The emphasis of these assessments has been toward reducing the contaminants and
 wastes at the source as opposed to cleaning up waste water after the fact.  In order to
 run your shop as economically and efficiently as possible, you should reduce all types
 of wastes including hazardous wastes, solid wastes, air emissions, and water
 discharges.  It has become apparent  that there are shortfalls in the command and
 control end-of-pipe regulations.

 The sources of pollution within industrial laundries must be identified and solutions
 found which reduce or eliminate the generation of the wastes through source
 reduction, reuse and recycling.  There will still be end-of-the-pipe requirements but it is
 this group's hope that by using a joint industry - government effort, the cost of
 complying with any future discharge regulations will be significantly reduced or in
 some cases eliminated altogether. Pollution prevention should be generally divided
 into laundry site activities and customer site activities.

 Recognizing that  what goes into a washing operation determines in large part what
 will come out of it, soiled articles and  process and treatment chemicals must be
 screened.  The most transparent thing about any large industrial laundry operation is
 that it begins with lots of clean water and finishes with lots of dirty water.  Identifying
 pollutants and problems isn't easy.  Its complexity varies from location to location
 depending on the size of the facility, the volume of water and chemicals consumed, the
 garment usage profile of the customers being serviced, and the specifics of local, state,
 and federal  requirements.

 This report presents several options for reducing solid and hazardous waste
 generation.  They should all be carefully evaluated.  Those which represent the
 highest return on  the time, effort and funds invested should be the first implemented.
 Opportunities to reduce the volume of non-hazardous solid wastes through better
 supplier partnerships also exist. Some options for reducing those wastes are also
 presented.   It is the writer's opinion that if an industrial laundry's corporate
 management makes a strong commitment to a continuing waste reduction program
 and improved customer partnerships, their plant can achieve significant waste


 The Plants are primarily engaged in supplying laundered uniforms (shirts and pants),
 garments, shop towels, mats, mops, table linen, barber and beauty towels.and
 restaurant bar towels to industrial or commercial users.  Uniforms are at the upper-end
of the market with service station and beer uniform accounts being the best. However,
 market pressures have cut the cost of a uniform from $1.60 to $1.20 currently.
Customers served include vehicle maintenance shops, metal fabrication machine


  shops, printers, printed circuit board manufacturers, aerospace, furniture
  manufacturers, agricultural businesses, and restaurants.
  Plants which handle light soils usually don't process shop towels.  A
  "middle-of-the-road" operation launders medium soils while heavy soil operations
  process shop towels and inkies. The plants operated on similar schedules and
  production shifts as follows:

              5 days per work week with 82 employees on 2 shifts (39 per shift);
              5 days per work week with 36 employees on 1 shift;
              5 days per work week with 170 employees on 1 production shift (2:00 am
              - 12:30pm);
              4 days per work week (closed Wednesday) with 96 employees on
              10-hour shift (midnight - 2:30 pm); and
              5 days per work week with 100 total employees on 1 shift, from 5:00 am -
             2.30 pm.

 The total production poundage laundered weekly at the assessed laundries was:

             61,000 pounds (Approximately 46,000 pounds/week are processed by
             water washing with 15,000 pounds/week processed by dry cleaning);
             100,000 pounds (Shirts and pants accounting for  50,000 pounds/week);
             175,000 pounds (Shop towels accounting for 25% of the volume or
             approximately 44,000 pounds);
             134,800 pounds; and
             83,000 pounds (Approximately 70,000 pounds/week are processed by
             water washing with 13,000 pounds/week processed by dry cleaning).

 Soiled materials are received and sorted according to soil type,  fabric type, garment
 type,  ownership, and color. The soiled textiles are sorted into loads for processing by
 washers of different sizes. Different wash formulas  are used depending on soil
 characteristics. In-coming shop towels with heavy soil may be soaked overnight.  A 10
 - 20 minute treatment operation prior to  the break is  used for heavy soil loading and it
 is best to drain the operation before the  break. For shop  towels, temperatures of 165 -
 170 degrees F or a terpene cleaner are  used to remove heavy, oily soils.

