Draft,
4/
12/
05;
subject
to
change
1
Industrial
Container
and
Drum
Cleaning
Industry
4.0
Introduction
The
Industrial
Container
and
Drum
Cleaning
(
ICDC)
industry
includes
facilities
that
clean
and
recondition
metal
and
plastic
drums
and
intermediate
bulk
containers
for
resale,
reuse,
or
disposal.
EPA
collected
data
and
compiled
a
Preliminary
Data
Summary
for
Industrial
Container
Drum
Cleaning
Facilities
(
PDS)
in
2002
(
EPA­
821­
R­
02­
011).
The
PDS
identified
approximately
291
ICDC
facilities,
all
of
which
discharge
indirectly
to
a
Publicly
Owned
Treatment
Works
(
POTW).

4.1
Industry
Profile
Industrial
Container
and
Drum
Cleaning
(
ICDC)
facilities
often
report
under
SIC
code
7699:
Repair
Shops
and
Related
Services.
The
1987
SIC
Code
Manual
defines
this
SIC
code
as
follows:


7699:
Establishments
primarily
engaged
in
specialized
repair
services,
not
elsewhere
classified,
such
as
farm
machinery
and
equipment
repair;
lawnmower,
saw,
knife,
and
tool
sharpening
and
repair;
bicycle
repair;
lock
and
gun
repair;
musical
instrument
repair;
and
the
repair
of
typewriters.
Repair
services
which
involve
primarily
electrical
or
electronic
equipment
or
components
are
classified
in
Industry
7629;
however,
primarily
mechanical
repair
of
electrically
powered
equipment,
such
as
electric
sewing
machine
repair,
is
included
here.

SIC
code
7699
encompasses
a
wide
range
of
operations,
of
which
drum
cleaning
and
reconditioning
is
only
a
small
subset
(
PDS).
Data
from
TRI,
PCS,
and
Census
that
are
based
on
SIC
code
7699
may
not
be
representative
of
ICDC
facilities
and,
therefore
will
not
be
presented.

Operations
at
ICDC
facilities
are
classified
into
three
categories:


Drum
washing;


Drum
burning;
and

Intermediate
Bulk
Container
(
IBC)
cleaning/
reconditioning.

Drums
typically
contain
oil
and
petroleum,
industrial
chemicals,
paint
and
ink,
cleaning
solvents,
Draft,
4/
12/
05;
subject
to
change
1RIPA
represents
the
industrial
container
and
reconditioning
industry
in
North
America.

2Specific
TWFs
used
were
from
the
2002
Study
and
have
not
been
updated
to
reflect
2005
TWFs.

3This
estimation
is
described
in
more
detail
in
Section
8.0
of
the
PDS.

2
resins,
adhesives,
food,
or
pesticides.
Intermediate
bulk
containers
(
IBCs)
may
contain
oil
and
petroleum,
chemicals,
or
food.

Based
on
1994
data,
the
2002
PDS
estimates
a
total
of
291
ICDC
facilities
in
the
U.
S.,
of
which
173
also
clean
transportation
equipment.
In
addition,
the
Reusable
Industrial
Packaging
Association
(
RIPA)
1
web
page
lists
92
reconditioner
members
as
of
2004.
Also,
according
to
RIPA,
the
majority
of
container
reconditioners
are
small
businesses
as
defined
by
the
SBA
for
SIC
Code
7699.

4.2
Wastewater
Characteristics
As
explained
in
Section
4.1,
neither
the
PCS
nor
TRI
database
contains
any
information
specific
to
discharging
ICDC
facilities.
The
2002
PDS
contains
data
on
wastewater
generation
and
pollutants
of
concern
and
their
concentrations
in
untreated
ICDC
wastewaters.

Wastewater
Quantity
According
to
the
2002
PDS,
the
ICDC
industry
generates
approximately
290
million
gallons
of
wastewater
per
year.
The
greatest
source
of
wastewater
is
rinse
water.
Other
sources
include:
interior
preflushes
and
washes;
spent
cleaning
solutions;
exterior
washwater;
leak
testing
wastewater;
compressor
condensate;
boiler
blowdown;
acid
washing
emissions
scrubber
water;
and
label
removal.

Raw
Wastwater
Quality
EPA
conducted
site
visits
at
three
ICDC
facilities
in
2000.
EPA
also
collected
raw
wastewater
samples
from
four
steel
drum
reconditioning
facilities
in
the
1980s.
These
data
are
the
basis
for
EPA's
raw
wastewater
quality
estimates
for
this
industry.
Table
5­
1,
5­
2,
and
5­
3
in
the
PDS
provide
mean
concentrations
for
pollutants
analyzed.

