Preliminary Data Summary for 

Industrial Container and Drum 

Cleaning Industry 

June 2002 
U.S. Environmental Protection Agency 

Office of Water (4303T) 

1200 Pennsylvania Avenue, NW 

Washington, DC 20460 

EPA-821-R-02-011

Preliminary Data Summary for 

Industrial Container and Drum 

Cleaning Industry 

EPA 821-R-02-011 

Christine Todd Whitman


Administrator


G. Tracy Mehan, III


Assistant Administrator, Office of Water


Geoffrey H. Grubbs


Director, Office of Science and Technology


Sheila E. Frace


Director, Engineering and Analysis Division


Donald F. Anderson


Acting Chief, Chemical Engineering Branch


Jan Matuszko


Engineering Technical Coordinator


Yu-Ting Guilaran and John Tinger


Project Engineers


James Covington


Economist


June 2002


U.S. Environmental Protection Agency, Office of Water


Washington, DC 20460

ACKNOWLEDGMENT AND DISCLAIMER 

This report has been reviewed and approved for publication by the Engineering 

and Analysis Division, Office of Science and Technology. The Agency would like to 

acknowledge the contributions of the Engineering and Analysis Division staff toward the 

development of this technical document. 

This report was prepared with the technical support of Eastern Research Group, 

Inc. under the direction and review of the Office of Science and Technology. Neither the United 

States Government nor any of its employees, contractors, subcontractors, or their employees 

make any warrant, expressed or implied, or assume any legal liability or responsibility for any 

third party’s use of or the results of such use of any information, apparatus, product, or process 

discussed in this report, or represents that its use by such party would not infringe on privately 

owned rights. 

The primary contact regarding questions or comments on this document is: 

Yu-Ting Guilaran


U.S. EPA Engineering and Analysis Division (4303T)


1200 Pennsylvania Avenue NW


Washington, DC 20460


(202) 566-1072 (telephone)


(202) 566-1053 (fax)


guilaran.yu-ting@epa.gov

TABLE OF CONTENTS


Page 

1.0 EXECUTIVE SUMMARY ............................................ 1-1


2.0 INTRODUCTION .................................................. 2-1


3.0	 DATA-COLLECTION ACTIVITIES ..................................... 3-1


3.1 1989 Preliminary Data Summary for the Drum Reconditioning


Industry ................................................. 3-1


3.2 Transportation Equipment Cleaning Industry Record .............. 3-2


3.3 EPA Site Visits/Sampling in 2000 ............................. 3-3


3.4 Industry-Submitted Data .................................... 3-5


3.5 Literature ................................................ 3-5


3.6 Other Data Sources ........................................ 3-6


3.7 References ............................................... 3-6


4.0 INDUSTRY DESCRIPTION ........................................... 4-1


4.1	 ICDC Industry Overview .................................... 4-1


4.1.1 Size of the Industry and Geographical Location ............ 4-1


4.1.2 Types of ICDC Facilities .............................. 4-4


4.2	 Cleaning/Reconditioning Process ............................. 4-5


4.2.1 Drum Washing ...................................... 4-5


4.2.2 Drum Burning ..................................... 4-10


4.2.3 IBC Cleaning/Reconditioning ......................... 4-12


4.3 Cargo Types Cleaned ...................................... 4-15


4.4 Chemical Cleaning Solutions ................................ 4-17


4.5 References .............................................. 4-17


5.0 WATER USE AND WASTEWATER CHARACTERIZATION ................... 5-1


5.1	 Water Use and Sources of Wastewater ......................... 5-1


5.1.1 Drum Washing ...................................... 5-2


5.1.2 Drum Burning ...................................... 5-3


5.1.3 IBC Cleaning/Reconditioning .......................... 5-4


5.2 Wastewater Discharge Practices .............................. 5-5


5.3 Water Reuse and Recycling .................................. 5-7


5.4 Wastewater Characterization ................................. 5-7


5.4.1 Steel Drum Washing ................................. 5-8


5.4.2 Plastic Drum and IBC Washing ........................ 5-12


5.4.3 Steel Drum Burning ................................. 5-13


5.5 References .............................................. 5-14


i 
TABLE OF CONTENTS (Continued) 