 Mats are washed in cold water and dirty dust mops are washed  in hot water. 'A dust
 suppressant is added to both mats and mops.  One plant quit applying  it and the
 customers have not noticed the change.  Finishing includes a steam tunnel and sheets
 and table clothes go through pressing machines.

 One facility processed shop towels  until recently  when discharge limitations could no
 longer be met and the shop towels were sent to a job-shop plant for laundering.  The
 shop towels are sorted at the plant and trucks pick up the soiled ones and deliver
clean  ones for the customers.  Another facility processed shop towels until mid-1992

  when discharge limitations could no longer be met and the shop towels were sent to
  another company-owned plant for laundering.  After pickup, shop towels are sorted at
  the plant and once-a-day a flatbed truck picks up the soiled ones and delivers clean
  ones for the customers.

  Dry-to-dry and wet-to-dry cleaning machines are used for longer life of pants and
  overalls (which cost $80/pair for a refinery).  Two dry cleaning machines are used at
  one plant to process 16% of the total weekly production poundage, mostly pants. The
  two machines have 170 pound capacities each per load.  Approximately 7 or 8 loads
  are processed in each daily. Therefore, approximately 2,600 pounds per day or
  13,000 pounds/week are dry cleaned.  At another plant, two 180 pound capacity
  machines process 15,000 pounds/week.  Solvent recovery by distillation and a
  water/oil separator is in-place at both locations. A flow diagram of the dry cleaning
  processes can be found ir Appendix G.


 Several different types  of pretreatment  systems are used on the wash water
 discharged from laundering ranging from sophisticated and costly to simple and more
 affordable.  Diagrams generalizing the  flow of materials through the laundering, dry
 cleaning, and treatment processes were developed and can be found in Appendix G.
 The waste streams identified during the assessment are also noted in the flow

 At one plant, wash water is discharged through a shaker screen to an equalization
 basin. A three chamber, primary separator is used next for pH adjustment and a
 coagulant is added.  Air flotation is used in 2 chambers in combination with an oil
 skimmer which generates a hazardous  waste tramp oil. The bottoms from the sludge
 tank are metered to the rotary drum which  generates 8.5 tons/month of filter cake that
 is 55% solids.

 At another plant, wash water from non-oily textiles is discharged to a clarifier where an
 oil skimmer generates small amounts of hazardous waste oil.  The shop towels' wash
 water is sent through a complete, on-site treatment system.  The batch treatment plant
 is used on the wash water discharged from laundering shop towels.  Acid cracking is
 used to break or float the oil and soils from shop towels. Lime is added  in the batch
 treatment process for floccing. After settling,  the sludge passes through a filter press
 which produces a sludge cake.  The cost to operate the system is $3.00 per gallon.
 The sludge cake is stored in roll-off bins located on the site. For economies-of-scale,
 two roll-offs are hauled at one time.

 At another plant, sulfuric acid cracking (pH 2 - 3) is used to break or float the oil and
 soils from shop towels.  It passes through an oil/water separator which generates
3,000 gallons of oil every 2 - 3 months.   This would be a rate of approximately 50 - 60

 gallons per day.  Ferrous sulfate and a 6% lime slurry are added in the rapid mix tank
 for floccing.  This process pulls out more oil. The next step in the treatment process is
 aeration and addition of an anionic polymer in the slow mix tank. After settling to 1 -
 2% solids, the sludge passes into a sludge holding tank (5% solids) and finally,
 through a filter press which produces a filter cake (60% solids). Two loads per day are
 generated and 6 loads fill a 20 cubic yard container. The filter cake is stored in the
 roll-off bins located on-site.  For economies-of-scale, two roll-offs are hauled at one
 time resulting in loads of 18 - 20 tons every 6 - 8 days. Water passes through a
 neutralization tank where sulfuric acid ensures a pH of 11 before being discharged to
 the POTW whose limit is pH 12.

