Months after it was expected, the Environmental Protection Agency (EPA) announced proposed effluent guidelines for the tank cleaning industry. The EPA estimates that implementation of the rules will cost the industry as a whole approximately $58 million.
The proposed rule was published in the June 25 Federal Register. The EPA set a deadline of September 23 for comments, but the National Tank Truck Carriers Inc already has announced that it plans to file a request for an extension. Comments should be sent to John Tinger, EPA, (4303), 401 M St SW, Washington DC 20460.
According to the proposal, EPA plans to establish pretreatment rules for existing and new chemical and foodgrade cleaning racks that discharge wastewater into lakes, rivers, or streams or to publicly owned treatment works (POTWs). Wash racks that send wastewater to industrial treatment facilities are exempt from the proposed rule. The agency also excluded cleaning facilities that are dedicated to petroleum products, dry bulkers, and intermediate bulk containers (IBCs).
EPA officials say in the rule that IBC, dry bulk, and petroleum cleaning were excluded because pollutant levels are low in the wastewater outflow from those operations. For instance, petroleum cargo tank cleaning facilities reportedly generate 900 to 175,000 gallons of wastewater annually.
Recognizing that many wash racks clean a variety of products and equipment, EPA states in the proposed rule that a wash rack will be defined as chemical or foodgrade if those types of cargoes account for 10% or more of the cleaning activity. Foodgrade products listed in the proposed rule are liquids and include corn syrup, sugar, juice, soybean oil, beverages, and animal and vegetable oils. Chemicals essentially are defined as anything that the EPA hasn't already classified as food, petroleum, or dry bulk material.
Technology Flexibility Wash racks that are covered by the proposed rule will be able to use "Best Practicable Technology" for treatment of wastewater that is directly (released into any lake, river, or stream) or indirectly (to a POTW) discharged. EPA officials say that wash racks can use whatever technology will enable the facilities to meet effluent limits.
"This is an important concession by the agency," says Cliff Harvison, NTTC president. "Many wash rack operators will be required to upgrade their facilities, but the industry will not be required to invent new technology or invest in pie-in-the-sky technologies to meet the requirements."
For chemical wash racks, the following system elements have been determined by EPA to meet "Best Practicable Technology" for both direct and indirect dischargers: flow reduction, equalization, oil/water separation, chemical oxidation, neutralization, coagulation, clarification, biological treatment, activated carbon absorption, and sludge dewatering.
EPA officials estimate that implementation of these technologies will cost about 43 cents per pound of pollutants removed. Agency officials say they believe the cost is low enough that no wash racks will be forced out of business.
Foodgrade wash racks that discharge effluent directly will need many of the same technology elements. However, chemical oxidation is replaced by biological treatment and carbon absorption is not called for. Foodgrade indirect dischargers are not addressed, and EPA says in the proposed rule that no regulations are intended for these facilities.
The proposed requirements should have no cost impact for foodgrade cleaning, according to EPA officials. The required equipment is already in place at the facilities studied by the EPA.
Contained in the proposed rule are pollutant discharge limits that must be met through wastewater treatment processes. EPA is proposing chemical cleaning limits for biological oxygen demand (BOD), total suspended solids (TSS), oil and grease, chromium, zinc, chemical oxygen demand, bis (2-ethylhexyl) pthalate, di-N-octyl phthalate, N-dodecane, N-hexadecane, styrene, and 1,2-dichlorobenzene. On the foodgrade side, EPA is setting limits on BOD, TSS, and oil and grease.
EPA is under a court-ordered deadline to have the proposed regulations in final form and implemented by 2000. At press time, a public hearing was scheduled for August 18 at the EPA headquarters in Washington DC.