disposal Restrictions (LDRs) are regulations prohibiting the
disposal of hazardous waste on land without prior treatment. Under
the LDRs (40 CFR 268), materials must meet land disposal restriction
(LDR) treatment standards prior to placement in a RCRA land
disposal unit (landfill, land treatment unit, waste pile, or surface
impoundment). Wastes subject to the LDRs include solvents,
electroplating wastes, heavy metals, and acids. Generators of waste
subject to the LDRs must provide notification of such to the
designated TSD facility to ensure proper treatment prior to disposal.
• Used Oil storage and disposal regulations (40 CFR Part 279) do not
define Used Oil Management Standards impose management
requirements affecting the storage, transportation, burning,
processing, and re-refining of the used oil. For parties that merely
generate used oil, regulations establish storage standards. For a party
considered a used oil marketer (one who generates and sells
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off-specification used oil directly to a used oil burner), additional
tracking and paperwork requirements must be satisfied.
• Tanks and Containers used to store hazardous waste with a high
volatile organic concentration must meet emission standards under
RCRA. Regulations (40 CFR Part 264-265, Subpart CC) require
generators to test the waste to determine the concentration of the
waste, to satisfy tank and container emissions standards, and to
inspect and monitor regulated units. These regulations apply to all
facilities who store such waste, including generators operating under
the 90-day accumulation rule. (Note: implementation of this rule is
expected in December of 1995 and changes are likely.)
Underground Storage Tanks (USTs) containing petroleum and
hazardous substance are regulated under Subtitle I of RCRA.
Subtitle I regulations (40 CFR Part 280) contain tank design and
release detection requirements, as well as financial responsibility and
corrective action standards for USTs. The UST program also
establishes increasingly stringent standards, including upgrade
requirements for existing tanks, that must be met by 1998.
Boilers and Industrial Furnaces (BIFs) that use or burn fuel
containing hazardous waste must comply with strict design and
operating standards. BIF regulations (40 CFR Part 266, Subpart H)
address unit design, provide performance standards, require
emissions monitoring, and restrict the type of waste that may be
burned.
EPA's RCRA/Superfund/UST Hotline, at (800) 424-9346, responds to
questions and distributes guidance regarding all RCRA regulations. The
RCRA Hotline operates weekdays from 8:30 a.m. to 7:30 p.m., ET, excluding
Federal holidays.
Comprehensive Environmental Response, Compensation, And Liability Act (CERCLA)
CERCLA, a 1980 law commonly known as Superfund, authorizes EPA to
respond to releases, or threatened releases, of hazardous substances that may
endanger public health, welfare, or the environment. CERCLA also enables
EPA to force parties responsible for environmental contamination to clean
it up or to reimburse the Superfund for response costs incurred by EPA. The
Superfund Amendments and Reauthorization Act (SARA) of 1986 revised
various sections of CERCLA, extended the taxing authority for the
Superfund, and created a free-standing law, SARA Title III, also known as
the Emergency Planning and Community Right-to-Know Act (EPCRA).
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The CERCLA hazardous substance release reporting regulations (40 CFR
Part 302) direct the person in charge of a facility to report to. the National
Response Center (NRC) any environmental release of a hazardous substance
which exceeds a reportable quantity. Reportable quantities are defined and
listed in 40 CFR §302.4. A release report may trigger a response by EPA, or
by one or more Federal or State emergency response authorities.
EPA implements hazardous substance responses according to procedures
outlined in the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP) (40 CFR Part 300). The NCP includes provisions
for permanent cleanups, known as remedial actions, and other cleanups
referred to as "removals." EPA generally takes remedial actions only at sites
on the National Priorities List (NPL), which currently includes approximately
1300 sites. Both EPA and states can act at other sites; however, EPA
provides responsible parties the opportunity to conduct removal and remedial
actions and encourages community involvement throughout the Superfund
response process.
EPA's RCRA/SuperJund/USTHotline, at (800) 424-9346, answers questions
and references guidance pertaining to the Superfund program. The CERCLA
Hotline operates weekdays from 8:30 a.m. to 7:30 p.m., ET, excluding
Federal holidays.
Emergency Planning And Community Right-To-Know Act (EPCRA)
The Superfund Amendments and Reauthorization Act (SARA) of 1986
created EPCRA, also known as SARA Title HI, a statute designed to improve
community access to information about chemical hazards and to facilitate the
development of chemical emergency response plans by State and local
governments. EPCRA required the establishment of State emergency
response commissions (SERCs), responsible for coordinating certain
emergency response activities and for appointing local emergency planning
committees (LEPCs).
EPCRA and the EPCRA regulations (40 CFR Parts 350-372) establish four
types of reporting obligations for facilities which store or manage specified
chemicals:
EPCRA §302 requires facilities to notify the SERC and LEPC of the
presence of any "extremely hazardous substance" (the list of such
substances is in 40 CFR Part 355, Appendices A and B) if it has such
substance in excess of the substance's threshold planning quantity,
and directs the facility to appoint an emergency response coordinator.
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EPCRA §304 requires the facility to notify the SERC and the LEPC
in the event of a release exceeding the reportable quantity of a
CERCLA hazardous substance or an EPCRA extremely hazardous
substance.
• EPCRA §311 and §312 require a facility at which a hazardous
chemical, as defined by the Occupational Safety and Health Act, is
present in an amount exceeding a specified threshold to submit to the
SERC, LEPC and local fire department material safety data sheets
(MSDSs) or lists of MSDS's and hazardous chemical inventory forms
(also known as Tier I and II forms). This information helps the local
government respond in the event of a spill or release of the chemical.
• EPCRA §313 requires manufacturing facilities included in SIC codes
20 through 39, which have ten or more employees, and which
manufacture, process, or use specified chemicals in amounts greater
than threshold quantities, to submit an annual toxic chemical release
report. This report, commonly known as the Form R, covers releases
and transfers of toxic chemicals to various facilities and
environmental media, and allows EPA to compile the national Toxic
Release Inventory (TRI) database.
All information submitted pursuant to EPCRA regulations is publicly
accessible, unless protected by a trade secret claim.
EPA's EPCRA Hotline, at (800) 535-0202, answers questions and distributes
guidance regarding the emergency planning and community right-to-know
regulations. The EPCRA Hotline operates weekdays from 8:30 a.m. to 7:30
p.m., ET, excluding Federal holidays.
Clean Water Act (CWA)
The primary objective of the Federal Water Pollution Control Act, commonly
referred to as The CWA, is to restore and maintain the chemical, physical,
and biological integrity of the nation's surface waters. Pollutants regulated
under the CWA include "priority" pollutants, including various toxic
pollutants; "conventional" pollutants, such as biochemical oxygen demand
(BOD), total suspended solids (TSS), fecal coliform, oil and grease, and pH;
and "non-conventional" pollutants, including any pollutant not identified as
either conventional or priority.
The CWA regulates both direct and indirect discharges. The National
Pollutant Discharge Elimination System (NPDES) program (CWA §402)
controls direct discharges into navigable waters. Direct discharges or "point
source" discharges are from sources such as pipes and sewers. NPDES
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permits, issued by either EPA or an authorized State (EPA has presently
authorized forty States to administer the NPDES program), contain industry-
specific, technology-based and/or water quality-based limits, and establish
pollutant monitoring reporting requirements. A facility that intends to
discharge into the nation's waters must obtain a permit prior to initiating a
discharge. A permit applicant must provide quantitative analytical data
identifying the types of pollutants present hi the facility's effluent. The
permit will then set forth the conditions and effluent limitations under which
a facility may make a discharge.
A NPDES permit may also include discharge limits based on Federal or State
water quality criteria or standards, that were designed to protect designated
uses of surface waters, such as supporting aquatic life or recreation. These
standards, unlike the technological standards, generally do not take into
account technological feasibility or costs. Water quality criteria and
standards vary from State to State, and site to site, depending on the use
classification of the receiving body of water. Most States follow EPA
guidelines which propose aquatic life and human health criteria for many of
the 126 priority pollutants.
Storm Water Discharges
In 1987 the CWA was amended to require EPA to establish a program to
address storm water discharges. In response, EPA promulgated the
NPDES storm water permit application regulations. These regulations
require that facilities with the following storm water discharges apply for an
NPDES permit: (1) a discharge associated with industrial activity; (2) a
discharge from a large or medium municipal storm sewer system; or (3) a
discharge which EPA or the State determines to contribute to a violation of
a water quality standard or is a significant contributor of pollutants to waters
of the United States.
The term "storm water discharge associated with industrial activity" means
a storm water discharge from one of 11 categories of industrial activity
defined at 40 CFR 122.26. Six of the categories are defined by SIC codes
while the other five are identified through narrative descriptions of the
regulated industrial activity. If the primary SIC code of the facility is one of
those identified in the regulations, the facility is subject to the storm water
permit application requirements. If any activity at a facility is covered by
one of the five narrative categories, storm water discharges from those areas
where the activities occur are subject to storm water discharge permit
application requirements.
