United States
Environmental Protection
Agency
Industrial Environmental
Research Laboratory
Cincinnati OH 45268
EPA-600/2-78-004g
April 1978
Research and Development
Source Assessment:
Rail Tank Car,
Tank Truck, and
Drum Cleaning,
State of the Art
Environmental Protection
Technology Series

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                RESEARCH REPORTING SERIES

Research reports of the Office of Research and Development, U.S. Environmental
Protection Agency, have been grouped into nine series. These nine broad cate-
gories were established to facilitate further development and application of en-
vironmental technology.  Elimination of traditional grouping was consciously
planned to foster technology transfer and a maximum interface in related fields.
The nine series are:

      1.   Environmental Health Effects Research
      2.   Environmental Protection Technology
      3.   Ecological Research
      4.   Environmental Monitoring
      5.   Socioeconomic Environmental Studies
      6.   Scientific and Technical Assessment Reports (STAR)
      7   Interagency  Energy-Environment Research and Development
      8.   "Special" Reports
      9.   Miscellaneous Reports

This report has been assigned to the ENVIRONMENTAL PROTECTION TECH-
NOLOGY series. This series describes research performed to develop and dem-
onstrate instrumentation, equipment, and methodology to repair or prevent en-
vironmental degradation from point and non-point sources of pollution. This work
provides the new or improved technology required for the control and treatment
of pollution sources to meet environmental quality standards.
This document is available to the public through the National Technical Informa-
tion Service, Springfield, Virginia  22161.

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                                            EPA-600/2-78-004g
                                            April 1978
               SOURCE ASSESSMENT:
  RAIL TANK CAR, TANK TRUCK, AND DRUM CLEANING
                State of the Art
                       by

D. E. Earley, K. M. Tackett, and T.  R.  Blackwood
          Monsanto Research Corporation
               Dayton, Ohio  45407
             Contract No.  68-02-1874
                 Project Officer

                Ronald J. Turner
      Industrial Pollution Control  Division
  Industrial Environmental Research Laboratory
             Cincinnati, Ohio  45268
  INDUSTRIAL ENVIRONMENTAL RESEARCH LABORATORY
       OFFICE OF RESEARCH AND DEVELOPMENT
      U.S. ENVIRONMENTAL PROTECTION AGENCY
             CINCINNATI, OHIO  45268

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                           DISCLAIMER
This report has been reviewed by the Industrial Environmental
Research Laboratory-Cincinnati, U.S. Environmental Protection
Agency, and approved for publication.  Approval does not signify
that the contents necessarily reflect the views and policies of
the U.S. Environmental Protection Agency, nor does mention of
trade names or commercial products constitute endorsement or
recommendation for use.

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                             FOREWORD
When energy and material  resources  are  extracted,  processed,
converted, and used, the  related  pollutional impacts on our
environment and even on our  health  often require that new and
increasingly more efficient  pollution control methods be used.
The Industrial Environmental Research Laboratory - Cincinnati
(lERL-Ci) assists in developing and demonstrating new and
improved methodologies that  will  meet these needs  both effici-
ently and economically.

This report contains an assessment  of air emissions and water
pollutants from the rail  tank car,  tank truck, and drum cleaning
industry.  This study was conducted to  provide a better under-
standing of the distribution and  characteristics of pollutants
from this industry.  Further information on this subject may be
obtained from the Organic Chemicals and Products Branch, Indus-
trial Pollution Control Division.
                            David G. Stephan
                                Director
                 Industrial Environmental Research Laboratory
                               Cincinnati
                                111

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                             PREFACE


The Industrial Environmental Research Laboratory  (IERL) of the
U.S. Environmental Protection Agency  (EPA) has the responsibility
for insuring that pollution control technology is available  for
stationary sources to meet requirements of the Clean Air Act, the
Federal Water Pollution Control Act, and solid waste legislation.
If control technology is unavailable, inadequate, or uneconomi-
cal, financial support is provided for the development of control
techniques needed for industrial and extractive process indus-
tries.  Approaches considered include process modifications,
feedstock modifications, add-on control devices, and complete
process substitution.  The scale of the control technology pro-
grams ranges from bench- to full-scale demonstration plants.

IERL has the responsibility for developing control technology for
a large number  (>500) of operations in the chemical and related
industries.  As in any technical program, identifying the un-
solved problems is the first step.  Each industry is to be exa-
mined in detail to determine if there is sufficient potential
environmental risk to justify the development of control tech-
nology by IERL.

Monsanto Research Corporation (MRC) has contracted with EPA  to
investigate the environmental impact of various industries that
represent sources of pollutants in accordance with EPA's respon-
sibility, as outlined above.  Dr. Robert C. Binning serves as
MRC Program Manager in this overall program, entitled "Source
Assessment," which includes investigating sources in each of four
categories:  combustion, organic materials, inorganic materials,
and open sources.  Dr. Dale A. Denny of the Industrial Processes
Division at Research Triangle Park serves as EPA Project Officer
for this series.  Reports prepared in this program are of two
types:  Source Assessment Documents and State-of-the-Art Reports.

Source Assessment Documents contain data on pollutants from
specific industries.  Such data are gathered from literature,
government agencies, and cooperating companies.  Sampling and
analysis are also performed by the contractor when available
information does not adequately characterize the source pollu-
tants.  These documents contain all the information necessary
for IERL to decide whether a need exists to develop additional
control technology for specific industries.
                                IV

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State-of-the-Art Reports include data on pollutants from specific
industries which are also gathered from literature, government
agencies, and cooperating companies.  However, no extensive samp-
ling is conducted by the contractor for such industries.  Results
from such studies are published as State-of-the-Art Reports for
potential utility by government, industry, and others having
specific needs and interests.

This study was undertaken to provide information on air emissions
and water pollutants from cleaning rail tank cars, tank trucks,
and drums.  The work was performed for the Organic Chemicals and
Products Branch of the Industrial Pollution Control Division at
Cincinnati under Mr. David L. Becker.  Mr. Ronald J. Turner of
IPCD served as EPA Project Leader.
                                v

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                            ABSTRACT


This document reviews the state of the art of air emissions and
water pollutants from cleaning rail tank cars, tank trucks, and
drums.  The composition, quantity, and rate of emissions and
pollutants are described.

Rail tank cars, tank trucks, and drums are used to transport a
wide variety of chemical and petroleum commodities from producer
to consumer.  Steaming, washing and/or flushing of such units
result in air emissions and wastewater effluents.  Air emissions
are predominantly organic chemical vapors.  Water pollutants com-
mon to these operations are primarily oil and grease, COD, BOD,
suspended solids, and many other organic and inorganic materials.
Because of the latter, there is a high degree of variability in
the wastewater constituents.  Representative sources were defined
for rail tank car cleaning, tank truck cleaning, and drum clean-
ing, the latter with washing and burning and with washing only.
To evaluate the hazard potential of the representative sources,
source severity was defined and evaluated for air emissions and
for wastewater effluents.  Control methods used to reduce emis-
sions from rail tank car and tank truck cleaning are flaring,
absorption, or product recovery of flushed gases.  All other
emissions are vented.  No practical control methods exist for
drum washing.  Emissions from drum burning furnaces are con-
trolled by maintaining proper operating conditions.  Wastewater
treatments consist of a variety of physical, chemical, and bio-
logical processes.  By EPA estimates, two-thirds of the tank
truck industry discharges to municipal systems with little or no
pretreatment.  Where it has been provided, treatment has general-
ly been limited to sedimentation, neutralization, evaporation
ponds, and lagoons.

This report was submitted in partial fulfillment of Contract No.-
68-02-1874 by Monsanto Research Corporation under the sponsor-
ship of the U.S. Environmental Protection Agency.  This report
covers the period August 1976 to June 1977, and the work was
completed as of September 1977.
                               VI

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                            CONTENTS
Foreword .	iii
Preface	iv
Abstract	vi
Tables	viii
Abbreviations and Symbols  	  x
Conversion Factors and Metric Prefixes 	 xi
   1.  Introduction  	  1
   2.  Summary	2
   3.  Source Description  	  7
            Cleaning operations description  	  7
            Geographical distribution  	 16
   4.  Emissions	21
            Selected pollutants and emissions  	 21
            Definitions of representative sources  	 25
            Environmental effects of air emissions 	 26
            Environmental effects of water pollutants  .... 29
   5.  Control Technology  	 38
            Present technology 	 38
            Future considerations  	 46
   6.  Growth Potential  	 47

References	48
Appendices

   A.  Estimates of drum burning emissions	51
   B.  Definition of source severity for water discharges and
         calculation of river or end-of-pipe concentrations   . 53

Glossary	55
                               vxi

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                             TABLES
Number                                                       Page
      Water Pollutants from Rail Tank Cars, Tank Trucks,
        and Drums 	
  2   Source Severities for Air Emissions from a Represen-
        tative Cleaning Source for Rail Tank Cars, Tank
        Trucks, and Drums	 . . .  4

  3   Source Severities for Water Pollutants from a Repre-
        sentative Cleaning Source for Rail Tank Cars, Tank
        Trucks, and Drums 	  5

  4   Tank Car Cleaning Facilities Data	10

  5   Products Handled and Percent of Total Haulage 	 12

  6   Trailer Internal Cleaning Generation Rates for One
        Terminal During One Month of Operation  	 12

  7   Commodity/Tank Truck Data for One Terminal During
        One Month of Operation	13

  8   Production of Steel Drums 	 15

  9   Rail Car Cleaning by State	17

 10   Tank Truck Cleaning by State	19

 11   NBADA Member Drum Cleaning and Burning by State  .... 20

 12   Measured Emissions from Tank Car and Tank Truck
        Cleaning	22

 13   Waste Treatment Plant Effluent Data, June 1973   .... 23

 14   Treatment Plant Operating Results—Matlack, Inc.,
        Swedesboro, New Jersey	24

 15   Maximum Ground Level Concentrations and Severity
        Factors for Different Emissions 	 28
                               Vlll

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                       TABLES  (continued)


Number                                                       Page

 16   Mass of Emissions from Tank Truck and Rail Tank Car
        Cleaning and Comparison with State and National
        Hydrocarbon Emission Burdens  	 30

 17   Mass of Emissions from Drum Burning and Comparisons
        with State and National Particulate Emission Burdens  32

 18   Effluent Concentrations and Hazard Factors for
        Representative Soruces  	 34

 19   Source Severities for Representative Sources  	 34

 20   Rail Tank Car Cleaning Contributions to State Emission
        Burdens	35

 21   Tank Truck Cleaning Contributions to State Emission
        Burdens	36

 22   Drum Washing Contribution to State Emission Burdens . . 37

 23   Lowest Effluent Concentrations Expected Using Various
        Treatment Process Combinations for Petroleum
        Refineries	45
                                IX

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                    ABBREVIATIONS AND SYMBOLS
AAQS      — ambient air quality standard
BOD       — biochemical oxygen demand
BODs      — amount of dissolved oxygen 'consumed in five days by
             biological processes breaking down organic matter
             in an effluent
C         — exposure level concentration
CD        -- raw effluent concentration

CM        — combustible material
COD       — chemical oxygen demand
Cc        — saturated dissolved oxygen concentration at 10°C
 o
(DO)WQ_,   — dissolved oxygen fresh water quality criteria

e         -- 2.72
F         — hazard factor
H         -- emission height
LC50      — lethal concentration of a pollutant to 50% of an
             aquatic life exposed to the pollutant
LD50      — lethal dose of a pollutant to 50% of a male rat
             population
pH        — measure of acidity or alkalinity of a material
Q         -- mass emission rate
S         — source severity
          -- severity of total oxygen demand potential
TOD       — total effluent oxygen demand
TSS       — total suspended solids
TLV       — threshold limit value
u~         -- average wind speed
Vn        -- volumetric flow rate of discharge

Vn        — volumetric flow rate of receiving waters
 K
VSS       — volatile suspended solids
Y         — maximum ground level concentration of pollutant
Amax                 ^                             ^
          -- time-averaged maximum ground level concentration
             of pollutant
          — 3.14

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             CONVERSION FACTORS AND METRIC PREFIXES

                       CONVERSION FACTORS
   To convert from

Degree Celsius  (°C)
Gr am/me te r 3  (g/m 3)
Gram/second  (g/s)
Kilogram  (kg)

Kilogram/meter 3
Meter  (m)
Meter/second
Meter3  (m3)
Meter3  (m3)
Meter3  (m3)
Meter3  (m3)
Meter3/second  (m3/s)
Metric ton

Milligram/liter  (mg/£)
Pascal  (Pa)
Pascal  (Pa)
Second  (s)
                       To
      (kg/m3)

   (m/s)
Degree Fahrenheit  (°F)

Pound/gallon
Pound/hour
Pound-mass  (pound mass
  avoirdupois)
Pound/gallon
Foot
Foot/minute
Barrel (42 gallon)
Foot3
Gallon (U.S. liquid)
Liter (H)
GalIon/minute
Ton  (short, 2,000 pound
  mass)
Pound/gallon
Torr  (mm Hg, 0°C)
Pounds-force/in.2  (psi)
Minute
                           Multiply by
                                      t° = 1.8
                 t° + 32
            8.344 x 10~6
                   7.936

                   2.205
            8.344 x 10~3
                   3.281
             1.181 x 10^
                   6.293
             3.531 x 101
             2.642 x 102
             1.000 x 103
            1.585 x lO-1*

                   1.102
            8.344 x 10~6
            7.501 x 10~3
            1.450 x lO'1*
            1.667 x 10~2
                         METRIC PREFIXES
Prefix   Symbol   Multiplication  factor
Kilo
Milli
Micro
k
m
y
    103
    io-3
    10~6
                                      Example
1 kPa = 1 x 103 pascals
1 mg = 1 x 10~3 gram
1 ym = 1 x 10~6 meter
aStandard for Metric Practice.  ANSI/ASTM Designation:   E 380-76e,
 IEEE Std 268-1976, American  Society  for  Testing and Materials,
 Philadelphia, Pennsylvania,  February 1976.   37  pp.
                                 XI

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                            SECTION 1

                          INTRODUCTION
Various chemical and petroleum products are transported by rail
tank cars, tank trucks, and drums.  These shipping containers
must be cleaned before being used to ship a different material
in order to prevent contamination of the new material.  Cleaning
prior to repair or testing is also necessary.

This report presents an assessment of the environmental impact
from the cleaning of rail tank cars, tank trucks, and drums which
have carried organic chemicals and petroleum products (not in-
cluding gasoline, diesel oil, fuel oil, jet fuels, or motor
oils).  Types of air emissions and wastewater effluents, pollu-
tant masses, ground level concentrations, source severities, and
affected population are discussed and analyzed.  Control tech-
nology and the growth of this source are described.

