ENVIRONMENTAL regulations have a big impact on tank wash racks. Failure to keep up with the latest regulatory developments can create serious problems and lead to major penalties.
John McKee with Outsource Environmental Management Inc reviewed environmental issues having a direct impact on tank cleaning rack operations during the National Tank Truck Carriers Tank Cleaning Council Seminar March 24 and 25 in Lake Buena Vista, Florida.
McKee briefly touched on the Environmental Protection Agency's (EPA's) Transportation Equipment Cleaning (TEC) Effluent Limits. He pointed out that many publicly owned treatment works (POTWs) have not yet adopted the TEC program.
McKee added that wash racks opting for numerical effluent limitations under the TEC program can't exceed the following pollutant levels: (TPH) (SGT-HEM) of 26 parts per million, copper at 0.84 ppm, and mercury at 0.0031 ppm.
Moving on to rules covering air pollution, the federal government's Title V program applies to any operation that emits (or has the potential to emit) at least 100 tons of air pollutants annually, 10 tons per year of any single hazardous air pollutant (HAP), or 25 tons annually of any HAP combination.
Many states have their own clean air regulations that pose challenges for wash rack operators. For example, Ohio regulates companies that emit 10 pounds per day of a criteria pollutant (nitrogen oxide, sulfur dioxide, particulate matter, among others) or a ton of HAPs annually. Texas has some of the most stringent requirements: emission models are required for all products cleaned, and a risk-based limit is imposed.
Storage tanks
Many wash racks, especially those operated by tank fleets, have aboveground storage tanks for fuel and other materials. Storage tanks that hold more than 1,320 gallons are covered under the Spill Prevention, Control, and Countermeasures (SPCC) program that takes effect in July 2004.
An SPCC plan is required for each facility at which aboveground storage tanks are used for petroleum compounds. A quirk of the rule is that the EPA Regional Administrator can require an SPCC plan for exempt facilities. Exempt storage includes underground tanks, 55-gallon drums, and wastewater treatment systems.
The new program calls for a five-year review schedule (instead of every three years under previous rules) using business records to satisfy record keeping requirements. A Professional Engineer or his agent must sign each SPCC plan.
Other requirements in the new SPCC program include brittle fracture evaluation of aboveground storage tanks, facility response plans with a more relaxed format, reductions in EPA discharge information, and annual oil handling training for employees. The plans must be written in plain English.
In addition to a good understanding of the federal and state regulations, wash rack managers need to know all of the waste streams produced by the facility. This will include wastewater, sludge (from wastewater treatment and sumps), heels, pre-rinse water, and other materials such as used oil collected in maintenance operations.
Waste streams must be analyzed to determine whether they are hazardous or non-hazardous. Waste quantities are a factor. A cleaning facility that produces more than 264 gallon per month of hazardous waste is classified as a large quantity generator. “Life is better for a small quantity generator,” McKee said.