United States
Environmental Protection
Agency
Office of Water &
Waste Management
Washington DC 20460
SW-170C
March 1979
xvEPA
Characterization of
Hazardous Waste
Transportation and
Economic Impact
Assessment of
Hazardous Waste
Transportation
Regulations
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Prepublication issue for EPA libraries f
State solid waste management agencies,
and GPO depository libraries
CHARACTERIZATION OF HAZARDOUS WASTE TRANSPORTATION
AND ECONOMIC IMPACT ASSESSMENT
OF HAZARDOUS WASTE TRANSPORTATION REGULATIONS
This report (SW-l?Qe) describes work performed
for the Office of Solid Waste under contract no. 68-01-4381
and is reproduced as received from the contractor.
The findings should be attributed to the contractor
and not to the Office of Solid Waste.
Copies will be available from the
National Technical Information Service
U.S. Department of Commerce
Springfield, VA 22161
U.S. ENVIRONMENTAL PROTECTION AGENCY
1979
-------
This report was prepared by Arthur D. Little, Inc., Cambridge,
Massachusetts, under contract no. 68-01-4381.
Publication does not signify that-the contents necessarily reflect the
views and policies of the U.S. Environmental Protection Agency, nor does
mention of commercial products constitute endorsement by the U.S. Govern-
ment.
An environmental protection publication (SW-170c) in the solid waste
management series.
ii
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ACKNOWLEDGEMENTS
The Arthur D. Little, Inc. (ADL) Project Director for this study was
George H. Harris. The economic impact assessment effort was conducted by
Louise M. Firth. Key technical contributors were Nancy J. Cunningham,
Joan B. Berkowitz, Anne L. Milewski, Thomas V. Renda, Donald B. Rosenfield,
and Melba G. Wood.
Harry W. Trask was the Project Officer for the U.S. Environmental
Protection Agency, Hazardous Waste Management Division, Office of Solid
Waste; the economic impact work was monitored by Michael Shannon. Special
appreciation is extended to Arnold M. Edelman of the EPA for his valuable
contributions to the transportation characterization portion of this study.
iii
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TABLE OF CONTENTS
Page
I. EXECUTIVE SUMMARY 1-1
A. PURPOSE AND SCOPE 1-1
B. SUMMARY OF MAJOR FINDINGS 1-1
C. DETAILED FINDINGS 1-12
II. INTRODUCTION II-l
A. OBJECTIVES II 1
B. SCOPE OF WORK II-2
C. INFORMATION ACQUISITION II-3
D. REGULATORY CONTROL II-8
E. INSURANCE COVERAGE 11-12
F. LIMITS OF ANALYSIS 11-18
G. SOME DEFINITIONS AND DISTINCTIONS II--20
H. ORGANIZATION OF REPORT 11-21
III. FOR-HIRE TRANSPORT III-l
A. TRANSPORT BY RAIL CARRIER III-l
1. METHOD OF APPROACH III-l
2. FACILITIES AND SERVICES PROVIDED III-2
3. TRANSPORTATION ACTIVITIES II1-4
4. BUSINESS/ADMINISTRATIVE PRACTICES 111-13
5. REGULATORY CONTROL 111-16
6. SOME REGULATORY COMPLIANCE PROBLEM AREAS 111-17
B. TRANSPORT BY MOTOR CARRIER (FOR-HIRE) 111-21
1. METHOD OF APPROACH 111-21
2. FACILITIES AND SERVICES PROVIDED 111-23
3. TRANSPORTATION ACTIVITIES 111-27
4. BUSINESS/ADMINISTRATIVE PRACTICES 111-35
5. REGULATORY CONTROL 111-39
C. TRANSPORT BY WATER CARRIER 111-41
1. METHOD OF APPROACH 111-41
2. FACILITIES AND SERVICES PROVIDED 111-42
3. TRANSPORTATION ACTIVITIES 111-43
iv
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TABLE OF CONTENTS (Cont.)
4. BUSINESS/ADMINISTRATIVE PRACTICES
5. CASE EXAMPLES
D. TRANSPORT BY AIR
1. METHOD OF APPROACH
2. FACILITIES AND SERVICES PROVIDED
3. TRANSPORTATION ACTIVITIES
4. REGULATIONS AND PRACTICES
5. PROBLEM AREAS
E. TRANSPORT BY PIPELINE
1. METHOD OF APPROACH
2. FACILITIES
a. TRANSPORTATION ACTIVITIES
4. REGULATORY CONTROL AND PRACTICES
IV. OFF-SITE TRANSPORT BY GENERATORS
A. METHOD OF APPROACH
B. INDUSTRIES THAT SELF-HAUL
C. TRANSPORTATION ACTIVITIES
D. BUSINESS/ADMINISTRATIVE PRACTICES
E. REGULATORY CONTROL
V. TRANSPORT BY OPERATORS OF HAZARDOUS WASTE MANAGEMENT
FACILITIES
A. METHOD OF APPROACH
B. FACILITIES AND SERVICES PROVIDED
C. TRANSPORTATION ACTIVITIES
D. BUSINESS/ADMINISTRATIVE PRACTICES
E. REGULATORY CONTROL
VI. ECONOMIC DESCRIPTION OF HAZARDOUS WASTE TRANSPORT
A. INTRODUCTION
B. ECONOMIC CHARACTERISTICS OF FIRMS ENGAGED IN TRANSPORT
C. ECONOMIC CHARACTERIZATION OF HAZARDOUS WASTE
TRANSPORTATION
111-46
111-54
111-57
111-57
111-58
111-58
111-59
111-62
111-64
111-64
111-64
III-66
111-68
IV-1
IV-1
IV-3
IV-6
IV-15
IV-18
V-l
V-l
V-2
V-4
V-9
V-ll
VI-1
VI-1
VI-3
VI-11
v
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TABLE OF CONTENTS (Cont.)
VII. COST OF COMPLIANCE WITH RCRA SECTION 3003
A. PROCESS ECONOMIC MODELS
B. TRANSPORTATION MODELS
C. COMPLIANCE ACTIVITIES REQUIRED UNDER SECTION 3003
D. COST OF COMPLIANCE
E. SUMMARY OF COMPLIANCE COSTS
VIII. ECONOMIC IMPACT OF RCRA SECTION 3003
A. APPROACH
B. FINANCIAL MODELS
C. DIRECT IMPACT—VEHICLE MODELS
D. DIRECT IMPACT—COMPANY MODELS
Page
VII-1
VII-1
VII-3
VII-9
VII-11
VII-17
VIII-1
VIII-1
VIII-2
VII1-4
VIII-6
APPENDIX A STANDARDS APPLICABLE TO TRANSPORTERS OF HAZARDOUS
WASTE
APPENDIX B ORGANIZATIONS FURNISHING INFORMATION
B-l RAIL CARRIER
B-2 MOTOR CARRIER
B-3 WATER CARRIER
B-4 AIR CARRIER
B-5 PIPELINE
B-6 GENERATORS
B-7 HAZARDOUS WASTE MANAGEMENT FACILITIES
APPENDIX C ILLUSTRATIONS OF TRANSPORT VEHICLES
APPENDIX D SAMPLE SHIPPING DOCUMENTS
APPENDIX E RAIL TRANSPORT OF HAZARDOUS WASTE
APPENDIX F FLOW OF FUNDS MODEL
APPENDIX G REFERENCES
APPENDIX H GLOSSARY OF TERMS
LIST OF TABLES
LIST OF FIGURES
A-l
B-l
B-2
B-3
B-5
B-6
B-7
B-8
B-9
C-l
D-l
E-l
F-l
G-l
H-l
vii
viii
vi
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LIST OF TABLES
No.. Page
1-1 ESTIMATED AMOUNT OF HAZARDOUS WASTE TRANSPORTED BY
MODE, 1977 1-3
1-2 ESTIMATED AMOUNT OF HAZARDOUS WASTE TRANSPORTED BY MODE
AND SEGMENT, 1977 1-4
1-3 SUMMARY OF COMPLIANCE COSTS WITH RCRA SECTION 3003 FOR
TRUCK TRANSPORT 1-7
1-4 IMPACT OF RCRA SECTION 3003 REGULATIONS UPON OPERATING
COSTS 1-10
1-5 REQUIRED INCREASE IN REVENUE TO RECOVER COSTS OF COMPLIANCE
WITH RCRA SECTION 3003 1-11
II-l NATIONAL ASSOCIATIONS CONTACTED II-5
II-2 U.S. GOVERMENT AGENCIES CONTACTED I1-5
II-3 ICC AND DOT REGULATORY AUTHORITY FOR INTERSTATE TRANSPORT
OF HAZARDOUS WASTE 11-11
II-4 SUMMARY OF INSURANCE COVERAGE AVAILABLE FOR HAZARDOUS WASTE 11-13
III-l WASTES LISTED IN THE HAZARDOUS MATERIALS TABLE
(49 CFR 172.101) Hl-5
III-2 ESTIMATED ANNUAL VOLUME OF SELECTED HAZARDOUS WASTES
SHIPPED ON AMERICAN RAILROADS—1976 III-6
III-3 INVENTORY OF RAILROAD EQUIPMENT IN UNITED STATES—1976 111-10
III-4 SHIPPING AND AGENCY DOCUMENTS TO BE PRESERVED (49 CFR 1220) 111-18
III-5 COMMODITY CLASSIFICATION FOR TRANSPORTATION STATISTICS
(49 CFR 1248.100) 111-19
III-6 FLEET SIZE DISTRIBUTION—FOR-HIRE MOTOR CARRIERS 111-25
III-7 COMMODITY CLASSIFICATION FOR DOMESTIC WATERBORNE
COMMERCE GROUP 40 - WASTE AND SCRAP MATERIALS 111-53
IV-1 SOURCES OF HAZARDOUS WASTE TRANSPORTED OFF-SITE IV-4
IV-2 TYPES OF VEHICLES USED BY GENERATORS WHO SELF-HAUL WASTES IV-11
IV-3 STORAGE PRACTICE IN SELECTED INDUSTRY SITUATIONS IV-17
V-l DISTRIBUTION OF HWMF/TRANSPORTERS SUPPLYING INFORMATION V-3
V-2 NUMBER OF MOTOR VEHICLES OPERATED BY HWMF/TRANSPORTERS V-5
V-3 NUMBER OF HWMF/TRANSPORTER EMPLOYEES INVOLVED IN
TRANSPORTATION V-5
V-4 MOTOR VEHICLE AGE DISTRIBUTION FOR HWMF/TRANSPORTERS V-6
V-5 DISTRIBUTION OF MOTOR VEHICLE TYPES FOR HWMF/TRANSPORTERS V-7
VI-1 TOTAL COST OF HAZARDOUS WASTE TRANSPORT TO SELECTED
GENERATING INDUSTRIES VI-4
vii
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LIST OF TABLES (Cont.)
No. Page
VI-2 DISTRIBUTION OF HAZARDOUS WASTE MANAGEMENT COMPANIES
BY SALES VOLUME—1975 VI-6
VI-3 FINANCIAL PROFILE OF HAZARDOUS WASTE MANAGEMENT FACILITIES
ALSO ENGAGED IN TRANSPORTATION VI~7
VI-4 FINANCIAL PROFILE OF FOR-HIRE TRANSPORTERS OF HAZARDOUS
WASTE VI-10
VII-1 HAZARDOUS WASTE TRANSPORTATION VEHICLE SCENARIO MODELS VII-4
VII-2 ADDITIONAL TRANSPORTATION EQUIPMENT COSTS VII-6
VII-3 HAZARDOUS MATERIALS INCIDENT REPORTS-REPORTING CARRIERS
AND REPORTS SUBMITTED VII-14
VII-4 TABULATION OF PROPERTY DAMAGE FIGURES EXCERPTED FROM
32,000 HAZARDOUS MATERIALS INCIDENT REPORTS RECEIVED
FROM 1971 THROUGH 1975 VII-15
VII-5 LAND SPILL RESPONSE COSTS FOR 4,000-GALLON SPILL VII-16
VII-6 SUMMARY OF COMPLIANCE COSTS WITH RCRA SECTION 3003 FOR
TRUCK TRANSPORT VII-18
VIII-1 IMPACT OF RCRA SECTION 3003 REGULATIONS ON RAIL CAR
OPERATING COSTS VIII-5
VIII-2 IMPACT OF RCRA SECTION 3003 REGULATIONS ON TRUCK
OPERATING COSTS VIII-6
VIII-3 REQUIRED INCREASE IN REVENUE TO RECOVER COSTS OF COMPLIANCE
WITH RCRA SECTION 3003 VIII-8
VI-1
FIGURE
AVERAGE COST FOR HAZARDOUS WASTE DISPOSAL AT SECURE
LANDFILLS
VI-12
viii
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I. EXECUTIVE SUMMARY
A. PURPOSE AND SCOPE
Section 3003 (42 USC 6923) under Subtitle C of the Resource Conserva-
' P
tion and Recovery Act of 1976 (RCRA) requires that the Environmental
Protection Agency promulgate standards applicable to transporters of
hazardous waste as may be necessary to protect human health and the en-
vironment. In recognition of the need for the development of Section
3003 standards, it is the purpose of this report to:
• Characterize the facilities, transportation activities,
business/administrative practices, regulatory environment,
and financial and economic structure of transporters of
hazardous waste in the United States; and
• Assess the costs of compliance with and economic impact
of EPA-proposed hazardous waste transportation regulations.
Such transportation is normally required to convey hazardous wastes
from the generator of these wastes to an off-premises waste facility for
treatment, storage, and/or disposal.
This report focuses on aspects of hazardous waste transportation
related to the four basic requirements under Section 3003, namely:
1) recordkeeping concerning such hazardous wastes transported, and their
source and delivery points; 2) transportation of such wastes only if
properly labeled; 3) compliance with the manifest system developed under
Section 3002 of the Act; and 4) transportation of all hazardous wastes
only to the hazardous waste management facilities which the shipper
designates on the manifest form to be a facility holding a permit issued
in accordance with Section 3005 of the Act.
B. SUMMARY OF MAJOR FINDINGS
1. Transporter Segments
Although transporters of hazardous waste do not constitute an
industry in the usual meaning of the term, three distinct participants
or segments have been identified:
1-1
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• Generator/transporter—generators, including industrial,
commercial, and governmental organizations, that act as
private carriers and self-haul hazardous wastes, invariably
by truck, to off-site hazardous waste management facilities.
• For-hire transporter—common and contract carriers, whose
principal business is commodity and/or waste transportation,
that transport hazardous waste from the point of generation
to off-site hazardous waste management facilities which they
do not also operate.
*
• Hazardous waste management facility/transporter —operators
of hazardous waste management facilities that act as contract
or private carriers in transporting hazardous waste from the
point of generation to treatment, storage, or disposal
facilities.
The vast majority of hazardous waste transport is by motor truck,
with rail a distant second. The distribution of hazardous waste
transport by mode appears in Table 1-1, where it is seen that air
and pipeline transport are negligible. This basic information is
shown in somewhat more detail in Table 1-2. The generator/trans-
porter trucks about 2-3 percent of all hazardous wastes that are
transported off-site. It has not been possible in this study to
determine separately the amounts of hazardous waste transported
by for-hire motor carriers or HWMF/transporters. From Table 1-2
it can be seen that both the generator/transporter and HWMF/
transporter engage solely in trucking. The focus of attention,
then, is on railroad and motor carrier operations of the three
segments.
2. Insurance Coverage
Railroads generally carry $25-50 million in third-party property
damage with large deductibles ($1-2 million). As a whole, railroads
would appear to have sufficient financial resources to meet their
* ,
Referred to as HWMF/transporter.
1-2
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TABLE 1-1
ESTIMATED AMOUNT OF HAZARDOUS WASTE
TRANSPORTED BY MODE, 1977
Hazardous Waste Percent of Total
Transport Transported Hazardous Waste
Mode (Metric Tons) Transported
Rail 400,000 5
Highway 7,400,000 94
Waterway 100,000 1
Air Negligible Negligible
Pipeline Negligible Negligible
Total 7,900,000 100
SOURCE: Arthur D. Little, Inc., estimates.
1-3
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TABLE 1-2
T
Transport
Mode
Rail
Highway
Waterway
(%)
ESTIMATED
TRANSPORTED
Generator/
Transporter
0
160,000
(2)
0
AMOUNT OF HAZARDOUS WASTE
BY MODE AND SEGMENT, 1977.
(Metric Tons)
For-Hire HWMF/
Transporter Transporter
400,000 0
(5)
? ?
100,000 0
(1)
A11 a
Segments
400,000
(5)
7,400,000
(94)
100,000
(1)
Air
Negligible
Negligible
Pipeline
Negligible
Negligible Negligible
All Modes
160,000
(2)
7,900,000
(100)
Table 1-1
SOURCE: Arthur D. Little, Inc., estimates,
1-4
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responsibilities stemming from spills of hazardous waste. The same
is true for the major generators of hazardous wastes that self-haul
off-site, as well as for the large national common motor carriers
that haul hazardous materials and wastes.
Most states have enacted financial responsibility laws for owners
of motor vehicles, although some states require no coverage. Typically,
the highly industrialized states require $100,000 in coverage for
bodily injury or death of one person, $300,000 for bodily injury or
death of more than one person, and $50,000 for property damage to
others. A few states have recently made special provision for trans-
porters of hazardous materials. Motor vehicle liability coverage
specifically extends to injury and damages attributable to accidental
loss of cargo. However, smaller firms transporting hazardous materials
and/or wastes and others with blemished safety records, are at a sig-
nificant disadvantage in obtaining sufficient liability coverage.
Insurance companies express great concern about the general problem
of providing adequate coverage for spills of hazardous materials and
wastes, particularly where cleanup of the environment would be a
covered expense. Coverage of hazardous material and hazardous waste
spills is currently undergoing change within the insurance industry.
3. Regulatory Control
All transporters engaged in interstate commerce involving
hazardous materials are subject to regulations promulgated by the U.S.
Department of Transportation. Most hazardous wastes in interstate
commerce, but by no means all, accordingly are regulated by the DOT.
Because a substantial but unknown portion of hazardous waste is
transported intrastate, the operations of these intrastate trans-
porters are governed only by existing state regulations, which vary
appreciably from state to state. Although all transporters of
hazardous waste contacted in this study claim to abide by existing
Federal and state regulations, it was not possible to verify these
claims of compliance. Furthermore, no effort was made in this study
to examine the enforcement policies and practices of Federal and
1-5
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state authorities. The greatest opportunity for violation of
existing regulations applies to motor carriers because of their
diverse operations, large number of vehicles in operation, and
overall lower visibility, than, say, railroads or airlines.
The transportation of property by carriers engaged in inter-
state or foreign commerce is subject to regulation by the Interstate
Commerce Commission. The Commission has recently ruled to the effect
that hazardous waste intended for disposal does not constitute
"property" and, therefore, does not come under its jurisdiction.
The effect of this ruling would appear essentially to minimize the
role of the Commission insofar as ensuring the safe transport of
hazardous waste.
4. Costs of Compliance
a. Motor Carrier
The costs of compliance for five truck transporter
models are shown in Table 1-3. Recordkeeping requirements
appear here as a fixed charge per truck, although Model 3 may
have slightly lower costs due to fewer trips. Recordkeeping
associated with the manifest requirements vary with the num-
ber of trips and additional driver time required. Thus the
cost per truck is lower for Models 1, 2 and 3, which make two
trips per day in their respective transportation scenarios,
than for Models 4 and 5 where driver time is required to
comply.
Registration cost was estimated at $24 for each hazardous
waste transport company during the first year. Marking will
also require an expenditure of $24 for each truck in the first
year (assuming that trucks are not currently marked). To be
conservative a cost of $48 per truck was used for registration
and marking combined. The cost of spill cleanup, $1320, was based
on an EPA study of all spilled hazardous materials. The per truck
spill frequency for hazardous waste transporters is unknown and thus
1-6
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TABLE 1-3
SUMMARY OF COMPLIANCE COSTS
WITH RCRA SECTION 3003 FOR
TRUCK TRANSPORT
H
-J
Truck Model
Model la
Model 2b
Model 3°
Model 4d
Model 5e
Registration
$24
24
24
24
24
Recordkeeping
$ 116/year
116 /year
116 /year
116/year
116/year
Manifest
System
$ 250/year
250/year
125 /year
1,452 /year
1,452/year
Marking
$24
24
24
24
24
Total Costs
First Year
$ 414
414
289
1,616
1,616
Recurring
$ 366
366
241
1,568
1,568
Spill Cleanup: $1,320
SOURCE: Arthur D. Little, Inc., estimates.
aThree-axle, power unit tractor; unlined aluminum tank unit (4,500 gal;; 190,000 ton-mi./yr; 2 trips/day.
Two-axle, power unit tractor; unlined aluminum tank unit (1,600 gal.); 26,250 ton-mi./yr.; 3 trips/day.
Semi-tank, three-axle power unit trailer; unlined aluminum tank unit (6,000 gal.); 625,000 ton-mi./yr.;
1 trip/day.
dTilt-frame with 40-foot roll-off container (80 55-gal. dmims), three axle power unit tractor; 225,000 ton-mi./yr.
2 trips/day. "
Straight ;truck with 20-foot bed (3U 55-gal. drums); 50,000 ton-mi./yr.; 2 trips/day.
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the cost of spill cleanup is shown separately.
b^ Rail Carrier
For rail transport, existing bills of lading can be used to meet
manifest system requirements. However, additional recordkeeping
might be required and therefore the impact of an additional expense
of $116 per car per year and $2.00 per trip was evaluated.
c. Water Carrier
There are no additional compliance activities imposed on water
transport as a result of Section 3003 provided that the current
shipping papers or dangerous cargo manifests can be used and no ad-
ditional recordkeeping or reporting requirements are necessary be-
yond those which currently exist.
d. Other Modes (Air and Pipeline)
The costs of compliance for other modes of transportation are
negligible.
5. Economic Impact Assessment
The impact of Section 3003 on transporters of hazardous waste was
svaluated both for a set of individual transport vehicles and for com-
posite companies representative of a-for-hire transporter and a hazardous
waste management facility. The impact on-generators was estimated by
calculated the total cost impact.
a. Impact on Vehicle Operating Cost
(1) Truck Transport
The increase in operating cost as a consequence of Section 3003,
shown in Table 1-4, will be greatest for transportation of drummed
waste and other waste that the truck operator must manually handle
during loading and unloading operations. This is due to the alloca-
tion of additional truck driver's time to have the manifest signed.
The increase is greater for truck Model 5 than for truck Model 4,
1-8
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because Model 5 has fewer ton-miles per year. Likewise, the impact
on truck Model 3 is the least because it represents a high annual
mileage, long-trip distance scenario. This is the expected result
singe costs of compliance vary with the number of trips.
The cost of S0111 cleanup used here amounts to 3.2-4.7 percent
of annual operating cost, and the total cost of spill cleanup is
estimated at $281,000 based upon some 213 spills per year.
(2) Rail Transport
The direct impact of compliance activities is shown in Table
1-4, which presents the discounted cost of owning and paying fares
for rail cars over twelve years to transport spent sulfuric acid on
a high-volume route (Model 2), and a low-volume route (Model 1), and
all routes nationally. Leased car and purchased car alternatives are
presented. For rail transport the cost of compliance represents a
very small increase in operating costs, with a maximum 0.8 percent
increase in the twelve-year costs due to compliance.
b. Impact on Companies
Two company financial models, one for a for-hire transporter and
one for a waste management facility also engaged in transportation,
were analyzed to determine the impact of the cost of compliance
with Section 3003. These impacts were then translated into cost
impacts on generator industries. Results appear in Table 1-5.
(1) For-Hire Transportation Company
In the absence of a price increase, profitability would decline
by 9 percent. However, an increase in revenue of 2.6 percent over-
all is needed to maintain the same rate-of-return. The impact of
compliance upon the transportation company, assuming a balanced mix-
ture of vehicle types, is between that for the high-impat and low-
impact models.
1-9
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TABU: i-4
I
M
O
IMPACT OF RCRA SECTION 3003
Truck Cost of
Transport First
Models # Trips/Day Year
1 2 $ 414
2 2 414
3 1 289
4 2 1,616
5 2 1,616
Bail Car
Model 1
Leased Car
Purchased Car
Model 2
Leased Car
Purchased Car
National Total
Leased Car
Purchased Car
REGULATIONS UPON OPERATING
A. TRUCK TRANSPORT
Compliance
Subsequent Annual
Years Operating Costs
$ 390 $32,500
390 28,375
215 41,500
1,640 34,000
1,640 29,625
B. RAIL TRANSPORT
Cost of
Before
Compliance
$ 84,600
90,000
771,300
819,000
5,545,000
5,703,000
COSTS
% of
Operating Costs
First Recurring
Year Years
1.3% 1.2%
1.5 1.4
0.7 0.6
4.9 4.8
5.6 5.5
Lifetime Operation
Spill
%
Cost
$1,320
1,320
1,320
1,320
1,320
Cleanup
Operating
Costs
4.1%
4.7
3.2
3.9
4.5
After
Compliance % Change
$ 85,000 0,
90,400 0
776,000 0
824,700 0
5,590,000 Q
5,590,000 0
.5
.4
.6
.6
.8
.8
Source: Arthur D. Little, Inc., estimates.
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TABLE 1-5
REQUIRED INCREASE IN REVENUE
TO RECOVER COSTS OF COMPLIANCE WITH RCRA SECTION 3003
For-hire
Transportation Company
Number of
Vehicles
14
Baseline
Revenue
$ 670,292
ROCC
6.7
Required Increase
in Revenue
$ % Change
$17,642 2.6
Impact on Profit
With
No Price Increase
/f ROCa % Change
5.7
-9
Hazardous Waste Management
Facility
1,635,190 15.4
8,800
0.5
15.0
-3
Return-on-Capital
Source; 'Arthur D. Little, Inc., estimates.
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There could be a differential impact upon rates that generators
pay if the differential cost impact per truck type or trip is reflected
in a relatively higher rate increase for short-haul, low-volume drummed
waste transport. This again implies that small waste generators will
face a greater relative increase than larger waste generators, although
the increase for both is not great.
(2) Hazardous Waste Management Company
In addition to the direct costs of owning and operating trucks,
hazardous waste management facilities have other expenses and pricing
policies which can result in a different impact on rates than that
V
indicated by examining trucks above. An increase in truck expenses
can be offset by increases revenues from trucking and/or disposal
operations.
The decline in profitability in the absence of a price increase
would be 3 percent, and a price increase of 0.5 percent is required
to recover the cost of compliance with Section 3003.
(3) Generators
If transportation costs increase by 2.6 percent, the total cost
to generators (14 industries identified by the EPA) of transporting
hazardous waste will increase between $0.7 million and $0.6 million
as a consequence of Section 3003. This increase is a fairly insig-
nificant portion of the cost of manufacture or value added.
SUMMARY OF DETAILED FINDINGS
1. For-Hire Transport
a. Rail Carrier
• Roughly 5 percent (400,000 metric tons) of hazardous
waste in transport moves by rail.
• Most hazardous waste transported by rail moves in tank
cars which are owned by generators.
1-12
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• Most hazardous waste transported by rail is destined for
reclamation centers as opposed to disposal facilities.
•» Intermodal transfers of hazardous waste involving rail
consist of truck pick-up or delivery to rail sidings,
barge transfer, or rail-truck piggyback.
• Rail shipment of hazardous waste in large volumes and
over long distances is less expensive than by truck,
and actual use reflects these economies.
• The dominant regulations pertaining to hazardous waste
are those administered by DOT and ICC, and these control
handling, loading, acceptance, marking, recordkeeping,
and classification of hazardous materials.
• Railroads do not ordinarily load, unload, or otherwise
directly handle hazardous waste as such, but only transport
rail cars ready for delivery. As common carriers regulated
by the ICC, all properly prepared shipments must be accepted
for delivery to the consignee.
b. Motor Carrier (Truck)
• Facilities and Services Provided
- Most firms have only one terminal location.
- Some firms do have temporary storage facilities, but
on-site storage of hazardous wastes is uncommon and
uneconomic.
- For large interstate common carriers, hazardous waste
transportation represents only a small portion of their
business.
Small intrastate carriers may specialize in hazardous
waste transportation.
- About half of the firms contacted transport interstate.
- All firms contacted are either privately owned or closely-
held stock corporations.
- Nearly 70 percent of the companies had 30 or fewer
vehicles; 35 percent had 5 or fewer.
1-13
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- Some companies specialize in a particular waste
(e.g., waste oil), but most handle a variety.
- The vast majority of transporters rely on generators
for chemical analysis of waste.
• Transportation Actiylties.
- Excluding national common carriers, the average round
trip distance travelled is about 50 miles. The national
common carriers typically travel hundreds of miles.
- The majority of vehicles are tank trucks with'a capacity
of 1200-8600 gallons.
- Most vehicles in use are less than 8 years old and have
a useful life of 5 to 10 years.
- Intermodal shipments are uncommon.
- Contractual arrangements between the transporter and
generator allow little time to plan for the routing
and dispatching of trucks.
- Responsibility for loading the vehicles depends upon
the form of waste and type of vehicle; if containers
are supplied by the generator, it is the generator's
responsibility to load. Vacuum trucks are loaded and
unloaded by the transporter. Tank trucks are usually
fully loaded by a single generator. National common
carriers make fewer multiple stops than other trans-
porters.
- Generally, it has been the transporter's responsibility
to select and deal with a disposal site.
- All large interstate carriers contacted use DOT placards
and follow ICC regulations; among the smaller truckers,
there are variations in practices having to do with
marking, labeling, and placarding.
• Business/Administratiye Practices
- All firms contacted keep shipping records, the most
common of which are bills of lading and weigh tickets
1-14
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most often used for billing purposes, and for reporting
to state environmental agencies; the retention period
is typically 5 to 7 years.
- Safety practices include driver training, personal
protective equipment* and vehicle maintenance.
- Most transport companies bill generators for both
transport and disposal; these charges are not always
distinct.
Water Carrier
• Facilities and Services Provided
- The only vessels found to carry hazardous wastes are
barges (often tank barges).
- The most commonly used barge is a 3-compartment tank
barge with a capacity range of 1200-1500 short tons.
These barges are usually double-hulled and some have
double bottoms.
- The total quantity of hazardous waste shipped in the
U.S. by barge appears to be relatively small (when
compared to truck transport).
- Barge shipments of hazardous waste move primarily on
the Gulf Intracoastal Waterway and the Missouri-
Mississippi River System.t
- All contacted companies are privately owned and operate
as contract carriers.
- Hazardous waste transport accounts for only a small
portion of their transportation activities.
- The destination is generally a resource recovery as
opposed to disposal facility.
• Transportation Activities
- Activities include scheduling and routing of barges,
mechanical pumping operations for loading and unloading
directed by a tankerman, and vessel towing to the
destination.
1-15
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It is not unusual for a barge to change tows several
times during a trip.
- Barge companies communicate regularly with tow boat
crews to ascertain position.
- Depending upon the time of arrival, the waste cargo
will either be accepted (and transferred) immediately,
or the barge may be placed in a queue perhaps for
several days.
• Business/Administrative Practices
- The bill of lading and dangerous cargo manifest are
the commonly used shipping documents. In most cases,
the manifest remains on board unmanned barges carrying
hazardous waste.
- The barging business is highly informal, involving both
long- and short-term agreements.
- Although changes are being made, crew training has been
basically a learn-as-you-go operation.
- Bulk shipments of hazardous materials and some hazardous
wastes are under U.S. Coast Guard jurisdiction.
- Under the Federal Water Pollution Act, an owner or
operator may be liable to the U.S. Government for up
to $14 million for an accidental discharge of a
s hazardous substance. Therefore, barge companies either
demonstrate adequate self-insurance or purchase special
pollution insurance.
d. Air Carrier
• The amounts of all hazardous materials shipped by air are
negligible compared to other modes and are only a small
portion of any air carrier's business.
• Small amounts of waste acids, metal shavings, and waste
samples are among the hazardous wastes carried. Wastes
that are not samples are usually shipped by air because
the proper disposal sites are not locally available, or
1-16
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because wastes are occasionally returned to manufacturers.
• Most people in the air transport business cannot recall
instances of hazardous waste transport by air.
• The STOP regulations of the Airline Pilots Association (ALPA)
control hazardous materials shipped on passenger airlines
and many cargo airlines.
• ALPA is trying to ban almost all hazardous materials on
passenger craft, and at this date has greatly restricted
transport on passenger craft.
• Shippers continue to foist dangerous cargoes on airlines
without proper labelling or packaging.
e. Pipeline
• Interstate and other major U.S. pipelines are not used for
transport of hazardous waste.
• Local pipeline transport of hazardous waste may occur when
a waste management facility is located in the midst of a
concentrated industrial area.
• Municipal or other public authorities often use pipelines
for sludge or sewage transport.
• Some mining operations and coal utilities use pipelines
for waste transport. All those identified involved on-
site disposal.
• In instances such as the Gulf Coast Waste Disposal Authority,
the pipelining of wastewater may be subject to the Federal
Pollution Control Act.
» There do not appear to be coherent, unambiguous standards
for hazardous waste transportation by pipeline.
2. Off-Site Transport by Generators
• Approximately 4 percent of generators of hazardous waste self-
haul to off-site disposal facilities; they haul 2-3 percent of
the total amount of hazardous waste that moves off-site.
• The smaller rather than the larger producing companies are
engaged in self-hauling.
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• The tendency to self-haul is industry-dependent. For example,
the leather tanning industry self-hauls about 25 percent of
waste going off-site, and the waste oil re-refining or repro-
cessing industry self-hauls over 50 percent. Some industries
such as metal smelting and refining do no self-hauling at all.
• The distance from the generator to the disposal facility is
usually less than 10 miles; often no more than 1-2 miles.
• One haul per day in a dump truck is common practice.
• Types of vehicles used include flatbeds, tank trucks, and
trailers, with flatbeds predominant.
• Although most companies claim that they follow DOT marking
and labeling requirements, they expressed interest in clear
guidelines for hazardous waste.
• Records are retained for at least seven years on the amount
of waste shipped, the destination, and the means of shipment.
• Wastes are temporarily stored on-site from a few
days to a few months.
3. Transport by Operators of Hazardous Waste Management Facilities
• Facilities and Services Provided
- The majority of firms operate interstate both in terms of
location of multiple facilities and transportation activities;
however, there are few interregional operations. Intrastate
operators tend to serve only a small section of the state.
- Most are privately owned (or closely-held public corporations),
Both in terms of number of vehicles and employees engaged in
transportation, the HWMF/transporters are relatively small
companies.
- Many firms representing themselves as HWMF/transporters
in fact do not both transport and dispose of hazardous
waste.
- More than half of the operations have been in business 10
years or less.
1-18
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• Transportation Activities
- Tankers represent about 60 percent of the vehicles in use;
flatheds and vans less than 30 percent.
- The average age of vehicles in use is between 9 and 12 years.
- When the vehicle itself is not the container, the generator
of the waste material is responsible for containerization.
- Transportation employees' training focuses more on vehicle
safety than on the hazards of the materials being transported.
- Generators initiate the transportation activity. The service
procurement agreement includes descriptions of the materials,
and specifications of the terms and conditions of pickup and
delivery.
- Loading of the vehicle is usually the responsibility of the
generator if the generator provides the containers; other-
wise the HWMF/transporter takes responsibility.
- There is little mixing of materials and multiple pickups
are rare.
- Some, but not all, HWMF/transporters chemically analyze
materials either prior to or upon receipt of wastes.
- There is always someone to accept delivery at the waste
management facility.
- Marking, labeling, and placarding are generally in accordance
with DOT regulations, according to transporters.
• Business/Administrative Practices
- Shipping papers, containing appropriate certification sig-
natures and which describe quantity, source, waste type and
delivery point, are maintained for at least three years.
- There is some on-site storage of hazardous waste at treat-
ment and disposal facilities.
- All facilities indicate that they follow generally accepted
or mandated safety practices.
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II. INTRODUCTION
A. OBJECTIVES
The objectives of this study are to:
• Characterize the facilities, transportation activities,
business/administrative practices, regulatory environment,
and financial and economic structure of transporters of
hazardous waste in the United States; and
• Assess the costs of compliance with and economic impact
of EPA-proposed hazardous waste transportation regulations.
Such transportation is normally required to convey hazardous wastes from
the generator of these wastes to an off-preaises waste facility for treat-
ment, storage, and/or disposal. All modes of transportation are addressed:
air, rail, highway, waterway, and pipeline, for both inter- and intra-state
movements.
The need for this study derives from enactment of the Resource Con-
servation and Recovery Act of 1976 (RCRA) (Pub. L. 94-580), which directs
the Administrator of the Environmental Protection Agency (EPA), under
Subtitle C—Hazardous Waste Management, of the Act, to promulgate regula-
tions within 18 months of enactment to ensure the proper controls on
generation, transportation, treatment, storage, and/or disposal of all
wastes defined as hazardous by the Act. Specifically, Section 3003 (42
U.S.C. 6923) of the Act (RCRA) requires the EPA to establish standards
applicable to transporters of hazardous waste as may be necessary to
protect human health and the environment.
According to Section 3003, paragraph (a), the standards developed
shall include but need not be limited to: (1) recordkeeping concerning
such hazardous wastes transported, and their source and delivery points;
(2) transportation of such wastes only if properly labeled; (3) compli-
ance with the manifest system developed under Section 3002 of the Act;
and (4) transportation of all hazardous wastes only to the hazardous
waste management facilities which the shipper designates on the manifest
form to be a facility holding a permit issued in accordance with Section
II-l
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3005 of the Act. This study focuses on aspects of hazardous waste
transportation related to these four requirements.
The costs of compliance estimates and economic impact assessment
reported here are based upon "Standards Applicable to Transporters of
Hazardous Wastes" proposed by the EPA, 43 FR 18506-18512, April 28, 1978
(reproduced in Appendix A). The economic impact conclusions are those
of the Contractor and not of the EPA.
B. SCOPE OF WORK
*
Three groups of participants have been identified as transporters
of hazardous waste:
• Generator/transporter - Generators, including industrial,
commercial, and governmental organizations, that act as
private carriers and self-haul hazardous wastes, invariably
by truck, to off-site hazardous waste management facilities.
• For-hire transporter - Common and contract carriers, whose
principal business is commodity and/or waste transportation, that
transport hazardous waste from the point of generation to off-site
hazardous waste management facilities which they do not also operate.
• Hazardous Waste Management Facility (HWMF)/transporter -
Operators of hazardous waste management facilities that
act as contract or private carriers in transporting hazardous
waste from the point of generation to treatment, storage, or
disposal facilities.
In gathering information, it has proven quite difficult to apply the
precise definition of hazardous waste contained in Section 1004 of RCRA:
"a solid waste, or combination of solid wastes, which because of its
The transporter is, by definition, the party providing the motive power
for the shipment. Thus, a generator of hazardous waste who owns and loads
a rail tank car is considered a Generator/transporter only if that party
were to operate the locomotive.
II-2
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quantity, concentration, or physical, chemical, or infectious characteris-
tics may—
"(A) cause, or significantly contribute to an increase in mortality
or an increase in serious irreversible, or incapacitating
reversible, illness; or
"(B) pose a substantial present or potential hazard to human
health or the environment when improperly treated, stored,
transported, or disposed of, or'otherwise managed."
Rather, hazardous waste has been liberally interpreted to mean "industrial
or processing waste generally," under the reasonable assumption that most
of such waste is hazardous. This simplification made it possible to more
easily communicate the intent of the term "hazardous waste" to hazardous
waste transporters from whom information has been elicited. All wastes
which meet the Department of Transportation's definition of hazardous
materials (see Section II.D.) have been considered hazardous wastes in this
study.
The RCRA specifically excludes the following wastes from regulation
under the Act: solid or dissolved material in domestic sewage; solid or
dissolved materials in irrigation return flows; industrial discharges
which are point sources subject to permits under Section 402 of the
Federal Water Pollution Control Act, as amended (33 U.S.C. 1342); and
source, special nuclear, or byproduct material as defined by the Atomic
Energy Act of 1954, as amended (42 U.S.C. 2011). Furthermore, the fol-
lowing have been excluded from this study as not being within the current
scope of RCRA: wastes destined for ocean disposal under the Marine Pro-
tection, Research and Sanctuaries Act of 1972 (33 U.S.C. 1401 and follow-
ing); and nonhazardous wastes such as municipal garbage and refuse generally,
unprocessed septage and sewage, and discarded material from mining and agri-
cultural operations.
C. INFORMATION ACQUISITION
A representative characterization of hazardous waste transportation
in the U.S. is a principal goal of this study. This has proven to be
II-3
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difficult to achieve on several counts. First, the three segments com-
bined do not truly constitute a readily identifiable industry. The
generator/transporter certainly does not view itself as part of the
hazardous waste transport industry; nor do many of the common carriers
(e.g., trucking firms, railroads). Many hazardous waste management
firms provide transportation only as a convenience to generators, and
in furtherance of their principal service: waste treatment and disposal.
Probably for this reason there are no comprehensive tabulations extant of
firms providing hazardous waste transportation services.
Second, a fringe portion of the industry, variously termed by large
transporters as gypsies, scavengers, or midnight dumpers, is supposedly
irresponsible or poorly informed regarding proper operating procedures.
These firms are said to undercut the established disposal costs of res-
ponsible carriers in handling hazardous wastes by illegally or imprudently
dumping waste as may be convenient. The existence of such firms seems
undeniable in view of the widespread dissatisfaction with and opposition
to their activities; however, the true extent of their operations in
transporting hazardous waste is undocumented and unknown. In this study,
it has not been possible to characterize independently the nature and
extent of this fringe segment.
To identify firms transporting hazardous waste contact was made with
all EPA Regional Offices for Solid Waste Management, various Federal Govern-
ment Agencies and national industry, associations identified in Tables II-l
and II-2. With the exception of regional EPA contacts, very few of the
Federal agencies and national associations were able to identify firms
engaged in the transportation of hazardous waste, again primarily be-
cause this activity does not yet constitute a readily-identifiable
industry.
A primary source for contacts with hazardous waste transporters
was drawn from firms attending a series of EPA-sponsored public parti-
cipation meetings held with generators, transporters, waste management
facilities, state and local governments, and public interest groups to
II-4
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TABLE II-l
NATIONAL ASSOCIATIONS CONTACTED
Air Freight Forwarders Association of America
Airline Pilots Association, International
Air Transport Association
American Association of General Contractors
American Petroleum Institute
American Trucking Associations, Inc.
The American Waterways Operators, Inc.
Association of American Railroads and Bureau of Explosives
Manufacturing Chemists Association
National Air Transportation Associations
National Center for Resource Recovery
National Solid Waste Management Association
National Tank Truck Carriers, Inc.
Slurry Transport Association
Transportation Association of America (Hazardous Materials
Advisory Committee)
TABLE II-2
U.S. GOVERNMENT AGENCIES CONTACTED
U.S. Department of Defense
Military Traffic Management Command
Air Force, Director of Transportation
Director of Environmental Research and Development
Army Corps of Engineers
U.S. Environmental Protection Agency, Office of Solid Waste
U.S. Department of Transportation
Federal Aviation Administration
Federal Highway Administration
Federal Railroad Administration
Materials Transportation Bureau, Office of Hazardous Materials Operations
Office of Pipeline Safety
U.S. Coast Guard
II-5
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discuss the development of Section 3003 standards. The public meetings
were conducted in ten cities across the United States during February -
May, 1977.
Various secondary sources of information were also used. Certain
states operating a permit system or having a registration requirement
for hazardous waste transporters were able to identify transport activi-
ties. Listings of firms were obtained for California, Indiana, Massa-
chusetts, Michigan, New York, Texas, and a partial listing for New
Jersey. These, of course, are highly industrialized states. Finally,
we surveyed the Telephone Yellow Pages Directories for major metropoli-
tan areas across the country under such headings as disposal contractors;
chemical cleaning—industrial; oils—waste; pumping contractors; and waste
reduction and disposal service—industrial. Once contact was made with
a few hazardous waste transporters in an area, additional references
were easily obtained.
The problem of developing a reasonably representative sample of
firms engaged in transporting hazardous waste was not easily resolved
due to lack of knowledge of basic "industry" characteristics. The
number of firms engaging in transportation of hazardous waste by segment
(or total) is unknown, as are their entry and exit rates. Although the
total amount of hazardous waste transported by the industry has been
ft
estimated at 7.9 million (wet) metric tons per year in 1977, the
distribution of waste transported by firm is still unknown, so that
it is difficult to judge the extent to which our findings are indeed
representative of the industry. Nevertheless, an attempt was made to
secure a representation of firms by geographic region served, size
(number of employees or vehicles, revenues), public/private ownership,
types of hazardous wastes handled, etc. To the extent that larger
firms are more readily identified and tend to be more communicative
than smaller firms, our sample is biased toward the former. Thus, the
sample may be regarded as implicitly weighted by annual quantity of
hazardous waste transported.
Reference 1. The estimate is based on hazardous waste generation from
13 industry groupings, rather than forecasting amounts received by the
hazardous waste management industry. (Ocean dumping is included in the
estimate.)
II-6
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The problem of representativeness is probably most serious for
generator/transporters and hazardous waste management facility/trans-
porters due to their large numbers and fairly diverse activities (despite
the fact that they engage exclusively in trucking). Regarding for-hire
transporters (air, rail, highway, and waterway), the problem is not very
significant because these common and contract carriers, which tend to
operate inter-state, are more strictly regulated by Federal authorities
(thus their activities tend to be relatively standard). However, intra-
state motor transport of hazardous wastes may not be regulated by state
or Federal authorities.
The information on which this report is based was obtained primarily
through personal contact with firms engaged in hazardous waste transporta-
tion, supplemented by data made available by various state agencies and the
EPA. No attempt was made to verify independently the accuracy of infor-
mation obtained via day-to-day observation of transporter operations
and records. In effect, the status of the hazardous waste transportation
sector is reported here as revealed by that sector; no rigorous attempt
has been made to verify these detailed findings. Site visits were made
to obtain certain information first-hand and to corroborate basic
findings.
The information gathering design essentially followed an "industry"
sector/transportation mode matrix approach. Generators in major waste-
producing industries were contacted to learn whether they self-hauled
hazardous waste off-premises, and, if so, what modes were used. Hazar-
dous waste management firms were contacted to learn whether they provided
transportation services to generators in addition to operating treatment,
storage, and/or disposal facilities, and, if so, what modes were used.
Finally, for-hire common and contract carriers in each mode (air, rail,
highway, waterway, and pipeline) that do not also operate treatment,
storage, and/or disposal facilities were contacted to learn whether they
engage at any time in transporting hazardous wastes, regardless of source
and destination. Further details concerning methodology followed will be
found in subsequent sections of this report dealing with "industry"
segments.
II-7
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D. REGULATORY CONTROL
1. Interstate Commerce Commission
Transporters of hazardous waste are currently subject to a
variety of Federal, State, and local regulations. At the Federal
level, the Department of Transportation (DOT) and the Interstate
Commerce Commission (ICC) share principal regulatory authority
over the transportation of hazardous waste.
The ICC under the Interstate Commerce Act has broad authority
*
to administer regulations involving the operating rights, finan-
cial structures, rates, and practices of transportation companies
(nearly all carriers except air) engaged in interstate or foreign
commerce. In particular, all non-exempt interstate carriers must
**
make application to the ICC for operating authority to engage in
any for-hire transportation business. Important distinctions are
made in the regulations among common, contract, and private carriers,
as well as among the different transportation modes. Common carriers
offer their services to the general public .and are bound to carry for
all who choose to employ them (for services they hold themselves
out to perform) and are liable as insurers for the loss or injury
of property, with certain exceptions. Interstate common carriers
must hold a certificate issued by the ICC, which limits
services to a specific geographic area and often to specific com-
modities. Contract carriers engage in for-hire transportation of
passengers or property under individual contracts or agreements.
Private carriers transport their own property, incidental to and
in furtherance of their primary business (other than transportation);
private carriers are generally excluded from regulation by the ICC
(aside from safety considerations).