 At another plant, wash water is discharged to a series of two pits where acid is added
 in the first pit if needed.  It then passes through a shaker screen into a third pit. From
 this pit, the water passes through a heat exchanger/reclaimer on the shaker screen for
 heating in-coming water before discharging into a fourth pit.  From pit #4 the water
 goes to a holding tank with an oil skimmer.  Finally, the water passes through a settling
 pit before going  to the sewer.  A nonhazardous sludge is pumped out of the settling pit

 At another plant, a small treatment system is used on the wash water discharged from
 laundering.  Wash water is discharged to a collection basin and then passes through a
 shaker screen to a two chamber baffle basin.  An oil skimmer had been  used in the
 past which generated a hazardous waste tramp oil. This facility processed shop
 towels until  mid-1992 when discharge  limitations could no longer be met.  The County
 limit for petroleum oil and grease is 100 ppm.

 Plants should continue looking for ways to get more oil out during the treatment
 process prior to the filter operation. At one plant assessed, they might consider an
 ozone injector in the treatment process to lower the TTOs from shop towels. A VOC
 Stripper or centrifuge can significantly reduce solvents entering the wash and
 treatment processes.  They can be expensive and options for reuse of the recovered
 solvents need to be developed which satisfy all regulations.  These and other liquid
 removal options  should be considered if technically and economically feasible for
 industrial laundries and their customers.  This option is discussed later in the Waste
 Reduction Opportunities section.


 Instituting a comprehensive conservation program can save money and valuable
resources.  For instance:

      Using the  latest technology or new equipment may require less energy, water
      and chemicals to operate properly and cycle times may be reduced.

 For example, plant management should consider automatic, liquid injection wash
 systems or retrofitting where economically and technically possible. They reduce
 cycle time and result in precise measurement of formulas as a better operating
 procedure. All laundry processes were automated with liquid injection of the laundry
 chemicals at one plant assessed. The liquid soaps are more expensive, however, the
 automatic loading of the chemicals saved 0.8 hours per day per machine. The
 automated system saved raw materials and reduced handling of chemicals which had
 previously been added by hand (40 - 50 pounds/load) as additional benefits. The
 liquid detergents and chemicals come in drums and are received on pallets.

             Monitoring your water, gas and electric meters routinely is necessary.
             Identify peaks and valleys for usage during the day and week and what
             measures might reduce usage. Determine if there are activities that
             consume water, gas and electricity that could  be curtailed during
             non-production  hours.

 Utility and water consumption are tracked at most plants. In-process recycling on-site
 should be considered for heat energy at industrial laundries.  The following questions
 should be asked:

             Is there a heat reclamation system in use and  where is it located?

             Where  is the reclaimed heat used?

             Can the efficiency of the existing system be improved?


 It does appear that heat and energy recovery is practiced widely by industrial
 laundries.  The most efficient energy reclamation measures and technologies should
 be put into place at all existing and new facilities.

 At one facility visited during the assessments, a heat exchanger is used for energy
 conservation by heating in-coming city water at 72 degrees F with the 150 degree F
 discharge water to a temperature of 100 -110 degrees F. At another plant, a heat
 exchanger is used for resource conservation by heating in-coming water with'the  150
 degree F discharge water to a temperature of 80 -100 degrees F before going into the
 boiler. A heat exchanger on the shaker screen is  used at yet another plant for
 resource conservation by heating city water.  And finally at a fourth plant assessed,
discharge water passes from one pit through a heat exchanger and reclaimer on a
shaker screen for heating in-coming water before being discharged into another pit of
the treatment system. There is also a flue gas recirculator at this facility to heat
in-coming water as an energy recovery measure.

 Water is heated to final wash temperatures with gas boilers. Gas is also used in dryers
 and steam tunnels.  The monthly costs for gas at the plants are:

             $4,500 ($54,000 annually;
             $4,600 ($55,200 annually);
             $9,500 ($114,000 annually); and
             $10,000 ($120,000 annually - It is estimated that the gas boiler at this
             plant represents about 50% of the costs).

 Monthly electric usage costs at the plants are:

             $3,880 ($46,550 annually);
             $5,350 ($64,200 annually);
             $4,500 ($54,000 annually - These rates are based on 10 hours per day
             in production during the "out-of-peak" time period - 2:00 am - 12:30 pm);
             $11,000 ($132,000 annually).


