United States
Environmental Protection
Agency
Enforcement And '•'
Oomjbiiahce Assurance
(2223A)
Profile Of The Ground
Transportation Industry^-
Trucking, Railroad And Pipeline
NOTEBOOKS
EFA Office Of Compliance Sector Notebook:!roje|S:
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
f 8 J997
THE ADMINISTRATOR
Message from the Administrator
Since EPA's founding over 25 years ago, our nation has made tremendous progress in protecting
public health and our environment while promoting economic prosperity. Businesses as large as
iron and steel plants and those 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
fire. Our skies are clearer. American environmental technology and expertise are in demand
around 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.
The Environmental Protection Agency has undertaken its Sector Notebook Project to compile,
for major 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 an extensive series covering other industries, the notebook you hold in your hand is
the result.
These notebooks will help business managers to understand better their regulatory requirements,
and learn more about how others in their industry have achieved 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 we together 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 haj4 in hand.
Carol M. Browner
R*cycl«d/R*cycUbl* 'Printed with Vegetable Ol Based Inks on 100% Recycled Paper (40% Postconsumer)
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Ground Transportation Industry
Sector Notebook Project
EPA/310-R-97-002
EPA Office of Compliance Sector Notebook Project:
Profile of the Ground Transportation Industry
Trucking, Railroad, and Pipeline
September 1997
For sale by the U.S. Government Printing Office
Superintendent of Documents, Mail Stop: SSOP, Washington, DC 20402-9328
ISBN 0-16-049394-3
Office of Compliance
Office of Enforcement and Compliance Assurance
U.S. Environmental Protection Agency
401 M St., SW (MC 2221-A)
Washington, DC 20460
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Ground Transportation Industry
Sector Notebook Project
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), Science Applications International Corporation (McLean, VA), 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 document numbers is included at the end of this document.
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
8:00 a.m. to 4:30 p.m., EST, 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, and local governments, and the media from EPA's National
Center for Environmental Publications and Information at (800) 490-9198. 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 via Internet on the Enviro$en$e World
Wide Web. Downloading procedures are described in Appendix A of this document.
Cover photograph by Steve Delaney, EPA.
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September 1997
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Ground Transportation Industry
Sector Notebook Project
Sector Notebooks Contacts
The Sector Notebooks were developed by the EPA Office of Compliance. Questions relating to the
Sector Notebook Project can be directed to:
Seth Heminway, Coordinator, Sector Notebook Project
US EPA Office of Compliance
401 M St., SW (2223-A)
Washington, DC 20460
(202) 564-7017
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 Industry
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 Industry
EPA/310-R-95-018. Transportation Equipment Cleaning Ind.
EPA/310-R-97-001. Air Transportation Industry
EPA/310-R-97-002. Ground Transportation Industry
EPA/310-R-97-003. Water Transportation Industry
EPA/310-R-97-004. Metal Casting Industry
EPA/310-R-97-005. Pharmaceuticals Industry
EPA/310-R-97-006. Plastic Resin and Manmade Fiber Ind.
EPA/310-R-97-007. Fossil Fuel Electric Power Generation. Ind.
EPA/310-R-97-008. Shipbuilding and Repair Industry
EPA/310-R-97-009. Textile Industry
EPA/310-R-97-010. Sector Notebook Data Refresh, 1979
Contact
Joyce Chandler
Steve Hoover
Bob Marshall
Walter DeRieux
Maria Malave
Seth Heminway
Scott Throwe
Jane Engert
Anthony Raia
Jane Engert
Robert Lischinsky
Walter DeRieux
Tom Ripp
Ginger Gotliffe
Maria Eisemann
Maria Malave
Scott Throwe
Virginia Lathrop
Virginia Lathrop
Virginia Lathrop
Virginia Lathrop
Jane Engert
Emily Chow
Sally Sasnett
Rafael Sanchez
Anthony Raia
Belinda Breidenbach
Seth Heminway
Phone (202}
564-7073
564-7007
564-7021
564-7067
564-7027
564-7017
564-7013
564-5021
564-6045
564-5021
564-2628
564-7067
564-7003
564-7072
564-7016
564-7027
564-7013
564-7057
564-7057
564-7057
564-7057
564-5021
564-7071
564-7074
564-7028
564-6045
564-7022
564-7017
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Sector Notebook Project
GROUND TRANSPORTATION INDUSTRY
(SIC 40,42,46, AND 49)
TABLE OF CONTENTS
List of Exhibits vj
List of Acronyms vjj
I. Introduction to the Sector Notebook Project 1
A. Summary of the Sector Notebook Project 1
B. Additional Information 2
II. Introduction to the Ground Transportation Industry 3
A. Introduction, Background, and Scope of the Notebook 3
B. Industry Sectors Analyzed 3
1. Rail Transportation 3
2. Trucking 4
3. Pipelines 5
III. Rail Transportation 7
A. Characterization of the Rail Transportation Industry - 7
1 .Industry Characterization 7
2. Industry Size and Geographic Distribution 8
3. Economic Trends 10
B. Operations in the Rail Transportation Industry 12
1. Rail Car Refurbishing and Maintenance 12
2. Locomotive Maintenance 13
3. Transportation 13
C. Raw Material Inputs and Pollution Outputs : 13
1. Rail Car Refurbishing and Maintenance 13
2. Locomotive Maintenance 14
3. Transportation Operations 16
IV. Trucking 19
A. Characterization of the Trucking Industry 19
1. Industry Characterization 19
2. Industry Size and Geographic Distribution 21
3. Economic Trends 24
B. Operations in the Trucking Industry 26
1. Truck Terminals and Maintenance Facilities 26
2. Truck Washing 29
3. Tank Truck Cleaning 29
4. Transport Operations 30
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Ground Transportation Industry Sector Notebook Project
C. Raw Material Inputs and Pollution Outputs 30
1. Truck Terminals and Maintenance 30
2. Truck Washing 32
3. Tank Cleaning 32
4. Transport Operations 33
V. Pipelines 37
A. Characterization of Pipelines 37
1. Industry Characterization 37
2. Industry Size and Geographic Distribution 38
3. Economic Trends 40
B. Operations in the Pipeline Industry 43
1. Pigging 44
2. Pipeline Leaks 44
3. Pipeline Inspections 45
4. Glycol Dehydration Units 49
C. Pollution Outputs and Causes of Pipeline Leaks 50
1. Pipeline Failures 50
2. Glycol Dehydration - Inlet Separator 52
3. Breakout Tank Leakage 52
VI. Pollution Prevention/Waste Minimization 55
A. Introduction 55
B. Rail Transportation 55
1. Water Discharge 55
2. Oil 57
3. Waste from Maintenance and Repair Operations 58
4. Paint 59
5. Fueling 59
C. Trucking 60
1. Truck Terminal and Maintenance Facilities 60
2. Vehicle Washing 61
3. Stormwater Pollution Prevention 61
4. Alternatively-Fueled Vehicles 63
D. Pipelines 63
1. Direct Leak Detection Enhancements 63
2. Supervisory Control and Data Acquisition (SCADA) Systems 64
3. Hydrostatic Testing 64
4. Cathodic Protection 65
5. Smart Pigs 65
6. Breakout Tanks 66
7. Proper Training 66
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Ground Transportation Industry
Sector Notebook Project
VII. Summary of Applicable Federal Statutes and Regulations 67
A. General Description of Major Statutes 67
B. Industry Sector Specific Regulations 78
1. Rail Transportation 78
2. Trucking g2
3. Pipelines 84
C. Pending and Proposed Regulatory Requirements 88
VIII. Compliance and Enforcement History 89
A. Background gg
B. Compliance and Enforcement Profile Description 89
C. Industry Sector Compliance History 93
D. Comparison of Enforcement Activity Between Selected Industries 98
IX. REVIEW OF MAJOR LEGAL ACTIONS 103
A. Review of Major Cases 103
LRail • '.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'. 103
2. Trucking 104
3. Pipelines 105
B. Supplemental Environmental Projects (SEPs) 106
X. Compliance Activities and Initiatives ; 107
A. Sector-Related Environmental Programs and Activities 107
LRail .'.'".'.'.'.'.'.'.'.'.'.' 107
2. Trucking 107
3. Pipelines 109
B. EPA Voluntary Programs 110
C. Trade Association/Industry-Sponsored Activity 113
1. Railroad Tank Car Safety Research and Test Project 113
2. The North American Non-Accident Release Reduction Program 113
3. Environmental Compliance Handbook for Short Line Railroads 114
4. Environmental Training Publications and Videotapes 114
5. Pipeline Integrity Programs - Natural Gas and Hazardous Liquid One-Call
Systems 115
6. Summary of Trade Associations 116
XI. Resource Materials/Bibliography 12i
Appendix A: Instructions for Downloading this Notebook A-l
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Ground Transportation Industry Sector Notebook Project
List of Exhibits
Exhibit 1: Facility Size Distribution of Rail Industry 9
Exhibit 2: Line-Haul and Switching and Terminal Railroads 9
Exhibit 3: Geographic Distribution of Railroads in the United States 10
Exhibit 4: Tons Originated and Revenue by Commodity 11
Exhibit 5: Rail Car Refurbishing and Maintenance Process Material Input/Pollutant Output . . 14
Exhibit 6: Truck Types 20
Exhibit 7: Facility Size Distribution of Trucking Industry 22
Exhibit 8: Geographic Distribution of Trucking Industry Facilities 23
Exhibit 9: Share of Freight Revenues by Mode of Transportation 24
Exhibit 10: Typical Trucking Maintenance Facility 28
Exhibit 11: Hydrocarbons Emission Sources 33
Exhibit 12: Carbon Monoxide Emission Sources 34
Exhibit 13: Nitrogen Oxides Emission Sources 34
Exhibit 14: Process Material Input/Pollutant Output from Trucking Operations 35
Exhibit 15: Facility Size Distribution of Pipeline Industry 39
Exhibit 16: Geographic Distribution of Oil Pipelines 40
Exhibit 17: Natural Gas Delivery Infrastructure 42
Exhibit 18: Methods of Monitoring Pipelines 48
Exhibit 19: Hazardous Liquid Pipeline Incident Summary by Cause 51
Exhibit 20: Natural Gas Pipeline Incident Summary by Cause 51
Exhibit 21: Storm Water Pollution Prevention Flowchart 62
Exhibit 22: Clean Water Act Requirements Applicable to Railroads 80
Exhibit 23: Heavy-Duty Truck Engine Emission Standards 83
Exhibit 24: Five-Year Enforcement and Compliance Summary for Transportation Sectors ... 94
Exhibit 25: One-Year Enforcement and Compliance Summary for Transportation Sectors ... 95
Exhibit 26: Five-Year Enforcement and Compliance Summary by Statute for Transportation
Sectors 96
Exhibit 27: One-Year Enforcement and Compliance Summary for Transportation Sectors ... 97
Exhibit 28: Five-Year Enforcement and Compliance Summary for Selected Industries 99
Exhibit 29: One-Year Enforcement and Compliance Summary for Selected Industries 100
Exhibit 30: Five-Year Inspection and Enforcement Summary by Statute for Selected
Industries 101
Exhibit 31: One-Year Inspection and Enforcement Summary by Statute for Selected
Industries ^2
Exhibit 32: Supplemental Environmental Projects in the Transportation Industry 106
Sector Notebook Project vi September 1997
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Ground Transportation Industry
Sector Notebook Project
AAR-
AFS-
AGA-
AIRS-
ATA-
BIFs-
BOD-
CAA-
CAAA-
CERCLA-
CERCLIS -
CFCs-
CO-
COD-
CSI-
CWA-
D&B-
ELP-
EPA-
EPCRA-
FIFRA-
FINDS-
HAPs-
HSDB-
IDEA-
LDR-
LEPCs-
LERCs -
MACT-
MCLGs -
MCLs-
MEK-
MSDSs -
NAAQS-
NAFTA-
NAICS-
NCDB-
NCP-
NEIC-
NESHAP-
NO."
List of Acronyms
Association of American Railroads
AIRS Facility Subsystem (CAA database)
American Gas Association
Aerometric Information Retrieval System (CAA database)
American Trucking Associations
Boilers and Industrial Furnaces (RCRA)
Biochemical Oxygen Demand
Clean Air Act
Clean Air Act Amendments of 1990
Comprehensive Environmental Response, Compensation and Liability Act
CERCLA Information System
Chlorofluorocarbons
Carbon Monoxide
Chemical Oxygen Demand
Common Sense Initiative
Clean Water Act
Dun and Bradstreet Marketing Index
Environmental Leadership Program
United States Environmental Protection Agency
Emergency Planning and Community Right-to-Know Act
Federal Insecticide, Fungicide, and Rodenticide Act
Facility Indexing System
Hazardous Air Pollutants (CAA)
Hazardous Substances Data Bank
Integrated Data for Enforcement Analysis
Land Disposal Restrictions (RCRA)
Local Emergency Planning Committees
Local Emergency Response Commissions
Maximum Achievable Control Technology (CAA)
Maximum Contaminant Level Goals
Maximum Contaminant Levels
Methyl Ethyl Ketone
Material Safety Data Sheets
National Ambient Air Quality Standards (CAA)
North American Free Trade Agreement
North American Industrial Classification System
National Compliance Database (for TSCA, FIFRA, EPCRA)
National Oil and Hazardous Substances Pollution Contingency Plan
National Enforcement Investigations Center
National Emission Standards for Hazardous Air Pollutants
Nitrogen Dioxide
Sector Notebook Project
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Ground Transportation Industry
Sector Notebook Project
NOV - Notice of Violation
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
OSW - Office of Solid Waste
OSWER - 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
RPI - Railway Progress Institute
RSPA - Research and Special Programs Administration
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
SPCC - Spill Prevention Control and Countermeasure
TOC - Total Organic Carbon
TRJ - Toxic Release Inventory
TRIS - Toxic Release Inventory System
TCRIS - Toxic Chemical Release Inventory System
TSCA - Toxic Substances Control Act
TSDF - Treatment, Storage and Disposal Facility
TSS - Total Suspended Solids
UIC - Underground Injection Control (SDWA)
UST - Underground Storage Tanks (RCRA)
VOCs - Volatile Organic Compounds
Sector Notebook Project
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Ground Transportation Industry
Introduction
TRANSPORTATION INDUSTRY
(SIC 40, 42, 46, AND 49)
L INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT
LA. Summary of the Sector Notebook Project
Integrated environmental policies based upon comprehensive analysis of air,
water and land pollution are a logical supplement to traditional single-media
approaches to environmental protection. Environmental regulatory agencies
are beginning to embrace comprehensive, multi-statute solutions to facility
permitting, enforcement and 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. Recognition of the
need to develop the industrial "sector-based" approach within the EPA Office
of Compliance led to the creation of this document.
The Sector Notebook Project was originally initiated by the Office of
Compliance within the Office of Enforcement and Compliance Assurance
(OECA) to provide its staff and managers with summary information for
eighteen specific industrial sectors. As other EPA offices, states, the regulated
community, environmental groups, and the public became interested in this
project, the scope of the original project was expanded to its current form.
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 available. 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
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Ground Transportation Industry Introduction
coverage of activities that can be further explored based upon the citations
and references listed at the end of this profile. As a check on the information
included, each notebook went through an external review process. The Office
of Compliance appreciates the efforts of all those that participated in this
process who 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 IX 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
OECA's Office of Compliance plans to periodically review and update the
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
(2223-A), 401 M St., SW, Washington, DC 20460. Comments can also be
uploaded to the Enviro$en$e World Wide Web for general access to all users
of the system. Follow instructions in Appendix A for accessing this system.
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 industry sector described in this notebook approximates the
national occurrence of facility types within the sector. In many instances,
industries within specific geographic regions or states may have unique
characteristics that are not fully captured in these profiles. 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 already
covered, please contact the Office of Compliance at 202-564-2395.
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Ground Transportation Industry
Introduction
II. INTRODUCTION TO THE GROUND TRANSPORTATION INDUSTRY
This section provides background information on the size, geographic
distribution, employment, production, sales, and economic condition of the
ground transportation industry. Facilities described within this document are
described in terms of their Standard Industrial Classification (SIC) codes.
D.A. Introduction, Background, and Scope of the Notebook
This notebook pertains to the transportation industry as classified by the
Office of Management and Budget (OMB) under Standard Industrial
Classification (SIC) codes 40 (Rail Transportation); 42 (Trucking); and 46,
4922-4924 (Pipelines). Where possible, data are specific to sub-divisions of
these SIC codes. In many cases, information about the industries (i.e., rail,
trucking, and pipeline) does not directly correlate to SIC distinctions. This is
due to various factors, including different reporting requirements and
classifications within each industry that are not consistent with SIC
delineations. This limitation is discussed throughout the notebook, as
appropriate. OMB is in the process of changing the SIC code system to a
system based on similar production processes called the North American
Industrial Classification System (NAICS). In the NAICS system, Rail
Transportation is classified as NAIC 482, Trucking is NAIC 484 and 492, and
Pipelines are NAIC 486.
The transportation industry includes other modes of transport such as water
and air. Although these are not addressed in this document, they make up an
important portion of overall transportation activity in the United States.
The transportation industry affects nearly every American. Either through the
necessity of traveling from one place to another, shipping goods and services
around the country, or working in a transportation-related job,
transportation's share of the national economy is significant. According to the
Eno Transportation Foundation, for all transportation-related industries, total
transportation expenditures in the U.S. accounted for 16.1 percent of the
gross national product in 1993.
n.B. Industry Sectors Analyzed
II.B.l. Rail Transportation
The rail transportation industry includes establishments furnishing
transportation by line-haul railroad, and switching and terminal establishments.
These terms refer to the distance the particular railroad operation covers —
line-haul operations cover longer distances, often connecting two cities, while
switching and terminal railroads generally travel through a single city. For the
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September 1997
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Ground Transportation Industry
Introduction
purpose of this notebook, rail transportation does not include passenger
railways serving a single municipality, contiguous municipalities, or a
municipality and its suburban areas; these economic units are classified in SIC
41. Other services related to railroad transportation are classified in SIC 47;
lessors of railroad property are classified in SIC 6517. The rail SIC sectors
covered in this notebook are shown in the following table.
SIC 40 - RAILROAD TRANSPORTATION
4011
4013
Railroads, Line-Haul Operations
Railroad Switching and Terminal Establishments
H.B.2. Trucking
The trucking industry includes establishments engaged in motor freight
transportation and warehousing. This includes local and long-distance
trucking or transfer services, and establishments engaged in the storage of
farm products, furniture, and other household goods, or commercial goods of
any kind. For the purpose of this notebook, the trucking industry also
includes the operation of terminal facilities for handling freight, both those
with and without maintenance facilities. The trucking SIC sectors covered in
this notebook are shown in the following table.
SIC 42 - MOTOR FREIGHT TRANSPORTATION & WAREHOUSING
4212
4213
4214
4215
4221
4222
4225
4226
4231
Local Trucking Without Storage
Trucking, Except Local
Local Trucking With Storage
Courier Services, Except by Air
Farm Product Warehousing & Storage
Refrigerated Warehousing & Storage
General Warehousing & Storage
Special Warehousing & Storage, NEC*
Terminal & Joint Terminal Maintenance Facilities for Motor
Freight Transportation
* NEC = Not Elsewhere Classified
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Ground Transportation Industry
Introduction
II.B.3. Pipelines
The pipeline industry includes establishments primarily engaged in the pipeline
transportation of petroleum and other commodities. Pipelines are classified
within two SIC categories, Major Group 46 (Pipelines, except Natural Gas)
and Major Group 49 (Electric, Gas, and Sanitary Services). This notebook
will integrate the relevant operations from the two groups whenever possible.
Occasionally, due to surveys that focus only on one of the groupings, data is
segregated. The pipeline SIC sectors covered in this notebook are shown in
the following table.
SIC 46 - PIPELINES, EXCEPT NATURAL GAS
4612
4613
4619
Crude Petroleum Pipelines
Refined Petroleum Pipelines
Pipelines, NEC*
SIC 49 - ELECTRIC, GAS, AND SANITARY SERVICES
4922
4923
4924
4925
Natural Gas Transmission
Natural Gas Transmission and Distribution
Natural Gas Distribution
Mixed, Manufactured, or Liquefied Petroleum
and/or Distribution
Gas Production
NEC = Not Elsewhere Classified
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Ground Transportation Industry
Rail Transportation
HI. RAIL TRANSPORTATION
III. A. Characterization of the Rail Transportation Industry
in.A.I.Industry Characterization
On February 28, 1827, the State of Maryland chartered the Baltimore & Ohio
(B&O) Railroad, inaugurating America's first common-carrier railroad. The
B&O marked the beginning of the nation's rail system. By 1850, rail trackage
extended over 9,000 miles, mostly in the Northeast. Mirroring the movement
of people to the American West, the first transcontinental rail link opened in
1869. By 1916, railroad tracks stretched across 254,000 miles. During the
mid-twentieth century, railroads suffered from strict regulation and increased
competition from trucks, buses, barges, and planes. By the late 1970s, nearly
a quarter of the nation's rail mileage was operated in bankruptcy.
Railroads began to recover economically in 1980 with the passage of the
Staggers Rail Act. This legislation partially deregulated the shipment rates
charged by railroads, but continued to allow the Interstate Commerce
Commission (ICC) to protect shippers from market abuse. The economic
balance struck by the Staggers Act renewed the rail industry: by 1990, the
rates charged to ship goods by rail had fallen 28.8 percent (adjusted for
inflation). Ton-miles of freight moved by rail (reflecting the number of tons
hauled and the miles traveled) per employee more than doubled from 1980
levels.
By 1993, the biggest railroads moved a record 1.1 trillion ton-miles of freight
with 57 percent fewer employees, 30 percent fewer miles of track, 36 percent
fewer locomotives, and 48 percent fewer freight cars than in 1980
(Association of American Railroads Information Handbook, 1994).
From an environmental standpoint, it is important to recognize that other
industries have grown up around the rail industry. For example, railroads do
not generally clean rail tank cars. This is usually performed by service
companies on a fee-for-service basis. In addition, rail cars and tank cars are
often owned and loaded by the shipper at its facility. Some of the operations
described in this section are performed by these types of entities.
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Ground Transportation Industry
Rail Transportation
m.A.2. Industry Size and Geographic Distribution
Industry Size
Variations in facility counts occur across data sources due to many factors,
including reporting and definition differences. This document does not
attempt to reconcile these differences, but rather reports the data as they are
maintained by each source.
The Interstate Commerce Commission (ICC) was the Federal agency that
regulated many economic aspects of the rail industry. The ICC was abolished
by an act of Congress in December 1995, with remaining essential functions
transferred to a newly created Surface Transportation Board (STB) within the
Department of Transportation. ICC statistics reported prior to the ICC's
abolishment are referenced in this document. The ICC classified railroads
based on their level of operating revenue. The levels are adjusted annually to
reflect inflation. For 1994, the revenue threshold for Class I railroads was
$255.9 million or more; Class II railroads had revenues of between $20.5
million and $255.8 million; and Class III railroads had revenues of less than
$20.5 million. Since 1979, the ICC required reporting on financial and
operating information from Class I railroads only. Class I railroad systems
make up approximately two percent of the number of American railroads, but
account for 73 percent of the mileage operated, 89 percent of the employees,
and 90 percent of freight revenue in the industry. To fill the gap in
information left by the ICC's decreased reporting requirements, the
Association of American Railroads (AAR) annually surveys non-Class I
railroads.
The AAR defines non-Class I railroads as being either regional or local (in
contrast to the ICC definitions, which were based strictly on revenue). In
1994, regional railroads were defined as line-haul railroads operating at least
350 miles of road and/or earning revenue between $40 million and $255.9
million. Local railroads included those line-haul operations not meeting the
regional criteria, plus switching and terminal railroads. Exhibit 1 summarizes
the operating information for Class I, regional, and local railroads. Exhibit 2
depicts the relationship between line-haul railroads and switching and terminal
railroads.
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Ground Transportation Industry
Rail Transportation
Exhibit 1
Facility Size Distribution of Rail Industry
Railroad
Class I
Regional
Local
Total
Number
12
32
487
531
Miles Operated
123335
19842
25599
168776
Year-End
Employees
189,240
10,701
13,070
213,011
Freight
Revenue
$29,930,893
$1,744,893
$1,422,285
$33,098,071
Source: Compiled from Railroad Facts (Association of American Railroads, 1995).