*
Pub. L. 89-670 (October 18, 1966) transferred to and vested in the
Secretary of DOT all functions, powers, and duties of the ICC relative
to safe transportation of hazardous materials.
**
A certificate of public convenience and necessity for common carriers
and permit for contract carriers.
II-8
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The Interstate Commerce Act and the ICC have granted numerous
regulatory exclusions which depend upon transportation mode, common/
contract carrier status, property/cargo carried, etc. Many of these
special situations, especially those pertaining to hazardous waste,
are discussed in subsequent chapters of this report separately for
each transport segment. Whether transportation of hazardous waste
by motor vehicle is ICC-exempt depends upon whether it meets the test
of property; at the present time, waste destined for disposal (rather
than resource recovery) would appear not to do so (Section III.B.5).
2. Department of Transportation
The DOT has regulatory and enforcement authority to ensure the
safe transportation of hazardous materials in interstate commerce.
These broad powers extend to all modes of transportation and apply
equally to common, contract, and private carriers. Generally, the
DOT Hazardous Materials Regulations address acceptance of materials
for transportation, loading, unloading, handling, storage of hazar-
dous materials, leaking containers, accident/spill reporting require-
ments, containerization, and detailed requirements for specific
classes of hazardous materials.
The DOT has stated (Office of Hazardous Materials Newsletter,
April/May 1977) that, "The Department's Hazardous Materials Regula-
tions may apply to any material regardless of its end use and the
fact that a material is considered a waste material does not relieve
application of these regulations." Thus, a waste that meets DOT's
definition of a hazardous material (49 CFR 172, 173) is ipso facto
a hazardous material subject to the Department's regulations. How-
ever, many hazardous wastes defined or listed under RCRA Section
3001 may not qualify as DOT hazardous materials, for example, cer-
tain persistent, toxic, environmentally-deleterious wastes; the
transportation of those environmentally hazardous wastes are not
currently regulated by the DOT.
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DOT hazardous materials regulations as they may apply to the
transportation of hazardous wastes are discussed in subsequent
chapters of this report separately for each transport segment.
In addition to hazardous materials transportation regulations,
DOT also administers safety regulations pertaining to the operation
of transport vehicles (i.e., rail cars, freight containers, motor
vehicles, vessels, cargo and portable tanks), aircraft and pipelines.
Safety regulations for carriage by rail, water, and air apply to
both intra- and interstate shipments. Further details concerning
regulatory authority will be found in subsequent chapters for each
hazardous waste transport segment.
A summary of both ICC and DOT regulatory authority with respect
to transport of hazardous wastes appears in Table II-3.
3. State Authorities
Whereas ICC regulations pertain to interstate conmon and contract
carriers, the individual states (Public Utility Commissions) exercise
varying degrees of control over intrastate shipments of hazardous
' ft
materials and wastes. The vast majority of states (49 out of 50)
require transporters to file for certificates of authority to trans-
port hazardous materials. Of these, 38 also regulate waste transporters.
Furthermore, various agencies in various states may require that a
transporter of hazardous waste obtain a permit or license (e.g., De-
partments of Health, Natural Resources, Environmental Protection,
Water Pollution Control, etc.).
Again, the individual states have exercised varying degrees of
(intrastate) control over regulation of hazardous materials trans-
*
portation and motor carrier safety. About half the states have
adopted DOT hazardous materials regulations for motor carriers in
their entirety or have similar regulations in effect. About three-
fifths of the states have adopted the DOT Motor Carrier Safety Regu-
lations or have similar rules in effect.
*
For further details see Reference 2.
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TABLE II-3
ICC AND DOT REGULATORY AUTHORITY FOR
INTERSTATE TRANSPORT OF HAZARDOUS WASTE
Transport Segment
ICC
DOT
For-Hire Carrier
Rail
Motor (truck)
Water (barge)
Air;.
Pipeline
Generator/transporter
HWMF/transporter
Non-exempt
£
Exempt/Non-exempt
b
Exempt
Exempt
Non-exempt
Exempt
Exempt
Non-exempt
Non-exempt
Non-exempt
Non-exempt
Non-exempt
Non-exempt
Non-exempt
aExempt if waste is not "property."
Bulk cargoes.
C3xempt if private carriage or waste is not "property1.1
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E. INSURANCE COVERAGE
1. Types of Coverage
The ability of hazardous waste transporters to meet their finan-
cial responsibilities arising from loss of cargo is of particular
concern to the EPA. In general, a firm may elect to self-insure
(self-retention of risk) a portion or all of the risk of loss or
purchase liability insurance for a specified amount of coverage.
Liability insurance protecting a firm from losses related to trans-
port of hazardous waste may be obtained in part through several
types of insurance coverages: motor vehicle accident liability
insurance,-comprehensive general liability insurance, and "umbrella"
liability insurance. Losses covered by such liability contracts
include all legally obligated payments as a result of bodily injury
or property damage. Insurance companies distinguish between two
types of incidents which may be covered:
• Marine spills (both for offshore waters and inland waters);
and
• Shoreside spills (i.e., onshore spills which may or may
not eventually find their way into a waterway).
Insurance available to cover liability arising from hazardous waste
spills is summarized in Table II-4.
Nearly all states have enacted financial responsibility laws for
owners of motor vehicles. Most highly industrialized states (e.g.,
California, Indiana, Michigan) require insurance coverage per occur-
rence, typically $100,000 for bodily injury or death of one person,
$300,000 for bodily injury or death of more than one person, and
$50,000 for property damage to others. Other states may require
significantly less coverage (e.g., $10,000/$10,000/$1,000 in
Louisiana; none in New Hampshire, Maryland, and New Jersey); still
other states make special provision for transporters of hazardous
The ICC requires (49 CFR 1043.2) that these minimum limits be met by
all regulated motor carriers, but does not set requirements for rail,
water, or pipeline carriers.
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TABLE II-4
SUMMARY OF INSURANCE COVERAGE AVAILABLE FOR HAZARDOUS WASTE SPILLS
Clean-Up
Spill Liability
Third-Party Liability
Marine
Smaller Firms
Larger Firms
WQIS
Self-Insure
WQIS
London Market
Self-Insure
Shoreside
Production Facilities
Railroads
MVA/CGL
MVA/CGL
MVA/CGL
MVA/CGL
Self -Insure
Trucking Firms
MVA/CGL
MVA/CGL
EWater Quality Insurance Syndicate
bMotor Vehicle Accident and/or Comprehensive General
Liability Insurance
SOURCE: Arthur D. Little, Inc., based on industry interviews.
11-13
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materials (e.g., California, Kentucky). Motor vehicle liability
coverage specifically extends to injuries and damages attributable
to accidental loss of cargo.
Beyond motor vehicle insurance, most firms will carry compre-
hensive general liability insurance, covering all sources of liability
not specifically excluded. Bodily injury and property damage payments
are subject to separate policy limits per incident, usually tied to a
deductible amount. Umbrella insurance is excess insurance over the
insured's traditional liability insurance policies and may also cover
sources of liability not covered under the insured's other liability
policies, usually subject to a minimum deductible of $25,000 per oc-
currence. The maximum limit of liability under the umbrella insur-
ance is usually at least $100,000 per occurrence and may range as
high as $25 million or more per occurrence.
Typical terms of insurance coverage are as follows:
• Production Facilities
&
The Fortune 1000 companies probably carry at least $20
million in excess liability coverage; the first 250 Fortune
companies may carry $50-100 million in coverage. A major s
heavy chemical producer which occasionally transports its own
wastes has $85 million in excess liability coverage above a
$l-million general liability policy.
• Railroads
Railroads generally carry $25-50 million in third-party
property damage with large deductibles ($1-2 million). Prac-
tically speaking, railroads self-insure for minor incidents.
• Trucking Firms
The larger trucking firms generally carry $25-50 million in
coverage. Coverage is believed to vary greatly for smaller
firms and to be significantly less.
Fortune Magazine annually ranks by sales revenues the largest
industrial corporations in the United States.
11-14
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The above insurance coverages for firms are often written as a
package by insurers, rather than as separate policies. However, the
cost, and indeed availability, of high-amount liability insurance is
dependent on several factors: (1) the extent to which the supposedly
high-risk portion of the business (e.g., hazardous materials) is sup-
ported by lower-risk business, (2) the total amount of insurance pur-
chased, and (3) the insured's historical claims experience. With
regard to coverage of liability stemming from handling (including
transporting) of hazardous materials generally, insurance underwriters
caution that each situation must be appraised individually on its own
merits, and generalizations are difficult. There is no question that
smaller firms transporting hazardous materials and/or wastes are at
a significant disadvantage in obtaining sufficient liability insurance.
Firms with blemished safety records will not easily obtain coverage.
The foregoing liability policies are strictly limited to sudden
and accidental (so-called measurable) loss situations. For example,
loss of cargo due to tank corrosion would be excluded.
Self-haulers of hazardous wastes would ordinarily carry standard
limited-liability motor vehicle insurance, covering personal injury
and property damage, in accordance with regulations set by the state.
Financially sound companies, self-hauling wastes under conditions
where the probability of catastrophic accident is not too great,
might be eligible for higher liability umbrella coverage for all
losses, usually with a substantial deductible. When a generator
contracts for waste transport, the contract normally has a clause
transferring possession of the waste to the contractor, who then
assumes all subsequent responsibility. The advantage of being able
to transfer liability for hazardous materials which are of no fur-
ther use to the company (i.e., hazardous wastes) is certainly an
important factor accounting for the very small number of generators
that do self-haul.
11-15
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2. Shoreside Spills
Insurance coverage is generally available for shoreside liabilities,
including clean-up costs which might result from a hazardous material
spill, through comprehensive general liability insurance. Such
policies provide some protection against hazardous material spills,
where the spills are sudden and accidental. Recently, because the
liability resulting from onshore spills is relatively vague, some in-
surers have been reluctant to provide this pollution coverage under
their comprehensive general liability insurance. Nevertheless, cover-
age of sudden and accidental spills is still generally available.
However, in general, it is not possible today (except possibly in
London insurance markets) to obtain liability coverage for oil spill
clean-up of the water environment. In no case will voluntary clean-
up of spills or restoration of the environment by the insured be
paid for by insurers; the business firm must be held legally respons-
ble before insurance will be paid.
In recent years, companies insuring corporations that produce
or transport hazardous materials have become increasingly concerned
with potential liability due to spills. In general, clean-up costs
and third party property damage costs due to most recent chemical
spills have been small, and insurance companies have not had to re-
imburse insured corporations for damage because costs were within
the amount of the deductible.
3. Marine Spills*
Coverage for marine spills is provided by at least one insurance
syndicate. The Water Quality Insurance Syndicate (WQIS), a recently
formed consortium of 28 marine insurance companies. The syndicate
insures commercial marine vessels (tankers, barges, tugs, etc.) but
not drilling rigs or recreational vessels, providing coverage for
spills of petroleum or hazardous chemical substances as determined
by the 1972 and 1977 Clean Water Acts. Most large carriers prefer
to self-insure themselves against possible spills, while many small
See Section III.C.4.f for further details.
11-16
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carriers prefer outside coverage. The majority of vessels insured
by WQIS are American Flag vessels.
Current insurance coverage for hazardous substance spills
covers clean-up costs of up to $1507ton under policies ranging in
size from a minimum of $250,000 to a maximum of $14 million per
incident. Additional insurance coverage can be purchased for third-
party property damage. For example, WQIS will provide up to $5
million coverage for third-party property damage under standard
policies and an additional $10 million under special policies,
while some London-based firms will provide up to $30 million
coverage. As of June 1978, no claims for hazardous substance
spills had been made to the WQIS because the list of hazardous
substances had not been finalized.
4. Insurance Industry Concerns
The U.S. insurance industry is concerned that the potential
liability due to hazardous material spills may be so great that it
would be unable to provide sufficient coverage. In that case,
many insurance dollars would flow to foreign markets, especially
to London. The insurance industry is also concerned that clean-up
costs may be defined to include mitigating measures as well as ac-
tual clean-up costs. Whether environmental mitigation expenses
would be covered by existing insurance is open to question. How-
ever, actions required by Federal, regulation and clearly made a
responsibility of the spiller, such as clean-up costs, would
probably be covered.
The entire issue of bonding and liability insurance for
hazardous material spills is undergoing rapid development at this
time. Most large industries appear to be adequately insured for
clean-up costs and damages which have resulted from hazardous
material incidents to date.
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F. LIMITS OF ANALYSIS
1. Definition of Hazardous Waste
It has proven difficult to communicate unambiguously to trans-
porters of waste the precise meaning of the definition of hazardous
waste contained in Section 1004 of RCRA. First, several transporters
denied that materials conveyed to resource recovery facilities con-
stituted waste, hazardous or otherwise. Second, some transporters
were not certain which, if any, of the wastes they customarily trans-
ported were indeed hazardous. Several interstate transporters believed,
incorrectly, that DOT hazardous materials regulations do not apply to
(hazardous) wastes. For these reasons, ambiguities understandably
existed in the minds of several transporters furnishing information
concerning the extent to which their operations involve hazardous
waste.
2. Representativeness of Firms
Because the firms engaged in transportation of hazardous waste do
not constitute a readily-identifiable industry, it has proven difficult
to ensure that a representative sample of firms has been selected for
examination. No consistent compilation of firms engaged in the trans-
port of hazardous waste exists. Nevertheless, the consistency of
responses obtained seems to indicate that a fairly broad spectrum of
transporters has been contacted during this study, with the exception
of those engaging in possibly illegal activities.
3. Illegal Activities
The extent of illegal or imprudent transportation of hazardous
waste is unknown but widely reported to exist, particularly in those
states lacking effective hazardous waste regulations. It has not
been possible in this study to characterize the nature and extent of
these fringe transporters.
11-18
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4. Classification of Transport Segments
Difficulties were encountered in distinguishing unambiguously
between 1) for-hire transporters not otherwise engaged in hazardous
waste management and 2) hazardous waste management facilities that
also transport waste. For example, some for-hire transporters con-
tract with generators to both transport and dispose of hazardous
waste. Often it was difficult to ascertain the true status of these
transporters. In contrast, some hazardous waste management facilities
provide transportation services which are quite distinct from their
disposal operations. Actually, some of these transporters might be
ICC-regulated coranon or contract carriers that also engage in hazar-
dous waste disposal. Furthermore, various corporate or subsidiary
relationships are possible between for-hire carriers and hazardous
waste management facilities, which tend to confound the exact "industry"
segmentation used in this study.
5. Verification of Information
Aside from several site visits to obtain basic information and to
corroborate certain findings, no rigorous attempt has been made to
verify the information provided by transporters of hazardous waste.
6. Restriction to Section 3003 Impacts
The economic impact assessment of RCRA Section 3003 regulations
excludes the effect of all other RCRA regulations on the transporta-
tion of hazardous waste. For example, an assessment of the impact
of Section 3004 regulations on the transportation of hazardous
waste is not within the scope of this study.
7. Descriptive Data
The economic impact assessment reported here has been based
largely upon descriptive data in the absence of detailed, statis-
tically-supported findings. For example, the number of firms
engaged in hazardous waste transportation and their total resources
(number of vehicles, etc.) is unknown. Nor is it known how
11-19
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transportation revenues are divided between for-hire motor carriers
and hazardous waste management facilities.
8. Compliance with DOT Regulations
All interstate transporters" of hazardous waste are presumed to
be in compliance with applicable"DOT hazardous materials regulations.
A separate economic analysis has not been made for those transporters
in violation of these regulations. Specifically, no special provision
has been made to recognize on-going illegal hazardous waste transpor-
tation activities (Cf. item 3 above).
9. Average Values
The cost of compliance estimates are average values. Substantial
variability will exist in costs of compliance for individual trans-
porters depending upon the precise nature and cost structure of their
transportation activities.
G. SOME DEFINITIONS AND DISTINCTIONS
The generator of hazardous waste is regarded as the shipper or
consignor of the waste. The transporter is the carrier of the hazardous
waste, and the hazardous waste management facility is the recipient or
consignee of the waste shipment.
In this report, comparisons are frequently made between DOT hazar-
dous materials and hazardous wastes. The vast majority of hazardous
materials are virgin materials or manufactured end products. Hazardous
wastes differ from hazardous materials in two important respects:
• Hazardous wastes intended for disposal have no intrinsic
economic value, and, therefore, the shipment need not be
safeguarded for economic reasons (aside from potential
third-party spill liability). On the other hand, loss of
most hazardous materials means a financial loss to the owner
or carrier, and for this reason such materials are regarded
as "property," whereas waste per se is usually not so regarded.
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• Whereas most hazardous materials have well-known and documented
physical and chemical properties, the same is not true for most
hazardous wastes. This means that most hazardous materials may
be readily classified as to their hazards, whereas hazardous
wastes are similarly classified only with great difficulty.
Thus, it is not uncommon for many people who handle wastes to
be unfamiliar with their hazards and the risks they represent.
H. ORGANIZATION OF REPORT
This report is organized by type or segment of hazardous waste
transportation:
Section Segment
III For-Hire Transporter
A Rail
B Highway
C Waterway
D Air
E Pipeline
IV Generator/Transporter
V HWMF/Transporter
The presentation within each category generally follows a parallel
development:
• Method of Approach
• Facilities and Services Provided
• Transportation Activities
• Business/Administrative Practices
• Regulatory Control
The last three chapters concern the economic consequences of Section
3003 standards—t:he cost of compliance with regulations and their
economic impact.
A glossary of special terms used in this report appears in
Appendix H.
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III. FOR-HIRE TRANSPORT
A. TRANSPORT BY RAIL CARRIER
1. METHOD OF APPROACH
Because railroad operating procedures are fairly standardized,
four representative railroads were contacted to obtain information con-
cerning the transport of hazardous waste. These four large interstate
railroads were selected in part because they service together much
of the United States. From the uniformity of the responses, it was in-
ferred that contacts with additional railroads were not necessary. Dis-
cussions were conducted by telephone with personnel who were generally
in charge of hazardous materials control and/or safety. In conjunction
with these interviews, the Bureau of Explosives of the Association of
American Railroads was interviewed both in person and by telephone.
The Bureau of Explosives closely monitors regulatory developments and
practices in the rail transport of hazardous materials. The Bureau of
Explosives also supplied data on movements of hazardous waste. All or-
ganizations contacted are listed in Appendix B-l.
This general approach was effective in determining the range of
standard practices followed in the transport of hazardous materials by
railroad. Through follow-up discussions with these railroads, data on
sample waste movements were obtained. A second stage of follow-up inter-
views was then conducted by telephone with disposers, recyclers, generators,
and truck transporters who were identified as receivers of rail shipments
or intermodal transporters. A total of seventeen such organizations were
identified of which ten were interviewed. These organizations included
a truck transporter who transfers waste from railroads, disposers and
recyclers with direct rail connections, a rail switching terminal, a
generator using intermodal transport for disposal, and a waste transporter
and disposer who transfers waste from a local rail siding. The disposers
and recyclers were in the Northeast, along the Gulf Coast and in Califor-
nia.
Considerable difficulty was encountered in identifying routes and
specific movements for disposed hazardous waste as distinct from recoverable
materials. The railroads identify a limited number of hazardous wastes in
III-l
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their hazardous materials classification system; the most prominent of
these is spent sulfuric acid. Investigation of the movements of spent
sulfuric acid showed that the destinations were all chemical companies
recovering the acid. Discussions with disposal facility operators
verified the existence of rail transport of hazardous waste and provided
certain details of the operation, but did not identify specific move-
ments. A reasonable conjecture is that railroad transport of hazardous
waste is dominated by recoverable materials. In any case, the railroads'
limited identification of hazardous wastes is biased toward resource
recovery activities and points to the need for more specific identifica-
tion of hazardous wastes.
2. FACILITIES AND SERVICES PROVIDED
The physical facilities and organizational structure of railroads
are quite similar throughout the industry. The extent and nature of
offered services distinguish railroads from other transportation
modes. The railroads are generally large, publicly-owned corporations
serving extensive regions of the country. Over 95 percent of the
operating revenues of the railroad industry are earned by Class 1 Rail-
roads (carriers having annual operating revenues of $10 million or more).
The four railroads interviewed are all among the largest in the nation.
The services offered by the railroads include only pure transporta-
tion. Railroads are not directly concerned with the loading and unloading
of transported goods. As common carriers regulated by the Interstate Com-
merce Commission, railroads must accept all properly packaged and labeled
cargo tendered to them within their tariff. If a package is leaking or
otherwise improperly prepared, the cargo, of course, is not considered
to be adequate for shipment. However, in general, the shipper accepts
responsibility for condition, description, packaging, and labeling.
One of the most significant aspects in the transport of hazardous
materials (including waste) by railroad is that the shipper does all
the packaging and the railroad does not directly handle the hazardous
material. The shipper must provide to the railroad the sealed or .closed
III-2
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containers of the hazardous material or waste. Furthermore, the railroad
car in which the containers are placed must be sealed or closed when
tendered. Thus, the railroad is concerned only with sealed or closed tank
cars, flat bed cars with sealed containers, closed boxcars or other types
of cars. Tank cars generally are sealed, although railroads can accept
unsealed cars. The issue of a sealed boxcar, however, has less meaning
than a sealed tank car. If hazardous wastes are sealed in drums, then
the boxcar in which the drums are consolidated does not have to be sealed
as such. In fact, for certain types of materials, an open hopper car can
be used. However, regardless of the type of car, the railroad will accept
only rail cars ready for shipment. Consolidation for delivery is often
done by agent for several generators of hazardous waste. The railroads
own and operate the flat cars on which the sealed containers are loaded
and the other cars are owned or leased by the railroad, shipper, or a
company which leases cars to the shipper. The extent of railroad pre-
paration of material for shipment is limited to loading a closed container
on the flatcar (at a piggyback loading ramp, for example).
The railroads do not provide storage and loading facilities. Both
of these functions are performed by shippers on leased or private sidings.
III-3
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3. TRANSPORTATION ACTIVITIES
a. Types, and Quantity of Wastes Transported
Railroads transport a variety of hazardous materials, including
* **
hazardous waste. Based on waybill samples in 1975 and 1976, 3 per-
cent of rail traffic is waste and scrap materials. This amount of
material, which comprised over 690,000 carloads during the year
studied, is predominantly non-hazardous but certainly includes a
significant amount of hazardous waste. The types of wastes generally
handled by the railroads (as well as other modes) can be found in the
Hazardous Materials Table in 49 CFR 172.101 (Table III-l). The hazar-
dous wastes identified in Table Ili-1 constitute a subset of the total
of some 2000 hazardous materials identified by the railroads, 1300
of which have also been designated as hazardous materials by the DOT.
(The transport of some of these commodities is examined in the next
subsection.) Many hazardous wastes are not specifically identified
in 49 CFR 172.101, coming under either a) headings which specify
classes of commodities not otherwise classified, or b) commodities
that can be either wastes or useable materials.
Table III-2 provides estimates of the annual volume (in carloads)
of selected hazardous wastes shipped on U.S. railroads in 1976. The
total of approximately 3300 carloads of hazardous waste is roughly
equivalent to 200,000 metric tons, which when doubled (arbitrarily)
to allow for incomplete sampling yields an estimate of some 400,000
metric tons of hazardous waste transported annually by rail, or ap-
proximately 5 percent of the 7.9 million wet metric tons per year
of waste transported off-site. (Detailed analysis of 1412 carloads
of spent sulfuric acid and four carloads of scrap battery parts
shipped between nine origin-destination pairs revealed that on
average each carload contained 69 metric tons of the former waste
*•
The waybill is strictly a carrier document and serves as the his-
torical record of shipment. It is prepared for each carload and
less-than-carload shipment, from the shipping order, which is the
carrier's copy of the bill of lading. All information contained on
the shipping order which concerns the transportation of the shipment
and the services to be performed by the carrier is transcribed to
the waybill. It moves with the freight from origin to destination,
regardless of the number of carriers over which the shipment is
transported.
** 1977 Yearbook of RAILROAD FACTS, Association of American Railroads.
III-4
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TABLE III-l
WASTES LISTED IN THE
HAZARDOUS MATERIALS TABLE (49 CFR 172.101)
Acid, sludge
Aluminum dross, wet or hot
Aniline oil drum, empty
Arsenical dust
Arsenical flue dus£
Bags, burlap, used
Bags, sodium nitrate, empty
and unwashed^
Barrel, empty
Battery parts (plates, grids,
etc.) unwashed, exhausted)
Black powder igniters with
empty cartridge bag
Bottles, not cleaned *
Burlap bag, used and unwashed,
or not cleaned
Burnt cotton, not repicked
Burnt fiber
Carboys, empty *
Cartridge cases, empty,
primed ^
Container, reused or empty
Cotton batting dross
Cotton waste or sweepings
Cotton waste, oily
Cylinder, empty*
Drums, empty
Dusts, by-product, poisonous
Empty cartridge bag with
black igniter
Empty cartridge case, primed
Excelsior (shredded wood)
Felt, waste
Felt, waste, wet
Fibers, burnt
Flue dust, poisonous
Garbage tankage
Gas drips, hydrocarbon
Grenade, empty, primed
Hair, wet
Iron mass or sponge, spent
Lead dross
Magnesium dross, wet or hot
Magnesium scrap
Metal borings, shavings,
turnings, or cuttings
Nickel catalyst, wet, spent
Nitrating acid, spent
Oiled clothing or material
Paper scrap or waste
Propellant explosives in water,
unstable, condemned, or deteriorated
Pyroxylin plastic scrap
Rags, oily or wet
Rocket ammunition with empty projectile
Rubber scrap or buffings
Sawdust and wood shavings
Sulfuric acid, spent
Tank car, empty*
Tank, portable, empty*
Tank truck, empty
Waste paper, wet
Waste textile, wet
Waste wool, wet
Zirconium scrap
Previously used for a hazardous
material.
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TABLE III-2
ESTIMATED ANNUAL VOLUME OF SELECTED HAZARDOUS WASTES
SHIPPED ON AMERICAN RAILROADS
1976
Commodity Carloads
Acid, sludge 94
Battery parts (plates, grids, etc., unwashed,
exhausted) 71
Garbage tankage 1
Lead dross 8
Nickel catalyst, wet, spent 1
Nitrating acid, spent 80
Rags, oily or wet 73
Rubber scrap (only as hazardous material) 2
Sulfuric acid, spent 2965
Total 3295
Source: Association of American Railroads.
III-6
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and 50 metric tons of the latter. With the assumption that carloads
of other liquid and solid hazardous wastes contain similar masses as
do carloads of spent sulfuric acid and scrap battery parts, respec-
tively, the 3300 carloads contain 200,000 metric tons of hazardous
waste.)
Most hazardous wastes received at disposal sites and reclamation
centers are transported in a liquid state by tank car. Other materials,
such as lead dross or magnesium scrap, are transported in gondola cars
or hopper cars.
b. Nature and Extent of Services
Only a few of the surveyed disposal facilities accept hazardous
waste by rail, and these do not receive substantial quantities. The
railroad may deliver a few tank cars per shipment directly to a rail
siding on the facility's property. Rail shipment is generally limited
to large generators, particularly chemical producers, since they are
more capable of filling tank cars. (A tank car can transport up to
34,500 gallons of liquid waste while highway cargo tanks are limited
to 6,000 gallons.) Larger generators often own their own tank cars
while smaller ones lease. Small waste shipments, of course, go by
truck.
The relative dominance of large generators using rail often results in
trips of great distances. The range of distances over which hazardous
waste was transported included short distances (e.g., six miles) to
very long distances (e.g., 2,000 miles). Most examples cited were on
the order of hundreds of miles.
Most hazardous wastes are apparently transported to recovery
facilities as opposed to disposal sites. For example, the most
eommonly transported hazardous waste identified by the railroads
is spent sulfuric acid. Nearly all of this goes to recyclers who
have rail sidings on their own property. Some of the origin-
destination pairs for spent sulfuric acid include Salt Lake City,
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Utah to Martinez, California; Channelview, Texas to Nacadgoces,
Texas; Bay town, Texas to Strang, Texas. Texas has numecous large
recycling facilities that are prominent in the reclamation of several
types of hazardous waste.
In addition to delivering wastes from private siding to private
siding, the railroads are involved in intermodal transport, which
is described in the next section.
c. Intermodal Rail Transfers
Transportation of hazardous waste by rail directly from origin
to destination necessarily involves two facilities with private
sidings. To obviate the need for both shipper and consignee to
have private sidings, an alternative is intermodal rail transport.
The extent of intermodal relative to unimodal rail transport is
difficult to assess. However, its occurrence was cited by rail*-
roads, a very large disposal facility, a reclamation center, a
truck transporter and a generator. It appears that intermodal
transfers constitute a small but still significant portion of rail
hazardous waste shipments.
The reasons for intermodal transfers are varied. Tank car
movements do not often lend themselves to intermodal transfers,
since direct transportation is less expensive and since generators
that accumulate wastes can load tank cars in stages on their own
rail sidings. However, many generators and disposers do not have
their own rail sidings. One large disposal facility that does not
have its own rail siding uses a public siding within a few miles
of the disposal site. In this instance, tank trucks make
several trips to unload the tank cars. Alternatively, smaller
generators sometimes transport hazardous waste by truck to a rail-
road team track. A team track is a rail siding owned by the rail-
road for use by small industries. One instance of truck-rail
piggyback transport of drums to a disposal facility was cited,
Drums of waste in intermodal transport are said not to hold up well.
III-8
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but this was admittedly an insignificant portion of total waste
delivered to the disposal site.
Finally, when water transport is involved, there is often an
intermodal transfer involving rail. A large disposal operation in
the Gulf of Mexico uses a barge operation that is preceded by a
short trip by boxcar.
d. Railroad Equipment
*
Railroad equipment in the United States averages 15 years old
and is 16 percent leased by users. The 1976 car inventory is pre-
sented in Table III-3. As noted, most of the hazardous waste trans-
ported by rail moves by tank car, which are almost invariably owned
or leased by shippers. Occasionally boxcars or covered hopper
cars, primarily owned by the railroads, are used.
Many companies other than railroads own freight cars; some sixty
non-railroads each own at least 300 rail cars. Most of these are
used for -crude or finished products but some are certainly used for
waste.
New tank cars that carry hazardous materials have a maximum
capacity of 34,500 gallons, while the maximum gross weight must
not exceed 263,000 pounds. These tank cars, of course, have a
much greater capacity than tank trucks and can haul materials
more economically over long distances. These two reasons—available
capacity and its cost—explain the role of railroads in hazardous
waste transport. Most hazardous waste transport, however, is
characterized by short distances and small quantities; thus, trucks
are the usual mode of transport.
See Appendix C for illustrations of typical rail cars that haul
hazardous waste,.
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TABLE III-3
Type
Box cars:
Plain
Equipped
Covered ho
Flat cars
Refrigerat
Stock cars
Gondola cars
Hopper cars
Tank cars
INVENTORY OF RAILROAD EQUIPMENT IN UNITED STATES
1976
Total
302,899
171,054
pers 230,069
141,781
r cars 98,017
3,637
s 185,776
365,526
168,018
ht cars 32,250
Class 1
Railroads
281,663
167,426
158,850
98,386
74,936
3,559
172,789
343,186
2,905
28,005
Other
Railroads
10,812
2,722
1,074
908
2,956
—
4,641
9,859
17
1,463
Car
Companies
and
Shippers
10,424
906
70,145
42,487
20,125
78
8,346
12,481
165,096
2,782
Total
1,699,027 1,331,705
34,452
332,870
Source: Association of American Railroads.
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e. Containerization Practices and Personnel
Containers for transporting hazardous materials are specified
by DOT regulations in 49 CFR 174, 178, 179. These define all types
of containers, including smaller containers placed within railcars
and the railcars themselves. Materials that are hazardous waste
but not considered to be DOT hazardous materials must be contained
according to the Uniform Freight Classification codes. As a result
of the DOT regulations for tank cars and containers, these vehicles
are generally dedicated for carriage of hazardous materials.
Railroad personnel are not involved in direct handling of
hazardous wastes; they merely accept tendered shipments. Genera-
tor and disposal facility personnel, respectively, prepare and
receive shipments. Personnel at disposal facilities are involved
in the reception of wastes from all transport modes rather than
specializing by mode. Certification of railroad employees involved
in the transport of hazardous materials (or waste) is not required
by Federal regulations. Employees are trained by the railroads,
but as noted previously, carriers do not directly handle hazardous
materials. DOT regulations are excerpted in the MR Bureau of
Explosives Pamphlet 20 for railroad employees, which serves as a
useful working guide. The Bureau of Explosives offers special
training courses in emergency handling of hazardous materials.
f. Operations
Prenotification of delivery is uncommon in the railroad industry.
Dispatching and control in route is handled by railroad personnel.
Interchange of carloads in rail shipments is common (over 50 percent
of rail shipments are handled by more than one carrier).
The shipper certifies* on the bill of lading that the shipment
conforms to DOT regulations; however, there is usually no formal
verbal acceptance (documented or otherwise). After a rail car is
49 CFR 172.204 requires that the shipper certify on the shipping
paper that "...the above-named materials are properly classified,
described, packaged, marked, and labeled and are in proper condition
for transportation according to the applicable regulations of the DOT.
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accepted for delivery, the railroad simply delivers it to the
consignee. The delivered car is moved to the appropriate rail
yard or siding, at which time the consignee is duly notified.
As noted previously, generator personnel (or a consolidating agent)
load the shipment, and disposal or reclamation facility personnel
unload it. For any hazardous material, proper storage facilities
must be provided at the destination; for tank car contained
material, loading cannot be done on a carrier siding unless a
private one is unavailable.
g. Marking, Labeling, and Placarding
DOT hazardous material marking, labeling, and placarding
requirements are found in 49 CFR 172. Generally speaking,
marking and labeling requirements apply strictly to the shipper,
whereas placarding requirements apply to both the shipper and
carrier.
In general, each rail car or container offered for shipment
must be placarded on four sides if the car or container carries
a DOT-specified hazardous material. Since some wastes are con-
sidered environmentally hazardous by the EPA but may not be a DOT
hazardous material, marking, labeling, and placarding requirements
do not presently apply to all hazardous wastes.
h. Handling of Spilled Materials
The larger U.S. railroads have departments dealing with safety
and spill prevention or hazardous materials control, and maintain
24-hour emergency response offices. Field personnel have special
training in leak and spill response, but in general the emergency
£
offices rely on shippers, consignees and CHEMTREC for assistance
and advice. The shipper and consignee are usually notified first.
Hazardous materials incidents must be reported at the earliest
practicable moment to the DOT if death or injury requiring
Chemical Transportation Emergency Center, operated 24 hours a day
by the Manufacturing Chemists Association.
111-12
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hospitalization occurs, property damage exceeds $50,000, or
radioactive or etiologic agents are breached; a detailed report
must be submitted to the DOT within fifteen days of the date of
discovery (49 CFR 171,15-.16). In addition, leaking tank cars must
be stopped in transit until repair is made.
4. BUSINESS/ADMINISTRATIVE PRACTICES
a. Shipping Documents
The relevant shipping documents for the transport of hazardous
waste by rail are the bill of lading and the waybill. The bill of
lading, which includes such standard information as shipper, con-
signee, date, description of goods shipped, and routing, originates
the shipment and is prescribed by the ICC in 49 CFR 1035. Addi-
tionally, it serves as 1) a receipt that the carrier received the
property specified on the bill of lading, 2) the contract of
carriage, and 3) documentary evidence of title to the goods shipped.
Under the Interstate Commerce Act, Section 20(11), a common carrier
must issue a receipt or bill of lading. Thus it is the carrier's
legal duty to issue the bill of lading, although the shipper fre-
quently does so as a convenience to the carrier. Any errors on
the bill of lading which the carrier has sufficient information
to detect when accepting the shipment,are the responsibility of
the carrier. For hazardous materials, 49 CFR 172 requires that
shipping papers (bills of lading) include: 1) proper shipping
name, 2) hazard classification according to 49 CFR 172.101, 3)
total quantity of material, 4) placard notation, and 5) shipper's
certification that the shipment is in compliance with DOT regula-
tions. The railroad is ordinarily required to accept faithfully
the certification of the shipper.
*For a more complete discussion of shipping papers for all modes of
transportation, see Kenneth V. Flood, Traffic Management, Win. C. Brown
Company Publishers, Dubuque, Iowa, 1975. Another document is the freight
bill, or the carrier's invoice.
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The bill of lading is ordinarily presented to the authorized
agent of the railroad and the railroad prepares a waybill for the
train crew. The waybill is the document of transit and generally
includes the information on the bill of lading plus- the standard
transportation commodity code and a special endorsement. At inter-
changes a copy of the waybill is forwarded or, if necessary, a new
one is produced. At the destination office of the railroad, the
waybill is sent to the accounting department for auditing and
filing. The crew transferring the rail car to a private siding
does not have to possess a copy of the waybill if the move is con-
considered a switch or transfer. Upon delivery the consignee
is notified, but there need not be any transfer of papers. For
consignees owning rail sidings, notification is the act of delivery
to the siding. For other consignees, notification is usually done
with a delivery ticket.
The rail shipping documents for intermodal transfers are
identical to those used on direct rail shipments: the bill of
lading and the waybill. The railroad is concerned only with its
part of the intermodal trip, i.e., from a single origin to a
single destination. Additional paper-work does not arise. If
the shipper uses additional carriers (e.g., a freight forwarder),
then these carriers must have on file a copy of the bill of lading
(certified if the material is hazardous). In the latter case, the
freight forwarder does not have to certify its bill of lading to
the railroad.
As noted previously, copies of the certified bill of lading
and waybills must be kept on file by the originating carrier for
at least three years (by ICC regulation). The railroads inter-
viewed all maintain shipping data in an internal computer system.
Samples of shipping documents are presented in Appendix D.
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b. On-Site Storage and Operator Training
As noted previously, there is no formal certification for rail-
road employees who transport hazardous materials. DOT regulations
also affect, however, many other aspects of transit, handling, and
delivery (49 CFR 174).
Some of these other regulations are highlighted here. In
switching yards, loaded tank cars cannot be cut off until the pre-
ceding car or cars clear the ladder track, and certain tank cars
with compressed gas cannot be set loose. No hazardous material
of any type can be transported on a train carrying passengers. At
delivery, hazardous materials must be removed from carrier property
within 48 hours. At private sidings, secure storage must be pro-
vided or the consignee must receive it in person. Railroads do
not intentionally store hazardous materials, although such may be
the case during switching operations; nevertheless, 49 CFR 174.14
requires that movements be expedited.
c. Maintenance
Maintenance of tank cars is of particular importance. Punc-
tures, the presence of contaminants, and rupture of tank car
safety discs have been cited by railroads as potential problems
in the carriage of hazardous materials. Tank car integrity in
general is the responsibility of the shipper. The railroad is
required to inspect tank cars when offered for transport initially
but the shipper is required to maintain the car in proper condition
thereafter.
d. Insurance
The larger railroads are primarily self-insured up to at least
$1 million for both the cost of spill clean-up and for potential
bodily injury and property liability claims. There are no Federal
financial responsibility requirements to meet carrier liability,
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but most railroads carry high amount umbrella policies covering
sudden and accidental damage ($5 million up to $100 million)
from such underwriters as Lloyds of London to cover both personal
and property liability and involuntary spill clean-up.
5. REGULATORY CONTROL
a. Safety
Federal regulations pertaining to rail transport of hazardous
materials are found in 49 CFR 171-174, 178, 179. All railroads
and other parties interviewed stressed the high degree of compli-
ance with DOT regulations. These regulations identify hazardous
materials and stipulate the containerization, handling, loading,
and placarding requirements described earlier, some of the record-
keeping procedures, and certain safety procedures. Identified haz-
ardous materials number over 2,000 and are assigned to hazard
classes. Handling, loading, switching, location within train and
delivery practices are often broken down by hazard class.
The Federal Government has traditionally exerted strong pres-
sure in the areas of railroad safety and the transportation of
hazardous materials. Accidents in the late 1960's led to promul-
gation of improved standards for certain tank cars. These accidents
resulted from tank cars that were uninsulated and were carrying up
to 40,000 gallons of cargo. Revised standards limit tank cars to
a capacity of 34,500 gallons, require head shields for uninsulated,
pressurized cars, and restrict handling of these tank cars in rail-
road yards. In the Federal Railroad Safety Act of 1970, DOT assumed
jurisdiction over all aspects of railroad safety including standards
for track, brakes, couplers, signal systems, locomotives, freight
cars and other equipment, operating rules, hours of service of
employees, etc; these regulations are found in 49 CFR 211-257.
States are allowed to have more stringent regulations where a parti-
cular local safety hazard exits.
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The military services have their own set of Joint Services
Regulations, which largely reiterate DOT regulations. Each mili-
tary service has its own transport department, and the Military
Traffic Management Command (MTMC) arranges for commercial carriers
and monitors regulations. Compliance, however, is the responsi-
bility of the individual military services.
b. Business Practices
As common carriers subject to the provisions of Part I of the
Interstate Commerce Act, railroads are obliged to accept for de-
livery any commodity in their tarrif that is properly packaged and
tendered for shipment. Railroads are required under 49 CFR 1220
to preserve certain records for minimum periods of time. Specifi-
cally, the shipping documents cited in Table III-4 must be preserved
for at least three years.
Railroads are also required under 49 CFR 1248 to compile and
report freight commodity statistics on the basis of a 5-digit Com-
modity Classification for Transportation Statistics (49 CFR 1248.100)
Unfortunately, the commodity code does not specifically identify
hazardous wastes, but does classify waste generally as shown in
Table III-5.
6. SOME REGULATORY COMPLIANCE PROBLEM AREAS
The railroads contacted all expressed satisfaction with the DOT
hazardous materials regulations and with the 49 Series Standard Trans-
portation Commodity Code (STCC), as it applies to hazardous materials.
The STCC code may be of considerable value in the event of an accidental
release of hazardous wastes. The system can potentially identify
100,000 hazardous materials. The first 50,000 numbers available have
been set aside for identification of DOT hazardous materials. The re-
maining 50,000 numbers are available for identification of hazardous
waste, hazardous substances, or other materials which are deemed
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TABLE III-4
SHIPPING AND AGENCY DOCUMENTS TO BE PRESERVED
(49 CFR1220)
Bills of lading and releases:
(a) Consignors' shipping orders, consignors' shipping
tickets, and copies of bills of lading, freight
bills from other carriers and other similar docu-
ments furnished the carrier for movement of freight
(b) Shippers' order-notify bills of lading taken up and
cancelled
Freight waybills:
(a) Local waybills
(b) Interline waybills received from and made to other
carriers
(c) Company freight waybills
(d) Express waybills
Freight bills and settlements:
(a) Paid copy of freight bill retained to support receipt
of freight carges
(b) Paid copy of freight bill retained to support receipt
of freight charges to other carriers
Other Freight Records:
(a) Records of freight received, forwarded, and delivered
(b) Notice to consignees of arrival of freight; tender of
delivery (two year retention)
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TABLE III-5
COMMODITY CLASSIFICATION FOR
TRANSPORTATION STATISTICS (49 CFR 1248.100)
Code Description
40 WASTE AND SCRAP MATERIALS
401 Ashes
402 Waste and scrap, except ashes
4021 Metal scrap, wastes and
tailings
40211 Iron and steel scrap, wastes
and tailings
4022 Textile waste, scrap and sweepings
4024 Paper waste and scrap
4026 Rubber and plastic scrap and
waste
42 CONTAINERS, SHIPPING, RETURNED .EMPTY
421 Containers, shipping, returned
empty, inc. carriers or devices
422 Trailers, semi-trailers, returned
empty
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hazardous by regulatory agencies other than DOT. These numbers will
be assigned by the Bureau of Explosives and used by railroads in
developing emergency response and data retrieval systems.
At present whether a waste is a hazardous material is dictated by
the regulations found in CFR Title 49. Clearly, all environmentally
hazardous materials and wastes are not presently covered by DOT regulations.
The railroad industry believes that EPA regulations for hazardous waste
transport should conform to the current DOT requirements, including
commodity identification and establishment of a new classification
system, if needed. The railroads are concerned that conflicting,
overlapping, and/or contradictory hazardous waste regulations would
create a highly confusing regulatory environment.
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B. TRANSPORT BY MOTOR CARRIER (FOR-HIRE)
1. METHOD OF APPROACH
a. Sampling
This section characterizes the transport of hazardous waste by
for-hire motor carriers (common and contract) that are not also en-
gaged in the operation of hazardous waste management facilities
(treatment, storage, or disposal). These carriers convey hazardous
waste from the generator's premises to the place of treatment,
storage, or disposal.
Initially, only very limited information identifying'for-hii;e motor
carriers was available. A first step was to contact various national
associations, such as National Tank Truck Carriers, Inc. and the Ameri-
can Trucking Associations, Inc. (see Table II-l). These associa-
tions did not have information readily available on members who were
transporting (hazardous) waste. Regional EPA offices were then con-
tacted to obtain lists of companies invited to and attending the ten
regional public participation meetings on the development of RCRA
Section 3003 standards; these listings offered only a few (12) for-
hire motor carrier contacts. In preparing invitation lists, the
regional EPA offices relied mainly on the individual state waste man-
agement offices to supply listings of transporters. The regional of-
fices did identify those.states which have hazardous waste transporter
permit systems and those which have newly implemented programs.
Several states that have a transporter permit system or a regis-
tration requirement were contacted and a listing of companies requested.
From the lists obtained it was necessary to identify those companies
involved only in the transport of hazardous waste as distinct from
those also operating hazardous waste management facilites. This in-
formation was compiled and later a "representative" sample was chosen
for telephone contact or personal visit. Listings were obtained for
California, Indiana, Massachusetts, Michigan, New York, Texas, and a
partial listing for New Jersey.
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Many of the states contacted had used the Telephone Yellow Pages
Directory to collect names of transporters when a formal system for
transport company identification was unavailable. Following this
example, a survey was conducted of the Yellow Pages of major metro-
politan areas across the country. Names were located under listings
such as: pumping contractors; waste reduction, recovery and dis-
posal—industrial; trucking—disposal contractors. Most of these
companies were readily identified as HWMF*/transporters, but a number
were also found to be for-hire motor carriers.
With the paucity of information available on the companies
involved in for-hire motor carriage of hazardous waste, there can
be no truly representative sample drawn for the purposes of this
study. However, an attempt was made to develop information based
upon a transporter sample using what is currently understood about
the generation and disposal patterns for hazardous wastes. This
sample addressed such variables as: geographical area; urban/
rural; large firm/small firm; firms regulated by the State/firms
not regulated by the State; firms which handle only (or mostly)
hazardous wastes /firms which only occasionally handle hazardous
wastes/firms which handle both hazardous and non-hazardous wastes
on a regular basis, common/contract carrier, publicly/privately-
owned firm, type of waste (by generating industry such as pharma-
ceutical, chemical, petroleum, batteries, etc.).
A total of 72 contacts were made with companies initially
identified as transporters of hazardous wastes. These telephone
calls resulted in the following:
Related and responding 36
Related and not responding 16
Not related 20
Not responding 6
Total 78
* Hazardous Waste Management Facility
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A listing of the companies contacted as transporters of hazardous
wastes (excluding the generators and the hazardous waste management
facilities that also transport) is presented in Appendix B-2.
2. FACILITIES AND SERVICES PROVIDED
a. Geographic Region Served
About half of the for-hire transporters contacted stated
that they did not transport any hazardous waste across state borders.
Others indicated that from 80 to 100 percent of their hazardous waste
transport business was interstate. These figures may relate only
to the companies contacted and may not be entirely representative.
In addition, the quantities of hazardous waste transported inter-
or intra-state could not be identified. In most cases, companies
could not estimate even the total quantity of waste (hazardous and
otherwise) transported. One firm reported transporting 40,000
gallons per week interstate; this was the only operation of the
facility.
The for-hire transporters contacted range from firms that have
one business location only to firms of national carrier status that
have sixty or more terminals across the country. Most of the firms
have only one location, several have between two and four locations.