These average amounts of water were used by the plants to process the  volume
(poundage)  laundered weekly:

             110,000 gallons/week  to process 46,000 pounds (2.4 gallons/pound);
             140,000 gallons/week  to process 70,000 pounds (2 gallons per pound);
             242,000 gallons/week  to process 100,000 pounds (2.4 gallons/pound);
             258,000 gallons/week  to process 135,000 pounds  (1.9 gallons per
             pound); and
             350,000 gallons/week  to process 175,000 pounds  (2 gallons per pound).

The annual costs for water usage and discharge to the sewer are:

            $39,000 (Assuming water at $11,400 and sewer at $27,600);
            $55,000 (Assuming water at $31,200 and surcharges are assessed at
            $6,000 per quarter for waste water discharges);
            $284,000 (Assuming water at $126,000 and annual sewer fees are
            $66,000 based on a monthly average of $5,500.  The plant also pays a
            "Significant Users Fee" of $23,000 per quarter or $92,000 annually. This
            is fee is going up to $25,000 per quarter soon.  Seventy percent of the
            sewer fee is a surcharge on total suspended solids (TSS) because the
            205 ppm limit cannot be met); and
            > $21,600 (Water usage currently is 28,000 gallons per day but cost was

              not determined during the assessment.  Annual sewer charges are
              $21,600 based on a flat fee of $5,400 per quarter with surcharges for
              BOD, TSS, and volume).

  In-process recycling or reuse on-site should be considered for water at industrial
  laundries.  The following questions about water conservation need to be answered:

              What percentage of all  laundries, small and large, are currently using
              water conservation measures?

              Does one washer or method of washing use more water than others?

              How is the liquid removed from the vessel when the cycle is complete (ie^
              gravity, pump, vacuum, etc.)?

              Can the various cycle discharges be separated?

              Is there a water reclamation/reuse system in operation?

              On what laundry process stream  is the reclamation associated?

              What water reuse systems can be benchmarked as the best-of-best and
              be incorporated by other laundries?

 Although there is much talk by laundry representatives  about what is being done in
 water conservation, the assessors didn't find this to be the norm at large laundry plants
 or "the cream-of-the-crop." More management commitment and effort needs to be
 focused  on the water reuse issue to achieve the highest percent technically and
 economically  feasible.  The following  observations were made during these

 One plant is plumbed for clean rinse water reuse  in flush cycles for heavy soiled
 textiles.  Currently, 10 - 20% of the clean rinse  water are reused on heavy soiled loads.
 A goal of 80% clean rinse water reuse has been set for accomplishment in the next
 two years.  Another plant was also plumbed for clean rinse water reuse in flush cycles
 for heavy soiled textiles. The percent  of water reused currently is _%.  Technical and
 economic feasibility should be determined with the help of laundry associations,
 local/state/federal P2 and regulatory staff, and consultants.

Water softeners are used on incoming water and brine is produced which is
discharged to the POTW. This brine waste stream can be costly and harder to manage
if the local POTW does not accept brine, as is the case in San Bernardino County.  At
one plant assessed, material recovery and reuse is accomplished by diverting calcium
that is displaced during the water softening process to the equalization tank in the

 treatment process. The calcium replaces lime in the morning until production levels
 require addition of lime throughout the shift.  Plant management should investigate this
 potential for reducing treatment chemical costs and brine disposal impacts on the


 The hazardous wastes generated by laundry and treatment processes are:

             filter cake:
                   RCRA hazardous;
                   California List; and
             waste oil;
             still bottoms from the distillation of perc;
             Recovered solvents;
             Vehicle maintenance wastes; and
             Lint from a shaker screen (which was generated at a rate of 1 drum per
             week and is shipped as a hazardous waste with the filter cake).

 Total annual costs of hazardous waste management were not determined during the
 assessments for all plants, however one facility spent more than $141,000 annually.
 The following descriptions of hazardous waste streams generated at the various plants
 do include costs where they were available.