Exhibit 2
Line-Haul and Switching and Terminal Railroads
Switching and Terminal
Railroads
Geographic Distribution
Reflecting the national importance of railroad transportation, the rail industry
is widely dispersed, and the rail system passes through every State in the
country. Due to the nature of its operations, however, the rail industry is not
characterized on a State-by-State basis, but rather by dividing the country into
two halves, separated by the Mississippi River. Freight train-miles measure
the movement of a train the distance of one mile, and are based on the
distance between terminals and/or stations. Of the 440,896,000 total freight-
train miles in the U.S. in 1994, 281,347,000 (64 percent) are West of the
Mississippi and 159,549,000 (36 percent) are East of the Mississippi. Exhibit
3 illustrates the miles of track associated with major rail routes in the United
States.
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Ground Transportation Industry
Rail Transportation
Exhibit 3
Geographic Distribution of Railroads in the United States:
Mileage of Class I Railroads*
m.A.3. Economic Trends
The rail industry began to recover from a period of nearly 25 years of steady
economic decline in 1980, with the passage of the Staggers Act. This
legislation allowed railroad managers to restructure internal operations and
meet competitive pressures. The Staggers Act authorized railroads to offer
contract rate volume discounts for guaranteed shipments. The railroad is
assured minimum volumes, which assists in capital budgeting and operations
planning.
The railroad industry rebounded from the effects of widespread flooding in
1993 to post improved financial and operational results in 1994. Class I
railroad traffic in 1994 increased 8.2 percent from 1993 to 1.201 trillion
revenue ton-miles, reflecting increases in tons originated and longer average
hauls. American railroads accounted for 39.2 percent of total inter-city
revenue freight ton-miles.
Operating revenue rose 6.9 percent in 1994 to $30.8 billion, while operating
expenses rose at a less rapid rate of 4.1 percent to $25.5 billion. Net railway
operating income (defined as operating revenue minus the sum of operating
expenses, current and deferred taxes, and rents for equipment and joint
facilities) was $3.4 billion, an increase of 34.7 percent over 1993 figures.
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Rail Transportation
Traditionally, the largest segment of railroad freight has been coal. In 1994,
coal accounted for 39.1 percent of total tonnage and 21.7 percent of freight
revenue. Other major rail commodities in 1994 included chemicals and allied
products, motor vehicles and equipment, food and kindred products, and farm
products. Exhibit 4 summarizes the tons originated and revenue associated
with the shipment of commodities by Class I railroads in 1994.
Exhibit 4
Tons Originated and Revenue by Commodity — 1994*
Commodity Group
Coal
Chemicals & Allied Products
Farm Products
Non-metallic Minerals
Food & Kindred Products
Lumber & Wood Products
Primary Metal Products
Stone, Clay & Glass Products
Petroleum & Coke
Metallic Ores
Pulp, Paper & Allied Products
Waste & Scrap Materials
Motor Vehicles & Equipment
All Other Commodities
TOTAL
TONS ORIGINATED
Tons
(thousands)
574,213
142,931
130,992
106,404
87,710
54,192
47,799
42,257
41,564
40,367
36,583
36,527
27,792
100,666
1,469,997
Percent of Total
39.1
9.7
8.9
7.2
6
3.7
3.3
2.9
2.8
2.7
2.5
2.5
1.9
6.8
100
REVENUE
$(millions)
7,021
4,559
2,407
862
2,427
1,421
1,165
1,009
928
378
1,510
655
3,174
4,909
32,424
Percent of
Total
21.7
14.1
7.4
2.7
7.5
4.4
3.6
3.1
2.9
1.2
4.7
2
9.8
15.1
100
information is for Class I railroads only.
Source: Railroad Facts (Association of American Railroads, 1995).
The 1990's saw an increase in the efficiency of railroads, the transport of
different materials such as waste and scrap materials, and a shift from boxcar
to the faster intermodal container transport. Intermodal is a term used to
describe containerization of freight for easy transloading to different modes
of transportation. For example, the same container may be transferred from
a truck to a train, with both modes of transportation equipped with locks or
other mechanisms to hold the container in place. In rail transport, there is a
growing use of truck containers and trailers.
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Ground Transportation Industry
Rail Transportation
IH.B. Operations in the Rail Transportation Industry
This section provides an overview of commonly employed operations in the
railroad industry. This discussion is not exhaustive; the operations discussed
are intended to represent the major sources of environmental hazards from
railroad transportation practices. These operations are grouped into three
categories: rail car refurbishing and maintenance; locomotive maintenance;
and transportation operations. Rail car refurbishing and maintenance
operations consist of cleaning the interiors and exteriors of the rail cars,
striping and painting the rail cars, and maintaining/repairing rail car parts.
Locomotive maintenance operations include the cleaning, repair, and
maintenance of the engine and locomotive car. Transportation operations
include all activities associated with the movement of locomotives and cars
over a section of track, including the loading and unloading of freight.
m.B.l. Rail Car Refurbishing and Maintenance
Rail car refurbishing and maintenance consists of cleaning the interiors and
exteriors of rail cars, refurbishing operations (i.e., striping and painting rail
cars), and other maintenance operations (i.e., brake and wheel set repair).
The initial cleaning of rail cars involves two steps: a mechanical cleaning and
a water wash. Mechanical cleaning is the physical shaking and vibrating of the
rail cars to loosen dirt and other debris. Typically, dirt and debris fall through
a steel grate in the floor of the maintenance facility and are intermittently
collected for disposal. The wash step usually consists of a high pressure water
cleaning, collection of wastewater, and wastewater treatment at an on-site
treatment facility.
Refurbishing operations are not employed at all rail facilities. Many railroad
establishments contract out refurbishing work. Refurbishing operations usually
start with paint removal using a steel grit blast system or other method. Paint
chips and grit are 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. Once the original paint has been removed from the rail cars, new paint
is applied to the clean rail car surface.
Rail cars have brakes and wheel sets that must be maintained and sometimes
repaired or replaced. Brake and wheel set maintenance and repair operations
consist of disassembly, cleaning, and repair; or disassembly and replacement
of damaged parts. When wheel sets and air brakes are to be replaced or
rebuilt, the cars must first be disassembled. Axles that can be reused are
washed in a caustic solution to remove grease and dirt. External debris is
removed from the air brakes or wheels using a grit or bead blast system or
other method. Parts cleaning may also include the removal of paint and
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Rail Transportation
cleaning with solvents or caustics. Repaired brakes or wheel set may require
repainting with spray guns.
m.B.2. Locomotive Maintenance
Locomotive maintenance includes, but is not limited to, the following
operations: brake repair; large scale equipment cleaning operations (e.g.,
locomotive car); small scale cleaning operations (e.g., engine parts); hydraulic
system repair, locomotive coolant disposal, metal machining, oil filter
replacement and used oil management, painting and metal finishing, paint
stripping, and spent battery management.
Locomotive maintenance operations usually take place at facility that is
owned and maintained by the railroad. Most used oil is recycled or reused in
energy recovery. Most locomotive batteries are recycled.
ni.B.3. Transportation
Transportation operations include all activities associated with the movement
of locomotives and cars over a section of track. These activities include
fueling and hazardous material transport.
III.C. Raw Material Inputs and Pollution Outputs
HI.C.I. Rail Car Refurbishing and Maintenance
Pollutant outputs from rail car refurbishing and maintenance are generally in
the form of wastewater from preliminary cleaning of interiors and exteriors,
and hazardous wastes generated from painting, paint removal, and the
cleaning of parts. Exhibit 5 shows typical hazardous wastes generated
including: spent solvents and solvent sludges; spent caustics and caustic
sludges; paint chips; and paint sludges. Volatile organic compound (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 often treated in an on-site wastewater treatment system and then
discharged to a publicly owned treatment works (POTW). Hazardous wastes
are typically drummed and shipped off site as RCRA hazardous waste. Spent
solvents, however, can be sent off site for reclamation. Brake and wheel set
repair is not a significant environmental hazard, but discarded brake shoes
may be regulated under the Resource Conservation and Recovery Act
(RCRA) in some States.
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Rail Transportation
Exhibit 5
Rail Car Refurbishing and Maintenance Process Material Input/Pollutant Output
Process
Oil and Grease
Removal
Car and Equipment
Cleaning
Rust Removal
Paint Preparation
Painting
Spray Booth, Spray
Guns, and Brush
Cleaning
Paint Removal
Material Input
Degreasers, engine cleaners,
aerosol, solvents, acids/alkalies
Degreasers, solvents,
acids/alkalies, cleaning fluids
Strong acids, strong alkalies
Paint thinners, enamel reducers,
white spirits
Enamels, lacquers, epoxies,
alkyds, acrylics, primers
Paint thinners, enamel reducers,
solvents, white spirits
Solvents, paint thinners, enamel
reducers, white spirits
Waste
Ignitable wastes, spent solvents,
combustible solids, waste acid/alkaline
solutions, used oil
Ignitable wastes, spent solvents,
combustible solids, waste acid/alkaline
solutions, rags
Waste acids, waste alkalies
Spent solvents, ignitable wastes, ignitable
paint wastes, paint wastes with heavy
metals, rags
Ignitable paint wastes, spent solvents, paint
wastes with heavy metals, ignitable wastes,
rags
Ignitable paint wastes, heavy metal paint
wastes, spent solvents
Ignitable paint wastes, heavy metal paint
wastes, spent solvents, rags
Source: U.S. EPA Office of Solid Waste, 1993.
III.C.2. Locomotive Maintenance
Each of the locomotive maintenance operations listed above is a potential
source of pollution outputs. Following are brief discussions of the wastes that
can be generated by these locomotive maintenance operations.
Brake Repair
Brake repair does not pose a significant environmental hazard, but discarded
brake shoes may be regulated under RCRA in some States. Some older brake
shoes contain asbestos and may require special disposal.
Cleaning Operations
Sludges created as a result of cleaning operations may be characterized as
hazardous. If so, hazardous waste regulations must be complied with prior
to disposal. Waste waters from locomotive cleaning can contain elevated
levels of oil, grease, suspended solids (a measure of particulate matter in
water) and pH (acidity or alkalinity of water). These substances are regulated
water pollutants, so wash waters must be processed in a way that is consistent
with Clean Water Act (CWA) requirements. In most cases, the State has
authority for enforcement of CWA provisions and permit administration.
Treatment of wash waters may be required before release to a local sewer
system or an outfall regulated by a National Pollutant Discharge Elimination
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System (NPDES) permit. The type of cleaning solution used may also pose
an environmental concern. If mineral sprits or other chemicals are used to
clean equipment, a variety of environmental compliance issues may result.
Mineral sprits are hazardous substances that have environmental compliance
requirements for storage, handling, and disposal.
Hydraulic System Repair
Used hydraulic fluids are listed as used oils under RCRA. The major
compliance issues associated with hydraulic system repair involve handling
and disposing of the hydraulic fluid, spill containment, and storage.
Environmental damage can occur from waste oil seepage into the soil, waste
oil run-ofFinto water bodies during storms, and other contamination methods.
Coolant Disposal
Locomotive cooling systems do not contain automotive type ethylene glycol-
based antifreeze. Because of this, locomotive cooling systems may need to
be drained when engines are shut down during road operation in cold weather.
Failure to do so can result in serious engine damage due to freezing of the
coolant. To protect the cooling system from corrosion, locomotive coolants
contain a dilute additive package, which is basically a mixture of sodium
borate and sodium nitrate. The additive package usually contains a dye, to
help identify leaks and ensure the cooling system is protected. The
compounds are diluted in the cooling system to approximately one to three
percent. The concentrations of the individual corrosion inhibitors is a fraction
of one percent. Used coolant must be disposed of properly.
Metal Machining
Metal machining and punching can generate regulated wastes that may
contaminate the environment from direct release into water or from
stormwater runoff. Pollutant-carrying stormwater runoff may violate the
CWA. Coolants from metal multi-punch operations may be regulated
substances under RCRA or local waste regulations and may require special
handling.
Oil Filter Replacement and Used Oil Disposal
A variety of environmental issues need to be considered when performing any
oil handling activities such as oil changes or oil filter replacement to
locomotives. Oil can drip or spill during maintenance and repair operations,
particularly during oil filter replacement operations. Oil releases to the
environment from oil drippage can also occur during locomotive tie-up. Oil
filter and used oil replacement are generally conducted indoors at locomotive
maintenance facilities and locomotive idling is conducted, to the extent
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Rail Transportation
practical, over track pans, absorbent materials, or other collection devices.
This makes it possible for most facilities to collect used oil and oil filters
before they leak or spill oil into the environment. Some facilities have routed
track pan drains to oil-water separation systems. Used oils are not typically
categorized as hazardous wastes under RCRA, but used oils have strict
disposal requirements in some States.
Painting
Painting operations can be significant sources of environmental harm. Air
pollution from the evaporation of chemicals contained in the paint (e.g.,
solvents) can contribute to smog and worker health and safety problems.
Solid and hazardous wastes from the painting process (e.g., paint-covered
cloths) may contaminate water and soil if not disposed of properly. Whether
hazardous wastes are generated during painting depends upon the type of
paint applied. Typically, latex paints and related paint wastes are classified as
non-hazardous. Ignitable or solvent-based paint or paint thinner wastes are
classified as hazardous. Air pollution issues are typical concerns only for
large-scale painting operations involving paint booths and associated air
ducting.
Battery Storage and Disposal
Used battery storage and disposal can be a significant environmental liability
for railroads since many spent signal batteries are classified as hazardous
wastes under RCRA. Most locomotive batteries are lead acid and recycled
as non-hazardous solid waste.
IILC.3. Transportation Operations
The three main transportation operations that pose potential environmental
problems are fueling, hazardous material transport, and oil and coolant
releases during transport.
Fueling Operations
Air pollution and fuel spillage are the major environmental concerns
associated with fueling operations. While air emissions are a problem for
volatile petroleum products such as gasoline, the railroad industry uses very
little gasoline on site. Their largest fuel product is diesel fuel, which is less
volatile. If gasoline is dispensed on site, it could contribute to local air quality
problems, and may require permitting and control. Spilled fuel may
contaminate soil, ground water, or water bodies. Some super tanker fueling
systems deliver fuel at approximately four gallons per second, so even a small
connection malfunction can result in a large spill event. Filling and
maintenance of fuel storage may require air quality permitting in some States.
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Hazardous Materials
The spilling/leaking of hazardous materials is a significant environmental
concern for the rail industry. According to DOT statistics, approximately 16
percent of all hazardous material releases to the environment in 1988 were
from rail transport. In addition to being harmful to the environment,
hazardous material spills and releases are subject to a variety of environmental
regulations and may result in costly cleanups or fines.
Valve leakage or safety valve releases can be sources of material spills on
pressurized and general service tank cars or other hazardous material
containers such as covered hoppers, intermodal trailers/containers, or portable
tanks. These leaks can manifest themselves as odors or vapors clouds from
tanker top valves; spraying or splashing from the tanker top valves; wetness
on the side of the car; or drippage from the bottom outlet valve. In
intermodal cars, spills/leaks can result from improper packing and resultant
load shifting during transport. Intermodal container doors and other openings
can be spill/release sources. Unloading and transfer facilities are high
potential spill and release areas. It should be noted that it is the responsibility
of the shipper to properly secure the transportation vehicles to prevent these
types of occurrences. In the latest effort to identify the source of these leaks,
in 1995 the Association of American Railroads (AAR) introduced the non-
accident release (NAR) program. The purpose was to identify and report
these releases so that corrective measures could be taken to reduce them.
If hazardous materials are transported, DOT requirements regulate car
inspections, car placement, switching, and shipping papers (e.g., waybills,
manifests). If hazardous materials pass through a facility, rail containers
should be inspected for proper labeling, valve cover placement, any signs of
leakage, proper car stenciling, and fulfillment of other DOT requirements.
Placarding and/or labeling is required for all containers carrying hazardous
materials.
Oil and Coolant Releases
Oil and coolant releases from the locomotive engine to the environment can
occur during transport operations. Oils can contaminate surface water,
ground water, and soil, and expose the rail facility to punitive fines from
violations of a variety of environmental statutes. Coolants may be regulated
substances under RCRA or local waste regulations.
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Ground Transportation Industry
Trucking
IV. TRUCKING
IV.A. Characterization of the Trucking Industry
IV.A.l. Industry Characterization
Construction of the nation's first transcontinental highway, the Lincoln
Highway (U.S. 30), started in 1912. It took 20 years to complete the 3385-
mile road between New York City and San Francisco. In 1956, the Federal
Aid Highway Act was signed into law, authorizing the 41,000-mile National
System of interstate and defense highways to be completed by 1972 at a cost
of $42 billion. In 1982, landmark legislation boosted Federal spending for
highway construction and repair work. By 1986, more than 97 percent of the
42,500-mile interstate highway system was open to traffic as the program
entered its 30th year. The system represented a total Federal and State
investment of more than $120 billion. Currently, there are 44,700 miles of
interstate highways with 132,000 miles of other arteries in the United States.
The types of trucks that travel these roads are diverse, ranging from small
pickup trucks to large tractor trailer combination units. Methods of
quantifying these vehicles vary as well. This section presents information
from a variety of sources, including the Census Bureau and trucking
associations. Different groups use various benchmarks to quantify the
trucking industry. This document does not attempt to reconcile these
differences, but rather reports the data as they are maintained by each source.
According to the American Trucking Associations (ATA), the total number
of commercial trucks in 1993 was 16.2 million, with approximately 3.9 million
commercial trailers registered in the same period. The ATA reports 322,739
interstate motor carriers on file with the U.S. Department of Transportation
(DOT) as of January 5, 1995. Eighty-two percent of those operate fewer than
six trucks, and 96 percent operate 28 or fewer trucks. 59,310 for-hire carriers
were authorized by the Interstate Commerce Commission (ICC), to haul
goods.
Types of trucks and trucking establishments are defined by various
classifications. Exhibit 6 shows the shape and size of different truck types.
This diagram does not include smaller trucks such as pickups, panels, vans,
and utility trucks which are usually not counted in industry statistics because
they are often used for personnel purposes.
In general, trucking establishments falls into two broad categories: private and
for-hire. Private carriers are shippers, manufacturers, merchants, and others
who use their own vehicles or leased trucks under their direct control for
moving their own goods. For-hire carriers are compensated for providing
transportation of freight belonging to another entity.
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Tracking
Exhibit 6
Truck Types
ffi ^&
W*r—w^ I5«* w
Straight Truck
I 18'-35' I
Truck/Trailer
26'-30' I I —26'-28' — I
Truck-tractor
2-Axle
Truck-tractor
3-Axle
3-Axle Tractor Semitrailer
4-Axle Tractor Semitrailer
j - 25MO'
38'-53'
5-Axle Tractor Semitrailer
40'-53'
Converter dolly
used to convert a semitrailer
for operation as a full trailer
Twin Trailer or "Doubles"
I— 28' —II— 28'
Typical Longer Combination Vehicles (LCV'S).
Operated only in certain States
Truck/double trailers
-26'-28' — 11 — 28' — | I — 28' -
Triple Trailer
— 28' - ,|— 28' - |
— 28' —
Rocky Mountain Doubles
. 40'-48' II— 28' -
Turnpike Doubles
. 33'_48' I I 33'-48'
IPfP WtP
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Trucking
There are three types of interstate for -hire carriers: common, contract, and
exempt carriers. Common carriers transport freight for the general public at
published rates. Contract carriers are those in stipulated types of operations,
such as trucks used only to carry newspapers, or vehicles used incidentally to
support air transport. (Motor Trucking Engineering Handbook, James W.
Fitch, Society of Automotive Engineers, 1994).
For-hire carriers regulated by the ICC were classified by size of operating
revenue. The ICC was abolished by an act of Congress in December 1995,
with remaining essential functions transferred to a newly created Surface
Transportation Board (STB) within the Department of Transportation. ICC
statistics reported prior to the ICC's abolishment are referenced in this
document. As of January 1, 1994, the ICC defined Class I carriers as those
establishments with annual revenues greater than $10 million, Class II carriers
with annual revenues between $3 and $10 million, and Class III carriers with
annual revenues of less than $3 million.
IV.A.2. Industry Size and Geographic Distribution
As discussed in Section IV. A. 1 above, variation in facility counts occur across
data sources due to many factors, including reporting and definition
differences. This document does not attempt to reconcile these differences.
Industry Size
Trucking companies are diverse, ranging from large employers to private
transporters who work for themselves and have no additional employees. A
concise discussion of the trucking industry is complicated by the different
methods used by the Census Bureau, the ICC, and trucking associations to
estimate the size of the trucking industry. In some cases, as with most census
data, only those companies with payrolls - those that pay drivers who were
not also owners - are tracked. In addition, only those trucking companies
formerly regulated by the ICC were required to report data.
The trucking industry consists of approximately 111,000 establishments with
payrolls, employing nearly 1.6 million people. This does not include small,
independent truckers who have no employees other than themselves. The
total number of truck drivers holding commercial drivers licenses as of June
1995 exceeded 6.5 million. In 1993, these drivers drove 656.6 billion miles
(American Trucking Trends, 1995). According to the American Trucking
Associations (ATA), 7.8 million people were employed throughout the
economy in jobs that relate to trucking activity and 2.8 million heavy-duty
truck drivers (including linehaul, local, courier, government, etc.) were
employed in 1994. In 1993, $226.9 billion was paid in wages relating to
trucking activity.
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Ground Transportation Industry
Trucking
Over 88 percent of trucking companies are small businesses, as defined by the
Small Business Administration. According to the ATA, of the 359,787
interstate motor carriers on file with the Office of Motor Carriers, 82 percent
operate six or few trucks, while 96 percent operate 28 or fewer trucks (as of
February 1996).
Exhibit 7 illustrates the facility size distribution for those motor freight
transportation and warehousing facilities with payrolls, based on the latest
complete Census Bureau data (1992).
Exhibit 7
Facility Size Distribution of Trucking Industry*
Industry
Local Trucking Without
Storage
Trucking, Except Local
Local Trucking with Storage
Courier Services, Except by
Air
Farm Product Warehousing
and Storage
Refrigerated Warehousing
and Storage
Cieneral Warehousing and
Storage
Special Warehousing and
Storage, NEC*
Terminal and Joint Terminal
Maintenance Facilities for
Motor Freight Transportation
Total
SIC
Code
4212
4213
4214
4215
4221
4222
4225
4226
4231
Total Employees
354,742
758,435
64,417
307,061
6,497
18,963
49,091
20,594
295
1,580,095
Total Number
of Facilities
49,870
40,821
4,512
5,966
584
929
6,753
1,452
21
110,908
Employees per
Facility
7.11
18.6
14.3
51.5
11.1
20.4
7.3
14.2
14.1
14.2
Source: Compiled from official 1992 statistics of the U.S. Bureau of the Census.
*Facilities with payrolls only.
As demonstrated in Exhibit 7, the majority of establishments and employees
in the trucking industry which maintain payrolls are classified in SIC Code
4212, Local Trucking Without Storage. This category includes dump
trucking, general freight, and garbage and trash collection. Trucking, except
local (SIC 4313), accounts for most of the other establishments and persons
employed in the trucking industry. General freight trucking accounts for most
trucking industry facilities.
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Ground Transportation Industry
Trucking
Geographic Distribution
Reflecting the national importance of highway transit, the trucking industry
is widely dispersed, with every State reporting the existence of at least 400
industry establishments (U.S. Bureau of the Census). The numbers in Exhibit
8 include both businesses with and without payrolls. All businesses covered
by the economic censuses are included, except direct sales retail and tax
exempt service businesses.
Exhibit 8
Geographic Distribution of Trucking Industry Facilities
Source: Compiled from official 1992 statistics of the U.S. Bureau of the Census.
Although the trucking industry is highly represented throughout the country,
motor freight facilities are most heavily concentrated around the Great Lakes
States (Minnesota, Wisconsin, Illinois, Indiana, Michigan, and Ohio).