Those facilities/activities that are subject to storm water discharge permit
application requirements are identified below. To determine whether a
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particular facility falls within one of these categories, the regulation should
be consulted.
Category i: Facilities subject to storm water effluent guidelines, new source
performance standards, or toxic pollutant effluent standards.
Category ii: Facilities classified as SIC 24-lumber and wood products
(except wood kitchen cabinets); SIC 26-paper and allied products (except
paperboard containers and products); SIC 28-chemicals and allied products
(except drugs and paints); SIC 291-petroleum refining; and SIC 31 l-leather
tanning and finishing.
Category iii: Facilities classified as SIC 10-metal mining; SIC 12-coal
mining; SIC 13-oil and gas extraction; and SIC 14-nonmetallic mineral
mining.
Category iv: Hazardous waste treatment, storage, or disposal facilities.
Category v: Landfills, land application sites, and open dumps that receive
or have received industrial wastes.
Category vi: Facilities classified as SIC 5015-used motor vehicle parts; and
SIC 5093-automotive scrap and waste material recycling facilities.
Category vii: Steam electric power generating facilities.
Category viii: Facilities classified as SIC 40-railroad transportation; SIC
41-local passenger transportation; SIC 42-trucking and warehousing (except
public warehousing and storage); SIC 43-U.S. Postal Service; SIC 44-water
transportation; SIC 45-transportation by air; and SIC 5171-petroleum bulk
storage stations and terminals.
Category ix: Sewage treatment works.
Category x: Construction activities except operations that result in the
disturbance of less than five acres of total land area.
Category xi: Facilities classified as SIC 20-food and kindred products; SIC
21-tobacco products; SIC 22-textile mill products; SIC 23-apparel related
products; SIC 2434-wood kitchen cabinets manufacturing; SIC 25-furniture
and fixtures; SIC 265-paperboard containers and boxes; SIC 267-converted
paper and paperboard products; SIC 27-printing, publishing, and allied
industries; SIC 283-drugs; SIC 285-paints, varnishes, lacquer, enamels, and
allied products; SIC 30-rubber and plastics; SIC 3l-leather and leather
products (except leather and tanning and finishing); SIC 323-glass products;
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SIC 34-fabricated metal products (except fabricated structural metal); SIC
35-industrial and commercial machinery and computer equipment; SIC 36-
electronic and other electrical equipment and components; SIC 37-
transportation equipment (except ship and boat building and repairing); SIC
38-measuring, analyzing, and controlling instruments; SIC 39-miscellaneous
manufacturing industries; and SIC 4221-4225-public warehousing and
storage.
Pretreatment Program
Another type of discharge that is regulated by the CWA is one that goes to
a publicly-owned treatment works (POTWs). The national pretreatment
program (CWA §307(b)) controls the indirect discharge of pollutants to
POTWs by "industrial users." Facilities regulated under §307(b) must meet
certain pretreatment standards. The goal of the pretreatment program is to
protect municipal wastewater treatment plants from damage that may occur
when hazardous, toxic, or other wastes are discharged into a sewer system
and to protect the toxicity characteristics of sludge generated by these plants.
Discharges to a POTW are regulated primarily by the POTW itself, rather
than the State or EPA.
EPA has developed general pretreatment standards and technology-based
standards for industrial users of POTWs in many industrial categories.
Different standards may apply to existing and new sources within each
category. "Categorical" pretreatment standards applicable to an industry on
a nationwide basis are developed by EPA. In addition, another kind of
pretreatment standard, "local limits," are developed by the POTW in order
to assist the POTW in achieving the effluent limitations in its NPDES permit.
Regardless of whether a State is authorized to implement either the NPDES
or the pretreatment program, if it develops its own program, it may enforce
requirements more stringent than Federal standards.
EPA's Office of Water, at (202) 260-5700, mil direct callers with questions
about the CWA to the appropriate EPA office. EPA also maintains a
bibliographic database of Office of Water publications which can be
accessed through the Ground Water and Drinking Water resource center, at
(202) 260-7786.
Safe Drinking Water Act (SDWA)
The SDWA mandates that EPA establish regulations to protect human health
from contaminants in drinking water. The law authorizes EPA to develop
national drinking water standards and to create a joint Federal-State system
to ensure compliance with these standards. The SDWA also directs EPA to
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protect underground sources of drinking water through the control of
underground injection of liquid wastes.
EPA has developed primary and secondary drinking water standards under
its SDWA authority. EPA and authorized States enforce the primary
drinking water standards, which are, contaminant-specific concentration
limits that apply to certain public drinking water supplies. Primary drinking
water standards consist of maximum contaminant level goals (MCLGs),
which are non-enforceable health-based goals, and maximum contaminant
levels (MCLs), which are enforceable limits set as close to MCLGs as
possible, considering cost and feasibility of attainment.
The SDWA Underground Injection Control (UIC) program (40 CFR Parts
144-148) is a permit program which protects underground sources of
drinking water by regulating five classes of injection wells. UIC permits
include design, operating, inspection, and monitoring requirements. Wells
used to inject hazardous wastes must also comply with RCRA corrective
action standards in order to be granted a RCRA permit, and must meet
applicable RCRA land disposal restrictions standards. The UIC permit
program is primarily State-enforced, since EPA has authorized all but a few
States to administer the program.
The SDWA also provides for a Federally-implemented Sole Source Aquifer
program, which prohibits Federal funds from being expended on projects that
may contaminate the sole or principal source of drinking water for a given
area, and for a State-implemented Wellhead Protection program, designed to
protect drinking water wells and drinking water recharge areas.
EPA's Safe Drinking Water Hotline, at (800) 426-4791, answers questions
and distributes guidance pertaining to SDWA standards. The Hotline
operates from 9:00 a.m. through 5:30 p.m., ET, excluding Federal holidays.
Toxic Substances Control Act (TSCA)
The TSCA granted EPA authority to create a regulatory framework to collect
data on chemicals in order to evaluate, assess, mitigate, and control risks
which may be posed by their manufacture, processing, and use. TSCA
provides a variety of control methods to prevent chemicals from posing
unreasonable risk.
TSCA standards may apply at any point during a chemical's life cycle.
Under TSCA §5, EPA has established an inventory of chemical substances.
If a chemical is not already on the inventory, and has not been excluded by
TSCA, a premanufacture notice (PMN) must be submitted to EPA prior to
manufacture or import. The PMN must identify the chemical and provide
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available information on health and environmental effects. If available data
are not sufficient to evaluate the chemicals effects, EPA- can impose
restrictions pending the development of information on its health and
environmental effects. EPA can also restrict significant new uses of
chemicals based upon factors such as the projected volume and use of the
chemical.
Under TSCA §6, EPA can ban the manufacture or distribution in commerce,
limit the use, require labeling, or place other restrictions on chemicals that
pose unreasonable risks. Among the chemicals EPA regulates under §6
authority are asbestos, chlorofluorocarbons (CFCs), and polychlorinated
biphenyls (PCBs).
EPA's TSCA Assistance Information Service, at (202) 554-1404, answers
questions and distributes guidance pertaining to Toxic Substances Control
Act standards. The Service operates from 8:30 a.m. through 4:30 p.m., ET,
excluding Federal holidays.
Clean Air Act (CAA)
The CAA and its amendments, including the Clean Air Act Amendments
(CAAA) of 1990, are designed to "protect and enhance the nation's air
resources so as to promote the public health and welfare and the productive
capacity of the population." The CAA consists of six sections, known as
Titles, which direct EPA to establish national standards for ambient air
quality and for EPA and the States to implement, maintain, and enforce these
standards through a variety of mechanisms. Under the CAAA, many
facilities will be required to obtain permits for the first time. State and local
governments oversee, manage, and enforce many of the requirements of the
CAAA. CAA regulations appear at 40 CFR Parts 50-99.
Pursuant to Title I of the CAA, EPA has established national ambient air
quality standards (NAAQSs) to limit levels of "criteria pollutants," including
carbon monoxide, lead, nitrogen dioxide, particulate matter, ozone, and
sulfur dioxide. Geographic areas that meet NAAQSs for a given pollutant
are classified as attainment areas; those that do not meet NAAQSs are
classified as non-attainment areas. Under §110 of the CAA, each State must
develop a State Implementation Plan (SIP) to identify sources of air pollution
and to determine what reductions are required to meet Federal air quality
standards.
Title I also authorizes EPA to establish New Source Performance Standards
(NSPSs), which are nationally uniform emission standards for new stationary
sources falling within particular industrial categories. NSPSs are based on
the pollution control technology available to that category of industrial
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source but allow the affected industries the flexibility to devise a
cost-effective means of reducing emissions.