 At one plant that used dry cleaning, two machines generated 400 pounds per month of
 still bottoms. Two machines at another dry cleaning facility generated four or five 16
 gallon drums per month which weighed approximately 535 - 665 pounds.  The cost for
 waste management by Safety Kleen is approximately $5,000 annually for this service.

 At one plant, the oil is decanted at a rate of 300 gallons per day. The oil is stored in a
 2,400 gallon tank and is hauled as a hazardous waste. The oil is "probably fuel
 blended." Initially, the cost for hauling and recycling was $1.10 per gallon but now is
 at $0.80 per gallon.  Assuming 21  working days in a month, the amount generated
 would be 6,300 gallons and would cost about $5,000.  This results in an annual
 generation rate of 75,000 gallons and a disposal cost of $60,000.

The oil from the oil/water separator is stored and  handled as a hazardous waste at
another plant. The oil is fuel blended by a company. The cost for hauling and fuel
blending is $1.00 - $4.00 per gallon and is determined by the BTU value and the
solids content. Assuming 3,000 gallons are generated quarterly, the amount
generated annually would be 12,000 gallons and would cost about $24,000 at an
average of $2.00 per gallon.

  At one plant, the oil skimmer on a holding tank removes 1/4-1/2 drum per day of
  tramp oil from discharge waters.  This would be 2 drums per week or 8 drums per
  month.  Costs for managing the waste oil were not determined during the assessment.

  An oil skimmer had been used in the past at one plant which generated a hazardous
  waste tramp oil. Amounts and costs for managing the waste oil in the past were not
  determined during the assessment.  The limits for petroleum oil and grease are 100
  ppm in the County where the laundry is located.  If fats, oil and grease (FOG) become
  a problem, an oil skimmer may be necessary again in the future.

  At one plant, the filter cake is landfilled at a cost of $60/ton and a haul fee of $350  As
  a hazardous waste, state taxes of $26Aon are levied which costs $221/month.  The
  management cost for this hazardous waste is $1,081/month or $13,000 annually.

  At one plant, the total estimated cost of filter cake (120 tons) disposal for the first ten
  months of operating a batch treatment was $11,500 or approximately $13,800
 annually.  Each haul of 40 tons would be approximately $3,850. Disposal of the filter
 cake costs $65.00 per ton. The flat rate transportation cost is $748.00 for the doubles
 Bin liners are $15.00 each or $30.00 per haul.  And finally, the bin rental fee is $3.50
 per day per bin or $147 per month for the two bins. Since placed in operation  10
 months ago, bin rental has cost $1,470 (or $490 per haul).

 At one plant, the filter cake (60% solids) is a hazardous waste because it fails the
 aquatic toxicity test because of trace solvents and oils.  Disposal costs for the filter cake
 and lint are $135.00 per ton with the transport fee included. It is estimated that the total
 cost of filter cake disposal , generator fees, and taxes is $75,000 annually.

 There is a potential long-term liability associated with this type of disposal and  some
 industrial  laundries are working with cement manufacturers to explore using the 50%
 silica filter cake (from rotary vacuum drum) in its process.

 At one plant, solvents recovery from shop towels generates 2000 gallons per month of
 hazardous waste.  The recovered solvents are sent for fuel blending at a cost of $1.75
 per gallon including the transport fee.  The monthly costs for management of this
 hazardous waste stream are $3,500 or $42,000 annually.

 One plant provides fleet vehicle maintenance for 33 trucks with 3 or 4 mechanics.
 They are  responsible for the proper handling and disposal of all used oils, filters and
 wastes. Used oil filters are stored in a drum; every 3 months it is picked up for
crushing and reclamation of the oil filters at a cost of $40.00 per  drum.  Every six
months, 5 drums of used oil are generated.  No disposal costs were given for this
waste stream during the assessment.  Antifreeze is sent through the plant's treatment
system. The mechanics use recovered solvents as needed for cleaning.