Reflecting the important trade routes between these States and the Northeast,
this concentrated area extends through Pennsylvania and New York. The five
largest States in terms of number of trucking establishments with payrolls are
California, Texas, Ohio, Florida, and New York.
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Trucking
Exhibit 8 illustrates the number of trucking establishments as recorded by the
Bureau of the Census. These numbers do not correlate to those presented in
Exhibit 9, also from the Bureau of the Census, due to the different scope of
the census data.
Exhibit 9
Share of Freight Revenues by Mode of Transportation
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Trucking
Reportedly, the estimated profit margin of the companies and independent
truckers averages one to two percent.
The following economic information is from the Census Bureau's 1993 Motor
Freight Transportation and Warehousing Survey Report. As with the census
data conveyed in Exhibit 7, this survey excludes private motor carriers that
operate as auxiliary establishments to non-transportation companies, as well
as independent owner-operators with no paid employees. As a result, the
dollar volume estimates and estimates of year-to-year percentage change
presented in this report should not be interpreted as representing
measurements of total trucking industry activity.
Revenue in 1993 for the for-hire trucking and courier services industry
(excluding air courier services) was estimated at $135.9 billion, up six percent
from 1992. Long-distance trucking, which accounted for approximately 75
percent of all motor carrier revenue, was up 5.6 percent over 1992. Local
trucking revenue rose 9.6 percent from 1992 to approximately $31.6 billion
in 1993. Truckload shipments accounted for approximately 61 percent of
motor carrier revenue in 1993 and increased 6.8 percent from 1992.
Nearly 48 percent of motor carrier revenue comes from transporting
manufactured products, such as furniture, hardware, glass products, textiles
and apparel, and the delivery of small packages. Revenue in 1993 from the
transport of metal products rose 8.8 percent from 1992. Expenses totaled
$127.9 billion in 1993, up 5.8 percent from 1992. Revenue for the courier
services industry, excluding air courier services (SIC 4215), rose 7.7 percent
in 1992 to approximately $20.2 billion in 1993. The Truck Inventory and Use
Summary (TIUS), part of the Census Bureau's Census of Transportation,
provides data on the physical and operational characteristics of the U.S. truck
population. According to TIUS, an increasing proportion of trucks are being
used mainly for "personal transportation," i.e., commuting to work, outdoor
recreation, etc. In 1992, almost 70 percent of all trucks were identified as
being for personal use; in 1987 the proportion was 66 percent, and in 1982
only 57 percent.
Annual payroll accounted for approximately 33 percent of all trucking
expenses, totaling $41.5 million for 1993. Purchased transportation rose 7.6
percent from 1992, while the cost of fuels and maintenance and repair
expenses rose 6.7 percent and 7.0 percent, respectively.
Public Warehouse Services
Total operating revenue for public warehousing services increased 8.6 percent
from 1992 to $8.1 billion. Total operating expenses rose 8.4 percent from
1992 to $6.8 billion. Employer contributions to employee benefit plans were
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up to 7.2 percent and represented almost eight percent of the warehousing
industry's total operating expenses.
Over 50 percent of all revenue was from general warehousing and storage
(SIC 4225). Revenue from refrigerated warehousing and storage (SIC 4222)
increased 3.3 percent to $1.7 billion, and accounted for 21 percent of the
warehousing industry's total operating revenue in 1993.
Revenue in 1993 for farm product warehousing and storage (SIC 4221),
which represents approximately eight percent of the warehousing industry's
total operating revenue, increased 9.2 percent to $686 million from 1992,
while expenses for the industry were up 7.8 percent to $593 million over the
same period.
IV.B. Operations in the Trucking Industry
This section provides an overview of commonly-employed processes within
the trucking industry, broken down by operations. This discussion is not
exhaustive; the operations discussed here are intended to represent the major
sources of environmental hazards from trucking operations. The operations
discussed include materials transport, truck maintenance, truck washing, tank
truck cleaning, and transport operations.
IV.B.l. Truck Terminals and Maintenance Facilities
Many segments of the trucking industry operate their own truck terminals and
maintenance facilities. Truck terminals are places where trucks come to
consolidate and transfer loads of shipped goods. Terminals typically have
large parking and staging areas for tractors and trailers, and a loading dock,
from which freight is moved between trailers. Truck maintenance facilities,
which may be located on the same property as the maintenance facilities,
which may be located on the same property as the terminals, perform routine
vehicle maintenance activities which are similar to those performed in the
automotive service industry. These activities include replacement of fluids
(e.g., motor oil, radiator coolant, transmission fluid, brake fluid), replacement
of non-repairable equipment (e.g., brake shoes/pads, shocks, batteries, belts,
mufflers, electrical components, water pumps),and repair of fixable equipment
(e.g., brake calipers/rotors/drums, alternators, fuel pumps, carburetors).
Some maintenance terminals also have fueling facilities, repair vehicle bodies,
wash trucks, and perform painting operations.
Truck maintenance involves the regular changing of a number of fluids.
Automotive fluids used to maintain trucks include brake fluid, transmission
fluid, gear oil, radiator fluid, and motor oil. Truck parts removed for repair
often require cleaning to allow for better visual inspection of the parts and to
remove contaminated lubricants/greases that would lead to early failure of the
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repaired part. Rags are often used to clean up a fluid spill or to wipe grease
from a part being repaired. If necessary, clean lubricants/greases are applied
to the parts during reassembly.
Parts cleaning often involves the use of a parts washer. Washers used in the
trucking industry include solvent parts washers, hot tanks, and jet spray
washers. A solvent parts washer recirculates solvent continuously from the
solvent drum to the solvent wash tray where the parts are cleaned. Old
solvent is typically replaced with fresh solvent on a monthly basis. The
solvents used for parts cleaning contain petroleum-based ingredients or
mineral spirits. Carburetor cleaner contains methylene chloride. Electrically
heated tanks are also used to clean parts. Parts are placed in a tank of hot
aqueous detergent or caustic solution to achieve cleaning and air or
mechanical agitation is employed to increase cleaning efficiency. Jet spray
washers also use hot aqueous solutions for cleaning, but in this application,
rotating jets spray the parts with cleaner. Both hot tanks and jet sprays are
usually serviced monthly by removing the spent cleaner and sludge and
recharging the washer with fresh detergent. Sludge that accumulates in the
waste sump of the pressure spray cleaning bays and in area wash-down
clarifiers is often taken off site to a local municipal landfill.
Truck maintenance facilities may also perform fueling operations. Fueling
facilities typically dispense diesel fuel. Exhibit 10 shows the layout of a
typical truck maintenance facility.
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Exhibit 10
Typical Trucking Maintenance Facility
Source: Stormwater Pollution Prevention Manual for the Trucking Industry ATA, 1993
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IV.B.2. Truck Washing
Trucks can be washed manually or by using a fixed wash bay system. Dry
washing, by using dry rags and a spray bottle, can be an option for manual
truck washing. Manual washing includes hand-held wash systems, hand-held
wand systems, and hand brushing with soap. Fixed bay washing operations
involve fixed equipment, such as drive-through wash racks or gantry wash
systems. Typically, wash bay systems include chemical storage facilities,
chemical and water application arches, water reclamation systems, and waste
water treatment systems.
IV.B.3. Tank Truck Cleaning
Tank trucks typically haul a wide range of liquid and dry bulk commodities,
including food-grade products such as milk and corn syrup, and industrial
process chemicals. Many aspects of transportation and labeling, as well as
spills and releases of these materials, are regulated by the Research Special
Programs Administration (RSPA) of the DOT. Because the material being
transported is loaded directly into a tank truck without any sort of container,
these trucks require special cleaning to remove residual cargo. Washing,
rinsing, and drying methods vary depending on the facility's equipment, the
last cargo carried, and the next cargo to be carried. Some cargoes may require
only a water rinse, while others may need a series of wash and rinse cycles
using different wash solutions.
Prior to tank cleaning, residual cargo, or heel, is removed. Heel volume from
tank trucks is typically five to ten gallons (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). Heel can be sent to an off-site Treatment Storage and
Disposal Facility (TSDF) or can be treated on site if it is an aqueous solution.
If organic, it may be put into containers for later treatment as a hazardous
waste.
Tank truck washing is performed either manually with hand-held sprayers, or
automatically with high pressure spinner nozzles or "butterworths." With
automatic washing, 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 p.s.i. while rotating around vertical and
horizontal axes.
Washing solution may consist of detergent solution, caustic solution, organic
solvents, or steam. Any wash solution can be used with either the manual or
automatic washing method, although worker safety is a concern when
manually spraying solvent and caustic wash solutions. Some facilities have the
capability to recycle washing solutions within a closed system, and
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periodically change to fresh water solutions. Tanks can be rinsed with hot or
cold water, and dried with passive or forced air.
IV.B.4. Transport Operations
Transport operations refer to all operations performed by a truck while on the
road. These operations include loading and unloading cargo, running the truck
engine, and fuel consumption. Commercial trucking transportation operations
consumed approximately 36 billion gallons of oil in 1993, or about 63 percent
of total U.S. consumption. This figure, according to the ATA, includes 23
billion gallons of diesel fuel and 13 billion gallons of gasoline.
IV.C. Raw Material Inputs and Pollution Outputs
I V.C.I. Truck Terminals and Maintenance
Materials Spills and Releases
In truck terminals, spills and releases of hazardous material shipments are the
main environmental issue of concern. Hazardous waste transportation is a
highly regulated and specialized segment of the trucking industry, covered by
extensive EPA (40 CFR) and DOT (49 CFR) regulations while the waste is
in transit. Due to the additional insurance and safety requirements, the
majority of general freight trucking companies do not have the authority nor
desire to transport hazardous waste.
Truck Maintenance
Maintenance facilities handle vehicle fluids that are used during normal
trucking operations, including oil, transmission fluid, brake fluid, and
antifreeze. The quantities of waste materials vary depending on the size of the
facility and the types of maintenance activities that are performed.
Oil, transmission fluid, and other liquids that are replaced, must be collected
and stored for later disposal. The storage, disposal, and transportation of
used oil is regulated by EPA and is a primary environmental concern in the
trucking industry. Generators of used oil must meet on-site management
standards for storage prior to shipment off-site or burning on-site for energy
recovery. Storage containers must be in good condition without leaks and
clearly labeled with the words "USED OIL." If a release occurs (spill or
leak), the generator must stop and contain the release, clean up and properly
manage the released used oil, and repair or replace any leaking containers.
Fluids such as antifreeze must be evaluated for hazardous waste
characteristics and dealt with accordingly if spilled or released. Antifreeze
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consists of water and ethylene glycol. Neither of these ingredients
demonstrates hazardous waste characteristics, however, as a result of use, the
antifreeze may become hazardous based on metals or benzene content.
Sludge that accumulates in the maintenance facility floor drains can contain
oil, grease, solvents, and dirt from routine operations. The hazardous/non-
hazardous nature of the sludge will determine the applicable disposal
regulations.
Truck Repair
Repair activities typically produce several types of waste materials in addition
to the parts themselves (i.e., batteries, brake parts, etc.), including oil,
coolants, and solvents. Oil rags can be considered a "used oil" waste. Shop
rags which are used to wipe up a hazardous waste (i.e., paint thinner) may be
a hazardous waste.
Spent lead-acid batteries are exempt from regulation as a hazardous waste
provided they are recycled. Generators of spent lead-acid batteries may store
and/or transport those batteries without waste activity notifications or permits
as long as the batteries are ultimately reclaimed. In some States, a new
battery cannot be purchased without the return of a used battery.
Used tires are a significant waste produced at truck maintenance facilities.
Old tires are not acceptable for landfill disposal unless they have been
shredded or quartered. Tires can be returned to a central location for
processing or recycling. Used truck tires are usually retreaded or recycled.
Used tires otherwise ready to be scrapped might be categorized as hazardous
waste.
Parts Washing
Parts washing solvents and residual liquids such as petroleum distillates,
mineral spirits, and naphtha are all considered hazardous wastes due to
ignitability. Filters removed from parts whose units may also be hazardous
due to toxicity (presence of metals and/or benzene) and ignitability. Even
filters which are not hazardous may still not be acceptable for landfill disposal
due to hydrocarbon content.
Air emissions occur when the solvent is sprayed onto parts and when parts are
improperly drained of solvent. Many air quality control districts specify that
equipment cannot be designed so as to provide a fine spray mist (which leads
to high evaporation rates) and that parts must be properly drained before
removal from the washer. For washers in which the solvent bath is always
exposed to the atmosphere (i.e., wash tanks), the lid must be kept closed
whenever the tank is not in use.
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Fueling Operations
Fueling operations may result in fuel spills or releases. Waste diesel fuel may
be a hazardous waste because its flash point ranges from 120°F to 160°F and
because it may contain concentrations of heavy metals and benzene in excess
of regulatory limits. Diesel fuel spills and releases - both underground and
above ground - are a significant concern in the trucking industry in terms of
stormwater run-off and land contamination.
IV.C.2. Truck Washing
The waste streams generated by vehicle washing operations are variable. If
vehicles are washed often, they enter the washing operation relatively clean,
and the waste wash water generated is cleaner thana waste stream generated
from washing vehicles that are washed only occasionally. The technology
used to wash the vehicle will also affect the waste stream. For example, if a
two-step acid-detergent wash is used, acid or salts will be found in the waste
stream that would not be present if the vehicle was steam cleaned. Season
and location can also affect the waste stream generated, for example, vehicles
in the northeast often bring in heavy mud and road salt in the winter months.
Vehicle washing is a regulated maintenance activity under the NPDES
program. Wastewater from vehicle washing and floor drain discharge is
considered industrial waste. The hazardous or nonhazardous nature of the
wastewater determines the applicable disposal regulations.
IV.C.3. Tank Cleaning
The primary pollutant output from tank cleaning operations is wastewater
contaminated with tank residues and cleaning solutions. Specific outputs
include: spent cleaning fluids, fugitive volatile organic compound (VOC)
emissions, water treatment system sludges, and tank residues. The quantities
of these outputs vary widely from facility to facility depending on the type of
cargo and cleaning methods. For example, an independent owner/operator
tank truck cleaning facility serving a large number of different users will
generate wastewater containing many ore contaminants than a shipper
operated facility serving trucks all carrying the same cargo.
Tank heels from a shipment of hazardous waste greater than 0.3 percent of
weight of the tank capacity continue to be regulated by RCRA after the
discharge of the waste at a TSDF. Under current regulation, the use of
solvents to further rinse out tanks is not considered treatment; however,
certain State RCRA programs regulate these processes more stringently and
should be contacted to determine if a treatment permit is required.
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IV.C.4. Transport Operations
Transport operations have the potential to generate three types of waste: the
release or spill of a hazardous waste during loading and unloading operations;
the spill or release of vehicle fluids such as oil or antifreeze during travel; and,
most significant, the emissions generated during fuel combustion. As
discussed above, engines, especially those of heavy duty trucks, generate
several forms of air pollution. Among common substances released to the air
from truck engines are hydrocarbons, carbon monoxide, oxides of nitrogen,
sulfur compounds, and particulate matter. A description of each of these
pollutants follows, while more information about EPA regulations governing
emissions is provided in Section VII.
Hydrocarbons: Although hydrocarbon emissions are not problematic when
they leave the vehicle, some hydrocarbons react in the atmosphere to promote
the formation of photochemical smog. Ozone concentration is generally used
to measure the extent of this photochemical reaction. Hydrocarbon emission
standards have been set to meet the National Ambient Air Quality Standard
(NAAQS) for ozone.
Exhibit 11
Hydrocarbons Emission Sources
Hydrocarbons Emissions Source
Stationary Fuel Combustion
Industrial Processes
Passenger Cars - Gasoline Engine
Light-Duty Trucks - Gasoline Engine
Heavy-Duty Vehicles - Gasoline Engine
Diesel Engine Vehicles
Other
Percentage of Total
Emissions
3.1%
13:3%
17.8%
6.4%
0.8%
1.8%
56.8%
Source: ATA
Carbon Monoxide: Carbon monoxide (CO) is a byproduct of incomplete fuel
combustion. The chemical is a colorless, tasteless, odorless gas that displaces
oxygen in the body. At high concentration in confined areas, CO can be
injurious to health. EPA has set a NAAQS and a vehicle emission standard
for CO.
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Exhibit 12
Carbon Monoxide Emission Sources
Carbon Monoxide Emissions Source
Stationary Fuel Combustion
Industrial Processes
Passenger Cars - Gasoline Engine
Light-Duty Trucks - Gasoline Engine
Heavy-Duty Vehicles - Gasoline Engine
Diesel Engine Vehicles
Other
Percentage of Total
Emissions
7.1%
5.7%
44.0%
14.5%
2.9%
1.9%
23.8%
Source: ATA
Nitrogen Oxides: Emissions of nitrogen oxides (NOX) are a significant
contributor to the creation of nitrogen dioxide, and are ingredients in the
formation of smog, although they play an ambiguous role in the process; at
times Nox appear to promote smog, while at other times they seem to inhibit
smog in urban areas.
Exhibit 13
Nitrogen Oxides Emission Sources
Nitrogen Oxides Emissions Source
Stationary Fuel Combustion
Industrial Processes
Passenger Cars - Gasoline Engine
Light-Duty Trucks - Gasoline Engine
Heavy-Duty Vehicles - Gasoline Engine
Diesel Engine Vehicles
Other
Percentage of Total
Emissions
50.6%
3.8%
15.2%
4.9%
0.8%
11.4%
13.2%
Source: ATA
Sulfur Compounds: Sulfur compounds are oxides that aggravate the
respiratory system and may cause respiratory disease. Very dense smog is
generally attributed to the buildup of SO and particulates during periods of
little air movement. Motor vehicles of all types, including passenger cars,
contribute only 4.2 percent of ambient sulfur compounds.
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Particulates: Particulates are particles of solid material that are products of
incomplete combustion, such as soot and fly ash. Small particles may remain
suspended in the air for long periods of time, while larger particles return to
the ground as dust. Suspended particles cause reduced visibility and increased
health hazards from other contaminants by providing a surface to carry
chemicals into human lungs.
Exhibit 14 summarizes the pollution outputs from those operations in the
trucking industry discussed in this document.
Exhibit 14
Process Material Input/Pollutant Output from Trucking Operations
Activity
Truck Terminals and
Maintenance Facilities
Vehicle Exterior
Washing
Tank Cleaning
Transport Operations
Material Input
Motor oil, brake fluid,
transmission fluid,
coolants, solvents, parts
cleaning solutions,
lubricants, truck cargo
Detergent, caustic
solution, organic solvents,
steam
Residuals from shipments,
cleaning fluids -
detergent, caustic
solution, organic solvents,
steam
Gas and diesel fuels,
alternative fuels, motor
oil, brake fluid,
transmission fluid,
coolant, truck cargo
Air Emissions
Possible CFC and VOC
emissions
VOC emissions
VOC emissions
Hydrocarbons, carbon
monoxide, oxides of
nitrogen, sulfur
compounds,
particulates
Process Wastes
Used oil, used
automotive fluids,
solvents, coolants,
used rags, used
cleaning solutions,
spilled or released
truck cargo
Oil and grease,
suspended solids,
detergents, pH,
metals
Spent cleaning fluids,
water treatment
system sludges, tank
residues
Used oil, used
automotive fluids,
spilled or released
truck cargo
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Ground Transportation Industry
Pipelines
V. PIPELINES
V.A. Characterization of Pipelines
V.A.I. Industry Characterization
Oil Pipelines
The history of oil and gas pipelines as they are used today begins with the first
commercial oil well, drilled in 1859. The first oil pipeline - 109 miles long,
with a diameter of six inches - was laid from Bradford to Allentown^
Pennsylvania, in 1879. Since the late 1920s, virtually all oil and gas pipelines
have been welded steel, a departure from the early versions made from
wrought iron. Although the first cross-country pipeline was laid in 1930,
connecting Chicago, Minneapolis, and other cities, it was not until World War
H, with frequent disruptions in coastal tanker traffic, that large-scale pipelines
were laid connecting different regions of the country. In the 1960s, larger-
diameter pipelines proved their economic advantage when a line consisting of
32, 34, and 36 inch diameters was built from Houston to New York, and a 40-
inch pipeline was constructed connecting Louisiana to Illinois. Discovery of
oil on Alaska's North Slope precipitated the construction of the country's
largest pipeline, the 48-inch diameter Trans-Alaskan Pipeline, or Alyeska (Oil
and Gas Pipeline Fundamentals, Kennedy, 1994).
By 1994, U.S. interstate pipeline mileage totaled nearly 410,000 miles, of
which over 250,000 miles transported gas and over 158,000 shipped liquid oil
and petroleum. Natural gas is delivered to U.S. consumers through a network
of 1.2 million miles of buried pipe and 429 underground storage reservoirs
that are linked to more than 1,200 local gas distribution companies.
Throughout this section, distinctions are made between gas and oil pipelines.
Although the fundamental design and purpose of these two systems are
similar, there are differences in their conveyance systems. Distinctions are
also made for product pipelines and breakout tanks which are defined below.
Crude oil must undergo refining before it can be used as product. Once oil is
pumped from the ground, it travels through pipes to a tank battery. One or
more tank batteries may be installed in a single field, each serving a number
of individual wells. A typical tank battery contains a separator to separate oil,
gas, and water; a fired heater to break water/oil emulsions to promote removal
of water from the oil; and tanks for storing the oil until it is shipped as crude
oil by truck or, more commonly, by a gathering line connected to storage
tanks. From these tanks, the oil is moved through large diameter, long-
distance trunk lines to refineries or to other storage terminals.
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Trunk lines rely on pumps to initiate and maintain pipeline pressure at the
level required to overcome friction, changes in elevation, or other pressure-
decreasing factors. Pumps are required at the beginning of the line and are
spaced along the pipeline to adequately propel the oil along.
Gas Pipelines
The purpose of gas-gathering and gas transmission pipelines is similar to that
of crude-gathering and crude trunk lines, but operating conditions and
equipment are quite different. Gas pipelines operate at higher pressures than
do crude lines, and use compressors instead of pumps to force the gas along.
Unlike oil, gas does not undergo refining, and transmission lines connect
directly to utility companies that distribute the gas to consumers via small,
metered pipelines. Gas is often treated in scrubbers or filters to ensure it is
"dry" prior to distribution.
Gas-well flowlines connect individual gas wells to field gas-treating and
processing facilities or to branches of a larger gathering system. The gas is
processed at the treating facility to remove water, sulfur, acid gases, hydrogen
sulfide, or carbon dioxide. Most field gas processing plants also remove
hydrocarbon liquids from the produced as stream. From field processing
facilities, the dried, cleaned natural gas enters the gas transmission pipeline
system, analogous to the oil trunk line system.
Products Pipelines
Once oil is refined, product pipelines transport it to storage and distribution
terminals. Refined oil products include automotive gasoline, diesel, home
heating oils, ammonia, and other liquids. Other products pipelines transport
liquefied petroleum gases (LPG) and natural gas liquids (NGL) from
processing plants, where oil and gas are produced, to refineries and
petrochemical plants.
Breakout Tanks
Breakout tanks are above ground tanks used to relieve surges in a hazardous
liquid pipeline systems or to receive and store hazardous liquid transported by
a pipeline for reinjection and continued transportation by the pipeline.
V.A.2. Industry Size and Geographic Distribution
Variation in facility counts occur across data sources due to many factors,
including reporting and definition differences. This document does not
attempt to reconcile these differences, but rather reports the data as they are
maintained by each source. The Bureau of the Census segregates economic
data depending on whether an establishment maintains a payroll. In the
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transportation industry, many owners/operators are independent businesses
with no employees, while others, including companies involved with pipelines,
hire contracted employees who are reported under other entities' payrolls.
The following data is available only for establishments with payrolls.
Industry Size
According to the Census Bureau, the pipeline industry consists of
approximately 4,900 establishments and employs nearly 170,000 people.
