United States
           Environmental Protection
Enforcement And '•'
Oomjbiiahce Assurance
           Profile Of The Ground
           Transportation Industry^-
           Trucking, Railroad And Pipeline

           EFA Office Of Compliance Sector Notebook:!roje|S:

                               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)

Ground Transportation Industry
Sector Notebook Project
             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


 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
       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.
Sector Notebook Project
        September 1997

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
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}
Sector Notebook Project
         September 1997

 Ground Transportation Industry
                      Sector Notebook Project
                               (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
Sector Notebook Project
September 1997

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
 Sector Notebook Project                    iv                            September 1997

  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

        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
Sector Notebook Project
September 1997

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

 Ground Transportation Industry
                                                Sector Notebook Project
 LERCs -
 MCLGs -
 MSDSs  -
                   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
 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
September 1997

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
September 1997

 Ground Transportation Industry
                             TRANSPORTATION INDUSTRY
                                (SIC 40, 42, 46, AND 49)


 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
Sector Notebook Project
September 1997

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

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.
 Sector Notebook Project                      2                             September 1997

 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
Sector Notebook Project
September 1997

Ground Transportation Industry
                     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.
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.
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
 Sector Notebook Project
September 1997

  Ground Transportation Industry
        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.
Crude Petroleum Pipelines
Refined Petroleum Pipelines
Pipelines, NEC*

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
Sector Notebook Project
September 1997

Page 6 intentionally left blank.

 Ground Transportation Industry
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

                     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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    September 1997

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

                     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
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     September 1997

 Ground Transportation Industry
Rail Transportation
                                          Exhibit 1
                          Facility Size Distribution of Rail Industry
Class I
Miles Operated
 Source: Compiled from Railroad Facts (Association of American Railroads, 1995).
                                           Exhibit 2
                        Line-Haul and Switching and Terminal Railroads
                                    Switching and Terminal
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
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    September 1997

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

                     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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Ground Transportation Industry
                           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
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
Percent of Total
Percent of
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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September 1997

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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September 1997

 Ground Transportation Industry
                           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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September 1997

Ground Transportation Industry
                          Rail Transportation
                                        Exhibit 5
     Rail Car Refurbishing and Maintenance Process Material Input/Pollutant Output
Oil and Grease
Car and Equipment
Rust Removal
Paint Preparation
Spray Booth, Spray
Guns, and Brush
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
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,
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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 Ground Transportation Industry
                           Rail Transportation
                     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

       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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Ground Transportation Industry
                          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 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
       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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                           Rail Transportation
       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
       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

 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

                     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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Ground Transportation Industry
                                            Exhibit 6
                                          Truck Types
  ffi                       ^&
 W*r—w^     I5«*	w
        Straight Truck

     I  	18'-35'	I

 26'-30'	I I —26'-28' — I
    3-Axle Tractor Semitrailer
4-Axle Tractor Semitrailer
      j - 25MO'
    5-Axle Tractor Semitrailer

                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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                September 1997

 Ground Transportation Industry
                      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
                     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*
Local Trucking Without
Trucking, Except Local
Local Trucking with Storage
Courier Services, Except by
Farm Product Warehousing
and Storage
Refrigerated Warehousing
and Storage
Cieneral Warehousing and
Special Warehousing and
Storage, NEC*
Terminal and Joint Terminal
Maintenance Facilities for
Motor Freight Transportation

Total Employees
Total Number
of Facilities
Employees per
     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
        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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                     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
 Ground Transportation Industry
                     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

                     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
        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
       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
Percentage of Total
           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
Percentage of Total
          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
Percentage of Total
          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
Truck Terminals and
Maintenance Facilities
Vehicle Exterior
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,
Residuals from shipments,
cleaning fluids -
detergent, caustic
solution, organic solvents,
Gas and diesel fuels,
alternative fuels, motor
oil, brake fluid,
transmission fluid,
coolant, truck cargo
Air Emissions
Possible CFC and VOC
VOC emissions
VOC emissions
Hydrocarbons, carbon
monoxide, oxides of
nitrogen, sulfur
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,
Spent cleaning fluids,
water treatment
system sludges, tank
Used oil, used
automotive fluids,
spilled or released
truck cargo
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  Ground Transportation Industry