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                            SECTION 2

                             SUMMARY
Rail tank cars, tank trucks, and drums are used to transport a
wide variety of chemical and petroleum commodities from producer
to consumer.  Industry officials estimate that as many as 700
different commodities are handled by these carriers.  This report
does not address such commodities as gasoline, diesel oil, fuel
oil, jet fuels or motor oils.  Rail tank cars, and most tank
trucks and drums, are in dedicated service (carrying one commod-
ity only) and, unless contaminated, are cleaned only prior to
repair or testing.  Nondedicated tank trucks  (approximately
20,000 or 22% of the total tank trucks in service) and drums
(approximately 5.6 million or 12.5% of the total) are cleaned
after every trip to prevent cross contamination.  The approxi-
mate total number of units cleaned per year are 37,200 rail tank
cars, 5,010,000 tank trucks, and 24,680,000 drums.

Steaming, washing and/or flushing of rail tank cars, tank  trucks,
and drums result in air emissions and wastewater effluents.
These cleaning operations are partially enclosed.  Residual mate-
rial is washed to the wastewater stream and only small amounts of
material escape through the vents to the atmosphere.  Burning of
drums (as an alternative cleaning operation)  is a more economical
cleaning method for large companies but can result in increased
air emissions.

Air emissions from cleaning of rail tank cars and tank trucks are
predominantly organic chemical vapors.  If these are all consid-
ered as hydrocarbon emissions, the total emissions from each of
these industries contribute less than 0.0022% of the national
emissions of hydrocarbons.  Washing of drums falls into this
same class  (very low emission of noncriteria pollutants), but
some drum burning can produce some criteria pollutants such as
hydrocarbons, and nitrogen oxides  (NOX).  These contribute less
than 0.0001% and negligible amounts, respectively, to the
national emissions burdens of these pollutants.  Water pollut-
ants from cleaning of rail tank cars, tank trucks, and drums are
primarily oil and grease, total effluent oxygen demand  (TOD),
suspended solids, and phenol.

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Since TOD values were not available,  they  were  estimated from
the chemical oxygen demand.  Quantities  of water  pollutants from
this source in the United States  (shown  for  individual  states in
Tables 20-22) are summarized in Table 1.

           TABLE 1.  WATER POLLUTANTS FROM RAIL TANK
                     CARS, TANK TRUCKS,  AND  DRUMS
                         (metric tons/yr)


     Source type
	(basis)	Oil and grease   Suspended solids	COD    Phenol
Rail tank car cleaning
(37,220 cars/yr)
Tank truck cleaning
(5,010,000 trucks/yr)
Drum cleaning
(24,680,000 drums/yr)

830

1,745

101

4,100

6,070

353

8,300

48,500

2,824

31

986

57

For use in assessing the  environmental  impact  of  rail  tank  cars,
tank trucks, and drums used  for  transporting various chemical
and petroleum products, representative  sources were defined for
each of the cleaning types.  A representative  rail tank  car
cleaning station cleans 575  cars per year.  The mix of commodi-
ties handled is:   35% petroleum  products,  20%  organic  chemicals,
25% inorganic chemicals,  15% compressed gases,  and 5%  food
products.  A representative  large tank  truck cleaning  terminal
cleans 10,000 tank truck  trailers per year.  The  commodity  mix
hauled is:  15% petroleum products, 35% organic chemicals,  35%
inorganic chemicals, 5% food products,  and 10% others  (e.g.,
paints, inks, navel stores,  etc.).  A  representative  drum cleaner,
washing only, cleans 83,780  drums per year.  A representative
drum cleaner, washing and burning,  cleans  400,000 drums  per year,
65% by burning and 35% by washing.

To evaluate the hazard potential of the representative sources,
the source severity was defined  for air emissions and  for waste-
water effluents.   For air emissions, source severity was defined
as the ratio of the time-averaged maximum  ground  level concen-
tration of a pollutant emitted from a representative source to
a hazard factor, F.  For  criteria pollutants,  the hazard factor
is the primary ambient air quality standard; for  noncriteria
pollutants, it is  a "corrected"  threshold  limit value.   For
wastewater effluents, the source severity  was  defined  as the
ratio of the exposure level  concentration  to a hazard  factor.
For oil and grease, phenol,  and  suspended  solids  in each of the
representative sources, the  hazard factor  was  the EPA  fresh
water quality criteria for these pollutants.   The exposure  level
concentration was  defined as the ratio  of  the  product  of the
volumetric discharge flow rate and the  raw effluent concentra-
tion, to the volumetric flow rate of the receiving waters.

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 The source severity of the total oxygen demand potential of a
 discharge was defined as the ratio of the potential total oxygen
 deficit to the permissible total oxygen deficit.  Total oxygen
 deficit was based on the discharge water volumetric flow rate,
 the receiving water volumetric flow rate, and the chemical
 oxygen demand; the permissible total oxygen deficit was the
 difference between the saturated dissolved oxygen concentration
 and the dissolved oxygen fresh water quality criteria.  The
 source severity values calculated for air emissions and waste-
 water effluents from each type of representative cleaning source
 are summarized in Tables 2 and 3.
                              i

      TABLE 2.  SOURCE SEVERITIES FOR AIR EMISSIONS FROM A
                REPRESENTATIVE CLEANING SOURCE FOR RAIL
                TANK CARS, TANK TRUCKS, AND DRUMS
                                                  Air
Type of cleaning Emissions source severity
Rail tank car



Tank truck




Drum washing
Drum burning



Ethylene glycol
Creosote
Chlorobenzene
o-Dichlorobenzene
Acetone
Perchloroethylene
Methyl methacrylate
Phenol
Propylene glycol
Organics
Particulates
Hydrocarbons
Carbon monoxide
Nitrogen oxide
0.00017a
•* U
3.6a'b
0.0061a
0.034a
0.045a
O.lla
0.0273
0.100a
0.00143
_C
0.28
P
V*
_
0.012

      These source severities, due to the intermittent
      nature of emissions, are for worst case conditions
      since the maximum ground level concentration was not
      time averaged.

      The sample was taken during the first 45 minutes of
      an 8-hr cleaning operation ; hence the severity value
      is suspected of being artificially high.
      Negligible.

Unlike most manufacturing industries, the tank truck industry
(which is service-oriented) produces wastewater whole volume and
characteristics may vary widely at each terminal.  Therefore,

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extensive data would be required for meaningful definition  of
the raw waste loads generated at truck terminals  (1).

      TABLE 3.  SOURCE SEVERITIES FOR WATER POLLUTANTS FROM
                A REPRESENTATIVE CLEANING  SOURCE FOR RAIL
                TANK CARS, TANK TRUCKS, AND DRUMS9
        Type of cleaning
   Pollutant
     Water
source severity
     Rail tank car
     Tank truck
     Drums  (with burning
       facilities)
     Drums  (washing only)
Oil and grease
TODb
Suspended solids
Phenol

Oil and grease
TOD
Suspended solids
Phenol

Oil and grease
TOD
Suspended solids
Phenol

Oil and grease
TOD
Suspended solids
Phenol
   0.16
   0.0034
   0.00033
   0.062

   0.014
   0.00081
   0.00002
   0.080

   0.0094
   0.00054
   0.000013
   0.053

   0.0030
   0.00017
   0.000004
   0.017
      See Appendix B  for detailed explanation of  source
      severity.

  ,    Total oxygen demand.

The population affected by the  average  ground level concentra-
tion, x", for which x/F>l-0 was  determined  from  the affected  area
and a representative  population density.   For emissions  from rail
tank car and tank'truck cleaning, the affected  population  is
zero.  For drum cleaning  (both  washing  and burning),  the affected
population is also zero.

Control methods used  to reduce  ^emissions from rail tank  car  and
tank truck cleaning are flaring, absorption, or product  recovery
of the gases flushed  from cars  or trucks that carry compressed,
combustible gases.  There are also  no practical control  methods
 (1) Analysis of Proposed  EPA  Effluent  Limitations  on the For-Hire
    Tank Truck Industry.   National  Tank  Truck  Carriers,  Inc.,
    Washington, D.C., June 1974.  31 pp.

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for emission reduction from drum washing at the present time.
Emissions from drum burning furnaces can be controlled by main-
taining proper operating conditions.  Control technology for the
treatment of wastewaters from these cleaning operations consists
of increasing use of a variety of physical, chemical, and bio-
logical processes.

Unless more stringent controls are placed on the cleaning of rail
tank cars, tank trucks, and drums, the increase in air emissions
from these operations should equal the 30% increase in chemical
production which is forecast through 1980.  Increased implementa-
tion of wastewater treatment processes will lead to an estimated
50% decrease in discharged water pollutants by 1980.

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                           SECTION 3

                       SOURCE DESCRIPTION


CLEANING OPERATIONS DESCRIPTION

The transportation of organic chemicals from point of production
to point of consumption is accomplished in rail tank cars, tank
trucks, drums, barges, and pipelines.  This report does not cover
barge or pipeline transport.  Contamination of successive ship-
ments can be avoided only by careful cleaning of containers prior
to refilling with a different or fresh material.

All rail tank cars and most tank trucks and drums are used in
dedicated service, which means that they are used repeatedly to
transport one kind of material.  In this service they are rarely
or never cleaned unless they become contaminated.  Some materials
require periodic cleaning even with dedicated service.  For exam-
ple, styrene cars and trucks must be cleaned after every fifth
trip because of slight polymerization of the styrene building up
on the sides of the container  (personal communications with
F. Bonham, Monsanto Company).

Tank trucks and drums not in dedicated service must be cleaned
after each trip before another material can be put into them for
shipping.  These shipping containers must also be cleaned prior
to repairs or testing.

Rail transportation is the principal mode for long-distance move-
ment of bulk chemicals.  Truck transportation is used for moving
bulk chemicals for distances up to a few hundred miles.  Drums
are used for transporting smaller quantities of chemicals and
are carried by either rail or truck, depending on distance.

Rail Tank Car Cleaning

There were 177,878 rail tank cars in use in 1972, of which 3,970
were owned by railroads and 173,908 were privately owned.  Car
owners operating in private carriage of their own products or raw
materials (chemical intermediates) account for approximately 10%
of the private ownership.  The rest are owned by car leasing and
operating companies and, along with the railroad-owned cars, are
operated on a for-hire basis (2).
(2) Yearbook of Railroad Facts, 1973.  Association of American
  >  Railroads, Washington, D.C., 1973.

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Tank car cleaning is conducted largely at shipping and receiving
terminals of manufacturers or producers where the wastes are com-
patible with and directed to the treatment systems of the indi-
vidual companies.  However, a significant amount  (30% to 40%)
of tank car cleaning is carried out at maintenance and service
stations operated or contracted by owner-lessors.  These instal-
lations must clean out wastes derived from a wide variety of
commodities, many of which require specific cleaning methods.
Wastewaters from these installations are partly or wholly treated
on site.  The extreme variety of commodities cleaned yields
wastewaters which are highly variable, complex, and difficult
to treat.

A typical tank car cleaning facility cleans from  4 to 10 cars
per day.  The tank cars cleaned in such facilities are used to
haul liquid commodities such as petroleum products (excluding
gasoline, fuel oils, and lubricating oils), vegetable and animal
oils, organic and inorganic chemicals, beverages, and liquefied
gases.  Capacity per car varies from 38 m3 to 129 m3 (10,000 gal
to 34,000 gal).

Cleaning agents used on tank cars are steam, water, detergents,
and solvents.  These agents are applied using steam hoses, pres-
sure wands, or rotating spray heads placed through the opening
in the top of the car.  Chipping and scraping of hardened or
crystallized products is frequently required.  Cars carrying
gases and volatile materials and those that are being pressure
tested have to be filled or flushed out with water.  The amount
of liquid used per car varies from 0.23 m3  (60 gal) for steam
cleaning to 129 m3  (34,000 gal) for total flushing of a large
tank car.  Table 4 presents tank car cleaning facilities data
for several stations  (3).  The average amount of residual mate-
rial cleaned from each car is estimated to be 250 kg (3).

Vapors from cleaning cars used to haul volatile materials are
sent to flares at some cleaning facilities.  Vapors of materials
such as anhydrous ammonia and chlorine are dissolved in water and
become wastewater constituents.  Vapors not flared or dissolved
in water are dissipated to the atmosphere.

Tank Truck Cleaning

An estimated 90,000 tank trucks are in service in the United
States, of which 30,000 are used exclusively by the owners to
haul their own products and 60,000 are operated on a for-hire
basis.
 (3) Development Document for Proposed Effluent Limitations Guide-
    lines and New Source Performance Standards for the Railroad
    Segment of the Transportation Industry Point Source Category.
    Office of Enforcement and General Counsel, National Field
    Investigations Center, Cincinnati, Ohio, February 1975.

                                8

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Approximately 20% of the  for-hire  trucks  are  used to haul bulk
dry freight and 80% are used  to haul  bulk liquids.   Most com-
panies operate fleets of  five trucks  or less;  these  constitute
about 90% of the fleets in operation.  The largest operating
company has 3,600 trucks  in its fleet.  Wherever  possible,  these
trucks are consigned to dedicated  service,  hauling one  product
for long periods of time.  The interiors  of dedicated trucks are
cleaned infrequently, usually in connection with  testing or
repair.

Interior washing of for-hire  tank  trucks  is conducted at many
tank truck dispatch terminals.  Each  year trucks  operating  from
a  single large terminal commonly haul 50  or more  organic and
inorganic chemicals, salts, acids,  bases,  agricultural  and  food
products, petroleum products, paint,  glue, plastics, soap,  lique-
fied gas, and latex.  Table 5 shows the mix of commodities  hauled
at a midwest terminal  (4).  Cleaning  tank trucks  which  have been
used for such a wide variety  of materials requires great flexi-
bility in the selection of cleaning methods.   Agents available
at most terminals include water, steam, detergents,  caustic,
acid, and solvents.  Tables 6 and  7 show  cleaning methods,  com-
modities and number of tank trucks cleaned at one terminal  in
one month as supplied by  the  terminal manager (4).   Cleaning
agents can be applied with hand-held  pressure wands  or  by Turco
or Butterworth rotating spray nozzles.  Detergent, caustic,  and
acid solutions are usually recycled until spent and  then sent
to the treatment facilities.   Solvents are recycled  in  a closed
system, and sludges that  accumulate are either incinerated  or
landfilled.  Quantities of liquid  used per tank truck vary  from
approximately 0.23 m3  (60 gal) for steam  operations  to  20.9 m3
 (5,500 gal) for full flushing, with 2 m3  (500 gal) being con-
sidered the average.  The average  amount  of material cleaned
from each trailer is estimated to  be  100  kg (4).
    *
Vapors from volatile materials are flared at  a few terminals,
but the most common practice  is to allow  them to  dissipate  in
the atmosphere.

Drum Cleaning

Steel drums used in shipping  organic  and  inorganic chemicals and
other products are manufactured in three  categories:  0.2-m3
(55-gal) drums made with  18-gauge  steel,  0.2-m3 (55-gal)  drums
with 20-gauge bodies and  18-gauge  heads,  and  0.11-m3  (30-gal)
drums in 20-/18-gauge.  Production of these drums  for 1972-1975
is shown in Table 8.
 (4) Development Document  for Proposed Effluent Limitations Guide-
    lines and Source Performance Standards  for the Trucking
    Segment of the Transportation  Industry  Point Source Category.
    Office of Enforcement and General Counsel, National Field
    Investigations Center, Cincinnati, Ohio,  1975.