Exhibit 15 illustrates the facility size distribution for the industry based on
1992 U.S. Census Bureau data.
Exhibit 15
Facility Size Distribution of Pipeline Industry*
Industry
Crude Petroleum Pipelines
Refined Petroleum
Pipelines
Pipelines, NEC**
Natural Gas Transmission
Natural Gas Transmission
and Distribution
Natural Gas Distribution
Mixed, Manufactured, or
Liquefied Petroleum Gas
Production and/or
Distribution
Gas and Other Services
Combined
Total
SIC
Code
4612
4613
4619
4922
4923
4924
4925
4932
Total Employees
10,355
5,578
846
12,928
69,311
65,239
445
4,459
169,161
Total Number of
Facilities
405
358
81
515
1,648
1,734
71
124
4936
Employees per
Facility
25.6
15.6
10.4
25.1
42.1
37.6
6.3
36.0
34.3
Source: Compiled from official 1992 statistics
*Facilities with Payrolls only
**Not Elsewhere Classified
of the U.S. Bureau of the Census.
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Geographic Distribution
State data is available only for those facilities with payrolls, as discussed
above. Because the Census Bureau does not segregate data for the natural
gas sectors covered by this profile, State-by-State information is available only
for oil pipelines. The oil pipeline industry is anchored in the Southwest, with
Texas, Louisiana, and Oklahoma accounting for over one-third of all
reported establishments. California, with 55 pipeline facilities, and Illinois,
with 41, have the next highest numbers of oil lines.
Exhibit 16 illustrates the number of oil pipeline establishments per State as
recorded by the U.S. Census for 1992.
Exhibit 16
Geographic Distribution of Oil Pipelines*
t
Source: Compiled from official 1987 statistics of the U.S. Bureau of the Census.
^Establishments with payroll only.
V.A.3. Economic Trends
Most gathering and long-distance pipelines in the U.S. are owned by pipeline
companies whose sole function is to operate a pipeline system. Historically,
natural gas in the U.S. was purchased by the pipeline company from the
producer, transported to market, then resold to a local distribution company.
Now, most gas is sold directly to the local distribution company the producer,
Qt-n-l »-»i»-»o1i*ie» /*i~»rv*ttafiioo r\rr\\r\A& r\nK/ ci trancnr*rtatirm cAr\/m.£» Oil r\n tn*^
producer, transported to market, tnen resoiu to a locai uisuiuuuun uu
Now, most gas is sold directly to the local distribution company the pn
and pipeline companies provide only a transportation service. Oil,
on the
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other hand, has traditionally been transported in the U.S. via pipeline by a
shipper/owner, who is generally a refiner as well (Kennedy).
Annual reports filed for 1994 with the Federal Energy Regulatory
Commission (FERC) show that both natural-gas and petroleum liquids
pipeline companies increased their net incomes in 1994 despite declining
operating figures. The ongoing shift of natural gas pipelines to primarily
transportation providers was reflected by an increase in volumes of gas moved
for others while volumes sold declined. Liquids pipelines moved nearly the
same number of barrels in 1994 as in 1993, but showed an increase in barrel-
miles, a measure of heightened efficiencies (Oil and Gas Journal November
1995).
The nearly 410,000 miles of pipeline in the U.S. in 1994 represents a 2.2
percent, 9,000 mile, decline from the previous year. All pipeline mileage
operated to move natural gas in interstate service declined nearly 4,000 miles,
while mileage used in deliveries of petroleum liquids fell more than 5,000
miles. Transmission pipeline mileage showed little change from 1993 to 1994.
Transmission mileage accounted for 77.5 percent of all natural gas mileage
reported to FERC. The more than 128,000 miles of crude oil and product
trunk lines represented more than 80 percent of all liquids mileage operated.
Natural gas companies have completed the shift from being marketers to being
transporters that began when the FERC began implementing a series of
regulatory orders that increased efficiency and heightened competition by
establishing open-access transportation. This allowed traditional pipeline
customers to buy gas from other sellers and have the pipelines provide
transportation only. A final piece of regulatory restructuring occurred in 1992
with the release of FERC Order 636, requiring pipelines to offer gas sales,
transportation, and storage services separately. In 1994, gas pipeline
companies moved nearly 20 times as much gas for other companies as they
sold from their own systems. Exhibit 17 demonstrates the relationship
between pipelines, marketers, producers, and users of natural gas.
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Exhibit 17
Natural Gas Delivery Infrastructure
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U.S. crude oil and product oil trunk line traffic also increased in 1994. Crude
oil traffic increased by 33 percent, while product traffic saw a modest rise of
nearly three percent.
A solid measure of the profitability of oil and natural gas pipeline companies
is the portion of operating income that is net income. For liquid pipeline
companies in 1994, income as a portion of operating revenues was 29.5
percent, up 'from 25.4 percent in 1993. Income as a portion of revenues for
natural gas companies was 14.3 percent, a marked increase from the 9.1
percent level reported in 1993.
Available information concerning future construction for the gas pipeline
industry indicates a slow growth rate. Based on filings during the 12 months
ending June 30, 1995, 725 new miles of land pipeline were proposed, and
nearly 78,000 horsepower of new or additional compression were applied for.
The world oil price (the average cots of imported crude oil for U.S. refiners)
is not expected to move significantly in 1996 from its current level of
approximately $16 per barrel. Despite the continued rise in world oil demand
over the forecast period, expected to exceed one million barrels per day per
year, world oil production capacity increases should accommodate the
demand growth in a balanced manner, keeping average prices relatively flat.
V.B. Operations in the Pipeline Industry
Gas and oil pipelines are essentially similar, with the greatest operational
difference resulting from the varying needs of transporting gas versus liquid.
Oil pipelines require pumps to propel their liquid contents, while gas lines rely
on compression to force the resource through the pipe. In both pump and
compressor stations, corrosion of piping and vessels must be monitored
constantly to prevent failure.
Most pipelines fall into three groups: gathering, trunk/transmission, or
distribution. One type of gathering pipeline is flowlines. Flowlines are small-
diameter pipelines that are owned by the producer and connect individual oil
or gas wells to central treatment, storage, or processing facilities in the field.
Another gathering system made up of larger-diameter lines, normally owned
by a pipeline company rather than an oil or gas producer, connects these field
facilities to the large-diameter, long-distance trunk or transmission line. In
some cases, individual wells are connected directly to the pipeline company's
gathering system. Crude trunk lines move oil from producing areas to
refineries for processing. Gas transmission lines carry natural gas from
producing areas and treatment/processing facilities to city utility companies
and other customers. Through distribution networks of small pipelines and
metering facilities, utilities distribute natural gas to commercial, residential,
and industrial users.
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Refined liquids and products, such as gasoline, kerosene, fuel oil, and jet fuel
are transported thousands of miles throughout the U.S. in product pipelines.
Efficient long distance transport by pipeline requires high operating pressures,
typically 500-1200 psi. Liquefied petroleum gases such as propane, butane,
and their mixtures, are usually liquids under normal line operating pressures,
so the pipelines transporting them are classified as liquid lines. Pump stations
are needed on liquid lines at line friction, and elevation changes. Storage
structures, such as tank farms for liquids and, increasingly, underground salt
caverns for propane, are also used as buffers in transmission network
operations and to distribution points of contact. Common pipeline operations
are discussed below.
V.B.I. Pigging
Pipeline pigs are used for multiple purposes in both liquid and natural gas
pipelines. A mechanical pig consists of a steel body with rubber or plastic
cups attached to seal against the inside of the pipeline and to allow pressure
to move the pig through the line. Brushes and scrapers are attached to the pig
to facilitate cleaning or other functions. Pigs and spheres are forced through
the pipeline by the pressure of the flowing fluid.
Mechanical pigs have traditionally been used to clean or segregate fluids
within liquid pipelines. Mechanical pigs are most often used in gas pipelines
to clean the line and maintain maximum efficiency. Downstream of
compressor stations, lubricating oil from the compressors needs to be
removed from the gas lines. On the intake side of both compressor and pump
stations, cleaning pigs are used to prevent unwanted materials from
contaminating the pumps or compressors. Recently, the use of pigs has
increased as sophisticated instruments are used to monitor pipeline conditions
and detect potential problems.
Large amounts of debris can be removed by a pig run over a long distance.
For example, assume a pig is run in a 24-inch diameter pipeline that is 100
miles long and removes 0.016 inches of wax material from the wall of the
pipeline. After 100 miles, the pig would be pushing a plug of wax about
1,450 feet long (Kennedy). Several sweeps by the pig may be required to
effectively clean the line. Both brush and scraper pigs contain holes that allow
fluid to bypass the pig, preventing buildups in front of the machine that could
cause plugging.
V.B.2. Pipeline Leaks
Pipeline leaks are considered either small, medium, or large. Small leaks are
below the limits of current computational pipeline monitoring leak detection
capabilities. They can be detected with chemical sensing cables or by finding
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small pools of leaking product or dead vegetation on the pipeline right of way.
They result from small, stable fractures or small corrosion holes that result in
leak rates usually less than one percent of flow. Many vendor- and company-
developed systems can detect leaks as small as 0.1 percent flow in field tests,
but pipeline operators are not. counting on this capability and are continuing
with visual inspections (US DOT/RSPA/Volpe Center 1995). Small leaks can
stay small and go unnoticed for weeks.
Medium leaks are detectable with some inferential leak detection methods, but
are not large enough to cause a loss of working line pressure. Spill rates as
high as 100 bbls per hour have gone undetected for up to a day on large lines
without the use of sophisticated detection systems. Medium leaks are caused
by fractures that remain narrow and by worn gaskets and valve stem packings.
Large leaks result in a rapid loss of working line pressure, which will generate
an alarm to the dispatcher, even without a leak detection system (LDS). They
are caused by third party damage and by unstable fractures that can grow
many feet in length. Many high carbon steels used before T970 are prone to
unstable fracture. Hydrogen gas, generated by cathodic protection systems
with excessively high voltage, and hydrogen sulfide, found in sour crude oil,
can make steel brittle and more prone to such fractures.
Improvements in materials, construction technologies, and inspection and
monitoring techniques have reduced the incidence of damage to pipelines. In
Western Europe, for example, gas leaks have dropped by 30 percent in the
past 20 years, despite an aging pipeline system.
V.B.3. Pipeline Inspections
More than half of the gas transmission pipeline capacity in the U.S. will be
over 40 years old by the year 2000. It is becoming increasingly important to
guarantee the structural integrity of these pipelines through structural
monitoring and periodic inspections. In addition, pipelines in unstable terrain
must be monitored using geotechnical instruments such as inclinometers and
pezometers, as well as by direct measurement of pipeline deformations, using
strain gauges. Over the past 50 years, methods for performing these tasks
have steadily improved.
Leak detection methods may be divided into two categories, direct and
inferential. Direct methods detect leaking commodity outside the pipeline.
Inferential methods deduce a leak by measuring and comparing the amount of
product moving through various points on a line.
Traditionally, pipelines have been inspected visually by walking along this line
or patrolling the pipeline route from the air. Today, leak detection ha become
more thorough, in part to meet environmental and safety regulations. A
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thorough inspection program requires both systematic periodic controls (e.g.,
patrolling the line or cathodic protection measurements) and specific
occasional controls (e.g., in-line inspection or hydrostatic retesting).
Inspection programs must address the needs of the pipeline, requiring a
detailed knowledge of construction characteristics, past and present service
conditions, the local environment, and maintenance history. Factors
influencing the rate of detection include the type of fluid, the accuracy of
measuring systems, line size, pipe thickness, length of the line, analytical
equipment, and the experience of the personnel involved.
One successful inspection technology is the instrument internal inspection
device, commonly referred to as the smart pig. Growing out of earlier
technology (mechanical pigs used for cleaning), smart pigs carry detection and
logging tools that store data on the state of the pipeline including data on
metal loss, pits, gouges, and dents while moving through the pipeline system.
The smart pig is launched from a pig launcher (a spur off the mainline), run
through the pipeline segment, trapped, and removed from the pipeline. The
data is then downloaded from the start pig data storage unit and analyzed.
The smart pig technology is based on the use of a single "sensor," called
magnetic flux leakage, or MFL. MFL pigs can detect metal loss, usually the
result of corrosion. Based on limited data, smart pigs are able to detect
approximately 60 percent of pipe defects. They cannot detect stress corrosion
cracking, longitudinal cracks, small defects, or gouges and dents caused by
excavation damage. An emerging technology called ultrasonic sensor
technology can detect smaller cracks and defects. However, sensors currently
require liquid to serve as a contact between the sensor and the material being
inspected. Research is underway to develop ultrasonic sensors that can
function in a dry natural gas pipeline. One of the most difficult inspection
hurdles is the many miles of pipes that cannot be inspected using pigs. Design
constraints such as intrusive valves, varying pipe diameters, and sharp turns
make internal pipe inspection difficult.
Another inspection practice is to measure the amount of pressure and volume
in a pipeline. This is done through metering. Metering measures the amount
of flow in and out of a pipeline segment. This approach is effective using both
simple and complex leak detection systems. The detection of small leaks can
be enhanced by sophisticated instrumentation and the use of computer models.
Natural gas pipelines can be inspected for leaks with surface-sampling
instruments by the flame-ionization principle. These units are made up of a
sampling probe with a pump to draw an atmospheric sample to a detection
cell. In the cell, the sample envelops a small hydrogen flame and carbon ions
flow to a collector plate, causing an imbalance in the circuit that deflects the
indicating meter. Because natural gas weighs less than air, it rises to the
ground surface as it progresses through the atmosphere. Leaks in liquid
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natural gas pipelines are not as easily detected, and the soil around the line
must be tested for constituents like propane and butane. Exhibit 18 shows
some of the practices used to monitor pipelines and the types of damage they
can reveal.
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Exhibit 18
Methods of Monitoring Pipelines
PRACTICES
CONDITIONS
OUTSIDE FORCES
3rd party damage
Earth movements
METAL LOSS
External corrosion
Internal corrosion
Gouges
GAS LEAKAGE
COATING
CRACKS
Scmn weld
Girth weld
Stress corrosion
Fatigue
Selective corrosion
GEOMETRY
Ovality, buckles
Obstructions, dents
Ovality, wrinkles
Bend radius
Pipeline movement
METALLURGICAL
Inclusions
Hard spots
Ltiminations
R-O-W
PATROL
Aerial Patrols
X
X
X
Ground Systems
X
X
X
CORROSION
CONTROL
CP
Measurements
X
X
-
Close Interval
X
X
£ E2
o S
§•'3
0 °
0 S
X
IN-LINE
INSPECTION
Vi
£
X
X
X
X
X
Geometry Pigs
X
X
X
X
X
X
X
Mapping Pigs
X
X
X
Cameras
X
X
X
X
BELLHOLES
§
It
> 5 •
X
X
X
X
X
X
X
X
X
X
X
X
NDE
Examination
X
X
X
X
X
X
X
X
X
TESTS
Hydrostatic
Retesting
X
X
X
X
X
X
X
X
X
Source: Natural Gas Technologies, 1993.
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V.B.4. Glycol Dehydration Units
Glycol dehydration units are commonly used to remove water vapor from
natural gas. Glycol dehydration of natural gas streams helps prevent
corrosion and the formation of hydrates in pipelines. Up to 40,000 glycol
dehydration units may be operating in the U.S. Approximately 17 to 18
trillion cubic feet per year of natural gas is currently dehydrated in North
America, with a large fraction of that amount being treated in the United
States.
#
During the water removal process, the glycol picks up other compounds from
the natural gas that can become part of waste streams. The most significant
issue is air emissions from the reboiler still vent. Increasing regulatory
pressure has made emissions of benzene, toluene, ethylbenzene, the xylene
isomers (BTEX), and volatile organic .compounds (VOC) from the reboiler
still vent of glycol dehydration units a major concern of the natural gas
industry.
Varying amounts of water accompany the production of natural gas,
depending on the temperature and pressure of the gas and the age of the field.
In addition to the produced water, most natural gas is saturated with water
vapor at the production temperature and pressure. The water vapor content
of saturated natural gas can be estimated given the temperature and pressure
of the gas. For example, at 800 psig and 80 °F, natural gas may contain as
much as 38 pounds of water per million standard cubic feet (MMSCF). In
addition, sour natural gas (i.e., gas containing significant concentrations of
hydrogen sulfide and carbon dioxide) will have a higher water content than
sweet gas.
As the pressure and temperature vary in the gas pipeline, water can combine
with the natural gas molecules (e.g., methane, ethane, and propane) to form
solid hydrates that can block or plug a pipeline. Hydrates are crystalline
structures composed primarily of water and hydrocarbons; methane can form
hydrate cells with up to 136 molecules of water. Hydrates may also
incorporate other gases such as hydrogen sulfide, ammonia, carbon dioxide,
acetylene, and bromine into their structure.
Initially, small hydrate crystals will form in the flowing gas when free liquid
water is present at the proper temperature and pressure. These small crystals
become condensation nuclei, and, as they collide and stick together, larger
crystals are formed. They will also accumulate on obstructions such as valves,
orifice meters, or sharp objects where pressure and flow rate changes occur.
Eventually, these crystals can grow to become a solid block of hydrates that
can completely close off a pipeline or other equipment at high pressure.
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Water also increases the corrosivity of the acid gases in the natural gas. Upon
cooling, water may condense in the pipeline and cause slug flow, resulting in
increased pipeline corrosion, erosion, and pressure drop.
To prevent the formation of hydrates at pipeline pressures and to limit
corrosion, natural gas must be dehydrated before it is sent to the pipeline. In
the U.S., the typical pipeline specification for the water content of the gas is
7 Ib/MMSCF of natural gas.
V.C. Pollution Outputs and Causes of Pipeline Leaks
Unlike the other pollution output sections in the document, this section
reflects the importance of determining the causes of pipeline ruptures, rather
than focusing on the material released. By definition, most pollution outputs
associated with pipelines are the oil and gas resources and products that the
pipelines convey.
The Federally-regulated pipeline system has consistently improved its safety
record over the last 25 years. However, there are still about 20 large (1,000
barrels or more) spills on the DOT's Office of Pipeline Safety (OPS) regulated
liquids lines each year (US DOT/RSPA/Volpe Center 1995). Between 1988
and 1994, the OPS received 1,401 reports of hazardous-liquid spills on U.S.
pipelines in which operators claimed a total of 1.2 million barrels of lost
product and $220 million in property damage, as well as a number of injuries
and fatalities.
Large crude and other viscous product spills are difficult and expensive to
clean up. Lighter products, such as gasoline and highly volatile liquids pose
less of a cleanup problem, but the risk of fire and explosion is significant.
Much of the improvement in the pipeline safety record over the last 25 years
has resulted from technical developments such as those in pipeline
components, construction, inspection, and corrosion control.
V.C.I. Pipeline Failures
According to the DOT, for gas pipelines, 40 percent of leak/spill incidents are
due to outside force or third-party damage; 21 percent are due to corrosion;
16 percent to material construction defects, and 23 to operational causes. For
oil pipelines, only 18 percent of incidents are due to outside force or third-
party damage; 20 percent due to corrosion, 16 percent due to material
construction defect, and 45 percent to operational incidents (US DOT
National Pipeline Safety Summit 1994, Data prepared by the NJ Institute of
Technology). Exhibits 19 and 20 provide more specific breakdowns of the
causes of pipeline leaks for hazardous liquid pipelines and natural gas pipelines
as well as a breakdown of the resulting damage.
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Exhibit 19
Hazardous Liquid Pipeline Incident Summary by Cause - 1994
Cause
Internal
Corrosion
External '
Corrosion
Defective
Weld
Incorrect
Operation
Defective
Pipe
Outside
Damage
Malf.. of
Equipment
Other
Total
Number of
Incidents
9
38
21
8
11
57
22
78
244
Percent of
Total
Incidents
3.69
15.57
8.61
3.28
4.51
23.36 .
9.02
31.97
100
Property
Damage
$282,000
$1,833,043
$4,320,680
$15,600
$2,154,000
$35,593,513
$1,159,517
$11,095,251
$56,453,604
Percent of
Total
Damages
0.50
3.25
7.65
0.03
3.82
63.05
2.05
19.65
100
Deaths
0
, 0
0
0
0
0
0
1
1
Injuries
0
0
0
0
0
1,853
1
4
1,858
Source: DOT Office of Pipeline Safety, 1995.
Exhibit 20
Natural Gas Pipeline Incident Summary by Cause - 1994
Cause
Internal
Corrosion
External
Corrosion
Damage from
Outside Forces
Construction/
Material Defect
Other
Total
Number
of
Incidents
20
13
23
9
15
80
Percent of
Total
Incidents
25.0
16.25
28.75
11.25
18.75
100
Property
Damage
$2,632,812
$2,028,835
$32,127,680
$342,647
$8,038,319
$45,170,293
Percent of
Total
Damages
583
4.49
71.13
0.76
17.8
100
Deaths
0
0
0
0
0
o
Injuries
0
1
16
2
0
Source: DOT Office of Pipeline Safety, 1995.
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V.C.2. Glycol Dehydration - Inlet Separator
The inlet separator removes liquid water, heavy hydrocarbons, brine solution,
and particulate matter such as sand, pipeline scale, and rust, or iron sulfide
from the incoming natural gas. The vessel is typically sized on the basis of
operating pressure and gas throughput to ensure that adequate separation
occurs and carryover is prevented. The liquid level must be regulated or
checked regularly so that plugs or upsets do not result in carryover; one way
to do this is to install a high-liquid-level shutdown. The liquid drain line
should be protected from freezing; if this line is frozen or plugged, the
separator will not remove any liquids. A mist eliminator in the top of the
separator is usually sufficient to reduce or prevent the carryover of liquid
droplets and particulate matter, although a filter may be required if aerosols
or compressor oils are present in the gas stream.
The inlet separator is considered by many to be the most important part of a
glycol unit, because a properly designed inlet separator can eliminate many
downstream problems. If the inlet separator is undersized or poorly designed,
contaminants may be carried over into the absorber, resulting in the following
problems in downstream equipment:
Free liquid water may enter the absorber and overload the glycol in
the absorber, which may prevent the gas from being dried to pipeline
specifications.
• Hydrocarbon contamination of the glycol may cause foaming.
« Heavy hydrocarbons may foul the heat exchange surfaces in the
reboiler, resulting in poor heat transfer, localized thermal degradation
of the glycol, inadequate glycol regeneration, and eventual fire tube
failures.
• Sodium chloride and calcium chloride may enter the system. Sodium
chloride often precipitates in the reboiler, calcium chloride precipitates
in the coldest portions of the system such as the absorber. Salt
contamination may ultimately necessitate replacement of the glycol.
V.C.3. Breakout Tank Leakage
Leaking above ground storage tanks pose several environmental problems.
First, leaking above ground tanks can seriously contaminate groundwater,
often making it impossible to ever return the groundwater to drinking water
standards. Groundwater is a source of drinking water for over half the
country; in rural areas, nearly all residents drink water from groundwater
wells. Pipeline-related facilities are frequently located in populated areas that
may rely on groundwater for drinking. Leaking tanks can also pose health and
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fire hazards to nearby buildings or infrastructures such as sewers, since
gaseous components can migrate into these enclosed areas and concentrate
to toxic or combustible levels.
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Pollution Prevention
VI. POLLUTION PREVENTION/WASTE MINIMIZATION
VI.A. Introduction
The best way to reduce pollution is to prevent it in the first place. Some
companies have creatively implemented pollution prevention techniques that
improve efficiency and increase profits while at the same time minimizing
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 substitution of toxic chemicals. Some
smaller facilities are able to actually get below regulatory thresholds just by
reducing pollutant releases through aggressive pollution prevention policies.
The Pollution Prevention Act of 1990 established a national policy of
managing waste through source reduction, which means preventing the
generation of waste. The Pollution Prevention Act also established as national
policy a hierarchy of waste management options for situations in which source
reduction cannot be implemented feasibly. In the waste management
hierarchy, if source reduction is not feasible the next alternative is recycling
of wastes, followed by energy recovery, and waste treatment as a last
alternative.
In order to encourage these approaches, this section provides both general
and company-specific descriptions of pollution prevention activities that have
been implemented within the pharmaceutical 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 be, 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. 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 be
examined to determine how each option affects air, land and water pollutant
releases.