Transport companies are located where there is waste to transport.
Where the concentration of industry is low, usually the generator
or a hazardous waste management facility provides the transport.
b. Ownership
All firms contacted are privately owned or closely-held stock
corporations (with perhaps the exception of Chemical Leaman and
Matlack, Inc.).
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c. Fleet Size and Number of Employees
The distribution of fleet size for the firms responding to this
study is shown in Table II1-6. Some of the national tank truck carriers
have nearly 3000 tank cars in operation. Nearly all of these handle
hazardous materials at some time, of which some portion also handle
hazardous wastes. These common carriers generally have less than one
percent of their business in hazardous wastes, and their records do
not readily lend themselves to answering questions quickly on hazar-
dous waste operations. Most firms contacted, however, had on the
order of 1 to 30 trucks, with few vehicles devoted to the handling
of hazardous wastes, though in some cases a stainless steel or
specially lined tank truck was dedicated to caustic or corrosive
wastes.
Firms were identified with 1 to 250 employees (excluding the
larger common carriers). Anywhere from less than one percent to
100 percent of these employees were involved in transport. In
those companies where less than 55 to 60 percent of their employees
are involved in transport, the company was conducting another busi-
ness activity, such as tank cleaning and maintenance. Often the
transport firms have maintenance shop personnel and clerical help
that made up the remaining 40 to 45 percent of the staff.
d. Services Provided
The transporter wants to provide a total service package to the
client/generator. For this reason, some smaller transporter may
accept a waste that he has never handled before and then search for
a facility to accept it. If this proves to be difficult, the trans-
porter might find it necessary to store the waste until a disposal
facility is found. Nevertheless, transporters indicate that wastes
are stored only on an infrequent basis and then only for a short
time. One company described the time period as about a week.
Firms contacted vary from having less than 0.1 percent to 100
percent of their transport business in hazardous waste; however, the
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TABLE III-6
FLEET SIZE DISTRIBUTION—FOR-HIRE
MOTOR CARRIERS
Number of Vehicles Percent Of
In^'Fleet Total Vehicles
1-5 35
6-15 17
16-30 17
31-500 17
501-2000 5
2001-3000 9
100
Total
Source: Arthur D. Little, Inc., estimates.
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total quantity of hazardous waste transported annually by these firms
is unknown. Large interstate common carriers handle significant quan-
tities of hazardous waste but it is only a very small portion of their
business (less than 1 percent in most cases). Many other firms started
out handling all kinds of waste and the "hazardous" label of their busir
ness came with the promulgation of state hazardous waste regulations.
Very sketchy information was made available on the nature of the
wastes transported. The following kinds of wastes were mentioned by
respondents: liquid/solid sludge, waste oil, solvent for recycling,
general hazardous trash, paint waste, hydrocarbon waste, chlorine
waste, acids (HC1, nitric), cyanide waste, caustic waste, hydrogen
fluoride waste, cleaning solution waste, radioactive waste. Some
transporters specialize in handling a particular waste such as waste
oil or spent acid; most transporters handle various types of hazardous
wastes. The frequency with which these wastes are collected varies
considerably. Often collections are made only when requested; others
are scheduled in advance, perhaps collections being made once a day.
Many estimates of the quantities of hazardous waste transported
are suspect because the definition and interpretation of what con-
stitutes a hazardous waste varies by state and by company within
the state. Often the smaller transporters appeared unaware of the
hazardous nature of much of their business. In addition, their view
of hazard is colored by the wear on their trucks, the safety of
their drivers, and the potential severity of any road accidents.
Many do not think in terms of environmental contamination at this
time.
Only one transport company was found to have its own laboratory
facilities for analyzing wastes. This company also provides con-
sulting services on the disposal of wastes, performing the analysis
as a service to their clients (as well as for their own protection).
Most of the transporters rely totally on the generator to supply any
necessary analyses such as those to identify the material for disposal
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site approval, or for general characteristics as required for vehicle
container specification. About 20 percent of those responding have
contracted with an outside laboratory to provide chemical analyses
for their clients, particularly for wastes the transporter has never
handled before. The charge for the laboratory analysis is added to
the generator's bill, but the laboratory is paid by the transporter.
The firms contacted have been in business from 5 to 58 years.
Their activities in hazardous waste transport range from 1 to 58
years. For the most part, the firms have been transporting similar
waste since they first started business. Obviously, the firms in
business for 58 years have seen a marked change in the known hazar-
dousness of the materials they handle. About 15 to 20 percent of
the firms contacted state that they had operated for a number of
years transporting relatively non-hazardous wastes prior to extending
operations to include hazardous wastes. Many of the firms sense
that there is a substantial growth opportunity in transporting
hazardous waste.
3. TRANSPORTATION ACTIVITIES
a. Extent of Services
Firms that have diverse business operations were contacted. Some
were servicing a metropolitan area, others an entire state, and still
others transport waste several hundred miles for resource recovery or
disposal. Most of the smaller operations have a service radius be-
tween 25 and 150 miles. Within those states where permits are
required, the companies usually provide statewide service.
The typical distance per trip (two-way) ranges from 25 to 150
miles, the most frequently cited distance being 50 miles. This ex-
cludes the national common carriers who did not provide estimates
(one, however, did indicate that 500-to 600-mile trips were normal).
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b. Age and Types of Vehicles, Utilization Rate
The majority of the vehicles identified are tank trucks. There
are a number of vacuum trucks ' (i.e., tank trucks with a vacuum unit
attached for suction of liquids), and considerably smaller numbers
of vehicles such as stake-body, flat-bed trucks (for hauling drums),
dumpsters, compactors, dump trucks, "roll-off" trucks, hopper trucks,
vans and pickups. Some of these are illustrated in Appendix C.
Only one pressurized tank truck was discovered. Although mention
was made of heated tank trucks used for hazardous waste, no transport
companies were discovered who have these specialized vehicles. Ex-
cluding the national common carriers, there are eight times as many
tank trucks as vacuum trucks, and far fewer still of all the remaining
types of vehicles.
The capacity of tank trucks ranges from 1200 to 8600 gallons. Many
firms have a fleet with the same size vehicles or only a couple of
sizes, while others have a variety of truck sizes. This may indicate
that the latter are acquiring trucks when bargains appear or are pur-
chasing used equipment as it becomes available. The stake-body, flat-
bed trucks are estimated to carry 35 to 65 drums. Some companies
indicated their intent never to stack drums in more than one level to
avoid the increased chances of spillage. Data obtained from the State
of California's manifest system during the period November 1977-March
1978 indicate that the average quantity of hazardous waste shipped by
truck (all carriers—common, contract, private) per manifest is 21.6
short tons, equivalent to 5200 gallons if the waste has a density equal
to that of water (8.3 pounds/gallon). However, because a single mani-
fest may suffice for multiple identical waste shipments between the same
origin and destination points carried by a single truck on a given day,
the cited average shipment quantity is likely to be biased high.
Those firms that responded indicate that most of their vehicles are
under 6-8 years old—at most 15 years for a truck devoted to waste oil.
Some companies did not know the "useful life" of their vehicles, while
others stated that it ranged from five to ten years. Several companies
responded that seven years is used for accounting (depreciation) purposes,
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but that "useful life" is considered to be about eight to ten years for
all equipment, except the unlined vacuum trucks with an estimated useful
life of five years. One firm purchased "good used equipment" and indicated
that a used tank truck would last about three years.
Most of the companies contacted did not have data readily available
concerning the intensity of vehicle use. This is understandable because
many of the companies are small with little record keeping capability
of this type. Small operations seem to rely on judgment to determine
whether additional equipment is needed or whether maintenance is be-
coming a problem.
Some companies mentioned a ten-hour per day state-enforced time
limit on their drivers. Others indicated that trucks are in use an
average of 10 to 14 hours per day, including standing time. (In
general, a truck is "utilized" whenever it is out of the yard.)
c. Containerization Practices
Hazardous waste materials move primarily in liquid bulk in tank
or vacuum trucks; however, drums are used widely. Usually the genera-
tor contains the waste in the drums prior to collection. Three
separate and independent estimates (by industry and state government)
place truck (common, contract, private) transport of hazardous waste at
75 percent bulk (e.g., tanker) and 25 percent packaged (e.g., 55-gallon
drums).
d. Transport Personnel
Most firms have only a one-man crew on each vehicle, particularly
in the case of tank trucks and vacuum trucks. If drums are to be
loaded onto a stake-body truck or into a pick-up or van at the genera-
tor's site, then a helper would occasionally accompany the driver.
Few transport companies allow their employees to load drums, insisting
that the generator do so with a forklift truck employing their own
personnel, perhaps with some assistance from the driver.
e. Initiation of Transport Services
Arrangements for transport of hazardous waste are usually initiated
in either of two ways: 1) generators contact transporters through re-
commendations and/or printed advertisements; or 2) generators respond
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to a transport company-originated "sales approach." Transporters then
discuss with generators the waste stream in question, and the provision
of waste samples for laboratory chemical anslysis. The transporter
then determines whether he is able to move the waste to appropriate
facilities, designated or not by the generator. The more capable
and experienced generators will usually independently evaluate the
transporter's competence to handle the waste. Many small generators
may give no consideration, except that of price, to the transporter's
qualifications. At this time, transport charges are also discussed. If
a mutual agreement is reached, the transporter may either arrange
immediately a pickup schedule, or indicate that services will be
rendered upon request.
Some transporters did indicate that multiple stops are made when
drums are collected or when the clients are well-known and the wastes
are compatible. This activity is not a general practice and appears
to occur among small operations only.
f. Routing/Dispatching
Most firms who responded indicate that there is little time
allowed for scheduling and routing; often as little as one hour to
one day notice is given by the generator, even when a contract is
signed for services. Some larger generators are serviced routinely,
for example daily. To facilitate collection, trucks may be radio-
dispatched.
g. Loading/Unloading
The process for loading and unloading trucks differs by the form
of waste and type of vehicle (e.g., bulk liquid in tanks versus drummed
waste on a stake truck). Tanks are unloaded and loaded via a hose coup-
ling through a vacuum pump, pressure or gravity-feed mechanism. Drummed
material or uncontainerized solid material may be palletized or may
lie on the bed of the trailer. In the latter case, where the cargo
lies on the bed of the trailer, the truck driver is heavily involved
with loading and unloading operations and is required to manually handle
the cargo.
A common delivery condition for cargo touching the truck bed is
"tail gate delivery", whereby the truck driver moves the packaged cargo
to the tailgate end of the truck, where it is removed by the recipient.
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Another form is "hand-off delivery", whereby the truck driver hands
the cargo to the recipient of the cargo. This latter method
would be common where pails are the form of cargo container. In
cases where the cargo is palletized, a forklift truck is typically
driven onto the truck bed to remove cargo. In this case, the truck
driver does not unload the truck.
Whenever a vacuum truck is used, the driver is responsible for
loading the truck and unloading it at the disposal or treatment
site. Wastes are pumped out of lagoons, diked areas and, in some
cases, drums at the generator's location. Some difficulties were
mentioned when pumping out of drums, e.g., mislabelled materials
in drums or incompatible wastes to be .mixed inside the tank. In
one instance, the mixed waste created back-pressure in the tank,
spraying the wastes out the suction hose. (No one was injured
but everyone had to run for cover because the hose was whipping
around.)
When stake-body trucks are used, the generator is normally
responsible for loading with a forklift truck. Some transporters
indicated that generally drums are not stacked on top of each other,
and that drums will not be transported unless they are in reason-
ably good condition.
"Boxes" (i.e., roll-off containers and transfer trailers) were
mentioned several times as transport containers for drums. In these
cases, the generator is responsible for loading the drums into the
container, and calling the transporter when it is full. Each trans-
porter requires that the drums be loaded to their own specification
and that the generator reload them if unsuitable. Unloading opera-
tions at the disposal site were not clear. Sometimes the disposal
site would handle this operation.
The use of tank trucks depends upon the available equipment at
the generator's site. With larger transporters requiring full loads,
the generator will have on-site liquid storage tanks and the
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associated equipment for loading, which he will operate. Other
\
transporters must contend with a wide variety of available loading
equipment and must occasionally bring their own pumps.
Most transporters prefer contracts that require transportation
to resource recovery operations, because there is considerable wear
on their trucks at landfill sites. Except for liquids which the
driver handles at the landfill (and drums that are occasionally
rolled off stake trucks and pick-up vehicles into a disposal site),
the disposal site seems to be responsible for unloading operations.
No one contacted considers leaking drums a problem. The trans-
porters state that they merely refuse to transport leaking drums,
and the generator must re-drum prior to shipment. In addition, no
one indicated that a waste has ever been rejected by a disposal site
(because the disposal facility is usually contacted prior to arrival
to arrange for fees and schedules).
Multiple pick-ups are not made in transporting "boxes." The
generator loads and pays for the entire container. Occasionally a
stake truck will make multiple stops to pick up drums; however, the
quantity loaded is unknown. The transporters indicated that attempts
are made beforehand to determine if the wastes are compatible by
the generator or an outside laboratory. Multiple stops usually re-
quire planning and are minimized by the need to respond quickly.
Generators usually do not want any unnecessary delays in pick up.
Tank trucks usually operate on a full-load basis unless there
are regular customers with compatible wastes. National common
carriers make fewer multiple stops than other transporters. Small
companies with fewer customers have less opportunity for arranging
multiple stops.
h. Delivery to Disposal Site
Comments varied relating to the choice of disposal site to
which hazardous wastes are transported. A few transporters carry
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to only one disposal site (typically a local landfill). Often this
is a relationship based upon years of tradition, although such ar-
rangements are being modified or rethought as new regulations are
passed by individual states. In some cases the generator/client
specifies the disposal site but this is not prevalent except for the
national common carriers. Generators are, however, taking more in-
terest in where their wastes are disposed.
Many of the firms contacted are offering a complete package that
includes transportation and selection of disposal site, as well as
furnishing to the generator requisite background on current regula-
tions. Such background information has been of more interest to
small and mid-size generators, or to those who only occasionally
have hazardous wastes requiring transport.
Transporters commented on the relatively rapid change in regu-
lations which is leading to fewer available treatment and disposal
facilities and the limitation of some sites to specific wastes.
They are hoping for an information center to assist them in locating
appropriate hazardous waste management facilities. Currently, many
transporters deal with a multitude of facilities, including landfill,
incineration, treatment, and recovery operations.
Some operators of disposal facilities require prearrangements for
disposal service while others do not. Disposal facilities that insist
upon prearrangements usually do so for the following reasons: 1) to assure
that the expected waste can be adequately handled at the facility;
2) to check on the validity of the transporter's permit and the status
of his insurance coverage; and 3) to acknowledge any limitations on
the quantity of waste that could actually be received for disposal.
One firm stated that arrangements for delivery of waste must be made
one day to one week in advance. These and other disposal facilities
may require some form of identification upon arrival, in addition to
the bill of lading, work ticket, or invoice forms normally carried.
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Many transporters indicate that upon arrival at a disposal
facility, a "man in responsible charge" examines the forms describing
the waste load and accepts it with his signature. In the event that
delivery is made after normal working hours, disposal site operators
state that the trucker is either turned away by a guard or the waste
is tentatively accepted by the guard pending chemical analysis and
paper work to be undertaken on the following business day. The pro-
cedure for disposal varies among facilities. In some cases, wastes
are unloaded and disposed of immediately; other facilities may per-
form a laboratory analysis before disposal occurs. In cases where
the disposal facility also maintains pretreatment and/or resource
recovery facilities, the wastes may be taken to storage areas. Dis-
posers receive a copy of the forms describing the waste load, as do
generators.
i. Marking, Labeling and Placarding
Only a few transport firms mentioned state requirements to have
the company name and sometimes the vehicle number marked on the
vehicle.
Transporters stated that they want more and better labeling but
cannot force generators to do this. Labeling, in most cases, is not
rigorously performed. Some generators stencil DOT-type labels on
the drums. Others reuse the original drums and cross off the sup-
pliers' names. Transporters did indicate that minimal or incorrect
labeling of drums has caused some hazardous waste incidents.
Knowledge of placards varied; some companies are not aware of
this identification method. All large interstate carriers contacted
use DOT placards and follow all DOT and ICC regulations. About half
the firms did not use placards; however, some of these are adopting
DOT placards by January 1978. Some placards are permanent stencils
(e.g., flammable); others are flip-type with eight to ten different
designations. Companies suggested that the generator be required to
choose and supply the appropriate placard for waste load identification.
In fact, 49 CFR 172.506 specifies that it is the shipper's responsibility
to provide the required placards to the motor carrier (in interstate commerce).
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j. Handling of Spilled Materials
Nope of the transportation companies contacted stated the occur-
rence of a spillage. They did, however, mention the following
agencies that would be contacted in the event of a spill:
• Highway patrol
• Fire department
• Main office of transporter
• State EPA office
• County health department
• U.S. Department of Transportation.
The notification requirements varied by state, type of transporter,
and type of waste.
k. Intermodal Shipments
Only a few instances of truck/rail and truck/barge operations
were observed; transporters, however, did not provide sufficient
information on these operations. Discussion of rail/truck and air/
truck will be found in Sections III-A3c and III-D3, respectively.
4. BUSINESS/ADMINISTRATIVE PRACTICES
a. Shipping _Documents
The relevant shipping documents for common motor carriers are
the bill of lading and the freight bill; these are entirely analo-
gous to the rail shipping documents. The ICC (49 CFR 1051.11) re-
quires that a receipt or bill of lading be issued by common motor
carriers in interstate commerce, but does not prescribe the exact
form as it does for rail carriage. The bill of lading (Appendix D)
must include the names of the consignor and consignee; the points
of origin and destination; the number of packages, description of
the articles, and weight, volume, or measurement of the property
received. For hazardous materials the DOT requires (49 CFR 172)
that the shipper prepare and certify in writing as correct,
shipping papers which describe the hazardous material (in the same
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manner as previously noted for rail carriage). Often the transporter
completes the DOT shipping paper requirements for the shipper and then
obtains the latter's certification on the document. However, when the
motor carrier supplies the cargo tank for bulk shipments, no certifica-
tion is required (49 CFR 172.204). According to DOT regulation (49
CFR 177.817) the shipping paper must -remain at all times with the
vehicle and in a prescribed location.
Generally speaking, the freight bill in the motor carrier industry
performs both the functions of an invoice and a waybill. At the des-
tination the delivery receipt copy of the freight bill is signed by
the consignee and returned to the driver; the consignee's copy and
the original freight bill are left with the consignee. The freight
bill contains the following information in addition to that on the
shipping paper: the date of shipment, the exact rate or rates
assessed; the total charges to be collected; the route of movement
indicating each carrier participating in the transportation service,
and the transfer point or points through which the shipment moved.
All firms contacted maintain records. The terms used to des-
cribe relevant paper work include the following: generator bill,
bill of lading, freight bill, weigh ticket, invoice, pay-slip, dis-
posal papers, dumping slip, manifest, order request form, ticket
system. Some of these records are required to be reported on a
monthly or annual basis to state environmental departments. In most,
but not all, cases, the shipping paper provides a description of the
waste. In those instances where the waste is not identified well,
it is listed as "miscellaneous processing wastes," etc. Often dis-
posal site personnel are present to weigh trucks in and out, and to
provide weigh tickets so that the disposal site could bill the trans-
porter and complete the required state forms, if any.
The transporters contacted state that records were retained for
at least five or seven years as a result of state, Internal Revenue
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Service, and/or Interstate Commerce Commission regulations (3 years),
in addition to general management practice. One firm, operating in
the New England area, mentioned that records were also retained as
protection against accident liability suits. In some states where
record keeping regulations have recently been implemented (e.g.,
Indiana), the intent is to preserve the forms for at least five
years.
b. Billing Procedures, Charges, and Contract Negotiations
Most companies bill generators for both transport and disposal,
and often these charges are separately distinguished on the invoice.
For certain interstate carriers, ICC regulations require that the
haulage fee be a distinct item. It is difficult to tell from names
or advertisements whether transporters do in fact have their own
disposal facilities. While there are often yearly contracts, the
transporters are still notified when the shipment is ready. The
transporter arranges with the disposal site for disposal fee and
schedule, and then bills the generator.
c. On-Site Storage
Most transporters emphatically stated that no storage for
hazardous wastes was provided. Most of the firms contacted handle
liquid wastes collected in tank trucks. To maintain access to
these trucks, transporters will not use them as storage vehicles.
No transporter was found with liquid storage on-site. A few firms
did indicate that drums of wastes are stored at their location until
a full load is available for transport to the disposal site, or un-
til arrangements can be made with a disposal facility to accept the
waste. One company described the length of storage as about a week
on an infrequent basis. Transporters indicated that economic
incentives governed on-site storage.
d. Driver Tra.ining./Licensine
No special licenses were found to be required for any of the
drivers in companies handling hazardous wastes. The standard state
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truck drivers' licenses are the only requirements. The large inter-
state carriers stated that their drivers are thoroughly trained in
precautions and use of safety equipment. Most other firms have
only on-the-job training, or claim to hire experienced drivers only.
Others have informal training which includes: one to three weeks of
on-the-job training; two to three months of guidance by owner; informal
discussion sessions—breakfast meetings; monthly meetings with guest
speakers; weekly meetings on basic safety and truck operations; and
quarterly meetings on basic safety and truck operation. One firm
mentioned that they are starting a safety program with the help of
the Occupational Safety and Health Administration.
e. Safety Practices
Questions related specifically to the use of safety equipment
were not asked; however, it was discovered that most trucks carry
fire extinguishers; interstate carriers are so required by 49 CFR
390-397. While mention was made of gloves, masks and goggles, it
does not appear that safety equipment is considered a highly impor-
tant aspect of operations, particularly with the smaller transporters
who also handle non-hazardous wastes. The large interstate carriers
are more versed in safety procedures.
f. Vehicle Maintenance
Many firms perform standard tank cleaning between loads (unless the
vehicles are dedicated to one waste such as waste oil). Often stan-
dard maintenance involves only checks on tires and engines with other
repairs made by outside personnel. For some firms, tank repairs are
carried out by the firms' own employees.
g. Special State Regulations
About one-third of the firms mentioned some inspection or certi-
fication requirement other than the Standard State Vehicle Inspection
required of all vehicles. Some states (including Massachusetts) re-
quire a one-time inspection at the initiation of a collection permit.
Others (Indiana, for example) require annual re-inspections. The
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California Health Department requires a once-a-year inspection. Some
tank truck manufacturers certify the vehicles, re-inspect every two
years, and recertify after five years as a service to their customers
(required by DOT regulation).
The following miscellaneous comments were made in relation to
relevant state regulations:
• Michigan requires a transport permit and surety
bond in the amount of $15,000 for in-state companies and
$30,000 for out-of-state companies.
• Texas specifies the minimum insurance coverage.
• California specifies the minimum insurance coverage.
Answers varied from $200,000 to $500,000 and may depend
upon the vehicle type.
• Oklahoma makes transporters liable for spills through
negligence by imposing fines up to $25,000.
• Numerous states require collection permits and hauler
certificates.
5. REGULATORY CONTROL
a. Safety
Federal regulations pertaining to interstate transport of
hazardous materials by public highway are found in 49 CFR 171-173,
177, and 178. These standards contain regulations for acceptance
of materials for transportation, loading, unloading, handling,
storage of hazardous materials, leaking containers, accident/spill
reporting requirements, coutainerization, and detailed requirements
for specific classes of hazardous materials. Furthermore, motor
carriers transporting hazardous materials in interstate commerce
must comply with DOT Motor Carrier Safety Regulations (49 CFR
390-397). Many states have adopted DOT Hazardous Materials
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Regulations and Motor Carrier Safety Regulations in their entirety
or in part or have similar regulations in effect. The foregoing
regulations apply to transporters conveying hazardous wastes which
meet the definition of hazardous materials.
b. Business Practices
ICG-regulated common motor carriers must accept for delivery
any commodity in their tariff that is properly tendered for ship-
ment. All motor carriers subject to the provisions of the Inter-
state Commerce Act are required under 49 CFR 1220 to preserve the
shipping documents cited in Table IIl-4,for at least three years, and
under 49 CFR 1248 to compile and report freight commodity statistics
annually (see Table III-5 for waste and related codes).
Motor carriers engaged in the transportation of waste products
for recycling or reuse in furtherence of recognized pollution con-
trol programs must file for a special certificate of public conven-
ience and necessity (49 CFR 1062.1).
However, motor carrier transportation of hazardous waste considered
by the generator to be devoid of economic value would appear to be
ICC-exempt by analogy on the basis of a recent Commission ruling.
On May 10, 1978, the Commission, in decision 129 MCC 339, declared
that the transportation by a contract carrier of nuclear waste which
had no economic value did not involve the movement of property and
was, therefore, exempt. The Commission further declared that its
responsibility with regard to assuring the safe handling of pro-
perty was met by existing Nuclear Regulatory Commission jurisdiction.
The analogy to the transportation of hazardous wastes which are also
DOT-regulated hazardous materials is apparent.
Finally, all motor carrier transportation within specified
commercial zones (e.g., New York City area) is generally exempt
from ICC regulation (49 CFR 1048 ) .
* A state-by-state review of applicable state regulations will be
found in Reference 2.
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C. TRANSPORT BY WATER CARRIER
1. METHOD OF APPROACH
This section presents a characterization of hazardous waste transport
by water on United States inland waterways. Because the quantity of hazar-
dous waste transported by barge on inland waters appears to be small rela-
tive to the conventional truck and rail modes, it has been difficult to
identify the number of carriers engaged in this activity and to assess
transport operations as a whole. However, due to the nature of the barging
business, it is fair to say that at one time or other nearly every firm
engaged in for-hire barging, especially those conveying hazardous materials,
may well transport hazardous waste. For these reasons, the information
presented hereafter is of general nature on the facilities, the transporta-
tion activities, and the business and administrative practices of barge
companies which transport hazardous waste. •
Several water carriers known to transport hazardous materials were
contacted initially; some were suggested by the American Waterways Opera-
tors. These companies supplied information when their operations related
to this study, and often suggested additional information sources when they
did not. A total of seven companies, largely barging operations, were con-
tacted and are listed in Appendix B-3. They are located in Houston, New
Orleans, St. Louis, and on the Ohio River. Obviously, the findings are
limited by the few companies contacted and the method of contact; however,
the_consistency of information obtained indicates some degree.of verification.
Because barges engaged in transporting waste for ocean disposal are
governed by the Marine Protection, Research and Sanctuaries Act of 1972, in-
vestigation of these activities was excluded from this study. Four
governmental agencies (Corps of Engineers, U.S. Coast Guard, Environmen-
tal Protection Agency, and Department of Commerce) participate under
this Act by issuing permits, coordinating and monitoring activities, and
enforcing regulations. Barge transporters must comply with RCRA when
transporting hazardous waste to ports of exit, and when the barge is
stored at dockside. From the time that the barge leaves the dock for
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the ocean disposal site, the Marine Protection, Research and Sanctuaries
Act becomes effective.
2. FACILITIES AND SERVICES PROVIDED
The carriers contacted operate on all U.S. inland waterways. However,
most shipments of hazardous waste move on the Gulf Intracoastal Waterway
and Missouri-Mississippi River System portion of the U.S. waterway system.
A typical one-way trip may originate in the Great Lakes region and termin-
ate in the Houston area, a distance of approximately 1200 miles. No vessels
other than barges have been found to carry hazardous wastes. Whereas most
generators of hazardous waste who ship by rail supply their own rail tank
cars, usually the barge line provides the vessel.
All companies contacted are privately owned. Most barge organiza-
tions are concerns of long-standing, in many cases passing from father
to son. The companies generally operate as contract rather than common
or private carriers. In all cases, the majority of commodities handled
are virgin materials. No company was found to transport hazardous waste
exclusively, or even to a substantial extent. A spokesman for one company
indicated that it was established in 1901, but had been involved with
hazardous waste transport for the past ten years. For this company, waste
transport constitutes less than 10 percent of total operations.
Most often, the hazardous waste transported on the inland waterways
include waste glycol, spent acids, and spent caustics. They are in liquid
bulk form, and it is very common for the industrial waste transported to
have a water content up to 90 percent. All hazardous wastes transported
by the companies interviewed go to resource recovery facilities.
The most commonly used barge for waste transport is a 3-compartment
tank barge with a capacity range of 1200 to 1500 short-tons. Most barges
used by the companies are double-hulled and some have double bottoms for
grounding protection. Information regarding the age and utilization rate
for the barges was not obtained. Illustrations of typical barges appear
in Appendix C.
The Interstate Commerce Act (49 USC 903) exempts most carriers of bulk
commodities by water, particularly liquid cargoes in bulk and tank
vessels certified by the Coast Guard.
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The key personnel in a hazardous material transportation by barge
operation are generally seasoned veterans, having spent a lifetime on
the coastal or inland waters. This would include the navigation and
engineering officers aboard the towboat. There is, however, a very high
turnover of the deck crew—sailors, etc. Many deckmen quit before a
single trip is completed, or complete one trip and never return. College
men to a great extent "sign on" for a trip as ordinary seamen (OS) be-
cause the money is good and a change of scene can be anticipated.
I-
3. TRANSPORTATION ACTIVITIES
a. Prenotification and Acceptance
Arrangements for hazardous waste collection are made prior to
the arrival of the barge. The crew members, who load the waste,
have no involvement with the paperwork. Shipping papers are placed
on the barge by an authorized individual, who also records the
quantity of waste loaded, but bill of lading and other forms are
handled through the mail. There are several copies of the shipping
papers. One copy remains with the barge; another copy of the papers
is with the power vessel, along with a cargo information card that
informs the crew members of the waste that is to be escorted and
the precautions that should be taken.
b. Routing/Dispatching
Most barge companies follow specified travel routes in trans-
porting cargo. To maintain an updated schedule of transport
activities, there is constant oral communication by telephone
or radio between the barge company, the facility shipping or
receiving the waste, and the harbor terminals. The barge com-
panies communicate with tow boat crews regularly to obtain informa-
tion on the "daily position" of the fleet. It is not unusual for
a barge during a trip to change tows one or more time, thereby
being in the custody of different barge companies. The procedures
of accepting and signing for the waste cargo vary with the opera-
tions of the barge companies. Oftentimes, shipments are accepted
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and transferred by radio communications. Any paper work is mailed
before or after the activity occurs.
c. Loading/Dispatching
The loading of the waste into the barge is handled by
a "tankerman." The tankerman can be either an employee of the barge
line or a contracted individual retained by the vessel operator to
handle loading or discharge in any geographical area. The tanker-
man, having proved his competency to the U.S. Coast Guard by obtaining
a license for completing first aid and fire protection safety training,
manipulates valves and onboard pumps in order to transfer the hazardous
waste.
Generally, onshore pumps are used for loading and the pump or
pumps on the marine craft are used for discharge. Either flexible
hose lines or telescoping metal arms are used for the actual transfer.
/
In either case, the transfer line is connected to piping manifolds
on the shoreside pier and on the vessel itself. The entire operation
is closely coordinated between the "tankerman" and the "dockman."
The latter individual, usually a company employee, is responsible
for all shoreside operations associated with the hazardous material
transfer.
Once loaded, the barge is normally secured into a line of barges
pushed to its destination by a "pusher" type tow boat. The number
of barges involved in a single "tow" can be such that a bow thruster
propulsion unit can be installed on the lead barge to handle the
turns effectively in an inland waterway. The controls for the bow
thruster are normally manipulated from the pusher tow boat. The
discharge operation, from an operational standpoint, essentially
duplicates the loading procedure in reverse.
As a general rule, the barges receive a full load at one stop and
discharge their entire contents at the final destination.
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d. Delivery to Final Destination
Upon arrival at the final destination, the waste cargo may be
accepted immediately, or the barge may be placed in a queue, perhaps
for several days. On occasion, particularly when the barge arrives
at night, no personnel may be on hand to accept the shipment. The
barge will then be tied up at the harbor terminal until it can be
received. At this location, an authorized individual checks the
quantity of waste unloaded against documents that have arrived
several days in advance by mail. The shipping papers remain on_the barge
to inform cleaning crews of the previous contents. Subsequently,
no one is particularly interested in these papers; they may be
destroyed by a member of the cleaning crew or remain on board until
they are replaced by new forms when the barge is reloaded.
e. Marking and Labeling
DOT hazardous material marking and labeling requirements for
packaged (non-bulk) commodities are found in 49 CFR 172; these apply
directly to the shipper. Although there is no label that defines a
cargo as "hazardous waste," several labels are used that describe the
danger associated with the hazardous waste being transported. In ad-
dition, red warning flags are positioned strategically on the barge.
f. Handling of Spilled Materials
No company indicated the occurrence of a spillage. The companies
did mention that in the event of an incident involving hazardous
materials the Coast Guard would be appropriately notified (in accord-
ance with 46 CFR 2.20-65).
g. Intermodal Shipments
No substantive information was obtained regarding intermodal
shipments of hazardous waste materials. A few companies did indi-
cate the ability to coordinate operations with rail and truck modes
at certain locations.
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4. BUSINESS/ADMINISTRATIVE PMCTICSS
a. Shipping Documents
The bill of lading, weigh ticket, and shipping manifest (Appen-
dix D) are the comnnly used shipping documents for transport of
hazardous waste by water. These records serve several purposes
which include billing, taxes, lost cargo claims, and compliance
with regulations. Handling of the shipping papers has been pre-
viously described. The retention period for records varied among
companies interviewed; however, 49 CFR 176.36 requires that ship-
ping papers, cargo lists, and other documents be preserved by the
carrier at his place of business or office in the U.S. for at least
one year after their preparation (packaged commodities only). The
companies stated that records are retained in current files for 5-7
years because of legal requirements, as well as administrative pro-
cedures. In the event of a marine casualty (46 CFR 4.05), voyage
records must be retained.
As described below, shipping paper requirements differ for
packaged versus bulk cargo.
Packaged Cargo
Shipping paper requirements for vessels carrying DOT hazardous
materials (excluding bulk carriage) are governed by 49 CFR 172, and
include the complete description of the hazardous material (proper
shipping name, hazard class, total quantity of material) and the
shipper's certification. Each shipment by water must have the
following additional shipping paper entries: identification of
the type of packages (e.g., barrels, drums, cylinders, boxes);
number of each type of pacakge; gross weight of each type of
package or the individual gross weight of each package.
The above requirements directly apply to the shipper; however,
the carrier may not transport a hazardous material by vessel unless
*
Definition of marine casualty: (a) actual physical damage to property
in excess of $1500, or material damage affecting the seaworthiness or
efficiency of a vessel, or stranding or grounding, or loss of life,
or injury causing any persons to remain incapacitated in excess of
72 hours.
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the material is property described on the shipping paper as pre-
scribed in 49 CFR 172.
Furthermore, the master of a vessel transporting hazardous
materials must prepare a dangerous cargo manifest, list, or
stowage plan (49 CFR 176.30). This document must be kept in a
designated holder, on or near the vessel's bridge. It must con-
tain the following information: name of vessel and official
number, nationality of vessel, shipping name of each hazardous
material on board, number and description of packages, gross
weight for each type of packaging, classification of the hazar-
dous material, additional description required by 49 CFR 172.203,
stowage location of the hazardous material on board the vessel,
and in the case of a vessel used for the storage of hazardous
materials, the following additional information:
- Name and address of vessel's owner;
- Location of vessel's mooring;
- Name of person in charge of vessel;
- Name and address of the owner of the cargo;
- A complete record by week of all receipts and disbursements
of hazardous materials, including the name and address of
all consignors and consignees.
Each carrier who transports or stores hazardous materials on a
vessel must retain a copy of the dangerous cargo manifest, list,
or stowage plan for one year.
Bulk Cargo
Tank Vessels (46 CFR 35.01-10) and Unmanned Barges Carrying
Certain Bulk Dangerous Cargoes (46 CFR 151.45-7)
Each loaded tank vessel (carrying liquid bulk cargo in tanks)
must have on board a bill of lading, manifest or shipping docu-
ment giving the name of the consignee (35.01-10) or shipper
(151.45-7) and the location of the delivery point (35.01-10)
or loading point (151.45-7); the kinds, grades, and approximate
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quantity by compartment of each kind and grade of cargo; and
for whose account the cargo is being handled. Such manifests
or bills of lading may be made out by the master, master of
the towing vessel, owner, or agent of the owner. However, in
the case of unmanned barges where shipping papers are not
available, an entry in the logbook of the towing vessel giving
the name of the shipper and location of shipping point, the
name of the consignee and location of delivery point, the ap-
proximate kind, grade, and quantity of cargo in each barge of
the tow, and for whose account the cargo is being handled, is
considered adequate for compliance purposes.
Solids in Bulk (46 CFR 148.02-1)
In order to transport by vessel solid hazardous materials
in bulk, the carrier must keep a shipping paper on board the
vessel along with the dangerous cargo manifest. The information
to be provided in these documents is essentially the same as for
packaged hazardous materials. However, in addition the shipping
paper must show the name and address of the U.S. shipper or his
authorized representative and the dangerous cargo manifest must
identify the hold(s) in which the material is being transported
and the quantity of the material in each hold. The Master of
the vessel must certify the correctness of the dangerous cargo
manifest. Each unmanned barge transporting solid hazardous
materials in bulk must have on board, in a readily retrievable
location, such as a metal tube attached to the barge, a dangerous
cargo manifest. Vessels, other than unmanned barges, must have
the dangerous cargo manifest on board and kept in a conspicuous
place on or near the bridge house.
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Self-propelled Vessels Carrying Hazardous Liquids
(46 CFR 153.908)
The shipping document requirements for tankships carrying
flammable or combustible liquid cargoes in bulk are essentially
the same as above. In addition, a cargo location plan must show
the location and number of each cargo tank and the name of the
cargo in each tank.
b. Billing Procedures/Contract Negotiations
Contracts are arranged before transport services are rendered.
The barging business is highly informal; a large percentage of nego-
tiations are conducted orally. There may be situations calling for
long-term agreements as well as short-term agreements. Billing
generally occurs following delivery of cargo. Customers may con-
tact harbor terminals for information on the quantity of waste loaded
and unloaded.
c. On-Site Storage
The companies interviewed stated that they did not have special
facilities for storage of waste. Whenever the cargo cannot be un-
loaded, it simply remains in the barge.
d. Training/Licensing and Safety Practices
Until recent years crew training was largely a learn-as-you-go
operation, with the more experienced crew members passing their
knowledge, and unsafe working habits, on to the new crew member.
However, this unsatisfactory situation is rapidly being corrected
by action from both the fleet operators and unions. In this respect,
the National Maritime Union of American operates an upgrading and
retraining school in New York City. The finances for operation
come from the Union's Pension and Welfare Fund with further finan-
cial assistance from the fleet owner/operators. Similarly, the
Seafarers International Union operates a school at Piney Point,
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Maryland. There are also a number of private schools for individuals
to study for license upgrading. All of the schools have special
courses on pollution control with special emphasis on the handling
of hazardous cargoes.
The Coast Guard is preparing guidelines which will clearly
define training and licensing procedures. Presently, barge com-
panies simply submit a form of certification to the Coast Guard
indicating that a crew member has received training.
Safety requirements for loading are largely an inplant respon-
sibility, with some Federal regulations that must be followed during
a loading operation. Federal requirements are directed to flexible
transfer hose testing, flying of flags and illumination of the area
to indicate the transfer of hazardous cargo.
e. Equipment Maintenance
The certification and inspection of all marine craft is under
the jurisdiction of the U.S. Coast Guard. Every two years, the
barges are dry-docked for examination. A USCG marine inspector
performs the routine check to determine whether the barge may be
used in future transport activities.
f. Insurance
Information made available by companies regarding insurance
coverage was not specific. However, according to one of the nation's
largest insurance brokers, barge fleets are rarely insured under a
standard policy, although a standard policy of insurance is available.
Most marine transportation organizations prefer custom-tailored
policies. Basic insurance is provided and readily available for
the transportation vessel itself. In the marine insurance market,
the phraseology "property and liability damage" is not used, "protec-
tion and indemnity" being the standard term.
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Regarding insurance, the Federal Water Pollution Control Act
stipulates that the owner or operator shall be liable to the United
States Government for the cost of removal of any discharge, such
cost not to exceed $100 per gross ton of such vessel, or $14 million,
whichever is less. The owner or operator is required to provide
evidence of financial responsibility by insurance bond or otherwise.
Costs can include the removal and destruction of a vessel prior to
discharge if it has created a "substantial threat of a pollution
hazard."
To protect against massive claims resulting from a pollution
incident, the major insurance companies have formed an organization
known as the Water Quality Insurance Group (WQIG), through which
they share the profits and losses on an invested percentage basis.
Until September 1, 1976, any insurance carrier could sell Hull and
Protection and Indemnity insurance. Since that date it has been
exclusively written by WQIG. Non-member companies continue, how-
ever, to sell Hull and P&I coverage. A chemical or oil cargo can
be insured either by the owner, shipper or consignee.
Coverage is possible up to the maximum limit of $14 million. An
owner of a vessel which is in excess of 300 gross tons must, under
Federal law: 1) carry insurance; 2) be self-insured, or 3) hold a
bond or bank account to cover full financial responsibility. None
of the listed requirements are needed for vessels under 300 gross
tons. The WQIG policy is in two sections. Section A provides for
liability to the Federal government for the costs of the cleanup
action; Section B provides for third-party liability.
Under the present arrangement, WQIG does not write for loss of
life or personal injury. They are responsible only for resulting
property damage. Currently 1300 applicants are on file with WQIG
for third-party liability. The ratings of the policy vary even
though a rate structure has been established. However, the premium
for hazardous materials, under which hazardous waste materials would
be considered a category, is higher than that for oil.
Coverage under Section 8 of the policy is developed by an under-
writing formula.
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REGULATORY CONTROL
a. Safety and Pollution
Federal regulations pertaining to water transport of packaged
hazardous materials are found in 49 CFR 171, 172, 173, 176, and
178. The bulk carriage of hazardous materials by water is governed
by 46 CFR 30-40 (Tank Vessels); 64 (Marine Portable Tanks); 98
(Certain Dangerous Cargoes in Bulk); 148 (Solids in Bulk); 151 (Un-
manned Barges); and 153 (Self-Propelled Vessels Carrying Hazardous
Liquids). These standards contain regulations for acceptance of
materials for transportation, loading, unloading, handling, storage
of hazardous materials, leaking containers, accident/spill reporting
requirements, containerization, and detailed requirements for speci-
fic classes of hazardous materials.
In addition, the remainder of CFR Title 46 (Shipping) bears on
the general subject of marine and vessel safety.
Regulations promulgated and enforced by the Coast Guard pertain-
ing to pollution of the nation's waterways are found in CFR Title
33, Subchapter 0, specifically:
33 CFR 151 Oil pollution regulations
153 Control of pollution by oil and hazardous
substances, discharge removal
154 Large oil transfer facilities
155 Vessel design and operations
156 Oil transfer operations
157 Rules for the protection of the marine
environment relating to tank vessels
carrying oil in bulk
The barge companies contacted indicated that they observe all
DOT (CFR Title 49) and Coast Guard (CFR Title 46) regulations.*
Incidents and/or discharges involving oil and hazardous materials
or substances must be immediately reported to the Coast Guard in
accordance with 46 CFR 2.20-65 and 33 CFR 153.203.
*
Barging activities on inland waterways are considered interstate opera-
tions and subject to Federal regulation; however, states may impose
their own regulations as well.
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b. Business Practices
Water carriers operating as common carriers subject to the
*
Interstate Commerce Act (Parts I and III) are obliged to accept
for delivery any commodity in their tariff that is properly ten-
dered for shipment. Regulated common and contract carriers are
required under 49 CFR 1220 to preserve the shipping documents
cited in Table III-4 for at least three years, and under 49 CFR
1248 to compile and report freight commodity statistics annually
(see Table III-5 for waste and related codes). Under the River and
Harbor Act of 1922 (33 U.S.C.A. 553), waterborne traffic movements
must be reported to the Corps of Engineers, Department of the Army,
by all vessel operators of record on prescribed forms for those
movements of their vessels which were classified as domestic
traffic. The four-digit commodity classification codes pertaining
to waste and scrap materials and tonnages shipped in calendar
year 1976 are reported in Table III-7. The portions of these wastes
that are hazardous is unknown.
TABLE III-7
COMMODITY CLASSIFICATION FOR DOMESTIC WATERBORNE COMMERCE
Code No.
4011
4012
4022
4024
4029
GROUP 40 - WASTE AND SCRAP
Item Name
Iron and steel scrap
Nonferrous metal scrap
Textile waste, scrap,
sweepings
Paper waste and scrap
Waste and scrap, not
elsewhere classified
MATERIALS
Tonnagef CY 1976
2,111,425
189,455
and 28,521
35,668
15,101,599
of 2000 pounds
SOURCE: Waterborne Commerce of the United States, Calendar
Year 1976, Part 5—National Summaries, U.S. Army
Corps of Engineers, page 9.
49 USC 903 exempts most water transportation of bulk commodities,
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6. .CASE EXAMPLES
a. Example 1
As a contract carrier, the company enters into a contract of
affreightment with a shipper to deliver a specified hazardous waste
to a consignee. The great bulk of commodities handled are virgin
materials, but some waste materials (e.g., waste glycol, spent
sulfuric acid) are handled. Waste handled is almost always in
liquid form and carried in tank barges. Very occasionally, barrels
of waste are handled, but no other type of contained waste.
Depending on the locations of the shipper and consignee, the
company may make arrangements for other barging companies to provide
tows along the route. That is, several different barging companies
may temporarily take possession of the barge, each conveying it to
a location where still another barge company will provide a tow
over a subsequent portion of the route. The result of this procedure
is that final delivery of the company's barge to the consignee will
often be made by a towing company other than the one that initially
took possession of the cargo.
The originating company is primarily in the spot transportation
business, conducting little in the way of dedicated tows (operating
the same barges between docks). It serves the midwestern United
States, particularly the Mississippi and Ohio Rivers. It is very
difficult to cite a typical distance hauled. Barge movements may
be made from one dock in a harbor to another dock in the same harbor,
or from the Ohio River Valley to Houston, Texas City, or Galveston,
a trip of about 2000 miles.
According to DOT regulations, shipping papers must remain on the
barge, rather than with the towboat. Again, this is because the
barge may be towed by several different fleets. Typically, the com-
pany radios instructions to its tow boats, indicating the location,
contents, and timing for pickup and delivery.
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The barge business is largely conducted by telephone, with a
good deal of trust on both sides. An invoice will ultimately be
sent to the shipper for services rendered, but certification of
delivery or other formal evidence of delivery or handling is not
usually required.
The price for barge shipments is usually determined by the type
of material (hazardous nature or difficulty of cleaning tanks) and
distance hauled (ton-miles). It is quite difficult to carry more
than one type of hazardous material in a barge, and in no case will
incompatible materials be placed in different compartments.
»
The company is self-insured.
b. Example 2
This company, established in 1901, operates as a contract
carrier out of the New Orleans area. It has 350 employees with
290 engaged in boat-work; the remaining 60 are administrative and
clerical. The company operates 130 barges but only two barges are
needed per month for waste transport. The barges move on all in-
land waterways, but waste transport activities are confined to the
Mississippi River. A 3-compartment, double-hulled tank barge with
a capacity of 1400 short tons is used for waste transport. The
barges are inspected every two years by the U.S. Coast Guard.
The company has been involved with hazardous waste transport
for the past ten years. Several types of chemical wastes are
transported to a resource recovery facility in the Houston area.
The activities of a round-trip are as follows: A contract is
negotiated between the barge company and the shipper or generator
of waste. The company may notify other barge companies to provide
tows along the route, if necessary. Once all scheduling has been
completed, a barge is fully loaded with chemical waste from a
storage tank on the generator's site. A licensed inspector at the
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dock records the quantity of waste loaded and places a manifest on
the barge. The manifest describes the type of material, quantity,
origin, and destination. At least two people are involved in the
loading and unloading process.