                                 9

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      TABLE  4.  TANK CAR CLEANING FACILITIES DATA  (3)
Cars
Site washed/
no . day
118 5.5
119 5.1
120 1.4
121 5.0
122 2.5
123 7
124 11
125 5
126 11
127 4
128 5
129 1.6
130 1.1
131 4.4
132 9
133 9
134 2
Hastewater flow
mVday gpd
61 16,000
19 5,000
53 7,000
+7 , 000
tank test
water
53 14,000
30 8,000
40 10,600
193 51,000
72 19,000
170 45,000
17 4,500
33 8,600
38 10,000
19 5,000
627 165,600
(includes
tank
test and
cooling
water)
95 25,000
{includes
sanitary
cooling
water)
57 15,000

Commodities cleaned
Type
Oils , greases
Acids, bases
Solids, foodstuffs
Organic liquids
Compressed gases
Approximately same as
above
Approximately same as
above
Approximately same as
above
Generally same, more
vegetable oils,
nitrogen fertilizer
Organic liquids
Inorganic liquids
Organic gases
Inorganic gases
Organic solids
Inorganic solids
Unknown
Same as Site 123
Same as Site 123
Same as Site 123
Same as Site 123
Same as Site 123
Oil
Chemicals
Compressed gas
Food
Oil
Chemicals
Compressed gases
Food
UPG
Anhydrous ammonia
Acid and caustic
Volatile hydrocarbons
Fuel oil and asphalt
Food products
Unknown

Petroleum products
Acid and caustic
Anhydrous ammonia and LPG
Petroleum products
Gases
Percent
of total
29
10
31
13
17




45.5
19.5
4.S
15.5
9.5
0.5
5.0





20.5
38.5
31.2
9.8
32.0
21.3
38.5
8.2
34
19
19
5
11
3
9

60
3
37
90
Cleaning methods
Steam, detergent, solvent
Dilute with water
Hater , steam
Steam, water
Water purge
Same as above but less
water due to wanner
climate
Generally same but higher,
lower volume than above
Generally same with more
solvents (recycled)
Generally same as Site 118,
but more low pressure
high volume water
Manual removal of solids;
steam; caustic; kerosene;
detergent; purging
Same as Site 123
Same as Site 123
Same as Site 123
Same as Site 123
Same as Site 123
Steam, caustic
Water , detergents , s team
Flaring, steam
Water, detergent, steam
Same as Site 129
Purge steam, water
Purge steam, water
Neutralise, purge
Steam, water, chemicals
Purge steam, water, solvent
Purge steam, water, solvent
Steam, fuel oil, detergent,
water
Venting, steaming, and
detergent
Steam , detergents
venting
Waste treatment
Segregation, primary settling;
skimming; batch treatment
for CK, phenol, CnpH adjust-
ment, pond settling
Primary settling; oil skimming
evaporation; no discharge
Collection of excess residual;
primary settling; gravity
oil separation; equalization
pond
Primary settling; oil separa-
tion in 3 ponds in series
Limited collection excess resi-
dual; primary settling;
gravity oil separation; 3
ponds in series
Gravity separation segregation;
chemical coagulation; clari-
fication
Same as Site 123 to city
Same as Site 123 to city
Pond, no outlet
Pond , spray , irrigation ; to
city
Gravity separation; chemical
coagulation; evaporation pond
Primary settling; oil separa-
tion; to Sanitary District
Oil separator; pH adjustment
Solvent recycled; landfill
fuel oil and asphalt; primary
settling skimmer; secondary
pond
API separatory and closed
system; to city
Containment and floating
skimmers ; evaporation
None for tank test water and
cooling water to city sewer;
closed system and incinera-
tion
NOTE: Blanks indicate no data reported.
                                                     (continued)
                               10

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                                        TABLE   4   (continued)
                              (g/m3,   for  columns   listed  below)
site       Oil         Suspended solids     BODs           COD           Cyanide      Chromium        Phenols           pH Units
 no.   fax   Effluent    Raw   Effluent  Haw Effluent    Haw   Effluent  ten Effluent Haw Effluent    Raw   Effluent   Raw   Effluent
 118  10-4,000  20-150  50-30,000  15-50
                                               200-40,000 200-5,000 0-1  0-0.02  0-10  0-0.05  0-150      0      1.5-12.5  6.5-8.5
 120
                                 much less concentrated than Site 118 in all constituents
 121


 122
                                                                                                 0.24
124
125
126 -»
127 10
128
129 " high


_a
252

510
                                                          _a          _a


                                                            835
                                                                                                0.002
                                                                                                                  7.2
 130
                21
                               100        128
                                                                      0.002        high
 131     52.5     23        16     18    11    30
                                                     81     135
                                                                                          0.011  0.035       7.5
 132  20-645   27-171  50-107    30-49
                                                                                                       4.1-4.3  6.3-6.5
 133
aito discharge.         NOTE: Blanks indicate no data reported.
                                                       11

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  TABLE 5.  PRODUCTS HANDLED AND  PERCENT OF TOTAL  HAULAGE  (4)

Percent of total hauled
Product
Rhoplex- latex
Glycols
Resin
Plastics (bulkers)
Poly glycols
Lacquer
Paint and enamel
MMA (aery late monomer)
Molasses
Unidentified
Acryloids
Toluene
Toluenediamine
Vinyl acetate
Wax
Formaldehyde
Plasticizers
Jet fuel
Lube oil
Tar
Whiskey
Miscellaneous
1971
32.5
10.9
10.4
8.1

3.1


1.3





1.2


2.5
5.3


24.5
1972
31.1
21.1
10.6
9.0
4.7
3.0
2.4
2.4
1.7
1.4
1.3
1.1
0.9
0.8
0.8
0.8
0.8
0.8
0.6
0.6
0.5
3.0

          NOTE:   Blanks indicate these commodities  were
                 not cleaned in 1971.
   TABLE 6.  TRAILER INTERNAL CLEANING GENERATION RATES  FOR
             ONE  TERMINAL DURING ONE MONTH OF OPERATION  (4)

Number
1
2
3

4

5

6
7


8

TOTALS
Water use,
Cleaning method m3/trailer
Cold water flush
Cold water flush— caustic/acid tank
Cold water flush — steam — cold water
rinse
Cold water flush — spin/detergent —
cold water rinse
MEK, MIBK / or acetone solvent — cold
water rinse
Styrene solvent — cold water rinse
Cold water flush — steam — cold water
rinse — spin w/detergent — cold
water rinse
Cold water flush w/Butterworth for
dry bulk trailer

0.
8.

3.

1.

0.
0.


3.

5.

57
3

0

1

57
57


6

7

Number of Total water
trailers use, m
84
321

316

123

0
0


68

78
990
47.6
2,666.0

954.5
'
139.3

0
0


243.9

441.7
4,493.3

MEK - methyl ethyl ketone; MIBK - methyl isobutyl ketone.

                                12

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 TABLE 7.  COMMODITY/TANK TRUCK DATA FOR ONE TERMINAL
           DURING ONE MONTH OF OPERATION (4)
Cleaning
 method
 number
Commodity
 No. of
trailers
 cleaned
             Uran fertilizer
             PAPI—isozylate
             Ethyl chloride
             Alum
             Water for glue
             Water softener

             Caustic soda  (50%)
             Silicate soda
             Acetic acid
             Phosphoric acid
             Spent acid
             Sulfuric acid
             Hydrochloric acid
             Corrosive liquid

             Solvent
             Toluene
             Xylene
             IPA—isopropyl alcohol
             Sodium MET
             EDA—ethylene diamine
             DTA—diethylene triamine
             Poly amines
             Vinyl acetate
             Cyescal
             Phenol
             Alcohol
             Petroleum chemicals
             Peroxide
             Biphenyl
             Sodium bichromate
             Sodium methylate
             PA-phthalic anhydride
             Acetone
             Adaline
             Ferric chloride
             TTA—Amine 220
             AN—acrylonitrile
             Protein feed supplement
             Calcium chloride
             Styrene
             Methyl acrylate
                          16
                           2
                          10
                          53
                           2
                           1

                         123
                           2
                          22
                           1
                          47
                          87
                          38
                           1

                          18
                          26
                           2
                          23
                           1
                          15
                           8
                           7
                          23
                           3
                          32
                          22
                           1
                           4
                           2
                           9
                           3
                           6
                           9
                           4
                           3
                           3
                           8
                           2
                           1
                           2
                           1

                      tcontinued)
                           13

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                 TABLE 7 (continued).
Cleaning
 method
 number
Commodity
 No. of
trailers
 cleaned
3 (cont.)    Weed killer
             Shell pan
             DMK—dimethyl ketone
             Benzene
             Pentylamine
             Ethylene glycol
             MEK—methyl ethyl ketone
             ITA
             Mineral spirits
             DAA—diacetone acrylonitrile
             NBA—normal butyl alcohol
             Methanol
             Butyl cellosolve
             Formaldehyde
             Oxylene
             Naphtha
             MIBK—methyl isobutyl ketone
             Demineralized water
             Turpentine
             Oxital—ethylene glycol mono-
               ethane ether
             TRI Clean D

   4         Glue
             Paint
             Resin
             Water treating compound
             Coastal pale oil
             Petroleum oil
             Cotton oil
             Script set

   7         Diesel oil
             Petrolatum
             Ink oil
             Strip oil
             Hi Boiler Oil
             Tall Oil
             Insulator oil  (new)
             CPTIC—crude petroleum

   8         Potash and fertilizers
             Plastic pellets
                           4
                           1
                           4
                           1
                           1
                           3
                          14
                           2
                           3
                           4
                           1
                           3
                           1
                          24
                           1
                           1
                           4
                           1
                           2

                           1
                           2

                          72
                           2
                          30
                           5
                           7
                           3
                           2
                           2

                          21
                          16
                           2
                          13
                           2
                           5
                           1
                           8
                          78
aCleaning method numbers correspond to those tested in
 Table 6.
                           14

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              TABLE  8.   PRODUCTION OF STEEL DRUMS9

Size
0.2-m3 (55-gal)
0.2-m3 (55-gal)
0.2-m3 (55-gal)
0.2-m3 (55-gal)
0.11-m3 (30-gal)

Drum
Gauge
18
18
20/18
20/18
20/18

Production, thousands
Type
Tight head
Open head
Tight head
Open head
Tight head and
open head
1972
10,851
3,231
9,359
2,044

2,757
1973
12,032
3,426
9,917
2,234
b

1974
12,357
3,083
12,349
2,484
b

1975
8,352
2,066
8,419
1,956
b

 Personal communication from the National Barrel and Drum Association, 1976.
b
 Not available.

Drums constructed of 18-gauge steel have an  average  life with
total cleaning of eight trips.  Drums constructed with  20-gauge
bodies and 18-gauge heads have an  average life of three trips
(private communication; estimated  by M. Hershon, National  Barrel
and Drum Association).  Not all drums are cleaned, especially
those of thinner construction.  If all  0.2-m3  (55-gal)  drums  were
cleaned for  their average life, 121 million  drums would be
cleaned each year.

Tight-head drums which have carried materials that are  easy to
clean are steamed or washed with caustic.  Drums used to carry
materials which are difficult to clean  are burned out either  in
a furnace or in the open.  Tight-head drums  have the head  cut out
before burning and  are reconditioned as open-head drums.   Steam
cleaning is  accomplished by inserting a steam nozzle into  the
drum, with vapors going to the atmosphere and condensed water
going either to a sewer or onto the ground.  Caustic washing  is
done by tumbling the drum with a charge of hot caustic  solution
and some pieces of  chain.  The caustic  solution is recycled until
spent and then neutralized and sent to  the sewer.  Some cleaners
pond the spent caustic to allow sludge  settling before  sending
the liquid to the sewer.  The sludge is periodically removed  from
the pond and landfilled.  There are few, if  any, air emissions
from caustic cleaning.
Fiber drums are lined with disposable plastic  bags.
are disposed of in an industrial  trash  container.
Old bags
Drum burning furnaces are of  two basic  types;  batch and contin-
uous.  A batch-type  furnace is  designed to  hold one 0.2-m3
(55-gal) drum at a time.  The same  chamber  is  used to process
0.11-m3 (30-gal) drums.  Several gas  burners are arranged to
completely bathe the drum in  flame.   The contents,  lining,  and
outside paint of the drum are completely burned away within a
                                15

-------
nominal 4-minute period with the drum reaching a temperature of
at least 480°C (5).

Continuous-type furnaces accomplish the same combustion process
on each drum but are designed with a conveyor to pass a continu-
ous stream of drums through a preheat zone, a combustion zone,
and a postcombustion zone.  The drums are given the same 4-minute
combustion period at a temperature of at least 480°C.  The tem-
perature of the drums must not exceed 540°C since this would
cause excessive scale and warping  (5).

After the combustibles are consumed, the drums are allowed to
cool.  They are then shot-peened to remove ash and char.  Dents
are removed, the drums are tested hydraulically, and protective
coatings are applied  (5).

Emissions from the combustion process are vented to an after-
burner or secondary combustion chamber where" the gases are raised
to at least 760°C for a minimum of 0.5 second.  These conditions
should ensure complete combustion of elemental carbon and organic
combustion contaminants in the primary effluent  (5).

Open air burning is far less efficient than furnace burning be-
cause there is no way to control combustion air and temperatures.
Since there is no feasible way of controlling emissions from open
burning, incompletely burned combustion products can be released
to the atmosphere.  The average amount of material removed from
each drum is approximately 2 kg  (5).

GEOGRAPHICAL DISTRIBUTION

Rail Tank Cars

Information on rail tank car cleaning racks from the Railway
Progress Institute (personal communication with A. M. Skogsberg,
16 December 1976) and Railway Age Magazine (6) is shown by state
in Table 9.

Rail tank cars operated by chemical manufacturing companies to
haul their own products or raw materials account for about 10%
of car ownership  (3).  All such cars are in dedicated service
and are rarely cleaned.  Therefore, the cleaning of tank cars by
these companies is estimated to represent less than 5% of the
total cleaning nationwide.  The cleaning conducted by each of
these companies is governed by the waste treatment regulations
applicable to its industry.
 (5) Air Pollution Engineering Manual,  Second  Edition,  J.  A.
    Danielson, ed.  Publication No. AP-40, U.S.  Environmental
    Protection Agency, Research Triangle  Park, North Carolina,
  ,  May 1973.  987 pp.
 (6) Railway Age Directory of Contract  Car Repair Facilities.
    Railway Age, 177(13):44-49, 1976.
                               16

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              TABLE 9.   RAIL CAR CLEANING BY STATE

NO. Of
cleaning
State racks
Alabama
Arkansas
California
Delaware
Georgia
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maryland
Mississippi
Missouri
Montana
Nebraska
New York
North Carolina
Ohio
Oklahoma
Oregon
Pennsylvania
Tennessee
Texas
Virginia
West Virginia
Wyoming
TOTALS
2
3
5
1
3
2
2
1
5
2
3
1
1
2
1
2
2
1
1
1
1
5
1
12
1
3
1
65
No. of cars
cleaned/yr
500
3,000
2,000
100
2,000
2,000
4,750
100
5,000
200
2,500
500
750
600
500
200
1,000
75
1,750
500
375
1,850
75
5,500
75
1,300
20
37,220

Tank Trucks

Interior washing of tank trucks in conducted at tank truck dis-
patch terminals, which are distributed throughout the states, but
they are heavily concentrated in areas such as Chicago, Northern
New Jersey, the Kanawha and Ohio River Valleys, and the Louisi-
ana-Texas Gulf Coast area where large chemical manufacturing com-
plexes are located  (7).  There is no adequate data base on how
(7) Final Report on Cost of Implementation and Capabilities of
    Available Technology to Comply with P.L. 92-500; Volume IV:
    Industry Categories 29-38.  Prepared for the National Com-
    mission on Water Quality by Battelle Columbus Laboratories,
    Columbus, Ohio, July 3, 1975.