VLB. Rail Transportation
VI.B.1. Water Discharge
At locomotive maintenance facilities, eliminating water from the clean up
processes may enable a facility to seal off the floor drains and attain zero
discharge. Spent solvents and cleaning solutions are often toxic and/or
hazardous and should be disposed of in an environmentally safe manner rather
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Pollution Prevention
than by pouring them into the storm drain or waste water line. If hazardous
cleaning agents (e.g., solvents) are used, care should be taken to wear
protective safety gear and follow good housekeeping practices (e.g., clear
labeling of all chemicals and wastes to avoid misuse and potential injury or
contamination).
If a discharge is going to a wastewater treatment facility, it should be
pretreated. Pretreatment means reducing the amount of pollutants in a
discharge before it proceeds to a municipal wastewater treatment plant. If
waste water is discharged directly or indirectly (i.e., via percolation or
injection wells) into a stream, a facility must obtain and comply with the terms
of an NPDES or State permit.
When disposing of wastewater, the following activities will foster pollution
prevention:
If a municipal treatment plant is not available, or it will not accept the
waste, route the waste to a tank or container for proper accumulation,
treatment, and disposal.
• Keep wastewater from service bays out of storm drains by
constructing berms around hazardous material storage areas to keep
spills from leaving the storage area.
Do not discharge industrial wastes to septic systems, drain fields, dry
wells, cesspools, pits, or separate storm drains or sewers. Facilities
that use these types of disposal systems may be in violation of Federal,
State, or local requirements.
If there is a floor drain in the facility, it should be plumbed to an
oil/water separator or appropriate wastewater treatment facility.
Alternatives to water cleaning include recycled solvents in self
contained solvent sinks. Dry cleaning can include cleaning by wire
brush or bake oven.
Waste minimization in equipment cleaning may be achieved by reducing the
amount of water used to clean large equipment. A reduction in water usage
will translate into a reduction in the volumes of generated waste waters.
Axle protective coatings can be removed with 140 solvent or a similar non-
hazardous or aqueous solvent to avoid hazardous waste generation. The use
of hazardous cleaning compounds in outdoor large equipment cleaning can
also be avoided by using a detergent/water mixture or steam. In these
processes, waste waters must be channeled properly for treatment or disposal.
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For small cleaning operations, it is possible to switch from hazardous organic-
based to non-hazardous aqueous-based solvents. This will reduce the amount
of hazardous waste generated from cleaning operations. Solvent recycling can
also decrease hazardous waste production from small parts cleaning.
Spent solvents can be cleaned and recycled with a solvent still. Spent solvent,
if hazardous, must be treated and disposed of as hazardous waste, unless
recycled properly. Solvents should not be poured down sewer drains, mixed
with used oil, or stored in open containers that allow them to evaporate.
Certain aqueous parts washers can use detergents instead of solvents.
VI.B.2. Oil
Most facilities in the rail industry recycle used oil. Recycling used oil requires
equipment like a drip table with a used oil collection bucket to collect oil
dripping off parts. Drip pans can be placed under locomotive or rail cars
awaiting repairs in case they are leaking fluids. Some facilities use absorbent
materials (e.g., pigmat) to catch drips or spills during activities where oil drips
might occur. One facility has established a reuse system for its waste oil:
waste oil is transported to another facility where it is used for fuel. This
method decreased disposal and heating costs while reducing landfill waste
loads. Used oil burning of this nature has permitting implications that a
facility needs to follow. Used oil burning can also occur in on-site space
heaters under certain circumstances. Recycling used oil by sending it to a
commercial recycling facility saves money and protects the environment. To
encourage recycling, the publication "How To Set Up A Local Program To
Recycle Used Oil" is available at no cost from the RCRA/Superfund Hotline
at 1-800-424-9346 or 1-703-412-9810.
Another pollution prevention alternative some railroads have initiated is the
use of retention tanks on locomotives. Locomotive retention tanks catch
leaking oil from the engine compartment. The tanks are subsequently drained
to an appropriate waste treatment facility during routine maintenance and
servicing.
Spent petroleum-based fluids and solids should be sent to a recycling center
wherever possible. Solvents that are hazardous waste must not be mixed with
used oil, or, under RCRA regulations, the entire mixture may be considered
hazardous waste. Non-listed hazardous wastes can be mixed with waste oil,
and as long as the resulting mixture is not hazardous, can be handled as waste
oil. All used drip pans and containers should be properly labeled.
A Material Safety Data Sheets (MSDS) logbook should be kept in a central
location and be easily accessible during an emergency. Along with MSDS's,
an emergency response plan should posted at all times and each employee
should know where it is and what procedures are included in it. All
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Pollution Prevention
employees should be aware of and understand the properties and potential
adverse effects of the materials they handle.
Facilities should conduct audits of the spill possibilities at their facilities.
Spills can be avoided by determining those locations and situations where spill
events are likely to take place and making employees aware of them. Some
facilities have posted signs at likely spill locations or conducted training with
their employees on spill awareness and preparedness. In addition, MSDS
sheets can be centralized for easy access in case of a spill event. A folder or
binder can be used for this purpose and should be maintained by a designated
MSDS collection person.
VI.B.3. Waste from Maintenance and Repair Operations
Batteries may be recycled through suppliers. Batteries should be stored in an
open rack or in a water tight, secondary containment area like a concrete bin
with sealer on the floor and walls. Batteries should be inspected for leaks
and/or cracks as they are received at the facility. Acid residue from cracked
or leaking batteries is likely to be hazardous waste under RCRA because it is
likely to demonstrate the characteristic of corrosivity, and may contain lead
and other metals. Many waste batteries must therefore be handled as
hazardous waste. Lead acid batteries are not considered a hazardous waste
as long as they are recycled. Facilities have many battery disposal options:
recycling on site, recycling through a local rail facility, recycling through a
supplier, or direct disposal. Facilities should explore all options to find one
that is right for the facility. In general, recycling batteries may reduce the
amount of hazardous waste stored at a facility, and thus the facility's
responsibilities.under RCRA. The following best management practices are
recommended when sorting used batteries:
Palletize and label them by battery type (e.g., lead acid, nickel, and
cadmium)
Protect them from the weather with a tarp, roof, or other means
Store them in an open rack or in a water tight secondary containment
unit to prevent leaks
Inspect and document them for cracks and leaks as they come in to
your storage program. If a battery is dropped, treat it as if it is
cracked
Avoid skin contact with leaking or damaged batteries
Neutralize acid spills and dispose of the resulting waste as hazardous
if it still exhibits a characteristic of a hazardous waste.
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Coolants for locomotives are not glycol based, but are a nitrate-based
corrosion inhibitor in water. These type of waste coolants can be disposed to
most POTWs. Though much of the activities associated with vehicles takes
place at off-site service centers, some maintenance is performed on this type
of equipment, where coolants from maintenance vehicles and fleet vehicles
should be collected and recycled and not mixed with locomotive coolant.
Solvents containing chlorinated hydrocarbons should be stored in separate
containers and disposed of properly. When possible, coolant should be
discharged when the locomotive has stopped and is at a location where the
coolant can be collected and managed. Locomotive operators should be
familiar with the spill reporting requirements of the States in which they
operate, and act accordingly when a coolant discharge takes place.
Metal scrap from old machine parts that is likely to be contaminated with oil
(e.g., wheel truing scrap), should be stored under a roof or covered with
tarpaulin to protect it from the elements. This scrap metal should also be
protected from rain water to eliminate the potential of contaminated runoff.
Metal scrap can be recycled if sorted and properly stored. Labeled recycling
containers can be placed around the shop for easy access and later sorting.
Liquid drum containers, if stored outdoors, should be in a berm and on a
paved impermeable surface or in a secondary containment unit to prevent
spills from running into water bodies.
Metal filings from parts machining should be collected and recycled if
possible. In no case should the filings be allowed to fall into a storm drain.
VI.B.4. Paint
To reduce the amount of wastes created by painting operations, all paint
should be used until containers are completely empty. "Empty" containers of
latex paint may be disposed of as solid waste. Used containers of hazardous
substances may need to be disposed of as hazardous wastes, if they are not
completely empty. To prevent environmental problems, it is possible to
switch from hazardous organic-based to non-hazardous aqueous-based paints.
Also, paint may be purchased in recyclable and/or returnable containers to
reduce disposal costs.
VI.B.5. Fueling
Self-locking fueling nozzles minimize the risk of both fuel spillage and air
pollution by ensuring a secure seal between the fuel source and tank. During
locomotive fueling, personnel should look for fuel drippage and spillage.
Catchment pans on either side of and between the rails will collect fuel spills
and prevent soil contamination. These pans should be drained to an oil-water
separator or retention tank. These pans can be cleaned periodically by
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railroad personnel to remove fuel debris and accumulated wastes for proper
disposal. In case of a spill, facilities should keep the following on hand:
absorbent booms, pads, or blankets to help contain spills and soak up pooling
liquid; rubber gloves and boots; and a shovel.
VI.C. Trucking
VI.C.l. Truck Terminal and Maintenance Facilities
Trucks require regular changing of fluids, including oil, coolant, and others.
To minimize releases to the environment, these fluids should be drained and
replaced in areas where there are no connections to storm drains or municipal
sewers. Minor spills should be cleaned prior to reaching drains. Used fluids
should be collected and stored in separate containers. Automotive fluids can
often be recycled. For example, brake fluid, transmission gear, and gear oil
are recyclable. Some liquids are able to be legally mixed with used motor oil
which, in turn, can be reclaimed.
During the process of engine and parts cleaning, spills of fluids are likely to
occur. The "dry shop" principle encourages spills to be cleaned immediately,
without waiting for the spilled fluids to evaporate into the air, be transmitted
to land, or to contaminate other surfaces. The following techniques help
prevent spills from happening:
Collect leaking or dripping fluids in designated drip pans or
containers. Keep all fluids separated so that they may be properly
recycled.
Keep a designated drip pan under the truck while unclipping hoses,
unscrewing filters, or removing other parts. The drip pan prevents
splattering of fluids and keeps chemicals from penetrating the shop
floor or outside area where the maintenance is taking place.
Immediately transfer used fluids to proper containers. Never leave
drip pans or other open containers unattended.
Radiator fluids are often acceptable to antifreeze recyclers. This includes
fluids used to flush out radiators during cleaning. Reusing the flushing fluid
minimizes waste discharges. If a licensed recycler does not accept the spent
flushing fluids, consider changing to another brand of fluid that can be
recycled.
If the maintenance facility services air conditioners, special equipment must
be used to collect the Freon or other refrigerant because it is not permissible
to vent the refrigerant to the atmosphere. Reusing the refrigerant on site is
less costly than sending the refrigerant to an off site recycler.
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VI.C.2. Vehicle Washing
Vehicle washing has become a major environmental compliance issue for most
companies that operate a fleet of vehicles. The following pollution prevention
activities will help ensure that a facility is addressing potential sources of
pollution:
Waste water discharge can be prevented by dry washing vehicles using
a chemical cleaning and waxing agent, rather than detergent and
water. The dry washing chemical is sprayed on and wiped off with
rags. No waste water is generated. Dry washing is labor intensive
and creates solid waste that must be disposed of properly.
Waste water can be contained by washing at a low point of the
facility, blocking drains from the facility using a containment dike or
blanket, or washing on a built-in or a portable containment pad.
Waste water can be disposed of by evaporation from the containment
area, or by discharging the waste water to a sanitary sewer system.
(Pretreatment of waste wash water generated from manual washing
before disposal to the sanitary sewer is not usually required for vehicle
exterior (no undercarriages or engines) washing. Permission must be
obtained from the sewer district before waste wash water can be
drained, pumped, or vacuumed to a sanitary sewer connection.
VI.C.3. Stormwater Pollution Prevention
Under the Clean Water Act NPDES requirements, discussed in more detail
below, truck maintenance facilities must maintain a stormwater pollution
prevention plan. The following information is taken from Stormwater
Pollution Prevention Plan for the Trucking Industry, American Trucking
Associations, 1993.
An effective pollution prevention plan for trucking facilities strives to prevent
pollution at the source, before it enters the environment. This is best done by
properly addressing the following potential sources of pollution:
Underground and above ground storage tanks of petroleum fuel
Drips, spills, and releases from fueling operations
Routine maintenance, including tire, battery, fluids, and oil changes
Containers of antifreeze, solvents, used oil, and other liquid wastes
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Management of shop drains (sometimes connected to an oil-water
separator) which may, accumulate oil, grease, and other shop wastes
• Vehicle washing operations
Storage of scrap tires and batteries.
The American Trucking Associations has developed a flowchart, duplicated
as Exhibit 21, that directs the attention of facility managers to the sources of
environmental contamination, and alerts them to the practices that best ensure
Exhibit 21
Storm Water Pollution Prevention Flowchart
EXHIBIT 21
Storm Water Pollution Prevention Flowchart
PLANNING AND ORGANIZATION
• Form Pollution Prevention Team
• Review other plans
V
e
ASSESSMENT PHASE
• Develop a site map
• Inventory and describe exposed
materials
• List significant spills and leaks
• Test for non-storm water discharges
• Evaluate monitoring data
• Summarize pollutant sources and risks
+
BMP IDENTIFICATION PHASE
• Baseline Best Management Practices
• Select activity - and site-specific
BMPs
t
IMPLEMENTATION PHASE
• Implement BMPs
• Train employees
*
EVALUATION MONITORING
• Perform annual site inspection/BMP
evaluation
• Perform recordkeeping and reporting
• Review and revise plan
Source: Storimvater Pollution Prevention Manual for the Trucking Industry, ATA, 1993.
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VI.C.4. Alternatively-Fueled Vehicles
One way to reduce vehicle emissions from the trucking industry is to switch
to alternative fuels. Natural gas vehicles, for example, are a viable alternative
to gasoline-and diesel-powered transportation.- Almost any gasoline- or
diesel-powered vehicle can be converted to run on natural gas including, light-
duty trucks and vans, medium-duty trucks, and even heavy-duty trucks such
as semi-tractors. Converting a gasoline-powered vehicle to run on natural gas
involves installing a natural gas fuel system 'and storage tanks without
removing any existing equipment. Diesel conversions are somewhat more
complicated because they also involve reducing compression and adding a
sparked-ignition system. Other fuels suitable for trucks can include methanol,
ethanol, and propane.
Some of the momentum to switch'to alternative fuels such as natural gas is
coming from legislation. Over the past few years, Congress has passed even
stricter clean-air laws, as well as incentives to encourage the use of alternative
fuels. Federal (and in some areas State) tax deductions for Alternative Fuel
Vehicles (AFVs) and related refueling equipment are available. The maximum
tax deductions range from $2,000 to $50,000 for each AFV and up to
$100,000 on refueling stations. Deductions on vehicles, including original
equipment manufactured vehicles or after-market conversions, apply to the
incremental cost of an AFV over the cost of its gasoline or diesel counterpart.
The deduction for AFVs can be taken by either an individual or a business, but
the deduction on refueling equipment applies only to businesses.
VLD. Pipelines
VI.D.I. Direct Leak Detection Enhancements
Direct leak detection is typically performed by line patrols who inspect the
pipeline right-of-way for pools of leaking product and dead vegetation.
Section 195.412 of the Federal pipeline safety regulation requires that
hazardous liquid pipelines be patrolled 26 times each year. A new technology
for direct leak detection is chemical sensing cable buried along the pipeline
right of way. Some cable systems can detect the presence and location of
hydrocarbon vapors. Other cables locate leaks by absorbing liquids, which
results in a loss in the cables' electrical conductivity at an identifiable location.
Sensing cables can offer superior detection times, sensitivity, and location
accuracy, especially in gathering lines, where the flows can be too irregular for
other methods. These cables must be buried close to the pipeline to work
well, and some liquid sensing cables must be dug up and replaced after every
detection. New burying methods are being developed for these cables to
lower their operating cost.
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VI.D.2. Supervisory Control and Data Acquisition (SCADA) Systems
The traditional inferential method of leak detection is called line balance,
where one measures the volume of product sent into the pipeline and
compares it with the volume that comes out the other end. Enhancement of
this method and others are used by SCADA and LDS systems to provide the
dispatcher with information that suggests a possible leak. SCADA systems
give pipeline dispatchers the ability to effectively monitor pipeline conditions
and control a pipeline's operation from a central location. SCADA systems
include pipeline sensing devices, a communications network, a centralized or
distributed data processing system, and a user interface for the dispatcher.
SCADA systems continuously monitor, transmit, and process pipeline
information for the control room dispatcher. Monitoring is conducted using
Remote Terminal Units (RTUs), which are placed at intervals along the
pipeline and at associated facilities, such as pump stations and delivery
terminals. RTUs periodically collect data from field instruments, which
measure pressure, temperature, flow, and product density. RTUs can also
receive information from vapor detectors and tank level gauges in pipeline
system routing and storage areas. RTUs process this information to varying
degrees and transmit it for analysis to a central computer through a
communications network. Information from RTUs may be transmitted by
company-owned lines, by a commercial telephone service, or by using ground-
or satellite-based microwave or radio communication.
The leak detection capabilities of most SCADA systems can be enhanced with
additional leak detection software and user interfaces. Field instruments
specifically designed for leak detection are also available for SCADA systems,
such as acoustic sensors and hydrocarbon cables.
VI.D.3. Hydrostatic Testing
Pipeline and utility companies test the pipes that comprise their system both
before they are buried and when they suspect that a section of pipe may need
maintenance. Hydrostatic testing is the process of filling a section of pipe
with water and pressurizing it to a level above normal operating levels. This
verifies the integrity of the pipeline.
Depending on the location of the pipeline, the water used in a hydrostatic test
is drawn from a local river, stream, or lake; taken from municipal supplies; or
trucked to the site. After air is bled from the pipeline, a pump raises the
pressure inside the pipe to the pre-determined testing level, where it is
maintained and monitored during the test period. Precision measurement
instruments are used to monitor pressures, and a record is maintained to chart
the results.
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VI.D.4. Cathodic Protection
Corrosion in pipelines is a common phenomenon, and must be controlled to
effectively prevent pipeline leaks or structural problems. Although modern
pipes are constructed of high quality steel, this will nevertheless corrode over
time. Corrosion results from an electrical current that naturally flows from a
pipe into the surrounding soil. As this occurs, metal loss, or corrosion, results.
One way to impede this process is to insulate the metal from the soil. This
occurs in the manufacturing process, when the pipe is coated. The coating is
rechecked at the construction site using a detector that looks for imperfections
or gouges that could occur during transportation. New coating is then applied
at the welded joints between pipe sections, first by sandblasting the weld, and
then applying the new coat.
To further protect the pipeline from corrosion, anodes or "ground beds" are
constructed at strategic points along the pipeline. These groundbeds provide
cathodic protection by inducing a very small electrical charge into the soil,
impeding the flow of electrons to the pipe.
The rectifier that induces the current into the ground bed is regularly checked
by pipeline personnel, who ensure that the system is applying sufficient current
to maintain cathodic protection to the pipeline. A single 200 foot ground bed
can protect as much as 50 miles of pipeline, but the low voltages used does
not harm animals or plants in the vicinity.
VI.D.5. Smart Pigs
Surveying a working pipeline for damage or corrosion can be disruptive to
consumers if sections of the pipeline must be taken out of service. One
nondestructive method of evaluation is a device called a smart pig. Smart pigs
are designed for use inside larger operating pipelines (as opposed to smaller
distribution lines) to identify possible corrosion defects or abnormalities.
Smart pigs are self-contained units consisting of three to five sections held
together by universal joints, allowing them to negotiate bends in the line. A
typical pig will have a recorder section for storing survey data, a magnetic
section that creates the magnetic field used to measure pipeline flaws, and a
drive section holding the battery power for the unit. Around the perimeter of
the pig are the transducers that measure the fluctuations in the magnetic field
indicating possible wall abnormalities.
The smart pig is placed into the pipeline at a pig launcher, which is a spur off
the mainline. Once the pig has been loaded, the launcher is pressurized so that
the pig enters the mainline. The pig will travel between five to ten miles per
hour while collecting data about the pipeline. To enable the pig to record its
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location while gathering data, devices called above ground markers (AGMs)
are placed at regular intervals along the surveyed pipeline.
The pig is removed from service at a pig trap or receiver. Crews prepare the
receiving site with a catch pan to collect pipeline liquids pushed ahead of the
pig. After removing the pig and placing it back into a holding trough, survey
personnel remove the tape recorder and download its records. The tape is
placed onto a special playback machine that feeds the data into instruments
that analyze the information and print out a log revealing information like the
location of potential corrosion sites or other anomalies not recognizable by
above-ground inspection methods.
VI.D.6. Breakout Tanks
To prevent spills and leaks, above ground tanks should have secondary
containment underneath tank bases and piping (or move piping above ground
for daily visual inspection) to capture any releases before soil or groundwater
is contaminated. Corrosion protection should, be added to tank bottoms.
Regular groundwater water monitoring should be employed and baseline
measurements should be taken at the time of installation.
VI.D.7. Proper Training
In a DOT study of remote control spill reduction technology, most pipeline
operators interviewed felt that the critical link in reducing the number of
incidents and the volume of pipeline spills lies with dispatcher training. They
frequently indicated that there was no substitute for a well-trained dispatcher,
especially not a software unit designed to automatically shut down the
pipeline. The dispatcher is often the final decision-maker in the process of
leak detection and pipeline shutdown. If dispatchers fail to recognize a
problematic situation and fail to intervene, unchecked spills are likely to be
large.
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Federal Statutes and Regulations
VII. SUMMARY OF APPLICABLE FEDERAL STATUTES AND REGULATIONS
This section discusses the Federal statutes and 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 VILA contains a general overview of major statutes
• Section VII.B contains a list of regulations specific to this industry
Section VII.C contains a list of pending and proposed regulations.
The descriptions within Section VII 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 clarification 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.
VILA. General Description of Major Statutes
Resource Conservation and Recovery Act
The Resource Conservation And Recovery Act (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 (ignitability, 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 must
obtain a permit either from EPA or from a State agency which EPA has
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authorized to implement the permitting program if they store hazardous
wastes for more than 90 days before treatment or disposal. Facilities may
treat hazardous wastes stored in less-than-ninety-day tanks or containers
without a permit. Subtitle C permits contain general facility standards 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 47 of the 50 States and two U.S. territories.
Delegation has not been given to Alaska, Hawaii, or Iowa.
Most RCRA requirements are not industry specific but apply to any company
that generates, 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 must follow to determine whether the material in
question 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 EPA ID number, preparing a manifest, ensuring proper
packaging and labeling, meeting standards for waste accumulation units, and
recordkeeping 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) (40 CFR Part 268) are regulations
prohibiting the disposal of hazardous waste on land without prior treatment.
Under the LDRs program, materials must meet LDR treatment standards prior
to placement in a RCRA land disposal unit (landfill, land treatment unit, waste
pile, or surface impoundment). 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 Management Standards (40 CFR Part 279) 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
processor, re-refiner, burner, or marketer (one who generates and sells
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off-specification used oil), additional tracking and paperwork requirements
must be satisfied.
RCRA contains unit-specific standards for all units used to store, treat, or
dispose of hazardous waste, including Tanks and Containers. 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 that store such waste, including large quantity
generators accumulating waste prior to shipment off-site.
Underground Storage Tanks (USTs) containing petroleum and hazardous
substances 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 includes upgrade requirements for existing tanks that must be
met by December 22, 1998.
Boilers and Industrial Furnaces (BIFs) that use or burn fuel containing
hazardous waste must comply with 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'sRCRA, Superfund and EPCRA Hotline, at (800) 424-9346, responds
to questions and distributes guidance regarding all RCRA regulations. The
RCRA Hotline operates weekdays from 9:00 am. to 6:00 p.m., ET, excluding
Federal holidays.
Comprehensive Environmental Response, Compensation, and Liability Act
The Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA), a 1980 law known commonly 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 m, also known as the
Emergency Planning and Community Right-to-Know Act (EPCRA).
The CERCLA hazardous substance release reporting regulations (40 CFR
Part 302) direct the person in charge of a facility to report to the National
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Response Center (NRC) any environmental release of a hazardous substance
which equals or exceeds a reportable quantity. Reportable quantities are 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 sites; however, EPA provides responsible
parties the opportunity to conduct removal and remedial actions and
encourages community involvement throughout the Superfund response
process.
EPA'sRCRA, Super/urn!andEPCRA Hotline, at (800) 424-9346, answers
questions and references guidance pertaining to the Superfund program.
