WASH racks are facing new environmental rules and tougher future emission controls.
“The record-keeping requirements are daunting,” said Andrew Woods of Bulk Transportation at the National Tank Truck Carriers Tank Cleaning and Environmental Council Seminar April 2-3 in New Orleans, Louisiana.
Woods, Travis O'Banion of National Tank Services, Ed Matlage of Miller Transporters Inc, Pete Nativo of Transport Service Co, Bruce Bishkin of ASPI Inc, and Bill McNutt of the WCM Group Inc discussed environmental regulations and what lies ahead for wash racks.
Woods, whose company is based in California, said requests for new discharge permits in that state are expensive and require extensive information from applicants. If discharge increases by as much as 25%, a new permit application is required.
“It's almost impossible to open a new wash rack in California,” Woods said of the difficulties and expense of meeting the requirements.
O'Banion pointed out that another problem lies in the many different environmental rules that are applied in various states.
The speakers predicted that the total maximum daily load (TMDL) of wastewater that is now allowed is likely to be reduced, and other environmental requirements are likely to be toughened. Woods said that in California, local entities are making TMDL decisions. There also are moves to require wastewater to be recycled because of California's water shortages. Other states, such as Arizona and Nevada, are considering similar recycling programs. If approved, it will mean new on-site requirements and increased expense for tank cleaning facilities.
Other disposal problems occur with products such as batteries, thermostats, and florescent lights that are used in tank cleaning facilities. Matlage pointed out that many products, especially those containing lead or mercury, now require specific waste disposal procedures.
Bishkin and Nativo discussed recovering sugar from wastewater by distillation. Without recovering the sugar from wastewater, the effluent may not meet biological oxygen demand (BOD) requirements mandated by the Environmental Protection Agency, which can result in hefty fines. Recovering the sugar and selling it for animal feed or other purposes can bring wastewater into compliance and provide a revenue generator, Nativo said.
Wastewater from the tank wash is fed into a distillation machine where a compressor is used to boost the pressure of steam from an evaporator so that it will condense at a higher temperature. Sugar solids can be captured and the distilled water reused, if sanitary requirements are not necessary. Recovered solid (rated about 60 brix or 60% sugar content) can be sold for animal feed and other uses.
The system can be used with some other products, but will not handle inks, paints, resins, or dry products such as cocoa powder, flour, and starches.
Also on the front line for tank cleaning facilities are EPA regulations that apply to the handling of hazardous air pollutants (HAPs). McNutt noted that Regulation 40 CFR 63 Subpart EEEE applies to organic liquid distribution (OLD) operations located at, or part of, a major source of HAPs. The rule applies directly to OLD facilities and indirectly to owners/operators of cargo tanks or cargo tank cleaning facilities.
Cargo tanks must meet the Department of Transportation pressure test requirements of 49 CFR 180, and those that delivered organic liquids to an OLD storage tank must be cleaned at a facility that utilizes a closed vent system and/or a control device (CVSCD). The CVSCD is usually a flare or carbon adsorption system with a minimum of 95% reduction, McNutt said.
To further explain the regulations, McNutt said that a continuous emission monitoring system must be installed on the carbon adsorption system, or the carbon vessels must be replaced at a frequency determined during the design evaluation or performance test.
In addition, cleaning facilities must submit written certification to the owner of the OLD storage tank and to the EPA administrator stating that the cleaning facility will meet the CVSCD emission control requirements.
Compliance with the requirement became effective February 5, 2007, and HAPs that tank wash managers will need to know about are listed in Table 1 to Subpart EEEE. Organic liquids include any non-crude oil liquid or liquid mixture that contains 5% by weight or greater of the organic HAP listed in Table 1 of the subpart. However, organic liquids (in Subpart EEEE) do not include gasoline, kerosene, diesel, asphalt, and heavier distillate oils and fuel oils.