                                17

-------
many tank truck dispatch terminals actually perform cleaning
operations.  Many truck fleets are too small to have their own
cleaning racks and must .have their cleaning done for them at
larger terminals.  Even the National Tank Truck Carriers organi-
zation does not have data that they consider adequate.  Based on
a limited study of the transportation segment, Battelle/Columbus
has estimated that there are about 500 terminals involved in tank
truck cleaning (7).  Table 10 shows, by state, the distribution
of tank truck cleaning, based on Battelle's estimates and other
information obtained from conversations with industry members.

Drum Cleaning and Burning

The National Barrel and Drum Association (NBADA) is made up of
133 member companies, 35 of whom have burning facilities.  NBADA
estimates that the membership comprises at least 90% of the total
business and approximately 33.3% of the total number of companies
involved in the industry (personal communication with Pamela
Terry, NBADA, September 24, 1976).  Examination of manufacturing
indexes and the yellow pages for several cities indicates that
the 1/3 to 2/3 ratio holds fairly well for distribution of loca-
tions also.  Table 11 shows NBADA member drum cleaning facilities
by state.  From this information, it is estimated that there are
24,680,000 drums cleaned per year with 10,100,000 of these burned
clean.  The total number of companies in the United States is
estimated at 399 with 39 having burning facilities.
                                18

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TABLE 10.  TANK TRUCK CLEANING BY STATE  (7)

NO. Of
cleaning
State terminals
Alabama
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
Florida
Georgia
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
10
3
10
23
5
10
3
5
6
2
30
25
7
19
20
25
1
15
15
15
11
3
10
5
5
1
3
25
2
20
3
2
20
15
2
15
2
5
3
8
30
2
1
15
No. of
tank trucks
cleaned/yr
81,000
25,000
90,000
240,000
55,000
82,000
35,000
50,000
45,000
20,000
290,000
220,000
70,000
172,000
195,000
250,000
6,500
110,000
150,000
160,000
120,000
30,000
125,000
45,000
40,000
6,900
15,000
300,000
19,000
190,000
35,000
19,000
200,000
150,000
21,000
155,000
10,000
50,000
29,000
90,000
400,000
20,000
8,800
125,000
                              (continued)
                    19

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                   TABLE 10 (continued)

State
Washington
West Virginia
Wisconsin
Wyoming
TOTALS
No- of
cleaning
terminals
10
18
10
5
500
No. of
tank trucks
cleaned/yr
91,000
200,000
121,000
48,000
5,010,000

TABLE 11.  NBADA MEMBER DRUM CLEANING AND BURNING BY STATE
No. of
cleaning
State facilities
Alabama
California
Colorado
Connecticut
Florida
Georgia
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maryland
Massachusetts
Michigan
Minnesota
Missouri
Nebraska
New Hampshire
New Jersey
New York
North Carolina
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
Tennessee
Texas
Virginia
Washington
Wisconsin
Wyoming
TOTAL NBADA members
TOTAL estimate, of
all drum cleaners
1
14
3
2
3
4
7
2
1
1
2
2
4
2
5
4
2
1
1
10
10
4
15
1
1
12
1
2
2
3
3
2
5
1
133

399
No. of
burning
facilities
0
5
0
0
0
2
2
0
0
0
2
0
1
1
3
3
0
0
0
2
2
1
2
0
0
3
1
1
0
1
0
1
2
0
35

39
10 3 Drums
washed
84
1,454
251
168
240
450
708
168
83
85
280
180
392
225
580
508
169
85
80
920
890
380
1,390
100
80
1,160
140
225
150
328
240
224
531
85
13,123

14,580
10 3 Drums
burned
0
1,300
0
0
0
500
530
0
0
0
525
0
265
250
785
750
0
0
0
525
500
260
700
0
0
720
230
250
0
300
0
220
480
0
9,090

10,100
                            20

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                           SECTION 4

                           EMISSIONS


SELECTED POLLUTANTS AND EMISSIONS

The great diversity of commodities (>700 chemicals) carried by
rail tank cars, tank trucks, and drums makes it nearly impossi-
ble to sample and obtain emission factors for every possible
material.  In the drum cleaning and burning industry, only com-
posite estimates are possible for a wide mixture of materials.

Sampling of emissions from the cleaning of representative indi-
viual commodities is practical with tank cars and tank trucks.
In order to achieve a practical, but representative, picture of
these emissions, the organic chemicals hauled by the carriers
were broken down into classes characterized by high, medium, and
low viscosities and by high, medium,  and low vapor pressures.
Viscosity affects the quantity of material remaining in the tank;
low viscosity materials drain readily while high viscosity mate-
rials do not.  Vapor pressure affects the air emissions since
high vapor-pressure materials volatilize more readily during
cleaning and tend to lead to higher emission rates.

After the classes of chemicals had been established, the selec-
tion of the particular chemical to be sampled for was dictated by
the specific materials which were being cleaned during the sam-
pling visits.  Table 12 presents the chemicals sampled, the total
of each per truck or car, and the TLV® (8, 9) (threshold limit
value) of each.

Virtually all of the air and water pollutants are removed from
the tank during the first washing cycle.  This takes 45 minutes
to 1 hour for tank trucks and 1 hour to 2 hours for rail tank
cars.  Subsequent rinsing adds only small (<2% est.) quantities
of washing solution to the wastewaters.
(8) TLVs® Threshold Limit Values for Chemical Substances and
    Physical Agents in the Workroom Environment with Intended
    Changes for 1975.  American Conference of Governmental Indus-
    trial Hygienists, Cincinnati, Ohio, 1975.  97 pp.

(9) Sax, N. I.  Dangerous Properties of Industrial Materials,
    Third Edition.  Reinhold Book Corporation, New York, New
    York, 1968.  1251 pp.


                                21

-------
            TABLE  12.  MEASURED EMISSIONS FROM TANK
                       CAR AND TANK TRUCK CLEANING
    Compound
  Chemical class
  Vapor
pressure Viscosity
          Measured
          emission
  Total    concen-
emissions,  tration,  	
            mg/m3   mg/m3  Ref.
                                                            TLV
Acetone
Perchloroethylene
Methyl methacrylate
Phenol
Propylene glycol
Ethylene glycol
Chlorobenzene
O-Dichlorobenzene
Creosote

High
High
Medium
Low
Low
Low
Medium
Low
Low

Low
Low
Medium
Low
High
High
Medium
Medium
High

311/truck
2 15/ truck
32. 4/ truck
5 . 5/truck
1 . 07/truck
<0.32/car
15.7/car
75.4/car
2,350/car
(8-hr)
654
526
79.1
14.0
4.3
<0.2
8.8
94.3
118

2,400
670
410
19
260
260
350
300
22

8
8
8
8
_b
8
8
8
9


 Total emissions =  (emission rate) x (emission volume).
 No TLV listed; assumed to be same as that for ethylene glycol based on
 comments in Sax (9).

Wastewater is  subject to great variability and, even with a good
treatment system,  is difficult to treat to consistently accepta-
ble levels.  Table 13 presents waste treatment plant effluent
data  (API separator, pH  adjustment, aeration basin, sedimenta-
tion) for one  month of operation supplied by one tank truck
terminal official  (4).   This terminal is adding more treatment
process  (equalization, air flotation, filtration, biological)
to improve their treatment capability.

Another tank truck terminal official reports the treatment  plant
influent and effluent data shown in Table 14 which represent the
results of tests taken over a 6-month operating period  (10).
This treatment facility  (Figure 1)  (10)  is a 45-m3/day  (12,000-
gal/day) demonstration plant funded by the U.S. Environmental
Protection Agency.

Reported wastewater treatment data for several rail tank car
cleaning stations  are shown in Table 4 in Section 3  (3).

Samples taken  from the stack of a drum burning furnace were
analyzed for unburned organic materials and for organic prod-
ucts from incomplete combustion.  Analysis showed no detectable
levels  (<5 x 10~6  g/m3)  of organic materials.  This indicates
(10) O'Brien, J. E.  A Demonstration Plant for the Treatment of
     Waste Waters from Tank Truck Cleanings.  Presented  at  the
     American Institute of  Chemical Engineers National Meeting,
     Atlantic City, New Jersey,  September 1, 1976.  8 pp.
                                22

-------
     TABLE 13.   WASTE TREATMENT PLANT EFFLUENT DATA, JUNE 1973  (4)

Total
residue , TSS ,
Date
6/1
6/4
6/5—2.9" rain
6/6
6/7
6/8
6/11
6/12
6/13
6/14
6/15
6/18
6/19
6/20
6/21
6/22
6/25
6/26
6/27
6/28
Monthly average
pH 	 mg/
7.72 1,315
6.73 1,199
6.94 1,196
7.45 1,469
7.47 499
7.12 548
8.08 755
7.62 677
8.06 448
8.90 409
7.68 686
8.23 573
8.11 692
7.92 815
7.95 880
7.51 4,602
8.12 2,788
8.02 2,402
8.36 2,060
8.24 1,744
7.81 1,288
fc 	 rng/g,
478
442
342
1,168
175
242
49.2
584
131
85.6
262
24
32.6
131
247
61.2
94
22
73.2
76
186
VSS , BOD ,
COD,
mg/& mg/£ mg/fc
120 1
148
122
238
36
42
14.8
90
20
16.4
49
12.8
12.4
33
44
21.2
29
26.8
26.8
20.8
56
,364
460
475
61
185
40
11.4
8.3
10.1
13.3
24
13.2
28
63
73
25




17.8
3,274
1,431
1,373
269
268
110
66
64
30
42
94
69
144
215
254
251
183
169
235
139
434
Settleable
Temperature , sol ids ,
°C
V«^— ^^^^^V~^M^^^ta^M«^^^H**^H«
25


21

27
.5 30
.8 23
.1
.2 24
.5 28
.3 28
28
28
26
25
25
23
31
26
26
	 mg/fc
96
30
24 .
548
9
12
0.4
70
10

15.6
12
9.2
12.4
112
13.6
8.4
5.6
4.4
11.2
53

TSS = total suspended solids,
COD = chemical
NOTE: Some of
oxygen demand.
the quantities
VSS = volatile

in Table 13 are
suspended

shown per
solids

liter
, BOD =

biochemical

(&) , which is the s\
oxygen demand,

rstem of units
used in Reference 4.  These values can be converted to the SI metric system using the
equality,  1 I = 0.001 m3.  Blanks indicate data not reported.

-------
       TABLE  14.   TREATMENT PLANT  OPERATING  RESULTS—
                   MATLACK,  INC., SWEDESBORO,  N.J. (10)

Parameter
PH
Color units
Turbidity, FTU
COD, g/m3
BOD5 , g/m3
Oil and grease, g/m
Phenols, g/m3
Suspended solids, g/m3
Raw feed
10.5
to
Over
Over
1,800
600
110
1
300
to
to
to
to
to
12.5
500
500
11,000
2,000
350
250
1,300
Effluent
6.5
10

125
20
0


to
to
_D
to
to
to
0,1
_b
8.5
50

300
100
1



     Formazin  turbidity  units; a  standard unit of turbidity
     based upon a known  chemical  reaction.
    'Data not  reported.
RAW WASTE
        SURFACE
        SKIMOIL
          I (RESALE)
                      FLOTATION
                      /•CELL
           pH PRESSURE   /
              '  CELL
                                                             ACTIVATED
                                                             CARBON
                                                             TRANSFER
                                                             TANK
                                                         SPENT CARBON
     DISCHARGE
RECYCLE
  Figure 1.  Wastewater  treatment  system, Matlack, Inc.,
              Swedesboro,  New Jersey  (10).

                                24

-------
that a properly operated furnace is capable of  essentially
total destruction of waste organic materials encountered  in
drum burning.

The drum cleaning companies visited had closed  drum washing  sys-
tems with no discharge of wastewaters.  It is reasonable  to
assume that wastewaters from drum washing would present the  same
treatment problems as those from tank truck and rail tank car
cleaning and would be treatable by use of the same basic  treat-
ment technology.

DEFINITIONS OF REPRESENTATIVE SOURCES

Four representative sources are defined for use in determining
the source severity for each type of cleaning;  i.e., rail tank
car, tank truck, drum burning and washing, and  drum washing  only.
Due to the lack of adequate published data, these definitions are
based on estimates made by several officials of companies in the
industry and by the industrial organizations  (Railway Progress
Institute, and National Barrel and Drum Association).

Representative Rail Tank Car Cleaning

The representative rail tank car cleaner cleans 575 cars/yr
 (5.5 cars/day).  The commodities hauled and cleaned are 35%  pe-
troleum products  (excluding gasoline, fuel oils, and lubricating
oils.), 20% organic chemicals, 25% inorganic chemicals, 15% com-
pressed gases, and 5% food products.  The emission height  (height
of car) is 4 m.

Representative Tank Truck Cleaner

The representative tank truck cleaner cleans 10,000 tank  truck
trailers per year.  This is equivalent to 20,000 nondedicated
tank trucks cleaned 5 times per week, 50 weeks  per year at the
500 cleaning sites  (Section 3.).  The commodities hauled  and
cleaned are 15% petroleum products  (excluding gasoline, fuel
oils and lubricating oils), 35% organic chemicals, 35% inorganic
chemicals, 5% food products, and 10% others  (paints,  inks, naval
stores, plastic pellets, etc.)  The emission height ("height  of
truck is 3.55 m.

Representative Drum Cleaners

Drum Cleaner with Burning Equipment  (Type a)—
The representative drum cleaner with burning equipment cleans
approximately 400,000 drums/yr  (assuming 260 days/yr, 1,540
drums/day), of which 65% are burned and 35% are washed.   Emis-
sion heights are 10 m for burning and 1 m for washing.

Drum Cleaner with Washing Only  (Type b)—
The representative drum cleaner, with washing only, cleans
83,800 drums per year.  Emission height  (top of drum) is  1 m.

                               25

-------
Both categories of drum cleaners clean drums used to  carry  a  vast
variety of commodities, with organic chemicals  (including sol-
vents) accounting for 50%.  The remaining 50% includes  inorganic
chemicals, asphaltic materials, elastomeric materials,  printing
inks, paints, food additives, fuel oils, etc.