 At another laundry, fleet vehicle maintenance is performed at a central garage facility.
 Oil changes are carried out at this facility with the used oil and filters being sent to the
 central garage for proper disposal.  They are responsible for the proper handling and
 disposal of all used oils, filters and vehicle maintenance wastes. The central garage
 facility also has a paint booth which probably generates paint and solvent clean up
 wastes.  No disposal costs were given for these waste streams during  the assessment

 Fleet vehicle maintenance is performed at one plant on 28 trucks. Safety Kleen
 services 3 solvent wash stations every two months.  The cost for this service is $150
 per month or $1,800 annually.  Oil changes generate 55 gallons per month of used oil
 which is handled by a company along with the tramp oil from skimming in the
 treatment system. The oil filters are taken by Safety Kleen who picks up  every 2
 months at a  cost of $109 or $650 annually. Another plant used a contract service for
 vehicle maintenance.

 No plant visited had underground storage tanks (USTs).


 The non-hazardous wastes which are generated at  laundry plants consist mostly of
 miscellaneous shipping and packaging materials such as cardboard, plastic bags,
 pallets, and fiber and steel drums. Chemicals come  in bags and drums on pallets. At
 one plant, the dumpsters were estimated to be "80% cardboard and paper" along with
 lint.  Other solid wastes include lint from shaker screens on discharge waters and lint
 collectors for the dryers.  The dryer lint collector at one plant  is cleaned once-a-day
 and put in the 6 cubic yard,  solid waste dumpster.

 A sludge which is pumped from a settling pit is disposed as a solid waste at one plant.
 The settling pit generates 4,500 gallons per month of sludge at a cost of $1,500 or
 $18,000 annually. Another solid waste stream generated at  industrial  laundries are
 old uniforms and textiles taken out-of-service.  One facility  assessed sends the old
 uniforms for rag manufacturing and the laundry receives $0.05 per pound. If an
 industrial laundry  is not currently recycling these solid wastes, the options available
should be reviewed and implemented.

The solid wastes are put in dumpsters which are emptied periodically.  The solid waste
management costs determined were:

             $400/month ($4,800/year);
             $205/month ($2,460/year - dumpster is emptied daily);
             $800/month ($9,600/year); and
            Costs were not determined during the assessment at one  plant but two, 4
            cubic yard dumpsters are emptied every 2 days.

  The following responses were given by plant staff when ask about solid waste
  management practices:

              The company that  handles our solid waste sorts for recycling."

              At one plant, "some of the cardboard boxes are broken down and sent
              back to the supplier for reuse." "Some cardboard boxes are hauled for

              Steel drums "are picked up by the suppliers." The treatment chemical
              supplier "picks up their drums." The chemical supplier "takes the drums

              Pallets "are taken by someone." Some pallets are "sold and the hangeir
              supplier picks their pallets up."  Pallets are "sent back to the supplier or
              trashed out."  Pallets "are  reclaimed by another company."

              "Hangers are recycled" at  most facilities.

              "Boiler maintenance  is performed once a year.  All of the waste
             generated is hauled off by the Contractor. M


 The following is a list of the opportunities for meaningful waste reduction which the
 assessments identified.   For each opportunity, further discussion and brainstorming
 with employees should produce a  list  of options to be considered for implementation.
 Selected sources of information relevant to the  pollution prevention options will be
 found in the appendices.

 1 •    Separate and Maintain Strict Control  of the  RCRA  and California
      List  Hazardous Waste Streams.

 During the plant visits, the writer observed that an environmental management system
 is being  used by industrial laundries to implement and assure compliance with ail
 existing regulations in the handling, storage and disposal of the wastes. Employee
 awareness and training  programs about hazardous wastes should be expanded to
 include identification of waste reduction opportunities.

 Management should identify and separate pollutant sources, if possible, to determine
potential problems from your waste streams and to maximize pretreatment efficiency.
Waste stream separation according to toxicity, type of contaminant, and/or physical
form can help achieve waste reduction during materials handling, transfer, storage,
and treatment.


 2.    Establish a Continuing  Waste Reduction Program

 Opportunities for waste reduction are present in every operation, unless ALL waste
 streams are eliminated or have been reduced to the lowest levels technically and
 economically achievable.  The way to take advantage of the opportunities is to
 establish a program to identify and capitalize on them.  Powerful incentives  for a
 continuing waste reduction program exist, but often are not recognized.  Their number
 will increase as business expands, regulatory pressures increase, landfills are filled,
 current disposal practices are prohibited, and labor and materials costs rise.