Several towing companies may escort the barge before the final
destination is reached. Company crew members will escort the barge
from northern Louisiana or a port in Mississippi to the Houston
area. There is regular communication between the barge company and
the tow crews to maintain a record on the location of the barge.
The barge company will notify the harbor terminal ahead of time on
the scheduled arrival of the barge. Documentation of the cargo is
sent to the receiving terminal by mail. Once the destination is
reached, an inspector records the quantity of waste unloaded. The
quantity noted should agree with the information on the documents
obtained by mail.
The return trip is a carbon copy of the initial trip. The barge
is fully reloaded with reprocessed waste, technically a DOT hazardous
material. The inspector records the quantity and places the shipping
papers on the barge. The barge then travels back to the generator to
exchange the reprocessed material for another shipment of hazardous
waste.
The company trains all employees involved with boat work.
Records are kept in current files for 9 years and are used
primarily for billing and tax purposes.
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D. TRANSPORT BY AIR
1. METHOD OF APPROACH
Several different types of sources believed to have knowledge con-
cerning air transport of hazardous waste were contacted (Appendix B-4).
These sources included:
(1) Persons knowledgeable in air cargo safety or hazardous
materials control at three major airlines involved in
both passenger and freight transportation.
(2) Persons knowledgeable in air cargo safety or hazardous
materials control at three major freight airlines.
(3) Sources at two small freight airlines.
(4) Three consolidators and/or ground handlers believed
to accept hazardous materials.
(5) Two major waste disposal laboratories.
(6) Federal Aviation Administration (FAA).
(7) Four major air transport associations:
• Airline Pilots Association (ALPA);
• Air Transport Association (ATA);
• National Air Transportation Association (NATA);
• Air Freight Forwarders Association (AFFA).
Because the amount of hazardous waste transported by air is quite
small, specific industry knowledge about such transport is very limited.
Most sources contacted did not have any direct knowledge of hazardous
waste transport by air, but could not discount the possibility of small or
infrequent shipments such as samples of waste for laboratory analysis. Some
sources observed that "all types of CFR Title 49 hazardous materials" have
been carried at one time or another, but not necessarily hazardous waste.
Each of the three air transport associations, ALPA, ATA, and NATA,have com-
mittees or staff members concerned with the transport of hazardous materials
and all felt that hazardous waste transport was very limited or nonexistent.
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2. FACILITIES AND SERVICES PROVIDED
National carriers, small local and regional airlines, as well as
consolidators and ground handlers, can and do accept hazardous waste in
limited quantities for transport. Details of air transport facilities
were judged not to be relevant to this report.
3. TRANSPORTATION ACTIVITIES
Hazardous waste transport by air is extremely limited due to its
expense. Not only is hazardous waste a very small part of the air cargo
industry, but the amount of all hazardous materials shipped by air is
small. About 4.53 million tons of hazardous materials were shipped by
2a
air in 1973, which represents 0.35 percent of the hazardous materials
shipped by all modes (but not including pipeline). Existing practices
and regulations in the air transport industry severely limit the quanti-
ties of hazardous materials generally that may be packaged and tendered
for shipment.
Several instances of hazardous waste transport by air were corro-
borated and are believed to be representative of the industry. One large
freight airline transports about 500 pounds per year of flammable metal
shavings, 500 pounds per year of waste nitric acid, and one ton per year
of waste radioactive material. This airline carried 7 million pounds of
hazardous materials and flew 811 million cargo ton-miles in 1975. The
wastes cited were shipped by air because local disposal or treatment
facilities were not adequate. (In the case of radioactive materials,
they are returned to the manufacturer for disposal.) The wastes are
typically relayed from the generator to the airline and from the airline
to the disposal facility by truck. Again, on the basis of the concrete
response of this airline (one of the larger airlines carrying freight),
the total amount of hazardous waste shipped by air is believed to be
very small.
Samples of hazardous waste are sometimes air-shipped to disposal
facilities for laboratory analysis prior to transporting the bulk wastes
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for disposal. Such air shipments to the larger disposal facilities amount
to a few quart- or pint-size containers per year.
Because air transport of hazardous waste is so limited, many of the
details regarding air transportation activities are irrelevant and have
been omitted. However, regulations and practices concerning air transport
of hazardous materials are described in the next section.
4. REGULATIONS AND PRACTICES
a. Federal Regulations
The existing regulations and standards for the transport of
hazardous materials by air are much more stringent than those for
other modes. Materials Transportation Bureau, Department of Trans-
portation regulations pertaining specifically to carriage of
hazardous materials by aircraft are found in 49 CFR 175. Public
Health Service regulations applicable to interstate transportation
of etiologic agents are found in 42 CFR 72. Additionally, the
Federal Aviation Administration, Department of Transportation
administers regulations (14 CFR 1-199) pertaining to aircraft
airworthiness standards and maintenance requirements; certifica-
tion of pilots, flight instructors, flight crew members, air carriers,
air taxi operators, etc.; requirements for schools and training pro-
grams, which include the handling of hazardous materials and other
matters. Safety, in general, is the overriding concern of these
FAA regulations.
DOT and FAA regulations also pertain to recordkeeping and
training. Copies of shipping papers (waybills) prepared by the
shipper must be carried on-board the aircraft. The originating
carrier must maintain a copy of the shipping paper for 90 days
(49 CFR 175.30). In addition to shipping papers, the air carrier
prepares a manifest for the total cargo shipment and the pilot
signs acceptance forms (14 CFR 121). Shipments must be labeled
according to DOT hazard classes. Sample shipping papers appear
in Appendix D.
111-59
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Airlines customarily follow other recordkeeping practices that
are not directly required by regulations. Airlines generally issue
a delivery ticket, requiring a signature upon delivery. Shipping
papers and delivery tickets are generally retained longer than the
90 days required by regulation. Federal Express, for example,
maintains copies of shipping papers and delivery tickets indefinitely
but maintains load manifests for 90 days only. For intermodal ship-
ments, shipping papers are certified by shipper even if an agent
(e.g., trucker) transports the shipment to the air carrier. If an
agent of the consignee accepts delivery, the agent signs for the
shipment.
Training procedures must be approved by the FAA and only
specially-trained personnel may handle hazardous materials. One
large freight airline, for example, provides instructions to pilots
for all restricted articles and gives each person handling hazardous
materials five days of initial training and another half day every
twelve months thereafter.
Although all of the present regulations and practices cited are
directed toward hazardous materials generally rather than wastes
specifically, there is no recognition of any distinction.
Some differences between practices for air transport and other
modes of transport are worth highlighting. The criteria for deter-
mining which materials may be shipped by air are more strict than
for other modes. Despite this limitation, however, both passengers
and hazardous materials can be placed on the same craft (unlike other
modes.) The allowable quantities of hazardous materials for air
carriage are considerably smaller than for other modes. Hazardous
materials on air flights generally do not require special placarding
(unlike other modes), although these materials must be placarded when
there is intermodal ground transport.
Most are limited to 50 pounds per compartment.
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b. Operation STOP
The Airline Pilots Association has promulgated strict standards
within Operation STOP—Hazardous Materials Standards and Limitations, with
which both freight and passenger airlines comply. The STOP standards place
the most severe restrictions on the transport of hazardous materials.
In addition to recognizing CFR Title 49 hazardous materials, the
Airline Pilots Association has defined "Other Restricted Articles"
(ORA) to include any article that "has anesthetic, irritating,noxious,
toxic or other characteristics, which can cause extreme annoyance or
discomfort to passengers and crew in the event of leakage in flight"
(ORA A), or "is a solid material which, when wet, becomes strongly
corrosive so as to be capable of causing damage to aircraft structure,"
(ORA B), or "has other inherent characteristics which make it unsuitable
for air carriage, unless properly prepared for shipment" (ORA C). Many
such articles may be refused from air shipment and all those accepted
must be "properly secured," and with certain exceptions limited to
50 pounds per compartment. The standards are more strict for passenger
aircraft than for cargoliners. ALPA is trying to ban restricted
articles on passenger craft (except such items as medically necessary
radioactive materials with very short half-lives). The latest STOP
standards have applied the old passenger craft standards to cargoliners
and have further constrained the passenger craft standards. (Such
increasingly stringent standards have reduced the amount of hazardous
materials shipped by air. Spent nitric acid, for example, is not
presently allowed on passenger aircraft.)
For passenger aircraft, the only allowable hazardous materials
are certain radioactive materials, dry ice, liquid nitrogen, magne-
tized materials, and some etiologic agents. For cargoliners, other
materials are also allowed, but must be labeled as "cargoliner only"
shipments. Flammable liquids, irritants and corrosive materials are
restricted to one-quart containers. Container drums of hazardous
materials are no longer allowed.
Jlafe ^Transportation of People
111-61
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All domestic passenger airlines except American Airlines are
members of the Airline Pilots Association (but American Airlines
claims to follow STOP standards). Many cargo airlines (including
Flying Tiger, Airlift International and Seaboard, but not Federal
Express) are also members of ALPA. Unfortunately, according to
ALPA, STOP standards and DOT regulations are being violated by
shippers and cargo managers. ALPA believes more thorough enforce-
ment is necessary.
5. PROBLEM AREAS
Surveillance and enforcement of air regulations is a generally ac-
knowledged problem. DOT acknowledges that the emphasis in the next twenty
years in hazardous materials transport by air will be in education, sur-
2a
veillance, and enforcement. This concern was echoed by several persons
in the industry, who noted the enforcement problem. Airline cargo person-
nel generally do not inspect cargo and are at the mercy of shippers. The
Airline Pilots Association has noted that "cargo managers... are tempted
*
to overlook violations of packaging and labeling requirements" and that
shippers "are shipping materials through airline cargo receivers who have
no idea of their potential for danger." ALPA has documented examples of
these violations. DOT has also noted that consolidators and freight-
forwarders often do not observe the more stringent requirements of air
transport, such as weight limitations and restrictions of certain articles.
It should be noted that Operation STOP was created to protest the con-
tinued violation of DOT regulations. In conjunction with the STOP program,
2a
a DOT task force recommended (on March 15, 1975):
• "Serious consideration be given to prohibiting carriage in
air commerce of those hazardous materials listed and defined
(in the report's appendix)."
*Air Line Pilot, 45, May 1976, pp. 20-29.
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• Amendment of the interpretation of "accessibility" of cargo to
the flight crew to read as follows: "No person may carry an
article requiring a flammable liquid or a flammable gas label
aboard a cargo-only aircraft unless the article is loaded in
a manner that will allow a crew member in flight unobstructed
access to the loaded position."
• Maintenance of DOT regulations on the premises of each air
carrier terminal where hazardous materials are accepted.
• Review of training programs by the FAA to insure meeting
minimum requirements.
• Clarification of DOT, FAA, and IATA regulations (regarding
hazardous materials).
• Vigorous enforcement of the regulations from shipper and
container manufacturer "through the various surface modes
to the ultimate final [sic] carrier."
International Air Transport Association
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E. TRANSPORT BY PIPELINE
1. METHOD OF APPROACH
In general, pipeline transport of hazardous waste in the United
States is extremely limited. As a result, the task of determining iso-
lated instances of hazardous waste transport by pipeline was difficult.
The approach used was to search available literature and make telephone
contacts with as many different types of sources as possible in the hope
of discovering instances of pipeline transport.
The information gathering process was dynamic in the sense that
initial contacts often provided additional sources of information.
Experts knowledgeable about the pipeline industry—the American Petro-
leum Institute and the Office of Pipeline Safety, Department of Trans-
portation—were contacted first. Subsequent interviews included an
officer of a slurry pipeline company, a coal company that formerly
operated a slurry pipeline, various pipeline manufacturers, and the
Army Corps of Engineers. This initial search indicated that mining
operations and coal burning utilities use pipelines for disposal of
waste on their own properties. Next officials of copper mining opera-
tions, an expert in coal burning utilities, and a company specializing
in fly ash (coal waste) and sludge treatment and disposal by pipeline
were contacted. Additional information about mining operations was
obtained from EPA Region VIII personnel. Several contacts were made
with municipal operations that transport sewage sludge via pipeline.
Although difficulties were experienced locating authorities on
hazardous waste transport by pipeline, the search was sufficiently
thorough, however, to discover relevant operations and reach con-
clusions concerning the limited extent of this activity. Organizations
contacted during the study are listed in Appendix B-5.
2. FACILITIES
The commercial pipeline transport industry in the United States is
largely dedicated to the transport of fuel products, especially crude
III-64
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and refined petroleum products and coal slurries. Pipeline companies
that transport crude oil or other raw material or product do not carry
hazardous waste for several reasons:
(1) Most pipelines are not designed for hazardous
waste transport.
(2) It is impractical and uneconomic to transport
both types of materials (waste and products),
and
(3) Existing pipelines,being stationary, do not ordinarily
link hazardous waste generators to treatment, storage,
or disposal facilities.
Thus, hazardous waste transport by pipeline is confined to a few
concentrated industrial areas in the United States.
There are presently 440,000 miles of major intercity pipelines,
none of which are waste lines, carrying 1.9 billion tons of materials
per year.3 Of these, 265,000 miles are natural gas lines (not including
service lines), 103,000 miles are crude oil lines, 68,000 miles are petro-
leum product lines, 4,050 miles are chemical lines, and 273 miles are coal
slurry lines. The chemical lines comprise an 850-mile anhydrous ammonia
line, a 1,100-mile liquid ammonia line and a 2,100-mile network for
ethylene products. The coal slurry line is the 273-mile Black Mesa
pipeline. A 108-mile Ohio coal line has been shut down due to compe-
4f
tition from rail and truck. Some 4,300 additional miles of coal
slurry lines have been proposed.
*Designs to convert this line to one carrying waste have not been acted upon.
Ill-65
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3. TRANSPORTATION ACTIVITIES
Pipelining of waste may be economically attractive where a disposal
site is located in the midst of a heavily industrialized area. In three
such instances pipeline transport of waste was found, implying that others
may exist elsewhere in the United States. At the site operated by William
J. Lamberton in Tulsa, Oklahoma, primarily acid waste is pipelined from
three galvanizing plants to a central disposal site. At another Tulsa
location, two metal-finishing plants share an injection well via pipe-
line. The Gulf Coast Waste Disposal Authority in Houston and Bayport,
Texas, handles pipelined wastewater, although this might be considered
industrial discharges which are point sources subject to permits under
Section 402 of the Federal Water Pollution Control Act. This instance
may, therefore, be strictly excluded from RCRA but might nevertheless
represent an important consideration to the EPA. Operations similar to
these three may exist in other locations. In general, however, the
extent of pipeline transport that might be directly regulated by RCRA is
severely limited essentially to other heavily industrialized areas in
proximity to disposal sites. No large-scale operations were discovered.
Other marginal instances of pipeline waste transport were discovered.
Regional sanitary districts sometimes use slurry pipelines for the trans-
port of sludge that may include industrial wastes. Industrial processes,
particularly mining operations and coal-burning utilities, use pipelines
to transport wastes to dedicated disposal sites, usually on the generators'
own property. (For mining operations the waste is often not hazardous.)
A brief discussion of the facilities, activities, and practices of these
types of operations is presented below.
The most important examples of industrial pipeline activity were
found in Oklahoma. William J. Lamberton operates a deep injection well
in Tulsa, Oklahoma to which three galvanizing plants transport mostly
waste acids by pipeline. The facility receives about 150,000 gallons
per month by pipeline and also accepts waste by truck. Most of the pipe-
lined waste is spent sulfuric acid; other wastes include other acids and
IH-66
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herbicide rinse water. The companies involved took the initiative in
building the system and are the owners of the pipelines which are on
the order of 1,000 feet each.
The practices and procedures of the operation differ somewhat from
the typical disposal facility. As owners of the pipeline, the galvanizing
companies are responsible for maintenance. The Lamberton facility, how-
ever, actually performs most of the work. There are about twelve specially
trained persons involved in operating the main pipeline. The companies
pump their waste on separate days and Lamberton coordinates the scheduling
and recordkeeping. All work requests are oral. Formal recordkeeping
consists of monthly billings. The billings are based on volumes
determined from actual measurements of the pumped wastes.
The Oklahoma Water Resources Board has authority over the operation,
but this will soon be taken over by the Oklahoma State Department of
Health, Industrial and Solid Waste Management Division. The authority
is primarily one of review. The injection well operators report to the
Solid Waste Management Division monthly and the generators report
annually.
Tulsa, Oklahoma is the location of another instance of hazardous
waste transport by pipeline. McDonnell Douglas and Rockwell Interna-
tional share property owned by the Air Force on which they conduct metal
finishing operations. A pipeline transports metal finishing waste and
rinse water to a holding tank one-half mile away. Rockwell International
owns an injection well located next to the holding tank.
A third instance of hazardous waste transport by pipeline is the
Gulf Coast Waste Disposal Authority, operating at two sites in Texas.
The operation is a quasi-governmental authority whose legal responsi-
bility is questionable should operational problems arise. Much of the
waste is industrial wastewater, which may constitute a point source
subject to the Federal Water Pollution Control Act. Other wastes
accepted include dissolved solids and ammonia, some of which arrives
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by truck. The regulatory agency for the operation is the State of Texas
Water Control Board.
Some public sanitary authorities also transport hazardous waste by
pipeline. It is not clear whether these situations are impacted by Sec-
tion 3003 of the RCRA. The Cleveland Regional Sewer Authority, for
example, has a 14-mile pipeline in which primary sludges and excess ac-
tivated sludge from domestic sewage is pumped from one treatment station
to another. The Metropolitan Sanitary District of Greater Chicago uses
sewage sludge to reclaim land 200 miles from the city. Sludge is pumped
from one treatment facility through a 30-mile pipeline to another facility
where it is treated and barged to the reclamation area. Recordkeeping is
performed on a monthly basis by an outside consultant. There is no addi-
tional shipping document for the barging part of the operation.
Both 'sludge operations have small operational crews and are run as
normal pipelines. One other public authority of interest is the Los
Angeles County Office of Sanitation which accepts applications for dis-
posal of industrial waste within the cpunty sewer system.
Several instances were identified of generator pipeline transport
and disposal on-site of flue dust (from coal-burning utilities) and mining
wastes. This leads to the conjecture that there may be instances of pipe-
line transport of similar wastes off-site, although none were discovered.
4. REGULATORY CONTROL AND PRACTICES
The pipeline transport of gases and liquids is generally governed by
49 CFR 190-199. Part 195 pertains specifically to liquids and applies
only to the transportation by pipeline in interstate and foreign commerce
of hazardous materials that are subject to 49 CFR 172-173, petroleum, and
petroleum products. Whenever a hazardous material is to be transported,
the Secretary of the DOT must be appropriately notified in writing. Ac-
cidents must be reported to the Director, Office of Pipeline Safety.
Additionally, municipal operations often need local disposal permits.
For the examples previously cited, state authorities have limited regu-
latory jurisdiction. Finally, uncertainty exists whether the Federal
111-68
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Water Pollution Control Act applies to the pipelining of wastewater. In
summary, the regulatory basis for hazardous waste transport by pipeline
is not altogether clear. The situation is further complicated by the
paucity of standards for pipeline operations.
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IV. OFF-SITE TRANSPORT BY GENERATORS
A. METHOD OF APPROACH
The objective of thework reported in this section is to examine and
characterize generators acting as private carriers that transport hazard-
ous waste off-premises in their own vehicles to hazardous waste manage-
ment facilities (treatment, storage, and disposal). In order to obtain
an estimate of the number of generators self-hauling to off-site facili-
ties and the fraction of hazardous wastes self-hauled, the 14 EPA Industry
O_1 £.
Studies were reviewed and telephone contact was made with the
Principal Investigator for each Industry Study. It was found that 3.5
percent of the plants inventoried as part of the industry studies trans-
ported their own wastes, and that less than 3 percent of the total quanti-
ty of wastehauled off-site was transported by the generator.
Thus, a survey of 100 plants selected at random would be expected to iden-
tify at most.four that hauled their own wastes. It was therefore not pos-
sible within the scope of work of this study to obtain a representative
sample of plants that self-haul.
A list of 54 plants likely to transport their own wastes was com-
piled from information supplied by the Principal Investigators of each of
the Industry Studies, information obtained in other parts of this study,
and information available from prior industrial work by Arthur D. Little,
Inc. The plant manager at each of the plants identified was contacted by
telephone. Twenty-seven contacts were made with large firms (over 100
employees), and twenty-seven were made with small firms,(20 to 50 employees),
Most of the contacts were with plants falling within the SIC codes covered
by the EPA Industry Studies. Transport was not specifically included in
the scope of work of the industry studies, and in fact very little trans-
portation information was gathered by the EPA contractors. In particular,
the universe of plants that self-haul is not known. Hence, there is no
basis for statistically valid sampling of plants for personal interview.
Nonetheless, the interview data that were obtained showed a generally
consistent pattern.
IV-1
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The type of information sought during the interview included:
• nature of the wastes self-hauled
• quantity of waste in a single haul
• source of waste in a single haul—waste from one process, several
processes, one plant, several plants
• number of hauls per year
• kind of transport vehicle used; age; useful lifetime
• procedure for loading and unloading wastes
• crew size
• placarding and labeling
• record keeping
• distance hauled
• final destination
• accidents, other than traffic violations.
The specific data obtained is summarized in the text. In general, there
was a marked contrast between small and large firms in willingness to dis-
cuss hazardous waste transport. When hazardous wastes were defined as
wastes likely to come under RCRA regulations, large firms understood im-
mediately, although many did resent the designation "hazardous." Small
firms either professed ignorance of RCRA, or flatly refused to discuss
the subject of waste transport at all.
Small firms, taken in the aggregate, probably generate significant
quantities of waste, even though the quantity generated by any given busi-
ness may be minor. Because of the low volume of wastes generated (one or
two 55-gallon drums per month), a small firm may be more likely than a
large one in the same industry to use its own trucks to haul wastes off-
site. It may in fact be difficult to find a permitted contractor to
handle a small quantity of waste. On the other hand, where the quantity
of chemical wastes is small, there may be a tendency to discard them
with municipal trash, pour them down the sewer, dump them on an unused
portion of the property, or keep them around in storage.
IV-2
-------
B. INDUSTRIES THAT SELF-HAUL
1. Industry and Geographic Distribution
Table IV-1 provides approximate figures for the quantities of
hazardous wastes transported off-site from industries that have been
studied under the 14 EPA/Hazardous Waste Management Division contracts.
The number of plants in each industry disposing off-site and using
self-haul, HWMF/transporters, and for-hire common and contract carriers
were extrapolated to the entire industry, based on data obtained by in-
dustry study contractors in a limited sampling of plants. The quantity
of waste transported by the generators (Q) was calculated as the total
quantity of waste hauled of f-site (W), multiplied by the ratio of the
number of plants self-hauling (S) to the total number of plants whose
waste was transported off-site (N), i.e.,
/
Q = W x (S/N) (1)
This relationship assumes that every plant is the same size, corres-
ponding to the approach used in the industry studies. Insofar as it
is the smaller plants that self-haul, the estimates of total quantity
of wastes transported by generators will be somewhat high.
For the industries in Table IV-1, 3.5 percent of the plants surveyed
self-haul some or all of their hazardous waste to an off-site disposal
facility. More than 10 percent of the waste oil re-refining, leather
tanning, and paint plants self-haul. Between 2 and 5 percent of the
plants in the textile, special machinery, and pharmaceutical industries
self-haul. Less than 1 percent of the plants in other industries self-
haul.
Approximately 19 percent of the total processing waste generated
by the industries listed in Table IV-1 is hauled off-site. Only 2-3
percent of the total hauled off-site (0.4 percent of the total generated)
*Firms operating hazardous waste management facilities acting as contract
of private carriers.
**
'As opposed to on-site treatment, storage, or disposal.
IV-3
-------
TABLE IV-1
SOURCES OF HAZARDOUS WASTE TRANSPORTED OFF-SITE
Textiles"
Inorganic Chemicals
Pharmaceuticals
Paints & Coatingsb
Organic Chemicals,
Pesticides, &
Explosives
Petroleum Refining
Rubber & Plastics
Leather Tanning &
Finishing
Primary & Secondary
Metal Smelting and
Refining
Electroplating &
Metal Finishing
Special Industry
Machinery
Office, Computing &
Accounting Machines
Electronic Components
Storage & Primary
Batteries
Waste Oil Re-refining
Totals
SIC
Code
22XX
281X
283X
285X
2869,
2879,
2893
291X
30XX
3111
33XX
3471
355X
357X
367X
3691-2
5093
Total
5366
900-
219
372
899
247
298
2690
197
5684
2855
263
27
20,017
Number
Using
Of f -Site
Facilitv
(N)
5366
225
219
372
899
247
298
108
130
5400
2483
92
19
15,858
of P
Self-
Haul
(S)
268
1
6
37
5
7
81
0
1
270
25
1
10
705
lants
Using
For-llire
Transport
1878
—
82
112
0
7
217
108
129
5130
2453
—
0
10,114
"•
1IWMF/
Transporter
,
3220
224
131
223
894
7
0
0
0
0
0
91
9
4,792
Hazardous Waste
Total
Generated
1,878,000
3,782,000
73,000
147,000
6,492,000
1,406,000
173,000
17,566,000
4,053,000
153,000
64,000
543,000
74,000
37,349,000
Transported
Off-Site
(W)
b
103,000
567,000
62,050
139,450b
l,300,000b
b
844,000
164,350b
351,000
2,837,000
145,000
55,700
353,000
55,000
6,977,000
Self-Hauled
Quantity
(Q)
5140
2520
1700
13,900
7230
7
45,700
0
21.800
7230
560
3840
28,900
138,000
Off-Site
As
Percentage
Of Total
Off-Site
(100 Q/W)
5
0.4
3
10
0.6
7
27
0
0.8
5
1
1
53
2.3C
Tfet metric tons per year
All firms dispose of some of their wastes off-site, but they also have on-site facilities for disposal of other wastes.
Excluding Petroleum Refining industry.
SOURCE: References 3-16
-------
is transported by the generator in company-operated vehicles.
At least one plant in every industry in Table Iv-l, except for metal
smelting and refining and petroleum refining, that self-hauls was identi-
fied and contacted in this study. Metal smelting and refining generates
large quantities of hazardous waste, most of which are handled on-site.
Petroleum refining is also a large generating sector, with a large
quantity of waste per average plant; whereas some wastes are handled
on-site, most wastes are handled by contractor services.
2. Fleet Size
Most self-haulers operate only one waste transport motor vehicle,
which in some cases is not even dedicated to this activity. The vehicle
is usually operated by a single driver employed by the plant. He may be
assisted in loading by plant personnel and in unloading by disposal site
personnel. The few generators that self-haul own the transport vehicles
*
used, and engage solely in motor carriage.
3. Services P_r_oyided_
Plants that self-haul handle only their own wastes. No industrial
waste generator was found that offers waste transport services to other
companies. Only one company was identified which provided general waste
transport services for a number of their own plants. The decision to self-
haul or to use a contractor is generally made at the plant level.
Wastes that are self-hauled are generally transported as generated,
without treatment. They are usually taken to a company-owned landfill,
or lagoon, and occasionally to a municipal or private landfill. No in-
stance was discovered in which the waste was self-hauled to resource re-
covery facilities, although this should not be ruled out*
Some generators own rail tank cars and/or tank barges that are used to
transport wastes, but the actual transport is not done by the generator.
This case does not fall into the category of "self-hauling,"
IV-5
-------
C. TRANSPORTATION ACTIVITIES
1. Extent of Services
As indicated previously, it is estimated that fewer than four
plants out of a hundred haul their own waste to off-site disposal
facilities. Even with a pre-selected list of companies believed to
transport their own wastes, the majority of the 54 plants contacted
were found to be using HWMF/transporters or for-hire common and con-
tract carriers. The limited data obtained suggest that self-hauling
firms tend to be the smaller firms in an industry, and tend to be
located in rural areas where external transport services are not
available. Wastes transported by plants are usually hauled a
distance of less than 10 miles, and often are hauled no more than
1-2 miles.
The following is a summary of the extent of self-transport ser-
vices by industry. The types of vehicles used, containerization
practices, personnel, prenotification/acceptance, routing/dispatching,
loading/unloading, delivery to disposal site, handling of spills, and
marking and labeling are discussed in subsequent sections.
a. Textile Industry, SIC 22XX
As part of the EPA Industry Study, visits were made to 80
plants, representing 16 percent of the production capacity of
this industry. While all plants visited used off-site disposal
facilities for some of their wastes, only four plants (5 percent)
were identified as self-haulers. In every case wastes were
trucked to a landfill located no more than 10 miles from the
plant site.
b. Pharmaceutical Industry, SIC 283X
One firm was identified as self-hauling. The firm has three
plants located within a 100-mile radius. Self-hauling is primarily
from the two older plants to the newest one. The latter is seven
or eight years old, and was designed to permit maximum recycling
IV-6
-------
and heat recovery incineration. Contract waste haulers are also
used, particularly for spent chemicals.
c. Paints and Coatings, SIC 285X
4
The EPA Industry Study states that 10 percent of the plants
visited haul wastes to landfills in their own trucks. The Principal
Investigator recalled that there were many self-haulers in the Bal-
timore, MD, and Dallas-Fort Worth, TX areas. Sludges or paint wastes
were typically loaded into 55-gallon drums and hauled a distance of
less than 10 miles to a landfill in open dump trucks together with
municipal trash.
d. Organic Chemicals, Pesticides, and Explosives, SIC 2869,
2879, 2892
These industries typically dispose of their hazardous wastes
either on-site or through contract waste haulers. Fourteen major
chemical companies were identified as possibly self-hauling based
on information obtained from the EPA Industry Study or contained
in Arthur D. Little, Inc. files. Telephone contact with environ-
mental directors in nine of these companies did not yield any in-
stances of generators that self-hauled. A petroleum refining
company was identified, however, that has a chemicals group with
plants in Lake Charles, LA, and Baltimore, MD. These plants oc-
casionally haul drums of spent catalyst and caustic in a stake-
body, flat-bed truck to municipal landfills. Approximately 15-20
drums are transported about once a year over a distance of at most
10 miles.
e. Leather Tanning and Finishing. SIC 3111
1 o
The EPA Industry Study stated that some plants, among the 41
visited, did haul their own wastes. The type of waste self-hauled,
according to the Principal Investigator of that study, is leather
scraps in some stage of processing. Open dump trucks are used
-------
for transporting the wastes, which are considered hazardous due
to the chromium content of the partially-processed hides. Typi-
cally, the distance hauled is about two miles to a municipal
dump.
f. Asbestos Products, SIC 3292
A company was contacted that manufactured asbestos products
at six locations. One plant out of the six transported their
own wastes. The other five used on-site disposal. The self-
hauling plant, located in New Jersey, transports asbestos pipe
scrap and settling basin wet solids in a dump truck less than
one mile to a landfill.
£. Electroplating and Metal Finishing, SIC 3471
3
The EPA Industry Study identified one firm out of 33
visited that used its own trucks to haul wastewater treatment
sludges, and one job shop out of nine visited that used its own
trucks to haul solid waste. A captive plating plant in Pennsyl-
vania was contacted. The plant self-hauls alkaline mixed metal
hydroxide sludges to a company-owned lagoon two miles from the
plant site.
h. Special Industry Machinery and Office, Computing, and
Accounting Machines, SIC 355X, 357X
According to the EPA Industry Study one company out of 33
visited trucked its own wastes to a landfill. Since the study
files appear to be unavailable, no further details could be ob-
tained. A Massachusetts machining company was contacted that
does haul its own wastes. Metal sludges and oil-contaminated
grindings are transported in company-owned trucks over a distance
of about 5 miles to a certified landfill.
IV-8
-------
i. Electronic Components, SIC 367X
The EPA Industry Study cited one case of a plant using its
own trucks to haul to landfill. The Principal Investigator
identified the plant as a large TV manufacturer in the Northeast.
The wastes hauled were lead-containing sludges. They were trans-
ported a distance of less than one mile to a company-owned disposal
lagoon. Due to a confidentiality agreement, no further information
could be supplied.
j. Storage and Primary Batteries^ SIC 3691, 3692
The EPA Industry Study8 stated that 80 percent of the plants
visited use contract or municipal waste haulers to transport wastes
to off-site facilities; 20 percent treat and dispose of their own
wastes. The Principal Investigator recalled that all lead-acid
battery wastes were treated on-site at these facilities by neutrali-
zation/recovery of Pb(OH)?. Scrap batteries, frequently mixed with
trash, are nearly always transported by municipal haulers to segre-
gated landfills.
Contact was made with one company identified as possibly hauling
their own wastes. Many of the company plants are located in small
towns. At these plants, company-owned and operated two-ton multi-
service trucks are used to haul scrap batteries together with gen-
eral trash to municipal dump sites. Haul distances are generally
less than 10 miles.
k. Waste Oil Re-refining, SIC 5093
The EPA Industry Study found 10 re-refiners, out of 27
visited, that hauled untreated clay wastes in their own trucks.
The self-haulers tend to be the smaller companies. The three
largest re-refiners use contract waste haulers.
IV-9
-------
2. Types of Vehicles
The transport vehicles used by generators who self-haul range from
general purpose stake-body,flat-bed and dump trucks to 5,000-gallon
tank trucks. Table IV-2 summarizes by industry the types of vehicles
used for various kinds of wastes, and the range of vehicle utilization.
Illustrations of various types of trucks appear in Appendix C. Most
self-haulers own and operate a single dump truck dedicated to the trans-
port of wastes. In battery plants, a non-dedicated multiservice truck
is often used. Dump trucks are typically over 10 years of age, which
plants claim to have made "leak-proof" and covered within the last
year or two. The average age of tank trucks is 6-8 years.
3. Containerization Practices
When waste is transported by tank truck, the vehicle itself of
course serves as the container. When a dump truck is used, wastes
may simply be deposited loose along with municipal trash. More of-
ten, however, the wastes are loaded into the truck in trash barrels
or in 55-gallon drums. Even when wastes are transported by a con-
tractor, the generator typically supplies the containers (usually
barrels for dry wastes and drums for liquids or sludges). Several
specific examples are given below.
A leather tannery in Maine operating its own open-top dump truck,
hauls chemically-contaminated leather scraps in barrels. An asbestos
products manufacturer hauls settling basin wastes in a dedicated "leak-
proof" covered dump truck which serves as its own container. Baghouse
wastes, however, are p.ut into marked plastic bags. A small electro-
plafing plant, using a contract hauler, loads the equivalent of six
barrels per week of floor sweepings from a polishing and buffing shop
uncontainerized into the contractor's dumpster bin. A special machinery
plant loads a mixture of metal sludges and oil contaminated grindings
loose into dump trucks. A capacitor manufacturer, using a HWMF/trans-
porter, transports PCB-saturated Fuller's earth filter media in 40-
gallon fiber drums with polyethylene linings. In the battery industry,
liquid wastes (cell washings) are generally hauled in drums by HWMF/
transporters. Scrap batteries are transported loose with municipal
IV-10
-------
TABLE IV-2
TYPES OF VEHICLES USED BY
GENERATORS WHO SELF-HAUL WASTES
f
Industry
Textiles
Pharmaceuticals
SIC No.
22XX
283X
Paints &
Coatings
Leather Tanning
& Finishing
Asbestos
Products
285X
3111
3292
Electroplating & 3471
Metal Finishing
Special Machinery, 355X.357X
Office Machines
Storage & Primary 3691,2
Batteries
Type of Waste
Nylon and cotton scrap
Treatment-plant sludge
(30 percent solids)
Dry solids
Sludges and paint with
municipal trash
Chrome-contaminat ed
leather scrap
Sludge (3 percent
solids)
Asbestos scrap, bag-
house wastes, and
settling basin sludge
Sludge
Metal sludges, oil-
contaminated grindings
PCB-saturated Fuller's
earth
Scrap batteries
Waste Oil Re-
refining
5093
Type of
Vehicle
Typical No. of
Vehicles
per Plant
Dump Truck 1
Tank Truck 2 (larger is
5000 gal.)
Dump truck 25-50
with tarp
cover
Dump truck 1
Dump truck
2000-gal.
tank truck
Dump truck
(leak-proof)
1500-gal.
tank truck
Dump truck
Semi-trailer
truck
1
5
1
1
1
2
Tarry sludges
Source: Arthur D. Little, Inc., based on industry survey.
2-ton dump
truck (covered
& leak-proof)
4000-gal. tank
truck
Utilization
Rate
2 hauls/week
25-30 hauls/week/
truck
4 hauls/week
1 haul/day
1 haul/day/truck
1 haul/day
6 hauls/day
1 haul/day
1 haul/month/trailer
1 haul/day
1-2 hauls/week
-------
trash by some rural plants. A major paint company stores solvent-
containing oil, waste paint, and sludge in company-supplied metal
drums, which are picked up by a contractor and hauled in stake-body,
flat-bed trucks. Most chemical companies contacted use waste haulers,
but have the wastes picked up in company-supplied 55-gallon drums.
The Department of Defense (DOD), which uses contractors for all waste
hauling and dispoal, also supplies containers. Frequently DOD uses
Sea/Land Semi-Trailers, and loads these with 55-gallon drums of waste,
which are put on container ships. DOD also uses CONEX containers,
which contractors must bring back. (CONEX containers were developed
during the Korean conflict for transport of supplies.)
4. Personnel
In situations where the generator is also a transporter, wastes
are typically hauled by a single driver, who often assists with
loading and unloading. The driver is an employee of the plant and
is trained in both safe handling of the wastes and vehicle safety.
When several trips to the disposal area are made each day, as many
as four or five persons from the various shifts may serve as back-
ups to the regular driver.
5. Routing/Dispatching
Trucks are filled from storage and dispatched when loaded. They
are generally routed via the most direct pathway to their final des-
tination. In most plants, wastes are usually transported during nor-
mal working hours, but infrequently they may be transported by shift
personnel as well.
6. Loading/Unloading
Company personnel are nearly always involved in loading, often
(but not always) with assistance from the driver of the vehicle, re-
gardless of whether the driver is a company or contractor employee.
When the driver is a company employee (self-hauling situation), the
driver is nearly always involved in unloading, with assistance from
landfill personnel. The reason is that self-hauled wastes are often
transported to a small landfill or lagoon owned by the company and
dedicated to its own wastes. A given vehicle, in a single haul, will
normally be carrying only wastes from one plant and will go directly
from the plant to the landfill with no intermediate stops.
IV-12
-------
Tank trucks are frequently gravity-fed from a storage tank seated
on a platform. In some cases still bottoms or sludges may be pumped
from a holding tank or 55-gallon drums into the tank truck. In one
case (a waste oil re-refiner), tarry sludges are loaded into a tanker
via an above-ground pipeline. Tank trucks are usually unloaded by
gravity through a four-inch valve at the rear of the vehicle, directly
into a. landfill or lagoon.
Wastes transported loose in dump or stake-body, flat-bed trucks
may be loaded into the truck from a wheelbarrow, and unloaded directly
into the landfill area by dumping. Barrels and drums are usually loaded
onto flat-beds via a forklift truck operated by company personnel (or
the driver in the case of self-haulers).
7. Delivery to Disposal Site
Wastes hauled by generators are typically taken either to a site
owned and operated by the company and dedicated to the wastes in ques-
tion, or to a general purpose municipal or private landfill. When de-
livery is to a company-owned and operated site, company personnel
accept the wastes and assist in unloading them, usually directly into
a landfill or lagoon. There is typically no testing, inspection or
paper work at the disposal site.
When the final destination is a municipal or private landfill,
prior arrangements are made to ensure that the landfill is permitted
for the wastes in question, and that the landfill is operated in
accordance with regulations. Such regulations might encompass times
that wastes can be delivered, signing in at an office or weighing
station, and disposing at a designated working face. Trucks submit
a copy of the bill of lading to the landfill operator for billing
purposes. The quantity of waste delivered is recorded either by
weighing or by a volume estimate, and the truck is directed to a
dumping area. Typically, no inspection or testing is done at the
landfill site.
IV-13
-------
8. Marking, Labeling, and Placarding
Marking and labeling practice varies a great deal. Many firms
do not placard their trucks carrying hazardous waste. Many companies
said they followed DOT marking and labeling requirements, but most
admitted that application of DOT requirements to hazardous wastes
(as opposed to hazardous materials) was not entirely unambiguous.
*
A number of specific examples are discussed below.
In the chemical industry, the companies typically assume respon-
sibility for labeling, whether they self-haul or use contractors.
Several major companies had developed labeling systems of their own.
These vary from stencilling drums with yellow permanent markers and
the DOT triangle, to fairly elaborate statements of the type of
wastes, warning, disposal procedures to be used, etc. All companies
look forward to some clear and effective labeling guidelines for
waste materials.
A large inorganic chemicals manufacturer in Louisiana uses outside
contractors to haul sodium/calcium sludge wastes by truck, rail car,
and barge. Appropriate DOT labels and placards are used on rail cars
and trucks. A pharmaceutical manufacturer engaged in self-hauling
does not placard its trucks and labels drummed wastes only with a
large red dot indicating "to be destroyed." A vegetable tanning firm
in Georgia self-hauls sludge containing 3-4 percent solids in 2000-
gallon company-owned and operated tank trucks. The sludge is sold
for pasture fortification. Trucks are not placarded in any way.
An electroplating plant self-hauling fluid sludge wastes does
not placard its tank truck. A manufacturer of special machinery hauls
loose sludge and grinding wastes in an unplacarded truck. A capacitor
manufacturer uses a HWMF/transporter to convey PCB-saturated Fuller's
earth in fiber drums. The drums are labeled in accordance with DOT
standards; however, the trucks into which the drums are loaded are
unplacarded.
*
In these examples the wastes described may or may not be hazardous
materials in interstate commerce. If they are not, DOT marking, labeling,
and placarding requirements are not applicable.
IV-14
-------
9. Handling of Spilled Materials
Very few of the firms contacted could recall any actual accidental
spills or incidents. Chemical industry plants generally seem to have
a spill response procedure in place. Other industry plants often do
not.
One accident reported by a chemical plant involved a local
resident who took a drum from a disposal site illegally. The drum
exploded when it was opened and the resident lost a leg. Damages
were apparently paid by the company rather than the disposal facility,
despite the fact that the contractor had legal possession of the
waste. Another accident was reported by an electroplating plant
self-hauling sludge wastes by tank truck. The truck was struck
by another vehicle and overturned on the road. A modest attempt
was made to recover the spilled waste, and apparently there were
no damages. The Department of Defense could recall only one waste
transport accident occurring in the past twenty years. A PCB con-
tainer ruptured as it was being unloaded from a ship onto a dock.
A crane knocked the container against the side of the ship. The
Corps of Engineers vacuumed the entire bottom of the channel to
remove the PCB's. The recovered material was placed in a secure
landfill. Clean-up costs were about $750,000.
Generally, if an accident occurs on the road an "environmental
affairs" group within the company is supposed to be notified, and
procedures have been established to dispatch a clean-up crew.
D. BUSINESS/ADMINISTRATIVE PRACTICES
1. Shipping Documents
Generators, at least the major companies, do keep records of
how much waste is shipped, who carried it and where it went. Such
records are usually kept for a period of at least seven years (com-
mon business practice in part inspired by Internal Revenue Service
considerations). Self-haulers transporting to a company-owned site
IV-15
-------
typically prepare a summary report monthly on the quantity of material
•<
hauled.
2. Billing Procedures, Charges, and Contract Negotiations
Generators that self-haul off-site to their own property do not
generally account separately for the costs of waste transport and
disposal.
Decisions with respect to contracting for waste transport and
disposal are usually made by the plant manager at each location. In
general, a plant manager will require three bids before letting a
contract, but many locations do not have a choice of three contractors.
Contracts are typically signed on an annual basis. Landfills are
purportedly investigated by the plant to make sure that they are ap-
proved for the wastes in question. The contracting agreement generally
provides for the contractor to take possession of the wastes on leaving
the generator's property.
A vegetable tannery which sells its sludge wastes for pasture
fortification passes on the costs of transport to the purchasers.
Although in this case the generator hauls, the records show the
purchaser as the transporter.
3. On-Site Storage
Storage practice varies a great deal—from the electroplating
plant that self-hauls its sludges six times a day and therefore
stores in a holding tank on the average of four hours, to the resin
plant that currently has phenol wastes in "temporary" storage on-
site "pending the development of an adequate disposal method."
Most plants fall somewhere in between, storing for periods ranging
from weeks to months. A summary of information obtained by industry
is given in Table IV-3. No instance was discovered of hazardous
waste storage in company-owned vehicles.
IV-16
-------
TABLE IV-3
STORAGE PRACTICE IN SELECTED INDUSTRY SITUATIONS
Industry
Textiles
Pesticides
Inorganic
Chemicals
Pharmaceuticals
Pharmaceuticals
H
M
-J
Paints & Coatings
Electroplating &
Metal Finishing
Waste Oil Re-
refining
Waste Oil Re-
SIC No.
22XX
2879
281X
283X
283X
285X
3471
5093
5093
Type of Waste
Nylon and cotton scrap
Rinsed and crushed 5-gallon
metal insecticide containers
Sodium/calcium sludge
Radioactive material
Liquids
Emulsion sludge from tank
washings - 18% solids,
82% water
Plating sludges
Spent liquid PCB's
Tarry sludge
Oil soaked in earth
Storage Mode
Drums
Bin
Drums
Packed in drums
with vermiculite
Holding tank
(contractor-
supplied)
Holding tank
Holding tank
55-gallon drums
Holding tank
Contractor sup-
Storage Time
2-3 days
3 months
1 month
3-4 months
3-7 days
1-2 days
4 hours
5-10 days
3-7 days
5 days
refining
(filter medium)
plied containers
Not during transport.
Source: Arthur D. Little, Inc., based on industry survey.
-------
4. Driver Training/Licensing
Drivers of generator-owned and operated vehicles are company
employees, all of whom generally receive safety training. With the
promulgation of the new DOT regulations for transport of hazardous
materials, most major companies have stepped up their safety and
driver training programs.
5. Safety Practices
Apart from trying to understand and follow DOT regulations, most
companies did not seem to have a strong, affirmative safety program
in place. Diking of storage tanks, for example, is more the excep-
tion than the rule. Many trucks are not covered, and many have only
recently been made "leak proof."
6. Vehicle Maintenance
Major companies not only inspect their own transport vehicles,
but also do not permit contractor vehicles to leave the premises
until they have been inspected.
7. Regulations Followed
Everyone claims to follow DOT regulations. Many generators
claim to follow state regulations as well. A New Jersey paint
plant, for example, claimed to use a permitted hauler and a per-
mitted landfill as required by the State. A Massachusetts manu-
facturer of special machinery claims to have a hazardous waste
transporter's license from the State to self-haul. An asbestos
manufacturer claimed to adhere to EPA air quality regulations
prohibiting visible emissions during transfer, transport and
disposal operations.
E. REGULATORY CONTROL
As previously discussed in Section III.B.5, the DOT administers Federal
regulations pertaining to interstate transport of hazardous materials by
public highway, including motor vehicle safety. Furthermore, many states
IV-18
-------
have adopted these regulations, or portions thereof, for intrastate
transport of hazardous materials. The foregoing regulations apply to
generators that self-haul hazardous wastes which meet the definition
of hazardous materials. Generally speaking, it is uncommon for generators
that self-haul to cross state lines.
All generators that self-haul (excluding transport companies that
become generators when cleaning their tank trucks, etc.) are ICC-exempt
as private carriers.
IV-19
-------
y. TRANSPORT BY OPERATORS OF HAZARDOUS
WASTE MANAGEMENT FACILITIES
A. METHOD OF APPROACH
This section characterizes the transport of hazardous waste by firms also
operating hazardous waste management facilities (treatment, storage, and
disposal) acting as contract or private carriers. These carriers convey
(invariably by truck) hazardous waste from the generator's premises to
the place of treatment, storage, or disposal. To avoid needless duplica-
tion this section does not repeat those aspects which HWMF/transporters
have in common with for-hire motor carriers discussed previously.