The CERCLA Hotline operates -weekdays from 9:00 a.m. to 6:00 p.m., ET,
excluding Federal holidays.
Emergency Planning And Community Right-To-Know Act
The Superfund Amendments and Reauthorization Act (SARA) of 1986
created the Emergency Planning and Community Right-to-Know Act
(EPCRA, also known as SARA Title III), 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.
EPCRA §304 requires the facility to notify the SERC and the LEPC in the
event of a release equaling or exceeding the reportable quantity of a CERCLA
hazardous substance or an EPCRA extremely hazardous substance.
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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,
known commonly 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'sRCRA, Superfund and EPCRA Hotline, at (800) 424-9346, answers
questions and distributes guidance regarding the emergency planning and
community right-to-know regulations. The EPCRA Hotline operates
weekdays from 9:00 a.m. to 6:00 p.m., ET, excluding Federal holidays.
Clean Water Act
The primary objective of the Federal Water Pollution Control Act, commonly
referred to as the Clean Water Act (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 §502)
controls direct discharges into navigable waters. Direct discharges or "point
source" discharges are from sources such as pipes and sewers. NPDES
permits, issued by either EPA or an authorized State (EPA has authorized 42
States to administer the NPDES program), contain industry-specific,
technology-based and/or water quality-based limits, and establish pollutant
monitoring requirements. A facility that intends to discharge into the nation's
waters must obtain a permit prior to initiating its discharge. A permit
applicant must provide quantitative analytical data identifying the types of
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pollutants present in the facility's effluent. The permit will then set the
conditions and effluent limitations on the facility discharges.
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
particular facility falls within one of these categories, consult the regulation.
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
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(except drugs and paints); SIC 291-petroleum refining; and SIC 311-leather
tanning and finishing, 32 (except 323)-stone, clay, glass, and concrete, 33-
primary metals, 3441-fabricated structural metal, and 373-ship and boat
building and repairing.
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 31-leather and leather
products (except leather and tanning and finishing); SIC 3 23-glass products;
SIC 34-fabricated metal products (except fabricated structural metal); SIC
3 5-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.
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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 quality 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 technology-based standards for industrial users of
POTWs. Different standards 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.
Spill Prevention, Control and Countermeasure Plans
The 1990 Oil Pollution Act requires that facilities that could reasonably be
expected to discharge oil in harmful quantities prepare and implement more
rigorous Spill Prevention Control and Countermeasure (SPCC) Plan required
under the CWA (40 CFR §112.7). 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 §112.20) and for PCB transformers and PCB-
containing items were revised and finalized in 1995.
EPA's Office of Water, at (202) 260-5700, will 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
The Safe Drinking Water Act (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
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create a joint Federal-State system to ensure compliance with these standards.
The SDWA also directs EPA to 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 9:00a.m. through 5:30 p.m., ET, excluding Federal holidays.
Toxic Substances Control Act
The Toxic Substances Control Act (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
The Clean Air Act (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, volatile organic
compounds (VOCs), 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 section 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. Revised NAAQSs for particulates and
ozone were proposed in 1996 and may go into effect as early as late 1997.
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 source.
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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 I,
section 112(c) of the CAA 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 EPAuses
to regulate mobile air emission sources.
Title IV of the CAA establishes a sulfur dioxide nitrous oxide 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 CAA 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 of the CAA 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) and chloroform, were phased out (except for
essential uses) in 1996.
EPA's Clean Air 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
Hotline, at (800) 535-0202, answers questions about accidental release
prevention under CAA §112(r). In addition, the Clean Air Technology
Center's website includes recent CAA rules, EPA guidance documents, and
updates of EPA activities (www.epa.gov/ttn then select Directory and then
CATC).
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VII.B. Industry Sector Specific Regulations
The transportation industry is regulated by several different Federal, State,
and local agencies. As noted earlier, several government entities regulate
specific transportation sectors. For example, the Department of
Transportation's (DOT's) Research and Special Program Administration is
designed to ensure the safe, reliable and environmentally sound operation of
the nation's pipeline transportation system. The DOT has traditionally
established national standards that are not affected by local or State laws.
EPA has traditionally relied on delegation to States to meet environmental
standards, in many cases without regard to the methods used to achieve
certain performance standards. This has resulted in States with more stringent
air, water, and hazardous waste requirements than the Federal minimums.
This document does not attempt to discuss State standards, but rather
highlights relevant Federal laws and proposals that affect the rail, trucking,
and pipeline industries.
VII.B. 1. Rail Transportation
RCRA
Railroad facilities produce a variety of RCRA regulated wastes in the course
of normal operations and utilize underground storage tanks for product and
fuel storage. Many railroad facilities qualify as hazardous waste generators
under RCRA law. Under RCRA, it is the facility's responsibility to determine
whether or not a waste is hazardous. See 40 CFR 261.31 - 261.33 for a full
list of EPA hazardous wastes.
Some examples of hazardous wastes produced during railroad operations
include solvent residues from parts cleaning and spent nickel cadmium
batteries. Used oil is currently not listed as a hazardous waste under RCRA;
however, if used oil meets one of the hazardous waste characteristics (e.g.,
ignitable) or is mixed with a listed hazardous waste, it must be stored and
disposed of as a hazardous waste. Most waste oil generated by a railroad
(e.g., spilled diesel fuel, motor oil) is not a hazardous waste, but cutting oil,
hydraulic oils, and any oil containing heavy metals may require hazardous
waste handling.
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Potential RCRA hazardous wastes generated during railroad operations
include:
Absorbent materials contaminated with hazardous substances
Aerosol cans, still pressurized
Cutting oils, hydraulic oils, and oil with heavy metals contamination
Grit blast wastes
Ignitable paint thinners
Lead-based or ignitable paint and related wastes
Lead acid batteries, non-recycled
Nickel cadmium, nickel iron, and carbonaire batteries -
Oil filters constructed with "terne"metal (a lead-tin alloy)
Solvents and solvent sludge.
Clean Water Act
The CWA is set up to regulate two types of water pollution: one from a point
source (e.g., an outflow pipe from a parts-washing basin), the other from a
non-point source (e.g., non-drained ground where oil has dripped). The
CWA applies to a variety of railroad operations. Any railroad operation that
produces a wastewater (e.g., locomotive, rail car, and small parts washing)
or deposits substances on the ground that may be carried away by stormwater
(e.g., fuel and oil spills), will trigger CWA requirements.
The CWA requires the following from railroads:
NPDES or POTW permits
Stormwater discharge permits
Spill prevention control and countermeasure (SPCC) plans and spill
reporting.
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Exhibit 22
Clean Water Act Requirements Applicable to Railroads
NPDES Permits
Sets limits on volume and nature
of discharge
.Sets limits on quantity of certain
pollutants
Contains monitoring and
reporting requirement
Note: facilities 'discharging to
POTWs do not require NPDES
permits.
For certain industrial facilities,
required if stormwater drains to
a municipal separate storm
sewer system or directly to
receiving water
Required for facilities involved
in vehicle maintenance or
equipment cleaning
Site maps, drainage and
discharge structures, and other
information required by permit
applications
Triggered by oil or petroleum
product storage in excess of 660
gallons in a single tank or 1,320
gallons in aggregate at facility
Local environmental
representatives to be contacted
in case of discharge
Documentation of storage
vessels, types of containment,
emergency equipment available,
etc.
The CWA also requires facilities to develop SPCC plans for petroleum
products, such as oil, if they are stored in large quantities at a particular
railroad. SPCC plans document the location of storage vessels, types of
containment, dangers associated with a major release of material from the
tanks, types of emergency equipment available at each site, and procedures
for notifying the appropriate regulatory and emergency agencies. No SPCC
plan is considered complete until it has been reviewed and certified by a
Registered Professional Engineer.
Clean Air Act
The CAA establishes two major categories for air pollution regulation: mobile
sources (e.g., automobiles, locomotives) and stationary sources (e.g., power
boilers, solvent-based cleaning stations). Possible air pollution sources for the
railroad industry include boilers, incinerators, forges, foundries, painting or
refinishing operations, shop blasting and dust collection control systems,
degreasers, and the filling and maintaining of fuel storage tanks.
The CAA regulations on chlorofluorocarbons (CFCs) and asbestos-containing
materials also affect railroad operations. Equipment containing CFCs, such
as refrigeration units or air conditioning systems, are common. In addition,
many old railroad facilities have asbestos-containing materials in floor tiles,
ceiling tiles, siding, or thermal system insulation.
Title II of the 1990 CAA Amendments deals with "mobile sources" and seeks
to phase in a new set of limits on emissions between 1994 and 1998. If
necessary, the EPA has discretion to implement an additional round of mobile
source emission limits in 2003.
Section 213(a)(5) of the CAA requires EPA to regulate emissions from
locomotives. EPA is expecting to propose locomotive emission regulations
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in the latter part of 1996 and issue final regulations in the latter part of 1997.
The final regulations are expected to impose emission limits on
remanufactured and new locomotives.
TSCA
CERCLA
EPCRA
FIFRA
Railroad operations may be affected by TSCA with respect to electrical
equipment, such as transformers, containing PCBs. TSCA regulations require
proper use, inspection, labeling and marking, recordkeeping, storage,
reporting, transportation, management, and disposal of all equipment
containing PCBs.
Under CERCLA, incidents must be immediately reported when any spill or
release exceeds the Reportable Quantity (RQ). Such a release must be
reported if it:
Occurs on a railroad's property.
• Occurs during transport
Occurs at a mechanical fixed facility like repair shops or engineering
operations.
EPCRA requires companies to identify their facilities to enforcement agencies
and provide certain data about the chemicals used at those facilities. EPCRA
does not require the reporting of spills that are confined to the boundaries of
a facility. All railroads with fixed facilities should maintain Material Safety
Data Sheets (MSDSs) for the materials used or stored at the facility. Hard
copies should be kept at the facility's site or be available by computer or fax.
The transportation of hazardous materials and storage incident to such
transportation is exempted from EPCRA requirements.
FJFRA regulations are applicable to railroad operations where herbicides are
used to control weeds and brush, or when pesticides and rodenticides are used
for pest control in company buildings. FIFRA can also apply to the field
application of creosote when bridge timbers or switch ties are installed.
Railroad operations should only apply herbicides, both general and restricted
use, according to label instructions. Certification is required for use of
restricted use herbicides. Railroads often use outside contractors to apply
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these products. The National Railroad Contractors Association, an
organization comprised of railroad weed control contractors, provides
training for restricted use herbicide applicators.
Oil Pollution Act of 1990
See page 84.
VII.B.2. Trucking
Clean Water Act- NPDES Requirements
As discussed above under the general description of the Clean Water Act,
EPA published storm water regulations on November 16, 1990, which require
certain dischargers of storm water to waters of the U.S. to apply for NPDES
permits. According to the final rule, facilities with a "storm water discharge
associated with industrial activities" are required to apply for a storm water
permit." The rule states that transportation facilities classified as SIC 40, 41,
42 (except 4221-4225), 43, 44, and 5171 which have vehicle maintenance
shops, equipment cleaning operations, or airpost deicing operations are
considered to have a storm water discharge associated with industrial activity.
However, only those portions of the facility that are either involved in vehicle
maintenance (including vehicle rehabilitation, mechanical repairs, painting,
fueling, and lubrication), equipment cleaning operations, airpost deicing
operations, or which are otherwise identified under paragraphs (b)(14)(I)-(xi)
of section 122.26 are considered to be associated with industrial activity.
Storm water discharges associated with industrial activity that reach waters
of the U.S. through municipal separate storm sewer systems (MS4s) are also
required to obtain NPDES storm water permit coverage. Discharges of storm
water to a combined sewer system or to a POTW are excluded.
The storm water regulation presents two options for storm water discharges
associated with industrial activity. The first option is to submit an individual
application consisting of NPDES Forms 1 and 2F. The second option is to
file a Notice of Intent (NOI) to be covered under a general permit.
Regardless of which permit option a facility selects, the resulting storm water
discharge permit will most likely contain a requirement to develop and
implement a Storm Water Pollution Prevention Plan. Trucking companies
which store petroleum products in quantities over 1320 gallons in above
ground tanks are also required to develop a Spill Prevention Control and
Countermeasures plan (SPCC).
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Clean Air Act - Emissions Standards
The most significant CAA regulations under the CAA that affect the trucking
industry address mobile source air emissions from truck engines. EPA has set
limits on exhaust emissions from new heavy-duty engines. EPA considers
heavy-duty truck engines to be those in vehicles weighing at least 8500
pounds gross vehicle weight rating (GVWR). In 1994, the regulations
required all heavy-duty truck engines to reduce the emission of nitrogen
oxides (NOx) from 5.0g/bhp-hr to 4.0 g/bhp-hr by 1998. Emissions standards
are also set for hydrocarbons (HC), carbon monoxide (CO), and particulates
(PM). Exhibit 23 displays the past, current, and future emission standards for
heavy-duty truck engines.
Exhibit 23
Heavy-Duty Truck Engine Emission Standards
Model Year
1991
1994
1998
6
5
4
HC
1.3
1.3
1.3
CO
15.5
15.5
15.5
PM
0.6
025
RCRA
CAA regulations mandate the use of alternate fuels for fleets of vehicles in the
8500-26,000 pound class that operate in 22 of the country's most polluted
areas. These fleets will be required to purchase 50 percent of their new or
replacement vehicles as clean fuel vehicles in any one of the covered areas.
Alternative fuels are defined by their ability to reduce NOx and non-methane
hydrocarbon emissions by a combined 50 percent from diesel baseline levels,
although a 30 percent reduction is permitted if 50 percent is unattainable.
In large part due to the 1993 introduction of congressionally mandated low-
sulfur, limited aromatic diesel fuel, manufacturers of diesel engines have been
able to closely approach the 1994 emission limits and to focus their efforts on
controlling particulates. New engine designs have been used to achieve more
efficient and cleaner combustion (Motor Trucking Engineering Handbook
James W. Fitch, 1994).
Truck maintenance facilities may face CAA issues for vapor recovery systems
on underground fuel tanks, waste oil to energy shop heaters, vehicle painting
operations, or CFC recycling and recovery systems.
Hazardous waste transportation is a highly regulated and specialized segment
of the trucking industry, covered by extensive EPA and DOT regulations.
The majority of general freight trucking companies do not transport
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hazardous waste. Nevertheless, RCRA issues at trucking facilities include
several non-transportation activities.
Some fluids used in truck maintenance are considered hazardous waste,
requiring specific storage treatment, and disposal. Waste accumulated or
generated during trucking maintenance may cause facilities to be considered
small or large quantity generators depending on the volume waste. The
primary RCRA issues for maintenance facilities are used oil, lead-acid motor
vehicle batteries, vehicle maintenance fluids, and scrap tire disposal.
EPCRA
OPA
Most trucking companies do not store listed chemicals for use in their
facilities. The only exception is diesel fuel or gasoline, which when stored at
facilities in quantities slightly over 10,000 gallons, requires reporting to Local
Emergency Response Commissions (LERCs) and State Emergency Response
Commissions (SERCs). Chemicals in transition are exempt from inventory
reporting under EPCRA. This includes all hazardous materials shipments in
packages or bulk quantities.
OPA imposes contingency planning and readiness requirements on certain
facilities defined to include rolling stock and motor vehicles. These
requirements may affect some trucking establishments.
VII.B.3. Pipelines
RCRA
Almost all of the petroleum feed stock and products used in the U.S. are, at
some point, transported through a Federally-regulated pipeline. The Office
of Pipeline Safety (OPS), part of the DOT's Research and Special Programs
Administration, regulate essentially all of the approximately 155,000 miles of
hazardous liquid pipelines in the U.S., as well as the approximately 255,000
miles of gas transmission lines.
Natural gas pipelines do not generate significant quantities of listed hazardous
waste. Typical pipeline wastes include condensate, cleaning solvents, and
used oil. Each gas pipeline compressor station typically produces an average
of 20,000 gallons of used oil each year. This figure depends on the amount
of maintenance performed on engines, how often the engines are running, and
how much oil is drained from the engines. Under RCRA, used oil is not
necessarily a hazardous waste and most gas pipeline companies sell it to
refiners.
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OPA
Water contaminated with constituents of crude oil and petroleum can be
regulated under RCRA. Oil pipelines generate hazardous waste when
hydrocarbons are mixed with water through pressure testing during
installation or through settling in tank bottoms. Oil pipelines can also
generate hazardous sludge that results from pigging operations. At pig
receipt sites, scraper and cleaning pigs deposit waste materials that often
contain hazardous levels of benzene and/or metals.
With regard to storage tanks, RCRA covers hazardous wastes (rather than
products) stored in tanks, and such tanks must have secondary containment.
EPA has the authority to issue administrative orders requiring cleanup or
product releases causing "imminent and substantial endangerment to health
or the environment."
Under the Oil Pollution Act (OPA), the owner or operator of an oil pipeline
is liable for removal costs and damages caused by the discharge of oil onto a
U.S. shoreline or into navigable waters. The OPA also imposes requirements
on affected facilities concerning contingency planning and readiness. Under
previous EPA regulations, facilities with the potential to discharge oil were
required to have spill prevention, control, and countermeasure (SPCC) plans
Under new requirements, facilities that could be reasonably expected to cause
"substantial harm" to the environment by a discharge of oil into navigable
waters may be required to adopt such plans.
The DOT'S Office of Pipeline Safety (OPS) is responsible for implementing
OPA requirements as they apply to onshore oil pipelines that could reasonably
be expected to cause significant and substantial harm to the environment by
discharging oil into the navigable waters of the U.S. and adjoining shorelines
The OPA applies to all oil pipelines, whether or not they are currently exempt
from existing Federal regulations or statutes.
Storage tank facilities that could cause significant and substantial harm to the
environment by discharging to navigable water must develop facility response
plans and submit them to the Federal government for approval. The act
includes extensive liability provisions for spills to navigable waters
Pipeline Safety Act
Congress passed the Pipeline Safety Act in 1992. The most far-reaching
effect of the Act is the expansion of OPS' traditional safety mission to include
environmental protection. Major provisions in the Act relate to excess flow
valves, cast iron pipelines, gathering lines, customer-owned service lines
underwater inspection and burial, underwater abandoned pipeline facilities'
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low internal stress pipelines, and emergency flow restricting devices, and
contain increased inspection requirements including use of "smart pigs," and
operator qualification testing. The Act also provides a statutory basis for the
DOT'S Research and Special Programs Administration (RSPA), which had
been initially established by the Secretary of Transportation in 1977. The
RSPA Administrator is to be appointed by the President and confirmed by the
Senate.
Natural Gas Pipeline Safety Act and the Hazardous Liquid Pipeline Safety Act
The Natural Gas Pipeline Safety Act (NGPSA) of 1968 provides for Federal
safety regulation of pipeline facilities used in the transportation of natural
gases. The Hazardous Liquid Pipeline Safety Act (HLPSA) of 1979 provides
for safety regulation of pipeline facilities used in the transportation of
hazardous liquids. Both provide a framework for promoting pipeline safety
through exclusive Federal regulation of interstate pipeline facilities, and
Federal delegation to the States for all or part of the responsibility for
intrastate pipeline facilities. To provide expertise during development of
pipeline safety regulations, NGPSA and HLPSA established two pipeline
safety advisory committees, the Technical Pipeline Safety Standards
Committee and the Technical Hazardous Liquid Pipeline Safety Standards
Committee, respectively. The Committees review proposed regulations for
technical feasibility, reasonableness, and practicability. The Committees also
provide advice to the DOT on pipeline safety and environmental issues.
TSCA
Some natural gas pipelines used PCBs in their system through the 1980s.
PCBs were widely used in transformers, as heat transfer fluids, and in some
types of compressor lubricants. In 1989, the Gas Research Institute began a
program to deal with the management of PCB residue. The first step involved
measuring and analyzing statistical data on PCB contamination of gas
transmission pipelines and reviewing remediation programs involving
condensate, soil, pipelines, and surface facilities. The Gas Research Institute
developed information on physical properties and analytical methods for PCB
condensate mixtures, the soil-water partitioning behavior of these mixtures,
and an evaluation of the risks associated with typical pipeline operations and
PCB abandonment.
CAA
The Clean Air Act affects pipeline system design, operation, and maintenance.
Materials such as carbon dioxide, hydrogen sulfide, and mercaptan sulfur are
often present in the field gathering systems that move natural gas from wells
to processing plants. Pipeline operators must track emissions from
compressor and pump stations. Fugitive emissions of benzene from seals on
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Federal Statutes and Regulations
pumps, compressors, valves, meters, and storage tanks must also be evaluated
and controlled.
In areas that meet Federal clean air standards, new or modified "major
sources" (e.g., tank farms) must install "Best Available Control Technology"
(BACT). In areas that do not meet Federal clean air standards, new or
modified major sources must utilize "Lowest Achievable Emission Rate"
technology, which must be at least as stringent as BACT; existing major
sources must utilize designated "Reasonably Available Control Technology,"
which may be less stringent than BACT. For major sources that emit
"Hazardous Air Pollutants," EPA is developing "Maximum Achievable
Control Technology" regulations.
CWA
The Spill Prevention Control and Countermeasures (SPCC) program covers
petroleum above ground tank facilities that may affect "navigable waters."
The SPCC program requires reporting of spills to navigable waters and
development of contingency plans that must be kept on-site. EPA has the
authority to issue administrative orders requiring cleanup.
SDWA
Regulations promulgated under the Safe Drinking Water Act classify
underground injection wells according to the type of operation or substance
involved. 40 CFR §144.6(b) describes Class II injection wells as those which
inject fluids:
Which are brought to the surface in connection with natural gas
storage operations, or conventional oil or natural gas production and
may be commingled with waste waters from gas plants which are an
integral part of production operations, unless those waters are
classified as a hazardous waste at the time of injection.
For enhanced recovery of oil or natural gas; and
For storage of hydrocarbons which are liquid at standard tempera*
and pressure.
:ure
Many wells associated with the oil and gas industry, including salt water
injection wells, enhanced recovery wells, and wells injecting liquid
hydrocarbons for storage, are likely to be regulated under the Underground
Injection Control (UIC) program.
Under the UIC, wells are required to obtain and adhere to the requirements
of operating permits. The permit application, must prove to the permitting
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Federal Statutes and Regulations
authority (usually the State) that operation of the underground injection well
will not endanger drinking water sources. Class II permits are issued for the
life of the well, but can be reviewed every five years.
VII.C. Pending and Proposed Regulatory Requirements
Regulations are currently under development for the transportation equipment
cleaning industry. These regulations, when effective, will impact railroads
that clean the interior of tank cars, hopper cars, and box cars, and produce
wastewater. If a tank car has carried hazardous materials, its car cleaning
waste waters may require proper handling under RCRA in addition to that for
normal waste waters due to contamination from leftover tank contents or
"heel."
In addition there may soon be an effluent guideline on Metal Products and
Machinery, which will apply to the rail industry especially for metal machining
shops.
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Compliance and Enforcement History
VIII. COMPLIANCE AND ENFORCEMENT HISTORY
VHI.A. Background
Until recently, 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.
VHI.B. Compliance and Enforcement Profile Description
Using inspection, violation and enforcement data from the IDEA system, this
section provides information regarding the historical compliance and
enforcement activity of this sector. In order to mirror the facility universe
reported in the Toxic Chemical Profile, the data reported within this section
consists of records only from the TRI reporting universe. With this decision,
the selection criteria are consistent across sectors with certain exceptions.
For the sectors that do not normally report to the TRI program, data have
been provided from EPA's Facility Indexing System (FINDS) which tracks
facilities in all media databases. Please note, in this section, EPA does not
attempt to define the actual number of facilities that fall within each sector.
Instead, the section portrays the records of a subset of facilities within the
sector that are well defined within EPA databases.
As a check on the relative size of the full sector universe, most notebooks
contain an estimated number of facilities within the sector according to the
Bureau of Census (See Section II). With sectors dominated by small
businesses, such as metal finishers and printers, the reporting universe within
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Compliance and Enforcement History
the EPA databases may be small in comparison to Census data. However, the
group selected for inclusion in this data analysis section should be consistent
with this sector's general make-up.