 A continuing waste reduction program should be fully implemented at all industrial
 laundries. When shipping hazardous wastes with a required RCRA manifest, the
 generator certifies a program is in-place to reduce waste streams where technically
 and economically feasible. California has a hazardous waste reduction planning law.
 Industrial laundries should develop a plan to  meet all state/federal requirements.  The
 essential elements of an effective company-wide program can be found in Appendix A.

 Some of the more significant incentives  for implementing a program are:


 3.     Best  Management  Practices  (BMPs)

 These assessments  pointed out the need for  an increased focus on best management
 practices by both laundries and their  customers in chemical usage, handling and
 storage of soiled textiles, and ensuring that no free-liquids are transported and
 processed in the laundries. Good operational control for waste reduction is  defined as
 a  procedure or policy within an  organization that reduces the generation of
 multi-media wastes.  Better standard  procedures usually relate to production
 (organizational structure, housekeeping improvements, initiatives, operations planning
 and control) rather than raw materials and design factors.

 Initial policy deployment by management should provide information on BMPs and
 monitoring and incentives for the professional sales staff and route salespeople (and
Teamsters).  The sales staff and route salespeople serve exclusive areas on
commission base-pay and interface with the customers trying to maximize sales within
their area. They understand the customer's needs and include requests for special
handling during washing for the heavy soiled loads they identify.  Any time not spent
actually servicing customers is spent finding new customers. They will need positive
benefits for the customer to help in  marketing  and will need a guide of "tips for better


 serving customers," especially those with solvent soiled textiles.  Marketing incentives
 used by sales staff and route salespeople should also include activities already
 implemented in water and energy conservation which will also improve the company's

 Since they work on commission, they have very limited interest in monitoring the
 condition of the customers' soiled textiles and uniforms. Route salespeople are most
 interested in making their service calls as quickly as possible. Management needs to
 consider a bonus program for preventing pollution and protecting the laundry facility
 from pollutants of concern.

 Route salespeople understand the customer's needs but may need help and
 instructions on what to look for.  Sales staff and route salespeople need to know when
 and why they can take shop towels.  There are BMPs for customers and treatment and
 disposal concerns at the laundry which should be covered by management. If these
 conditions are met,  route salespeople can take shop towels.  A checklist should be
 designed for the route salespeople that would clearly describe what they should be
 doing at each stop to appropriately screen the materials that they're picking up.  Some
 larger laundries have staff trained and assigned to marketing services and screening
 clients for soil types.

 Route salespeoples1 training should begin with identifying and targeting soil types and
 pollutants of concern and the probable sources of these contaminants. The training
 should focus on verifying that best management practices (BMPs) are being employed
 by the customer to ensure that no free-liquids are transported back to the laundry.
 Route salespeople need to  have answers for materials handling and transport
questions such as:

            What type of management commitment and support is there for requiring
            implementation of pollution prevention and best management practices"
            (BMPs) by the customers?

            Are there proper collection systems or liquid extraction equipment at the
            customer's facility?

            Have there been any instances or problems with liquids in transit from
            the customer to the laundry?

            Can  a list (or MSDSs) of chemicals used by the customer be provided
            before the initial pick up of soiled textiles and where should that list

              What trigger mechanisms are in-place at the laundry to ensure that target
              pollutants in soiled textiles are reviewed by management and
              environmental/safety staff prior to contracting with a potential client?

              What steps  are involved in getting the soiled textiles to the loading bay?

              What steps  are taken once at the loading bay involving sorting and
              counting the pieces?

 Guidelines and material information for the route salespeople and the customers
 should include BMPs that help reduce the toxicity of chemicals used and eliminate
 free-liquids in the soiled textiles.  An effort to educate customers about best
 management practices via guidance manuals,  fact sheets,  and a  general awareness
 may have an impact in reducing contaminants  before the soiled textiles are picked up
 for cleaning.  Daily/weekly sales meetings should be used for no free-liquids training
 and better chemical usage awareness.  A bibliography of manuals, fact sheets, and
 checklists has been developed for "risky" clients, which have been identified in an
 Institute of Industrial Launderer's (IIL) study. This pollution prevention bibliography
 can be found in Appendix  B.