Using
the
information
on
pollutant
concentrations
in
raw
ICDC
wastewaters,
information
on
total
annual
production,
and
toxic
weighting
factors
(
TWFs)
2
EPA
estimated
total
annual
raw
wastewater
pollutant
loadings
(
in
lb­
eq)
for
the
ICDC
industry3.
Table
4­
1
presents
the
estimated
Draft,
4/
12/
05;
subject
to
change
3
raw
wastewater
loadings
for
the
ICDC
industry.
Dioxins
and
furans
accounted
for
more
than
90
percent
of
the
total
annual
loadings,
and
metals
accounted
for
the
majority
of
the
remaining
10
percent.

Table
4­
1.
Raw
Wastewater
Loadings
from
2002
Study
of
the
ICDC
Industry
Container
Type
Raw
Wastewater
Pollutant
Loadings
(
lb­
eq/
container)
#
of
Containers
Cleaned
per
year
Total
Annual
Raw
Wastewater
Pollutant
Loadings
(
lb­
eq)

Steel
Drum
Washing
0.037
11
million
410,000
Plastic
Drum
Washing
5.5
8.2
million
45,700,000
Steel
Drum
Burning
0.0023
20.2
million
46,000
IBC
Washing
0.014
to
61
500,000
7,000
to
31,000,000
Total
(
TWPE)
46
million
to
77
million
Source:
2002
PDS.

4.3
On­
Site
Wastewater
Treatment/
Pretreatment
and
Pollution
Prevention
According
to
the
2002
PDS,
most
ICDC
facilities
that
discharge
wastewater
discharge
to
a
POTW.
EPA
did
not
identify
any
direct
dischargers.
Some
facilities
achieve
zero
discharge
by
hauling
wastewater
to
a
centralized
waste
treatment
facility,
or
disposing
of
wastewater
by
land
application
or
evaporation.
In
addition,
some
facilities
achieve
zero
discharge
by
recycling
or
reusing
100%
of
ICDC
wastewater.

Treatment
technologies
at
ICDC
facilities
commonly
include
equalization,
pH
adjustment,
gravity
settling,
oil/
water
separation,
chemical
precipitation
followed
by
clarification
or
air
flotation,
and
sludge
dewatering.

Water
reuse
and
recycling
activities
at
ICDC
facilities
include:


Recirculating
cleaning
solutions
and
water
washes;


Reusing
drum
burning
quench
water;


Reusing
final
rinse
water
as
initial
rinse
water;


Using
treated
ICDC
wastewater
as
source
water;


Using
leak
testing
wastewater
as
source
water;
and

Using
final
rinse
wastewater
as
cleaning
solution
"
make­
up"
water.
Draft,
4/
12/
05;
subject
to
change
4
4.4
Multimedia
Environmental
Releases
ICDC
facilities
will
generate
sludge
from
wastewater
treatment
units
such
as
DAF
or
chemical
precipitation
and
separation
that
are
designed
to
remove
solids.
The
sludge
is
not
usually
considered
to
be
a
hazardous
waste,
and
is
normally
disposed
of
in
a
non­
hazardous
landfill.

ICDC
facilities
will
also
have
air
emissions
associated
with
their
operations.
Based
on
the
data
on
raw
wastewater
quality,
ICDC
wastewaters
contain
various
volatile
organic
constituents.
Because
these
wastewaters
have
contact
with
the
ambient
air,
some
portion
of
these
constituents
will
volatilize
as
air
emissions.

4.5
Industry
Trends
The
2002
PDS
identifies
the
following
trends
in
the
ICDC
industry
from
the
mid­
1980s
to
2000:


The
number
of
drums
reconditioned
has
decreased;


Drum
burning
operations
have
increased,
while
drum
washing
operations
have
decreased;


The
number
of
IBCs
reconditioned
has
increased;
and

Use
of
plastic
drums
has
increased
significantly.

4.6
References
US
EPA.
2002.
Preliminary
Data
Summary
for
Industrial
Container
and
Drum
Cleaning
Industry.
EPA­
821­
R­
02­
011.

RIPA
web
page.
Accessed
at
<
http://
www.
reusablepackaging.
org/>
on
October
21,
2004.

RIPA.
Comments
on
the
draft
PDS
for
the
ICDC
Industry,
October
22,
2001.