Under Title I, EPA establishes and enforces National Emission Standards for
Hazardous Air Pollutants (NESHAPs), nationally uniform standards oriented
towards controlling particular hazardous air pollutants (HAPs). Title III of
the CAAA further directed EPA to develop a list of sources that emit any of
189 HAPs, and to develop regulations for these categories of sources. To
date EPA has listed 174 categories and developed a schedule for the
establishment of emission standards. The emission standards will be
developed for both new and existing sources based on "maximum achievable
control technology (MACT)." The MACT is defined as the control
technology achieving the maximum degree of reduction in the emission of
the HAPs, taking into account cost and other factors.
Title II of the CAA pertains to mobile sources, such as cars, trucks, buses,
and planes. Reformulated gasoline, automobile pollution control devices^
and vapor recovery nozzles on gas pumps are a few of the mechanisms EPA
uses to regulate mobile air emission sources.
Title IV establishes a sulfur dioxide emissions program designed to reduce
the formation of acid rain. Reduction of sulfur dioxide releases will be
obtained by granting to certain sources limited emissions allowances, which,
beginning in 1995, will be set below previous levels of sulfur dioxide
releases.
Title V of the CAAA of 1990 created a permit program for all "major
sources" (and certain other sources) regulated under the CAA. One purpose
of the operating permit is to include in a single document all air emissions
requirements that apply to a given facility. States are developing the permit
programs in accordance with guidance and regulations from EPA. Once a
State program is approved by EPA, permits will be issued and monitored by
that State.
Title VI is intended to protect stratospheric ozone by phasing out the
manufacture of ozone-depleting chemicals and restrict their use and
distribution. Production of Class I substances, including 15 kinds of
chlorofluorocarbons (CFCs), will be phased out entirely by the year 2000,
while certain hydrochlorofluorocarbons (HCFCs) will be phased out bv
2030.
EPA's Control Technology Center, at (919) 541-0800, provides general
assistance and information on CAA standards. The Stratospheric Ozone
Information Hotline, at (800) 296-1996, provides general information about
regulations promulgated under Title VI of the CAA, and EPA's EPCRA
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Hotline, at (800) 535-0202, answers questions about accidental release
prevention under CAA §112(r). In addition, the Technology Transfer
Network Bulletin Board System (modem access (919) 541-5742) includes
recent CAA rules, EPA guidance documents, and updates of EPA activities.
VLB. Industry Specific Requirements
Clean Water Act
Wastewater from transportation equipment cleaning facilities discharging to
surface waters is regulated under the Federal Water Pollution Control Act
(FWPCA). National Pollutant Discharge Elimination System (NPDES)
permits must be obtained to discharge wastewater into navigable waters. As
mandated by section 304(m) of CWA, EPA is developing effluent limitations
guidelines for wastewater discharge from transportation equipment cleaning
facilities. The guidelines are scheduled to be proposed in 1996 and
promulgated in 1998. (Contact: Gina Matthews or Jan Goodwin, Office of
Water, 202-260-6036 and 202-260-7152, respectively). In addition, the
recent storm water rules require facilities that discharge storm water to apply
for a storm water NPDES permit. Existing NPDES permits for
transportation equipment cleaning facilities discharging wastewater are likely
to already cover the collection, treatment and discharge o'f storm water.
However, some additional treatment and monitoring of storm water flows
may be required when NPDES permits are renewed.
Resource Conservation and Recovery Act
Several types of wastes generated from transportation equipment cleaning
facilities are shipped off-site as hazardous under RCRA. The largest
quantities of RCRA hazardous wastes are sludges generated during
wastewater treatment. These wastes are typically either landfilled,
incinerated, or otherwise treated or disposed. In addition, rail car
refurbishing and maintenance operation generate hazardous wastes as
wastewater treatment system sludges, paint removal, painting, and from
cleaning parts with solvents and caustics. RCRA listed wastes are subject to
the hazardous waste regulations of 40 CFR Parts 124,261 through 266, 270,
271, and 302.
RCRA hazardous waste regulations defining an "empty" tank (40 CFR
§261.7) are particularly relevant to the transportation equipment cleaning
industry and the handling of tank heels. Tanks containing heels of RCRA
regulated residues above the RCRA-empty limits are technically defined as
a hazardous waste. Under RCRA rules, the waste must, therefore, be
accompanied by a RCRA manifest and the facility itself must be permitted
as a RCRA Treatment, Storage, or Disposal Facilities (TSDF). In practice,
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tank heels typically do not have RCRA manifests, and tank cleaning facilities
are rarely RCRA permitted. A committee of EPA, Department of
Transportation (DOT), and industry trade groups that was formed to increase
the uniformity of RCRA permits, also looked at the issue of how to manifest
tank residues that are above the RCRA limits. The committee agreed on a
number of options that require RCRA manifests for tank heels in quantities
above the RCRA-empty limits. The EPA Office of Solid Waste is currently
charged with making a final decision on this issue. (Contact: Ann
Codrington 202-260-4777)
Comprehensive Environmental Response, Compensation and Liability Act
A number of wastes generated from the transportation equipment cleaning
refining process contain CERCLA hazardous substances. Therefore, past
spills and on-site releases of such substances may require remedial clean-up
actions under Superfund.
Hazardous Materials Transportation Act (HMTA)
The transport of hazardous materials is regulated by the DOT under the
Hazardous Materials Transportation Act. Materials covered by the Act
include all RCRA listed wastes and some additional materials deemed by
DOT to be dangerous to transport. Therefore, the transport, handling and
unloading of tank heels could be covered by the HMTA regulations. The
HMTA regulations (49 CFR Parts 174-177, and §§171.15, 171.16) cover
packaging, labeling, shipping papers, emergency planning, incident
notifications, and liability insurance. Because there is some overlap between
the DOT regulation under HMTA and EPA regulations under RCRA, DOT
personnel have been active on the committee formed to look at manifesting
of tank residues under RCRA.
1990 Oil Pollution Act
The 1990 Oil Pollution Act affects those barge and ship tank cleaning
facilities that clean vessels carrying oil. The Act establishes strict, joint and
several liability against facilities that discharge oil or which pose a
substantial threat of discharging oil to navigable waterways. Standards have
been set for tank equipment, spill prevention control plans, and vessels.
Some specific requirements include double hulls, drug and alcohol abuse
policies, and on-board manning and vessels personnel policies. There are
also criminal and civil penalties for deliberate or negligent spills of oil.
Regulations covering response to oil discharges and contingency plans (40
CFR Part 300), and facility response plans to oil discharges (40 CFR Part
112) were revised and finalized in 1994.
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OSHA and Coast Guard Safety Rules
Worker safety is regulated by the Occupational Safety and Health
Administration (OSHA) (29 CFR §1910.1028) at track, rail and airport
facilities and the Coast Guard (33 USCA 1221-1232, 2718) at tank barge
facilities. Safety rules specific to the management of hazardous materials
deal with occupational exposure limits, personal protective equipment,
materials handling procedures, safety training requirements, and confined
space entry procedures.
VI.C. Pending and Proposed Regulatory Requirements
Clean Water Act
Presently, there are no effluent limitations guidelines specific to the
transportation equipment cleaning industry. Effluent guidelines are currently
being developed for the industry (tank interior cleaning only) by the Office
of Water (Contact: Gina Matthews or Jan Goodwin, Office of Water, 202-
260-6036 and 202-260-7152, respectively). EPA is under a court-ordered
deadline to propose and promulgate wastewater effluent guidelines for the
industry (including aircraft deicing) by the end of 1996 and 1998,
respectively. The Office of Water is currently collecting more extensive and
up-to-date industry data through questionnaires, site visits to facilities, and
sampling which will be used as a basis for developing the effluent limitations
guidelines.
Effluent limitation guidelines for aircraft cleaning and deicing are expected
to be studied and developed separately from those for tank cleaning facilities.
Recently issued Federal Aviation Administration guidelines on aircraft
deicing, and the recent EPA storm water rales, are likely to have significant
effects on airport deicing operations. The EPA Office of Water will study
the effects of these regulations before initiating its own deicing rale making.
hi addition, the EPA Office of Water will also work with the Department of
Defense to study deicing operations at military installations. Depending on
the results of this study, guidelines specific to deicing at military installations
may be developed.
Resource Conservation and Recovery Act (RCRA)
A committee made up of representatives from EPA, DOT and industry trade
groups that met to increase uniformity in RCRA manifests also examined the
manifesting of tank heels that are above RCRA-empty limits. Presently,
DOT regulates tank heels under the Hazardous Material Transportation Act
(49 USCA 1801-1819), and EPA regulates the tank heels under RCRA (40
CFR Parts 262-265). The committee agreed on a number of options for
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manifesting of tank residues in quantities above RCRA-empty limits. EPA
will issue a proposed rule on manifesting requirements based on the
committee recommendations in 1995. (Ann Codringtdn 202-260-4777)
Sanitary Food Transportation Act (SFTA)
The Sanitary Food Transportation Act was enacted in 1990 and is
implemented by the DOT. The Act aims to prevent contamination of food
products from shipping containers previously used to transport toxic
materials. DOT is currently developing regulations that will likely effect
carriers as well as the tank cleaning industry. (Contact: Joseph Delevanko,
U.S. DOT, (202) 366-4484)
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VII. COMPLIANCE AND ENFORCEMENT HISTORY
To date, EPA has focused much of its attention on measuring compliance
with specific environmental statutes. This approach allows the Agency to
track compliance with the Clean Air Act, the Resource Conservation and
Recovery Act, the Clean Water Act, and other environmental statutes.