  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*
Crude Petroleum Pipelines
Refined Petroleum
Pipelines, NEC**
Natural Gas Transmission
Natural Gas Transmission
and Distribution
Natural Gas Distribution
Mixed, Manufactured, or
Liquefied Petroleum Gas
Production and/or
Gas and Other Services

Total Employees
Total Number of
Employees per
 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*	
               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

                      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

3rd party damage
Earth movements
External corrosion
Internal corrosion
Scmn weld
Girth weld
Stress corrosion
Selective corrosion
Ovality, buckles
Obstructions, dents
Ovality, wrinkles
Bend radius
Pipeline movement
Hard spots
Aerial Patrols


Ground Systems






Close Interval



£ E2
o S
0 °
0 S





Geometry Pigs



Mapping Pigs






> 5 •















                              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
                     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

                     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
External '
Malf.. of
Number of
Percent of
23.36 .
Percent of
, 0
                          Source: DOT Office of Pipeline Safety, 1995.
                                     Exhibit 20
                Natural Gas Pipeline Incident Summary by Cause - 1994
Damage from
Outside Forces
Material Defect
Percent of
Percent of

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

                     •      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

                     •      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.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

                      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
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

                     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

                            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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                           Pollution Prevention
                      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

                      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

                             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

                             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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                           Pollution Prevention
                      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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                         Pollution Prevention
                     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

                            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

                      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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                            Pollution Prevention
         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

                             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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                                                                    Pollution Prevention
                           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

• Form Pollution Prevention Team
• Review other plans
• Develop a site map
• Inventory and describe exposed
• List significant spills and leaks
• Test for non-storm water discharges
• Evaluate monitoring data
• Summarize pollutant sources and risks
• Baseline Best Management Practices
• Select activity - and site-specific
• Implement BMPs
• Train employees
• Perform annual site inspection/BMP
• Perform recordkeeping and reporting
• Review and revise plan

            Source: Storimvater Pollution Prevention Manual for the Trucking Industry, ATA, 1993.
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                           Pollution Prevention
  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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                                                                     Pollution Prevention
       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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                           Pollution Prevention
        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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                         Pollution Prevention
                     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
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              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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             Federal Statutes and Regulations
                    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

                    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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              Federal Statutes and Regulations
                     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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            Federal Statutes and Regulations
                    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

                    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

                    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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               Federal Statutes and Regulations
                     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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             Federal Statutes and Regulations
                     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

               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

                     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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               Federal Statutes and Regulations
                      (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

                      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
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             Federal Statutes and Regulations
              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 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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               Federal Statutes and Regulations
                     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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            Federal Statutes and Regulations
                    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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               Federal Statutes and Regulations
                      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
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            Federal Statutes and Regulations
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
                     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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               Federal Statutes and Regulations
                      Potential RCRA hazardous wastes generated during railroad  operations

                             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
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                         Federal Statutes and Regulations
                                          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
    Contains monitoring and
    reporting requirement
    Note: facilities 'discharging to
    POTWs do not require NPDES
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
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,
                      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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               Federal Statutes and Regulations
                      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.
                      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
                     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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             Federal Statutes and Regulations
                     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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               Federal Statutes and Regulations
         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


                     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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            Federal Statutes and Regulations
                     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.
                     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
                     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
 Sector Notebook Project
September 1997

   Ground Transportation Industry
                Federal Statutes and Regulations
                       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'
Sector Notebook Project
                                                                           September 1997

Ground Transportation Industry
            Federal Statutes and Regulations
                     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

       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.
                     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.
                      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
 Sector Notebook Project
September 1997

  Ground Transportation Industry
                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.
                      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.
                     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.
                     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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                                                                          September 1997

             Ground Transportation Industry
            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

                                  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
               Sector Notebook Project
September 1997

 Ground Transportation Industry
          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
Sector Notebook Project
September 1997

Ground Transportation Industry
        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,
 Sector Notebook Project
September 1997