Following this introduction is a list defining each data column presented
within this section. These values represent a retrospective summary of
inspections and enforcement actions, and reflect solely EPA, State, and local
compliance assurance activities that have been entered into EPA databases.
To identify any changes in trends, the EPA ran two data queries, one for the
past five calendar years (April 1, 1992 to March 31, 1997) and the other for
the most recent twelve-month period (April 1, 1996 to March 31, 1997). The
five-year analysis gives an average level of activity for that period for
comparison to the more recent activity.
Because most inspections focus on single-media requirements, the data
queries presented in this section are taken from single media databases. These
databases do not provide data on whether inspections are state/local or EPA-
led. However, the table breaking down the universe of violations does give
the reader a crude measurement of the EPA's and states' efforts within each
media program. The presented data illustrate the variations across EPA
Regions for certain sectors.1 This variation may be attributable to state/local
data entry variations, specific geographic concentrations, proximity to
population centers, sensitive ecosystems, highly toxic chemicals used in
production, or historical noncompliance. Hence, the exhibited data do not
rank regional performance or necessarily reflect which regions may have the
most compliance problems.
Compliance and Enforcement Data Definitions
General Definitions
Facility Indexing System (FINDS) -- this system assigns a common facility
number to EPA single-media permit records. The FINDS identification
number allows EPA to compile and review all permit, compliance,
enforcement and pollutant release data for any given regulated facility.
Integrated Data for Enforcement Analysis (IDEA) ~ is a data integration
system that can retrieve information from the major EPA program office
databases. IDEA uses the FINDS identification number to link separate data
records from EPA's databases. This allows retrieval of records from across
media or statutes for any given facility, thus creating a "master list" of
1 EPA Regions include the following states: I (CT, MA, ME, RI, NH, VT); II (NJ, NY, PR, VI); III (DC, DE, MD, PA,
VA, WV); IV (AL, FL. GA, KY, MS, NC, SC, TN); V (IL, IN, MI, MM, OH, WI); VI (AR, LA, NM, OK, TX); VII
(IA, KS, MO, NE); VIII (CO, MT, ND, SD, UT, WY); IX (AZ, CA, HI, NV, Pacific Trust Territories); X (AK, ID, OR,
WA).
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records for that facility. Some of the data systems accessible through IDEA
are: AIRS (Air Facility Indexing and Retrieval System, Office of Air and
Radiation), PCS (Permit Compliance System, Office of Water), RCRIS
(Resource Conservation and Recovery Information System, Office of Solid
Waste), NCDB (National Compliance Data Base, Office of Prevention,
Pesticides, and Toxic Substances), CERCLIS (Comprehensive Environmental
and Liability Information System, Superfund), and TRIS (Toxic Release
Inventory System). IDEA also contains information from outside sources
such as Dun and Bradstreet and the Occupational Safety and Health
Administration (OSHA). Most data queries displayed in notebook sections
IV and VII were conducted using IDEA.
Data Table Column Heading Definitions
Facilities in Search - are based on the universe of TRI reporters within the
listed SIC code range. For industries not covered under TRI reporting
requirements (metal mining, nonmetallic mineral mining, electric power
generation, ground transportation, water transportation, and dry cleaning), or
industries in which only a very small fraction of facilities report to TRI (e.g.,
printing), the notebook uses the FINDS universe for executing data queries'
The SIC code range selected for each search is defined by each notebook's
selected SIC code coverage described in Section II.
Facilities Inspected — indicates the level of EPA and state agency
inspections for the facilities in this data search. These values show what
percentage of the facility universe is inspected in a one-year or five-year
period.
Number of Inspections -- measures the total number of inspections
conducted in this sector. An inspection event is counted each time it is
entered into a single media database.
Average Time Between Inspections - provides an average length of time,
expressed in months, between compliance inspections at a facility within the
defined universe.
Facilities with One or More Enforcement Actions - expresses the number
of facilities that were the subject of at least one enforcement action within the
defined time period. This category is broken down further into federal and
state actions. Data are obtained for administrative, civil/judicial, and criminal
enforcement actions. Administrative actions include Notices of Violation
(NOVs). A facility with multiple enforcement actions is only counted once
in this column, e.g., a facility with 3 enforcement actions counts as 1 facility.
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Compliance and Enforcement History
Total Enforcement Actions - describes the total number of enforcement
actions identified for an industrial sector across all environmental statutes. A
facility with multiple enforcement actions is counted multiple times, e.g., a
facility with 3 enforcement actions counts as 3.
State Lead Actions -- shows what percentage of the total enforcement
actions are taken by state and local environmental agencies. Varying levels
of use by states of EPA data systems may limit the volume of actions
recorded as state enforcement activity. Some states extensively report
enforcement activities into EPA data systems, while other states may use their
own data systems.
Federal Lead Actions - shows what percentage of the total enforcement
actions are taken by the United States Environmental Protection Agency.
This value includes referrals from state agencies. Many of these actions result
from coordinated or joint state/federal efforts.
Enforcement to Inspection Rate -- is a ratio of enforcement actions to
inspections, and is presented for comparative purposes only. This ratio is a
rough indicator of the relationship between inspections and enforcement. It
relates the number of enforcement actions and the number of inspections that
occurred within the one-year or five-year period. This ratio includes the
inspections and enforcement actions reported under the Clean Water Act
(CWA), the Clean Air Act (CAA) and the Resource Conservation and
Recovery Act (RCRA). Inspections and actions from the TSCA/FIFRA/
EPCRA database are not factored into this ratio because most of the actions
taken under these programs are not the result of facility inspections. Also,
this ratio does not account for enforcement actions arising from non-
inspection compliance monitoring activities (e.g., self-reported water
discharges) that can result in enforcement action within the CAA, CWA, and
RCRA.
Facilities with One or More Violations Identified ~ indicates the
percentage of inspected facilities having a violation identified in one of the
following data categories: In Violation or Significant Violation Status
(CAA); Reportable Noncompliance, Current Year Noncompliance, Significant
Noncompliance (CWA); Noncompliance and Significant Noncompliance
(FIFRA, TSCA, and EPCRA); Unresolved Violation and Unresolved High
Priority Violation (RCRA). The values presented for this column reflect the
extent of noncompliance within the measured time frame, but do not
distinguish between the severity of the noncompliance. Violation status may
be a precursor to an enforcement action, but does not necessarily indicate that
an enforcement action will occur.
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Compliance and Enforcement History
Media Breakdown of Enforcement Actions and Inspections - four
columns identify the proportion of total inspections and enforcement actions
within EPA Air, Water, Waste, and TSCA/FIFRA/EPCRA databases. Each
column is a percentage of either the "Total Inspections," or the "Total
Actions" column.
VIII.C. Industry Sector Compliance History
Exhibits 24-31 illustrate recent enforcement activity within the transportation
industry. Of the 12,904 inspections conducted at rail, trucking, and oil and
gas pipeline facilities over a five year period, 774, or 6 percent, resulted in
enforcement actions. Of the three transportation industries addressed by this
profile, the pipeline industry has received greater scrutiny from Federal and
State inspectors, although certain portions of the trucking industry have also
been subject to environmental compliance inspections. While the greatest
number of inspections of rail facilities addressed the CWA, the trucking
industry had more RCRA inspections while the pipeline industry was subject
to the most inspections under the CAA.
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Exhibit 24
Five-Year Enforcement and Compliance Summary for Transportation Sectors
Rail
Trucking
•
Oil
Pipeline!:
Natural
Gas
Pipelines
A
SIC
Code
4011
4013
4212
4213
4214
4215
4221
4222
4225
4226
4231
4612
4613
4619
4922
4923
4924
4925
4932
B
Facilities
in Search
434
136
991
475
195
103
219
63
427
479
492
377
362
45
2,942
190
118
192
30
c
Facilities
Inspected
165
62
236
205
87
31
119
16
151
264
180
189
193
21
1,380
84
53
112
17
3,263
D
Number
of
Inspections
717
328
987
737
539
60
337
52
599
1,828
747
780
991
57
4,566
342
210
620
90
12,904
E
Average
Number of
Months
Between
Inspections
36
25
60
39
22
103
39
73
43
16
40
29
22
47
39
33
34
19
20
36
F
Facilities
w/One or
More
Enforcement
Actions
30
9
34
22
0
10
3
25
75
28
16
16
3
88
2
5
12
4
G
Total
Enforcement
Actions
13
69
43
0
15
6
54
182
68
71
5
3
7
31
4
H
State
Lead
Actions
85%
88%
81%
-
73%
33%
94%
87%
85%
86%
100%
100%
100%
87%
100%
Federal
Lead
Actions
15%
12%
19%
-
27%
67%
6%
13%
15%
14%
0%
0%
0%
13%
0%
Enforcement
to Inspection
Rate
0.04
0.09
0.08
-
0.04
0.12
0.09
0.1
0.09
0.07
0.09
0.01
0.03
0.05
0.04
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-Compliance and Enforcement History
Exhibit 25
One-Year Enforcement and Compliance Summary for Transportation Sectors
D
Facilities w/One or
More Enforcemenf
Actions
, in Columns E and Fare based on the number of facilities inspected (Column C). Percentages can exceed 100% bee
violations and actions can occur without a facility inspection.
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Exhibit 26
Fivr-Year Enfir^mMit and Compliance Summary by Statute for Transportation Sectors
Rail
Trucking
Oil
Pipelines
Natural
Gas
Pipelines
SIC
Code
4011
4212
4213
4214
4215
4221
4222
4225
4226
4612
4613
4922
4923
4924
4925
4932
Number of
Facilities
Inspected
165
236
205
87
31
119
16
151
264
180
189
193
21
1,380
84
53
112
17
Total
Inspections
717
328
987
737
539
60
337
52
599
1,828
747
780
991
57
4,566
342
210
620
90
Enforcement
Actions
51
13
147
69
43
0
15
6
54
182
68
85
71
5
122
3
7
31
4
Clean Air Act
% of Total
Inspections
18%
30%
13%
23%
5%
88%
12%
31%
46%
17%
79%
64%
54%
92%
89%
80%
71%
39%
%of
Total
8%
17%
16%
0%
87%
17%
9%
53%
7%
73%
20%
67%
71%
72%
50%
% of Total
Inspections
56%
11%
6%
0%
1%
56%
16%
. 15%
11%
20%
23%
8%
13%
12%
42%
%of
Total
Actions
56%
54%
4%
7%
0%
0%
50%
6%
14%
13%
5%
3%
20%
33%
29%
13%
25%
Conservation and
Recovery Act
% of Total
Inspections
13%
74%
70%
95%
9%
33%
52%
38%
71%
16%
21%
5%
3%
8%
17%
17%
%of
Total
Actions
31%
78%
72%
0%
7%
33%
83%
32%
78%
23%
60%
0%
0%
9%
25%
EPCRA/Other
% of Total
Inspections
1%
1%
1%
0%
1%
0%
2%
1%
1%
0%
2%
0%
0%
0%
2%
%of
Total
Actions
8%
0%
5%
0%
7%
0%
2%
1%
1%
1%
0%
0%
0%
6%
0%
Actions taken to enforce the Federal Insecticide, Fungicide, and Rodenticide Act; the Toxic Substances and Control Act, and
tha Emergency Planning and Community Right-to-Know Act as well as other Federal environmental laws.
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Compliance and Enforcement History
Exhibit 27
One- Year Enforcement and Compliance Summary for Transportation Sectors
Pipelines
Gas
Pipelines
Code
4013
4213
4214
4215
4221
4222
4225
4226
4231
4613
4619
4923
4924
4925
932
Facilities
Inspected
28
70
43
8
58
4
58
152
65
122
10
41
29
58
g
Inspections
60
126
106
8
71
6
95
317
137
186
45
66
50
107
13
Enforcement
Actions-
1
16
10
0
1
0
2
24
10
5
0
2
3
9
1
Clean Air Act
% of Total
Inspections
30%
12%
12%
25%
82%
17%
37%
48%.
19%
72%
50%
83%
92%
79%
46%
% of
Total
0%
19%
20%
0%
0%
0%
50%
42%
0%
75%
60%
0%
96%
100%
33%
100%
100%
*Actions taken to enforce the Federal Insecticide, Fungicide, andRoa
and the Emergency Planning and Community Right-to-Kno-w Ac
Clean Water Act
% of Total
Inspections
51%
50%
14%
10%
10%
0%
0%
33%
14%
12%
13%
4%
22%
8%
3%
11%
2%
8%
38%
%of
Total
67%
100%
0%
0%
0%
0%
0%
0%
0%
17%
0%
0%
- 0%
0%
0%
0%
67%
0%
0%
enticideAct; the Toxi
1 as well as other Fed
Resource
Conservation and
Recovery Act
% of Total
Inspections
33%
20%
69%
78%
77%
75%
18%
50%
49%
39%
68%
9%
6%
42%
4%
6%
6%
12%
15%
%of
Total
17%
0%
69%
81%
80%
0%
100%
0%
50%
38%
100%
25%
40%
0%
4%
0%
0%
0%
0%
c Substances and Con
eral environmental la\
FIFRA/TSCA/
EPCRA/Other
% of Total
Inspections
0%
0%
0%
• 0%
0%
0% •
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
0%
" 0%
0%
trolAct,
vs.
%of
Total
0%
0%
0%
0%
0%
0%
0%
0%
0%
4%
0%
0%
0%
0%
0%
0%
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Compliance and Enforcement History
VHLD. Comparison of Enforcement Activity Between Selected Industries
The following exhibits present inspection and enforcement information across
numerous manufacturing sector industries including the ground, water, and
air transportation industries.
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Compliance and Enforcement History
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Compliance and Enforcement History
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Compliance and Enforcement Hist(
Sector Notebook Project
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Compliance and Enforcement History
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Review of Major Legal Actic
IX. REVIEW OF MAJOR LEGAL ACTIONS
This section provides summary information about major cases that have
affected this sector. As indicated in EPA's Enforcement Accomplishments
Reports from 1992-1994, several significant enforcement actions were
resolved between 1992-1994 involving the rail, trucking, and pipeline
industries. Characterizations of the types of enforcement actions taken are
provided for each of the cited cases.
IX.A. Review of Major Cases
IX.A.1. Rail
U.S. v. Consolidated Rail Corporation, CAA, 1992
U.S. District Court entered a second amendment to consent order resolving
EPA's CAA contempt action against Consolidated Rail Corporation (Conrail).
The amendment requires Conrail to pay $165,000 in penalties for past
violations. In addition, it allows the company to apply encrusting agents in
lieu of water to control fugitive dust. The amendment is based on a consent
order EPA and Conrail negotiated in 1986 to resolve violations of Ohio's
State Implementation Plan (SIP).
U.S. v. CSX Transportation, CWA, 1993
CSX Transportation signed a consent decree to pay $3,00,000 in civil
penalties and perform four Supplemental Environmental Projects (SEPs)
valued at $4,000,000 for alleged violations of CWA for exceeding NPDES
limits.
Burlington Northern, Multi-media, 1994
EPA Region V sought $279,078 to recover costs incurred consistent with the
NCP under CERCLA and OP A, natural resource damages totaling $250,000
and CWA penalties totaling $2,500,000 for three incidents of railroad
derailment.
In the matter of Burlington Northern Railroad, EPCRA, 1994
A RCRA consent order was issued for the contamination of groundwater, and
a 1993 unilateral administrative order, based on a multimedia inspection,
required the defendant to cease discharge of oil and chlorinated waters.
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Southern Pacific Transportation Corporation, 1994
A train derailment caused the release of a herbicide into the Sacramento River
killing all plant life for 42 miles. The settlement provided for recovery of $36
million in response costs. The decree also required payment of a $500,000
civil penalty (the statutory maximum for the violation). Defendants must also
establish a $14 million fund for natural resource damages.
U.S. v. Norfolk & Western Railway Company, 1994
Criminal plea agreement and settlement resulted in the U.S. receiving
$500,000 fine and $500,000 restitution. Missouri received $700,000 fine and
$1.7 million in restitution, $1 million for creation of a park, and establishment
of a $2.2 million environmental awareness program.
EX.A.2. Trucking
U.S. v. The Carborundum Company, et al., CERCLA, 1994
On March 30, 1994, a consent decree was lodged in the District Court of
New Jersey which partially settles Region Us cost recovery claims relating to
the Caldwell Trucking Company Superfund site in Fairchild Township, New
Jersey. From 1950 through the mid 1970s, Caldwell Trucking hauled septage
and other wastes from residential, commercial, and industrial customers and
disposed of these wastes in unlined lagoons at the site. The nine settling
defendants agreed to pay $2.46 million for EPA's past and future costs and
agreed to perform all scheduled remedial and natural resource restoration
work at the site, valued at an additional $32 million. New Jersey will also
receive its first natural resource damage payment under CERCLA, in the
amount of $984,000, and the U.S. Department of the Interior will receive
$40,000 for its assessment and monitoring costs.
U.S. v. Comer's Diesel and Electric Company, RCRA, 1994
Comer's Diesel and Electric Co., with automotive and truck maintenance
facilities located in Belgrade, Great Falls, and Missoula, Montana, was
sentenced on March 24, 1994, following a plea of guilty to one-count of
unlawful transportation of a hazardous waste in violation of RCRA. The
company was placed on supervised probation for two years and fined
$100,000, $50,000 of which was suspended in recognition of remediation
conducted at its Belgrade facility.
Hamner, Inc., Corpus Christi, CWA, 1994
An administrative Class I complaint was issued against Hamner, Inc. Corpus
Christi, Texas, on May 24, 1994, with a proposed penalty of $9,108 for
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violations of the CWA. The corporation's tanker truck overturned,
discharging approximately 24 barrels of petroleum naphtha. The petroleum
naphtha entered navigable waters of the U.S. in quantities determined to be
harmful. The oil did not enter a major waterway, no drinking water supply
was affected, and there were no signs of damage to wildlife or aquatic life.
Settlement negotiations are underway.
IX.A.3. Pipelines
U.S. v. Shell Oil Pipeline Corporation, Criminal Enforcement, 1992
Pipeline rupture caused an 860,000 gallon oil spill into the Mississippi,
Gasconade, and Missouri rivers. Shell pleaded guilty to violation of the
Refuse Act and agreed to pay $8,400,000 in fines, restitution, and settlements.
U.S. v. Texaco, CERCLA, 1993
Texaco entered a consent decree for performance of a remedial design and
remedial action at the Pacific Cost Pipeline Superfund site in California. The
RAis valued at $4,000,000. Texaco also agreed to reimburse California for
response costs, the U.S. for future response costs, and EPA for past RI/FS
costs.
U.S. v. Transwestern Pipeline Company, TSCA, 1993
A consent decree was terminated when the defendant met all terms and
conditions of settlement (including payment of a penalty of $375,000 and
groundwater monitoring). Under the decree, 144,991 tons of PCB
contaminated soil and debris were removed and disposed in TSCA landfill.
U.S. v. Tennessee Gas Pipeline Co., CWA, 1993
Court entered final order for dismissal after parties agreed to a penalty of
$725,000 for unauthorized discharges of PCBs from a pumping station.
U.S. v. U.S. Oil and U.S. v. Texaco, OPA, 1993
U.S. Oil agreed to pay civil penalties of $425,000 and Texaco agreed to pay
$480,000 in penalties. Both were made to acquire and install state-of-the-art
spill detection and prevention equipment valued at $800,000 for each
company. Both were also required to reimburse for Federal spill response
costs of $60,000 and $125,000 respectively. The actions represent the first
judicial penalties assessed under OPA.
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IX.B. Supplemental Environmental Projects (SEPs)
Below is 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.
Exhibit 32 contains a sample of SEPs from the transportation industry. The
information contained in the chart is not comprehensive and provides only a
sample of the types of SEPs developed for the transportation industry.
Exhibit 32
Supplemental Environmental Projects in the Transportation Industry
Case Name
Statute
Estimated
Cost to
Company
Environmentally Beneficial Activities
General Chemical
Company
CAA
$90,000,
Facility was to purchase and install an Airless Paint
Spray Unit and Fanu Robotics Spray Unit in order to
reduce total VOC releases to the atmosphere by 10
percent.
Thatcher Chemical
Company
EPCRA §304
Not Known
SEP included the construction of a building with
scrubbing equipment for enclosing loading products
to prevent future releases into the environment to be
completed by January 24, 1994.
CSX Transportation
CAA
$ 4,000,000
Company was required to:
Perform NPDES compliance audits at 21 active
CSX railroad yards
Conduct multi-media risk assessment audit at 61
inactive facilities
Provide environmental awareness training
program for managers
Develop best management practices manual and
a seminar on storm water runoff at railroad
yards.
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X. COMPLIANCE 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. This section of the notebook also contains a
listing and description of national and regional trade associations.
X.A. Sector-Related Environmental Programs and Activities
Environmental compliance assurance activities have been conducted by the
major trade associations for each of the transportation sectors covered in this
report. The following examples represent some of the industry initiatives that
promote compliance, or assess methods to reduce environmental
contamination.
X.A.1. Rail
Waste Minimization Assessment for a Manufacturer of Rebuilt Railway Cars and
Components
U.S. EPA funded a pilot project to assist small- and medium-size
manufacturers wishing to minimize their generation of hazardous waste, but
lacking the expertise to do so. The Agency established Waste Minimization
Assessment Centers (WMACs) at selected universities, adapting procedures
from EPA's 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 hazardous waste outputs.
X.A.2. Trucking
Consolidated Compliance Reviews
The trucking industry has worked with the Department of Transportation,
Federal Highway Administration (FHWA), to develop streamlined processes
for conducting compliance reviews. As a result, the FFfWA now conducts all
record reviews and inspection activities in a "one stop" process.
The original process involved several different inspections. The first type of
inspection focused on compliance with ICC rules and operating authority
licenses. The second type of inspection focused on safety compliance issues.
Additional inspections were conducted to ensure compliance with hazardous
materials transportation regulations were added in the 1980's. More recently,
driver drug testing was added to the inspection requirements.
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DOT-FHWA's compliance review is now conducted with the inspector using
a lap-top computer with built in prompters, programs to generate checklists,
work sheets, tabulations, and regulations and interpretations. These tools
allow the inspector to cover all the components of the inspection in "one
stop." The compliance review often occurs at corporate headquarters. The
system was developed in 1986; currently, about 200 DOT-FHWA inspectors
use the system.
Inspectors receive six weeks of training when they come into the DOT-
FHWA, including training on case development, regulations, compliance
reviews, and sensitivity. Inspectors do not need permission before entering
a facility but usually call in advance so the appropriate staff and records can
be available. Unannounced inspections may occur if criminal activity is
suspected.
DOT-FHWA inspectors are providing more and more technical assistance to
the regulated community. They have education packages on specific issues,
such as hazardous materials, and "On Guard" announcements of new safety
problems or rules affecting the industry.
Cooperative Hazardous Materials Enforcement Development
The Cooperative Hazardous Materials Enforcement Development
(COHMED) program is an outreach activity of the U.S. DOT's Research and
Special Programs Administration (RSPA). COHMED works to promote
coordination, cooperation, education, and communication for Federal, State,
local agencies, and industry having enforcement, response, and management
responsibilities for the safe transportation of hazardous materials. Through
education and training, COHMED participants are able to improve current
programs, and develop new programs to enhance hazardous materials safety.
COHMED conducts semi-annual conferences and hazardous materials
seminars. COHMED also publishes a quarterly newsletter, "The Reporter,"
and the "Bullet" when expedient dissemination of information is required.
COHMED participation is open to Federal, State, local agencies, and industry
involved in enforcement, emergency response or planning and preparedness.
For more information call (202) 366-4900.
CHEMTREC
CHEMTREC is a pubic service organization established by the Chemical
Manufacture's Association and its members in 1971 to provide first
responders, the transportation industry, medical professionals, and others
access to response information and technical assistance from chemical industry
experts for incidents involving hazardous materials. The Center is staffed by
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trained communicators who can contact thousands of chemical manufacturers,
shippers, distributors, and carriers. Through these contacts, CHEMTREC cari
teleconference responders at the scene of an incident with technical experts
to provide immediate advice and assistance. CHEMTREC can also
immediately provide and transmit, via fax, product Material Safety Data
Sheets or other specific product information. The CHEMTREC Center can
be reached 24 hours a day, 7 days a week at 1-800-424-9300.