Within the last several years, the Agency has begun to supplement single-
media compliance indicators with facility-specific, multimedia indicators of
compliance. In doing so, EPA is in a better position to track compliance with
all statutes at the facility level, and within specific industrial sectors.
A major step in building the capacity to compile multimedia data for
industrial sectors was the creation of EPA's Integrated Data for Enforcement
Analysis (IDEA) system. IDEA has the capacity to "read into" the Agency's
single-media databases, extract compliance records, and match the records
to individual facilities. The IDEA system can match Air, Water, Waste,
Toxics/Pesticides/EPCRA, TRI, and Enforcement Docket records for a given
facility, and generate a list of historical permit, inspection, and enforcement
activity. IDEA also has the capability to analyze data by geographic area
and corporate holder. As the capacity to generate multimedia compliance
data improves, EPA will make available more in-depth compliance and
enforcement information. Additionally, sector-specific measures of success
for compliance assistance efforts are under development.
VILA. Transportation Equipment Cleaning Industry Compliance History
An enforcement and compliance matrix based on information from the IDEA
(Integrated Data for Enforcement Analysis) database is not available for the
transportation equipment cleaning industry. Information from the IDEA
system is sorted by industry using SIC codes. Because their are no SIC
codes that apply solely to transportation equipment cleaning, compliance and
enforcement information specific to the industry cannot be obtained from the
IDEA system.
VII.B. Review of Major Legal Actions
This section provides summary information about major cases that have
affected this sector, and a list of Supplementary Environmental Projects
(SEPs). SEPs are compliance agreements that reduce a facility's stipulated
penalty in return for an environmental project that exceeds the value of the
reduction. Often, these projects fund pollution prevention activities that can
significantly reduce the future pollutant loadings of a facility.
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VII.B.1. Review of Major Cases
Historically, OECA's Office of Enforcement Capacity and Outreach does not
regularly compile information related to major cases and pending litigation
within an industry sector. The staff are willing to pass along such
information to Agency staff as requests are made. In addition, summaries of
completed enforcement actions are published each fiscal year in the
Enforcement Accomplishments Report. To date these summaries are not
organized by industry sector. (Contact: Office of Enforcement Capacity and
Outreach, 202-260-4140)
VH.B.2. Supplementary Environmental Projects
Supplemental environmental projects (SEPs) are an enforcement option that
requires the non-compliant facility to complete specific projects. Regional
summaries of SEPs undertaken in the 1993 and 1994 federal fiscal years
were reviewed. No SEPs were identified that involved transportation
equipment cleaning facilities during this period. However, an injunctive
relief action was identified which was carried out following a violation of the
CWA at the Union Tank Car Co. in Louisiana. The specifics of the violation
were not provided by the reporting Region. The company was fined
$350,000 and was required to construct a pipeline from the facility to the
local POTW to stop the unpermitted discharge of wastewater from the
facility's rail car cleaning operations. It was also required that the pipeline
be constructed to allow local residents to tie-in the system. No reduction in
the initial cash penalty was granted for the implementation of the project.
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VIII. COMPLIANCE ASSURANCE ACTIVITIES AND INITIATIVES
This section highlights the activities undertaken by this industry sector and
public agencies to voluntarily improve the sector's environmental
performance. These activities include those independently initiated by
industrial trade associations. In this section, the notebook also contains a
listing and description of national and regional trade associations.
VIII.A. Sector-related Environmental Programs and Activities
Environmental compliance assurance activities by both government and
industry have been extremely limited for the transportation equipment
cleaning industry. In part, this is due to the lack of environmental
regulations specific to the industry at this time. While most facilities must
obtain and meet the requirements of NPDES permits for wastewater and
storm water discharge, and must comply with RCRA hazardous waste
requirements, the wastes generated and the methods of handling and
disposing of these wastes are not unique to the industry. Compliance
assurance activities specific to the cleaning of transportation equipment,
therefore, may not be an industry priority. Another possible factor limiting
industry specific compliance assurance activities is that many transportation
equipment cleaning facilities are a relatively small part of larger
manufacturing, maintenance, repair, and depot/terminal facilities. The
primary focus of industry and government compliance assurance activities
would naturally focus on the various other environmental regulations that
cover these facilities.
EPA activities to date have primarily been aimed at assessing the
environmental effects and collecting data for the purpose of developing
regulations for controlling pollutant discharges in wastewater. As a result,
compliance assistance activities specific to the transportation equipment
cleaning industry have been limited.
Waste Minimization Assessment for a Manufacturer of Rebuilt Railway Cars and Components
The U.S. EPA funded a pilot project to assess small- and medium-size
manufacturers who want to minimize their generation of hazardous waste but
lack the expertise to do so. Waste Minimization Assessment Centers
(WMACs) were established at selected universities and procedures were
adapted from the EPA Waste Minimization Opportunity Assessment Manual.
The WMAC team at the University of Tennessee inspected a plant that
rebuilds approximately 2,000 railway cars each year and that refurbishes
wheel assemblies and air brake systems. The team issued a report and made
a number of recommendations for minimizing wastes.
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VIII.B. EPA Voluntary Programs
33/50 Program
The "33/50 Program" is EPA's voluntary program to reduce toxic chemical
releases of eighteen chemicals from manufacturing facilities. Participating
companies pledge to reduce their toxic chemical releases and transfers by 33
percent as of 1992 and by 50 percent as of 1995. Certificates of
Appreciation have been given out to participants meeting their 1992 goals.
The list of chemicals includes seventeen high-use chemicals reported in the
Toxics Release Inventory. (Contact: Mike Burns 202-260-6394 or the 33/50
Program 202-260-6907)
Environmental Leadership Program
Project XL
The Environmental Leadership Program (ELP) is a national initiative piloted
by EPA and state agencies in which facilities have volunteered to
demonstrate innovative approaches to environmental management and
compliance. EPA has selected 12 pilot projects at industrial facilities and
federal installations which will demonstrate the principles of the ELP
program. These principles include: environmental management systems,
multimedia compliance assurance, third-party verification of compliance,
public measures of accountability, community involvement, and mentoring
programs. In return for participating, pilot participants receive public
recognition and are given a period of time to correct any violations
discovered during these experimental projects. Forty proposals were
received from companies, trade associations, and federal facilities
representing many manufacturing and service sectors. (Contact: Tai-ming
Chang, ELP Director, 202-564-5081 or Robert Fentress 202-564-7023)
Project XL was initiated in March 1995 as a part of President Clinton's
Reinventing Environmental Regulation initiative. The projects seek to
achieve cost effective environmental benefits by allowing participants to
replace or modify existing regulatory requirements on the condition that they
produce greater environmental benefits. EPA and program participants will
negotiate and sign a Final Project Agreement, detailing specifc objectives
that the regulated entity shall satisfy. In exchange, EPA will allow the
participant a certain degree of regulatory flexibility and may seek changes
in underlying regulations or statutes. Participants are encouraged to seek
stakeholder support from local governments, businesses, and environmental
groups. EPA hopes to implement fifty pilot projects in four categories
including facilities, sectors, communities, and government agencies regulated
by EPA. Applications will be accepted on a rolling basis and projects will
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move to implementation within six months of their selection. For additional
information regarding XL Projects, including application procedures and
criteria, see the May 23,1995 Federal Register Notice, or contact Jon Kessler
at EPA's Office of Policy Analysis (202) 260-4034.