From the EPA publication "Hazardous Waste Management Facilities in
„**
the United States - 1977 , which lists approximately 110 hazardous waste
management facilities, about 60 were initially selected. These were
described in the publication as being involved in transportation and there-
fore became candidates for interviews. At the same time, cognizant agencies
of several state governments were contacted either to develop background
information on the selected facilities or to identify other potential in-
terview candidates. The information on which this section is based was
obtained through telephone and in-person interviews with HWMF/transporters
and through perusals of state agency files. Helpful general discussions
were held with the National Solid Waste Management Association and the
National Center for Resource Recovery, but these did not yield pertinent
data compilations on HWMF/transporters or suggested transporter contacts.
A total of 75 contacts were made with firms initially identified as
HWMF/transporters, as summarized below:
Related and responding 54
Not directly related 21
Not responding ii.
Total 86
Information sources are listed in Appendix B-7.
*
**
Hazardous waste management facility/transporters.
•
EPA/530/SW-146.3, January 1977.
V-l
-------
Of these, 7 firms operated hazardous waste management facilities but did
not transport, and 14 firms transported hazardous waste but did not operate
hazardous waste management facilities. (Many firms identified initially
as HWMF/transporters in actuality provide either hazardous waste manage-
ment or transport services, but not both; however, they frequently have
working agreements with other companies providing the complementary ser-
vice. In many cases, the generator contcacting with these firms is
unaware of and disinterested in these private arrangements.)
B. FACILITIES AND SERVICES PROVIDED
1. Geographic Region Served
According to the EPA publication "Hazardous Waste Management
Facilities in the United States - 1977", 67 percent or 74 of the
listed hazardous waste management facilities are also transporters.
The majo'rity (56 percent) of the listed HWMF/transporters are located
*
in EPA Regions II and V with 35 percent in Region V alone. Region
IX (California), which has the largest number (13) of facilities
identified, has relatively few (4) which are engaged in transporta-
tion.
The location and distribution of facilities from which informa-
tion has been obtained is shown in Table V-l. Information was
obtained either directly from the facilities or indirectly through
state agencies. It should be noted that not all of the 54 facilities
from which information was obtained provided complete information
sets. Therefore, the discussions and tables which follow do not
necessarily include all facilities.
Sixty-four percent of the surveyed facilities transport hazardous
waste interstate. Further, 56 percent of the firms have facilities
in more than one state or are receiving hazardous waste from outside the
state. Thus, many of the HWMF/transporters are subject to regula-
tions of multiple jurisdictions including those of Federal agencies.
*
Region II includes New York and New Jersey, and Region V includes
Minnesota, Wisconsin, Illinois, Indiana, Ohio, and Michigan.
V-2
-------
TABLE V-l
DISTRIBUTION OF HWMF/TRANSPORTERS
SUPPLYING INFORMATION
EPA Number of
Region State HWMF/Transporters
I Connecticut 1
Massachusetts 1
II New Jersey 2
New York 2
V Illinois 1
Indiana 4
Michigan3 27
Ohio 6
VI Arkansas 1
Oklahoma 1
Texas 3
IX California 4
X Washington _1
Total 54
The large number of facilities in Michigan resulted from
access to the registration/certification files of the state's
Water Control Division of the Environmental Protection Branch,
Department of Natural Resources.
V-3
-------
2. Ownership
With the exception of a few very large companies, most HWMF/
transporters surveyed are privately owned or closely held public
corporations. Although a few firms were willing to discuss the
financial implications of the pending regulations, the private
ownership factor has mitigated against obtaining financially-related
information concerning transportation.
3. Fleet Size and Number of Employees
*
Whether expressed in terms of number of motor vehicles or num-
ber of employees involved in transportation, the HWMF/transporters
included in the investigation are relatively small; 74 percent operate
ten or fewer vehicles and at least 66 percent have ten or fewer em-
ployees. Tables V-2 and V-.3 give size distributions for the
approximately 50 firms from which data were obtained.
C. TRANSPORTATION ACTIVITIES
1. Extent of Services^
As indicated previously, most of the HWMF/transporters surveyed
convey hazardous waste both interstate and intrastate, but the total
quantity transported annually is unknown.
Those HWMF/transporters who operate only intrastate tend to serve
in a relatively small (say, less than 100-mile radius) geographical
area or section of the state. Those who operate interstate generally
serve within a region rather than operating interregionally—for in-
stance, within the heavily industrialized portion of the Midwest
including the states of Illinois, Indiana, Michigan, and Ohio. The
split between interstate and intrastate operators is unknown in terms
of quantity of waste hauled nor is it known what fraction of an inter-
state operator's business is done outside his home state.
*
Vehicles used exclusively within the hazardous waste management
facility itself are of no concern in this chapter.
V-4
-------
TABLE V-2
NUMBER OF MOTOR VEHICLES
OPERATED BY HWMF/TRANSPORTERS
Number of
Vehicles
1-2
3-5
6-10
11-15
16-20
21-30
Over 30
Total
Source: Arthur D.
Percent of Firms
Including*1
Michigan Data (N = 50)
12
28
34
14
8
0
4b
100
Little, Inc., estimates.
Percent of Firms
Excludinga
Michigan Data (N = 22)
14
18
32
18
9
0
9b
100
The differentiation being made results from the fact that the data
are dominated by those from Michigan. *
The largest number of vehicles was 100; the second largest was 50.
TABLE V-3
NUMBER OF HWMF/TRANSPORTER EMPLOYEES
INVOLVED IN TRANSPORTATION
Percent of Firms Percent of Firms
Number of Including8 Excluding3
Employees Michigan Data (N = 52) Michigan Data (N = 24)
1-5 38 29
6-10 36 38
11-15 10 8
16-20 6 4
21-25 2 4
Over 25 8 17
Total 100 100
Source: Arthur D. Little, Inc., estimates,
EThe differentiation being made results from the fact that the data are
dominated by those from Michigan. Because employee counts for the
several facilities in Michigan were unavailable, an assumption was
made that there was one employee for each vehicle in that state. This
assumption appears to be reasonable in light of interviews conducted
with other HMWF/transporters in this study.
V-5
-------
2. Age and Types of Vehicles
HWMF/transporters use motor vehicles that average between 9 and
12 years of age; the range is from brand new to over 20 years. Table
V-4 shows two distributions of the age of vehicles. The first dis-
tribution includes all vehicles for all firms. The second is restricted
to data obtained from firms in Michigan; these data may be more repre-
sentative of the actual nation-wide population in that they were
obtained from each of the 27 HWMF/transporters in Michigan (i.e., a
complete sample). Moreover, of the 116 vehicles in the "All Firms"
column whose age is five years or less, 50 vehicles are from a single
company.
TABLE V-4
MOTOR VEHICLE AGE DISTRIBUTION
FOR HWMF/TRANSPORTERS
Firms in Michigan Only
Age in
Years
1-5
6-10
11-15
16-20
Over 20
Total
All Firms
No. of Vehicles
116
61
50
39
31
297
Percent
39
21
17
13
10
100
No. of Vehicles
28
51
42
39
31
191
Mean * 12
Percent
15
27
22
20
16
100
years
Mean - 9 years
Source: Arthur D. Little, Inc., estimates.
As seen in Table V-5, tankers and tank trailers predominate in
terms of types of motor vehicles used. There are some flatbeds
and vans; these represent less than 30 percent of vehicles used.
Illustrations of various types of trucks appear in Appendix C. No
instances of barges or rail tank cars provided by HWMF/transporters
were discovered.
V-6
-------
TABLE V-5
DISTRIBUTION OF MOTOR VEHICLE TYPES
FOR HWMF/TRANSPORTERS
Type of
Vehicle
Tankers
Tank Trailers
Stake-body ,
flat-beds
Vans
Dump Trucks
Total
All Firms
No. of Vehicles
191
43
56
30
1
321*
Percent
60
13
18
9
0
100
Firms in Michigan Only
No. of Vehicles Percent
113 58
35 18
17 9
29 15
195a 100
aThe difference in vehicle counts between Tables V-4 and V-5 is due
to the unavailability of ages for all the vehicles.
Source: Arthur D. Little, Inc., estimates.
3. Container izat ion Practices
For the most part generators are responsible for supplying
portable containers. Of the 18 HWMF/transporters from whom these
data were gathered, only one assumed responsibility for supplying
containers. In two instances both the generator and HWMF/ transpor-
ter shared the responsibility; otherwise, the generator provided
the containers. Of the 16 HWMF/transporters who responded to the
inquiry, 15 said they were satisfied or generally satisfied with
generator-supplied containers. However, at the same time, they
commented on the typical problems they have encountered, for
example :
• There is often bottom corrosion of drums because
generators neglect to use pallets.
• Generators sometimes put incompatible materials in
the same container.
• Generator-provided stick-on labels come off in the rain.
• There is often poor, improper or nonexistent labeling of
wastes.
• Sometimes wastes are not chemically classified.
V-7
-------
4. Transport Personnel
As previously stated, about 70 percent of the HWMF/transporters
employ ten or fewer people who are directly involved in transporta-
tion either as drivers or vehicle maintenance personnel. For the
most part, these employees are drivers whose training is focused
on safety associated with the vehicle rather than on the hazards of
the wastes being transported. In about 80 percent of the facilities,
these ten or fewer employees represent less than 50 percent of the
total number of employees of the facility. The non-transportation
employees are involved in waste treatment and disposal, administra-
tion, and clerical support activities.
5. Waste Handling Procedures
Whether or not term or retainer contracts between the HWMF/
transporter and the generator are in effect, the generator usually
initiates the process by requesting transportation services. Usually
each transaction is treated as a separate service procurement whereby
the materials are described and the terms and conditions of pickup
and delivery are specified.
When the containers used are either drums or barrels, they are
almost always provided by the generator and are loaded onto the
transport vehicle by the generator either by forklift truck or by
hand. If the container is the transport vehicle itself (e.g.,
tank truck), the HWMF/transporter takes part in the loading; if a
vacuum truck is used, the HWMF/transporter does the loading. It
is uncommon for HWMF/transporters to mix wastes in tank or vacuum
trucks from different generators. Whatever mixing occurs is done by
the generator before the HWMF/transporter arrives. Furthermore, multiple
stops at different generators to pick up loads is uncommon.
Several HWMF/transporters indicated that they chemically analyze
materials either prior to or upon receipt of wastes. In situations
where the generator is unknown or not "trustworthy," the HWMF/trans-
porter insists on chemical analysis prior to accepting a job.
V-8
-------
Some facilities do not have chemical analysis capabilities, although
most do have them. In either event, if the HWMF/transporter engages
in treatment or reclamation, it takes care to ascertain contents in
order to protect its equipment. With respect to delivery to the
disposal site by HWMF/transporters, there is invariably someone at
the site to accept the waste.
6. Marking, Labeling, and Placarding
No firm indicated that it was not behaving responsibly with
respect to marking, labeling, and placarding requirements. That is,
their motor vehicles bear an identification of the company and a
placard indicating the hazardous nature of the materials being
transported. In this respect, most of the facilities indicated
that they followed DOT regulations. In instances where DOT was not
cited, the HWMF/transporter identified state (e.g., California,
Texas, Ohio) regulations as the controlling factor for marking and
describing the nature of the cargo.
With respect to labeling, the HWMF/transporters indicated that
they properly identified the materials contained in drums or barrels.
However, many indicated that generators or other transporters either
did not take care in labeling or were ignorant of the importance of
proper labeling.
D. BUSINESS/ADMINISTRATIVE PRACTICES
1. Shipping Documents
Nearly all the HWMF/transporters indicated that they prepare and
retain documents which at a minimum describe the quantity, source,
waste type, and delivery point for each transport/disposal job.
These records, which contain signatures upon delivery or transfer
are in one form or another, including: billing records (invoices),
shipping documents or bills of lading, purchase orders or job tickets,
and self-initiated or state-required manifests. Sample shipping
documents appear in Appendix D. Usually these documents, which
V-9
-------
represent stages in a transaction, are filed together. Among the
states which require record keeping and reporting to show quantity,
source, waste type, and delivery point are: California, Illinois,
Indiana, New York, Michigan, Ohio, Oklahoma, and Texas.
Based upon common business practice and upon the requirements
of the IRS (7-year retention for financial records), the ICC (3-year
retention), state tax departments, and other cognizant state agencies,
it is safe to assume that these documents are being retained for
several years. In those states where a manifest system has been, or
is about to be, implemented the norm for record retention is two to
three years.
2. On-Site Storage
HWMF/transporters admit to a minimal amount of on-site storage
at their treatment or disposal facilities. However, no instance of
off-site storage was discovered.
3. Safety Practices^
As might be expected, no HWMF/transporter suggested that it was
not taking safety precautions or did not have adequately trained
employees. In many instances, "DOT spill-handling procedures" were
cited as being in effect (these were not explained satisfactorily).
Many firms indicated that they provided driver training, including
safety training concerning the nature of materials transported.
However, discussions with staff of the cognizant agencies in several
states suggested that, in many instances, training was inadequate.
Data with respect to vehicle inspection/certification and main-
tenance are sketchy. However, many of the"HWMF/transporters indi-
cated that the states in which they operate have motor vehicle
inspection/certification requirements; several indicated that they
perform their own inspection to be assured of certification.
V-10
-------
E. REGULATORY CONTROL
As previously discussed in Section IIIB5, the DOT administers Federal
regulations pertaining to interstate transport of hazardous materials by
public highway, including motor vehicle safety. Furthermore, many states
have adopted these regulations, or portions thereof, for intrastate trans-
port of hazardous materials. The foregoing regulations apply to HWMF/
transporters conveying hazardous wastes which meet the definition of
hazardous materials.
It appears that HWMF/transporters are in general ICC-exempt on one
or more counts: first, many do not engage in interstate commerce; second,
most operate as private carriers (transporting their own property only as
an incidental activity in furtherance of their regular business); third,
-^
waste intended for disposal (as opposed to resource recovery, recycling,
or reuse) may be an ICC-exempt commodity because the waste is not a manu-
factured end product possessing economic value (i.e., not "property").
According to case law, private trucking is illegal if it is a secondary
business with the express purpose of profiting from the transportation.
V-ll
-------
VI. ECONOMIC DESCRIPTION OF
HAZARDOUS WASTE TRANSPORT
A. INTRODUCTION
The basic role of the transportation sector in the management of
hazardous waste is to convey hazardous waste from the point of generation
to an off-site waste facility for treatment, resource recovery, storage,
and/or disposal. The modes of transportation involved in this activity
are: motor carrier, rail, water, air, and pipeline, with motor carrier
(i.e., motor truck) by far the dominant mode and rail a distant second.
The quantity of hazardous waste transported by air and pipeline is minimal.
Three groups of participants have been identified as transporters
of hazardous waste:
• Generator/transporter - Generators, including industrial,
commercial, and governmental organizations, that act as
private carriers and self-haul hazardous wastes, invariably
by truck, to off-site hazardous waste management facilities.
• For-hire transporter - Common and contract carriers, whose
principal business is commodity transportation, that trans-
port hazardous waste from the point of generation to off-
site hazardous waste management facilities which they do
not operate.
• Hazardous Waste Management Facility (HWMF)/transporter -
Operators of hazardous waste management facilities that
act as contract or private carriers in transporting hazardous
waste from the point of generation to treatment, storage, or
disposal facilities.
The transporter is, by definition, the party providing the motive power
for the shipment. Thus, a generator of hazardous waste who owns and loads
a rail tank car is considered a Generator/transporter only if that party
were to operate the locomotive.
VI-1
-------
These participants, especially the Generator/transporter, generally
do not view themselves as being part of an industry devoted to hazardous
waste transportation, and indeed these transportation activities do not
conform to the customary definition of an industry. Rather, they view
themselves as being engaged in an activity which is part of a larger set
of business activities; they engage in hazardous waste transportation
because of convenience or for economic reasons, but it is not per se
their principal commercial interest. Most for-hire transporters are in
the business ot hauling cargo which is only sometimes hazardous waste,
although some may specialize in transporting, hazardous materials and/or
waste. Maiay of the waste management facilities (HWMF/transporters) are
engaged in waste transportation as a complement to their other waste
handling activities.
The supply and demand elements of this sector are dictated by the
quantities and characteristics of the hazardous waste generated. A small
firm generating a low volume of hazardous waste is more likely to use its
own trucks to transport the wastes off-site. Also, this may occur when
contract transporters refuse to handle small quantities of waste. On the
other hand, firms generating high volumes of hazardous waste may require
contract transporters to collect the wastes daily, weekly, or as neces-
sary, if they do not haul themselves.
The choice of transport mode depends upon the distance of the
hazardous waste management facility from the point of generation, the
frequency of collection, the environmental setting, the plans for usage
of the hazardous waste, and the like. For example, a firm located on
or near a waterway may utilize barge transportation. Or firms that
have hazardous wastes transported over 50 miles may employ truck or rail
services. These examples are prevalent particularly when hazardous waste
goes to a resource recovery facility.
The mode of transport used for hazardous waste is predominantly
truck (94 percent by weight), with some rail (5 percent) and a limited
amount of barge transport (1 percent). The amount of hazardous waste
VI-2
-------
transported by air carrier and pipeline is negligible. Generators that
self-haul and HWMF/transporters invariably use truck transport. The
shipper (generator) usually owns rail tank cars and occasionally barges;
however, rail and barge transport is exclusively performed by a for-
hire transportation company.
B. ECONOMIC CHARACTERISTICS OF FIRMS ENGAGED IN TRANSPORT
1. Generators
The EPA has identified- a number of industries which generate
potentially significant amounts of hazardous waste. Table VI-1
lists those generator industries as well as the 1975 value of
shipments and number of establishments in each industry.
All but one of the industries (waste oil re-refining) fall
within the manufacturing sector SIC codes (20XX to 39XX). Genera-
tors, as the producers of hazardous waste, create the need for
hazardous waste management. If the generator does not treat,
store, or dispose of the hazardous waste on-site, then the waste
must be transported from the generating location to an off-site
hazardous waste treatment facility, which the generator may or may
not own. The generator ordinarily incurs the cost of transport*as
part of the cost of off-site treatment, storage, or disposal,
whether the waste is hauled by the generator itself, the hazardous
waste management facility, or an independent for-hire transportation
company.
The waste oil re-refiners are part of SIC 5093, Scrap Service
and Waste Products, which includes scrap metal dealers and sellers
of textile waste as well as petroleum re-refining. The total sales
for SIC 5093 were $9.7 billion for the twelve months ending August
1977, the transport cost of re-refiner's waste is small in compari-
son. However, this may be misleading if re-refiners are a small
portion of industry 5093 sales.
*Although a generator may be paid for waste delivered to a resource
recovery facility, the generator still bears the cost of transport.
VI-3
-------
TABLE VI-1
TOTAL COST OF HAZARDOUS WASTE TRANSPORT 10 SELECTED GENERATING INDUSTRIES
Indus try
Textiles
Pharmaceuticals
Inorganic Chemicals
Paints & Coatings
Organic Chemicals,
Pesticides,
Explosives
Petroleum Refining
Leather Tanning
Metal Smelting &
Refining
M
1
Electroplating &
Metal Finishing
Special Machinery,
Office Machines
Electronic Components
Storage Batteries
Waste Oil Re- refining
Totals
SIC
Code
22XX
2831
2833
2834
281X
2851
2869,
2879,
2892
2911
3111
3331,
3332,
3334,
3339
3471
355X
357X
3671-79
3691
5093
1975
Value of
Shipments
13,348.9
758.2
1,484.4
8,178.2
8,177.7
4,677.5
14,017.1
2,265.9
412.3
52,169.6
1,027.1
2,371.1
NA
2,759.8
578.6
1,230.9
8,267.8
11,061.2
9,799.7
1,291.1
9,690.0
153,567.1
($ Millions)
Estimated
1975 1972
Value
Added
5,501
478
757
6,452
4,316
2,192
7,582
1,179
288
9,247
357
417
NA
1,149
219
881
4,965
6,224
5,917
636
NA
57,764
.3
.4
.9
.3
.9
.3
.0
.2
.0
.4
.0
.4
.1
.2
.9
.7
.7
.2
.2
.1
Number of
Estimated Cost Waste
of Waste Transport
Hazardous Waste Transport Cost as %
Disposed
Off -Site Upper
Establishments Wet Metric Tonsd Bound
4,572
182
140
756
1,419
1,599
514
388
93
323
517
31
16
31
82
3,265
3,681
993
5,232
213
7,139
31,186
103
62
567
139
1,300
844
164
351
2,837
145
55
353
55
6,976
,000
,050
,000
,450
,000
,000
,350
,000
,000
,000
,700
,000
,000
,550
3.4
2.0
18.7
4.6
42.9
27.9
5.4
11.6
93.6
4.8
1.8
11.6
l.p
230.1
Lower
Bound
0.4
0.2
2.3
0.6
5.2
3.4
0.7
1.4
11.3
0.6
0.2
1.4
0.1
27.9
Value-Added
Upper
0.06%
0.03
0.43
0.21
0.47
0.30
1.51
0.65
10.60
0.04
0.03
1.82
Lower
<0.01%
<0.01
0.05
0.03
0.06
0.04
0.20
0.08
1.28
<0.01
<0.01
0.22
Reference 34
bReference 35 (1972 Value Added * 1972 Value of Shipments) x 1976 Value Shipments
Reference 34
dTable IV-1
6 ADL estimates based upon lower bound cost/ton-mile of $0.08, an upper bound ccost/ton-mile of $0.66, 50-mile
Percent of value of shipments
round trip.
-------
For generators, the management of hazardous waste is an activity
necessary to continuance of the manufacturing process but is ancillary
to their principal business. Table VI-1 contains an estimate of the
range of cost of hazardous waste transport based upon the range of
known truck transport rates. While the transport cost relative to
industry value of shipments varies, it is a very small portion of
total value-added in each SIC category, with the exception of the
Electroplating and Metal Finishing industry, where it may reach 10
percent.
2. Hazardous Waste Management Facilities
a. Supply/Demand
A number of hazardous waste management facilities provide
transportation service as a means of obtaining a hazardous
waste to treat, store, or dispose. Often, the price for the
transport service is embedded in the overall management cost and
not shown or quoted as a separate item. Where price is broken
out, it is quite variable from facility to facility ($0.075 to
$1.00 per ton-mile); however, hazardous waste management facili-
ties do not seem to keep track of transport costs separately
from disposal costs.
Some hazardous waste management facilities are owned by
large corporations—for example, Chemtrol and Rollins—while
others are owned by small companies operating only one or two
facilities. In 1975, five firms generated over one-third of
total industry sales, while hazardous waste management revenue
varied from $12,000 to $12 million per firm. Table VI-2 de-
picts the distribution of hazardous waste management facility
sales in 1975. According to this distribution, the median
sales value was $1.0 million.
b. Financial Profiles^
The pro-forma financial statements shown in Table VI-3 were
derived from data developed by an EPA contractor. These data
VI-5
-------
TABLE VI-2
DISTRIBUTION OF HAZARDOUS WASTE MANAGEMENT
COMPANIES BY SALES VOLUME
1975
Percentage of Firms
Sales Volume in Sales Bracket
Up to $100,000 19
$100,000 - $500,000 , 21
$500,000 - $1,000,000 15
$1,000,000 - $2,000,000 31
$2,000,000 - $5,000,000 10
$5,000,000 or greater 4
Total 100
Median Value = $1,000,000
SOURCE: Reference 1.
VI-6
-------
TABLE VI-3
FINANCIAL PROFILE OF HAZARDOUS WASTE MANAGEMENT
FACILITIES ALSO ENGAGED IN TRANSPORTATION
INCOME STATEMENT
Percent of Total Revenues
Expenses
Depreciation
Operating Profit
Other Income (Expense)
Profit Before Tax
Tax
Profit After Tax
78.6
9.6
11.8
(3.7)
8.1
3.9
4.2
BALANCE SHEET
Assets
Current Assets 30.9%
Fixed Assets 69.1
Total Assets 100.0%
Liabilities
Current Liabilities 32.9%
Long-Term Debt 35.6
Equity 31.5
Total Liabilities 100.0%
SOURCE: Derived by Arthur D. Little, Inc., from Reference 1.
VI-7
-------
were used as the basis of the economic impact assessment of
RCRA Section 3003 regulations upon the hazardous waste transport
sector.
At the present time, about 67-75 percent of disposal
facilities also provide transportation service. They also
typically accept waste transported by generators and for-hire
transportation companies. Because the total amount of hazar-
dous waste transported by hazardous waste management facilities
as a whole is unknown, the total cost of transport incurred by
them cannot be determined. There is no way at present to de-
termine the portion of total revenue/cost shown in Table VI-1
that is attributable to hazardous waste management facilities.
The impact assessment to follow (Section VIIl) is therefore based
upon the "average" facility as represented by the pro-forma
models contained in Reference 1.
3. For-hire Transportation Companies
a. Supply/Demand
For-hire transportation companies carrying hazardous waste
are predominantly trucking companies, aside from the relatively
few instances of barge transport or rail shipment. For most
for-hire trucking companies, hazardous waste is but a small
portion of their total business, and they view the shipment of
hazardous waste in the same way as the shipment of hazardous
material.
Because the total amount of hazardous waste carried by for-
hire transportation companies as opposed to generators and HWMF/
transporters is unknown, there is no way at present to determine
the portion of total revenue/cost shown in Table VI-1 that is
attributable to for-hire transportation companies.
VI-8
-------
b. Financial Profiles
Pro-forma financial statements for for-hire transporters of
hazardous waste, developed from a composite of sources,33'38 are
shown in Table VI-4. Each of the sources used was also based
upon a composite of companies, so any given company could vary
appreciably from the pro-forma company. However, the pro-forma
financial statements are consistent with investment costs and
depreciation periods for truck equipment described in Chapter
VII, Process Economic Models. The pro-forma trucking company
also includes capital assets other than trucks, amounting to
16 percent of fixed assets; general and administrative expenses
38
for this type of company amount to 15 percent of sales.
In general, the financial risk perceived for a trucking
company is less than that for a hazardous waste management
facility of comparable size. Transportation companies do not
have the long-term liabilities of hazardous waste management
facilities, do not have their pollution problems, and together
possess a greater experience base for the evaluation of finan-
cial risk. Also, the assets of truck companies engaged in
hazardous waste transport are trailers and tractors which are
fungible with those used in the transport of other commodities.
In simple terms, this means that if a bank must repossess a
truck due to payment default, there is a market for such vehicles
so that the bank has less at risk if the truck company cannot
meet its payment obligations. Trucking companies are generally
able to finance equipment purchase. Smaller companies may be
required to put up more of a down payment than larger companies
(20 percent versus 10 percent) in the case of purchased equip-
ment with bank financing. Also, the truck company has the
option of leasing the equipment.
VI-9
-------
TABLE VI-4
FINANCIAL PROFILE OF FOR-HIRE TRANSPORTERS OF
HAZARDOUS WASTE
INCOME STATEMENT
Expenses
Depreciation
Operating Profit
Other Income (Expense)
Profit Before Tax
Tax
Profit After Tax
Percent of Total Revenues
84.2
9.9
5.9
(0.4)
5.5
2.6
2.9
BALANCE SHEET
Assets
Current Assets
Fixed Assets
Total Assets
Liabilities
Current Liabilities 15.8%
Long-Term Debt 28.8
Equity 55.4
Total Liabilities 100.0%
SOURCE: Derived by Arthur D. Little, Inc., from References 33 and 38.
VI-10
-------
To contrast for-hire transporters with HWMF/transporters, the
latter can also probably obtain similar financing for truck
equipment but not for investments in incineration equipment,
pollution control equipment, and landfill construction.
C. ECONOMIC CHARACTERIZATION OF HAZARDOUS WASTE TRANSPORTATION
1. Substitutes and Alternatives
There is potential substitution of one mode of transport for
another and substitutability among transportation services that
could be provided by generators, for-hire transporters, or hazar-
dous waste management facilities. In addition, some generators
have the option of on-site disposal, which may or may not require
transportation service.
As mentioned in Chapter IV, the decision for a generator to
self-haul or use an outside service is made at the plant level.
Also, a plant generating a small volume of waste is more likely
to self-haul than a plant generating a large volume because of
the probable inability to find a contractor to handle a small
quantity of waste.
There are definite scale economies in hazardous waste dis-
posal; the average cost curve is shown in Figure VI-1. Although
there are differences of opinion as to the shape of the average
cost curve and the point at which it levels off, most generating
plants would fall on the sharply falling portion of the cost curve.
The implication of this, purely from an out-of-pocket cost stand-
point, is that transportation cost per ton-mile must be significant
(due to long distance for off-site disposal, etc.) to make on-
site disposal economically attractive.
As mentioned above, there are non-cost factors which determine
whether off-site disposal, and therefore hazardous waste transport,is
selected. For example, generators desire to eliminate their liability
VI-11
-------
FIGURE VI-1
AVERAGE COST FOR
HAZARDOUS WASTE DISPOSAL
AT SECURE LANDFILLS
$
Cost
Per
Cubic
Meter
100
90
80
70
60
50
40
30
20
10
Average Cost
Most
Generators
10 15
Annual Capacity
(000 Cubic Meters)
20
VI-12
-------
associated with disposal and also may not have available to them
land for on-site disposal. These factors permit contractors to
charge a premium for hazardous waste transport and disposal. The
nature of hazardous waste disposal and the role of hazardous waste
transport in this process indicate that the price elasticity of
demand for the transportation activity is likely to be inelastic.
2. Capacity Utilization and Growth
Hazardous waste management facilities have been operating at
about 50 percent of capacity in recent years. At the same time,
transportation equipment at hazardous waste management facilities
32
has been operated at 75-80 percent of capacity. This study 'has
found that for-hire transporters utilize their trucks at nearly
100 percent of capacity (8-14 hours/day) . Generators who self-
haul appear to have the lowest capacity utilization rates because
&&
they typically make one short haul per day. The implication of
current capacity utilization rates are that HWMF/ transporters can
handle some expansion in hazardous waste transported without pur-
chasing additional equipment, while many for-hire transporters
would require additional equipment if the amount of hazardous waste
transported off -site increased significantly-
3^. Pricing Practices
Generators of hazardous waste who self-haul do not provide
3*2
hazardous waste transport services to other firms. They, however,
ultimately pay the price for hazardous waste transport either
through out-of-pocket cost for their own trucks and tank cars or
through purchase of the service as part of, or ancillary to, hazar-
dous waste disposal.
Section III.B.3.b
**
Section IV.C.2
VI-13
-------
For-hire transportation companies can operate as common or
contract carriers. In the former case, particularly where interstate
transport is involved, the transport rate may be a tariff price.
This is particularly true for all rail shipments and also applies to
some truck transport. In the latter case, the price is a figure
mutually agreed up,on by the generator and hauler.
As previously mentioned, hazardous waste management facilities
that also provide transportation service often do not break out the
transportation charge. Where they do, the range varies widely, from
32
$0.075 to $1.00 per ton-mile, without apparent explanation. Since
hazardous waste management facilities do not generally keep track of
transport costs, the price for transport could be below the average
transportation cost per ton-mile under some conditions.
There are no apparent constraints upon pricing and the ability
of individual transportation parties to change prices, except compe-
tition from illegal dumpers and long-term contractors. Many hazardous
waste management facilities complain about their inability to price-
32
compete with illegal dumpers. Long-term contracts that do not al-
low for cost pass-through could defer price increases to cover cost
increases. However, the extent of the use of this type of contract
is unknown.
VI-14
-------
VII. COST OF COMPLIANCE WITH RCRA SECTION 3003
A. PROCESS ECONOMIC MODELS
1. Approach
In order to assess the incremental cost of compliance with
standards pursuant to Section 3003 of RCRA for transporters of
hazardous waste, a data base was established to provide cost re-
presentations for each segment of the hazardous waste transport
*
industry. Cost elements and other entities of interest in the
configuration of the cost representations include:
• capital cost of transport equipment;
• annual operating cost of transport equipment;
• type of hazardous waste transported;
• transport equipment type (capacity, features);
• annual mileage;
• annual volume of waste transported;
• roundtrip transport distance;
• charge rate for tonnage hauled.
The most common transport operations in each of the industry
segments is used in the analysis. Transportation operations differ
according to the type of waste transported and according to the
type of transport equipment used in moving the various waste types.
Information presented earlier indicates that transporters in each
industry segment employ basically the same type of transport equip-
ment for containment of wastes in transit. For example, lined or
insulated tank and vacuum units generally contain spent acids, spent
caustics, hydrocarbons, and some solvents. Aluminum and stainless
steel units (uninsulated or unlined), and drums contain numerous
waste types, e.g., oily waste, flammable waste, cyanide waste,
sludges, etc., that do not react with materials containing them.
In essence, the weight and chemical/physical properties of the waste
dictate the type of transport equipment to be used.
The term "industry" is used hereafter to mean those firms engaging in
the transport of hazardous waste.
VII-1
-------
The primary information source of this chapter is based on
personal communication with firms engaged in hazardous waste trans-
portation. Transporters contacted were unwilling, for the most
part, to discuss capital and annual operating costs for transport
equipment. Some transporters did supply the rates charged for
tonnage hauled and fragmented examples of what a typical hauling
trip would entail. To circumvent the problem of fragmented infor-
mation, several scenarios were formulated to provide an adequate
representation of the industry.
Based on specifications from the preceding industry characteri-
zation and contacts with several manufacturers of transport equipment
and trucking associations who supplied information regarding capital
and operating costs of equipment used in hazardous waste transport,
five truck scenarios and one rail scenario were developed to serve as
transport models. Several associations and transporters were recon-
tacted to verify the resulting data, and these contacts also suggested
revisions when the figures used were considered non-representative.
Thus, the scenarios depict expenses for the most common transport
operations discovered in the industry, and, in turn, are used in the
models which examine the economic impacts resulting from compliance
with standards governing the transport industry.
The individual truck transport models were combined along with
company financial characteristics to approximate fleets that are
representative of hazardous waste management facility fleets and
for-hire transporter fleets. Generator fleets were analyzed on a
stand-alone basis because waste transport is such a small portion
of their total cost of operation.
VII-2
-------
B. TRANSPORTATION MODELS
1. Vehicle Types
Process economic models were developed for five truck vehicles
and one rail tank car; they are described in Table VII-1. The
process economic models for trucks were based on the "Trip Distance/
Frequency" scenarios shown in the table. In addition a number of
assumptions were used in the formulation of the truck costs and
scenario parameters, as follows:
21 22
• The driver workday is eight hours, five days per week; '
• There are 250 operating days per year;
• The driver's salary plus fringe benefits is approximately
21 7?
$23,000; '
• Vehicle insurance, licenses and taxes, amount to $3,500
21
per truck;
27 o/:
• Fuel cost is $0.55 per gallon; '
• Vehicles travel at an average speed of 40 miles per hour;
• Vehicle loading and unloading time averages two hours per
trip for tank trucks, and three hours per trip for flat-
beds;
27 o£
• Vehicles obtain six miles per gallon of fuel. '
Tonnage capacity for equipment was based upon the following
measurement units:
• 231 cubic inches per gallon;
» 1728 cubic inches per cubic foot;
*
• 70 pounds of bulk waste per cubic foot;
• 2000 pounds per (short) ton.
In addition, waste moving in bulk was estimated to have an ullage
of 10 percent for both truck and barge transport.
Truck tractors and trailers have a useful life of eight to ten
years under normal conditions. Power equipment with gasoline engines
may transport up to 100,000 miles before major maintenance is needed,
Many bulk wastes are aqueous solutions or solvents. Some are lighter
than water (petroleum wastes) while others are heavier (spent sulfuric
acid, chlorinated solvents). The truck models are based on the assump-
tion that the wastes, on average, will be slightfy heavier than water.
VII-3
-------
TABLE VII-1
HAZARDOUS WASTE TRANSPORTATION
VEHICLE SCENARIO MODELS
Description
Typical Trip
Roundtrip Distance
Trips /Day
Waste Tonnage/Trip
Ton-miles/year
Capital Cost
Tractor
Truck
Container
Operating Cost
Salary plus fringes
Insurance, Taxes, etc.
Fuel, Oil, Tires
Maintenance & Repair
Total Annual
Operating Cost/Ton-Mile3
Annual Aye. Cost/
Ton-Mile
Scenario 1
Three axle,
power unit trac-
tor; unlined
aluminum tank
unit (4,500 gal.)
40 miles
2 trips
19 tons/trip
190,000 ton-mi.
$35,000
12,500
$47,500
$23,000
3,500
5,000
1,000
$32,500
$0.17
$0.21
Scenario 2
Two axle, power
unit tractor;
unlined alumi-
num tank unit
(1,600 gal.)
•
10 miles
3 trips
7 tons/trip
26,250 ton-mi.
$25,000
10,000
$35,000
$23,000
3,500
1,500
375
$28,375
$1.08
$1.28
Scenario 3
Semi-tank, three
axle power unit
trailer; unlined
aluminum tank
unit (6,000 gal.)
200 miles
1 trip
25 tons/trip
625,000 ton-mi.
$35,000
20,000
$55,000
$23,000
3,500
12,500
2,500
$41,500
$0.07
$0.08
1 Scenario 4
Tilt-frame with
40-foot roll-off
container (80, 55
gal. drums).
Three axle power
unit tractor
50 miles
2 trips
18 tons/trip
225,000 ton-mi.
$35,000
c
13,000
2,000
$50,000
$23,000
3,500
6,250
1,250
$34,000
$0.15
$0.18
Scenario 5
Straight truck
with 20-foot bed
(30, 55-gal.
drums)
25 miles
2 trips
8 tons /trip
50,000 ton-mi.
$24,000
$24,000
$23,000
3,500
2,500
625
$29,625
$0.59
$0.66
Scenario 6
Lined tank rail
car with capacit
of 13,350 gal.
12,500 mi/yr.
90 tons
1,125,000 ton-mi
$33,000
3,500
$36,500
$60,600d
900
$61,500
$0.055
$0.058
aTotal Operating Cost * Annual Ton-miles
b(Total Operating Cost - Annualized Capital Cost) t Ton-miles
CHolst Frame
Rail transporter net charge
Source: Arthur D. Little, Inc., estimates.
-------
while diesel engines may not require major maintenance for 200,000
miles. While vehicles making short trips will get 8 to 20 miles
per gallon of fuel, 6 miles per gallon was suggested as a good
average for modelling.21'22'26
Each of the models in Table VII-1 has the following components:
• Description;
• Typical trip;
• Capital costs;
• Operating costs.
The description and typical trip components complete the trans-
port scenario. While generators, for-hire transporters, and hazar-
dous waste management facilities could have any of these trucks in
their fleet, generators would be better represented by the short-
haul scenarios (Models 2 and 5). Model 6, a lined rail tank car,
is also particular to generators, since they either own or lease
26
their own rail tank cars.
The "Capital Costs" represent the estimated purchase price of
the tractor and trailer truck units in Models 1 through 5 and the
cost of a rail tank car in Model 6. Additional truck equipment
costs are shown in Table VII-2. According to manufacturers, trucking
28
companies may order optional equipment and accessories. The
cost models employ only the basic equipment required to fit the
scenario.
Operating costs for trucks are principally comprised of the
truck driver's salary, fuel costs, insurance and taxes, and main-
tenance costs. The insurance costs are primarily for liability
insurance and are therefore not vehicle-size or value dependent.
The annual operating costs per ton-mile, exclusive of capital
charges, vary with the size and capacity of the vehicle. Long
distance, large volume vehicles have considerably lower operating
Table IV-2. VLI-5
-------
TABLE VII-2
ADDITIONAL TRANSPORTATION EQUIPMENT COSTS
Semi-tank trailers
rubber-lined
stainless steel uninsulated
stainless steel insulated
Tank trucks
tank units
Vacuum trucks
power unit
vacuum units
Straight truck
Tank accessories (pump,
hoses, etc.)
Used power equipment
Size/Capacity
6000 gallons
1600-4500 gallons
2 axle
1600-2200 gallons
Approximate
Cost Range, Dollars
25,000-30,000
37,000
42,000-45,000
10,000-16,000
25,000
16,000-18,000
light to heavy model 12,000-30,000
3,000+
2 or 3 axle 10,000+
SOURCE: Reference 26 .
VII-6
-------
costs per ton-mile than small, short-haul vehicles ($0.07 - $0.17
per ton-mile versus $0.42 - $1.08 per ton-mile, respectively). A
common price for bulk waste transport is about $0.12 per ton-mile,
with values ranging to over $1.00 per ton-mile. The scenarios pro-
duce >costs per ton-mile covering this range. Transportation scenarios
1, 3, 4 and 5 are representative of hazardous waste transport by for-
hire trucking companies and hazardous waste management facilities.
Scenario 2 is more representative of a self-hauling generator, al-
though many self-haulers would have a lower capacity utilization.
Data collected from railroads on rail shipments of hazardous
waste are contained in Appendix E. Additional information was ob-
tained from a rail tank car manufacturer. From the data in Appen-
dix E, it becomes apparent that spent sulfuric acid comprises most
of the hazardous waste shipped by rail. Spent sulfuric acid moves
in lined tank cars of 13,350 gallons capacity. The lining (rubber
or epoxy) depends on the composition of the waste.
Tank cars can be leased or purchased. The base price of the
car is $33,000 new, plus $2,000 to $5,000 for the lining; delivery
time is 5-6 months following order placement. The usual lease
period is 12 years, with the investment tax credit accruing to
the lessor. An approximate lease rate is $375 per month, which
covers maintenance, taxes and a multitude of other smaller items,
as well as capital cost.
When the shipper or consignee supplies a tank car, the railroad
makes "mileage payments"to the owner. If the car is leased, the
lessor offsets the mileage payment against the lease payment (up
to 100%), so the payment accrues to the shipper. The mileage
payment depends on the depreciated value of the car. For the type
considered here, it is $0.21 per loaded mile for a new car and
$0.18 for one that is old but not ancient. In the calculations,
$0.20 was used. The average tank car travels 12,500 loaded miles/
year.
VII-7
-------
Barge transport of hazardous waste is infrequent and the pro-
visions of Section 3003 are similar to existing Coast Guard regula-
tions, so that no barge model was constructed.
Based upon the limited information available, the following costs
and prices were found for barges:
• Capital cost: $175,000 to $200,000;
• Rate $10 to $12 per ton of cargo.
A typical one-way trip could originate in the Great Lakes and ter-
minate in Houston—& distance of 1200 miles. A 3-compartment, double-
hulled tank barge with a capacity of 1400 tons would be suitable for
hauling bulk hazardous waste.
2. Facility Models
The truck models described above were then employed to simulate
for-hire transportation companies and hazardous waste management
facilities.
As discussed in Section III.B, the median fleet size of truck
transporters is 14 and the average distance per round trip is 50
miles. The model truck transporter company was assumed to own
two vehicles each of Model types 1, 2, 3, and eight of Model type
4. This combination of transport scenarios is equivalent to an
average roundtrip distance of 64 miles.
The hazardous waste management facilities have an average fleet
size of seven vehicles. The hypothetical company was assumed to
have one each of truck Models 1, 2, and 3 and four of Model type 4.
The same assumptions as to depreciation, equipment life and financing
were used for both (see Chapter VIII).
VII-8
-------
C. COMPLIANCE ACTIVITIES REQUIRED UNDER SECTION 3003
Regulations applicable to transporters of hazardous waste were
proposed pursuant to Section 3003 of RCRA (42 USC 6901) on April 28,
1978 (see Appendix A). These regulations, summarized below, contain
provisions for registration, recordkeeping; acceptance, handling, and
delivery of hazardous waste; marking of vehicles; and reporting of
incidents for transportation of hazardous wastes requiring a manifest
under Section 3002 of the Act.
1. Scope^
The regulations apply to any person or Federal agency that
transports hazardous waste within the United States, excluding
transport on the site of a hazardous waste generator or permitted
hazardous waste management facility. All transporters must comply
with applicable hazardous materials regulations of the DOT.
2. Registration
Transporters must notify the EPA or authorized state agency that it
transports or intends to transport hazardous waste. Upon notifica-
tion, the transporter will obtain from the EPA an identification
code which must appear on 1) all manifests it handles, 2) any inci-
dent report, and 3) the delivery document, if one is issued.
3. Recordkeeping
Recordkeeping provisions require that the transporter maintain
for at least three years 1) a copy of the manifest, or 2) a delivery
or other shipping document which contains certification of receipt
of waste at a permitted hazardous waste management facility.
4. Acceptance/Manifest Compliance
In accepting the hazardous waste, the transporter must obtain
a manifest signed by the generator certifying that the waste has
been properly described, labelled, contained, and designated for
shipment to a permitted facility. The transporter must sign the
VII-9
-------
manifest acknowledging acceptance of the waste. Subsequent trans-
porters handling the same shipment must obtain or prepare a manifest
or shipping document containing prescribed information.
5. Handling
In handling the wastes, the transporter must load and stow the
wastes so that hazardous materials which are incompatible do not
come in contact with one another. It is the transporter's responsi-
bility to replace labels lost during shipment and to report any
leaking containers. Transporters must not transport containers
which are leaking or appear to be damaged.
6. Delivery
Upon delivery of the waste only to the permitted hazardous
waste management facility designated by the generator,
(a) the transporter must obtain certification of delivery on
the manifest from an authorized agent of the facility, or
(b) if the transporter cannot obtain immediate certification
of delivery, such certification on the manifest or delivery
document must be acquired within five working days after
delivery of the shipment.
7. Spills and Reporting
The regulation provides for expeditious handling of a spill
which represents a hazard to human health or the environment whereby
the transporter is required to a) telephone immediately the National
Response Center, U.S. Coast Guard, or predesignated on-scene coor-
dinator; b) file a written report to the DOT; and c) clean up the
spill or take other action as may be required by Federal, state or
local agencies.
VII-10
-------
8. Marking, of Vehicles
Placarding requirements apply to hazardous waste meeting DOT's
definition of a hazardous material. All hazardous waste transporters
whose vehicles require DOT placarding or are carrying more than 1000
pounds of hazardous waste must mark their vehicles with:
• The name of the transporter; and
• The city or community of the home office.
COST OF COMPLIANCE
1. Registration
All transporters must initially register with the EPA or
authorized state. A base expense of $24 is estimated for employer
time (1 hour at $20 including fringes) and a clerk's time (1/2
hour at $8 including fringes) as follows:
Owner time: 1 hour at $20 = $20
Clerk time: 1/2 hour at $8 = 4
Total $24
2. Recordkeeping
Existing DOT and ICC regulations apply to rail carriers. As
a result of routine railroad industry recordkeeping practices, there
is no incremental cost of recordkeeping for rail carriers because
existing bills of lading, etc., can be modified and used as Section
3003 manifests. V
i
For intrastate truck transporters, annual recordkeeping expendi-
tures would occur in those states where three-year requirements do
not currently exist (24 states). Costs for maintaining these
records are estimated at one hour of clerical time for filing per
month plus $20 per year for three years for storage- Unit costs
per truck per year operated in a state with no recordkeeping re-
quirements are therefore:
VII-11
-------
Clerk's time 1 hour/month 12 x $8 = $96
Annual storage 20
Total $116 per truck/year
These costs amount to a maximum of 0.4 percent of annual operating
costs for any one of the five truck models in Scenarios 1-5.
3. Compliance with the Manifest System; Acceptance and Delivery
Compliance with the acceptance and delivery requirements of
the manifest system (e.g., acquiring certification of delivery from
an authorized agent of the permitted facility, checking containers
for proper labelling and replacing labels when necessary, and issuing
a delivery document when appropriate) will require additional
attention and time on the part of the driver. For tank trucks the
signing of the manifest can usually be accomplished during vehicle
loading and unloading (for which a total of three hours per trip is
allowed in the cost models). If no one is available to sign the
manifest at the hazardous waste management facility, additional
time at the end of the day might be required for additional paper
work by the driver. If this happens every other day, an incremental
time requirement of 15 minutes for one out of every six trips will
constitute an additional cost of compliance for tank truck trans-
port:
Truck driver's time: 0.25 x $12/hour x No. trips/6 = $0.50/trip.