ENVIRONMENTAL EFFECTS OF AIR EMISSIONS

Maximum Ground Level Concentrations

The maximum ground level concentration, Xmax, of each pollutant
resulting from rail tank car and tank truck cleaning and from
drum burning and washing was estimated by Gaussian plume disper-
sion meteorology.  ^max values for each type of cleaning are
shown in Table 15.  For comparison, the TLV's and ambient air
quality standards (AAQS) are also listed.  Air emissions from
drum washing are negligible since each drum is washed by charging
with cleaning solution, putting in some chain, closing  the drum,
and tumbling it.  During this cycle, no vapors can escape except
during charging and dumping.  Emission rates would therefore  be
less than in rail car and tank truck cleaning, and these are
shown in Table 15 to be extremely low.

Sampling and analysis for organic materials in the stack gases
from drum furnaces show no detectable organics present  (detec-
tion limit 5 x 10~6 g/m3).  The primary combustion chamber
operates at less than 530°C with 200% excess air.  Secondary  com-
bustion is accomplished at approximately 700°C with 100% excess
air.  These conditions are conducive to complete combustion of
the organic materials in the drums, but the temperatures are  low
enough to prevent the formation of large quantities of nitrogen
oxides (NOX) .  Also, the concentrations of carbon monoxide  (CO)
and particulates would be small.  Automobile body incinerators
operate at conditions analagous to drum furnace conditions but
with less excess air.  Using emission factors for particulates
and N02 from auto body incinerators (11) , the emission  factors
from drum burning are estimated (see Appendix A) .  Maximum ground
level concentrations are not given for organics, carbon monoxide,
or hydrocarbons since the stack concentrations are below
detection.

The following equation was used for the calculation of  X    (12) :
                          X    =  2 Q                          (1)
                           max   7TH2eu
(11)  Compilation of Air Pollutant Emission Factors, Second Edi-
     tion.  Publication No. AP-42, U.S. Environmental Protection
     Agency, Research Triangle Park, North Carolina, April 1973.
     p.  2.2.-1.

                                26

-------
where  Q = mass emission rate,  g/s
       u = U.S. average wind  speed,  4.47  m/s
       H = emission height, m
       e = 2.72
       TT = 3.14

Environmental Effects

To  obtain  an indication  of the hazard potential of the emission
source,  the  source severity,  S, is  defined as  (12):


                               _ xmax
                             b ~  F

where ^max is the time-averaged maximum ground level concentra-
tion of  each pollutant emitted from a representative source of
tank or  for  criteria  pollutants and "a corrected" threshold
limit value  (TLV  • 8/24  •  1/100) for noncriteria pollutants.
The source severity represents the  ratio of time-averaged maxi-
mum ground level  exposure  to the hazard level of exposure for a
particular pollutant.

x"max is  the  maximum ground level concentration (Xmax)  averaged
over a given period of time.   The averaging time is 24 hours for
noncriteria  pollutants.  For criteria pollutants, averaging
times are  the same as  those used in the primary ambient air
quality  standards.


For the  tank truck and rail tank car cleaning operations, the
time periods during which emissions occur are approximately 1 hr
 for tank trucks and 2 hr for rail tank cars.   These times cor-
respond  to the initial wash cycle of each carrier.  Since it is
 rare for more than one truck or car containing a particular
material to be cleaned in any one day, time-averaging of Xmax for
that particular pollutant over a 24-hr period would result in an
extremely low Xmax and S.   Using Xmax in place of Xmax in Eclua~
tion 1 gives a worst case  source severity which represents the
maximum  hazard level  of exposure for a particular pollutant at
any time during a normal 24-hr period.

The values for Xmax and s  for each pollutant from each type of
cleaning are given in Table 15.  The worst case source severity
factors  for the pollutants from tank truck cleaning are <0.1 for
 (12)  Serth,  R.  W.,  and T.  W.  Hughes.   Source Assessment:
      Phthalic Anhydride (Air  Emissions).  EPA-600/2-76-032d, U.S.
      Environmental  Protection Agency, Research Triangle Park,
      North Carolina,  December 1976.  154 pp.

                                 27

-------
most classes of materials and  just  over 0.1 for the high vapor-
pressure, low viscosity class.  For rail tank car cleaning, the
worst case source severity  factors  are  <0.1 with the materials*
sampled except for one creosote car which was exceptionally
dirty.

       TABLE 15.  MAXIMUM GROUND LEVEL  CONCENTRATIONS AND
                  SEVERITY  FACTORS  FOR  DIFFERENT EMISSIONS

Type of
cleaning

Tank truck






Rail tank car





Drum burning


Emission

Acetone
Perchloroethylene
Methyl methacrylate
Phenol

Propylene glycol

Ethylene glycol
Chlorobenzene

o-Dichlorobenzene

Creosote
Particulates
NO
X
yS/$

359
248
37
6.35

1.24

<0.14
7.14

34.3

267
73
1.2

TLV,
g/m3

2.4
0.67
0.41
0.019

0.26

0.26
0.35

0.3

0.022
_b
_

AAQS, (13)
g/m3
a
~a
~a
~a

a

a
~a



a

0.00026°
0.0001"

Source
severity

0.045
0.11
0.027
0.100

0.0014

0.00017
0.0061

0.034

3.6
0.28
0.012


 AAQS not defined for these materials.

 Not applicable.
 24-hr average.
d
 Annual average.

For drum burning, the source severity  factors  are  very low with
particulates accounting for the highest  severity of  0-56.   Sever-
ity distributions for air emissions are  not presented since esti-
mates were used to define the representative source.   A survey of
the industry would be required to define ranges or limits  on
source size and this would necessitate an extensive  effort.

Contribution to Total Air Emissions
                i
The total air emissions from a particular source for each  state
and the nation are determined by multiplying the emission  factor
(13)  Code of Federal Regulations, Title  42  -  Public  Health,
     Chapter IV - Environmental Protection  Agency, Part 410  -
     National Primary and Secondary Ambient Air  Quality
     Standards, April 28, 1971.   16 pp.

                                28

-------
of a pollutant by the source production.  For  tank  truck  and  rail
tank?car cleaning, since the exact distribution of  the  represen-
tative chemical classes in total cleaning is unavailable,  the
emission factor for acetone  (the highest measured)  was  used to
calculate state and national burdens  for tank  truck cleaning; the
emission factor for creosote was used for rail tank car cleaning.
The total organic emissions from tank truck and rail tank  car
cleaning in each state were compared  with the  reported  total
hydrocarbon emission burden for that  state  (14), and these are
shown in Table 16.  Tank truck and rail tank car cleaning  contri-
bute <0.02% to the organic pollutant  burden of the  states  or
nation.  Total hydrocarbon emissions  from drum washing  or  burning
are negligible.  Total particulate emissions from drum  burning
contribute <0.023% of any state emission burden and 0.0007% of
national emissions burden  (Table 17).

Affected Population

To obtain a quantitative evaluation of the population influenced
by a concentration of emissions from  a source, the  area exposed
to the time-averaged ground level concentration, x", for which
X/Fi^l.O is obtained by determining the area within  the  isopleth
for x"  (15) , and the number of people  within the exposed area  is
then calculated by using a proper population density.

As shown in Table 15, the source severities  (except for creosote)
from rail tank car and tank truck cleaning, and from drum  wash-
ing and burning are below 1.0, even though these are worst case
calculations.  When no area is exposed to a severity £1.0, the
affected population for these operations is zero.   The  creosote
emission was from an exceptionally dirty car and is not consid-
ered to be typical of the industry.

ENVIRONMENTAL EFFECTS OF WATER POLLUTANTS

Effluent Concentration

The effluent concentrations, CD, are  defined as the total  mass of
suspended or dissolved material in a  unit volume of effluent  at
 (14) Eimutis, E. C., and R. P. Quill.  Source Assessment:  State-
     by-State Listing of Criteria Pollutant Emissions.  EPA-600/
     2-77-107b, U.S. Environmental Protection Agency, Research
     Triangle Park, North Carolina, July  1977.   146 pp.
 (15) Turner, D. B.  Workbook of Atmospheric Dispersion Estimates
     Public Health  Service Publication No. 999-AP-26, U.S.
     Department of  Health, Education, and Welfare, Cincinnati,
     Ohio, 1969.  64 pp.
                                29

-------
         TABLE  16.   MASS OF EMISSIONS FROM TANK TRUCK AND RAIL TANK CAR CLEANING AND

                     COMPARISON WITH STATE AND NATIONAL HYDROCARBON EMISSION BURDENS
u>
o

Carriers
hauling organics,
no. cleaned
State
Alabama
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
Florida
Georgia
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
Trucks
28,350
8,750
31,500
84,000
19,250
28,700
12,250
17,500
15,750
7,000
101,500
77,000
24,500
60,200
68,250
87,500
2,275
38,500
52,500
56,000
42,000
10,500
43,750
15,750
14,000
2,415
Rail cars
100
0
600
400
0
0
20
0
400
0
400
950
20
1,000
40
500
0
100
0
0
0
150
120
100
40
0
Total emissions,
metric tons/yr
Trucks
8.82
2.72
9.80
26.12
6.00
8.93
3.81
5.44
4.90
2.18
31.57
23.95
7.62
18.72
21.23
27.21
0.71
11.97
16.33
17.42
13.06
3.27
13.61
4.90
4.35
0.75
Rail cars
0.24
0
1.41
0.94
0
0
0.05
0
0.94
0
0.94
2.23
0.05
2.35
0.09
1.18
0
0.24
0
0
0
0.35
0.28
0.24
0.09
0
Percent of state (14)
hydrocarbon burden
Trucks
0.0014
0.0014
0.0050
0.0012
0.0031
0.0041
0.0060
0.0009
0.0011
0.0026
0.0017
0.0040
0.0024
0.0060
0.0065
0.0014
0.0006
0.0040
0.0037
0.0024
0.0032
0.0017
0.0033
0.0018
0.0034
0.0014
Rail cars
0.00004
0
0.00072
0.00004
0
0
0.00008
0
0.00021
0
0.00005
0.00037
0.00002
0.00076
0.00003
0.00006
0
0.00008
0
0
0
0.00018
0.00007
0.00009
0.00007
0
                                                                                (continued)

-------
                                    TABLE  16  (continued)
!—

Carriers
hauling organics,
no. cleaned
State
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
Trucks
5,250
105,000
6,650
66,500
12,250
6,650
70,000
52,500
7,350
54,250
3,500
17,500
10,150
31,500
140,000
7,000
3,080
43,750
31,850
70,000
42,350
16,800
Rail cars
0
0
0
200
25
0
0
100
55
720
0
0
0
25
1,100
0
0
25
0
220
0
4
Total emissions,
metric tons/yr
Trucks
1.63
32.66
2.07
20.68
3.81
2.07
21.77
16.33
2.29
16.87
1.09
5.44
3.16
9.80
43.54
2.18
0.96
13.61
9.91
21.77
13.17
5.22
Rail cars
0
0
0
0.47
0.06
0
0
0.24
0.13
1.69
0
0
0
0.06
2.59
0
0
0.06
0
0.52
0
0.01
Percent of state (14)
hydrocarbon burden
Trucks
0.0018
0.0040
0.0014
0.0016
0.0009
0.0029
0.0019
0.0048
0.0010
0.0019
0.0017
0.0006
0.0035
0.0027
0.0020
0.0022
0.0023
0.0037
0.0029
0.0187
0.0025
0.0094
Rail cars
0
0
0
0.0004
0.0001
0
0
0.00007
0.00006
0.00019
0
0
0
0.00002
0.00012
0
0
0.00002
0
0.00045
0
0.00002
    NATIONAL
1,730,000
7,440
538.05
87.47
0.0022
0.00037

-------
 TABLE 17.  MASS OF EMISSIONS FROM DRUM BURNING AND COMPARISONS
            WITH STATE AND NATIONAL PARTICULATE EMISSION BURDENS
    State
    No. Of
barrels burned
   Total
 emissions,
metric ton/yr
TOTAL
 10,100,000
   119.6
Percent of
   state
particulate
  burden
California
Georgia
Illinois
Kentucky
Maryland
Massachusetts
Michigan
Minnesota
New Jersey
New York
North Carolina
Ohio
Pennsylvania
Rhode Island
South Carolina
Texas
Washington
Wisconsin
1,400,000
550,000
590,000
580,000
290,000
280,000
870,000
830,000
580,000
550,000
290,000
780,000
800,000
260,000
280,000
330,000
240,000
530,000
16.8
6.6
7.0
7.0
3.5
3.3
10.3
9.9
7.0
6.6
3.5
9.2
9.5
3.0
3.3
4.0
2.9
6.4
0-0017
0.0017
0.0007
0.0013
0.0007
0.0034
0.0014
0.0037
0.0046
0.0041
0.0007
0.0006
0.0005
0.023
0.0017
0.0008
0.0018
0.0015
  0.0007
a given temperature and pressure.  In the raw effluent from
representative cleaning operations, Cp was estimated on the
basis of available information.  Concentrations for rail tank
car cleaning were taken as the average of the values shown for
the first site in Table 4.  This site, except for cleaning more
cars, closely approximate the representative source.  For tank
truck cleaning, the raw effluent averages shown in Table 14 were
used since this terminal's cleaning operation is similar to the
representative source  (30 trucks/day versus 40/day for the rep-
resentative plant).  No effluent concentration data were avail-
able for drum washing operations.  The assumption was made,
therefore, that the total material cleaned from drums was dis-
tributed in the same percentage ratios as the effluents from
tank trucks with no allowance made for removal of settleable
solids (see Appendix A).  The C^ values for all of these repre-
sentative cleaning operations along with effluent flow rates
are shown in Table 18.

Source Severity

Determination of the source severity for the representative
sources gives a measure of the effluent species concentration
                               32

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relative to a potentially hazardous or permissible concentration.
The source severity  (defined in Appendix  B)  is  calculated as
follows (16):
                                                               (3)


where   C = exposure level concentration, g/m33
        F = hazard factor  (Table 18)
       VD = volumetric flow rate of discharge, m3/s
       VR = volumetric flow rate of receiving waters, m3/s
             (national average river flow rate =  856 m3/s)
       Cj-j — concentration in raw effluent, g/m3

Severity values were calculated using Equation 3  for oil and
grease, phenol, and suspended solids for each of  the representa-
tive sources, and these are shown in Table 19.  The severity of
the total oxygen demand potential  (STOD) °f a discharge is the
ratio of the potential total oxygen deficit divided by a permis-
sible total oxygen deficit.  Thus, Equation 3 was modified as
follows to permit calculation of the severity of  the total
oxygen demand of a discharge  (17):
                                V
                                ~  (TOD)
                     q      =    R	                     (A\
                     S(TOD) - Cs -  (DO)WQC


where      TOD = total effluent oxygen demand, g/m3
            C,.. = saturated dissolved oxygen concentration at
             b   10°C  (= 11.3 g/m3)
        (DO)   , = dissolved oxygen fresh water quality
                 criteria  (=5.0 g/m3)
a
 g/m3 is equivalent to mg/£, which is the normal nonmetric unit
 used for concentration.
 (16) Decision Criteria for Water Discharges.  Draft prepared for
     EPA review under Contract 68-02-1874 by Monsanto Research
     Corporation, Dayton, Ohio, 1976.  4 pp.
 (17) Eimutis, E. C., T. J. Hoogheem, and T. W. Hughes.  Briefing
     Document:  Water Source Severity and Initial Water Prioriti-
     zation Structures.  Draft prepared under EPA Contract
     68-02-1874 by Monsanto Research Corporation, Dayton, Ohio,
     September 21, 1976.  12 pp.