Green Lights Program
WasteWi$e Program
EPA's Green Lights program was initiated in 1991 and has the goal of
preventing pollution by encouraging U.S. institutions to use energy-efficient
lighting technologies. The program has over 1,500 participants which
include major corporations; small and medium sized businesses; federal,
state and local governments; non-profit groups; schools; universities; and
health care facilities. Each participant is required to survey their facilities
and upgrade lighting wherever it is profitable. EPA provides technical
assistance to the participants through a decision support software package,
workshops and manuals, and a financing registry. EPA's Office of Air and
Radiation is responsible for operating the Green Lights Program. (Contact:
Maria Tikoff at 202-233-9178 or the Green Light/Energy Star Hotline at
202-775-6650)
The WasteWi$e Program was started in 1994 by EPA's Office of Solid
Waste and Emergency Response. The program is aimed at reducing
municipal solid wastes by promoting waste minimization, recycling
collection, and the manufacturing and purchase of recycled products. As of
1994, the program had about 300 companies as members, including a number
of major corporations. Members agree to identify and implement actions to
reduce their solid wastes and must provide EPA with their waste reduction
goals along with yearly progress reports. EPA, in turn, provides technical
assistance to member companies and allows the use of the Waste Wi$e logo
for promotional purposes. (Contact: Lynda Wynn 202-260-0700 or the
WasteWi$e Hotline at 800-372-9473)
Climate Wise Recognition Program
The Climate Change Action Plan was initiated in response to the U.S.
commitment to reduce greenhouse gas emissions in accordance with the
Climate Change Convention of the 1990 Earth Summit. As part of the
Climate Change Action Plan, the Climate Wise Recognition Program is a
partnership initiative run jointly by EPA and the Department of Energy. The
program is designed to reduce greenhouse gas emissions by encouraging
reductions across all sectors of the economy, encouraging participation in the
full range of Climate Change Action Plan initiatives, and fostering
innovation. Participants in the program are required to identify and commit
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to actions that reduce greenhouse gas emissions. The program, in turn, gives
organizations early recognition for their reduction commitments; provides
technical assistance through consulting services, workshops, and guides; and
provides access to the program's centralized information system. At EPA,
the program is operated by the Air and Energy Policy Division within the
Office of Policy Planning and Evaluation. (Contact: Pamela Herman 202-
260-4407)
NICE3
The U.S. Department of Energy and EPA's Office of Pollution Prevention
are jointly administering a grant program called The National Industrial
Competitiveness through Energy, Environment, and Economics (NICE3). By
providing grants of up to 50 percent of the total project cost, the program
encourages industry to reduce industrial waste at its source and become more
energy-efficient and cost-competitive through waste minimization efforts.
Grants are used by industry to design, test, demonstrate, and assess the
feasibility of new processes and/or equipment with the potential to reduce
pollution and increase energy efficiency. The program is open to all
industries; however, priority is given to proposals from participants in the
pulp and paper, chemicals, primary metals, and petroleum and coal products
sectors. (Contact: DOE's Golden Field Office, 303-275-4729)
VIH.C. Trade Association/Industry Sponsored Activity
Industry compliance assurance activities have primarily been aimed at the
transportation safety requirements of the Department of Transportation, the
Occupational Safety and Health Administration, and the U.S. Coast Guard.
However, "the trade associations anticipate providing increased
environmental compliance assistance activities with the development of the
wastewater Effluent Guidelines.
VIII.C.1. Environmental Programs
Industry Working Group on Deicing
A deicing working group formed by the American Association of Airport
Executives and the Airports Association Council International studied the
use of deicing chemicals on aircraft and the feasibility of deicing facilities
away from airport gates and to provide information to both industry members
and the federal government on ways in which deicing operations can be
improved upon. As part of their investigation, the working group sent out
surveys to the major airports to determine which deicing procedures and
chemicals are being used by the industry. Some of the survey questions
related to environmental effects of deicing and recovery, reuse, and recycling
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of waste deicer. The results of the survey indicated that a number of air
carriers are using alternative chemicals, and have constructed remote deicing
facilities with deicer recovery systems. (Contact: David Jeffrey, American
Association of Airport Executives, 703-824-0500 ext.136)
Global Environmental Management Initiative
The Global Environmental Management Initiative (GEMI) is made up of a
group of leading companies dedicated to fostering environmental excellence
by business. GEMI promotes a worldwide business ethic for environmental
management and sustainable development to improve the environmental
performance of business through example and leadership. In 1994, GEMI's
membership consisted of about 30 major corporations.
National Pollution Prevention Roundtable
The National Pollution Prevention Roundtable published The Pollution
Prevention Yellow Pages in September 1994. It is a compilation of
information collected from mail and telephone surveys of state and local
government pollution prevention programs. (Contact: Natalie Roy 202-543-
7272). State programs listing themselves as having expertise in pollution
prevention related to transportation equipment cleaning were not identified
in The Pollution Prevention Yellow Pages; however, areas of expertise are
listed as SIC categories which do not include a specific category for
transportation equipment cleaning.
Chemical Manufacturers Association
The Chemical Manufacturer's Association funds research on issues of
interest to their members particularly in support of their positions on
proposed or possible legislation. They recently funded a study to
characterize the environmental fate of organochlorine compounds.
Responsible Care® Program
The Responsible Care® Initiative of the Chemical Manufacturer's
Association requires all members and partners to continuously improve their
health, safety, and environmental performance in a manner that is responsive
to the public. Launched in 1988, the Responsible Care® concepts are now
being applied in 36 countries around the world. Responsible Care® is a
comprehensive, performance-oriented initiative composed often progressive
Guiding Principles and six board Codes of Management Practices. These
Management Practices cover all aspects of the chemical industry's
operations, from research to manufacturing, distribution, transportation, sales
and marketing, and to downstream users of chemical products. Through
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Responsible Care®, CMA members and partners gain insight from the public
through, among other means, a national Public Advisory Panel and over 250
local Community Advisory Panels. This, coupled with the fact that
participation in Responsible Care® is an obligation of membership with the
Chemical Manufacturer's Association, make this performance improvement
initiative unique. The Synthetic Organic Chemical Manufacturer's
Association whose membership consists of smaller batch and custom
chemical manufacturers with typically fewer than 50 employees and less than
$50 million in annual sales, encourages its members to achieve continuous
performance improvement in their health, safety, and environmental
programs through implementation of the chemical industry's Responsible
Care® initiative. SOCMA is a partner in Responsible Care®.
ISO 9000
ISO 9000 is a series of international total quality management guidelines.
After a successful independent audit of their management plans, firms are
qualified to be ISO 9000 registered. In June of 1993, the International
Standards Organization created a technical committee to begin work on new
standards for environmental management systems. The new standards are
called ISO 14000 and are expected to be issued in 1996.
VHI.C.2. Summary of Trade Associations
Truck Transport
National Tank Truck
Carriers
2200 Mill Rd.
Alexandria, VA 22314
Phone: (703) 838-1960
Fax: (703) 684-5753
Members: 260
Staff: 7
Budget: $1,000,000
Contact: John Conely
The National Tank Truck Association (NTTC), founded in 1945, represents
for hire tank truck carriers of liquid and dry-bulk commodities, chemicals,
food processing commodities, and petroleum and related products. The
NTTC provides its members with periodic bulletins on the latest changes in
federal, state and local regulations, as well as political and market issues. In
addition, the NTTC conducts research and sponsors annual training schools.
NTTC publications include the annual Cargo Tank Hazardous Materials
Regulations, a monthly Newsletter, an annual Hazardous Commodity
Handbook, and an annual National Tank Truck Directory, in addition to
pamphlets and books. The NTTC holds a general conference each May, a
Cargo Tank Maintenance Seminar each October, and special seminars on
timely topics. A committee has been formed that will deal specifically with
tank cleaning issues.
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Rail Transport
American Trucking Associations
2200 Mill Rd.
Alexandria, VA 22314
Phone:(703)838-1844
Fax: (703) 684-5720
Members: 4100
Staff: 300
Budget: $35,000,000
Contact: Allen Schaeffer
The American Trucking Associations (ATA), founded in 1933, represents
motor carriers, suppliers, state trucking associations, and national
conferences of trucking companies. The ATA works to influence the
decisions of federal, state, and local government bodies to promote increased
efficiency, productivity, and competitiveness in the trucking industries. ATA
promotes highway and driver safety, supports highway research projects, and
studies technical and regulatory problems of the trucking industry. In
addition, the association provides its members with a guide to federal and
state regulations and offers comprehensive accounting service for all size
carriers. An information center containing numerous ATA and other
publications is available to members and others.
Railway Progress Institute
700 N. Fairfax Street
Alexandria, VA 22314
Phone: (703) 836-2332
Fax: (703) 548-0058
Members: 150
Staff: 7
Contact: Robert Mathews
Founded in 1908, the Railway Progress Institute (RPI) is comprised of
railway and rapid transit rail equipment and supply companies. The RPI
promotes the interests of its membership and, the American railroad system
in general, before federal agencies and Congress. The RPI publishes an
annual report and the bimonthly Railway Progress News, a newsletter
reporting industry events.
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Association of American Railroads
Library Room 5800
50 F Street, NW
Washington, D.C. 20001
Phone: (202) 639-2280
Fax: (202) 639-2986
Members: 110
Staff: 745
Contact: Robert Fronczak
The Association of American Railroads functions as the coordinating and
research agency of the American railway industry. Membership is
comprised of the larger, Class I railroads. Focus areas include: railroad
operation and maintenance, statistics, medical problems, cooperative
advertising and public relations, rates, communication, safety, and testing of
railroad equipment. The AAR was founded in 1934 and maintains a library
of current and historical volumes and periodicals. The AAR also operates
an on-line database of all rail cars, trailers, and containers used in North
America called Universal Machine Language Equipment Register.