For flat-bed trucks where drums are not containerized or palletized,
tailgate delivery is probably used. In those cases (Models 4 and 5),
an extra 15 minutes is allowed for loading and unloading time for
signing the manifest:
Truck driver's time: 0.25 x $12/hour = $3/trip.
Model 5 provides 45 minutes per day of slack time, so that the
cost above represents an opportunity cost rather than an extension
of an eight-hour day or reduction in number of trips per day.
VII-12
-------
No measurable incremental cost of compliance with the manifest
system will be incurred by rail transporters, because the EPA
requirements can be accomodated by the current bill of lading/
waybill.
4. Handling
No additional costs are expected for this section of the
regulation.
5. Spills and Reporting
Table VII-3 depicts the number of unintentional releases of
hazardous materials during transportation. The information is
compiled by DOT's Office of Hazardous Materials. The overwhelming
majority of incidents do not pertain to hazardous waste requirements
under Section 3003 because they were associated with virgin (non-
waste) materials and include spills from small packages and minor
splashes from large containers.
Table VII-4 depicts the property damage from hazardous materials
incident reports. The average damage from a spill was about $1600 and
50 percent of the spill reports were for damage under $100.
Detailed reports of an incident are due from carriers within
15 days, with immediate notification required when the release
results in death, injury, estimated property damage over $50,000
or spillage of radioactive material or etiologic agents.
A study for EPA estimated the cost of cleanup for a land
spill (as opposed to water), as shown in Table VII-5. These
costs for a typical hazardous material spill include one or more
of the following steps:
• Containment by plugging sewers, building dikes, etc;
• Removal of spilled material from site using vacuum
pump equipment, earthmoving equipment and/or sorbants;
A
Estimation of the Frequency and Costs Associated with Cleanup of Hazardous
Materials Spills. Preliminary Draft Report to the EPA, April 1978,
Arthur D. Little, Inc.
VII-13
-------
TABLE VII-3
HAZARDOUS MATERIALS INCIDENT REPORTS-
REPORTING CARRIERS AND REPORTS SUBMITTED
The following tables list by mode of transport the number of reporting carriers and
the number of HMI reports submitted by each mode.
Mode
Air Carriers
Hwy Carriers (For-hire)
Hwy Carriers (Private)
Rail Carriers
Water Carriers
TOTAL
3
233
54
28
10
328
Reporting Carriers
Percent
1971 1972 1973 1974 1975 1976* Total* of Total
11
323
58
35
8
435
15
353
73
35
7
483
32
380
82
40
17
551
31
392
116
44
23
606
40
600
200
50
40
50
700
250
75
50
4
62
22
7
4
930 l,125**See Note
Reports Submitted
Mode
Air Carriers
Hwy Carriers (For-Hire)
Hwy Carriers (Private)
Rail Carriers
Water Carriers
TOTAL
1971
1
2
5
,633
258
346
13
,255
1972
32
3,613
352
337
10
4,344
1973
48
5,092
450
412
12
6,014
1974
155
7,254
361
617
26
8.413
1975
152
8,988
903
675
32
10 , 750
1976
9
1
11
150*
,900*
950*
,000*
50*
,898
Total*
36
3
3
44
550
,500
,300
,400
150
,000
Percent
1 1/4
83
7 1/4
7 1/2
1/4
See Note
Estimated
Total number of different reporting carriers during the 6 year period - NOT the ad-
dition of numbers for each year. (For example - Carrier XYZ submitted reports in
EACH year but as the "total" reporting carriers, XYZ is only one reporting carrier -
not six.)
NOTE: About 10 freight forwarders and 14 other reporters (such as stevedoring firms,
Port Authorities, Police, etc.) submitted about 100 HMI reports during this
6 year period.
SOURCE: Materials Transportation Bureau, DOT.
VII-14
-------
TABLE VII-4
TABULATION OF PROPERTY DAMAGE FIGURES EXCERPTED FROM 32,000
HAZARDOUS MATERIALS INCIDENT REPORTS RECEIVED FROM 1971 THROUGH 1975
Property Damage Shown
On HMI Reports
$ Over 500,000
$ 500,000
$ 250,000 to $499,999
$ 100,000 to $249,999
$ 50,000 to $ 99,999
$ 25,000 to $ 49,999
$ 10,000 to $ 24,999
$ 5,000 to.$ 9,999
$ 2,500 to $ 4,999
$ 1,000 to $ 2,499
$ 500 to $ 999
$ 250 to $ 499
$ 100 to $ 249
$ 50 to $ 99
$ 25 to $ 49
$ 10 to $ 24
$ 1 to $ 9
"0" or blank or shown as
"UNKNOWN"
TOTAL REPORTS
1971
Reports
1
3
1
3
18
44
68
38
34
68
64
86
184
176
195
250
164
805
2,200
1972
Reports
2
0
5
7
10
38
*
69
44
38
99
100
131
324
379
398
594
587
1,575
4,400
1973
Reports
1
0
3
5
15
39
94
58
66
110
133
186
492
487
674
833
839
1.946
6,000
1974
Reports
3
0
4
7
8
36
99
60
87
179
180
238
694
791
928
1,414
1,283
2.489
8,500
1975
Reports
0
0
3
10
19
36
75
69
68
154
192
490
916
1,114
1,383
1,887
1,349
3,014
10,800
Total
7
3
16
32
70
193
405
269
293
610
669
1,131
2,610
2,947
3,578
4,978
4,241
9.829
32,000
SOURCE: Materials Transportation Bureau, DOT.
VI1-15
-------
TABLE VII-5
LAND SPILL RESPONSE COSTS FOR
Item
Motorized elevating
scraper w/driver
Back hoe w/driver
Vacuum tank trailer
Operator
Tractor
Dump trucks (2)
Operators (2)
Supervisor
Laborer
4000-GALLON
Rate
($/hr)
100
32
35
11
12
36
22
16
10
SPILL
Time Ons ite
(hr)
4
4
4
4
4
6
6
8
8
Cost
($)
400
128
140
44
48
216
132
128
80.
1,316
Disposal costs: $l/gallon
Total cost: 1.00 +
- $1.33/gallon
= $0.16/pound
Source: Estimation of the Frequency and Costs Associated with Cleanup
of Hazardous Materials Spills, Preliminary Draft Report to the
EPA, April 1978, Arthur D. Little, Inc.
Reference: "When the Cop's Shoes Rotted, Disposal Probe Really Started,"
Boston Sunday Globe, January 29, 1978. Article notes that specialized
waste disposal services charge "as high as $1 or more per gallon of
waste.
VII-16
-------
• Disposal of contaminated material;
• Sampling and analysis of underground water supplies;
• Restoration of surface soils.
Spills on land are rarely cleaned up in such a comprehensive
manner, but this cost was used because it represents the ideal
for spill cleanup. Thus a cost of $1320 was used for cleanup
with no incremental reporting cost, since that is already required.
6. Marking
Marking requirements would represent additional costs to truck
transporters only. The estimated first-year cost for marking the
vehicle as specified in Section 3003 is:
2 hours x $12/hour = $24 in the first year.
Placarding requirements are identical to DOT requirements.
E. SUMMARY OF COMPLIANCE COSTS
The costs of compliance for the process economic model truck trans-
porters of hazardous waste are shown in Table VII-6. Recordkeeping
requirements appear here as a fixed charge per truck, although Model 3
may have slightly lower costs due to fewer trips. Recordkeeping as-
sociated with the manifest requirements vary with the number of trips
and additional driver time required. Thus the cost per truck is lower
for Models 1, 2 and 3, which make two trips per day in their respective
transportation scenarios, than for Models 4 and 5 where driver time is
required to comply.
Registration cost was estimated at $24 for each hazardous waste
transport company during the first year. Marking will also require an expen-
diture of $24 for each truck in the first year (assuming that trucks
• are not currently marked). To be conservative, a cost of $48 per truck
was used for registration and marking combined.
VII-17
-------
TABLE VII-6
SUMMARY OF COMPLIANCE COSTS
WITH RCRA SECTION 3003 FOR
TRUCK TRANSPORT
Truck Model
Model 1
Model 2
Model 3
Model 4
S Model 5
oo
Registration
$24
24
24
24
24
Recordkeeping
$116/year
116/year
116/year
116/year
116/year
Manifest
System
$ 250/year
250/year
125/year
1,452 /year
1,452/year
Marking
$24
24
24
24
24
Total
First Year
$ 414
414
289
1,616
1,616
Recurring
$ 366 -
366
241
1,568
1,568
Spill Cleanup: $1,320
SOURCE: Arthur D. Little, Inc., estimates.
-------
2
EPA estimates that 213 hazardous waste spill incidents occured in
1976. Based on a spill cleanup cost of $1320, this leads to an annual
cost of $281,160 for hazardous waste spill cleanup. Since the spill
frequency (number of incidents/truck) is unknown, the impact of the
cost of spill cleanup has been considered separately from other costs
which can be estimated on a per truck or facility basis.
For rail transport, existing bills of lading will be used to meet
manifest system requirements. However, additional r^cordkeeping might
be required, and therefore the impact was evaluated of an additional
expense of $116 per car per year and $2.00 pet trip.
There are no additional compliance activities imposed upon barge
transport as a result of Section 3003 standards, provided that current
shipping papers or dangerous cargo manifests can be used and no addi-
tional recordkeeping or reporting requirements are necessary beyond
those which currently exist.
VII-19
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VIII. ECONOMIC IMPACT OF RCRA SECTION 3003
A. APPROACH
As noted in Chapter VI, the transportation of hazardous waste is not
an industry but rather a complementary function of other industries. The
approach taken to analyze the impact of Section 3003 was to examine the
transportation portion of the relevant impacted industries. The three
transporter segments analyzed consisted of 1) generators who self-haul
to off-site hazardous waste management facilities; 2) for-hire transporters
of hazardous waste, and 3) hazardous waste management facilities also en-
gaged in transportation. In addition to a breakdown by class of organiza-
tion, two modes—rail and truck—were examined.
Two types of analyses were performed. The transportation function
itself was analyzed to determine a cost of ownership of a single vehicle
over its lifetime, to determine revenue levels for profitable vehicles,
or to determine total costs for particular routes and volumes of hazar-
dous waste. A company analysis was used to examine the operation of
typical companies for which the transport of hazardous waste was a signi-
ficant function of business, i.e., for-hire transportation companies and
hazardous waste management facilities.
The two types of analyses were used as appropriate for each of the
three transporter segments engaged in the transportation of hazardous
waste. For generators who self-haul to hazardous waste management
facilities, the transportation function is usually a very small portion
of company operations. The incremental cost of the transportation func-
tion was determined and the costs were discounted over the lifetime of
the vehicles.
The generator's transportation functions included both trucking and
rail operations. For trucking operations, the costs of operating a
single vehicle both before and after compliance were computed using the
truck scenarios outlined in Chapter VII.
As the railcars engaged in hazardous waste transport are generally owned by
generators, the transport can be considered a function of the generator in the
sense that the generator will be responsible for the generator and some trans-
porter compliance requirements.
VIII-1
-------
The rail mode was treated somewhat differently since the amount of
hazardous waste transported nationally is a great deal lower than by
truck and could be quantified. Spent sulfuric acid is one of the major
hazardous wastes shipped by rail. The total cost for transporting spent
sulfuric acid by rail was projected for the national volume, based on
sample routings. The sample routings, identified in communications with
railroads, represented over half of the national volume shipped. (See
Appendix E.) In addition to the total cost nationally, two routes,
representing a high-cost origin-destination pair and a low-cost origin-
destination pair were analyzed to determine total costs, discounted
over rail car life. For all three cases, the options of generator
leasing and generator purchasing of rail tank cars were considered.
For for-hire transporters, a typical company (assumed to be involved
only in hazardous waste transport) was analyzed. Cash flow statements
and balance sheets were derived based on the financial profiles of Chapter
VI. A company analysis was performed for hazardous waste management
facilities also engaged in transportation, based on the financial profiles
described in Chapter VI.
The measurement of impact depends on the type of transporter. For gen-
erators, the measure of impact was the percent increase in the cost of life-
time transportation of hazardous waste, as well as the increase in lifetime
cash flow associated with hazardous waste transport. For hazardous waste
management facilities that transport, and for-hire transport, the impact of
cost of compliance per vehicle was measured in two ways: the change in pro-
fitability that would occur without a rate increase, and the revenues (price
increase) needed to maintain the historic internal rate-of-return.
B. FINANCIAL MODELS
Financial models were developed for trucking companies and hazardous
waste management facilities engaged in hazardous waste transport. The
pro-forma financial statements shown in Chapter VI were used to provide
a transportation company financial structure which was input into a fin-
ancial model (described in Appendix F ). A base-line company revenue
VIII-2
-------
(and derivative) price was estimated based upon the total cost of operating
the company, including allowance for profit, consistent with the after-tax
rate-of-return on total capital historically earned by trucking companies
(6-7 percent). The price impact of the costs associated with Section 3003
was determined by estimating the revenue (and derivative price) after costs
of compliance were added to the model company. The difference between
revenue before and after compliance is equivalent to the long-run price
increase in hazardous waste transport that will occur as a result of
Section 3003 regulations.
To simulate a trucking company over a ten-year period, it is neces-
sary to specify investment schedules and financing. The investment schedule
was based upon a uniform age distribution for the 14 vehicles, ranging from
&
0 (new) to 10 years. Replacement of equipment occurred after ten years,
while depreciable life was five years for trailers and eight years for tank
units. Financing for vehicles is based upon a four-year chattel loan with
30 percent down payment.
To derive a financial model of hazardous waste management facilities,
the pro-forma financial statements shown in Table VI-3 were used along with
additional information, as follows:
**
1977 Average Revenue: $1.3 million
Average Real Growth: 3 percent per year
Annual Investment: $183,000 per year
This information represents the hazardous waste management portion of the
company. The financial structures of the seven vehicles represent the
transportation portion of the company, assumed to be a scaled-down version
of the for-hire transportation company.
Interviews with hazardous waste management facilities indicate some vehicles
are up to 20 years old. The uniform age distribution useci here does not make
any difference from a rate-of-return viewpoint since all vehicles over 8 years
old are fully depreciated.
JLjr
Derived from the 1975 average revenue, excluding transportation shown in
Reference 1, allowing for two years of growth.
VIII-3
-------
C. DIRECT IMPACT—VEHICLE MODELS
1. Rail Transport
The direct impact of compliance activities is shown in Table VIII-1,
which presents the discounted cost of owning and paying fares for rail
cars over twelve years to transport spent sulfuric acid on a high-volume
route, a low-volume route, and all routes nationally. Leased car and
purchased car alternatives are presented. For rail transport the cost
of compliance represents a very small increase in operating costs, with
a maximum 0.8 percent increase in the twelve-year costs due to compliance.
2. Truck Transport
The costs of compliance with Section 3003 for each truck model
analyzed are shown in Table VIII-2. First-year and recurring-year
costs of compliance are shown for each model and compared to pre-
compliance annual operating costs. Additionally, the cost of a
spill cleanup is compared for each model separately. The increase in
operating cost as a consequence of Section 3003 will be greatest for
transportation of drummed waste and other waste which the truck
operator must manually handle during loading and unloading.
This is due to the allocation of additional truck driver's time to
obtain certification of delivery. The increase is greater for truck
model 5 than for truck model 4, because model 5 has fewer ton-miles
per year. Likewise, the impact on truck model 3 is the least because
it represents a high annual mileage, long-trip distance scenario.
This is the expected result since costs of compliance vary with the
number of trips.
The cost of spill cleanup amounts to only 3.2 - 4.7 percent of
annual operating cost. The spill frequency per truck for hazardous
waste transportation is unknown and thus ah expected annual cost
could not be derived.
V1II-4
-------
TABLE VIII-1
IMPACT OF RCRA SECTION 3003
REGULATIONS ON RAIL CAR OPERATING COSTS
National Total
Before Compliance
After Compliance
$ Change
% Change
PRESENT VALUE OF 12-YEAR OPERATING COST ($000)
Leased Car Purchased Car
$5,545.1
5,589.8
44.7
0.8
$5,703.3
5,751.8
48.5
0.8
Case 1
Before Compliance
After Compliance
$ Change
% Change
84.6
85.0
0.4
0.5
90.0
90.4
0.4
0.4
Case 2
Before Compliance
After Compliance
$ Change
% Change
$ 771.3
776.0
4.7
0.6
$ 819.0
824.7
4.9
0.6
Case 1: Low-cost origin-destination pair with
annual volume of 1,275 tons
Case 2: High-cost origin-destination pair with
annual volume of 9,000 tons
Source: Arthur D. Little, Inc., estimates.
VIII-5
-------
TABLE VIII-2
IMPACT OF RCRA SECTION 3003
M
I
REGULATIONS ON TRUCK OPERATING COSTS -
Truck
Transport
Model
1
2
3
4
5
No. Trips /Day
2
2
1
2
2
C©st of
First
Year-
$ 414
414
289
1,616
1,616
Compliance
Subsequent
Years
$ 390
390
215
1,640
1,640.
Percent of
Operating Costs
Annual
Operating^ Costs3
$32,500
28,375
41,500
34,000
29,625
First
Year
1.3
1.5
0.7
4.9
5.6
Recurring
Years
1.2
1.4
0.6
4.8
5.5
Spill Clean-up
Cost
$1,320
1,320
1,320
1,320
1,320
% Operating
Costs
4.1
4.7
3.2
3.9
4.5
Derived from Chapter VII. Excludes capital costs.
Source: Arthur D. Little, Inc., estimates.
-------
D. DIRECT-IMPACT COMPANY MODELS
The two company financial models, one for a for-hire transporter
and one for a waste management facility also engaged in transportation,
were analyzed to determine the impact of the cost of compliance with
Section 3003.
1. For-Hire Transportation Company
To establish a baseline for gauging impact, pre-compliance
revenue consistent with historic for-hire truck company rates-of-
return were generated. The revenue required to recover the cost of
compliance with Section 3003 was also generated. Table VIII-3
presents the baseline (pre-compliance) revenue and the revenue re-
quired to recover the costs of compliance. The pre-compliance price
per ton-mile implicit in the model is $0.122 for the 14-truck com-
posite.
The effect of compliance is measured in two ways:
(1) Decrease in return on capital (profitability) in the
absence of a price increase; and
(2) Increase in revenues (prices) necessary to
recover the cost of compliance, and earn the
historic rate-of-return.
In the absence of a price increase, for-hire transporter profitability
would decline by 9 percent. However, an increase in revenue of 2.6 per-
cent overall is needed to maintain the same rate-of-return. The impact
of compliance upon the for-hire transportation company, assuming a
balanced mixture of vehicle types, is between that for the high-impact
and low-impact models.
There could be a differential impact upon rates that generators
pay if the differential cost impact per truck type or trip is
reflected in a relatively higher rate increase for short-haul, low-
volume drummed waste transport. This again implies that small waste
generators will face a relatively greater increase than larger waste
generators, although the increase for both is not great.
VIII-7
-------
TABLE VIII-3
REQUIRED INCREASE IN REVENUE
TO RECOVER COSTS OF COMPLIANCE WITH RCRA SECTION 3003
H
M
M
do
For-hire Transportation
Company
Hazardous Waste
Management Facility
Number of
Vehicles
14
Baseline
Revenue % ROC
Required Increase
in Revenue
Impact on Profit
With No Price Increase
% Change % ROCa% Change~
$ 670,292 6.7 $17,642 2.6
1,635,190 15.4 8,800 0.5
5.7
15.0
-9
-3
ROC: Return-on-capital.
SOURCE: Arthur D. Little, Inc., estimates.
-------
2. Hazardous Waste Management Company
In addition to the direct costs of owning and operating trucks,
hazardous waste management facilities have other expenses and pricing
policies which can result in a different impact on rates than that in-
cated by examining trucks above. An increase in truck expenses can
be offset by increases in revenues from trucking and/or disposal
operations.
The hypothetical hazardous waste management company described in
Chapter VI derives 22 percent of its revenues from transportation
operations. A change in transportation expenses due to compliance
activities will require a smaller increase in total revenues to
recover costs than for the for-hire transportation company. The
impact of the cost of compliance with Section 3003 can be measured
in two ways:
w
(1) Decrease in return on capital (profitability) in the
absence of a price increase; and
(2) Increase in revenues (prices) necessary to recover the
cost of compliance, and earn the historic rate-of-return.
Table VIII-3 also shows the impact on hazardous waste manage-
ment facilities. The increase in revenues necessary to maintain the
historic rate-of-return for the company is 0.5 percent, while the
decline in profitability is 3 percent. The impact on the hazardous
waste management facility is a smaller decrease in profit than for
the transportation company because transportation represents only
22 percent of this total.
3. Generators
The total cost of hazardous waste transport for the generator
industries identified in Table VI-1 was estimated at between $27.9
million and $230.1 million per year. If the 2.6 percent price in-
crease indicated in Table VIII-3 materializes, the total increase in
rates will be between $730,000 and $6,000,000 as a result of Section
VIII-9
-------
3003 hazardous waste transport regulations. The cost of hazardous
waste transport will still be a very small portion of the total cost
of manufacture or value added and not sufficient to cause a shift
between off-site and on-site disposal.
VIII-10
-------
APPENDIX A
STANDARDS APPLICABLE TO TRANSPORTERS
OF HAZARDOUS WASTES
A-l
-------
FRIDAY, APRIL 28, 1978
PART (V
ENVIRONMENTAL
PROTECTION
AGENCY
Standards Applicable to
Transporters of
Hazardous Wastes
A-2
-------
18506
(6560-01]
ENVIRONMENTAL PROTECTION
AGENCY
CFRL 875-31
[40 CFR Port 2M1
ITANDAROt APPUCAIll TO TIANSKMTttS
OP HAZAMOUI WMTI AND HJMK MIA*.
'• KM
AGENCY: Environmental Protection
Agency.
ACTION: Proposed rule.
SUMMARY: The Environmental Pro-
tection Agency (EPA) issues proposed
standards under section 3003 ol the
Solid Waste Disposal Act (the Act)
prescribing procedures for recordkeep-
tng, acceptance of hazardous waste for
transport, compliance with the mani-
fest system, delivery of the hazardous
waste to a designated facility, spills.
and placarding/marking of vehicles. In
addition. EPA proposes that all haz-
ardous wastes which meet the Depart-
ment of ' Transportation's (DOT'S)
definition of a hazardous material be
subject to the Federal DOT Hazardous
Material Regulations for both inter-
state and intrastate shipments. DOT is
in the process of developing regula-
tions which will include coverage of
hazardous wastes. If DOT develops
standards similar to those proposed by
EPA, the EPA hazardous waste trans-
portation standards,will be modified to
reflect the DOT Hazardous Materials
Regulations or will reference the DOT
Hazardous Materials Regulations.
These proposed standards are applica-
ble to transporters of hazardous waste,
and they are being Issued to protect
human health and the environment.
EPA will be issuing additional pro-
posed regulations for hazardous waste
at a later date. For details concerning
dates and hearings on these future
proposed regulations see supplemen-
tary information.
DATES: Comments requested on or
before June 27, 1978. Hearing: First
Joint hearing with DOT is scheduled
for June 20,1978.
For details concerning for comment
due date and hearings on this pro-
posed regulation, see supplementary
information.
ADDRESSES: Comments to: Deputy
Assistant Administrator for Solid
Waste (WH-562), U.S. Environmental
Protection Agency. Washington, D.C.
20460. Communications should identi-
fy the regulatory docket or notice
number, which is Section 3003 for
these proposed standards.
• Official record for this rulemaking
available at: Room 2111D, U.S. Envl-
.tonmental Protection Agency, 401 M
Street SW., Washington, D.C. 20460,
and is available for viewing from 9
"un. to 4 p.m., Monday through
Friday, excluding holidays.
PROPOSED RULES
Hearing: First joint hearing with
DOT is scheduled for June 20, 1978, at
the Holiday Inn, Old Town, 480 King
Street, Alexandria, Va., 703-549-6080.
FOR FURTHER INFORMATION
CONTACT:
Mr.
SUPPLEMENTARY INFORMATION:
Dates— EPA will propose all hazardous
waste regulations under Subtitle C
during the spring and summer of 1978.
Since certain Sections will be ready for
proposal ahead of others, EPA will
propose each Section as It becomes
available. Comments concerning Sec-
tion 3003 standards would be appreci-
ated by June 27> 1978.' However, the
comment period for all Sections (3001-
3005), will remain open until at least
60 days after the last Section is pro-
posed in the FEDERAL REGISTER. This
will enable those who* would prefer to
comment on all five Sections at the
same time to do so. A notice announc-
ing the closing date for all Sections
will be published in the FEDERAL REG-
ISTER upon publication of the last Sec-
tion.
HEARING: Public hearings on all
Subtitle C proposed regulations (3001-
3005) will be held during the summer
of 1978. The dates of the public hear-
ings will be announced in the FEDERAL
REGISTER. EPA and DOT plan to hold
joint public hearings on these regula-
tions. The first joint hearing with
DOT is scheduled for June 20, at the
Holiday Inn, Old Town, 480 King
Street, Alexandria, Va.. 703-549-6080.
Additional EPA/DOT hearing dates
will be announced in the FEDERAL REG-
ISTER to coincide with the public hear-
ings that will be held on Sections 3001
and 3002.
Oral or written comments may be
submitted at the public hearing on
these proposed standards. Registra-
tion for the hearing will be held be-
tween 8:30 and 9 a.m. Requests to par-
ticipate in the public hearing should
be directed to: Ms. Oerrl Wyer, Public
Participation Officer. Office of Solid
Waste (WH-562), U.S. Environmental
Protection Agency, Washington, D.C.
20460. 202-755-9157.
FOR FURTHER INFORMATION
CONTACT:
Mr. Arnie Edelman, Hazardous
Waste Management Division, Office
of Solid Waste (WH-565), U.S. Envi-
ronmental Protection Agency, Wash-
ington, D.C. 20460, 202-755-9187.
Subtitle C of the Solid Waste Dis-
posal Act, as amended by the Resource
. Conservation and Recovery Act of
1976 (Pub. L. 94-580) (hereinafter
RCRA), creates a regulatory frame-
work to control hazardous waste. Con-
gress has found that such waste pre-
sents "special dangers to health and
requires a greater degree of regulation
than does non-hazardous solid waste"
(Section 1002(bX5)). Because of the se-
riousness of this waste problem. Con-
gress intended that the States develop
programs to control it. In the event
that States do net choose to operate
WWiifefffftffl, IPA !S required to do so.
This rule is one of ft sefi&j ef seven
being developed and propaspd Uflde*
Subtitle C to implement the hazard-
ous waste management program. It is
important to note the broad definition
of solid waste (Section 1604(27)) which
encompasses (with a few exceptions)
garbage, refuse, sludges, and other dis-'
carded materials including liquids,
semi-solids, and contained gases from
both municipal and Industrial sources.
Hazardous wastes, which are a subset
of all solid wastes, are those which
have particularly significant impacts
on public health and the environment.
Subtitle C, then, creates a manage-
ment control system which, for those
wastes defined as hazardous, requires
"cradle-to-grave" cognizance including
appropriate monitoring, recordkeep-
ing, and reporting throughout the
system. Section 3001 defines the crite-,
ria and characteristics for identifying
and listing hazardous wastes. Those
wastes which are identified as hazard-
ous by these means are included in the
management control system contract-
ed under Sections 3002-3006 and 3010.
Those that are excluded will In any
case be subject to the requirements
being carried out by States under Sub-
title D, under which open dumping is
prohibited and environmentally ac-
ceptable practices are required.
Section 3002 addresses the standards
applicable to generators. The Agency
does hot interpret the Intent of Con-
gress to include in this category indi-
vidual homeowners. Section 3002 re-
quires the creation of a manifest
system which will track wastes from
the point of generation to their ulti-
mate disposition.
Section 3003 addresses standards af-
fecting transporters of hazardous
wastes to assure that wastes are care-
fully managed during the transport
phase. The Agency is exploring oppor-
tunities for meshing closely with pro-
posed and current DOT regulations to
avoid duplication in this area.
Section 3004 addresses standars af-
fecting owners and operators of haz-
ardous waste storage, treatment, and
disposal facilities. These standards
define the levels of environmental pro-
tection to be achieved by these facili-
ties and provide the criteria against
which EPA (or State) officials will
measure applications for permits. Fa-
cilities on the generator's property, as
well as off-site facilities, are covered
by these regulations and will require
permits. Generators and transporters
who do not treat, store, or dispose of
hazardous wastes do not need permits.
Section 3005 describes the scope and
coverage of the actual permit-granting
FEDERAL REGISTER, VOL 43, NO. 83-FRIDAY, APRIL 28, 1978
A-3
-------
PROPOSED RULES
18507
process for facility owners and opera-
tors. Requirements for the permit ap-
plication, as well as for the issuance
and revocation process, are defined by
these regulations. Section 3005(c) pro-
vides for interim .. permitted status
during the time period in which the
Agency or State is reviewing the pend«
ing permit applieatlans,
Section 3008 requires EPA to issue
guidelines for State programs and pro-
cedures by which States may seek
both full and interim authorization to
carry out the hazardous waste pro-
gram in lieu of an EPA-adminlstered
program.
Section 3010 defines procedures by
which any person generating, trans-
porting, owning or operating a facility
for storage, treatment, and disposal of
hazardous waste must notify EPA of
this activity within 90 days of promul-
gation of regulations defining any haz-
ardous waste (section 3001). Certain
States will be authorized to perform
this function upon application to the
Administrator. It is significant to note
that no hazardous waste subject to
Subtitle C regulations may be legally
transported, treated, stored, or dis-
posed, nor may interim permits be
issued, unless this timely notification
is given to EPA or a designated State.
After this 90-day notification period,
transporters will need to comply with
250.32, which requires transporters to
obtain an identification code from
EPA or an authorized State. '
Sections 3001, 3002, 3004. and 3005
standards are expected to be proposed
during the summer of 1978. The
Agency intends to promulgate final
regulations by the fall of 1978 for all
of these sections of Subtitle C. Howev-
er, it is Important for the regulated
communities to understand that the
regulations (sections 3002-5) do not
take effect until six months after pro-
mulgation. Thus, there will be a time
period after final promulgation during
which public understanding of the reg-
ulations can be increased and those
covered by the regulations can prepare
to comply. During this same period,
notifications required under section
3010 and permit applications required
under section 3005 can be distributed
for completion by applicants.
Table I appearing below cross refer-
ences the numbered sections of RCRA
to the Subpart designations to be used
in the regulations:
TABLE I
Solid Waste Disposal Act.
Subtitle C—Numbering System.
Subpart A—Section 3001 Standards lor Cri-
teria, Identification, and Listing of Ha»-
ardous Waste.
Subpart B—Section 3002 Standards Applica-
ble to Generators.
Subpart C—Section 3003 Standards Applica-
ble to Transporters.
Subpart D—Section 3004 Standards for
Owners and Operators of Treatment
Storage, and Disposal Facilities.
Subpart E—Section 3005 Permits for Treat-
ment, Storage, or Disposal.
Subpart F—Section 3006 Guidelines for Au-
thorized State Programs.
Subpart G—Section 3010 Preliminary Noti-
fication of Hazardous Waste Activities.
BACKGROUND *
In developing these stancteird* for
transporters of hazardous waste, the
Environmental Protection Agency has
solicited comments, data, opinions,
and suggestions from the regulated
community (i.e., hazardous waste gen-
erators, transporters, operators of
treatment and disposal facilities),
States, and the public on the major
Issues confronting EPA as part of the
regulation development process. This
effort has included the publication of
an Advance Notice of Proposed Rule-
making (ANPR) 42 FR 22332 (May 2,
1977), a series of 13 public meetings
with a total attendance of over 1,000
people, and the review of the draft
regulations by representatives from
the public, public interest groups.
State and local governments, trans-
porters, generators, and disposers of
waste. All comments were reviewed
and cpnsidered by EPA before propos-
ing these standards for hazardous
waste transportation.
Compliance with these hazardous
waste transportation regulations
(which include by reference most of
CFR 46 and CFR 49) by no means
exempts the transporter from compli-
ance with the requirements of other
Federal, State, or local regulations.
Section 3003(a) of the Act directs
the Administrator to promulgate regu-
lations establishing standards applica-
ble to transporters of hazardous
wastes "as may be necessary to protect
human health and the environment."
Such standards shall include but need
not be limited to recordkeeping. trans-
portation of properly labeled wastes.
compliance with the manifest system,
and delivery of the hazardous waste
only to a permitted facility. Section
3003(b) states that in case any hazard-
ous waste identified or listed by EPA
is subject to the Hazardous Materials
Transportation Act' (88 Stat. 2156; 49
U.S.C. 1801 and following), the Subti-
tle C regulations promulgated by the
Administrator shall be consistent with
the Department of Transportation's
(DOT'S) Hazardous Materials Regula-
tions. The Administrator is authorized
to make recommendations to the Sec-
retary of Transportation concerning
the regulations of hazardous waste.
The criteria for identifying and list-
ing hazardous waste, as developed
under section 3001 of the Act. will take
into account toxicity, persistence, de-
gradability in nature, potential for ac-
cumulation In tissue, flammability,
corrosiveness, and other hazardous
characteristics.
Hazardous wastes defined or listed
under Section 3001 may Include haz-
ardous materials as defined by DOT or
"hazardous substances" as defined by
EPA under the Federal Water Pollu-
tion Control Act. DOT has designated
material as hazardous upon finding
that the transportation of a material
in commerce may pose an unreason-
able risk to health and safety or prop-
erty (49 CFK 171.8). The criteria and
testing methods to evaluate whether
or not a material la hazardous are
found in 49 CFR 173. The following
have been designated as classes of haz-
ardous materials by the Secretary of
Transportation: Explosives, Combusti-
ble Liquids, Corrosive Materials, Flam-
mable Liquids, Flammable Gases, Non-
flammable Gases, Flammable Solids,
Organic Peroxides, Oxidizers, Poisons,
Irritating Materials, Etiologic Agents,
and Radioactive Materials.
Regulations defining hazardous sub-
stances under Section 311 of the Fed-
eral Water Pollution Control Act are
found under 40 CFR 116. The Admin-
istrator is required to designate haz-
ardous substances that present an im-
minent and substantial danger to the
public health or welfare when dis-'
charged in any quantity into or upon,
the waters of the United States.
EPA AND DOT COORDINATION
The standards set forth under sec-.
tion 3003 are consistent with stan-
dards developed under the Hazardous
Materials Transportation Act (49 CFR
100-189).
After lengthy discussions between
EPA and DOT, DOT has expressed a
strong Interest in broadening its Haz-
ardous Materials Regulations to In-
clude most or all of EPA's proposed
hazardous waste regulations. Depend-
ing on DOT'S actions, EPA may even-
tually jointly promulgate with DOT,
modify these proposed regulations, or
adopt forthcoming DOT regulations..
EPA and DOT intend to jointly en-
force any DOT regulations governing-'
transportation of hazardous waste.
COMPLIANCE WITH U.S. DOT
HAZARDOUS MATERIALS REGULATIONS
According to a recent interpretation
by the Office of Hazardous Materials
Operations (DOT), any material, in-
cluding waste, which meets the DOT
criteria of a hazardous material must
be handled according to DOT regula-
tions.
The Office of Hazardous Materials
newsletter of April/May 1977 states:
There have been numerous inquiries to
the Office of Hazardous Materials Oper-
ations regarding the applicability of the De-
partment's Hazardous Materials Regula-
tions to the Transportation of waste materi-
als. These regulations are structured to
apply to any materials that may pose an
undue hazard in transportation and, as
such, do not differentiate between waste
and other than waste materials. If. after
processing, a material meets the definition
FEDERAL REGISTER, VOL. 43, NO. 83— FRIDAY, APRIL 28. 1978
A-4
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18508
PROPOSED RULES
of a hazardous material, then that material
must be classed and shipped in accordance
with the requirements prescribed for the
hazard associated with the material. Many
materials, including those considered waste
materials, may have more than one hazard
and certain other materials may lose their
hazardous characteristics due to processing.
A mixture of materials, both waste and
other than waste, must be properly evaluat-
ed to determine its characteristics, since,
after processing, a mixture may become
more or less hazardous than It was prior to
processing.
The Department's Hazardous Materials
Regulations may apply to any material re-
gardless of its end use; the fact that materi-
al is considered a waste material does not re-
lieve application of these (DOT) regula-
tions.
DOT'S current Hazardous Materials
Transportation Regulations only
apply to transporters engaged In inter-
state or foreign commerce and the
shippers who use them. However,
some intrastate shipments are regulat-
ed by States that have adopted the
Federal regulations or have similar
regulations. In the above cases, the
shipper usually is responsible for
proper description of the hazardous
material, proper labeling, packaging,
and placarding.
DOT regulations applicable to trans-
porters are found in the Code of Fed-
eral Regulations Title 49, parts 171
(General Information, Regulations,
and Definitions); 174 (Carriage by
Rail): 175 (Carriage by Aircraft); 176
(Carriage by Vessel); 177 (Carriage by
Public Highway). Bulk shipments of
hazardous materials by vessel are gov-
erned by the following DOT regula-
tions: 46 CFR 30-40 (Tank Vessels); 64
(Marine Portable Tanks); 98 (Bulk
Cargos); 148 (Solids in Bulk); and 151
(Unmanned Barges). Each of these
standards contains regulations for •ac-
ceptance of materials for transporta-
tion, loading, unloading, handling,
storage of hazardous materials, leak-
ing containers, accident/spill reporting
requirements, containerization, and
detailed requirements for specific
classes of hazardous materials.
EPA's proposed regulations require
that when a material is both a hazard-
ous waste as defined by EPA and a
hazardous material as defined by
DOT, the provisions of the U.S. DOT
Hazardous Materials Regulations must
be complied with for intrastate as well
as interstate transportation.
For those hazardous wastes not cur-
rently subject to the DOT Hazardous
Materials Regulations (primarily toxic
materials), EPA recognizes DOT'S pri-
mary mandate for the development of
standards concerning the safety as-
pects of loading, unloading, and han-
dling of materials in transportation.
Since EPA anticipates that DOT will
redefine hazardous materials to in-
clude all hazardous wastes, EPA has
determined that DOT should develop
such safety standards.
To the extent that problems are
identified by EPA and DOT regarding
additional measures needed for safety
in transportation for these newly cov-
ered wastes, the two Agencies will de-
velop appropriate revisions to the cur-
rently anticipated rulemakirigs. Com-
ments are requested concerning the
additional safety measures that may
be needed for the safe transportation
of these hazardous wastes.
SCOPE OP REGULATIONS
EPA's transportation standards do
not apply to every shipment of haz-
ardous waste. They only apply when a
manifest is required under regulations
to be proposed under Section 3002 of
the Act. The manifest is the form used
for identifying the quantity, composi-
tion, and the origin, routing, and desti-
nation of the hazardous waste. A
manifest will not be required under
Section 3002 for transport on the same
premises where the waste is generated,
treated, stored, or disposed. In such
cases, the waste must be properly la-
beled, contained, treated, stored, or
disposed.
Even though a manifest is not re-
quired for certain shipments of haz-
ardous waste, transporters who con-
solidate shipments of hazardous
wastes are required under Section
250.30 to deliver the shipment • to a
permitted facility. In addition such
transporters must comply with the ap-
plicable DOT Hazardous Materials
Regulations concerning shipping
papers, labeling, marking, placarding
and transportation (49 CFR 100-189).
IDENTIFICATION CODE
Section 250.32 of these regulations
will require that every transporter of
hazardous waste must furnish infor-
mation to EPA or an authorized State
concerning its hazardous waste trans-
portation activity. Upon submission of
this information, the transporter will
be issued an identification code. The
identification code will in most cases
be identical to existing.codes assigned
to transporters by Federal or State
agencies. Generators and shippers of
hazardous waste will not be permitted
to use transporters who do not have
such code. The identification code
should not be construed as either a
seal of approval by EPA or the issu-
ance of a license or permit.
RECORDKEEPINO
Section 3003 of the Act requires that
records be kept concerning hazardous
waste transported and its origin and
destination. In current transport prac-
tice, records are often kept (as re-
quired by the State public utility com-
missions or public service commissions
and the Interstate Commerce Commis-
sion) in the forms of bills of lading,
waybills, or invoices. These documents
include the following Information: the
shipper's name and address; the trans-
porter's name and address; the con-
signee; the quantity of the material;
and a description of the material.
To avoid duplication,. EPA has tai-
lored its recordkeeping requirements
to the existing shipping papers. The
Agency requires that a record be kept
indicating the origin and destination
of each shipment of the waste, the
date of pick-up, quantity of waste
transported, a description of the waste
and a certification that the waste has
been transferred to another transport-
er or delivered to a permitted facility.
In most cases, the record will be a
copy of the manifest or "delivery doc-
ument" with the above information.
(EPA uses the term delivery document
to refer to all forms of shipping papers
which contain the above information.)
The transporter is required to retain a
copy of this record for a three-year
period.
ACCEPTANCE OF HAZARDOUS WASTE FOR
TRANSPORT
Under the Hazardous Materials Reg-
ulations, a transporter cannot accept a
hazardous material for transport
unless it is properly described, labeled,
packaged, and placarded. EPA has de-
veloped similar shipping and accep-
tance regulations for hazardous
wastes. Under regulations to be pro-
posed under section 3002 of the Act,
the generator is required to certify
that the hazardous waste is properly
prepared for transportation.
As a service to the generator, the
transporter may prepare a manifest
(the generator must sign the certifica-
tion), label, and package the hazard-
ous waste. However, since the gener-
ator is responsible for these functions
under Section 3002 of the Act, the
generator may arrange with the trans-
porter to privately indemnify the gen-
erator against financial loss due to im-
proper performance.
LOADING AND STOWAGE FOR •
TRANSPORTATION
For substances which are both haz-
ardous materials under DOT regula-
tions and hazardous wastes under EPA
regulations, EPA in Section 250.30 has
adopted DOT regulations regarding
loading and stowage. These regula-
tions will apply to intrastate as well as
to interstate transportation.
Mixing of wastes which results in
the generation of gases, explosion, or
fire is prohibited by DOT regulations
(which are adopted by reference in
Section 250.34). If other hazardous
wastes from different generators or
separate wastes from the same gener-
ator are mixed, and the manifest no
longer identifies the composition of
the waste shipment, the transporter
will be considered a generator, and
therefore required to comply with the
FEDERAL REGISTER, VOL 43, NO. 83-FRIDAY, APRIL 28, 1978
A-5
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PROPOSED RULES
18509
standards for generators as contained
in Subpart B.
COMPLIANCE WITH THE MANIFEST
The manifest system developed
under Section 300* of the Act is in-
tended to track the movement of the
hazardous waste from the generator to
the ultimate disposal site. A manifest
need not accompany the shipment of
hazardous waste if information con-
tained on the manifest accompanies it
in another form, e.g., a bill of lading or
hazardous material shipping paper.
Signatures on the manifest or delivery
document will certify the transfer of
the hazardous waste from the gener-
ator to the transporter(s), and finally.
acceptance by the hazardous waste
management facility.
If the transporter of the waste
transfers it to another transporter
using a different mode of transporta-
tion or, with respect to air and high-
way, between different transporters
using the same mode, the manifest or
the delivery document will require the
signature of each transporter.
Upon delivery, one copy of the
signed manifest or delivery document
is retained by the transporter; another
copy is forwarded by the hazardous
waste management facility to the gen-
erator.
DELIVERY OF HAZARDOUS WASTES
The transporter must deliver all haz-
ardous waste to a permitted hazardous
waste management facility designated
. by the generator. If the transporter
removes the hazardous waste from the
transport vehicle and stores, consoli-
dates or mixes it with another waste,
the transporter will be required to
comply_ with standards developed
under Sections 3002 and 3004 and re-
ceive a permit for the facility from
EPA or ah authorized State.
Prior to acceptance of the hazardous
waste, the transporter should contact
the facility designated by the gener-
ator to determine its operating hours.
Deliveries of hazardous waste to facili-
ties after operating hours should be
avoided.
If, for any reason the waste manage-
ment facility cannot accept the haz-
ardous waste, the transporter should
ask the generator whether the hazard-
ous waste shipment should be re-
turned or delivered to an alternative
facility. (Under Section 3002 of the
Act, EPA intends to allow the gener-
ator of the hazardous waste to specify
in advance alternative facilities on the
manifest.) The transporter should pro-
vide' advance notice to the alternate
facility prior to taking the waste ship-
ment there.
SPILLS
These regulations provide for the ex-
peditious handling of a spill of a haz-
ardous waste or a hazardous material
(which,, when spilled, becomes a
waste). When a spill requires immedi-
ate removal (as determined by EPA.
other Federal Agencies, or a State or
local authorized official), due to a
threat of imminent hazard to human
health or the environment, EPA's
standards concerning identification
codes for transporters, recordkeeping,
acceptance of the hazardious wastes,
compliance with the manifest, delivery
to the designated facility, and placard-
ing and marking of vehicles will be
suspended until the spill is cleaned up,
rendered non-hazardous, or deter-
mined to no longer present an immi-
nent hazard to human health or the
environment (as determined by EPA,
other Federal Agencies, or a State or
local authorized official). When a spill
occurs, these proposed standards re-
quire the transporter to: (a) telephone
the National Response Center (NEC);
(b) file a written report on the spill to
the DOT using the DOT Hazardous
Materials Incident Report; and (c)
clean up the spill, or take such action
as may be required by Federal, State,
or local agencies so that the waste no
longer presents a hazard to human
health or the environment.
EPA is proposing the use of the ex-
isting 24-hour emergency NRC phone
number for telephone calls relating to
hazardous waste spills. Once the NRC
is notified, the appropriate Federal
and State agencies will be contacted.
(Transporters may also be subject to
State telephone notification require-
ments in the event of a spill.) Every
spillage of a hazardous waste during
transportation regardless of quantity
will require a telephone contact to the
NRC.
EPA has adopted 49 CFR 171.16 to
govern the written reporting of haz-
ardous waste spills. Title 49 CFR
171.16 requires a transporter of haz-
ardous materials to report in writing
within IS days to the U.S. Department
of Transportation each incident (in-
cluding spills) that occurs during the
course of loading, transport, or un-
loading.
Spill reports are Important to allow
EPA to evaluate current regulations
concerning the handling and packag-
ing of hazardous wastes and monitor-
ing of environmental damage. In fill-
ing out the DOT Hazardous Materials
Incident Report, the transporter
should Indicate if the spilled hazard-
ous waste entered a water body, public
drinking water supply or ground-
waters, destroyed vegetation or wild-
life, or produced any other harmful ef-
fects on the environment. The trans-
porter should also estimate the total
quantity of the material removed from
the spill site and describe Its final dis-
position. If it.was delivered to a per-
mitted hazardous waste management
facility, the permit number should be
included. If any residual remains, the
quantity should be estimated and the
transporter should describe any ac-
tions taken to reduce the hazardous-
ness of the waste, including actions re-
quired by Federal, State, or local agen-
cies.
MARKING OF VEHICLES
The ICC and DOT currently require
motor vehicles involved in the inter-
state transport of hazardous materials
to be marked withthe name and home
office of the transporter. EPA has
adopted this requirement for all haz-
ardous waste transporters whose vehi-
cles require DOT placarding or carry
more than 1,000 pounds of hazardous
waste. If there is an emergency and
the manifest or delivery document is
not available, such marking enables
the public or emergency response per-
sonnel to contact the transporter's
home office to determine the contents
of the shipment.
PLACARDING OF VEHICLES.
For hazardous wastes which meet
DOT'S definition of a hazardous mate-
rial, EPA has adopted existing DOT
placarding requirements. Vehicles con-
taining certain hazardous wastes
which are toxic, bioaccumulative. car-
cinogenic, or may cause genetic
change are not now required to be pla-
carded by DOT. EPA is considering
recommending to DOT the develop-
ment of a new placard for such sub-
stances. Comments on the need for.
such a placard are requested.