                                33

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       TABLE 18.  EFFLUENT CONCENTRATIONS  (CD) AND HAZARD
                  FACTORS  (F)  FOR REPRESENTATIVE SOURCES






Effluent concentrations, g/m3
Source
Rail tank cars
Tank trucks
Drums, type a
Drums, type b
Hazard factor, F
Oil and
grease
2,005
230
148
148
0.01 (18)
. COD
20,100
6,400
4,130
4,130 fa
6.3
Phenol
75
130
84
89
0.001 (18)
Suspended
solids
10,025
800
517
517
25 (18)
Flow,
m3/day
61
45
25
15


a
 EPA fresh water criteria or equivalent.

 [C  -  (DO)   ] factor in Equation 4,  allowable dissolved oxygen depletion.
           y

     TABLE 19.   SOURCE  SEVERITIES FOR REPRESENTATIVE  SOURCES


                                  Source severity
                        Oil and           Suspended
         Source  type	grease	TOD	solids	Phenol

         Rail  tank  car   0.16    0.0034   0.00033    0.062
         Tank  truck      0.014   0.00081  0.000020   0.080
         Drums,  type a,b  0.0030  0.00017  0.000004   0.017


         The  representative sources have been defined in
         Section 4.

Since TOD values are  not available, Equation 4 was modified  to
(17):

                             y?-  1.3 (COD)

                   •   STOD = [Cs -  (DO)WQ(J                    (


where  COD =  chemical oxygen demand, g/m3

Severity values for TOD are shown in Table 19 for each of the
representative  sources.   In all of the source severity deter-
minations, the  assumption was made that the raw effluent was
(18) Quality Criteria  for Water.   EPA-440/9-76-023, U.S.  Environ-
     mental Protection Agency,  Washington, D.C.  501 pp.

                                34

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discharged with no treatment, thus  giving  a  worst case  determi-
nation.  In practice, oil and grease  separation  and batch treat-
ment of phenol provide a lower actual impact than the calcula-
tions indicate.  Reductions in oxygen demand and suspended solids
are also accomplished in the treatment processes used by  the
different cleaning facilities so  these impacts are in practice,
lower than the calculations indicate.   Severities are low in  all
cases with the highest value being  0.16.   Severity distributions
for effluent species are not presented since estimates  were used
to define the representative source.   A survey of the industry
would be required to define ranges  or limits on  source  size and
this would necessitate an extensive effort.

Contribution to State and National  Burdens

The total discharge quantities of oil and  grease,  COD,  phenol,
and suspended solids, assuming no treatment,  were calculated  by
dividing the production of the representative source into state
production totals and multiplying this by  the discharge per
representative source.  These quantities are shown,  by  state  and
nation, for each type of cleaning operation  in Tables 20,  21,
and 2 2.

         TABLE 20.  RAIL TANK CAR CLEANING CONTRIBUTIONS
                    TO STATE EMISSION BURDENS
State
Alabama
Arkansas
California
Delaware
Georgia
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maryland
Mississippi
Missouri
Montana
Nebraska
New York
North Carolina
Ohio
Oklahoma
Oregon
Pennsylvania
Tennessee
Texas
Virginia
West Virginia
Wyoming
Cars/yr
500
3,000
2,000
100
2,000
2,000
4,750
100
5,000
200
2,500
500
750
600
500
200
1,000
75
1,750
500
375
1,850
75
5,500
75
1,300
20
Oil and
grease,
metric
tons/yr
11
67
44
2.2
44
44
106
2.2
110
4.4
56
11
17
13
11
4.4
22
1.7
39
11
8.3
41
1.7
120
1.7
29
0.4
COD,
metric
tons/yr
110
670
440
22
440
440
1,100
22
1,100
44
550
110
170
130
110
44
220
17
389
110
83
410
17
1,200
17
290
4.4
Suspended
solids,
metric
tons/yr
56
330
220
11
220
220
530
11
560
22
280
56
83
67
56
22
110
18.3
194
56
42
206
8.3
610
8.3
140
2.2
Phenol,
metric
tons/yr
0.42
2.5
1.7
0.083
1.7
1.7
3.9
0.083
4.2
0.17
2.1
0.42
0.62
0.50
0.42
0.17
0.83
0.062
1.5
0.42
0.31
1.5
0.062
4.6
0.062
1.1
0.017
         TOTALS
37,220
                             830
8,300
                       4,100
                                                     31
                                 35

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TABLE 21.  TANK TRUCK CLEANING CONTRIBUTIONS
           TO STATE EMISSION BURDENS
State
Alabama
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
Florida
Georgia
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
TOTALS
Cars/yr
81,000
25,000
90,000
240,000
55,000
82,000
35,000
50,000
45,000
20,000
290,000
220,000
70,000
172,000
195,000
250,000
6,500
110,000
150,000
160,000
120,000
30,000
125,000
45,000
40,000
6,900
15,000
300,000
19,000
190,000
35,000
19,000
200,000
150,000
21,000
155,000
10,000
50,000
29,000
90,000
400,000
20,000
8,800
125,000
91,000
200,000
121,000
48,000
5,010,000
Oil and
grease,
metric
tons/yr
28
8.7
31
84
19
29
12
17
16
7
101
77
24
60
68
87
2.3
38
52
56
42
10
44
16
14
2.4
5.2
104
6.6
66
12
6.6
70
52
7.3
54
3.5
17
10
31
139
7
3.1
44
32
70
42
17
1,745
COD
metric
tons/yr
785
242
872
2,326
533
794
339
484
436
194
2,810
2,131
678
1,667
1,890
2,422
63
1,066
1,453
1,550
1,163
291
1,211
436
388
67
145
2,907
184
1,841
339
184
1,938
1,453
204
1,502
97
484
281
872
3,876
194
85
1,211
882
1,938
1,172
465
48,545
Suspended
solids,
metric
tons/yr
98
30
109
291
67
99
42
61
54
24
351
266
85
208
236
303
7.9
133
182
194
145
36
151
54
48
8.4
18
363
23
230
42
23
242
182
25
188
12
61
35
109
484
24
11
151
110
- 242
147
58
6,068
Phenol ,
metric
tons/yr
16
4.9
18
47
11
16
6.9
9.8
8.9
3.9
57
43
14
34
38
49
1.3
22
30
'32
24
5.9
25
8.9
7.9
1.4
3
59
3.7
37
6.9
3.7
39
30
4
30
2
9.6
5.7
18
79
3.9
1.7
25
18
39
24
9.4
986
                      36

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TABLE 22.  DRUM WASHING CONTRIBUTION TO STATE EMISSION BURDENS

1
State
Alabama
California
Colorado
Connecticut
Florida
Georgia
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maryland
Massachusetts
Michigan
Minnesota
Missouri
Nebraska
New Hampshire
New Jersey
New York
North Carolina
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
Tennessee
Texas
Virginia
Washington
Wisconsin
Wyoming
TOTALS
103 Drums/yr
93
1,616
279
187
267
500
787
187
92
94
311
200
436
250
644
564
188
94
89
1,022
989
422
1,544
111
89
1,289
156
250
167
361
267
249
590
94
14,580
Oil and
grease ,
metric
tons/yr
0.65
11.2
1.9
1.3
1.9
3.5
5.5
1.3
0.64
0.65
2.2
1.4
3.0
1.7
4.5
3.9
1.3
0.65
0.62
7.1
6.9
2.9
10.8
0.77
0.62
8.97
1.1
1.7
1.2
2.5
1.9
1.7
4.1
0.65
101
Suspended
solids,
metric
tons/yr
2.2
39.1
6.8
4.5
6.5
12
19
4.5
2.2
2.3
7.5
4.8
10
6.0
16
14
4.6
2.3
2.2
24.8
24
10
37.4
2.7
2.2
31.2
3.8
6.1
4.0
8.7
6.5
6.0
14
2.3
353
COD,
metric
tons/yr
18
313
54
36
52
97
152
36
18
18
60
39
84
48
125
109
36
18
17
198
192
82
299
21
17
250
30
48
32
70
52
48
114
18
2,824
Phenol ,
metric
tons/yr
0.37
6.36
1.1
0.74
1.0
2.0
3.1
0.74
0.36
0.37
1.2
0.79
1.7
0.98
2.5
2.2
0.74
0.37
0.35
4.02
3.9
1.7
6.08
0.44
0.35
5.07
0.61
0.98
0.66
1.4
1.1
0.98
2.3
0.37
57
                              37

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                            SECTION  5

                       CONTROL TECHNOLOGY
PRESENT TECHNOLOGY

Practical and economically feasible control of air emissions  from
the cleaning of rail tank cars and tank trucks does not exist at
present except for combustible gases and for water-soluble vapors
such as ammonia and chlorine.  Tanks carrying combustible gases
are filled completely.  The displaced gases from the tank are
sent to a flare and burned.  Vapors of materials such as ammonia
and chlorine are absorbed in water and sent to the wastewater
stream.

Air emissions from drum burning furnaces are controlled by proper
operation of the afterburner or secondary combustion chamber  of
the furnace.  There is no feasible control for emissions from
open burning of drums.  Solution washing of drums yields no air
emissions since the drum is closed during the wash cycle.  There
is currently no control used for emissions from steaming of
drums.  Most of the material from the drums is carried off with
the condensate water, and the air emission is dissipated to the
atmosphere.

Until the late 1960's little attention was given to wastewater
treatment in the rail tank car, tank truck, and drum reclaiming
industries.  This inattention resulted because the wastewaters
were generally low in volume, installations were small, and en-
vironmental impacts were considered relatively small in compari-
son to those of other industrial pollution sources.  Wastewater
from an estimated two-thirds of the installations was directed to
municipal treatment systems.  The rest were discharged directly
to surface water streams with only some oil separation.

In recent years, both the rail and truck industries have been
making a serious effort to improve their wastewater treatment
capabilities.  No installation is known to have a completely
satisfactory treatment system.  State-of-the-art treatment tech-
nology applicable to rail and truck wastewaters is, for the most
part,  well known and has been used by manufacturing industries
for several years.  Wide diversity in the materials entering  the
wastewaters prevents the use of a single specific treatment sys-
tem by all companies.  For this reason, tank car and tank truck
cleaning companies are approaching their individual problems  by


                                38

-------
using one or more combinations  of the methods described below in
a building block approach  to  develop alternate treatment schemes.

Gravity Separation

Free oil enters the wastewaters from tank contents,  exterior
washing of tanks, and  from leaks or  spills.   This  is removed by
gravity separation and incinerated or given  to a contracting
waste scavenger.  The  American  Petroleum Institute (API)  separa-
tor design is the most widely used.   This separator  is  a long,
rectangular basin which provides enough  retention  time  for  the
oil to float to the surface for removal.   API separators are
divided into bays to maintain laminar flow and prevent  short
circuiting.  They are  equipped  with  skimmers that  move  the  oil  to
the downstream end where it is  collected in  a slotted pipe  or
drum.  When returning  to the  upstream end, the skimmers  travel
along the bottom and move  settled solids into a collection
trough.  The sludge is dewatered and then incinerated or disposed
of in a landfill, with the water going to the next treatment
step.

There are several other designs of gravity separators but the
differences only amount to different geometries.

Gravity separation is  only effective for nonemulsified free  oil;
emulsified oil is not  removed.   Other factors affecting  the  effi-
ciency of gravity separation  are temperature,  oil  density,  and
suspended solids content.   Oil  removal also  takes  out some
phenols, BOD, and COD  since some organics are miscible with  oil.

Equalization

For ease of operation  and  for a more constant quality of waste-
water, the flow and waste  concentration  to mixed chemical treat-
ment systems should be as  uniform as possible.  Large fluctuation
should be dampened in  equalization facilities.

Equalization is provided in holding  tanks or  ponds with  a reten-
tion capacity of 1 day or  longer.  Baffles and  mixers are used to
improve equalization.   Holding  ponds are  sometimes used  to pro-
vide final treatment,  relying on long retention times (several
days) for settling and biological  oxidation.   Removal efficien-
cies vary widely:  5%  to 40%  for BOD5, 5% to  30% for COD, 20% to
90% for oil, 10% to 80% for suspended solids,  0% to  70%  for
phenol, and 30% to 70% for odor (19).

Wastewater is directed from the holding  basin to an  emulsion-
breaking and dissolved air-flotation chamber  to remove emulsified
oils and suspended solids.
(19) Manual on Disposal of Refinery Wastes.  American Petroleum
     Institute, Washington, D.C., 1969.
                                39

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Emulsion Breaking

This operation can employ either chemical or physical methods.
Physical methods include electrolysis, coalescence,  filtration,
centrifugation, distillation, and temperature change.  Chemical
methods, aimed at breaking down the stabilizing agent in the
emulsion, are more satisfactory.

The most practical method of chemically breaking emulsions
involves the addition of an acid or acid salt such as sulfuric
acid, alum, ferrous sulfate, or ferric chloride.  Soda ash may
then be used to neutralize the separated water.  The resulting
free oil and alum or iron floe can be separated by sedimentation
or air flotation.

Dissolved Air Flotation

This process consists of saturating a portion of the wastewater
feed, or some of the recirculated effluent from the flotation
unit, with air at a gage pressure of 275 kPa to 415 kPa (40 psi
to 60 psi).  The wastewater or recycled effluent is held at this
pressure for 1 minute to 5 minutes in a retention tank and then
released at atmospheric pressure to the flotation chamber.  The
sudden reduction in pressure releases air bubbles less than
100 ym in diameter which attach themselves to the oil and sus-
pended particles in the wastewater.  The resulting agglomerates
are then buoyed to the surface to form a froth layer which is
removed by skimming devices.  The retention time in the flotation
chamber is usually 15 minutes to 40 minutes.  The addition of
flocculating agents, such as polyelectrolytes, often improves the
effectiveness of the air flotation process and clarification.

Coagulation

Coagulation consists of adding chemicals to the wastewater to
create fast-settling agglomerates or floes from finely divided
and slow-settling particles.  Chemical coagulation and sedimenta-
tion can be used to treat the effluent from a gravity separator
prior to biological treatment.

The chemical coagulation-sedimentation process has three essen-
tial steps.  First, chemicals and/or polyelectrolytes are added
in a flash mix tank for 1 minute to 3 minutes.  Next, the waste-
water is gently stirred in a flocculation basin for 10 minutes to
30 minutes so that floes grow large enough to settle readily.
Finally, the agglomerated sludge is separated in a clarifier or
settling basin.  This process is capable of giving results com-
parable to those of dissolved air flotation in removing oils,
solids, BOD, and COD.

When operated properly, dissolved air flotation with chemical
coagulation can produce an effluent having an oil content of less


                                40

-------
than 10 g/m3.  The reduction of organic pollutants may be  inci-
dental to the removal of oil and  suspended  solids.  BOD5 reduc-
tion can range from 20% to  70%  (4).