Publications include the quarterly Official Railway Equipment Register, the
biweekly Rail News Update, and the periodically published Railroad Facts.
The AAR also publishes studies, statistical reports, and general information
publications. Because the membership consists of the railroads and not the
rail carriers, the environmental focus is primarily aimed at the effects of the
railroad ties and contaminated soils on the environment. Tank car and
equipment cleaning is of a lessor concern to the membership.
Ship and Barge Transport
American Waterways Operators
1600 Wilson Blvd.
Suite 1000
Arlington, VA 22209
Phone: (703) 841-9300
Fax: (703) 841-0389
Members: 305
Staff: 25
Budget: $2,000,000
Contact: Robert O'Niell
Founded in 1944, the American Waterways Operators (AWO) consists of
towboat, tugboat, and barge operators, as well as the shipyards that build and
repair those vessels. The AWO represents the industry before government
bodies. Committees include Inland Dry Sector, Inland Liquid Sector,
Coastal Sector, and Harbor Services Sector. In addition, the American
Waterways Shipyard Conference (AWSC) was organized within AWO to
represent U.S. Second Tier (small and medium sized) commercial shipyards.
Tank barge cleaning issues are handled by the AWSC. The association
provides technical assistance in the form of publications and seminars. Most
assistance activities are aimed at improving safety in the industry. The
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AWSC worked with the U.S. Coast Guard to publish Safety Guidelines for
Tank Vessel Cleaning Facilities, which will be used by the industry and as
a guide manual for inspectors. Other publications include an annual report,
a biweekly AWO Letter, Action Bulletin and Information Bulletin, and an
annual membership directory.
Inland Rivers, Ports and Terminals, Inc.
204 E. High Street
Jefferson City, MO 65101
Phone:(314)634-2028
Fax:(314)634-2028
Air Transport
Members: 165
Contact: Kathy Pabst
Founded in 1974, the Inland Rivers, Ports and Terminals, Inc. (IRPT) is a
non-profit corporation representing port and terminal owners/operators, port
authorities, towing companies, and other river related businesses. The IRPT
promotes the growth of inland rivers, ports and terminals commerce through
the exchange of information and coordinated action among its members.
Activities include the review of impending regulations, dissemination of
interpretations of regulations, and periodic meetings which include
presentations on issues effecting the industry. Publications include a weekly
News Bulletin; an annual membership directory; and Waterways and
Transportation Review, an open forum for articles pertaining to research,
opinions, operations, policies, strategies, and methodologies relating to the
waterways industry. IRPT assistance to members has not focused on
environmental issues, however, more environmental compliance assistance
is expected to be provided as it becomes more of a concern to the
membership.
American Association of Airport Executives
4212 King Street
Alexandria, VA 22302
Phone: (703) 824-0500
Fax: (703) 820-1395
Members: 4,000
Staff: 25
Budget: $4,100,000
Contact: David Jeffrey
The American Association of Airport Executives (AAAE) is comprised of
airport management personnel and representatives of companies serving the
civil airport industry. The AAAE sponsors educational seminars, conducts
examinations and maintains a speakers' bureau. Assistance in complying
with environmental regulations is provided in the form of regulation
interpretations, training seminars, and manuals. Environmental compliance
assistance as focused on the storm water rules and has not yet been specific
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to aircraft cleaning and deicing operations. Publications are the bimonthly
Airport Executive Magazine and the Airport Report Newsletter. Separate
yearly conferences are on national airports, legislative issues (semiannual),
international facilities, and general annual issues.
Airports Association Council International
1220 19th Street
NW, Suite 200
Washington, D.C. 20036
Phone: (202) 293-8500
Fax:(202)331-1362
Members: 235
Staff: 20
Contact: Bonnie Wilson
The Airports Association Council International (AACI) is comprised of
operators of public airport facilities. The group also includes government
bodies that own and operate major airports. The association provides
compliance assistance to members through seminars, meetings, conferences,
regulation interpretations, and manuals. One day conferences are frequently
held on environmental management and auditing techniques. The
association's environmental compliance assistance activities have not yet
included aircraft cleaning and deicing, but assistance is expected to be
offered if rules are put in place. Committees include planning and
environmental, safety and security, and U.S. government affairs.
Publications are the weekly Airport Highlights, the annual Worldwide
Airport Traffic Report, and the Airport Environmental Management
Handbook. The AACI holds an annual meeting in September or October.
National Air Transport Association
4226 King Street
Alexandria, VA 22302
Phone: (703) 845-9000
Fax: (703) 845-8176
Members: 1,945
Staff: 20
Contact: Andrew Cebula
The National Air Transport Association (NATA) represents the interests of
aviation services companies such as fixed-base operators and on-demand air
taxis. NATA provides compliance assistance to members in the form of
guidelines, explanations of regulations, and seminars. Most of NATA's work
relates to Federal Aviation Administration regulations, however,
environmental services are also provided. Environmental aspects of deicing
and aircraft cleaning are not a major focus, because the membership does not
include the carrier companies, however, some fixed-based operators carry
out deicing operations. Publications include an annual membership
directory, an annual report, and the monthly A TAnews.
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Air Transport Association of America
1709 New York Ave., NW
Washington, D.C. 20006
Phone: (202) 626-4000
Members: 22
Staff: 125
Contact: Donald Minnis
The ATA is comprised of airlines engaged in transporting persons, goods, or
mail by aircraft. Departments include government affairs, industry services,
and technical services. Publishes annual Air Transport as well as fact sheets,
press releases, studies, speeches, and references pertaining to air transport.
The ATA holds quarterly meetings.
General Transport
Independent Liquid Terminals Association
1133 15th St., NW, Suite 650
Washington, D.C. 20005
Phone: (202) 659-2301
Fax: (202) 466-4166
Members: 82
Staff: 7
Budget: $600,000
Contact: John Prokop
Independent terminal companies that handle, transfer, and store bulk liquid
commodities on a "for hire" basis are members of the Independent Liquid
Terminals Association (ILTA). Member operations include deep water and
barge terminals for the storage of chemicals, petroleum, fertilizers, and basic
bulk liquid food products such as animal fats and vegetable oils, molasses,
and spirits. The ILTA advises members on pending regulation and
legislation, promotes the exchange of information among members, and
investigates opportunities for increased safety and efficiency in handling
increasing varieties of liquid products. The ILTA has task forces on
Environment, Safety, and Training. Publications include an annual Directory
of Bulk Liquid Terminals and Storage Facilities and a weekly ILTA
Newsletter addressing federal and state legislation and regulation. The ILTA
has an annual conference/trade show.
September 1995
57
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Sector Notebook Project
Transportation Equipment Cleaning
Association of Waste Hazardous
Materials Transporters
2200 Mill Rd.
Alexandria, VA 22314
Phone: (703) 838-1703
Fax: (703) 549-9570
Members: 65
Staff: 2
Contact: Cynthia Hilton
The Association of Waste Hazardous Materials Transporters (AWHMT) is
affiliated with the American Trucking Association. It represents companies
that transport waste hazardous materials including, PCBs, radiation, and
hazardous and industrial wastes, by truck and rail. The Association is a not-
for-profit organization that promotes practices and performance standards
that minimize risks to the environment, public health and safety; develops
educational programs to expand public awareness about the industry; and
contributes to the development of effective laws and regulations governing
the industry. AWHMT publishes an annual directory of transporters and
meets three times per year.
September 1995
58
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Sector Notebook Project
Transportation Equipment Cleaning
IX. CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS/BIBLIOGRAPHY
For further information on selected topics within the transportation
equipment cleaning industry a list of contacts and publications are provided
below:
Contacts3
Name
Virginia Lathrop
Gina Matthews
Ann Codrington
Joseph Delevanko
John Dickinson
Cynthia Hutchinson
Organization
EPA/OECA
EPA/OW
EPA/OSWER
DOT
EPA Region IV
EPA Region VII
Telephone
(202) 564-7057
(202) 260-6036
(202) 260-4777
(202) 366-4484
(404) 347-7603
(913)551-7478
Subject
Regulatory requirements and compliance
assistance
TECI industry size, distribution,
economics, pollutant releases, effluent
guidelines, and waste water treatment
operations
Regulatory requirements (RCRA)
Regulatory requirements (SFTA)
Inspector experienced in inspections of
rail tank car cleaning facilities
Experience in inspections of rail tank car
cleaning facilities
OECA: Office of Enforcement and Compliance Assistance
OW: Office of Water
OSWER: Office of Solid Waste and Emergency Response
DOT: Department of Transportation
CWA: Clean Water Act
RCRA: Resource Conservation and Recovery Act
General Industry Profile
1993 Screener Questionnaire of the Transportation Equipment Cleaning Effluent Guidelines, U.S.
EPA Office of Water, Engineering and Analysis Division, Washington, D.C., 1994.
Preliminary Data Summary for the Transportation Equipment Cleaning Industry, U.S. EPA, Office
of Water Regulations and Standards, September 1989.
