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
Transportation Equipment Cleaning
                                                                  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
September 1995

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Sector Notebook Project
Transportation Equipment Cleaning
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.
 September 1995

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 Sector Notebook Project
     Transportation Equipment Cleaning
                        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)
September 1995

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 Sector Notebook Project
Transportation Equipment Cleaning
         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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 Sector Notebook Project
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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
  September 1995
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 Sector Notebook Project
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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.
September 1995

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 Sector Notebook Project
Transportation Equipment Cleaning
 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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Transportation Equipment Cleaning
                     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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                                 Transportation Equipment Cleaning
 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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                                       Transportation Equipment Cleaning
    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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         Transportation Equipment Cleaning
                    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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 Sector Notebook Project
           Transportation Equipment Cleaning
 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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        Transportation Equipment Cleaning
                    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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          Transportation Equipment Cleaning
                    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.
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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.
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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.
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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.
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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

-------
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
* 10.00
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



















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    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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