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Transportation Equipment Cleaning - Proposed Rule


U.S. EPA recently proposed effluent guidelines (wastewater rules) for the Transportation Equipment Cleaning Category (40 CFR 442).  The proposed rule includes some P2.

The proposed rule appeared in the Federal Register on June 25, 1998 (pp. 34685-34746).
An electronic version is available from  http://www.epa.gov/ost/rules/ or http://www.epa.gov/fedrgstr/.

A very brief summary of the proposed rule:

Who and What's Covered?

Transportation Equipment Cleaning (TEC) facilities are defined as those facilities that generate wastewater from cleaning the interior of tank trucks, closed-top hopper trucks,
rail tank cars, closed-top hopper rail cars, intermodal tank containers, inland tank barges, ocean/sea tankers, and other similar tanks...The rule also covers wastewater generated from washing vehicle exteriors, equipment and floor washings, and TEC contaminated wastewater at those facilities...

EPA is proposing subcategorizing TEC into 11 subcategories based on cargo carried and
transportation mode (ie. Truck/Petroleum, Rail/Food etc...).

U.S. EPA estimates approximately 2,405 TEC facilities in the U.S.
The largest number of facilities in Illinois and Region V (Illinois, Indiana, Michigan, Ohio,
Minnesota, and Wisconsin).

What P2 is discussed in the Proposed Rule? 

P2 applicable to TEC includes things such as:  use of dedicated tanks, heel reduction and recycle, reduction in the amount and toxicity of cleaning solutions including substitution,
high-pressure low volume cleaning equipment, mechanical and dry cleaning methods,
cascade tank cleaning, wastewater recycle and reuse.

U.S. EPA incorporated the use of two common P2 practices into the technology options for all categories:  heel removal and management, and water conservation practices.
TEC facilities are not required to use the technology option for their category.  TEC facilities are free to use any combination of wastewater treatment and P2 strategies to meet numeric limits.

Section VI (pp. 34697-) and Section VIII (pp. 34703-) of the proposed rule discusses P2 in more detail.

What are the Pollutants and Limits?

Pollutants and limitations vary according to the subcategories.  Generally, pollutants that could be covered include oil&grease, TSS, BOD, TPH, some metals (Zn,Cr,Cd,Cu, Pb) and various semi-volatile and volatile organics.  

Pollutant limits are expressed in grams/tank (mass-based).   This will help encourage water conservation/flow reduction by TEC facilities.  U.S. EPA is looking for comments on this approach.  Based on comments received, U.S. EPA may convert to concentration-based limits in the final rule.  See page 34715 for more discussion.

Pages 34741-34746 contain the limits for the subcategories.

When are Comments Due?

Comments are due to U.S. EPA by September 23, 1998.
Pages 34734-34735 outlines some specific comments being solicited.
Comments can be sent electronically to: Tinger.John@epamail.epa.gov

What is the Rule Final?

The TEC proposed rule was originally scheduled for 1/98 with the Final Rule scheduled
for 2/2000.

Jeff Lewis
Ohio EPA/Office of Pollution Prevention
P.O. Box 1049
Columbus, OH 43216-1049
Phone (614) 644-2812
FAX (614) 485-1617