Source Assessment: Rail Tank Car, Tank Truck, and Drum Cleaning, State-of-the-Art, Monsanto
Research Corp, Dayton, Ohio, prepared for the U.S. EPA Industrial Environmental Research
Laboratory, Cincinnati, Ohio, April, 1978.
a Many of the contacts listed above have provided valuable background information and comments during the
development of this document. EPA appreciates this support and acknowledges that the individuals listed do not
necessarily endorse all statements made within this notebook.
September 1995
59
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Sector Notebook Project
Transportation Equipment Cleaning
Waste Minimization Assessment for a Manufacturer of Rebuilt Railway Cars and Components, F.
William Kitsch and Gwen P. Looby, University City Science Center, Philadelphia, PA and U.S.
EPA Risk Reduction Engineering Laboratory, Cincinnati, Ohio, July, 1991. EPA/600/M-91/017.
Process Descriptions and Chemical Use Profiles
Report of the American Association of Airport Executives - AD HOC Working Group on Deicing,
American Association of Airport Executives, Alexandria, Virginia, 1993. (Contact: David Jeffrey,
American Association of Airport Executives, 703-824-0500 ext.136)
Safety Guidelines for Tank Vessel Cleaning Facilities, first edition, American Waterways Shipyard
Conference, Arlington, Virginia, June, 1992. (Contact: Robert O'Neill, American Waterways
Shipyard Operators, 703-841-9300)
Regulatory Profile
Sustainable Environmental Law, Environmental Law Institute, West Publishing Co., St. Paul, Minn.,
1993.
September 1995
60
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APPENDIX A - INSTRUCTIONS FOR DOWNLOADING NOTEBOOKS
Electronic Access to the Sector Notebooks via
the Enviro$en$e World Wide Web (E$WWW) and
the Enviro$en$e Bulletin Board System (E$BBS)
The Sector Notebooks are available through two electronic systems, the Enviro$en$e
Bulletin Board System (via modem connection), and the Enviro$en$e World Wide Web (via
Internet). The Enviro$en$e Communications Network is a free, public, interagency-supported
system operated by EPA's Office of Enforcement and Compliance Assurance and the Office of
Research and Development. The Network allows regulators, the regulated community, technical
experts, and the general public to share information regarding: pollution prevention and innovative
technology; environmental enforcement and compliance assistance; laws, executive orders,
regulations and policies; points of contact for services and equipment; and other related topics. The
Network welcomes receipt of environmental messages, information and data from any public or
private person or organization. This document first provides summary information on E$WWW
access, then provides information on downloading protocols from within the E$BBS.
A. ACCESS THROUGH ENVIRO$EN$E WORLD WIDE WEB
To access the Sector Notebooks through the Enviro$en$e World Wide Web, set
your World Wide Web Browser to the following address:
WWW/INTERNET ADDRESS: http://wastenot.inel.gov/envirosense/
HOTLINE NUMBER FOR E$WWW ONLY: 208-526-6956
EPA E$WWW MANAGER: Myles Morse, 202-260-3161
From the Enviro$en$e home page, click on "Compliance and Enforcement" to
obtain instructions on how to access the Sector Notebooks and how to provide comments.
Names, e-mail addresses, and telephone numbers will also be provided should you require
assistance. The same documents listed below under the E$BBS instructions are available
on the E$WWW.
B. ACCESS THROUGH THE ENVIRO$EN$E BULLETIN BOARD SYSTEM -
Instructions for Connecting, Registering and Downloading Notebooks
E$BBS MODEM CONNECTION NUMBER: 703-908-2092
HOTLINE FOR E$BBS ONLY: 703-908-2007
MANAGER: BBS Platform: Louis Paley, 202-260-4640
The following instructions are condensed from longer documents that provide
information on the full features of the Enviro$en$e Bulletin Board. Further documentation
is available on-line in the files that are listed at the end of this Appendix.
A-l
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STEP 1. ESTABLISHING MODEM SETTINGS
Connecting to the ENVIRO$EN$E BBS is done using a modem and
communications software. The modem can be either an internal or external model
connected directly to your computer or part of a modem pool that is accessible through your
Local Area Network (LAN) system. The communications software (e.g.. CrossTalk,
ProComm, QModem, Microphone, etc.) is what allows you to access and control your
modem. Your software needs to be set to the values noted below (many of these settings
are the standard defaults used):
• Telephone number - 703-908-2092 (Tip: Be sure you have entered
the appropriate dialing prefix; e.g., 9 for an outside line, 1 for long
distance...)
• Baud rate - up to 14,400 BPS is supported (always select the highest
speed which YOUR modem will support).
Terminal Emulation - BBS, ANSI, VT-100, VT-102 etc. (Tips:
Do not use TTY. After you log in, if you see screen characters appear on
the lines where you need to enter information, chances are that you need to
properly set your terminal emulation. The emulation can normally be reset
before or during communication with Enviro$en$e).
Data Bits - 8 (Eight).
Stop Bits - 1 (One).
• Parity - None.
• Transfer Protocols - ZModem, YModem, XModem, HS/Link,
BiModem, ASCII (text files only). If your communications software
supports ZModem, this will increase upload/download efficiency. You
must select the same protocol that BOTH your communications software
and the BBS support so that they can "talk the same language" when
sending and receiving files.
• Error correction/data compression protocols - v.32, v.42, and
other older, hardware-dependent ones are supported.
Refer to your communications software manual on how to set and save the
communication parameters noted above (these will generally be the default). Also check to
make sure you know where the communications software will send the files you
download. Due to document sizes it is best not to download Sector Notebooks to floppy
disks.
A-2
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STEP 2. CONNECTING AND REGISTERING
/• ' ,
•" Connect to E$BBS via a modem, using communications software set to the
above settings by dialing:
(703) 908-2092
NOTE: EPA Employees can access E$ directly via LAN from the Agency Lan
Services Menu or Icon and then follow the instructions below. The end of this
document lists additional resources for accessing E$BBS through the LAN.
• Once you are in the BBS, hit the ENTER/RETURN key twice (2) to accept
the default values for the screen.
• on successive pages, type your first name and hit
ENTER/RETURN; type your last name and hit ENTER/RETURN;
and type your password (if you have NOT registered yet,
make one up, and remember it for subsequent logons to
E$) and hit ENTER/RETURN; and
• Register (first time only) and immediately receive access to the BBS
for 120 minutes per day;
Type responses to the Registration questions, and hit
ENTER/RETURN to begin using ENVIRO$EN$E. (Tip: the last
registration question is Country? )
You may need to hit ENTER/RETURN several times to move past System
News and Alert messages.
STEP 3. DOWNLOADING SECTOR NOTEBOOKS
The files that appear on the following table can be downloaded from E$. Most files
cannot be viewed on-screen within the E$BBS. As indicated on the following table, each
document appears in several formats - WordPerfect 5.1 (PC), WordPerfect 6.1 (PC),
Microsoft Word 5. la (Mac) or WordPerfect 2.0 (Mac). Please note that the quality of
formatting and graphics is highest in the file version in which the notebook was originally
created. The high quality versions are underlined on the following list of filenames.
Information on Macintosh/Microsoft Word Files
Available Macintosh files are not compressed. The files are easily identified by the seventh
and eighth position in the filename - which is "MA." The extension They can be directly
downloaded and read using Microsoft Word 5.la, or within other word processing
software that supports conversion of Microsoft Word 5.la documents. Conversion to
other programs may alter formatting and graphics quality.
Information on PC/WordPerfect Files
The WordPerfect files are all compressed ("zipped" files ending with the .ZIP extension)
files that need to be decompressed ("unzipped") after they are downloaded. The notebooks
that are available in WP 5.1 and WP 6.0 are zipped together (this is why the filenames on
the following table are the same). When these files are downloaded and "unzipped," you
will have a version with the extension ".WP5" and one with ".WP6".