PERMITTING TRANSPORTERS
Several States, public interest
groups, waste management representa-
tives, and transporters recommended
that a permitting system for trans-
porters of hazardous wastes be devel-
oped by EPA. Such a permitting
system would serve two purposes: to
identify and collect data on hazardous
waste transporters, and to enable the
permitting agency to revoke the
permit in the event of misconduct.
After reviewing the legislative histo-
ry of the Solid Waste Disposal Act.
EPA has found no Congressional
intent to authorize it to require a
permit system for transporters. Al-
though section 3003 generally calls for
promulgating "regulations establish-
ing such standards applicable to trans-
porters of hazardous waste identified
or listed under this subtitle, as may be
necessary to protect human health
and the environment," Section 3005,
which sets out the permit require-
ments, is directed only toward owners
and operators of facilities for the
treatment, storage, or disposal of haz-
ardous waste, and not toward trans-
porters. Moreover, the States and the
Interstate Commerce Commission cur-
rently regulate (often by permit)
FEDERAL REGISTER, VOL. 43, NO. 83—FRIDAY, APRIL U, 1978
A.-6
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18510
PROPOSED RULES
many transporters of hazardous
wastes directly. Therefore, at this
time, EPA will not develop an EPA
transporter permitting program.
REFERENCES TO SECTION 3002
STANDARDS
In the following proposed standards.
references are made to the standards
. being developed for a manifest system
and for labeling practices under sec-
tion 3002.
Section 250.22 describes standards
for the manifest system. The manifest
is designed to provide information on
the movement of hazardous waste
' from the point of generation to the
designated permitted hazardous waste
management facility. To be consistent
with DOT requirements for hazardous
materials, EPA requirements are simi-
lar to the DOT shipping paper re-
quirements. The manifest is envi-
sioned as a shipping document that
does not leave commercial channels
and takes the basic form of the stan-
dard Bill of Lading.
Section 250.26 describes standards
for labeling containers of hazardous
wastes. Any hazardous waste which is
also a DOT hazardous material must
be labeled and marked in accordance
with the DOT regulations. In addition
to the DOT requirements, EPA is con-
sidering a marking that will identify
the generator and (for individual pack-
ages) the manifest number for the
shipment of hazardous waste.
A reporting impact analysis is being
performed for the substantive environ-
mental regulations to be published
under RCRA Subtitle C. Hazardous
Waste Management 'in conjunction
with a data processing system feasibil-
ity study. These proposed standards
will require the transporter, in the
event of a spill of hazardous waste, to
telephone the NRC and submit a writ-
ten report to DOT. The written report
uses the existing DOT Hazardous Ma-
terials Incident Report with supple-
mental information required. It is an-
ticipated that cost for compliance is
minimal. The cost of the report prep-
aration (clerical and management) and
phone notification is estimated to be
no more than $100 per year per vehi-
cle involved In a spill of hazardous
waste.
ECONOMIC AND ENVIRONMENTAL IMPACTS
In accordance with Executive Order
12044 and 11821 as amended by Execu-
tive Order 11949, and OMB Circular
A-107 and EPA policy as stipulated in
39 PR 37419. October 21, 1974 respec-
tively, analyses of the economic and
environmental impacts are being per-
formed for the entirety of Subtitle C.
Hazardous Waste Management, and
are not completed as yet. However, a
separate report on the cost of compli-
ance with section 3003 proposed stan-
dards has been prepared. It is antici-
pated that the cost of compliance is
minimal due to the extent of existing
ICC, DOT, and State regulations; and
the nature of the transport activity,
which includes significant loading and
unloading times, during which mani-
fest compliance activities can usually
be accomplished.
The Draft EIS will be released for
public comment 30 days after the last
Subtitle C regulation is proposed.
Copies of the EIS and the economic
analysis will be available for review
through the Office of Solid Waste.
Dated: April 21. 1978.
BARBARA BLUM,
Acting Administrator.
Title 40, Code of Federal Regula-
tions, Part 250 would be amended, by
adding a Subpart C consisting of
§5 250.30-250.38 as follows:
PART 250— HAZARDOUS WASTE CUIDI LINES
AND REGULATIONS
Subporti A-t— (RmrvMll
I w UH WHM Wflntot
Sec.
250.30 Scope.
250.31 Definitions.
250.32 Identification code.
250.33 Rccordkeeping.
250.34 Acceptance and transport of hazard-
ous waste.
• 250.35 Compliance with the manifest.
250.36 Delivery of hazardous wastes to a
designated permitted facility.
250.37 Spills.
250.38 Placarding/marking of vehicles.
Subpart G—(Rtltrvid!
AUTHORITY: Sees. 2002(a> and 3003. Pub. L.
94-580. 90 Stat. 2804. 2807 (42 U.S.C. 8912.
6923).
$250.30 Scope.
(a) These regulations establish stan-
dards which apply to any person or
Federal agency that transports haz-
ardous waste within the United States
which requires a manifest as specif led
under subpart B of this part or any
transporter importing a shipment of
hazardous waste from abroad. If a
manifest is not required, any person or
Federal agency that consolidates for
shipment and transports hazardous
waste shall deliver the entire quantity
of hazardous waste(s) to a facility per-
mitted under subpart E of this part
and shall comply with the DOT regu-
lations listed in 250.30(c).
(b) These regulations do not apply
to persons Or* Federal agencies that
transport hazardous waste(s) on the
site of a hazardous waste generator or
permitted hazardous waste manage-
ment facility.
(c) If hazardous waste identified or
listed under subpart A of this part also
meets the definition and criteria for
hazardous materials of the Depart-
ment of Transportation (49 CFR 171.8
and 173), the following regulations of
the Department of Transportation will
apply for both intrastate and inter-
state transportation: 49 CFR 171, Gen-
eral Information. Regulations, and
Definitions: 49 CFR 174, Carriage by
Rail; 49 CFR 175, Carriage by Aircraft;
49 CFR 176, Carriage by Vessel; 49
CFR 177. Carriage by Public Highway;
46 CFR 30-40, Tank Vessels; 46 CFR
64, Marine Portable Tanks; 46 CFR 98,
Bulk Cargos; 46 CFR 148, Solids in
Bulk; and 46 CFR 151. Unmanned
Barges.
§250.31 Definitions.
For purposes of this part, all terms
not herein defined shall take the
meaning given them by the Solid
Waste Disposal Act (Pub. L. 94-580).
(a) "Delivery document" means a
shipping paper (bill of lading, waybill,
dangerous cargo manifest, or other
shipping document) used in lieu of the
orginal manifest to fulfill the record-
keeping requirement of § 250.33.
(b) "Generator" means any person
defined as a generator in regulations
under subpart B of this part.
(c) "Hazardous material" means a
substance or material which has been'
determined by the Secretary of Trans-
portation to be capable of posing an
unreasonable risk to health, safety.
and property when transported in
commerce, and which has been so des-
ignated under 49 CFR 171.8 and 173.
(d) "Identification code" means the
unique code assigned to each trans-
porter of hazardous waste by EPA or
an authorized State upon notification
in accordance with subpart G of this
part or upon compliance with §250.32
of this subpart.
(e) "Manifest" means the form used
for identifying the quantity, composi-
tion, and the origin, routing and desti-
nation of hazardous waste as specified
in regulations under §250.22, subpart
B of this part.
(f) "Mode" means any of the folow-
ing transportation methods: Rail.
highway, air, or water.
(g) "Motor vehicle" means a vehicle,
machine, tractor, trailer, or semi-
trailer, or any combination thereof,
propelled or drawn by mechanical
power and used upon the highways in
transportation. It does not include a
vehicle, locomotive, or car operated ex-
clusively on a rail or rails.
(h) "On the site", means on the same
or geographically contiguous property.
Two or more pieces of property which
are geographically contiguous and are
divided only by public or private
right(s)-of-way are considered a single
. site.
(1) "Permitted hazardous waste man-
agement facility" (or "permitted facili-
ty") means a hazardous waste treat-
FEDERAL REGISTER, VOL 43, NO. 13—FRIDAY, APRIl 2«, 1978
A-7
-------
PROPOSED RULES
18511
ment, storage, or disposal facility that
has received an EPA permit in accor-
dance with the requirements of sub-
part E of this part or a permit from an
authorized State agency.
(j) "Spill" means any accidental dis-
charge of a hazardous waste onto or
into the land or water.
(k) "Transporter" means a person or
Federal agency engaged in the trans-
portation of hazardous waste by air,
rail, highway, or water.
(1) "Transport vehicle',' means a
motor vehicle, rail freight car, freight
container, cargo tank, portable tank,
or vessel (as defined in 49 CFR 171.8)
used for the transportation of hazard-
• ous waste.
: (m) "United States" means the 50
States, District of Columbia, the Com-
monwealth of Puerto Rico, the Virgin
Islands, Guam, American Samoa, and
the Commonwealth of the Northern
Mariana Islands.
§250.32 Identification code.
Any transporter who transports or
Intends to transport hazardous waste
within the United States shall comply
with §§250.822 and 250.823 to obtain
an identification code from the Envi-
ronmental Protection Agency or an
authorized State. The identification
code issued shall be included on:
(a) The manifest (§ 250.22);
(b) The hazardous materials incident
report (§ 250.37); and
(c) The " delivery document
(§ 250.35(O).
§ 250.33 Recordkeeping.
Each transporter shall maintain a
copy of the manifest or delivery docu-
ment for a period of not less than 3
years from date of either transfer of
the hazardous waste to another trans-
porter or delivery of the hazardous
waste to a permitted facility as indi-
cated on the manifest or the delivery
document.
§ 250.34 Acceptance and transport of haz-
ardous waste.
(a) A transporter shall not accept
from a generator a shipment of haz-
ardous waste without a manifest
signed by the generator in accordance
with the provisions of § 250.22.
(b) A transporter shall not transport
a shipment of hazardous waste from a
generator without signing the mani-
fest acknowledging acceptance of the
hazardous waste shipment.
(c) If a shipment of hazardous waste
is transported by more than one trans-
porter, subsequent transporters shall
not accept for transport or transport
the hazardous waste shipment without
,a manifest or shipping document that
contains the information on the mani- -
fest in accordance with the provisions
of § 250.22.
(d) A transporter shall not transport
a shipment of hazardous waste in con-
tainers not properly labeled or marked
in accordance with the provisions of
§ 250.26:
(1) If the DOT label is lost or de-
tached, the transporter .must replace
that DOT label in accordance with the
provisions of § 250.26. *
(2) The DOT replacement label must
be based on the information taken
from the manifest covering the ship-
ment.
(e) A transporter shall not transport
containers which are leaking or appear
to be damaged. In the event that leak-
age develops or is^ discovered during
transportation and the leakage results
In a spill, the transporter shall comply
with 250.37.
(f) A transporter shall not accept or
consolidate hazardous waste(s) consist-
ing of a material or mixture of materi-
als that is prohibited from transporta-
tion by 49 CFR 173.21.
§ 250.35 Compliance with the manifest.
(a) Each transporter shall assure
that a copy of the manifest or the in-
formation contained on the manifest
(in the form of, e.g., a hazardous mate-
rials shipping paper, bill of lading,
waybill) at all times accompanies the
shipment of hazardous waste. >
(b) If the hazardous waste shipment
is transferred between the different
modes (air, rail, highway, or water) or
between different transporters using
the air or highway mode, each trans-
porter and each subsequent transport-
er shall sign the manifest or delivery
document acknowledging acceptance
of the shipment before the hazardous
waste can be transported.
(c) The delivery document shall:
(1) Contain as a minimum, the fol-
lowing information:
(i) Name, address of transporter;
(ii) Name, address, identification
code of generator;
(iii) Name, address, identification
code of designated permitted facility;
(iv) Corresponding manifest docu-
ment number; and
(v) Description and quantity of haz-
ardous waste.
(2) Only be used when the original
manifest is not with the shipment of
hazardous waste.
(d) The transporter shall, upon de-
livery of the hazardous waste to the
designated permitted facility, obtain
the signature of an authorized agent
of the permitted facility on the mani-
fest or delivery document certifying
delivery.
(1) If a delivery document Is used in
lieu of the manifest, the transporter
shall issue three copies of the delivery
docuent to the designated permitted
facility for signature. The transporter
shall retain one of the signed copies as
required by 250.33.
(2) If the transporter cannot acquire
immediate certification, the transport-
er shall:
(i) Indicate on the manifest or deliv-
ery document the following:
(A) Time and date of delivery: ana
(B) Reason manifest or delivery doc-
ument could not be certified upon, de-
livery; and
(ii) Acquire certification on the
manifest or delivery document by an
authorized agent of the permitted fa*
cility as soon as possible, but not to
exceed 5 working days after delivery
of the shipment.
§ 250.36 Delivery of hazardous wastes to a
designated permitted facility. ' <
(a) The transporter shall deliver the
entire quantity of hazardous waste(s)
accepted from a generator or a trans-
porter to a permitted facility designat-
ed by the generator on the manifest.
(b) If the transporter removes the,
hazardous waste from a transport ve-
hicle or aircraft for purposes of blend-
ing, mixing, treating, or storing, the
blending, mixing, treating, or storing
shall be done at a permitted facility.
(c) If hazardous wastes from differ-,
ent generators or separate wastes from
the same generator becomes mixed
after having been accepted by the
transporter, the transporter shall
comply with the generator standards
under subpart B of this part unless
the transporter can demonstrate that
the information designated on the
manifest(s) under §250.22 (a) (5), (6)
of subpart B of this part still identifies
the hazardous waste.
§ 250.37 Spills.
(a) If a spill of hazardous waste re-
quires immediate removal to protect
human health or the environment (as
determined by EPA, other Federal •
agencies, or a State or local authorized?
official), the requirements of this sec-
tion shall apply in lieu of §§250.32,
250.33, 250.34, 250.35, 250.36, and
250.38 of this subpart until the spilled
hazardous waste no longer presents an
immediate hazard to human health or
the environment (as determined- by
EPA, other Federal agencies, or a
State or local authorized official).
(b) In the event of any spill of. haz-
ardous waste during transportation,
the transporter shall:
(1) Telephone immediately:
(i) The National Response Center,
U.S. Coast Guard, toll free, 800-424-
8802; or
(ii) The government official prede-
signated in the applicable regional
contingency plan pursuant to 40 CFR
1510 as the on-scene coordinator for
the geographic area in which the inci-
dent occurs.
(2) Furnish the following informa-
tion upon notification:
(i) Name of person reporting the
spill;
(ii) Name and address of transporter;
(iii) Name and address of generator;
(iv) Phone number where reporter
can be contacted;
FEDERAL REGISTER, VOL 43, NO. 83—FRIDAY, APRIL 28, 1978
A-8
-------
18512
PROPOSED RULES
(v) Date, time, and location of inci-
dent, (indicate pollution of land,
water, air, or public water supply, if
known);
(vi) Type of transport vehicle and
mode;
(vii) Type of incident (e.g., fire,
breakage, spillage);
(Till) Classification, name, and quan-
tity of hawtfdeui waste involved, to
the extent available; and
(ix) The extent of injuries, if any.
(3) File within 1ft days a written
report in duplicate with the Director,
Office of Hazardous Materials Oper-
ations, Materials Transportation
Bureau, Department of Transporta-
tion, Washington, D.C. 20590, on each
spill that occurred during the course
of transportation. DOT form F 5800.1'
shall be utilized as a basic reporting
document; item A 1.6 shall be filled in
'DOT form F 5800.1 is filed as part of the
original document and available from the
Office of Hazardous Materials Operations.
Materials Transportation Bureau, Depart-
ment of Transportation, Washington, D.C.
30590.
as "waste"; item B4 shall include the
transporter's identification code. In
addition under part H of DOT form
5800.1, the following information shall
be included:
(i) If known, location of spill in rela-
tion te surface Waters, Public-water
•apply, greufldwatef, wildlife ha&itata,
and agricultural production areas:
(ii) Quantity of material removed
and disposition of the material; and
(ill) Disposition and quantity of un-
removed material.
(c) The transporter shall clean up all
the spilled hazardous waste or take
such action as may be required by
Federal, State, or local agencies so
that the spilled hazardous waste no
longer presents u hazard to human
health or the environment.
$ 250.38 Placarding/marking of vehicles.
(a) A transporter shall not move a
transport vehicle containing hazard-
ous waste which is also a DOT hazard-
ous material unless it is placarded in
accordance with 49 CFB 172, subpart
F. This prohibition applies to both in-
trastate and interstate transportation.
(b) A transporter shall mark each
motor vehicle being operated under its
own power for the transportation of
hazardous waste if the motor vehicle
is required to be placarded or if the
motor vehicle contains greater than
1)000 pounds of hazardous-waste. The
marking §h&}i &§giay Die following in-
formation:
(1) Name of transporter Ufldev
whose authority the vehicle is being
operated; and
(2) The city or community in which
the carrier maintains its principal
office or in which the vehicle is cus-
tomarily based.
(i) The marking must:
(A) Appear on both sides of the vehi-
cle;
(B) Be in letters that contrast sharp-
ly in color with the background; and
(C) Be readily legible during day-
light hours from a distance of 50 feet
while the vehicle is stationary.
(ii) The marking may consist of a re-
movable device meeting the above
identification requirements.
IFR Doc. 78-11698 Filed 4-27-78; 8:45 am)
FEDERAL REGISTER, VOL 43, NO. 83-fRIDAY, APRIt M. 1978
A-9
-------
APPENDIX B
ORGANIZATIONS FURNISHING INFORMATION
(IN ADDITION TO THOSE LISTED IN
TABLES II-l AND II-2)
B-l
-------
APPENDIX B-l
RAIL CARRIER SEGMENT
Railroads
Southern Pacific Railroad
San Francisco, California
Missouri Pacific Railroad
St. Louis, Missouri
Southern Railroad
Atlanta, Georgia
The Chessie System
Baltimore, Maryland
Disposers and Reclaimers
ENS CO
El Dorado, Arkansas
SCA/Chem-Trol
Model City, New York
Rollins Environmental Services, Inc.
Houston, Texas
Solvents Recovery Service of New Jersey, Inc.
Linden, New Jersey
Industrial Tank, Inc.
Martinez, California
Merichem Co.
Houston, Texas
Stouffer Corp.
Alabama, Texas, & Ohio
Others
Bureau of Explosives
Association of American Railroads
Washington, D.C.
Schneider Tank Lines
Neenah, Wisconsin
Texas City Terminal Railway
Company
Texas City, Texas
Military Traffic Management
Command
Department of Defense
Washington, D.C.
Director of Transportation
U.S. Air Force
Washington, D.C.
Ethyl Corp.
Louisiana
B-2
-------
APPENDIX B-2
FOR-HIRE MOTOR CARRIER SEGMENT
Advanced Pollution Control Corp.
Braintree, Massachusetts
Area Sanitary Service
Monticello, Indiana
Charles George Trucking Company, Inc.
Tyngsboro, Massachusetts
Chemical Leaman
Downingtown, Pennsylvania
Barrel H. Wright Trux
Jamestown, Colorado
Davis Transport Company
Paducah, Kentucky
FPR Bohager and Sons, Inc.
Baltimore, Maryland
General Drainage
Gary, Indiana
Glazer Scrap Corporation
Richmond, Indiana
Groendyke Transport, Inc.
Enid, Oklahoma
Independent Waste Systems, Inc.
Gary, Indiana
Inland Pumping and Dredging Co.
Downingtown, Pennsylvania
Jones Chemicals, Inc.
Beech Grove, Indiana
Keefe Trucking Company
Portsmouth, New Hampshire
Liberty Waste Disposal
Baytown, Texas
Liquid Removal Service Company, Inc.
Broomall, Pennsylvania
Maryln Engineering Corporation
Boston, Massachusetts
Matlack, Inc.
Lansdowne, Pennsylvania
M.E. Trucking Company
Detroit, Michigan
Mister Frank, Inc.
South Holland, Illinois
McKay Trucking Company
Coalinja, California
Oilfields Trucking Company
Bakersfield, California
Powell Sanitation
Oklahoma City, Oklahoma
Rainbow Truck Company
Long Beach, California
Reiss Envirochem, Inc.
Sheboygan, Wisconsin
Schneider Tank Lines
Neenah, Wisconsin
Scrap Haulers of Riverdale
Riverdale, Illinois
Snow Environmental Services
Marcus Hook, Pennsylvania
Tappan Tanker Terminal, Inc.
Hastings on the Hudson, New York
The Liquidator, Inc.
Everett, Massachusetts
B-3
-------
APPENDIX B-2 (Cont.)
United Pumping Service
El Monte, California
Valley Industrial Pumping
San Jose, California
Van't Tank Truck Service
Marine City, Michigan
Waste Transport Company
Adams City, Colorado
B-4
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APPENDIX B-3
WATER CARRIER SEGMENT
American Commercial Barge Lines
Jeffersonville, Indiana
B and M Towing Company
Houston, Texas
Canal Barge Company
New Orleans, Louisiana
Chotin Transport, Inc.
New Orleans, Louisiana
Dixie Carriers
Hous ton, Texas
Marine Transport Company
St. Louis, Missouri
Merichem Company
Houston, Texas
U.S. Coast Guard
Department of Transportation
Washington, D.C.
B-5
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APPENDIX B-4
AIR CARRIER SEGMENT
Air Line Companies
American Airlines
New York, New York
Blackhawk Air Service, Inc.
Rock Falls, Illinois
Blackhawk Airways, Inc.
Jonesville, Wisconsin
Federal Express Corporation
Memphis, Tennessee
Flying Tiger Line, Inc.
Los Angeles, California
Ozark -Air Lines, Inc.
St. Louis, Missouri
Seaboard World Airlines, .Inc.
Jamaica, New York
United Air Lines, Inc.
Chicago, Illinois
Other
Airport Control Tower
Longview, Texas
CFE Air Cargo, Inc. (Ground Handler)
Norfolk, Virginia
Department of Defense:
Director of Transportation,
U.S. Air Force
Military Airlift Command
Military Traffic Management Command
Department of Transportation
Federal Aviation Administration
Washington, D.C.
Profit by Air, Inc.
Springfield Gardens, New York
Shulman Transport Enterprises
Cherry Hill, New Jersey
Associations
Air Freight Forwarders Association
of America
Washington, D.C.
Air Line Pilots Association,
International
Washington, D.C.
Air Transport Association
of America
Washington, D.C.
National Air Transportation Associations
Washington, D.C.
B-6
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APPENDIX B-5
PIPELINE SEGMENT
American Petroleum Institute
Washington, D. C.
Department of the Army
Corps of Engineers
Washington, D. C.
Asarco, Inc.
New York, New York
Bechtel Corporation
San Francisco, California
Black Mesa Pipeline
Los Angeles, California
Buckeye Pipe Line Company
Radnor, Pennsylvania
Cleveland Regional Sewer Authority
Cleveland, Ohio
Colonial Pipeline Company
Atlanta, Georgia
Consolidated Edison Company
of New York, Inc.
New York, New York
Consolidation Coal Company
Los Angeles County Office of Sanitation
Los Angeles, California
Metropolitan Sanitary District of
Greater Chicago
Chicago, Illinois
Oklahoma State Development of Health,
Industrial, and Solid Waste Management Div.
Oklahoma City, Oklahoma
Slurry Transport Association
Washington, D. C.
U. S. Department of Transportation
Office of Pipeline Safety
Washington, D. C.
William J. Lamberton
Tulsa, Oklahoma
Dravo Corporation
Pittsburgh, Pennsylvania
Gulf Coast Waste Disposal Authority
Intercomp Resource Development and
Engineering, Inc.
Houston, Texas
Kennecott Copper Corporation
New York, New York
B-7
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APPENDIX B-6
GENERATOR SEGMENT
A&K Materials Company
Oklahoma City, Oklahoma
Aerojet Solid Propellant
Sacramento, California
Air Products and Chemicals
Oklahoma City, Oklahoma
Aladd Pest Control Company, Inc.
Oklahoma City, Oklahoma
AMF Tuboscope
Edmond, Oklahoma
Amtekco Industries, Inc.
London, Ohio
APW Company, Inc.
Rockaway, New Jersey
Arapahoe Chemicals Inc.
Boulder, Colorado
Atco Termite and Chemicals
Tulsa, Oklahoma
Augusta Bag & Burlap Company
Augusta, Georgia
Avril G.A. Company
Cincinnati, Ohio
Bibb Manufacturing Co.
Columbus, Georgia
Bona-Allen
Buford, Georgia
Continental Oil Co.
Denver, Colorado
Cook Paint and Varnish Co.
Kansas City, Missouri
Dorchester Gas Producing Company
Hooker, Oklahoma
Dow Chemical Company
Midland, Michigan
E.I. DuPont de Nemours & Co.
Deepwater, New Jersey
E.I. DuPont de Nemours & Co.
Wilmington, Delaware
Eastman Kodak
Rochester, New York
Electra-Power, Inc.
Cincinnati, Ohio
Eli Lilly
Clinton, Indiana
Ethyl Corp.
Baton Rouge, Louisiana
FMC Corporation
Philadelphia, Pennsylvania
General Motors
Warren, Michigan
B. F. Goodrich
Cleveland, Ohio
Greenfield Tap & Die
Greenfield, Massachusetts
Henny Penny Corp.
Easton, Ohio
Johns Manville Sales Corp.
Denver, Colorado
Linde Division
Union Carbide Corp
Tulsa, Oklahoma
B-8
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APPENDIX B-6 (Cont.)
Majestic Lubricating Company
Tulsa, Oklahoma
Mapco, Inc.
Tyrone, Oklahoma
Mary Carter Paints
Wheeling, Illinois
Monsanto Industrial Chemical Co.
St. Louis, Missouri
Moore Chrome Products Co.
Toledo, Ohio
National Cylinder Gas
Chemetron Corporation
Oklahoma City, Oklahoma
Olin Corporation
New Haven, Connecticut
Osborne Hosiery Company
Dallas, Georgia
Pfizer, Inc.
Groton, Connecticut
Prime Tanning
Berwick, Maine
Rockport Machine and Tool Co.
Lakewood, Ohio
Roisman Drug Sundries, Inc.
Oklahoma City, Oklahoma
Rubicon Chemical
Geismar, Louisiana
Schill Pattern Company
Toledo, Ohio
Sharp Industries, Inc.
Somerdale, New Jersey
Sherwin Williams,
Cleveland, Ohio
Smith Electro Chemical Co.
Cincinnati, Ohio
Stauffer Chemical Co.
Westport, Connecticut
Sylvania GTE
Danvers, Massachusetts
Talon Zipper
Meadville, Pennsylvania
Thomas Enterprises
Tulsa, Oklahoma
3M Company
St. Paul, Minnesota
Union Carbide
Institute, West Virginia
B-9
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APPENDIX B-7
HAZARDOUS WASTE MANAGEMENT FACILITY SEGMENT
A-l Disposal, Inc.
Plainwell, Michigan 49080
American Chemical Service
Griffith, Indiana 46319
Approved Chemical Treatment
Grand Rapids, Michigan 49608
Approved Industrial Removal
Grand Rapids, Michigan
Big 3 Enterprises
Kansas City, Missouri 64101
Browning-Ferris, Inc.
Houston, Texas 77025
By-Products Management, Inc.
Schererville, Indiana 46375
Chem-Met Services
Wyandotte, Michigan
Chem-Nuclear Systems, Inc.
Portland, Oregon 97207
Chemical Processors, Inc.
Seattle, Washington 96108
Chemical Recovery Systems, Inc.
Romulus, Michigan 48174
Chemical Waste Management
Calumet City, Illinois
Chemline Corporation
Ohio Industrial Wastes Division
Lisbon, Ohio
Conservation Chemical Co.
Gary, Indiana 46406
Dearborn Refining Company
(Phillips Waste Oil Pickup)
Dearborn, Michigan 48121
Earth II
Chicago, Illinois 60617
Edwards Waste Oil & Road Oiling Service, Inc.
Detroit, Michigan
Environmental Waste Control, Inc.
Inkster, Michigan 48141
Erieway Pollution Control
Bedford, Ohio 44146
Fisher-Kalo Chemical & Solvent Corp.
Kingsbury, Indiana
Gaess Environmental Services
Division of SCA Services, Inc.
Passaic, New Jersey
General Oil Co., Inc.
Detroit, Michigan 48239
Gulf Coast Waste Disposal Authority
Houston, Texas
Hammond Septic Tank Service
East Leroy, Michigan
Hartley and Hartley, Inc.
Kawkanlin, Michigan 48631
IWD Liquid Waste Incorporated
Dayton, Ohio 45414
Industrial Liquid, Waste Disposal Co.
Columbus, Indiana
Interstate Pollution Control
Rockford, Illinois 61101
Jacobusse's Refuse Service Co.
Holland, Michigan 49423
Koski Construction Co.
Ashtabula, Ohio
B-10
-------
APPENDIX B-7 (Cont'd.)
William J. Lamberton
Tulsa, Oklahoma
Liqwacon Corporation
Thomaston, Connecticut
The Major Oil Co., Inc.
Romulus, Michigan 48174
Malone Company -
Texas City, Texas 77590
Metro Tank Service
Warren, Michigan 48093
Michigan Petroleum
Detroit, Michigan 48212
Nelson Chemicals Co.
Detroit, Michigan 48227
Newco Chemical Waste Systems, Inc.
Niagara Falls, New York
(Braintree, Massachusetts Div.)
Nuclear Engineering Co., Inc.
San Ramon, California 94583
Ohio Liquid Disposal, Inc.
Fremont, Ohio 43420
Omar Rendering Company
Chula Vista, California
Pacific Disposal Systems
Martinez, California
Pollution Control
El Dorado, Arkansas 71730
Richmond Sanitary Service
Richmond, California
Rollins Environmental Services, Inc.
Wilmington, Delaware
Swedesboro, New Jersey
Baton Rouge, Louisiana
Houston, Texas
Deer Park, Texas
Robert Ross & Sons, Inc.
Grafton, Ohio 44044
Rozema Industrial Waste
Hudsonville, Michigan
SCA Services, Inc.
Boston, Massachusetts
Bay City, Michigan
Model City, New York (Chem-Trol Plant)
Spartan Chemical Company
Wyoming, Michigan 49509
C. Stoddard & Sons Company
Wayland, Michigan 49348
D. A. Stuart Oil Co., Ltd.
Northville, Michigan
Chicago, Illinois
Systech Waste Treatment Co.
Muskegon Heights, Michigan 49444
Thomas Solvent Co., Inc.
Battle Creek, Michigan 49016
Thrall Oil & Chemical Co., Inc.
Flint, Michigan 48503
U. S. Chemical Co., Inc.
Roseville, Michigan 48066
U. S. Pollution Control, Inc.
Division, Beard Oil Co.
Oklahoma City, Oklahoma
U. S. Scrap Company
Chicago, Illinois
Usher Oil Service, Inc.
Detroit, Michigan
Wagoner Transportation Company
Muskegon Heights, Michigan
Waste Acid Services
Detroit, Michigan
B-ll
-------
APPENDIX B-7 (Cont'd.)
Waste Management, Inc.
Chicago, Illinois
Owen G. Weisenbach
Sebewaing, Michigan 48759
Zero Waste Systems, Inc.
Oakland, California 94608
B-12
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APPENDIX C
ILLUSTRATIONS OF TRANSPORT VEHICLES
C-l
-------
KKMIGJIT CARS: Ilox, Cliiss XM
CHICAGO AND ILLINOIS MIDLAND
BOXCAR
Rated capacity is 154,000 Ihs. or 5227 cu.
ft. Dimensional data is shown on the
general arrangement diagram, below.
Built 1973.
PULLMAN-STANDARD 50-FOOT
GENERAL PURPOSE BOXCAR
, INCH/MILLIMETER
INCH
MILLIMETER
Dimensions are given first in English, then in
metric form, following accepted standards for
dimensioning drawings. English dimensions are
in inches with decimal fractions, metric in
millimeters.
Source: Car and Locomotive Cyclopedia,
Centennial Edition, Simmons-
Boardman, New York, 1974.
ATCHISON, TOPEKA AND SANTA FE HI-CUBE BOXCAR
An excess height hi-cube car, it has a rated capacity o£ 185,000 Ibs. or 6196 cu.
ft. Outside dimensions arc 511 ft. 11 in. high, 10 ft. I) in. wide and Ifl ft. 11 in.
high. Inside dimensions .'ire 50 ft. fl In. loni;, D ft. (i In. wide and 12 ft. 11 in.
high. Total door opening measures 16 ft. wide and 12 ft. high, lluilt by Pull-
man-Standard, 1074.
B-Fnd Arrantiempnl
C-2
-------
FREIGHT CARS: Tank
~1
45« SAFETY VENT A
2' AIR CONNECTION
QUICK OPENING FILL HOLE
7,000 GALLON CAPACITY • NON INSULATED
DOT • 103AK
FOR 5ULFURIC ACID SERVICE
MINIMUM HORIZONTAL CURVE NEGOTIABILITY
1. TWO LIKE CARS COUPLED TOGETHER-US PT
2. TANK CAR ON TANGENT • STANDARD
CAR |40'-6"> ON CURVE -152 FT
CAPACITY & WEIGHTS
NOMINAL CAPACITY « t% OUTAGE - 7,000 GALS
ESTIMATED LIGHT WEIGHT - 42,400 LBS
HAIL LOAD LIMIT (50 TON TRUCKS) - 177 000 LBS
COMMODITY MAXIMUM DENSITY
TRUCK CAPY.
50 TON
WHEEL BASE
5' 8
NON COILED COMM WT/GAL.
IS 3»
13.350 GAaON CAPACITY - NON INSULATED
DOT - 111A100W2
FOB SULFUWC ACID SERVICE
MINIMUM HORIZONTAL CURVE NEGOTIABILITY
I. TWO LIKE CARS COUPLED TOGETHER 149 FT.
2. TANK CAB ON CURVE • STANDARD CAR
I40'-6"l ON TANGENT 117 FT.
CAPACITY & HEIGHTS
NOMINAL CAPACITY t n OUTAGE - 13.350 GALS.
ESTIMATED LT. WT INON COILEDI - 55.600 LBS.
RAIL LOAD LIMIT (100 TON TRUCKS) -263,000 LBS.
COMMODITY MAXIMUM DENSITY
Source: Car and Locomotive Cyclopedia,
Centennial Edition, Simmons-
Boardman, New York, 1974.
TRUCK CAPY
100 TON
WHEEL BASE
5 10
NON • COILED COMM. WT./GAL.
15 3«
GAUGING DEVICE. SAFETY VALVE. V IHEIWOME1ER WELL.
3 • 2" ANGLE VALVES ft *" TEST TUBE ANGLE VALVE
CENTER LINE
OF ANGLE VALVE
I4'.| ll-lr. '
— 39 -5V TRUCK CENTERS
50'-5" OVER STRIKERS
63-.QVi--COUPLED LENGTH
26,100 GALLON CAPACITY • NON INSULATED
DOT - 117A340W
IOR VINT! CMIOHIOI MHVICC
MINIMUM HORIZONTAL CUIIVC NEOOTIAllLITr
1. TWO LIKE CARS COUPLED TOGEIMER 160 FT.
2. lANKCAd ON CURVE STANDARD
CAR 141) 6"! ON TANf.fNI ISO FT
CAPACITY ft WEIGHTS
NOMINAL CAPACITY • IK* FILL ING DENSITY -26.100 GALS
ESTIMA1EO LIGHT WIIGHT 74,500 LBS
RAIL LOAD LIMIT 1100 ION TRUCKS' - 15' 10' KrMm'BASi 1 2«3 Dm LBS
C-3
-------
FREIGHT CARS: Covered Hoppers, Class LO
Norfolk & Western uovorsd hop-
par car. Road Class HC-71.
Built bv the rnllrond In 1973, It In
vqtilplird with gnivlty-pnminmtlc
discharge gales. Hated at 186,000
Ibs or 4750 cu ft capacity. Inside
length 56 ft 3 in.; Inside width 10
ft.
1 Ml H-M 'I- I
i L,,JJ' .j«u-U U.-BIK>- —
_ n'-o- 4-— T^IOJ" -J
J.- »'.|0' - -
- 4B'-»"
jrgjjg*_.CCHTggS
_ 97ie- oven STffi
TROUGH OPENING
1
-------
TRUCKS
Flatbed
7 MPG
65,000 Ib. Capacity
Large Dump
6 MPG
55,000 Ib. Capacity
Small Dump
7 MPG
20,000 Ib. Capacity
Stake
8 MPG
15,000 Ib. Capacity
Hopper-Type Dump
6 MPG
80,000 Ib. Capacity
Bulk Tanker
7 MPG
65,000 Ib. Capacity
Source: Motor Vehicle Manufacturers Association,
Detroit, Michigan.
C-5
-------
TANK NOMENCLATURE
MC 307 CHEMICAL
Walkway
Ladder
Hose Tube
Fenders,
o
Connection
.Box
Sand Shoes Hose Tube
Upper Coupler Supports
Source: Transportation Equipment Corp., Minneapolis, Minnesota
-------
Hopper Barge Open Barge
XXV \
TYPES OF BARGES ON INLAND WATERS
AS DESIGNATED IN COL. 3
r
Car<9'o
/»
Single Deck
Covered Burge
x, Car^o
//////////////A
'<\
Double Dock
Covered Barge
Deck House
Barge
Carg'o
Drop Dnck
(Covered Barg
Catfo
Drop Dock
Opou BarKe
•?77S/7$.
4
v//.////?///
Coaming Deck
Barge
.xxxx^!
Deck Barge
Source: Record of American Bureau of Shipping, New York, 1965.
-------
APPENDIX D
SAMPLE SHIPPING DOCUMENTS
D-l
-------
1. Rail Carrier
D-2
-------
(For U.. I. Connection .Hh Uniform Domestic Straight BUI of lading. adopted by Corr,.,, m Official. Sou*.,*. Western .nd ,|to,, Clo,.lf,c.tlon T.rrllorl.,. March 15. 1922. o ..... d.d August I. IMO. end fan.
UNIFORM STRAIGHT BILL OF LADING AND TRANSIT RECORD
NO. 1 THIS SHIPPING ORDER ^J
sh,PP.,-,No
Southern Pacific Transportation Company
RECEIVED. «ib|«cl to th. classification, and tariffs In effecl on the dale of the receipt by the carrier of Ihe properly described in Ihe Original Bill of lading.
>. RICHMOND. CALIFORNIA
July 1 19 77
ABC REFINING COMPANY
From. ____
Ih, property dncribed b.low. in oppor.nl good order. .«c«pt o, nol.d (content, and rendition of content, ol package, unknown!, marked, consigned, and dettined Ol Indicated b.low, which laid company |>he
word con-pony being understood Ihroughoin Ihii conlrocl Ol meaning ony person or corporation in possession of Ih. properly under Ihe conrrocll, ogre., to corry >o ill usual ploce ol d.liv.ry ol laid destination,
II on ill own road of in awn wol.r lin.. otherwise to deliver to onoth.r corner on Ihe route to loid d.ilinollon. It n muluolly ogreed, ol to eoch corrier ol all or ony of .o,d prop.rly over oil or ony portion of
laid rout, to d«ltinotion. ond ai lo each party al ony t.m. inlereited in oil or ony of loid property, thol every lervice lo be performed h.r.under ihol! be lubjeel to oil the conditioni not prohibited by low whether
printed or written, hgr.in eontoin.d. including th. conditioni on poclc h.r.of, which ore hereby agreed to by th. shipper and accepted for himielf and hii oiugni.
(Mall or ilraet address of consignee—For purposes of notification only.)
Consigned te! ABC DISTRIBUTOR COMPANY
LOS ANGELES
S,at. CALIFORNIA
_Counly_
ri§nipping name or descriptions
classification)
CorNo.12345
Delivering Carrier
SERVICE DESIRED: Door to Door (
) • D*pot to Door (
e D«po| lo D*pot (
DESCRIPTION OF ARTICLED SPECIAl
Subject to SecMon 7 of cor-.JitloiM, If
this shipment Is (o be delivered to Ihe
consigned without recourse on lh« con-
signor, Ihe consignor shall sign the (bl-
owing statement:
The carrier shot! not make delivery of
this shipment without payment of freight
nd all other lawful charges.
FLAMMABLE
PLAUAH1JKU FLAMMABL
-^placard notation
basic deacrijrfcTom
If charges are to be prepaid, write 01
stamp here, "To be Prepaid."
^(.certification
This is to certify that the abovo
named materials
lo apply in prepayment of the charges on
Ihe property described hereon.
are properly classified, described
. packaged
condition
and are in proper
portation. according to the appl
A f ^ lb _. TA ._. _L .. _^ ^. __L A. ~. f~~tt\—.~. ...«_. ^^B^J. _. ^
cable ree
ol the Department of Transportat
John Smith
e« Ih. ihipm.nl mov.s b.lv/e.n two porll by a corrtor by wol.r. th. low require. Ihal Ih. bill of lading shall Hot. wh.th.r II ii '•carri.r's or shipper's weight."
NOtt-Wh.r. rh. rale is dependent on value, shipoen are. required to lUte specifically in writins th. agreed or declared volu. al the property.
Ike agreed or declared value of the property is hereby specifically staled by the shipper to be not exceeding per
Charges Advanced$_
COLLECT ON DELIVERY S.
. COD Charge lo b« Paid By; Consignee ( ) Shipper ( )
INBOUND REFERENCE
Tender Is hereby mode of Ihe following recorded Freight Bills or Tronsil Tonnage Credit Slips, to be applied on Ihe above outbound shipment;
Transit
Bureau
Com-
modity
Transit
Operation
FROM
Car No.
Woy-Bill
Pot.
WoyBill
No.
Issuing
Road
Rote
•
Transit
Weighl
Transit
Weighl
Used
Transit
House
Balance
of Rate
«
ABC REFINING COMPANY
.Shipper
P»r_
Agent mutt d«lach ond retain thli Shipping Order
ond mull sign Ihe Original Bill of Lading.
Ptrmon.nl poitofrlc* addr«« of «hlppe>r_
, „ ,. .,.n^ by „. .n,pp.r ond „.„. 0, .„.
ulnfl
D-3
-------
(For U» In Connection with Uniform Domvitfc Straight Bill of Lading, adopted by Carrier j In Official, Southern, Wetlarn and Illinois Cla tiff I cotton Territories, March 15, 1922. as amended Avflyil 1, 1930, and June 15,1
M _ O
NO. f.
UNIFORM STRAIGHT BILL OF LADING AND TRANSIT RECORD
Is an acknowledgment (hat a bill of lading hot bean issued and is
THIS MEMORANDUM notlh" Or'9inal.*•" °*Udlnawa copy or duplicate covering the Shipper's No..
prep.rt/ m
inS no
.r.in, or*, is illt.nd.dsol.ly for filing or r.»rd.
Southern Pacific Transportation Company
RECEIVED, sub|ecl to th« classifications and tariffs in .ffect or Ih. dale of the receipt by the carrier of the property described in Ih. Orlginol BUI ot Lading,
A. Richmond. California
July 1, 19JZZ—
frnm ABC Manufacturing Company
the property described below, in apparent good order, except as noted (contents and condition of c nients of packages unknown], marked, consigned, and destined os indicated below, which said company [the
word company being understood throughout this ccnfrael os moaning ony person of corporation in possession of the property under the contract), agrees to carry 10 ir$ usual ploce of delivery of soid destination,
If on its own road or its own water line, otherwise to deliver lo another carrier on the route to soid destination. It is mutually agreed, os to each carrier of all or any of laid property over oil or ony portion of
laid route lo destination, and os to each party ot any lime interested in all or any of said property, that every service lo be performed here under shall be subject to all the conditions nor prohibited by low, whether
printed or written, herein contained, including the condition* on bock hereof, which ore hereby ogieed to by the shipper and accepted for himself find his assigns.
Consigned «~ ABC Distributor Company
(Mail or street address of consignee — For purposes of notification only.)
107 Main. Los Angeles, Calif.
Los Angeles
state California
_County_
Route.
SP
SP
Delivering Carrier.
SEIVICE DESIRED: Door to Doer I 1 • Door to Pop* 1 1 • Popo* to Door (
.Car Initials
1 • Oopot lo Dopot (
SP
.Car No. 12345
No. Pkgs.
100
300
50
DESCRIPTION OF ARTICLES. SPECIAL MARKS, AND EXCEPTIONS
Arsenic. Solid Q)"L /*r\
poison B ra J Q;
Placarded Poison (£)
Detergent, intermediate, petro
alkvlate
Bowling Balls, pl?.stic
©
""" This is to certify that the abov
are properly classified, descrit
and labeled , and are in proper c
portation according to the applj
of the Department of Transportat
John Smith
i - — - - - - ••e*^^™*^>»*.^»^»*».^"J»"^»^»*».*
'Weight (Sub|. to Corr.]
2.000
600
50O
e named mi
edj packa^
ondition :
cable regi
ion.
-t Agent, t
Class or Rate
iteria
;ed, m
'or tr
ilatio
iBU Mi-1
Check Col.
Is
arked
ans-
ns
li. (JO
*;f (he shipment moves belween fwo purls by a carrier by wolu<, lite law require* thai ititi bill o( lading sholi slotu whether it is "carrier's or shipper's weight."
NOTE~Where (he ral« is dependent en value, shippers ore re' ;>9d lo state specifically in writing the agreed or declared vclue of the property.
Ih. oareed or declared value of the oroDertv is hereby specilicullv slated by the shipper to be not exceeding per
Subject to Section 7 of conditions, if
this shipment is to be delivered to the
consignee without recourse on the con-
signor, the consignor shall sign the fol-
owing statement:
The carrier shall not make delivery of
{Signature of co"-' '
If charges are lo be p< -<•>, wrile or
stamp here, "lo be Prepaid."
Rec'd $
the property described here^,,,
Per
(The signature here etc! ,;es
only the amount ; ;
Is hereby modo of the following r«corded Frein'-t Biils or Transit Tonnarj1) Cr:ilil Slips, to be opplied on the above outbound shipment:
' Transit
Bureau
Mi.
Com-
modity
Troniit
Oper<:,:ion
FROM
Car No.
Way-Bill
Dale
Way-r.ill
No.
Issuing
Rood
Role
Transit
Weight
Transit
Weighl
Used
Balance Due
Transit
House
me.
. Hole
Shipping name or description (172.202 (1))
Classification (172.202 (2))
Basic description (172.202 Ufa))
Total quantity (172.202 Uc))
Placard notation (172.203 (g))
Certification (172.204 (a))
ABC Manufacturing co.
.Shipper
-Agent
Per_
Per.
Permanent pos toff ice address of shipper.
(This Bill of Lading is to be signed by the shipper and agent of the carrier issuing same.)
•D-4
-------
(Uniform Dom..tlc Slralghl BUI of Lading. odopLdI by Corrtm In Official, South.™. «.,,.„> and lllln.1. Cbu.lflca.lon T.rrHorl... March 15,1922. a. «m.nd«J Au,,,,,. 1.1930. and Jun.
UNIFORM STRAIGHT BILL OF LADING AND TRANSIT RECORD
NO. 3 OMGINAI-NOTNEGOHABIE
"w * * Shlpp.r'» No
Southern Pacific Transportation Company
No._
RECEIVED, subject to the doislflcotloni and tariffs In effect on Ihe dot. of th. Issue of mil Bill of Lading,
AJ Richmond. California
July 1. i9?7
AflC Manufacturing Company
the property described below. In opporenl good order, except 01 noted {contents and condition of contents of packages unknown), marked, consigned, and de.tlned 01 Indicated Mow which nld compcew Mo
word company being undentood Ihroughoul thil contract at meaning ony person or corporation In potieiilon of the property under the contract!, agreet to cor™ la It. usual place of delivery at laid de«lno«o«
If on in own road or In own woter line, otherwise la deliver to another corner on the route to laid deitlnatlon. It li mutually agreed. 01 to each carrier of all or any of laid property over all or any portla. 0}
laid route to destination, and o. to each party at any time interested In all or any of laid property, that every urvlce la be performed hereunder .hall be lubiecl to all the condition.™' prohibited by law whether
printed or written, herein contained.! Including the condition! on bock hereof, which are hereby agreed to by the ihipper and accepted for himielf and hit aiiigni.