Page 

6.0 POLLUTION PREVENTION AND WASTEWATER TREATMENT TECHNOLOGIES ... 6-1


6.1	 Pollution Prevention Controls ................................ 6-2


6.1.1 Heel Reduction ...................................... 6-2


6.1.2 Heel Removal ....................................... 6-5


6.1.3 Reduction in the Amount and Toxicity of Chemical


Cleaning Solutions ................................... 6-6


6.1.4 Good Housekeeping Practices .......................... 6-8


6.2	 Flow Reduction Technologies ................................ 6-9


6.2.1 Process Modifications ............................... 6-10


6.2.2 Cleaning Without the Use of Water ..................... 6-11


6.2.3 Cascade Rinsing .................................... 6-12


6.2.4 Recirculated Rinse Water ............................ 6-13


6.2.5 Treated Wastewater Recycle and Reuse ................. 6-14


6.3	 End-of-Pipe Wastewater Treatment Technologies ............... 6-15


6.3.1 Equalization ....................................... 6-16


6.3.2 pH Adjustment ..................................... 6-16


6.3.3 Gravity Settling .................................... 6-17


6.3.4 Oil/Water Separation ................................ 6-17


6.3.5 Chemical Precipitation ............................... 6-18


6.3.6 Clarification ....................................... 6-19


6.3.7 Air Flotation ....................................... 6-20


6.3.8 Sludge Dewatering .................................. 6-21


6.4	 Wastewater Treatment Performance Data ...................... 6-22


6.4.1 Oil/Water Separation ................................ 6-23


6.4.2 Chemical Precipitation Followed by Air Flotation ......... 6-23


6.5 References .............................................. 6-24


7.0	 COMPARISON OF THE DRUM RECONDITIONING AND TRANSPORTATION


EQUIPMENT CLEANING INDUSTRIES .................................. 7-1


7.1 Size of the Industry ........................................ 7-2


7.2 Cleaning/Reconditioning Processes ............................ 7-3


7.2.1 Drum Washing and Tank Cleaning ...................... 7-3


7.2.2 Drum Burning and Tank Cleaning ....................... 7-6


7.2.3 IBC Cleaning/Reconditioning at Drum Washing and Tank


Cleaning Facilities ................................... 7-6


7.3 Cargo Types Cleaned ....................................... 7-8


7.4 Water Use and Wastewater Generation ......................... 7-9


7.5 Wastewater Characteristics ................................. 7-11


7.6 Pollution Prevention and Wastewater Treatment Technologies ..... 7-14


7.7 References .............................................. 7-15


ii 
TABLE OF CONTENTS (Continued) 

Page 

8.0	 POLLUTANT LOADINGS AND COSTS TO MANAGE ICDC WASTEWATER ....... 8-1


8.1 Estimated Pollutant Loadings ................................ 8-1


8.2 Estimated Costs ........................................... 8-5


8.3 References ............................................... 8-7


9.0	 TRENDS IN THE INDUSTRY ......................................... 9-1


9.1 ICDC Industry Size ........................................ 9-1


9.2 Drum and Container Recycling ............................... 9-5


9.3 Cleaning/Reconditioning Process ............................. 9-8


9.4 Pollution Prevention and Wastewater Treatment Technologies ...... 9-9


9.5 References .............................................. 9-10


10.0 GLOSSARY .................................................... 10-1


Attachment A - §261.7 Residues of Hazardous Waste in Empty Containers 

iii 
LIST OF TABLES


Page 

5-1	 Comparison of Steel Drum Washing Raw Wastewater Characterization 


Data ......................................................... 5-15


5-2	 Summary of Raw Wastewater Characterization Data for Plastic Drum and


IBC Washing .................................................. 5-21


5-3	 Summary of Raw Wastewater Characterization Data for Steel Drum


Burning ...................................................... 5-23


6-1 Treatment Performance Data for Oil/Water Separation, Facility A ......... 6-26


