NTTC Provides Comment Letter to EPA on Transportation Equipment Cleaning Facilities
On November 16, 2023, the National Tank Truck Carriers (NTTC) sent a letter to the U.S. Environmental Protection Agency (EPA) opposing the Advanced Notice of Proposed Rulemaking on Used Drum Management and Reconditioning (Docket Number EPA-HQ-OLEM-2023-0320) published on August 11, 2023.
EPA requested information to assist in the potential development of options that would ensure management of used industrial containers that held hazardous chemicals as waste. Further, EPA expressed interest in approaches applicable to address, without evidence, environmental issues at transportation equipment cleaning facilities. EPA claimed that lack of oversight of transportation equipment cleaning facilities may have resulted in environmental impacts. NTTC vehemently defended tank cleaning facilities in its letter, providing broader context to inform EPA that such facilities are already highly regulated by federal, state, and local mechanisms. NTTC reminded EPA that it already has regulatory authority of transportation equipment cleaning industry through the Resource Conservation and Recovery Act (RCRA) and Clean Water Act.
Many NTTC members own or operate tank wash facilities, conducting external and internal cleaning of tank trucks’ last containing cargoes. NTTC members are committed to meeting and exceeding environmental regulations – not only because it is the law, but because members seek to keep employees and their surrounding communities healthy and safe. Recognizing that EPA is looking to reduce leftover products from being released into the environment, NTTC’s letter read in part, “It is usual and customary for tank truck cleaning facilities to have company-wide residuals management programs based on the intent of the RCRA regulations. In many cases, tank truck cleaning facilities will not accept trailers for cleaning that have more than 5-gallons of residual product remaining in them.” NTTC asserted that additional regulations placed on the transportation equipment cleaning industry would be both unnecessary and redundant. NTTC’s letter to EPA is available by clicking here.