Wash rack operators were reminded that they are required to submit a baseline monitoring report on their effluent discharge to the local publicly owned wastewater treatment agency (POTW), and it was due by March 12, 2001. The report is part of the new Transportation Equipment Cleaning-Effluent Limitation Guideline issued last year by the Environmental Protection Agency (EPA).
Jack E Waggener, an environmental consultant with Dames & Moore, delivered the reminder as part of an update on the Effluent Limitations Guideline final rule. He spoke April 10 during the National Tank Truck Carriers Tank Cleaning Council seminar in San Antonio, Texas.
“We realize that some POTWs are accepting a pollution management plan (PMP) in lieu of the baseline report,” he said. “However, the baseline report is a federal requirement, so go ahead and do it. It’s proactive for your operation, and it’s easy to assemble.”
Another important date to keep in mind is September 13, 2003. This is the deadline for full compliance with the regulation. Most tank wash racks fall under the rule as indirect dischargers, because they release their treated wastewater to a municipal sewage plant. Data gathered by Waggener and NTTC suggest that just a handful of wash operations are classified as direct dischargers.
Waggener said he believes the pollution management plan will be the best compliance option for most tank cleaning facilities. A few companies with opt for numerical limits, and some will use both systems.
“Most POTWs will work with you on all of this,” he said. “Wash racks are not required by the regulation to provide both a PMP and numerical limits program, but they may want to do so if that will keep a POTW happy. It’s all negotiable.”
Documentation and record keeping are key elements in the PMP approach. Wash rack operators will need to monitor the volume, content, and characteristics of cleaning chemicals. They need to develop procedures for heel management, prerinse/presteam, and cleaning agents. They must document operator training and develop a waste minimization plan.
NTTC plans to provide its member wash racks with packet of compliance materials to make it easier to put together a plan. It will include a sample PMP, general verbiage that can be incorporated into a facility’s plan, specific limits guidelines, and the much-delayed EPA guidance publication.
The guidance document can be used by both wash racks and POTWs to interpret the regulation. It was supposed to be published before the baseline report was due but was so flawed that it was sent back for rewrite, according to Waggener. Changes are still being made.
In addition to the compliance packet, NTTC is updating its Cleaning Facility Audit Form to include details relevant to the Transportation Equipment Cleaning-Effluent Limitation Guideline.