6-2	 Treatment Performance Data for Chemical Precipitation Followed by Air


Flotation, Facility B ............................................. 6-28


6-3	 Treatment Performance Data For Chemical Precipitation Followed by Air


Flotation, Facility D ............................................. 6-31


7-1	 Comparison of Raw Wastewater Characterization Data for Drum


Reconditioning and TEC Facilities ................................. 7-16


iv 
LIST OF FIGURES


Page 

4-1 General Drum Washing Process Diagram ............................ 4-19


4-2 General Drum Burning Process Diagram ............................ 4-20


4-3 General IBC Cleaning Process Diagram ............................. 4-21


5-1 Water Use in ICDC Operations .................................... 5-25


v 
Section 1.0 - Executive Summary 

1.0 EXECUTIVE SUMMARY 

This Industry Profile Report provides information about the Industrial Container 

and Drum Cleaning (ICDC) industry, including the practices and technologies used by the 

industry to control pollutant discharges to U.S. surface waters and publicly-owned treatment 

works (POTW). EPA conducted this study of ICDC operations to increase its understanding of 

the industry and to provide data to facilitate a decision as to whether or not national categorical 

effluent limitations guidelines and standards should be developed for this category of 

dischargers. 

The ICDC industry includes facilities that clean and recondition metal and plastic 

drums and intermediate bulk containers (IBCs) for resale, reuse, or disposal. ICDC facilities can 

be further classified as facilities that either burn open-head steel drums or wash plastic or tighthead (i.e., bung-type) steel drums and IBCs. Most ICDC facilities purchase used drums or 

containers that they clean and recondition for resale. 

EPA estimates a total ICDC industry population of 291 facilities. These include 

an estimated 118 ICDC facilities that do not clean transportation equipment, and an estimated 

173 ICDC facilities that also clean transportation equipment (based on 1994 data). Available 

data suggest that IBC use and reconditioning has grown significantly in the 1990s, and continued 

growth is expected in the future. Both transportation equipment cleaning (TEC) facilities and 

drum reconditioning facilities consider the IBC cleaning business as an important growth market; 

therefore, ICDC industry growth consists of installing new IBC washing lines at existing drum 

washing and TEC facilities. Future growth or decline in the drum reconditioning market is 

expected to equal growth or decline in the general chemical industry. 

ICDC facilities often report under 1987 Standard Industrial Classification code 

7699 (Repair Shops and Related Services, Not Elsewhere Classified). The Reusable Industrial 

Packaging Association (RIPA) estimates that 60% of their member ICDC facilities (i.e., ICDC 

facilities that do not clean transportation equipment) are classified as small businesses (size 

1-1

Section 1.0 - Executive Summary 

cutoff unknown). In contrast, EPA estimates 30% of transportation equipment cleaning facilities 

(which include at least 173 ICDC facilities) are small businesses (annual revenues less than $5 

million). 

EPA estimates total production by the ICDC industry as follows: 

Container Type Number Reconditioned/Year 

Steel Drums 11.0 million tight-head 

20.2 million open-head 

Plastic Drums 7.6 million tight-head 

664,000 open-head 

IBCs 500,000 plastic and steel 

The most significant uses of water associated with drum and container washing 

operations include interior preflush, hot water washes and rinses, exterior washing, and 

formulation of cleaning solutions. Wastewater is generated primarily through drum and IBC 

washes and rinses. At drum burning facilities, water is used mainly in the quenching stage of the 

drum burning process, and most quench water is lost to evaporation. Some drum burning 

facilities rinse drums prior to painting; at these facilities, rinse water is the predominant water use 

and source of wastewater. Other wastewater sources at ICDC facilities include leak testing, air 

pollution scrubber wastewater, paint booth water curtain wastewater, and storm water runoff. 

EPA believes that most ICDC facilities discharge ICDC wastewater and that all or 

almost all of these facilities discharge indirectly to a POTW. EPA has not identified any 

facilities that discharge directly to surface waters. EPA also believes that a portion of the 

industry achieves zero discharge by hauling the wastewater to a centralized waste treatment 

facility, or disposing of the wastewater by land application or evaporation. Alternatively, some 

ICDC facilities achieve zero discharge by recycling or reusing 100% of its wastewater. EPA 

estimates that the total annual volume of wastewater generated by the ICDC industry is 295 

million gallons, including 200 million gallons from drum washing, 45 million gallons from drum 

burning, and 50 million gallons from IBC cleaning. 