TRANSCAER
TRANSCAER is an outreach program that focuses on assisting communities
that do not host a major chemical facility but have major transportation routes
within their jurisdiction. TRANSCAER is sponsored by the chemical
manufacturing, distribution and transportation industries. TRANSCAER's
objectives are to ensure that communities are prepared to handle hazardous
materials transportation emergencies and that an ongoing dialogue exists with
the public about chemical transportation. The program provides assistance for
communities to develop and evaluate their emergency response plan for
hazardous material transportation incidents. For more information contact the
TRANSCAER Task Group at c/o CMA, 1300 Wilson Blvd Arlington VA,
22209. '
CMA 's Lending Library
Since 1985, the CMA's Lending Library has provided free access to videotape
training programs on hazardous materials and handling hazardous materials
incidents. Contact the CMA Publication Fulfillment department at (202) 887-
1253 for ordering information.
X.A.3. Pipelines
The giant Alaska company Alyeska has undertaken the most expensive
corrosion repair program in the industry's history with a campaign to inspect
pipelines for corrosion, repair damaged sections, and replace pipe sections as
needed. The estimated costs of this effort from 1991-1996 are $600-800
million. External and internal corrosion at some of the 800-mile line's pump
stations was discovered with the help of a corrosion detection pig that
exceeded Federal standards for corrosion detection and mitigation (U.S
Petroleum Strategies, Bob Williams, 1991).
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X.B. EPA Voluntary Programs
Environmental Leadership Program
Project XL
The Environmental Leadership Program (ELP) is a national initiative
developed by EPA that focuses on improving environmental performance,
encouraging voluntary compliance, and building working relationships with
stakeholders. EPA initiated a one year pilot program in 1995 by selecting 12
projects at industrial facilities and federal installations that 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, pollution
prevention, community involvement, and mentor programs. In return for
participating, pilot participants received public recognition and were given a
period of time to correct any violations discovered during these experimental
projects.
EPA is making plans to launch its full-scale Environmental Leadership
Program in 1997. The full-scale program will be facility-based with a 6-year
participation cycle. Facilities that meet certain requirements will be eligible
to participate, such as having a community outreach/employee involvement
programs and an environmental management system (EMS) in place for 2
years. (Contact: http://es.inel.gov/elp or Debby Thomas, ELP Deputy
Director, at 202-564-5041)
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 providing participants
regulatory flexibility on the condition that they produce greater environmental
benefits. EPA and program participants will negotiate and sign a Final Project
Agreement, detailing specific environmental objectives that the regulated
entity shall satisfy. EPA will provide regulatory flexibility as an incentive for
the participants' superior environmental performance. 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 industrial facilities, communities, and government
facilities regulated by EPA. Applications will be accepted on a rolling basis.
For additional information regarding XL projects, including application
procedures and criteria, see the May 23, 1995 Federal Register Notice.
(Contact: Fax-on-Demand Hotline 202-260-8590, Web:
http://www.epa.gov/ProjectXL, or Christopher Knopes at EPA's Office of
Policy, Planning and Evaluation 202-260-9298)
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Climate Wise Program
EPA's ENERGY STAR Buildings Program is a voluntary, profit-based program
designed to improve the energy-efficiency in commercial and industrial
buildings. Expanding the successful Green Lights Program, ENERGY STAR
Buildings was launched in 1995. This program relies on a 5-stage strategy
designed to maximize energy savings thereby lowering energy bills, improving
occupant comfort, and preventing pollution -- all at the same time. If
implemented in every commercial and industrial building in the United States,
ENERGY STAR Buildings could cut the nation's energy bill by up to $25 billion
and prevent up to 35% of carbon dioxide emissions. (This is equivalent to
taking 60 million cars of the road). ENERGY STAR Buildings participants
include corporations; small and medium sized businesses; local, federal and
state governments; non-profit groups; schools; universities; and health care
facilities. EPA provides technical and non-technical support including
software, workshops, manuals, communication tools, and an information
hotline. EPA's Office of Air and Radiation manages the operation of the
ENERGY STAR Buildings Program. (Contact: Green Light/Energy Star Hotline
at 1-888-STAR-YES or Maria Tikoff Vargas, EPA Program Director at 202-
233-9178 or visit the ENERGY STAR Buildings Program website at
http ://www. epa.gov/appdstar/buildings/)
Green Lights 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 saves money for businesses and
organizations and creates a cleaner environment by reducing pollutants
released into the atmosphere. The program has over 2,345 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. As of March 1997, participants had
lowered their electric bills by $289 million annually. EPA provides technical
assistance to the participants through a decision support software package,
workshops and manuals, and an information hotline. EPA's Office of Air and
Radiation is responsible for operating the Green Lights Program. (Contact-
Green Light/Energy Star Hotline at 1-888-STARYES or Maria TikofT Vargar •
EPA Program Director, at 202-233-9178 the )
WasteWi$e Program
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 prevention, recycling collection and the
manufacturing and purchase of recycled products. As of 1997, the program
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had about 500 companies as members, one third of whom are Fortune 1000
corporations. Members agree to identity and implement actions to reduce
their solid wastes setting waste reduction goals and providing EPA with
yearly progress reports. To member companies, EPA, in turn, provides
technical assistance, publications, networking opportunities, and national and
regional recognition. (Contact: WasteWiSe Hotline at 1-800-372-9473 or
Joanne Oxley, EPA Program Manager, 703-308-0199)
NICE3
The U.S. Department of Energy is administering a grant program called The
National Industrial Competitiveness through Energy, Environment, and
Economics (NICE3). By providing grants of up to 45 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, and
demonstrate 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
forest products, chemicals, petroleum refining, steel, aluminum, metal casting
and glass manufacturing sectors. (Contact: http//www.oit.doe.gov/access/
nice3, Chris Sifri, DOE, 303-275-4723 orEricHass, DOE, 303-275-4728)
Design for the Environment (DfE)
DfE is working with several industries to identify cost-effective pollution
prevention strategies that reduce risks to workers and the environment. DfE
helps businesses compare and evaluate the performance, cost, pollution
prevention benefits, and human health and environmental risks associated with
existing and alternative technologies. The goal of these projects is to
encourage businesses to consider and use cleaner products, processes, and
technologies. For more information about the DfE Program, call (202) 260-
1678. To obtain copies of DfE materials or for general information about
DfE, contact EPA's Pollution Prevention Information Clearinghouse at (202)
260-1023 or visit the DfE Website at http://es.inel.gov/dfe.
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X.C. Trade Association/Industry-Sponsored Activity
The trade associations that represent the transportation industry are a valuable
source of economic and environmental compliance data. The following
subsections list major transportation trade organizations and highlight
environmental initiatives sponsored by some of these groups.
X.C.I. Railroad Tank Car Safety Research and Test Project
Since 1970 the Railway Progress Institute (RPI) and Association of American
Railroads (AAR) have cosponsored the RPI-AAR Railroad Tank Car Safety
Research and Test Project. The purpose of the project, initiated following
several fatal tank car crashes in the late 1960s, is to identify and understand
the causes of tank car punctures and ruptures in accidents and to develop
engineering solutions. Results of this continuing project have led to the
development and introduction of several devices to improve tank car crash
worthiness, including double-shelf couplers and head and thermal protection
systems. In addition, the program has produced a database of more than
35,000 records of tank cars damaged over the past 30 years (Ensuring
Railroad Tank Car Safety, Transportation Research Board, National Research
Council, 1994).
The research conducted on tank car safety has resulted in the implementation
of regulation to increase the safety of certain hazardous material cars. DOT
HM-175 which was finalized in September 1995, covers a wide range of tank
car safety related issues, including new tank car specifications for halogenated
organic compounds. This effort has resulted in significantly safer tank cars for
these materials.
In addition, there have been several improvements in an industry agreement
between the AAR, the Chemical Manufacturers Association (CMA), and RPI,
including:
Thicker tank cars made of stronger steel;
• Elimination of bottom outlets, a common source of releases in
accidents; and
A full height head shield to protect the end of the tank from punctures
in accidents.
X.C.2. The North American Non-Accident Release Reduction Program
The North American Non-Accident Release Reduction Program was initiated
in June 1995 by the rail industry. A "Non-Accident Release" (NAR) is any
unintended release of a hazardous commodity from a railroad car not caused
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by a train accident. Most NAR's involve small quantity releases, but some
have been very costly and all have the potential for serious injury. The North
American NAP Program is an awareness campaign designed to alert shippers
and carriers to repeated instances of NARs of hazardous commodities from
rail tank cars and encourage positive action to prevent recurrence.
General oversight of the NAR Program rests with AAR's Hazardous Materials
Working Committee and the NAR General Committee, made up of
representatives from shippers, carriers, car owners, and industry associations.
The NAR Program has two sub-committees, a Technical Subcommittee and
a Communications/Regulatory Subcommittee. The Technical group reviews
NAR data and attempts to develop technical solutions to identified problems.
The Communications/Regulatory group works on program publicity and
government (regulatory) relations.
NAR data is collected by carriers and reported to AAR, who enters it into an
NAR database, keeping all business data confidential. When a threshold
number of releases has been recorded for any given company, AAR prepares
an "action package" outlining the details of each release and forwards the
information to a designated individual at that company. Recipients of action
packages are encouraged to take whatever actions are appropriate to address
the causes of the releases, advising AAR of their response. The NAR General
Committee has set a goal to reduce the number of NARs from hazardous
materials tank cars in North America by 25 percent over a two year period.
The North American NAR Program is an expansion of a successful program
started in Canada in 1992. NAR's in Canada were reduced 32% over a two
year period after implementation of the program.
X.C.3. Environmental Compliance Handbook for Short Line Railroads
As part of its mandate to clarify and communicate environmental regulatory
responsibilities to the freight and rail industry, EPA's Freight, Economy, and
the Environmental Work Group has worked with the Federal Railroad
Administration (FRA) to prepare a handbook on EPA regulations applicable
to short line railroads. The handbook is a "plain English" guide to short line
railroad environmental responsibilities and the laws that created them. The
handbook also provides State and Federal agency contacts and Hotlines.
X.C.4. Environmental Training Publications and Videotapes
The American Trucking Associations (ATA) has developed numerous
documents and videotapes to help those in the trucking industry to better
understand applicable environmental regulations and to assist them in
compliance. Following is a list of some the materials offered by the ATA.
For a more complete catalogue listing these and other products, contact the
ATA document center at (800) ATA-LINE.
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Stormwater Best Management Practices: Guidance for Vehicle
Maintenance Facilities (video) - Identifies practical and effective best
management practices that can be used in vehicle washing, fueling,
and loading areas.
Used Oil: A Guidebook to Best Management Practices - Helps the
user determine the company's responsibilities and develop procedures
that are productive, cost-efficient, and in compliance with Federal and
State guidelines.
Hazardous Waste Regulations for the Trucking Industry - Outlines
and explains hazardous waste regulations as they relate to the trucking
industry.
Stormwater: Pollution Prevention for the Trucking Industry -
Explains how to write a pollution prevention plan and covers the five
general phases of a plan in detail.
Vehicle Washing Compliance Manual - Provides a State-by-State
review of applicable regulations affecting vehicle washing and a
survey of vehicle washing technology.
X.C.5. Pipeline Integrity Programs - Natural Gas and Hazardous Liquid One-Call
Systems
More than 60 percent of pipeline accidents are the result of third-party
damage. One-call systems were developed to reduce the number of incidents
involving accidental pipeline ruptures.
Contractors and homeowners who work in the vicinity of natural gas and
hazardous liquid lines can learn of their location via a single telephone
number. This number is supplied in 48 of the 50 States and in Canada by
various one-call systems, and is usually posted on pipeline markers along the
pipe route.
Each one-call system is an organization funded by member underground
utilities. The system acts as a computerized link between people digging
around pipelines and the operators of these conveyance systems. When a
contractor or homeowner calls the toll-free number, the one-call operator
takes information regarding the time and location of planned work and
immediately notifies aU members with underground facilities in the excavation
area.
When a member receives notification of planned excavation in its area, its
operators are responsible for determining the potential hazards to the line. If
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the work does have the potential to affect the pipeline, the company will
dispatch crews within 24 to 72 business hours to locate and mark the
pipeline's route. After determining the direction and width of the pipe,
personnel use a series of flags or spray paint to mark the exact location of the
system. If the work will cross the pipeline, crews also test for exact pipeline
depth.
X.C.6. Summary of Trade Associations
The trade and professional organizations serving the transportation industry
are presented below, classified by industry sector.
Rail
Association of American Railroads
50 F Street, NW
Washington, D.C. 20001
Phone: (202)639-2839
Fax: (202)639-2465
Members: 64
Staff: 607
Budget: $48,800,000
The Association of American Railroads (AAR) is 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 railcars, 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 annual Railroad Facts. The AAR also publishes studies,
statistical reports, and general information publications.
National Railway Labor Conference
1901 L Street, NW, Suite 500
Washington, D.C. 20036
Phone: (202)862-7200
Fax: (202)862-7230
Members: 150
Staff: 25
Budget: $4,100,000
The National Railway Labor Conference (NRLC), founded in 1963, serves as
a management collective bargaining agency for the railroad industry. NRLC
represents railroads as well as switching and terminal companies and compiles
statistics on the industry.
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Trucking
American Trucking Associations
2200 Mill Road
Alexandria, VA 22314
Phone:(703)838-1844
Fax:(703)838-1992
Members: 4,100
Staff: 300
Budget: $45,000,000
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 governmental 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. ATA and its
affiliated conferences provide extensive educational opportunities and
products to assist trucking companies with safety, OSHA, and environmental
regulation. In addition, the association provides members with a guide to
Federal and State regulations and offers a comprehensive accounting service
for carriers of all sizes. An information center containing numerous ATA and
other publications is available to members and the public.
Association of Waste Hazardous Materials Transporters
2200 Mill Road
Alexandria, VA 22314
Phone:(703)838-1703
Fax:(703)519-1866
Members: 75
Staff: 2
The Association of Waste Hazardous Materials Transporters represents
carriers that transport PCBs, used oil, and hazardous and radioactive waste
by truck and rail.
National Tank Truck Carriers
2200 Mill Road
Alexandria, VA 22314
Phone:(703)838-1960
Fax: (703) 864-5753
Members: 260
Staff: 7
Budget: $1,000,000
The National Tank Truck Carriers (NTTC) was founded in 1945 and
represents common or contract tank truck carriers transporting liquid and dry
bulk commodities, chemicals, food processing commodities, petroleum and
related products. NTTC promotes Federal standards of construction, design,
operation, and use of tank trucks and equipment. NTTC sponsors schools'
conducts research, and produces periodicals, including the annual Cargo Tank
Hazardous Materials Regulations and Hazardous Commodities Handbook.
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Regional and Distribution Carriers Conference
2200 Mill Road, Suite 540
Alexandria, VA 22314
Phone:(703)838-1990
Fax: (703)836-6870
Members: 375
Staff: 5
The Regional and Distribution Carriers Conference (RDCC) consists of
companies participating in trucking for hire, including local cartage and short
haul. RDCC was founded in 1943 and represents motor haul carriers
rendering distribution services beyond commercial zones. RDCC is affiliated
with ATA and conducts an executive management seminar and exhibit.
RDCC produces a monthly newsletter and several informational phamplets.
Interstate Truck Carriers Conference
2200 Mill Road, 3rd Floor
Alexandria, VA 22314
Phone:(703)838-1950
Fax: (703)836-6610
Members: 800
Staff: 7
Budget: $800,000
The Interstate Truck Carriers Conference (ITCC) consists of contract carriers,
irregular route common carriers, shippers, and others related to the motor
carrier industry. ITCC was founded in 1983 and serves as an industry
spokesperson for this part of the trucking industry. ITCC represents their
members' interests before Congress, the Interstate Commerce Commission,
and the courts. ITCC is affiliated with ATA and has a refrigerated carrier
division as well as a political action committee. ITCC conducts a
management development seminar at Notre Dame University and produces
bulletins and newsletters.
Pipelines
Interstate Natural Gas Association of America
555 13th Street, NW, Suite 300 West
Washington, DC 20004
Phone: (202)626-3200
Fax: (202)626-3249
Members: 35
Staff: 30
The Interstate Natural Gas Association of America (INGAA) represents
transporters of natural gas. INGAA has established committees on issues
regarding regulatory and government affairs, policy analysis, and the
environment. INGAA produces Interstate Natural Gas Association of
American - Washington Report, a weekly newsletter that covers legislative
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Ground Transportation Industry
Compliance Activities and Initiatives
and regulatory developments affecting the industry which is available to both
members and non-members.
American Petroleum Institute
1220L Street, NW
Washington, DC 20005
Phone: (202)682-8000
Fax: (202)682-8030
Members: 300
Staff: 500
The American Petroleum Institute (API) works to ensure cooperation
between industry and government on all matters of mutual concern. API
conducts research, sets standards, provides information services, and
maintains a large library. API was founded in 1919 and represents
corporations in the petroleum and allied industries, including producers,
refiners, marketers, and transporters of crude oil, lubricating oil, gasoline, and
natural gas. API has committees on industry technical issues, health,
environment and safety, and government affairs and produces many standards'
periodicals, books, and manuals.
Association of Oil Pipe Lines
1101 Vermont Avenue, NW, Suite 604
Washington, DC 20005
Phone: (202)408-7970
Fax: (202)408-7983
Members: 80
Staff: 3
The Association of Oil Pipe Lines (AOPL), founded in 1947, consists of oil
pipeline companies which are generally regulated carriers. AOPL compiles
and presents statistical and other data related to the pipeline industry to
Congress, government departments, agencies and commissions, trade
associations, and the public. AOPL is affiliated with API and produces
several publications, including Oil Pipelines of the United States: Progress
and Outlook.
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Ground Transportation Industry
Resource Materials/Bibliography
XL RESOURCE MATERIALS/BIBLIOGRAPHY
For further information on selected topics within the transportation industry sectors profiled in this
document, a list of publications is provided below:
General Profile
Transportation in America, Eno Transportation Foundation, Inc., 1994.
National Transportation Statistics, U.S. Department of Transportation, 1995.
1992 Census of Transportation, Communications, and Utilities: Geographic Area Series Summary,
U.S. Department of Commerce.
1992 Census of Transportation, Communications, and Utilities: Subject Series (Establishment and
Firm Size), U.S. Department of Commerce.
1992 Census of Transportation, Communications, and Utilities: Nonemployer Statistics Series
Summary, U.S. Department of Commerce.
Encyclopedia of Associations, 27th ed., Deborah M. Burke, ed., Gale Research Inc. Detroit
Michigan, 1992.
Enforcement Accomplishments Report, FY1992, U.S. EPA, Office of Enforcement (EPA/23 0-R93-
001), April 1993.
Enforcement Accomplishments Report, FY 1993, U.S. EPA, Office of Enforcement (EPA/3 00-R94-
003), April 1994.
Enforcement Accomplishments Report, FY 1994, U.S. EPA, Office of Enforcement, April 1995.
Environmental Sources and Emissions Handbook, No. 2, Marshall Sitig, Noyes Data Corporation
1975.
McGraw-Hill Encyclopedia of Science & Technology, 7th ed., vol. 8, McGraw-Hill Book Company
New York, New York, 1992.
Standard Industrial Classification Manual, Office of Management and Budget, 1987.
U.S. Industrial Outlook 1994, Department of Commerce.
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Ground Transportation Industry
Resource Materials/Bibliography
Rail Profile
Railroad Facts, 1995 Edition, Association of American Railroads, 1995.
Waste Minimization Assessment for a Manufacturer of Rebuilt Railway Cars and Components, F.
William Kirsch and Gwen P. Looby, University City Science Center, Philadelphia,
Pennsylvania and U.S. Risk Reduction Engineering Laboratory, Cincinnati, Ohio, July, 1991.
EPA/600/M-91/017.
Ensuring Railroad Tank Car Safety, Transportation Research Board, National Research Council,
1994.
Association of American Railroads Catalogue of Publications: 1995-1996, AAR.
Railroad Information Handbook, AAR, 1994.
Trucking Profile
Source Assessment: Rail Tank Car, Tank Truck, and Drum Cleaning, State-of-the-Art, Monsanto
Research Corporation, Dayton, Ohio, 1978.
One Hundred Years of Infrastructure: 1892-1992. July 1992.
General Pipeline Profile
Oil and Gas Pipeline Fundamentals, Second edition, JohnL. Kennedy, Pennwell Books, 1993.
"U.S. Interstate Pipelines Ran More Efficiently in 1994," Oil and Gas Journal, November 27, 1995.
Gas Pipeline Profile . .
Natural Gas 1995: Issues and Trends, Energy Information Administration, 1995.
Energy Policy Act Transportation Study: Interim Report on Natural Gas Flows and Rates, Energy
Information Administration, 1995.
Natural Gas Technologies: Energy Security, Environment and Economic Development: Conference
Proceedings, 1993, International Energy Agency, 1993.
Reporting Requirements of Interstate Natural Gas Pipelines (Report No. 93-1), INGAA, 1993.
Overvi&v of Natural Gas Storage Operations (Report No. 91-6), INGAA, 1991.
Analyses Related to the Impact of Air Quality Regulation on the Natural Gas Transmission Industry,
INGAA Foundation, 1992.
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Ground Transportation Industry
Resource Materials/Bibliography
New Directions: Natural Gas Supply, Natural Gas Council, 1992.
New Directions: Natural Gas Energy, Natural Gas Council, 1992.
Natural Gas Reliability, Natural Gas Council, 1993.
New Directions: Natural Gas Technology Research and Development, Natural Gas Council, 1993.
Natural Gas Reliability Principles, Natural Gas Council, 1995.
New Directions: Natural Gas, Energy and the Environment, Natural Gas Council, 1993.
America's Natural Gas Pipelines: A Network Built on Safety, INGAA.
Pipeline to Clean Energy: An Introduction to Interstate Natural Gas Association of America
Legislative Affairs, 104th Congress, INGAA.
Going the Extra Mile for Safety: America's Interstate Natural Gas Pipelines, INGAA Foundation.
Natural Gas Pipelines: The Safe Route to Energy Security, INGAA.
Factbook: Energy, the Environment, and Natural Gas, AGA, 1983.
Profiles of U.S. and Canadian Natural Gas Pipeline Companies, Third Edition, 1995.
Oil Pipeline Profile ^
International Petroleum Encyclopedia, Pennwell Publishing Co., 1994.
U.S. Oil Pipelines, George S. Wolbert, Jr., API, 1979.
U.S. Petroleum Strategies in the Decade of the Environment, Bob Williams Pennwell Publishing
Co., 1991. ' 5
Modern Petroleum: A Basic Primer of the Industry, Third Edition, Bill Berger and Ken Anderson
Pennwell Books, 1992.
"Regulation of Underground Storage," Petroleum Supply Monthly, August, 1991.
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APPENDIX A
INSTRUCTIONS FOR DOWNLOADING THIS NOTEBOOK
Electronic Access to this Notebook via the World Wide Web (WWW)
This Notebook is available on the Internet through the World Wide Web. The Enviro$en$e
Communications Network is a free, public, interagency-supported system operated by EPA's Office
of Enforcement and Compliance Assurance and the Office of Research and Development. The
Network allows regulators, the regulated community, technical experts, and the general public to
share information regarding: pollution prevention and innovative technologies; environmental
enforcement and compliance assistance; laws, executive orders, regulations, and policies; points of
contact for services and equipment; and other related topics. The Network welcomes receipt of
environmental messages, information, and data from any public or private person or organization.
ACCESS THROUGH THE ENVIRO$EN$E WORLD WIDE WEB
To access this Notebook through the Enviro$en$e World Wide Web, set your World Wide
Web Browser to the following address:
http ://es. epa.gov/comply/sector/index.html
or use
WWW.epa.gOV/OeCa - then select the button labeled Industry and Gov't
Sectors and select the appropriate sector from the
menu. The Notebook will be listed.
Direct technical questions to the Feedback function at the bottom of the web page or to
Shhonn Taylor at (202) 564-2502
Appendix A
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