A-3
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Available Notebooks, Filenames and File Formats
Profile of the Industry PC WP 5.1
Dry Cleaning DRYCLNSN.ZIP
Electronics and Computer ELECMPSN.ZIP
Wood Furniture and Fixtures WDFURNSN.ZIP
Inorganic Chemical INRGCHSN.ZIP
Iron and Steel IRONSTSN.ZIP
Lumber and Wood Products LMBRWDSN.ZIP
Fabricated Metal Products FABMETSN.ZIP
Metal Mining METMINSN.ZIP
Motor Vehicle Assembly MOTVEHSN.ZIP
Nonferrous Metals NFMETLSN.ZIP
Non-Fuel, Non-Metal Mining NOMTMISN.ZIP
Organic Chemical ORGCHMSN.ZIP
Petroleum Refining PETREFSN.ZIP
Print ing PRINTGSN.ZIP
Pulp and Paper PULPPASN.ZIP
Rubber and Plastic RUBPLASN.ZIP
Stone, Clay, Glass and Concrete STCLGLSN.ZIP
Transportation Equipment Cleaning TRNSEQSN.ZIP
PC WP 6.1
DRYCLNSN.ZIP
INRGCHSN.ZIP
IRONSTSN.ZIP
Macintosh
Worcj^ 5.1a/WP2.0
DRYCLNMA.WP2
ELECMPMA.WD5
WDFURNMA.WD5
INRGCHMA.WP2
IRONSTMA.WP2
LMBRWDMA.WD5
FABMETMA.WD5
MBTMINMA.WP5
MOTVEHMA.WD5
NFMETLMA.WD5
NOMTMIMA.WD5
ORGCHMSN.ZIP
PETREFSN.ZIP
PRINTGSN.ZIP
PULPPASN.ZIP
ORGCHMMA
PETREFMA
PRINTGMA
PULPPAMA
RUBPLAMA
,WP2
.WP2
.WP2
.WP2
.WD5
STCLGLMA.WP5
TRNSEOSN.ZIP TRNSEQMA. WP2
Note: Underlined files contain the highest quality format/graphics
STEP 3 CONTINUED - PROCEDURES FOR DOWNLOADING
From the E$ Main Menu, select "D" to Download then hit ENTER/RETURN.
• Type in the Sector Notebook filename from above that you would like to select for
downloading and hit ENTER/RETURN.
• The system will ask you to select a file transfer protocol. Select the file transfer
protocol that matches what you have selected within your PC communications
software (ZModem is recommended) and hit ENTER/RETURN. (Tip: ZModem
users may also be allowed to enter more than one filename to download more than
one document at a time. Simply continue to enter a new filename each time a new
filename prompt appears on the screen. This option is disabled for other users.)
• At this point, you may
begin downloading by hitting ENTER/RETURN. This should begin the
download if you are using the ZModem transfer protocol. If you don't see
information on the screen showing the progress of the download, follow the
next step.
• If the download does not begin after following the last step, you need to tell your
communications software to start receiving the file. To do this, look for a
"RECEIVE" icon or command on your communications software menu and activate
it This tells your software to begin the download.
A-4
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STEP 4
When the download is completed, a message will appear on the screen to confirm
transmission.
The downloaded file will appear in the folder or directory that you defined in your
communications software.
Repeat the above procedure to download other notebooks.
Macintosh users can logoff using the [G]oodbye command from the main menu
THE FOLLOWING STEP MUST BE TAKEN BY ALL USERS THAT
HAVE DOWNLOADED ZIPPED FILES (files with a ".ZIP" filename
extension) FROM E$. MACINTOSH USERS CAN SKIP THIS
STEP.
In order to read the zipped file(s) you have downloaded, you
must download the decompression software required to
"unzip" your files. To download the decompression software, follow
the same download instructions given above. Type in the filename
"PKZ204G.EXE" and hit ENTER/RETURN. You only need to download
this file to your hard drive once.
Logoff using the [G]oodbye command from the main menu.
To end the phone connection, the user should use the "hang up" or "terminate call"
option provided with your communications software.
DECOMPRESSING ".ZIP'D" DOWNLOADED FILES (PC Only -
Macintosh files do not need to be decompressed)
After you have downloaded a compressed (".ZIP") file to your PC, you must
decompress it to its original format and size by using the "PKUnzip" file which you
downloaded at the beginning of Step 3. The file which you downloaded'
"PKZ204G.EXE", contains PKZip.EXE and PKUnzip.EXE files. PKUNZIP will
decompress the file, returning it to its original size and format as if it had never been
compressed or transmitted over the BBS. To use the PK commands (pkunzip.exe &
pkzip.exe), you must be at the DOS prompt (third-party software interfaces exist for
Windows). For details on how to use either command, simply type the command at the
DOS prompt (without any parameters, i.e., just type "PKUNZIP") and hit
ENTER/RETURN. Since parameters are required for the PKs to work they will
automatically go into help mode and give you a brief explanation of how they work If a
user needs more direction, there is full documentation included in the PKZ204G EXE in
the "Hints" file.
To decompress any file, use PKUNZIP.EXE by taking the following steps:
Go to the DOS C: prompt and type PKUNZIP.EXE; then,
Type "PKUNZIP [Filename]" (e.g.. the filename and the path of the
compressed file you wish to decompress).
NOTE: after the paired files are unzipped, two files will exist, one with the
extension ".WP5" and one with the extension ".WP6.
A-5
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C. COMMENTING OR PROVIDING ADDITIONAL INFORMATION ON THE
SECTOR NOTEBOOKS VIA E$BBS
Comments on the Sector Notebooks, or supplemental documents of interest can be
uploaded to the Enviro$en$e BBS. Follow upload instructions that appear on the screen,
or look at the instructions for compressing and uploading documents. The instructional
documents are listed below under Section D of this Appendix. All documents that you
upload will be publicly accessible, and should contain a short abstract (less than 50 words)
that describes the document. It is recommended that this abstract contain the words "Sector
Notebook Comments," the title of the Notebook that the comments are directed toward,
and the words "SIC «Insert applicable 2-digit SIC code»".
NOTE: To help the system operator know what you've uploaded and where it
should be put within the BBS, it is helpful to send a message to the system
operator. Before logging out of E$, you will be given the option to comment to the
system operator (Sysop). Please indicate what files you have sent, and that the
comments or supplemental documents should be placed in Directory 51 - "Sector
Compliance Information and Notebooks." Messages can also be sent to the Sysop
from the main menu using the Message option.
D. ADDITIONAL RESOURCE DOCUMENTS AVAILABLE ON E$BBS
The following files can be viewed from the "Bulletins" section of E$BBS main
menu. To receive these documents electronically, the files can be downloaded ("and
viewed) from Directory #160 (utilities). If you would like to download these files, follow
the same procedures that are outlined (Section C). The directions for direct dial modem
users are different than the directions for EPA LAN users. How you have accessed the
E$BBS determines which of the paired files below that you should follow.
Entered E$
via Modem
CONREGWP.TXT
FINDVIEW.TXT
CONVCOMP.TXT
DNLDTXWP.TXT
DNLDZPWP.TXT
UPLOADWP.TXT
SNHOWTO.TXT
Entered E$
EPA LAN
CNREGLAN.TXT
FNDVWLAN.TXT
CVCMPLAN.TXT
DNLTXLAN.TXT
DNZPLAN.TXT
UPLDLAN.TXT
SNHOWLAN.TXT
Description of File
How to Connect and Register on the E$BBS
via Modem
Finding and Viewing Files from E$BBS via
Modem
Converting, Compressing & Uncompressing
Files via Modem
•Flagging and Downloading "Uncompressed"
Files from E$BBS
Flagging and Downloading "Compressed"
Files from E$BBS
Directions for Uploading Files via Modem
to the E$BBS
Contains this document "Appendix A -
Downloading Instructions"
A-6
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To order other EPA Sector Notebooks
use the form below
United States Government
INFORMATION
Order Processing Code:
*3212
Charge your order.
It's easy!
Fax your orders (202) 512-2250
Phone your orders (202) 512-1800
Qty.
Stock Number
055-000-00512-5
055-000-00513-3
055-000-00518-4
055-000-00515-0
055-000-00516-8
055-000-00517-6
055-000-00519-2
055-000-00520-6
055-000-00521-4
055-000-00522-2
055-000-00523-1
055-000-00524-9
055-000-00525-7
055-000-00526-5
055-000-00527-3
055-000-00528-1
055-000-00529-0
055-000-00514-1
Title
Dry Cleaning Industry, 104 pages
Electronics and Computer Industry, 160 pages
Fabricated Metal Products Industry, 164 pages
Inorganic Chemical Industry, 136 pages
Iron and Steel Industry, 128 pages
Lumber and Wood Products Industry, 136 pages
Metal Mining Industry, 148 pages
Motor Vehicle Assembly Industry, 156 pages
Nonferrous Metals Industry, 140 pages
Non-Fuel, Non-Metal Mining Industry, 108 pages
Organic Chemical Industry, 152 pages
Petroleum Refining Industry, 160 pages
Printing Industry, 124 pages
Pulp and Paper Industry, 156 pages
Rubber and Plastic Industry, 152 pages
Stone, Clay, Glass and Concrete Industry, 124 pages
Transportation Equipment Cleanina Industry. 84 paaes
Wood Furniture and Fixtures Industry, 132 oaaes
Price
Each
$ 6.50
"11.00
S11.00
$ 9.00
* 8.00
* 9.00
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M1.00
* 9.00
* 6.50
»11.00
*11.00
$ 7.50
$11.00
*11.00
$ 7.50
$ 5.50
* 8.00
Total for Publications
Total
Price
The total cost of my order is $_
Price includes regular shipping and handling and is subject to change.
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(Please type or print)
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9/95
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Important Include completed order form with your remittance
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Mail to: Superintendent of Documents
P.O. Box 371954, Pittsburgh, PA 15250-7954
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