1-2

Section 1.0 - Executive Summary 

Primary sources of pollutants in ICDC wastewater include residual material, heel, 

in the drums and containers, as well as carry-over and spent chemical cleaning solutions. Drums 

and IBCs are used to transport thousands of different cargos, including oil, solvents, paint, resins, 

chemicals, lacquers and varnishes, adhesives, cleaners, and food. Open-head drums are better 

suited to transport viscous liquids, powders, or slurries than tight-head drums and IBCs. 

For this study, EPA conducted site visits to three drum cleaning and 

reconditioning facilities, including one facility that also cleans plastic containers, in order to 

assess ICDC wastewater characteristics. In addition, in 1989, EPA completed a preliminary data 

summary for the drum reconditioning industry. Based on the sampling results from both studies, 

EPA detected over 100 pollutants in ICDC wastewater, including volatile and semivolatile 

organics, dioxins and furans, pesticides and herbicides, metals, and classical pollutants. In 

general, except for dioxins and furans, pollutant concentrations in steel drum washing wastewater 

are comparable to or greater than those in steel drum burning wastewater. In general, pollutant 

concentrations in plastic drum and IBC cleaning wastewater are significantly less then those in 

steel drum washing and steel drum burning wastewaters. Raw wastewater pollutant loadings (in 

pounds) are predominantly (80% to 99%) contributed by classical pollutants such as chemical 

oxygen demand, solids, oil and grease, and biochemical oxygen demand. Metals contributed 

approximately 1% to 20% of raw wastewater pollutant loadings, and volatile and semivolatile 

organics contributed approximately 0.2% to 3% of pollutant loadings. EPA estimates that raw 

wastewater pollutant loadings for the ICDC industry range from 46 million to 77 million poundequivalents per year. 

End-of-pipe wastewater treatment technologies commonly used by ICDC facilities 

visited in 2000 and in the mid-1980s include equalization, pH adjustment, gravity settling, 

oil/water separation; chemical precipitation followed by clarification or air flotation, and sludge 

dewatering. More than half of respondents to a 2000 survey of RIPA members reported having 

on-site wastewater treatment. However, the survey responses do not provide specific treatment 

technologies used by these facilities. 

1-3

Section 2.0 - Introduction 

2.0 INTRODUCTION 

Effluent limitations guidelines and standards (or “effluent guidelines”) are 

technology-based national standards that are developed by EPA on an industry-by-industry basis, 

and are intended to represent the greatest pollutant reductions that are economically achievable 

for an industry. These limits are applied uniformly to facilities within the industry scope defined 

by the regulations regardless of the condition of the water body receiving the discharge. To 

address variations inherent in certain industries, different numeric limitations may be set for 

groups of facilities (i.e., subcategories) within the industry based on their fundamental 

differences, such as manufacturing processes, products, water use, or wastewater pollutant 

loadings. The limits and standards that are developed are used by permit writers and control 

authorities (e.g., publicly owned treatment works or “POTW”) to write wastewater discharge 

permits. The permits may be more stringent due to water quality considerations but may not be 

less stringent than the national effluent guidelines. EPA has issued national technology-based 

effluent guidelines for over 50 industries. 

In the mid-1980s, EPA conducted studies of the drum reconditioning and the 

transportation equipment cleaning (TEC) industries to determine whether national categorical 

effluent limitations guidelines and standards should be developed for these categories of 

dischargers. In the case of the TEC industry, EPA promulgated effluent limitations guidelines 

and standards in June 2000 (65 FR 49665). During development of the TEC rule, information 

submitted by commenters indicated that there was some overlap in the TEC and the drum 

reconditioning industries. Specifically, intermediate bulk containers (IBCs), which are portable 

plastic and metal containers with 450 liters (199 gallons) to 3,000 liters (793 gallons) capacity, 

were cleaned by facilities in both industries. This was a significant finding because the number 

of IBC cleanings has increased dramatically since the early 1990s. In the case of the drum 

reconditioning industry, EPA concluded at that time that the industry did not merit national 

regulation. In addition, for the drum reconditioning industry study in the mid-1980s, EPA did 

not collect any data on IBC cleaning because so few IBCs were being used by the industry at that 

time. 