(Mall or street address of conllgnee—For purpoiei of notification only.)
107 Main, Los Angeles, Calif.
Consigned te; ABC Distributor Company
De.«na,.on__Los_Angeles_
state California
_ County.
Route.
SP
SP
SP
Delivering Carrier_E£ Car Initial. ar
SERVICE DISHED; Door to Door ( ) • Door lo D«pot ( ) • D.po< to Door ( ) • D.pol la D.pot [
No. Pkgs.
300
100
500
hM
X
DESCRIPTION OF ARTICLES. SPECIAL MARKS. AND EXCEPTIONS
Detergent, intermediate,
petro alkvlate
Arsenic, Solid
-------
|ror Use In Connection with Uniform Domestic Straight 8)11 of Lading, adopted by Carriiri In Official, Southern, Wnt*rn ond Illlnolt Cfcmlfkatlon T«rrltorl«s, March 15, 19^2. as omenavd August t, 1930, a.,
-------
(f« Us. I. Co,n.dlon wllh Unlbrm DC™,,* Slml,M BUI of lodlr.,. eddied by Carrier, I. OWclol. Saulr,.™. W.,,.,r, end Mm.,, ammo,.!.,, I.,,,*,,,.,. March 15. l«2. , ..... ded A,,u,l 1. 1930, .« Jui» I "IS}
UNIFORM STRAIGHT BILL OF LADING AND TRANSIT RECORD
No. 5
THIS
I ma
ODDFD """' u I**MI *»•* «• i» >»•. in indelible
UKUtK pencil, or ir,carbon and retained by the A»en..
,., , .,
Shipper1! No
Southern Pacific Transportation Company
Agent's No..
RECEIVED, sub|ect la Ih. classifications and tarlfb In .H.cl on Ih. dot. of the receipt by the carrier ol the properly described In the Original BUI of Lading.
A. Richmond. California _
July 1, I977
ABC Refining Company
the properly deuribed below, in opporenl good order. e«cept n» noted (contents ond condition ol contents of packages unknownl. marked, consigned, and deslined a. indicated below which sold company Irhe
ward company being understood throughout Ihis contract as meaning any person or corporation in possession ol the properly under Ihe contract), agrees la corry lo its usual place ol delivery ot told dciiinalion
II on its own road or it. own woler line, otherwise lo deliver lo another carrier on the route lo sold desl.nolion. ll is mutually agreed, as lo each carrier of all or any of said property over all ar any porlion of
said route lo destination, ond OS lo each porly ol ony tme interested in all or ony of said property, that every urvice to be performed hereunder shall be subject lo all the conditions nol prohibited by law whether
primed or wtlllen. herein contained, including the conditions an bock hereof, which ore hereby agreed la by Ihe shipper ond accepted for himself ond his assigns.
(Mall or street address of consignee—For purposes of notification only.)
107 Main, Los Angeles, Calif.
Consigned *» A**C Distributor Company
Los Angeles
California
_ County.
Route.
SP
SP
Delivering Carrier.
SEKVICE DESIRED: Deer lo Door ( ) • Door lo Depot ( ) • Depot to Door (
.Car Initial* GATX
) • Depot lo Depot (
.Car No. 12345
No. Pigs.
I
1
DESCRIPTION OF ARTICLES, SPECIAL MARKS, AND EXCEPTIONS
Tank Car
EMPTY: Last Contained Gasoline
Flammable liquid, Placarded
#**OR***
Tank Car
Empty | Gasoline r
Flammable liquid, Placarded
*W eight (Subj. to Corr.)
Class or Rate
Check Col.
*Jf &• shipment move* betwam two ports by a carri.tr by wotar, Ih« low require* that the bill of lading shall stole whether il ii "carrier's or shipper's weight."
NOTE-Wher* Hi* rat* b d*p«i.i«fll en vain*. sh!pp*rs or*. r*quir*
consignee without recourse on the con-
signor, the consignor shall sign the (bl-
owing statement:
The carrier shall not moles H«Mv*ry of
this shipment without payment of freight
(Signature of consignor)
If charges are to be prepaid, writ* or
stamp here, "To be Prepaid."
R«c'rJ t
Ih* property described hereon.
Agent or Cashier
P.r
only th« amount prepaid.)
COLLECT ON DELIVERY S
COD Charge to be Paid By; Consignee ( ) Shipper ( )
INBOUND REFERENCE
Tmdw Is hereby made of Ihe following recorded Frelghl Bill! or Transil Tonnage Credil Slip., lo be opplled on Ihe obove outbound shipment:
Tranji*
Bureau
No.
Com-
modity
Tranill
Operation
FROM
Car No.
Way-Bill
Dale
Woy-Bill
No.
l.luing
Rood
Rate
Transit
Weight
Transit
Weight
Used
Balance Due
Transit
Hau.e
Balance
olRate
<•
ABC Refintne Company
-Shlpp.r
P«r_
Agenl mull deloch ond retain hSle Shipping Order
and mu«l ilgn the) Original BUI of lading.
Permanent po,teffic. oddr«. of .hlppr „„,. g|l, „ udm, I. I. b. ..«,». by Ih. .Mppe, c*. .,.nt .1 .he or,!.,
D-7
-------
PLACE SPECIAL SEP.VICE
CASTERS HERE
No. 1
*#*#******* s~.
S* ©
CS/00 3.A
A A f >3:
721 - SOUTHERN PACIFIC TRANSPORTATION COMPANY - 721
FREIGHT WAYBILL .
TO BE USED FOR SINGLE CONSIGNMENTS, CARLOAD, LESS CARLOAD, AND T.O.F.C. I
DANGEROUS
CAB INITIALS AND NUWBER
SP 12345
IF tRAILf * INITIAL AND NUMBf B
o.
E TRAILER INITIAL A! lO NUMBER
c.
STOP AT
THIS AT
1KIND WEIGHT IN TONS
GROSS TARE NET
KIND
UNGIH
PLAN
NUMBER
IENG1H
PLAN
NUMBER
CARAT
TO NO STATION STATE OR PROV.
Los Angeles, California
ROUTE 'Show each Junction and Carrier in Route order to destination Route
of waybill 1 Code No.
SP
Show 'A if Agent s Routing 01 'S if Shipper s Routing
PECONSiGNEC TO STATION
AUTHORITY
CONSIGNEE AND ADDRESS
AdC Distributor Gomp
107 Main, Los Angel e
STATE OR PROV
1 Code No
any
s, Calif.
FINAL DESTINATION AND ADDITIONAL ROUTING
Tos Angeles, Calif ornir
INSTRUCTIONS Protective Service Milling Weighing etc
On L.C.L. Traffic, Transfer Stamps to be shown in this space.
N°. pkg*. s:s'»:,t:s'E".p,,. i
ST" LQ 212 07 ^ *
ICO Arsenic, Solid©? .- "~
Poison B© J©
Placarded Poison (£)
300 Detergent intermeoiato, petro
a Iky late
50 Bowling Balls, plastic
LENGTH OF CAR MARKED CAPACITY OF CAR
ORDERED FURNISHED ORDERED
FURNISHED
DATE OF SHIPMENT WAYBILL NUMBER
July 1, 3977 45676
CONSIGNEE AND ADDRESS AT STOP
FROM NO STATION STATE OR PROV
SRIG,AN (22500 ) Klchfflond, California
BILLED AT . ( )
SHIPPER. ALSO SHIPPER S NUMBER OR BILL OF LADING
NUMBER. WHEN AVAILABLE SHIPPER S COMPLETE AD-
DRESS AND INVOICE NUMBER ON CO D. SHIPMENTS.
Code No
£8C Manufacturing Company
.JRIC'N AND DATE. ORIGINAL CAR TRANSFER FREIGHT BILL AND PREVIOUS
WAYBILL REFERENCE AND ROUTING WHEN REBILLED.
AMOUNT WEIGHED
\i» S AT
. FEE
0 GROSS
• S ' ~ - - - -
ft IOIM TARE
ALLOWANCE
PICKUP SERVICE
YES NO
'"'IrUVER'r SERVirE I-IWI
REQUESTED IF CHARGES ARE TO BE PREPAID WRITE OR STAMP HERE
vtS NO TO BE PREPAID
WHEN SHIPPER IN THE UNITED STATES EXECUTES THE NO-RECOURSE
CLAUSE OF SECTION 7 OF THE BIU OF LADING. INSERT YES '
'ndiccrte bv iyi'bol irs Column provided it how weights we-e obtained for L C L Sh pmer.is oniv
y Railroad Scale. S Shipper i Tested Weights E bnmaied Weiyh and Conect
T Tonff Clossifico''on of Minimum
r WEIGHT RATE FREIGHT ADVANCES
2,000(J)
600
500
PREPAID
DESTINATION AGENT S
FREIGHT BILL NO.
Shipping mrs <-."• 'jesrriptior. (T72.2Oi
Classification ;17?.?02 (2))
Total quantify (172.P02 UoU
Placard notation (]7i>. W? (g))
Placard endorsement (174..2.5 \a,2jj
St.andarr! Commodity Code number
Basic descrirtion '.172.202 (4b))
Oulbound junction ogenl will ihaw lunction ilomps in space and order provided Additional junction itamps and all v('fd stompi to be placed on bock hereof
FIRST JUNCTION
SECOND JUNCTION
THIRD JUNCTION
FOURTH JUNCTION
Destination Agent Wilt Stamp Herein
Stntinn Nnme and Dm* R
721 - SOUTHERN PACIFIC TRANSPORTATION COMPANY - 721
D-8
-------
3-74
PLACE SPECIAL SERVICE
PASTERS HERE
^DANGEROUS*
7i«NMf»fOIOCAIi
I
CAS INITIAIS AND NUMBER
_QAI1
T.
0. _
F. "*"'
C.
721 - SOUTHERN PACIFIC TRANSPORTATION COMPANY - 721
FREIGHT WAYBILL
TO BE USED FOB SINGLE CONSIGNMENTS, CARLOAD, LESS CARLOAD, AND T.O.F.C.
KIND
KIND
'NUlAi AND NUMBtB
1
WEIGHT IN TONS
TARE
PUN
NUMBER
PLAN
NUMBED
STOP AT.
THIS AT
__
TO NO.
STATION
STATE OR PROV.
LENGTH OF CAR
DATE OF SHIPMENT
FURNISHED
July 1,. 1077 I 23^,56
CONSIGNEE AND ADDRESSATSTOP
MARKED CAPACITY OF CAR
WAYBILL NUMBER
FROM NO. STATION STATE OR PROV.
ORIGIN' (22500 ).Kic}imDiXfil._Californ.ia
BILLED AT ( )
ROUTE 'Show eoch Junction ond Carrier in Route order to destination
of waybill.:
SP
Show A if Agent's Routing or "S" if Shipper s Routing
Route
Code No.
SHIPPER, ALSO SHIPPER'S NUMBER OR BILL OF LADING
NUMBER. WHEN AVAILABLE. SHIPPER'S COMPLETE AD-
DRESS AND INVOICE NUMBER ON C.O.D. SHIPMENTS.
AriC Manufacturing Company
Code No.
RECONSIGNED TO
AUTHORITY
STATION
STATE OR PROV.
ORIGIN AND DATE. ORIGINAL CAR. TRANSFER FREIGHT BILL AND PREVIOUS
WAYBILL REFERENCE AND ROUTING WHEN REBILLED.
CONSIGNEE AND ADDRESS
ABC Distributor Company
107 Main Los Angeles, Calif.
Code No.
FINAL DESTINATION AND ADDITIONAL ROUTING
Los Angeles, C*l*fornis_
C.s
F"
0.
D.
TOTAl
INSTRUCTIONS - Protective Service, Milling, Weighing, etc.
On L.C.L. Traffic, Transfer Stamps to be shown in this space.
PICKUP SERVICE
YES NO
DELIVERY SERVICE
REQUESTED
YES NO
AT
GROSS_
TARE
ALLOWANCE
NET
IF CHARGES ARE TO BE PREPAID, WRITE OR STAMP HERE
"TO BE PREPAID."
WHEN SHIPPER IN THE UNITED STATES EXECUTES THE NO- RECOURSE
CLAUSE OF SECTION 7 Of THE BILL OF LADING, INSERT "YES"
Indeate by symbol in Column provided It how weights were obtained for L.C.L. Shipments only.
K Roilfood Stole. S • Shipper s Tested Weights, E Esumoted Weigh ond Correct
T Tariff Classification or Minimum.
No. (
WEIGHT
RATE
FREIGHT
ADVANCES
PREPAID
1 T*mk Car
EMPTX: Laat Contained Gasoline
Flammable liquid, Placarded
Tank Car
Empty, Gasoline
Flammable liquid, Placarded
DESTINATION AGENT'S
FREIGHT BILL NO.
Outbound (unction, agent will show junction slomps in spate and order provided. Additionol lumi.on stomps and oil yord stomps to be placed on back hereof
FIRST JUNCTION | SECOND JUNCTION I THIRD JUNCTION I FOURTH JUNCTION
Destination Agent Will Stamp Herein
Station Nome and Date Reported
721 - SOUTHERN PACIFIC TRANSPORTATION COMPANY - 721 D~9
®»
-------
2. Motor Carrier
D-10
-------
TERMINAL NO.
matlack ,/nc „
pipeline on wheels
ESTABLISHED lift
MUOF
LADING
JO WEST BALTIMORE AVE., LANSDOWNE, PA. 19050/215-259-9800
X
PREPAID
COLLECT
PICKUP DATE
DELIVERY DATE
CONSIGNOR
CONSIGNEE
c.o.o. AMOUNT ITRACTOR
INTERLINE/TRIP LEASE CARRIER
COMPT MARKER SEAL NO.
TRAILER
INTERLINED AT
COMMODITY
Received subject to tariffs and/or con-
tract
DRIVER - MATIACK, INC.
NO.
DRIVER -MATIACK. INC.
NO.
Received the above described property
in good condition except as noted.
CONSIGNEE
ORIGIN
DESTINATION
QUANTITY ORDIRED
BILL MINIMUM D
00 NOT BILL MINIMUM Q
QUANTITY LOAD TEMP °F
TOTAL
This is to certify that the above named
articles are properly described and are in
proper condition for transportation accord-
ing to the regulations of the Interstate
Commerce Commission and/or any other
regulatory bodies. v
SHIPPER
MILES
FINISH
START
TOTAL
LOAD TIME
ARRIVE
START
FINISH
UNLOAD TIME
ARRIVE
START
FINISH
TOTAL ROUND TRIP TIME
HRS. MIN.
PICKUP TRIP TIME
HRS. MIN.
MILES
I SHIPPERS NO._
P CUSTOMER NO._
LUL.O.
CO PAY CODE
L,O.
_CTL. NO-
UJ-
O
rr-
o
D.S. TIME
D.S. MILES
PUMP/COMPRESSOR YES NO
ORDERED D D
USED TO LOAD Q O
USED TO UNLOAD D D
STAINLESS STEEL D D
CUSTOMER D D
METER YES NO
ORDERED D D
USED D O
WEIGHING
CHARGES
APPLY D O
TOTAL NO. FEET HOSE ORDERED
TOTAL NO. FEET HOSE USED
-FT.
DELAY FORM OP 142 COMPLETED
ATTACHED
B B
SPECIAL EQUIPMENT ORDERED.
IF YES SPECIFY
a a
If this shipment is to be delivered to the
consignee without recourse on the consign-
or, the consignor shall sign the following
statement.
"The carrier shall not make delivery of
this shipment without payment of freight
and all other lawful charges."
X
CONSIGNOR
SIGN HILL SIGNATURES—INITIALS NOT ACCEPTED
DRIVER: RETURN THIS COPY TO OFFICE
-------
r~ ~i
ROLLINS ENVIRONMENTAL SERVICES, INC.
Ill P. O. BOX 73877
BATON ROUGE, LOUISIANA 70807
I 504-778-1234 ,
• ,_ *
Gross
Tar p
Net
Bill To Address
QUANTITY
STREAM No.
MO 7R1I
Order Date * " ~
Ordered By
Ship Via
Mileage Out
In Plant Service
Yes D No D
Driver
Out Res
In Res
Representative
DESCRIPTION OF MATERIAL
PURCHASE ORDER NUMBER:
•» O
in
Dispatcher
Tractor
Trailer
Mileage In
Number Helpers
Bill of
Lading
In Cust.
Out Cust.
Zone
Area
PRICE
TOTAL
AMOUNT
-------
SCRAP HAULERS OF RIVERDALE
13840 SO. HALSTED
RIVERDALE. IL 60627
PHONES. (312) 995-1674
(312)841-7020
Date
PRODUCE* OF LIQUID WASTE
MO 01082
Pitkif Tim. Ml
Pickip Time PM
(KECK TYPE OF LIQUID WASTE:
1. Acid Solution
2. Alkaline Solution
a. Pesticides
4. Etching Solution
5. Spent Plating Solution
i. Caialjit
1. Brine
g. ErniCum
1 Tetra Ettijl Lead Sludge
10. Toik Tank Bottom
Sediment
11. Other Toiic Solutions:
[Name]:
12. Chemical Fertilizer
13. Chemical Toilet Wastes
14. Cannery Waste
IS. Oil
IS. Grease
17. Non-toiic RoUrj Drilling
Mud
11. Acetfkme Sludge
11 Paint Sludge
20. Asphalt Sludge
21. Latet Waste
22. Tito Glan Waste
23. Lime Soda Water
2*1 SolMflt
25. Non-talc Mud and Water
26. Other Non-tak
Solution: [Name):
Quantii)
[Circle one]
pilous or barrels
n
o
Q
Q
D"
n
Q
Q
Q
n
Q
Hunt [priat or type):.
Pick up Address.
[Number]
[Street]
Type of process
which produced wastes: .
[Examples: metal platiiii, equipment i;iuain«, •.,,,.»*•, lerr.jjtion, ,.;<.]
I cirtilj that the described wtsti was delivered to tht licensed hiultr nimod Mm for legal disponl it the siti indicitid
Signature of Product! or Authorized Afent and nit
HAULER
Nimi [print or type)
Scrap Haulers of Riverdale
BIBJIWB Address.
13840 So. Halsted
Riverdale, Illinois 60627
[Number) [Street] [City]
I certify that the described waste was hauled by me in a vehicle with a «alid liquid waste hauler registration certificate
to the disposal facility named below and was accepted
Stale Waste Hauler's Registration No.:.
Local Business License Truck Tat No. [il applicable]:.
DISPOSAL FACILITY
Name [print or tjpe] ^_____^______
Site Address
Signature of Hauler or Authorized Atent and Title
I certify that the hauler abow delivend the described liquid waste to this disposal facility
Treatment or.
Recomrj Pncess
IF WASTE IS HELD FOR DISPOSAL ELSEWHERE,
SPECIFY FINAL LOCATION
,Pond_
.Spreading
Area
.Landfill.
Am
.Other.
Producer of Liquid Waste Copy
Signature of Waste Disposal facility Operator
Authoriad Af ent and Title
-------
NAME OF
CARRIER
STRAIGHT BILL OF LADING —SHORT FORM — ORIGINAL — Not Negotiable
RECEIVED, subject t» the classifications and tariffs In effect on the date of the Issue of this Bill of Lading,
1f» pfopaiff described below. In opparvnt good order, except 01 noted (contend and conditions of content* of package* (mfcnownt, marked, eorwlgned, and cfefTfrwd O» tntfleeTtcT fe*>
low, .which, wid carrier (the word carrier being understood throughout this contract as meaning any person or corporation tn powesston of the property vnder the contract) agree* to
Carry lo Its utual place of delivery ot taid destination, if on ItJ route, olherwise to deliver to another carrier on the route to (aid destination. It II mutually agreed, at to oach
Carrier of all or any of *aid property over all or any portion of laid route to dettinotion, and a* lo eaxh party at any time Interested In oil or any of (aid property, that «vsry MrVlce
to b« performed hereunder (hall be subject to all the term* and condition! of the Uniform Domestic Straight Bill of Lading tet forth (1] In Official, Southern, Western and Illlnoli
freight Qawificalion* in effect on the date hereof, if this Is a rail or a rail-water shipment, or (2) In !ne applicable motor carrier classification or tariff If thl* li a motor carrier
-'• mint.
Shipper I
r which *<>v
CARRIER'S NO.
SHIPPER'S NO.
)M
CONSIGNED TO
(Mall or street address of consignee—For purposes of DotiflcaUoD only.)
DESTINATION
STATE
COUNTY
DELIVERY
ADDRESS
(To be filled In only when shipper desires and governing tariffs provide for delivery thereat.)
DELIVERING
CARRIER
VEHICLE OR
CAR INITIAL & NO.
No..
Packages
— i
KIND OF PACKAGE, DESCRIPTION OF ARTICLES, SPECIAL MARKS. AND EXCEPTIONS
/
/ -/ j* -<7 j» "n 4 ^ f:
r//t ^A/u/ini i
' »
.sfs?s* "/"/^ f" j /3 /
s/'//i / r* /'ft*
\ . '
"Weight
(Sub. to Core.)
s*
^
Class
or Rate
Ck.
Col.
*If the shipment moves between two ports by a carrier by water, the law requires that the bill of lading shall state whether it is "carrier's or shipper's weight."
NOTE — Where the rate Is dependent on Talue, shippers are required to state specifically in writing the agreed or declared value of the property.
The agreed or declared Talue of the property is hereby specifically stated by the shipper to be not exceeding
per
Subject to Section 7 of Conditions of
applicable bill of lading, If this shipment
is to be delivered to the consignee without
recourse on the consignor, the consignor
shall sign the following statement:
The carrier shall not make delivery of
this shipment without payment of freight
and an other lawful charges.
(Signature of Consignor.)
If charges are to be prepaid, write or
stamp here, "To be Prepaid."
Bec-d J to
the property described hereon.
Agent or Cashier
Per
(The signature here acknowledges only the
amount prepaid.)
Charges
Advanced $
"Shipper's Imprint ID lieu of stamp; cot
a part of bill of lading approved by tbe
Interstate Commerce Commission."
The Fibre Boxes used for this shipment
conform to the specifications set forth In
the box maker's certificate theron, and an
other requirements of Bule 41 of the Con-
solidated Freight Classification.
CO. 1>.
-Shipper, Per_
fl
-Agent, Per_
Permanent Post Office Address of Shipper-
D-14
-------
Bp3 United Parcel Service
lH 637861
i
SHIPPER'S CERTIFICATION
FOR HAZARDOUS MATERIAI
PULL •HtPPINO NAM« OF ARTICL*
(ABBKBVIATIONS NOT pBitMiTTcol
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
SHIPPER'S NAMB AND ADDRESS
A n 1 ITTI F ING.
n. u. LM i t.t» « v*»
CAMBRIDGE, MASS.
LS
O.O.T. CLASSIFICATION
(ABBREVIATIONS NOT PERMITTED)
%
- \
CERTIFICATION: This is to certify that the above named articles are properly class
applicable regulations of the Department of Transportation, Title-4
ui208 Rev. 6-77 (40M BKs-6/77) Shipper '« Signotu
WT./VOL.
TVPB D.O.T. LABRL. REOUIREO
(ABBREVIATIONS NOT PERMITTED)
-
J^. 0-14-213
STAMP YOUR UPS SHIPPER NUMBER ABOVE
RECEIVER'S NAME CJTV & STATE
(ABBREVIATIONS ARE PERMITTED) •-
f
ified, described, packaged, marked and labeled, and are in proper condition for transportation, according to the
9, Part 171-177, Code of Federal Regulations, and Requirements of United Parcel Service:
n? Date / /
. ___ . _ —^ — , ., — _ — . — . — _ — _^ u . — . _ — _ — • • in ^^..^^^^^^^^^^^^^^^^^^.^
• LOADING
Dmora oni copy at
fam And InMrt In
toinlous Materials
pnrvldtd.
•TRANSIT
Driver must havt
Huirdout Materlili
in whicto
taMtt.
-------
3. Barge Carrier
D-16
-------
Trip No..
Drier No._
Barfe No. _
Gndc
Loading Dntt_
CHOTIN TRANSPORTATION, INC.
LOADING PAPER
Loidla|DMe:_
DwUniOon-From:.
To:.
BOW»
No. 1 Port
C.argn
No. 2 Port
OrB™
No. 3 Port
Cargo
No. 4 Port
Cftrvo
No. 5 Port
f*.*Ttm
No. 6 Port
f'.mrtfn
No. 1 Starboard
(Vrern
No. 2 Starboard
C.xrgr,
No. 3 Starboard
r«rj»i
No. 4 Starboard
f!«T[n
No. S Starboard
r.rjm
No. 6 Starboard
C*rr<
STERN
REMARKS:.
D-17
-------
4. Air terrier
D-10
-------
PLEASE COMPLETE ALL INFORMATION IN THE 5 BLOCKS OUTLINED IN ORANGE.
SEE REVERSE SIDE FOR COMPLETE PREPARATION INSTRUCTIONS.
MHXJOT NUMBER 021-005G-9
DATE
AIRBILL NO.I
I6QR9R82
FROM (Your Name)
TO (Consignee's Name)
I If Hold For Pick Up. Phone-No.
COMPANY
ARTHUR D. LITTLE^GS.
DEPARTMENT/FLOOR NO.
COMPANY
DEPARTMENT/FLOOR NO.
STREET ADDRESS
20 ACORN PARK
M
VO
CITY
CAMBRIDGE.
STATE
ZIP
CITY
STATE
ZIP
021
PURCHASE ORDER NO. OR
YOUR REFERENCE NO.
PURCHASE ORDER NO. OR
CONSIGNEE REFERENCE NO.
PAYMENT D Bill Shipper
OCashlnAdvance
NON-NEGOTIABLE AIRBILL SUBJECT TO
CONDITIONS OF CONTRACT SET FORTH ON
REVERSE OF SHIPPERS COPY
SERVICE
(Check One)
PRIORITY ONE (P-1)
D (Overnight Packages)
COURIER PAK
D Overnight Envelope
(Upto2lbs.)
D Overnight Box
(Up to Site.)
D Overnight Tube
(UptoSlbs.)
STANDARD AIR
D (Scheduled 2 Day
Delivery)
DELIVERY"
INSTRUCTIONS
(Check One)
Hold Fo.
Delv. Pick Up
AGT/PRO
AGT/PRO
RECEIVED D Shipper's Door
AT DFEC Station
SPECIAL HANDLING
(Check One If Desired)
Delv. Articles SSS Govt. Other
F.E.C. USE
FREIGHT CHARGES
VALUATION CHARGE
ADVANCE ORIGIN
ADVANCE
DESTINATION
OTHER
TOTAL CHARGES
FEC-S-0049 8/78
-------
FEDERAL EXPRESS
SHIPPER'S CERTIFICATION FOR HAZARDOUS MATERIALS
(excluding radioactive materials)
Two completed and signed copies of this certification shall be handed to carrier. (Use block letters.)
• - — __„__„„__„_„„„„„__„_„„„_ __—»__
WARNING: Failure to comply in all respects with the applicable regulations of the Department of Transportation,
49 CFR, Parts 100-199 and, for international shipments, the IATA Restricted Articles Regulations may be a breach
of the applicable law, subject to legal penalties. This certification shall in no circumstance be signed by an IATA
Cargo Agent or a consolidator for international shipments.
This shipment is within the limitations prescribed for: (mark one)
CD passenger & cargo aircraft D cargo-only aircraft
n
I No.
Of
Pkgs.
'
•^^B^^^^^—
Article
No.
(Int'l
only)
Proper Shipping Name of Materials as shown
in 49 CFR, part 172.101 and additional des-
cription requirements specified in 49 CFR
172.203, and (for int'l shipments) the IATA
Restricted Articles Regulations.
Class
Specified in
49 CFR 172.101
IATA
Packing
Note No.
Applied
(Infl
only)
Net
Quantity
per
Package
Flash Point j
(closed cup)
For Flammable
Liquids |
°C.
°F- i
1
Special Handling Information:
I hereby certify that the contents of this consignment are fully and accurately described above by Proper Ship-
ping Name and are classified, packed, marked, and labelled, and in proper condition for carriage by air according
to applicable national government regulations.
Name and full address of Shipper
Date
Name and titje -oLpetsen signing Certification
Emergency telephone no.
Signature of the Shipper (see WARNING above)
Federal Express Airbill No.
0147 REV JAN 78
41730147
Origin Station
Destination Station
DISTRIBUTION: White Copy - Attached to Airbill
.Canny Copy - Attached to Airbill
Pink Copy - Attached to Package
Goldenrod Copy - Shipper
D-20
-------
APPENDIX E
RAIL TRANSPORT OF HAZARDOUS WASTE
E-l
-------
TABLE E-l
SAMPLE MOVEMENTS OF SPENT SULFURIC ACID ON THE
SOUTHERN PACIFIC RAILROAD <1976)
ORIGIN
w
K)
AMOUNT
IN
CARLOADS
AMOUNT
IN
TONS /CAR TONS
REVENUE
$000
REVENUE
$/CWT;
American Oil
Salt Lake City, Utah
ARCO
Channelview, Texas
ARCO
Channelview, Texas
El Paso Acid
Ashley, Texas
Olin
Chaison, Texas
Stauffer Chemical 120
Martinez, California
Texas Farm Products 89
Nacadgoces, Texas
Dupont 224
Strang, Texas
Stauffer Chemical 15
Houston, Texas
Stauffer Chemical 498
Houston, Texas
75
46
51
85
66
9016 179.3
4100
11451
1269
31.4
29.3
19.4
32851 135.7
.99
.38
.13
.76
.21
MILES
787
135
26
823
65
-------
TABLE E-2
SAMPLE MOVEMENTS OF SCRAP "BATTERY PARTS ON THE
SOUTHERN PACIFIC RAILROAD (1976)
i
OJ
ORIGIN
National Metals
Tucson, Arizona
National Metals
Tucson, Arizona
Arizona Recycling
Phoenix, Arizona
DESTINATION
National Fibers
Dallas, Texas
Houston Lead
Houston, Texas
Tuboscope
Houston, Texas
AMOUNT AMOUNT
IN IN REVENUE
CARLOADS TONS/CAR TONS $000
50
50
50
ioo
50
50
2.92
1.57
.96
REVENUE
$/CWT. MILES
1.46
1.57
.96
1400
1136
1215
-------
TABLE E-3
SAMPLE MOVEMENTS OF SPENT SULFURIC ACID ON THE
MISSOURI PACIFIC RAILROAD (1976)
ORIGIN
Baytown, Taxas
Channelview, Texas
Channelview, Texas
Freeport, Texas
DESTINATION
Channelview, Texas
Bay town, Texas
Strangi Texas
Houston, Texas
NO.
OF CARS
121
100
132
113
NO.
TONS/CAR OF TONS X-336 RATE MILES
t
91 10,964 .23 cwt.-R.35 15.6
86 8,617 .23 cwt.-R.35 15.6
85 11,156 .31 cwt.-R.35 38.6
77 8,661 .37 cwt.-R.35 66.6
-------
TABLE E-3
RATES FOR MOVEMENT OF HAZARDOUS WASTES BY RAIL
TOTAL $/CWT
w
In
RR
Spent Sulfuric Acid
SP
MoPac
Scrap Battery Parts
SP
CARLOADS
120
89
224
15
498
121
100
132
113
2
1
1
TONS/CAR
75
46
51
85
66
91
86
85
77
50
50
50
$/CWT
0.99
.38
.13
.76
.21
.23
.23
.31
.37
1.46
1.57
.96
MILES
787
135
26
823
65
16
16
39
67
1400
1136
1215
CAR LEASE
COST (a)
0.08
.02
.004
.08
.01
.001
.001
.003
.007
_~
-
...
LEASED
CAR (a)
1.07
.40
.13
.84
.22
.23
.23
.31
.38
—
-
—
OWNED
CAR(b)
0.92
.36
.13
.70
.20
.23
.23
.31
.36
— s
-
«-P
NOTE: Average carload =69.5 tons
(a) At 16C per loaded car mile, net of mileage payment
(b) At 13
-------
APPENDIX F
FLOW OF FUNDS MODEL
F-l
-------
1. Flow of Funds Model
ADL has developed a model of the financial operations of a company or
investment project incorporating:
• Taxation
• Depreciation
• Short-and long-term financing
• Flow of funds.
The model can be used, for example, for forecasting the performance of
a company over a planning horizon, for pricing decisions, or for deter-
mining the profitability of an investment. The essence of the model is
the cash flow equations, which are summarized in this Appendix.
The basic equation underlying the analysis of capital requirements is the
cashflow model:
GCF = P~Q - COi" - TAX + ITC - INV - INT (1)
U L. £ t I™ t w t
NCFfc = GCF + D - DA (2)
where
*
GCF = Gross cashflow in period t
NCF = Net cashflow (cashflow to equity in period t)
INT = Interest paid in period t
P = Product price in period t
Q = Product sales volume in physical units in period t
COE = Cash operating expense in period t (exclusive of interest
and taxes)
D = Total new debt raised in period t
F-2
-------
DA = Debt repaid in period t
TAXt = Federal income tax payable in period t
ITCt = Investment tax credit'in period t
INVj. = Investments in period t
The gross cashflow is defined as the total amount of cash arising from
operations (if positive) or the total amount of cash required for opera-
tions (if negative) excluding debt repayment or debt raised. Note that
for a single project, the gross cashflow stream (when working capital
is included with investment) reflects the profitability of the project.
When debt raised and payed is added to .the gross cashflow, the net cash-
flow is derived. The net cashflow is the total cash arising out of or
required for operations. The net cashflow can also be-defined as the
difference between sources and uses. Due to the balancing of sources and
uses, the excess goes into dividends working capital and marketable
securities. If negative, it is balanced by new equity. Formally,
NCFfc = DIVt + AWCt + AMSt - Efc (3)
where
AWC = Net increase in working capital in period t - WCt - WC^
WC = Working capital in period t
AMS = Increase in marketable securities in period t - MSt - MSt_1
MS = Marketable securities in period t
E = New equity raised in period t
F-3
-------
There are two distinct types of analyses performed with the model:
• Project Analysis
• Company Analysis
A project analysis is primarily used to evaluate a new investment or an
existing operation based upon the cash flow generated by that investment/
operation alone, without regard to the capital structure of the corpora-
tion of parent company. A company analysis is used to examine performance
(historic or forecast).
The project analysis treats working capital as part of investment (i.e.,
AWCfc is added to INV and otherwise ignored, and hence change in working
capital appears in gross cashflow. In addition, short-term borrowing to
cover cash shortages is not allowed, and liquid assets, dividends, etc.,
are not involved in the analysis. For a company analysis, short-term
needs (e.g., minimum working capital) are satisfied first from marketable
securities and income, and then if necessary from short-term borrowed.
Formally:
SD. = Max (0, - MS,, + AWC. - GCF. + DA - LD - E )
L t"""J. t tttt
where
SD = Short-term debt raised in period t
LD = Long-term debt raised in period t
The external financing requirement is the difference between the required
outlays of funds and the funds available from operations or from the
liquidation of uncommitted cash assets. The distribution of capital be-
tween equity and long-term debt is controlled with parameters input into
the model. The remainder of external financing comes from short-term
F-4
-------
analyses. For project analyses, external financing is usually all "equity,"
i.e., the amount of financing required from the corporate entity or parent
to support the project. Debt can be used if one wishes to generate interest
expense automatically.
Dividends are expressed as a percentage of profits except that they are
limited by available funds before short-term borrowing. Thus,
DIVt = Min (at NIt> Et + LD - DAfc + GCFt - AWC + MS ^
where
a = Pre-specified dividend percentage for period t
NI = Net income in period t
= PtQt ~ COEt - DEP - TAXfc + ITCt
DEP = Depreciation in period t
Federal income tax is
TAX = T(P Q - COE - DEP - INT - TXCF )
t t t t • L. L t
where
T = Federal income tax rate
TXCF = Tax loss carryforward utilized in period t
and the investment tax credit ITC is limited by TAX .
The working capital equation is
WCt = OCBt + INVENTt + RECt - PAYfc
where
OCB = Operating cash balance held in period t
INVENT = Inventories held in period t
REC = Accounts receivable held in period t
PAY = Accounts payable accrued through period t.
F-5
-------
OCB and PAY are assumed to be proportional to operating loss while
INVENT and REG are assumed to be proportional to sales.
2. Pricing Applications
The project application of the model allows revenue or price to be set to
attain a specified internal rate of return. In the hazardous waste industry
analyses, a ten percent after tax internal rate of return was targeted
on new investments and the marginal revenues (change in price) necessary
to obtain the rate of return was then determined.
3. Parameters and Assumptions
(1) Working Capital Factors
The parameters used to determine working capital factors were based on
the report "Potential for Capacity Creation in the Hazardous Waste Manage-
ment Industry." These factors were
• Operating cash balance = 13 days cash operating costs (excluding
interest and taxes),
• Receivables = 16 days sales, and
• Inventories = 16 days sales.
• Accounts payable = 18 days cash operating cost.
(2) Debt Assumptions
Short-term interest was assumed to be 12% and long-term interest was
assumed to be 10%. The debt repayment schedule was at an equal level
with a 10-year period. The percentage borrowed was assumed to be 60%,
which is consistent with the long-term debt to equity ratio indicated in
the above referenced report.
F-6
-------
(3) Depreciation
The new investment was depreciated over facility life (ten years). Both
straight-line and double-declining balance depreciation options are
available. However, the straight-line method was used in this analysis.
F-7
-------
APPENDIX G
REFERENCES
G-l
-------
APPENDIX G
REFERENCES
1. Potential for Capacity Creation in the Hazardous Waste Management
Service Industry, Foster D. Snell, Inc. Environmental Protection
Publication SW-127c. U.S. Environmental Protection Agency, August
1976. NTIS No. PB-257 187.
2. Development of Standards Applicable to Transporters of Hazardous
Waste, Draft background document, Hazardous Waste Management Division,
Office of Solid Waste, U.S. Environmental Protection Agency, January
1978.
2a. National Transportation Trends and Choices to the Year 2000. U.S.
Department of Transportation, U.S. Government Printing Office,
Washington, D.C., January 12, 1977.
3. Assessment of Industrial Hazardous Waste Practices, Electroplating
and Metal Finishing Industries—Job Shops, J. B. Hallowel, et al.
[Battelle Columbus Laboratories]. Environmental Protection Publica-
tion SW-136c. U.S. Environmental Protection Agency, 1977. NTIS
No. PB-264 349.
4. Assessment of Industrial Hazardous Waste Practices. Paint and Allied
Products Industry Contract Solvent Reclaiming Operations, and Factory
Application of Coatings, [WAPORA, Inc.], Environmental Protection
Publication SW-119c., U.S. Environmental Protection Agency, 1976,
NTIS No. PB-251 669.
5. Assessment of Industrial Hazardous Waste Practices, Special Machinery
Manufacturing Industries, J. Leven, et al. [WAPORA, Inc.], Envir-
onmental Protection Publication SW-141c., U.S. Environmental Protec-
tion Agency, 1977, NTIS No. PB-265 981.
6» Assessment of Hazardous Waste Practices in the Petroleum Refining
Industry. D. G. Rosenberg, et al. [Jacobs Engineering Company],
Environmental Protection Publication SW-129c., U.S. Environmental
Protection Agency, June 1976, NTIS No. PB-259 097.
7. Assesment of Industrial Hazardous Waste Practices. Organic Chemicals,
Pesticides, and Explosives Industries. G. E. Gruber, [TRW Systems
Group], Environmental Protection Publication SW-118c., U.S. Environ-
mental Protection Agency, April 1975, NTIS No. PB-251 307.
G-2
-------
8. Assessment of Industrial Hazardous Waste Practices. Storage and
Primary Batteries Industries. [Versar, Incorporated], Environmental
Protection Publication SW-102c, U. S. Environmental Protection
Agency, 1974, NTIS No. PB-241 204.
9- Assessment of Industrial Hazardous Waste Practices. Metal Smelting and
Refining Industry. [Calspan Corporation], U.S. Environmental Pro-
tection Agency, in preparation, to be distributed by the National
Technical Information Service.
10. Assessment of Industrial Hazardous Waste Practices. Textiles Industry.
E.F. Abrams, D. K. Guinan, and D. Derkics, [Versar, Incorporated],
Environmental Protection Publication SW-125c, U.S. Environmental
Protection Agency, June 1976, NTIS No. PB-258 953.
11. Assessment of Industrial Hazardous Waste Practices. Rubber and Plastics
Industry. [Foster D. Snell, Inc.], U.S. Environmental Protection
Agency, in preparation, to be distributed by the National Technical
Information Service.
12. Assessment of Industrial Hazardous Waste Practices, Inorganic Chemicals
Industry. R. G. Shaver, et al., [Versar, Incorporated], Environmental
Protection Publication SW-104c, U.S. Environmental Protection Agency,
March 1975, NTIS No. PB-244 832.
13. Assessment of Industrial Hazardous Waste Practices. Leather Tanning
and Finishing Industry, T. E. Conrad, G. L. Mitchell, and D. H. Bauer,
[SCS Engineers, Inc.], Environmental Protection Publication SW-131c,
U.S. Environmental Protection Agency, November 1976, NTIS No. PB-261 018.
14. Pharmaceutical Industry. Hazardous Waste Generation, Treatment and
Disposal. [Arthur D. Little, Inc.], Environmental Protection Publica-
tion SW-508. U.S. Environmental Protection Agency, 1976.
15. Assessment of Industrial Hazardous Waste Management Practices. Petro-
leum Refining Industry, U.S. Environmental Protection Agency, in
preparation, to be distributed by the National Technical Information
Service.
16. Assessment of Industrial Hazardous Waste Practices — Electronic
Components Manufacturing Industry, G. 0. Peters, J. Levin, and P.
Thomas, [WAPORA, Inc.], Environmental Protection Publication SW-14Qc,
U.S. Environmental Protection Agency, April 1977, NTIS No. PB-265 532.
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PERSONAL COMMUNICATION SOURCES
17. Boston Steel and Manufacturing Company, Maiden, Massachusetts
•i
18. By-Products Management, Inc., Schererville, Indiana
19. International Harvester, Medford, Massachusetts
20. Keefe Trucking Company, Portsmouth, New Hampshire
& •
21. Matlack, Inc., Lansdowne, Pennsylvania
22. National Tank Truck Carriers, Inc.
American Trucking Associations, Inc., Washington, B.C.
23. Pollution Control, El Dorado, Arkansas
i f •• '• ' •
24. Research Information Office
Office of Hazardous Material Operations
Department of Transportation
Washington, D.C.
25. Tech-Weld Corporation, Burlington, Massachusetts
'* '' '• F.,.
26. Truck Trailer Manufacturer's Association, Arlington, Virginia
27. Barge Company
" ' ' '„ ' j i
28. Tank Car Division, GATX, Chicago, Illinois
29. Southern Pacific Railroad
30. Missouri Pacific Railroad
31. Chesapeake-Baltimore and Ohio Railroad
32. Foster D. Snell, Inc.
Division of Booz, Allen and Hamilton, Inc.
Florham Park, New Jersey
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PUBLICATIONS
33. Annual Statement Studies. Robert Morris Associates, 1976 Edition.
34. 1975 Annual Survey of Manufacturers. U.S. Department of Commerce,
Bureau of the Census.
35. 1972 Census of Manufacturers. U.S. Department of Commerce, Bureau
of the Census, August 1976.
36. Current Business Reports, Monthly Wholesale Track, August, 1977,
U.S. Department of Commerce, Bureau; of the Census BW77-28, October
1977.
37. Faith, Keys & Check's Industrial Chemicals. F.A. Lowenheim and M.K.
Moran, Fourth Edition, John Wiley & Sons, New York, 1975
38. Motor Carrier Industry Financing^ Regular Common Carrier Conference,
Washington, D.C., 1968.
39. Cost of Complying with Hazardous Waste Management Regulations, Draft
Report to the U.S. Environmental Protection Agency, Contract No.
68-01-4360, Arthur D. Little, Inc., October 1977. '
40. Tchobanoglous, G., Theisen, H., and Eliassen, R., Solid Wastes
Engineering Principles and Management Issues, McGraw-Hill Book
Company, New York, 1977,
41. U.S. Environmental Protection Agency, Decision Makers Guide in Solid
Waste Management, SW-500, Washington, D.C., 1976.
G-5
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APPENDIX H
GLOSSARY OF TERMS
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APPENDIX H
GLOSSARY OF TERMS
BILL OF LADING — An itemized list of goods contained in a shipment.
COMMODITY — Any article of commerce. Goods shipped.
COMMODITY, EXEMPT — Goods that may be transported in interstate commerce
without operating authority or published rates.
COMMON CARRIER — A transportation business that offers service to the
general public. Interstate common carriers must hold a franchise issued
by the Interstate Commerce Commission which limits service to a specific
geographical area.
COMPETITIVE RATE — A charge established to meet the competition of an-
other transportation line.
CONTRACT CARRIER — A company that engages in for-hire transportation of
property under individual contract or agreement with one or a limited num-
ber of shippers.
DUMP BODY — Truck body of any type which can be tilted to discharge its
load.
EXEMPT CARRIER — Trucks hauling certain commodities are exempt from
Interstate Commerce Commission economic regulation. The largest portion
of the exempt carriers transport agricultural commodities or seafood.
FLATBED — Truck or trailer without sides and top.
FORK LIFT — A machine used to move goods loaded on pallets or skids.
FREIGHT BILL — Document for a common carrier shipment. Gives descrip-
tion of the freight, its weight, amount of charges, taxes and whether
collet or prepaid. Charges paid in advance are called prepaid freight
bills. Charges collected at destination are called destination or collect
freight bills.
FREIGHT FORWARDER — A company that assembles small shipments, from
various shippers, into larger shipments to form a full truck or car load.
Forwarders send the consolidated freight to a station where it is dis-
assembled and routed to the proper destinations.
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GYPSY — An independent truck operator who drives his own truck and
secures freight wherever he can, or one who trip-leases to authorized
carriers.
HOPPER BODY — Truck body capable of discharging its load through a bot-
tom opening without tilting.
INSULATED BODY — Truck or trailer designed for transportation of com-
modities at controlled temperatures. It may be equipped for refrigeration
or heating.
INTERSTATE COMMERCE ACT — An act of Congress regulating the practices,
rates, and rules of transportation lines engaged in handling interstate
traffic.
INTERSTATE COMMERCE COMMISSION (ICC) — The federal body charged with
enforcing Acts of Congress affecting interstate commerce.
INTRASTATE TRAFFIC — Traffic having origin, destination, and entire
transportation within the same state.
POINT OF ORIGIN — The terminal at which freight is received from the
shipper.
PRIVATE CARRIER — A company which maintains its own trucks to transport
its own freight.
PROOF OF DELIVERY — Delivery receipt copy of freight bill signed by
receiver at time of delivery.
RATE — The charge for transporting freight.
REGULAR COMMON CARRIER — Any company authorized to serve the public arid
to transport general commodities over set routes.
RESTRICTED ARTICLES — Commodities that can be handled only under certain
specific conditions.
SHIPPING ORDER — Instructions to carrier for transportation of a ship-
ment, usually a copy of the bill of lading.
STAKE BODY — Truck or trailer platform body with readily removable
stakes, which may be joined by chains, slats, or panels.
STRAIGHT TRUCK — A truck with the body and engine mounted on the same
chassis (as contrasted to a combination unit such as a tractor semitrailer),
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TANK TRUCK CARRIER — Any for-hire carrier that serves the general public
and is authorized to carry petroleum, chemical liquid, or dry commodities
in bulk, by means of specialized tank truck units.
TANK TRAILER — Enclosed truck trailer designed solely for the trans-
portation of fluid commodities in bulk.
TANKER — Truck, semitrailer, or trailer with a tank body for hauling
liquids.
TRANSPORT — To move freight from one place to another.
WAYBILL — Description of goods sent with a common carrier freight ship-
ment.
yo!765
SW-170C
* u.i. mamm mam tmt, m -M1-U7/J7
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