  Ground Transportation Industry
          Compliance and Enforcement History
                      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

                     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.
Sector Notebook Project
September 1997

Ground Transportation Industry
       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

                     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.
 Sector Notebook Project
September 1997

  Ground Transportation Industry
           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.
Sector Notebook Project
September 1997

Ground Transportation Industry
       Compliance and Enforcement History
Exhibit 24
Five-Year Enforcement and Compliance Summary for Transportation Sectors





in Search

Number of
w/One or

















to Inspection





 Sector Notebook Project
September 1997

  Ground Transportation Industry
          -Compliance and Enforcement History
                                          Exhibit 25
           One-Year Enforcement and Compliance Summary for Transportation Sectors
                                                            Facilities w/One or
                                                            More Enforcemenf
         , 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.
Sector Notebook Project
                                                                            September 1997

Ground Transportation Industry
    Compliance and Enforcement History
Exhibit 26
Fivr-Year Enfir^mMit and Compliance Summary by Statute for Transportation Sectors





Number of

Clean Air Act
% of Total






% of Total


. 15%




Conservation and
Recovery Act
% of Total







% of Total








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.
 Sector Notebook Project
September 1997

 Ground Transportation Industry
         Compliance and Enforcement History
Exhibit 27
One- Year Enforcement and Compliance Summary for Transportation Sectors

















Clean Air Act
% of Total




% of


*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
- 0%
enticideAct; the Toxi
1 as well as other Fed
Conservation and
Recovery Act
% of Total
c Substances and Con
eral environmental la\
% of Total
• 0%
0% •
" 0%



Sector Notebook Project
September 1997

Ground Transportation Industry
       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.
 Sector Notebook Project
September 1997

  Ground Transportation Industry
          Compliance and Enforcement History
Sector Notebook Project
                            September 1997

Ground Transportation Industry
      Compliance and Enforcement History


           o |




                                                                            U -~


  Sector Notebook Project
September 1997

  Ground Transportation Industry
          Compliance and Enforcement Hist(
Sector Notebook Project
                                                                   September 1997

Ground Transportation Industry
                                             Compliance and Enforcement History
                                                  i &

 'a a
         O B.


         O B,

         •3 3

         o a
 Sector Notebook Project
September 1997

  Ground Transportation Industry
                 Review of Major Legal Actic
                      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

              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

              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.
Sector Notebook Project
                                                                        September 1997

Ground Transportation Industry	  Review of Major Legal Actions

              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

  Sector Notebook Project                    104        '.                   September 1997

 Ground Transportation Industry
                 Review of Major Legal Actions
                      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

               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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                                    Review of Major Legal Actions
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
  Cost to
     Environmentally Beneficial Activities
       General Chemical
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
       Thatcher Chemical
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
$ 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
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  Ground Transportation Industry
            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
        X.A.1. Rail
        Waste  Minimization Assessment for  a Manufacturer of Rebuilt Railway  Cars and

                     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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        Compliance Activities and Initiatives
                    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

                    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 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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            Compliance Activities and Initiatives
                      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 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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        Compliance Activities and Initiatives
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

                     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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            Compliance Activities and Initiativ
         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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        Compliance Activities and Initiatives
                    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)
                     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,

                           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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         Compliance Activities and Initiatives
                    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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            Compliance Activities and Initiatives
                             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

                             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

                     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

                     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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Ground Transportation Industry
        Compliance Activities and Initiatives
                     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

       X.C.6. Summary of Trade Associations

                     The trade and professional organizations serving the transportation industry
                     are presented below, classified by industry sector.
               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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                American Trucking Associations
                2200 Mill Road
                Alexandria, VA 22314
               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
              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
               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
              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

               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.
               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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                       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.
Sector Notebook Project
September 1997

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 Ground Transportation Industry
              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

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.
Sector Notebook Project
September 1997

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.

Ensuring Railroad Tank Car Safety, Transportation Research Board, National Research Council,

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.
 Sector Notebook Project
September 1997

  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.
Sector Notebook Project
September 1997


                               APPENDIX A


          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.


      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