2-1

Section 2.0 - Introduction 

EPA had originally considered including IBCs in the scope of the TEC rule 

because many TEC facilities also clean IBCs. EPA obtained some IBC data from the data 

collection phase of the rule (through screener and detailed questionnaires) in 1994. EPA also 

received public comments on IBCs during proposal regarding their similarities and differences to 

tanks versus drums, and performed site visits, at the request of commenters, at two TEC facilities 

that also clean and recondition IBCs. IBC wastewater was later removed from the scope of the 

TEC rule because EPA’s assessment suggested IBC cleaning wastewater was more similar to 

drum cleaning wastewater than to TEC wastewater. 

Currently, facilities that clean industrial drums and containers may be regulated 

under other effluent guidelines. For example, manufacturing facilities covered by other 

categorical limitations and standards may clean and recondition drums and containers. In 

addition, under the Metal Products and Machinery (MP&M) rule which was proposed on January 

3, 2001 (66 FR 424), EPA proposed and requested comment on including wastewater generated 

by metal drum and IBC reconditioning/refurbishing in the scope of the MP&M rule. The MP&M 

rule proposed to cover wastewater generated by the unit operations performed on metal drums 

and/or IBCs such as chaining, caustic washing, acid cleaning, acid etching, impact deformation, 

leak testing, corrosion inhibition, shot blasting, and painting. In the proposal, the Agency 

considers facilities that perform these operations as part of the Stationary Industrial Equipment 

sector under the MP&M rule. EPA is currently evaluating comments submitted in response to 

the proposed MP&M rule. Alternatively, EPA is also evaluating regulating facilities that 

recondition/refurbish and clean metal and plastic drums and containers such as IBCs as a separate 

industrial category, referred to as the industrial container and drum cleaning (ICDC) industry. 

The U.S. Environmental Protection Agency (EPA) is required by Section 301(d) 

of the Federal Water Pollution Control Act Amendments of 1972 and 1977 (the “Act”) to review 

and revise every five years, if appropriate, effluent limitations promulgated pursuant to Sections 

301, 304, and 306. EPA conducted this study of ICDC operations to increase its understanding 

of the industry and to provide data to facilitate a decision as to whether or not national 

categorical effluent limitations guidelines and standards should be developed for this category of 

2-2

Section 2.0 - Introduction 

dischargers. EPA collected and reviewed data from numerous sources to increase its 

understanding of the following technical issues related to ICDC operations: ICDC processes, 

wastewater generation, wastewater collection and handling, and pollution prevention/treatment 

technologies. This document describes these findings in the sections listed below. Note that if 

EPA develops regulations for the ICDC industry, the Agency would cover metal drum and IBC 

reconditioning/refurbishing facilities under the ICDC regulation rather than under the MP&M 

regulation. 

� Section 3.0 - Data-Collection Activities; 

� Section 4.0 - Industry Description; 

� Section 5.0 - Water Use and Wastewater Characterization; 

� Section 6.0 - Pollution Prevention and Wastewater Treatment 

Technologies; 

� Section 7.0 - Comparison of the Drum Reconditioning and Transportation 

Equipment Cleaning Industries; 

� Section 8.0 - Compliance Costs and Pollutant Load Removals; 

� Section 9.0 - Trends in the Industry; 

� Section 10.0 - Glossary. 

2-3

Section 3.0 - Data-Collection Activities 

3.0 DATA-COLLECTION ACTIVITIES 

EPA collected data from a variety of sources, including existing data from 

previous EPA data-collection efforts, industry-provided information, and site visit and sampling 

data. Each of these data sources and its use in this study is discussed below, as well as the 

quality assurance/quality control (QA/QC) and other data-editing procedures. Summaries and 

analyses of the data collected by EPA are presented in the remainder of this document. 

The following topics are discussed in this section: 

� Section 3.1: Discusses the 1989 Preliminary Data Summary for the Drum 

Reconditioning Industry; 

� Section 3.2: Presents relevant information obtained from the 

Transportation Equipment Cleaning Industry record; 

� Section 3.3: Describes EPA site visits and sampling in 2000; 

� Section 3.4: Discusses industry-submitted data; 

� Section 3.5: Discusses technical literature; 

� Section 3.6: Discusses other data sources; and 

� Section 3.7: Presents the references used in this section. 