The effluent from flotation-coagulation systems or from primary
settling may be further treated biologically  in aerated lagoons,
or by trickling filters, or by activated  sludge.  Some tank truck
cleaners are trying biological treatment  at the present time.
Activated carbon adsorption is being used as  an alternative to
biological treatment.

Aerated Lagoon

Aerated biological treatment is achieved  by mixing dilute  concen-
trations of microorganisms  with wastewater  in a large basin.  The
oxygen necessary to aerobically degrade the organic matter is
supplied by mechanical or diffused aeration units, or by induced
surface aeration.  The turbulence normally  maintained distributes
the oxygen and biological solids throughout the basin.

An aerated lagoon differs from an activated sludge unit in that
the effluent from the aerated lagoon may  not  be settled prior to
discharge, and the biological solids are  not  recirculated.  The
low rate of organic removal resulting from  the low concentration
of biological solids maintained in the lagoon requires a greater
retention time for an equivalent reduction  in BOD than is  the
case with activated sludge.  An aerated lagoon is capable  of
removing 50% to 95+% of BODs, depending on  temperature and pol-
lutant treatability  (4).  The removal efficiencies may be
improved by further treating the lagoon effluent using chemical
coagulation, sedimentation, filtration, or  an effluent polishing
pond.

Trickling Filter

In this process, wastewater is passed through a porous bed
(stones or plastic) that contains a fixed growth of microorgan-
isms.  A microbial film develops on the surface of the filtering
medium and removes organic  materials from the wastewater by
adsorption, bioflocculation, and sedimentation.  Oxygen is very
important in this system  (as it is in any aerobic biological
system) for rapid metabolism of the removed organic matter.
Since the filter medium has a large surface area, oxygen can move
readily by simple diffusion from the void spaces into the  liquid
layer.  Treatment rates of  trickling filters  are controlled by
both hydraulic and organic  loading rates.   Stone trickling
filters are limited, due to the low flow  rates involved, to
depths between 1 m and 3 m.  Those using  plastic generally have
high hydraulic and organic  loadings, and  their bed depths  range
from 5 m to 12 m.  A modification of the  trickling filter, used
at one treatment system visited, consists of  a large, rotating,
cylindrical cage, mounted horizontally and  partially submerged,


                                41

-------
carrying plastic rings.  The rotation of  the  cage  constantly
renews the oxygen and maintains a high  trickle  rate.

As the microbial film ages  and dies  on  the  medium,  it  drops  off
and is washed away.  With high organic  and  hydraulic loadings,
the film growth is more rapid.  However,  the  lack  of oxygen  in
the medium interface coupled with greater hydraulic shearing
action causes the microbial film to  wash  from the  media  surface
continuously.  A final clarifier is  normally  used  to remove  these
solids from the filter effluent to maintain minimum effluent BOD
and suspended solids concentration.

Activated Sludge

In this process, high concentrations (1.5 kg/m3 to  3 kg/m3)  of
newly grown and recycled microorganisms are suspended  uniformly
throughout a holding tank to which raw wastewaters  are added.
Oxygen is introduced by mechanical aerators,  diffused  air
systems, or other means.  The organic materials in  the waste are
removed from the aqueous phase by the microbiological  growths and
stabilized by biochemical synthesis  and oxidation  reactions.  The
basic activated sludge process involves the use of  an  aeration
tank followed by a sedimentation tank.  The flocculant microbial
growths removed in the sedimentation tank are recycled to the
aeration tank to maintain a high concentration of active micro-
organisms.  Although the microorganisms remove  almost  all of the
organic matter from the waste being  treated, much of the con-
verted organic matter remains in the system in the  form of micro-
bial cells.  These cells have a relatively  high rate of oxygen
demand and must be removed from the  treated wastewater before it
is discharged.

Activated Carbon Adsorption

This is one of the most effective methods for removing from
wastewaters countless dissolved organic materials  (both biode-
gradable and refractory) which contribute to BOD, COD, and taste
and odor problems.  In a few existing units, biologically treated
effluent is passed through vessels filled with granular, acti-
vated carbon.  In another unit visited, powdered activated carbon
is added along with coagulation chemicals into a tank  following
biological treatment.  It has been demonstrated in  pilot units
that raw wastes, which have been given chemical coagulation  (with
sedimentation or filtration) to remove suspended solids, can be
processed by carbon adsorption to provide almost any level of
treatment (20) .  The carbon gradually loses its adsorptive capac-
ity as it accumulates organic materials from the wastewater  and
must be eventually replaced.  To make the process more economi-
 (20) Process Design Manual for Upgrading Existing Wastewater
     Treatment Plants.  Contract 14-12-933, U.S. Environmental
     Protection Agency, October 1971.
                                 42

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cal the spent carbon is usually  reactivated and the bed replen-
ished with new carbon.  Frequently multiple adsorption colums  are
utilized in series or in .parallel so  that at least one unit  may
be pulled out of service  for  replenishment.   Moving bed carbon
filters are sometimes used  to eliminate the spare  colums required
for regeneration and to produce  more  consistent effluent,  but
there seem to be problems involved in the countercurrent movement
of the carbon particles.  Unlike biological treatment  processes,
the efficiency of carbon  treatment is not very  sensitive to
seasonal temperature changes.  In most cases, the  combined use
of coagulation, filtration, and  carbon adsorption  is more reli-
able and controllable than  biological treatment.

Granular Media Filtration

The media used in granular  filters, either  pressurized  or  grav-
ity, may consist of 1) sand,  2)  sand  and coal,  or  3) sand,
coal, and a heavy fine material  such  as  garnet.  When  the  medium
is sand, a relatively uniform grade of  sand  rests  on a  layer of
coarser sand or fine gravel.   When the medium is sand  and  coal, a
layer of fine sand rests  on a layer of medium coal.  These two
types of filters present  the  problem  of  keeping the  fine  sand
from moving through the coarse layer  to  the  bottom.  This  problem
can usually be solved by  placing a layer of  garnet between the
fine and coarse layers.   This  comprises  the  third medium  listed
above.  Periodically, the top sand layer is  removed  for  landfill-
ing and is replaced with  fresh sand.

Granular media filters are capable of prodnr.tng an effluent which
consistently shows extremely  low suspended  solids and oil content
on the order of 5 g/m3 to 10  g/m3 for each  (4).

Batch Treatment of Individual  Waste Streams

Sometimes, wastes are encountered which  are  not effectively
treated by the above processes or even interfere with them.
Metals and cyanide wastes are  examples.   Normally they occur
intermittently and in relatively small quantities, making them
amenable to batch treatment prior to discharge to surface waters
or before mixing with other wastes for further treatment.  Chro-
mium wastes, for example, can  be treated with sulfuric acid and
sulfur dioxide to reduce  hexavalent chromium to trivalent, which
can then be discharged for precipitation in  the coagulation-
sedimentation system described previously.   Cyanides can be
subjected to alkaline chlorination destruction.   At one facility,
phenol wastewaters are segregated and treated with ozone before
discharge to the regular  wastewater treatment system.  Phenol
concentrations are reduced from  as high  as  30 kg/m3 to less than
5 g/m3 (4).

Ponds or Lagoons

Wastewater treatment in ponds  or lagoons is  a common practice  in
the railroad industry and, to  some degree,  in the trucking

                                 43

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industry.  It may be preceded by any one of the above described
methods although it most often follows gravity separation.  Where
practiced, ponding is ordinarily the final step in treatment.

Ponds may be used for further gravity separation, for evapora-
tion, or for aerobic digestion.  Ponds are also used simply for
equalization to eliminate slug discharges of pollutants to sur-
face waters or to treatment facilities.  The relatively long
retention times provided assist in further oil separation and
sedimentation, both of which are time dependent.  Oil-skimming
devices are used at the effluent outlet.

Evaporation ponds which have no discharge are used effectively
where the rate of evaporation exceeds the rate of precipitation
by an amount equal to or greater than the rate at which waste-
water is sent to the pond.  Evaporation ponds are inadequate if
some of the wastewater dissipates through ground seepage and
contaminates groundwaters.  Ponds have actually been designed to
leak where the soil is porous but, generally, this is not con-
sidered acceptable practice because of groundwater contamination
possibilities.

Ponds or lagoons may be used to provide for aerobic digestion of
oxygen-demanding wastes.  Atmospheric aeration may be sufficient
if the pond has a large surface area and volume compared with
waste concentration.  If atmospheric aeration is not adequate,
mechanical aeration may be used.  Ponds may also be used for
anaerobic decomposition of organic wastes, but grossly unpleasant
odors and putrid conditions frequently result.

Adequately designed ponds are capable of removing up to 95% of
oil, suspended solids, BOD, and other constituents, depending on
retention time, temperature, and treatability.  Under ideal
conditions, evaporation ponds can remove virtually 100% of all
waste materials, leaving just solids to be incinerated or land-
filled (4).

Neutralization

Neutralization, or pH adjustment to near the neutral value of
7.0, can be provided at any stage of treatment.  Some microorgan-
isms and treatment chemicals are somewhat pH sensitiver in which
case pH control becomes mandatory.  The adjustment of pH is
accomplished by the addition of either acidic or basic chemicals,
depending on the condition to be corrected.  The hauling of acids
and caustics, and the use of caustic or acid wash solutions, fre-
quently necessitate pH control, even if only to meet regulatory
limits on effluents.

Table 23 summarizes reported effluent concentrations from various
combinations of the above described systems for petroleum
                                 44

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       TABLE 23.  LOWEST EFFLUENT CONCENTRATIONS EXPECTED
                  USING VARIOUS TREATMENT PROCESS
                  COMBINATIONS FOR PETROLEUM REFINERIES (21)

Process
API separator
API separator and
clarifier
API separator and
dissolved air flotation
API separator and
granular media filter
API separator and
oxidation pond

BODs
250
45
45
40
10
Effluent concentration, g/m3
Suspended
COD solids Oil Phenol
260 50 20 6
130 25 5 10
130 25 5 10
100 563
50 20 2 0.01
     API separator and
       clarifier,
       dissolved air flotation,
       granular media filter,
       aerated lagoon

     API separator and
       trickling filter

     API separator and
       clarifier,
       dissolved air flotation,
       granular media filter,
       activated carbon
10
10
25    80    2,010
       0.5
0.1
      30
10
0.1
     Note:  Blanks indicate data not available.

refiners  (21).   Wastewater composition  could  affect the effluents
achieved.   In  general, a system which includes  gravity separa-
tion, dissolved air flotation, granular media filtration, and
activated carbon adsorption is capable  of  producing a high
quality effluent.   However, carbon treatment  is relatively costly
and is not  a cure-all for effluents.

The above treatment systems are available  to  the drum cleaning
industry, and  some companies are attempting to  use some of the
processes for wastewater treatment.  Ponds are  used by some com-
(21)  Development  Document for Proposed Effluent Limitations
     Guidelines and New Source Performance  Standards for Petro-
     leum Refineries.   Office of Enforcement  and General Counsel,
     National Field Investigations Center,  Cincinnati, Ohio, 1973.
                                 45

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panies for sedimentation before sending the effluent to a munici-
pal treatment system.  Several companies have begun using closed
systems for their washing cycles.  In such systems, suspended
solids are removed for landfilling, and the caustic liquor is
regenerated and reused for long periods.  When necessary, the
liquid can be neutralized and discharged to the municipal system.

Solid waste materials are universally either incinerated or land-
filled.  In some cases, it is possible for undesirable materials
to be landfilled in such a condition as to be hazardous because
of soil percolation.  This should be prevented by careful control
of landfill operations involving these wastes.

FUTURE CONSIDERATIONS

Air

Closed, recycled washing systems for tank cars, tank trucks, and
drums have very low, if any, air emissions.  Drum burning fur-
naces, when afterburners are operated properly, are capable of
being controlled to meet most standards.  Vapors from complete
water flushing of tank cars and tank trucks used to haul vola-
tile, combustible materials can be, and often are, sent to flares.

Open cleaning operations, such as steaming of tank cars, tank
trucks, and drums, and open air burning of drums are sources of
uncontrolled air emissions.  There are no feasible, or readily
available, control methods known for these operations at the
present time.  Converting open cleaning operations to closed-
cycle cleaning, and eliminating open air drum burning, seem to be
the only alternatives for the immediate future.

Water

Existing control technology for wastewater treatment available to
all three types of cleaning operations appears to be capable of
providing adequate control of effluents (10).  Further develop-
ment in the area of effective strains of microorganisms for
biological treatment of organic materials would be desirable.
Economic considerations are a key factor in future applications
of treatment technology.  The development of standardized,
building-block process units could lead to greater economy in
capital costs for treatment facilities.

Solid

Incineration and landfilling of solid wastes are in fairly common
usage at the present time.  When properly done, these methods may
be adequate for the future needs of tank car, tank truck, and
drum cleaning.

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                            SECTION 6

                        GROWTH POTENTIAL
At present there is no practical, economical method for effec-
tively reducing the emissions from rail tank car, tank truck, and
drum cleaning.  It is expected that the volume of chemical mater-
ials transported will increase in parallel with the increase in
chemical production.  It has been forecast that chemical produc-
tion will increase 9% in 1977, 7% in 1978, 5% in 1979, and 6% in
1980 for a total increase of 30% through 1980 (22).  Therefore,
emissions from these cleaning operations will increase by 30%
also, unless some control methods are developed.

Continued efforts by the cleaning companies to install and/or
optimize wastewater treatment systems should result in a decrease
(estimated 50%) in the amount of discharged water pollutants
through 1980.
 (22) Outlook is Optimistic for Chemicals in 1977.  Chemical and
     Engineering News, 54(48):6-7, 1976.
                                 47

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                         REFERENCES
1.  Analysis of Proposed EPA Effluent Limitations on the For-
    Hire Tank Truck Industry.  National Tank Truck Carriers,
    Inc., Washington, B.C., June 1974.  31 pp.

2.  Yearbook of Railroad Facts, 1973.  Association of American
    Railroads, Washington, D.C., 1973.

3.  Development Document for Proposed Effluent Limitations
    Guidelines and New Source Performance Standards for the
    Railroad Segment of the Transportation Industry Point
    Source Category.  Office of Enforcement and General Counsel,
    National Field Investigations Center, Cincinnati, Ohio,
    February 1975.

4.  Development Document for Proposed Effluent Limitations
    Guidelines and Source Performance Standards for the
    Trucking Segment of the Transportation Industry Point
    Source Category.  Office of Enforcement and General Counsel,
    National Field Investigations Center, Cincinnati, Ohio,
    1975.

5.  Air Pollution Engineering Manual, Second Edition,
    J. A. Danielson, ed. Publication No. AP-40, U.S. Environ-
    mental Protection Agency, Research Triangle Park,
    North Carolina, May 1973.  987 pp.

6.  Railway Age Directory of Contract Car Repair Facilities.
    Railway Age, 177(13):44-49, 1976.

7.  Final Report on Cost of Implementation and Capabilities of
    Available Technology to Comply with P.L. 92-500; Volume IV:
    Industry Categories 29-38.  Prepared for the National
    Commission on Water Quality by Battelle Columbus Labora-
    tories, Columbus, Ohio, July 3, 1975.

