GENERAL SECTION

EPA Issues New Wastewater Discharge Standards for the Transportation Equipment Cleaning Category

On August 15, 2000 the U.S. EPA issued a final rule establishing effluent limitations for industries that clean the interiors of transportation equipment used for carrying chemical, petroleum or food grade cargos. The rule regulates discharges of wash water from the cleaning of tanks including truck, rail, barge and intermodal tank containers.

OVERVIEW
The new rule, 40 CFR Part 442, establishes discharge limitations for direct discharges to surface water and discharges to POTW’s for transportation equipment cleaning facilities. Transportation equipment cleaning facilities generate wastewater from the cleaning of the interior of tanks that come into direct contact with chemical, petroleum or food grade cargos. Wastewater from exterior tank cleaning, floor and equipment washing are also regulated under the effluent limitations for facilities covered under this rule. Facilities that clean only the exterior of tanks are not subject to this rule.

The EPA subcategorized transportation equipment cleaning facilities into four subparts:

• Subpart A: Tank Trucks and Intermodal Tank Containers with Chemical or Petroleum Cargos,
• Subpart B: Rail Tank Cars with Chemical and Petroleum Cargos,
  
• Subpart C: Tank Barges and Ocean Tankers with Chemical or Petroleum Cargos, and
• Subpart D: Tanks Transporting Food Grade Cargos.
  

Technology based effluent limitations, new sources performance standards and pretreatment standards were established for Subparts A through C. Subpart D had only technology based effluent limitations and new sources performance standards established.

Facilities that discharge less than 100,000 gallons per year of cleaning wastewater are excluded from the Transportation Equipment Cleaning rule but may be subject on a case-by-case basis. In addition, facilities that clean tanks that have only contained raw materials, by-products, and finished products associated with the facilities on-site operation are also excluded from the rule. No effluent standards were developed for truck, rail or barge hopper subcategories since hoppers are used to transport dry goods and the wastewater generated from cleaning hoppers was found to contain few pollutants at treatable concentrations.

CONCLUSION
The U.S. EPA has promulgated a new rule placing effluent limitations on discharges of wastewater from transportation equipment cleaning facilities. The rule becomes effective September 13, 2000. Industries potentially subject to the rule are required to notify the appropriate regulatory authority and make an application to continue wastewater discharges. Potentially affected industries should contact the local sewer authority and the state EPA Wastewater Division to determine the applicability of the rule to their specific operations and obtain necessary permit applications. This should be done no later than 60 days after the effective date of the rule although state or local requirements may be more stringent. If you would like more information on the new rule, or you would like help in determining its applicability to your facility, please contact Kara Pettinger or Tony Domanico at
(513) 489-2255 or toll free at (800) 229-1443 or by e-mail at kmp@paynefirm.com or aid@paynefirm.com.