3.1 1989 Preliminary Data Summary for the Drum Reconditioning Industry 

EPA conducted a study of the drum reconditioning industry and published a report 

in 1989 documenting its findings. The study was a result of findings from the Domestic Sewage 

Study that the quantity of hazardous wastes generated and discharged to publicly owned 

treatment works (POTWs) by the drum reconditioning industry was unknown. For this study, 

EPA performed site visits at 16 facilities and sampling at four drum reconditioning facilities that 

did not clean IBCs. Analyses were conducted for over 400 conventional, nonconventional, 

priority, and non-priority pollutants. The study also relied heavily on responses to a 1980 

3-1

Section 3.0 - Data-Collection Activities 

membership survey conducted by the National Barrel and Drum Association (now the Reusable 

Industrial Packaging Association (RIPA)). 

EPA used this study to collect information about the drum cleaning segment of 

the ICDC industry, in particular, descriptions of drum cleaning and reconditioning operations to 

supplement the industry description, and wastewater pollutant concentrations and loadings for 

comparison to more recent sampling data and for use in estimating raw industry wastewater 

pollutant loadings and pollutant removal estimates. 

Transportation Equipment Cleaning Industry Record 

EPA promulgated effluent limitations guidelines and standards for the 

Transportation Equipment Cleaning Point Source Category in August 2000 for the discharge of 

pollutants into waters of the United States and into POTWs by existing and new facilities that 

perform transportation equipment cleaning operations. Transportation equipment cleaning (TEC) 

facilities are defined as those facilities that generate wastewater from cleaning the interior of tank 

trucks, closed-top hopper trucks, rail tank cars, closed-top hopper rail cars, intermodal tank 

containers, tank barges, closed-top hopper barges, and ocean/sea tankers used to transport 

materials or cargos that come into direct contact with the tank or container interior. 

EPA searched the rulemaking record for this point source category for information 

on facilities that clean intermediate bulk containers (IBCs) in addition to other tanks or 

containers (e.g., tank trucks). EPA had originally considered including IBCs in the scope of the 

TEC rule. EPA obtained some IBC data from the data collection phase of the rule (through 

screener and detailed questionnaires) in 1994. EPA also received public comments on IBCs 

during proposal regarding their similarities and differences to tanks versus drums, and at the 

request of commenters performed site visits at two TEC facilities that also clean and recondition 

IBCs. IBCs were later removed from the scope of the TEC rule because EPA’s assessment 

suggested IBC cleaning wastewater was more similar to drum cleaning wastewater than to TEC 

wastewater. 

3-2


3.2 
Section 3.0 - Data-Collection Activities 

3.3 EPA Site Visits/Sampling in 2000 

In order to increase its understanding of the ICDC industry, EPA conducted site 

visits at representative ICDC facilities. EPA used information collected from literature searches 

and contact with trade association members to identify representative facilities for site visits. 

RIPA worked with their membership to suggest three facilities willing to participate in EPA’s 

sampling program. In general, these facilities encompassed the range of ICDC operations, 

wastewater characteristics, and wastewater treatment practices. The first facility is in the eastern 

United States and performs plastic drum and IBC washing. The second facility is in the 

midwestern United States and performs steel drum washing and burning, and the third facility is 

also in the midwestern United States and performs steel drum washing. 

Facility-specific selection criteria are contained in site visit reports (SVRs) 

prepared for each facility visited by EPA. During the site visits, EPA collected the following 

information: 

� General facility information, including size and age of the facility; 

� A general description of ICDC operations; 

� Wastewater characterization information; 

� On-site wastewater treatment data, including the treatment technologies 

used, treatment costs, monitoring, discharge, and permit information; and 

� Economic information. 

This information is documented in the SVR for each facility. 

3-3

Section 3.0 - Data-Collection Activities 

During the study, EPA conducted one-day sampling episodes at three facilities 

(those facilities which EPA site visited) for raw wastewater characterization. The Agency 

collected the following grab samples during each site visit: 

� Influent to wastewater treatment;


� Trip blanks; and


� Duplicate wastewater sample (one sample at one facility).