8.  TLVs® Threshold Limit Values for Chemical Substances and
    Physical Agents in the Workroom Environment with Intended
    Changes for 1975.  American Conference of Governmental
    Industrial Hygienists, Cincinnati, Ohio, 1975. 97 pp.
                             /
9.  Sax, N. I. Dangerous Properties of Industrial Materials,
    Third Edition.  Reinhold Book Corporation, New York,
    New York, 1968.  1251 pp.

                               48

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10.  O'Brien, J. E.  A Demonstration Plant for the Treatment of
     Waste Waters from Tank Truck Cleanings.  Presented at the
     American Institute of Chemical Engineers National Meeting,
     Atlantic City, New Jersey,  September 1, 1976.  8 pp.

11.  Compilation  of Air  Pollutant Emission Factors,  Second
     Edition.   Publication No.  AP-42,  U.S. Environmental
     Protection Agency,  Research Triangle Park,  North Carolina,
     April  1973.   p.  2.2-1.

12.  Serth,  R.  W., and T. W.  Hughes.   Source Assessment:
     Phthalic Anhydride  (Air  Emissions).  EPA-600/2-76-032d,
     U.S. Environmental  Protection Agency, Research  Triangle
     Park,  North  Carolina,  December 1976.  154  pp.

13.  Code of Federal  Regulations,  Title  42 - Public  Health,
     Chapter IV - Environmental Protection Agency, Part 410 -
     National Primary and  Secondary Ambient  Air  Quality
     Standards, April 28,  1971.  16 pp.

14.  Eimutis, E. C.,  and R.  P. Quill.  Source Assessment:   State-
     by-State Listing of Criteria Pollutant Emissions, EPA-600/
     2-77-107b,  U.S.  Environmental Protection Agency, Research
     Triangle Park, North Carolina, July 1977.  146 pp.

15.  Turner, D.  B.  Workbook of Atmospheric Dispersion Estimates
     Public Health Service Publication No. 999-AP-26, U.S.
     Department of Health,  Education, and Welfare,
     Cincinnati, Ohio, 1969.   64 pp.

16.  Decision Criteria for Water Discharges.   Draft prepared for
     EPA review under Contract 68-02-1874 by  Monsanto Research
     Corporation,  Dayton, Ohio,  1976.   4 pp.

17.  Eimutis, E. C.,  T. J.  Hoogheem, and T. W. Hughes.  Briefing
     Document:   Water Source Severity and Initial Water
     Prioritization Structures.  Draft prepared  under EPA
     Contract 68-02-1874  by Monsanto Research Corporation,
     Dayton, Ohio, September 21, 1976.  12 pp.

18.  Quality Criteria for Water.  EPA-440/9-76-023, U.S.
     Environmental Protection Agency,  Washington, D.C.  501  pp.

19.  Manual  on  Disposal of  Refinery Wastes.   American Petroleum
     Institute,  Washington,  D.C., 1969.

20.  Process Design Manual  for Upgrading Existing Waste Water
     Treatment  Plants.  Contract 14-12-933, U.S.  Environmental
     Protection  Agency, October 1971.
                                49

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21.   Development Document for Proposed Effluent Limitations
     Guidelines and New Source Performance Standards for
     Petroleum Refineries.   Office of Enforcement and General
     Counsel,  National Field Investigations Center,
     Cincinnati, Ohio, 1973.

22.   Outlook is Optimistic for Chemicals in 1977.  Chemical and
     Engineering News, 54(48) :6-7, 1976.
                              50

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                           APPENDIX A



               ESTIMATES OF DRUM BURNING EMISSIONS
PARTICULATES
The particulate emission factor for auto incineration is

0.68 kg/car, based on 112 kg of combustible material  (CM) on a

stripped car body  (11) .



Assuming 2 kg of combustible material per drum gives:



               E  = 0-68 kg t    car    . 2 kg CM

                p     car   * 112 kg CM *   drum



                  = 0.012 kg/drum



A large representative plant cleans 400,000 drums/yr of which

65% are burned.  Thus, 260,000 drums/yr are burned, and assuming

260 days/yr of operation, 24 hr/day gives:
Therefore,
                  Q  = 0.012 -2- . 0.012
                        .    --    .
                   p         drum          s



                     = 0.00014 kg/s or 0.14 g/s



where  Q  = mass particulate emission rate, g/s




NITROGEN OXIDES  (NO )
                   X


Following the same logic as above:
        = o 01 -. • , , 0   _  - 2kg_CM =       1Q-, k /drum

    iNO         car   112 kg CM    drum                 y/
      J^.


A large representative plant burns 0.012 drum/s; therefore



            Q Q  = 1.8 x I0~k kg/drum • 0.012 drum/s
= 2.2 x 10~6 kg/s or 2.2 x 10~3 g/




               51
                                                    s

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DERIVATION OF REPRESENTATIVE DRUM CLEANING PLANTS

There are two types of plants:  those which wash and burn drums
clean and those which only wash drums clean.  Using NBADA data on
drums burned and washed  (Table 11), the average size of the two
types of plants can be derived.

There are 9,090,000 drums burned clean at 35 facilities, for an
average of 2-60,000 drums per facility.  Assuming that 65% of the
drums handled by these facilities require burning and that the
remaining 35% can be cleaned by washing, the average facility
handles 400,000 drums per year.  The remaining 98 facilities wash
drums only and handle the remaining 8,200,000 drums per year.

The facilities which wash clean only are much smaller with an
average of 84,000 drums per year for NBADA members.  A representa-
tive plant which washes only would be even smaller if the total
number of facilities were considered.  For purposes of this
report, the larger size is chosen.  Thus, the representative
plants are:

             Burning and washing - 400,000 drums/yr
             Washing only     ,   -  84,000 drums/yr

ESTIMATION OF DRUM CLEANING EFFLUENTS

Using tank truck cleaning effluent data, drum cleaning was esti-
mated as follows.  For 30 tank trucks per day, 45.4 m3/day
(12,000 gal/day) of effluent are produced when removing 100 kg of
material per truck.  For oil and grease, this gives 230 g/m3 in
the effluent, or 10.4 kg/day.  This is 3.48 g of oil and grease
per kilogram of material removed.  Since each drum contains 2 kg
of waste, the oil and grease are estimated as 6.96 g per drum
washed.  For the representative plants, this means:

           35% of Type a plants - 0.97 metric tons/yr
          100% of Type b plants - 0.585 metric tons/yr

Assuming 260 days of operation per year gives:

                   Type a plant - 3.75 kg/day
                   Type b plant - 2.25 kg/day

Estimated flow rates (from plant personnel) of 25 m3/day
(6,600 gal/day) and 15 m3/day  (4,000 gal/day) for Type a and
Type b plants, respectively, gives effluent concentrations as
follows:

                     Type a plant - 148 g/m3
                     Type b plant - 148 g/m3

Other effluents are calculated in a similar manner.


                               52

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                           APPENDIX B

       DEFINITION OF SOURCE SEVERITY FOR WATER DISCHARGES
     AND CALCULATION OF RIVER OR END-OF-PIPE CONCENTRATIONS


Source severity is defined as the pollutant concentration to
which aquatic life is exposed divided by an acceptable concen-
tration.  The "exposure" concentration is the fully diluted
receiving water concentration resulting from the effluent of
the specific discharge of concern.  The "acceptable" concentra-
tion (F) is defined as that concentration at which it is assumed
that an incipient adverse environmental impact occurs.  For most
pollutants, it is the water quality criteria.  For pollutants
without water quality criteria, F is the lowest value of the
following concentrations:
0.01 LCso (LCso is the lethal concentration of a pollutant to
           50% of an aquatic life exposed to the pollutant)

0.00225 LD50  (LD50 is the lethal dose of a pollutant to 50% of
              a male rat population)

Mathematically, source severity  (S) is:


                          s _(VVR CD)
                          b "    F

where  V^, V_, = volume of discharge and river flow, respectively
        D   R
           C  = concentration of discharge

            F = acceptable concentration as defined above

The oxygen source severity is defined as the maximum mass of
oxygen that can potentially be consumed by a specific discharge
divided by the mass of oxygen in the receiving water that can
be consumed without exceeding the minimum "water quality criteria
for dissolved oxygen.  The maximum mass of oxygen potentially
consumable by the discharge is defined as the total oxygen
demand (TOD) concentration multiplied by the discharge flow
rate.  The "allowable" mass is defined as the receiving water
volumetric flow rate of mixing zone volume multiplied by the
difference between the saturation concentration  (Cg) at 10 °C
and the minimum water quality criteria for dissolved oxygen
                                53

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Hence, the source severity can be defined mathematically as:
                               ^ITOD
                       s =
                            CS - D°(WQC)

The receiving water is assumed to be initially at saturation and
the discharge is assumed to be fully diluted and mixed upon enter-
ing the receiving water.  It is also assumed that all of the
total oxygen demand occurs instantaneously with no reaearation of
the receiving body of water.

If it is desired to evaluate the severity at any other river flow
rate, severity can be calculated as follows:
                          So = S
where        Sj = standard source severity as shown in Table 19
             82 = source severity at river flow rate, V^
       VR   VR  = river flow rates corresponding to the 2
         lf   2   source severities S\ and 82, respectively

In addition, the concentration expected in the river can be
determined by multiplying the source severity and the hazard
factor (Table 18).  The concentration expected from the discharge,
CD (no dilution in the river, can be calculated using the follow-
ing set of equations:
                            CD = SD F
where
and   S = severity from Table 19

     V0 = river flow in Equation 3, 856 m3/s
      R                »
     V  = volumetric discharge, m3/s

      F = hazard factor from Table 18
                               54

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                            GLOSSARY

affected population:  Number of nonplant persons exposed to
     concentrations of airborne materials which are present in
     concentrations greater than a determined hazard potential
     factor.

biochemical oxygen demand:  A measure of the amount of oxygen
     consumed in the biological processes that break down organic
     matter in water.

chemical oxygen demand:  A measure of the amount of oxygen
     required to oxidize organic and oxidizable inorganic
     compounds in water.

criteria pollutants:  Emission species for which ambient air
     quality standards have been established; these include
     particulates, sulfur oxides, nitrogen oxides, carbon
     monoxide, and nonmethane hydrocarbons.

dedicated:  Type of car, truck or drum used for carrying one
     commodity only and, unless contaminated, cleaned only prior
     to repair or testing.

emulsion:  A heterogeneous liquid mixture not normally miscible,
     held in suspension by agitation or certain additives.

hazard factor:  The ambient air quality standard of a criteria
     pollutant or a "corrected" TLV for noncriteria pollutants.

national emissions burden:  The total quantity of specific
     pollutants generated in the U.S.

noncriteria pollutants:  Emission species for which no ambient
     air quality standards have been established.

nondedicated:  Type of car, truck or drum which is cleaned after
     every use to prevent cross contamination.

pollutant:  Any introduced gas, liquid, or solid that makes a
     resource unfit for a specific purpose.

representative source:  A source whose performance characteris-
     tics are representative of those of a large number of actual
     sources of similar type and function.
                                55

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source severity:  An indication of the hazard potential of a
     pollution source.
                                                                 i
state emission burden:  The total quantity of specific pollutants
     generated in a specific state.

threshold limit value:  Airborne concentrations of substances
     that represent conditions under which it is believed that
     nearly all workers may be repeatedly exposed day after day
     without adverse effect.

total oxygen demand:  A quantitative measure of all oxidizable
     material in water or wastewater as determined by measuring
     the depletion of oxygen in a known gas stream.

turbidity:  A cloudy condition in water due to the suspension of
     silt or finely divided organic matter.

water quality criteria:  The level of pollutants that affect the
     suitability of water for a given use.

water quality standard:  A plan for water quality management
     containing four major elements:  the use to be made of the
     water; criteria to protect those uses; implementation plans
     and enforcement plans; and an antidegradation statement to
     protect existing high quality waters.

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                         .„  ,   TECHNICAL REPORT DATA
                         (flease read Instructions on the rtvtnt btfore completing)
 . REPORT NO.   f
  EPA-600/2-78-004g
4. TITLE AND SUBTITLE
  SOURCE ASSESSMENT:  RAIL TANK CAR,  TANK TRUCK,
  AND DRUM CLEANING, State of the Art
            3. RECIPIENT'S ACCESSION NO.
            6. REPORT DATE
             .April 1978 issuing date
           0. PERFORMING ORGANIZATION CODE
 7. AUTHORIS)                  '       '	—	
  D. E. Barley,  K. M. Tackett and T.  R.  Blackwood
           a. PERFORMING ORGANIZATION REPORT NO.
               MRC-DA-713
9. PERFORMING ORGANIZATION NAME AND ADDRESS
  Monsanto  Research Corporation
  1515 Nicholas Road
  Dayton., Ohio  45407
            10. PROGRAM ELEMENT NO.
                1AB604
            11. CONTRACT/GRANT NO.
             68-02-1874
 13. SPONSORING AGENCV NAME AND ADDRESS
  Industrial Environmental  Research Laboratory-cin.,  OH
  Office  of Research and Development
  U.S. Environmental Protection Agency
  Cincinnati. Ohio 45268	;	
            13. TYPE OF REPORT AND PERIOD COVERED
            Task Final  8/76-9/77
            14. SPONSORING AGENCV CODE
                        EPA/600/12
 15. SUPPLEMENTARY NOTES
  IERL-Ci project leader  for this report  is R. J. Turner,  513-684-4481.
 16. ABSTRACT                   _          	__________________________________
  This document reviews  the state of the  art of air emissions and water
  pollutants  from cleaning rail tank cars,  tank trucks,  and drums.  Compo-
  sition, quantity, and  rate of emissions and pollutants are described.
  Rail tank cars, tank trucks, and  drums  are used to transport chemical  and
  petroleum commodities  from producer  to  consumer.  Steaming, washing  and/or
  flushing of such units result in  air emissions and wastewater effluents.
  Air emissions are predominantly organic chemical vapors.   Water pollut-
  ants common to these operations are  primarily oil and  grease, COD, BOD,
  suspended solids and many other organic and inorganic  materials.
  Representative sources were defined  in  order to evaluate  the hazard  poten-
  tial.  Source severity was defined and  evaluated for air  emissions and
  for wastewater effluents.   Control methods used to reduce emissions  from
  rail tank car and tank truck cleaning consist only of  flaring flushed
  gases.  By  EPA estimates,  two-thirds of the tank truck industry dis-
  charges into municipal systems with  little or no pretreatment.  This
  treatment has generally been limited to sedimentation,  neutralization,
  evaporation ponds, and lagoons.
17.
                            KEY WORDS AND DOCUMENT ANALYSIS
                DESCRIPTORS
  Air Pollution
  Water Pollution
  Assessments
                                         b.lDENTIFIERS/OPEN ENDED TERMS
Air  Pollution Control
Water Pollution
   Control
Source Assessment
                         COSATi Field/Group
68A
 8. DISTRIBUTION STATEMENT

    Release  to Public
19. SECURITY CLASS IThti Report/
    Unclassified
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20. SECURITY CLASS (This page I
    Unclassified
                        22. PRICE
EPA Form 2*20-1 (t-73)
                                        57
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