The following classes of pollutants were analyzed: 

� Volatile organics;


� Semivolatile organics;


� Metals;


� Pesticides/herbicides;


� Dioxins/furans;


� Hexane extractable material (HEM);


� Silica-gel treated hexane extractable material (SGT-HEM);


� Biochemical oxygen demand, 5-day (BOD5);


� Total suspended solids (TSS);


� Chloride;


� Total organic carbon (TOC);


� Chemical oxygen demand (COD);


� Ammonia as nitrogen;


� Nitrate/nitrite as nitrogen;


� Total phosphorus; and


� Total cyanide.


Section 5.4 of this report discusses the results of EPA’s wastewater characterization sampling 

effort. 

During the sampling period, field measurements of temperature, pH, and free 

chlorine were collected for each sample point. Waste stream flow, production data (e.g., number 

and types of containers cleaned), and any information on non-ICDC operations that generate 

wastewater that is commingled with ICDC wastewater were also collected when available. 

3-4

Section 3.0 - Data-Collection Activities 

During each sampling episode, EPA collected and preserved samples and shipped 

them to EPA contract laboratories for analysis. Sampling collection and preservation were 

performed according to EPA protocols as specified in the Quality Assurance Project Plan for 

Field Sampling and Analysis - Industrial Container and Drum Cleaning Industry (QAPP) (1) and 

the EAD Sampling Guide (2). 

EPA collected the required types of quality control samples as specified in the 

QAPP, such as trip blanks and duplicate samples, to verify the precision and accuracy of sample 

analyses. The list of analytes for each episode, analytical methods used, and the analytical 

results, including quality control samples, are included in the Sampling Episode Report prepared 

for each sampling episode. 

3.4 Industry-Submitted Data 

EPA made several contacts with members of RIPA, which is the primary trade 

association for drum reconditioning facilities. EPA obtained anecdotal process and production 

information, as well as facility wastewater discharge practices. EPA used the information 

obtained from facilities and from RIPA throughout its analyses and incorporated it into this 

report. 

RIPA also provided EPA a summary of the results of a membership survey 

conducted in 2000 which included data for certain process operations, wastewater management, 

and hazardous waste management. Surveys were sent to 98 RIPA members engaged in the 

reprocessing of steel and plastic drums, as well as IBCs, and 36 survey responses were submitted. 

3.5 Literature 

EPA performed several Internet and literature searches to identify applicable 

materials for use in the study. Literature sources were identified using the Dialog® service. The 

3-5

Section 3.0 - Data-Collection Activities 

literature collected discussed trends in the ICDC industry and information about specific ICDC 

facilities. EPA used these data to supplement this report. 

EPA reviewed the Hazardous Cargo Bulletin International Drum & IBC Guide, 

which is an international directory of drum, IBC, and other industrial packaging producers to 

determine population estimates. EPA also reviewed two industry trade journals, Hazardous 

Cargo Bulletin and Modern Bulk Transporter, for additional information on the ICDC industry. 

EPA reviewed The Future of the IBC Market, a Hazardous Cargo Bulletin report, 

which describes many aspects (technical and economic) of the IBC industry (3). EPA also 

reviewed Assessment of Combustion Sources that Emit Polychlorinated Dioxins and Furans, 

Polycyclic Aromatic Hydrocarbons, and Other Toxic Compounds, which presents air emissions 

characterization data for drum burning processes (4). 

3.6 Other Data Sources 

EPA made several phone calls to facilities in the Hazardous Cargo Bulletin that 

were not confirmed by RIPA as reconditioning facilities to verify whether they were ICDC 

facilities and to assist in the preparation of population estimates. 

3.7 References 

1.	 Eastern Research Group, Inc. Quality Assurance Project Plan for Field Sampling 

and Analysis - Industrial Container and Drum Cleaning Industry, August 2000 

(DCN D00104). 

2. Viar and Company. EAD Sampling Guide. June 1991 (DCN D00115). 

3.	 Dixon, B., The Future of the IBC Market - A Hazardous Cargo Bulletin Report, 

Intapress Publishing Ltd. London, England, 2000 (DCN D00008). 

3-6

Section 3.0 - Data-Collection Activities 

4.	 Midwest Research Institute. Assessment of Combustion Sources that Emit 

Polychlorinated Dioxins and Furans, Polycyclic Aromatic Hydrocarbons, and 

Other Toxic Compounds, PB94-129871. January 1992 (DCN D00146). 

3-7