 Best management practices  (BMPs) by the customer and laundries for shop towels
 have been summarized from:  (1) Washington State Dept. of Ecology, July 1992 Focus
 handout; (2)  Minnesota Pollution Control Agency, October 1989 memo; and (3) the
 Institute of Industrial Launderers and Textile Rental Services Association 1992
 brochure entitled, "Management Practices for Soiled Reusable Textile Handling." This
 summary can be found in Appendix C.

 Contracting office staff should also be aware of and involved in ascertaining
 acceptability  of what's being taken in for processing. If there were a list (or MSDSs) of
 chemicals provided by the customers, the safety programs at both facilities would be
 involved and  become  aware of each other and  potential safety, health, and
 environmental concerns. This type of supplier partnership will be of benefit to both
 parties in the long-term.

 4.    Better Standard  Operating  Procedures

 A business's  first step in a  waste reduction program can be to change procedures.
 Improving operating procedures reduces accidental and material losses while
maintaining or increasing productivity.  Improved procedures can  range from a change
in management approach to a  change in waste handling  procedures. Proper
procedures to reduce waste must be a part of the overall operating plan for a business.

  Purchasing (Substitute) Raw  Materials and  Inventory Control

  Instituting a comprehensive chemical review and purchasing program can save
  money and valuable resources and reduce toxics and waste. For instance:

        Identifying all process and treatment materials that you use in your facility and
        evaluating how much is going into the different processes and what residuals
        are exiting to all media - land, air and water ~ is an important element of a
        waste reduction plan.

  Material safety data sheets (MSDSs) were obtained for Factor Plus, Promote Plus, FB
  Counterpunch, Economy Sour, Sentinal Sour, Silver-Wyte, and Digress a powdered,
  chlorinated laundry bleach.  Factor Plus, a laundry detergent is incompatible with
  strong oxidizers.  Promote Plus, an industrial shop towel laundry detergent, is
  incompatible with strong oxidizers.  Silver-Wyte, a laundry bleach, is a strong oxidizer
  with the potential for release of chlorine. FB Counterpunch is a liquid, industrial, dry
  cleaning detergent which is  incompatible with oxidizing agents and chlorinated
  cleaners. Laundry bleachs (Silver-Wyte and Digress) are  strong oxidizers with the
  potential for release of chlorine when mixed with acids, ammonia, oil, and liquid
  organic materials.  Economy Sour and Sentinal Sour are  incompatible with strong
  alkalies or chlorinated cleaners which may also be present in laundry operations. A
  nonbenzene-based, powdered dye  is manually added when needed for the last 10
 minutes of the wash cycle at most plants. Chemical oxygen demand (COD) could be
 added to the waste water by this dye. Some surfactants used contain ethytene glycol,

 Technical information on Regenerate II, a terpene liquid laundry additive used at one
 plant, claims it is an environmentally safe detergent-solvent formulation designed for
 removing ink, paint,  grease, and oil from cotton, polyester, and polyester/cotton blends.
 It is designed to be used in combination with other complete detergents and a break
 operation should follow the treatment. Compatibility  testing is suggested prior to using
 this terpene cleaner on mats since it may soften or damage natural and synthetic
 rubbers.  An MSDS was not obtained on this terpene cleaner  but it should be noted
 that some terpenes contain volatile organic compounds (VOCs) and may contain an
 ingredient from the SARA Title III Section 313 chemical list. This could be a source of
 solvent contamination in the wash water.

 Safety meetings should focus on proper handling and storage of all process chemicals
 to avoid health hazards and the generation of waste from spills and cleanup.  The
 automatic, liquid injection systems that are available  do reduce the handling of
 approximately 40 - 50 pounds of laundry chemicals per load which improves worker

Consider replacing your current raw materials with others that reduce the amount or
toxicity of the waste that you generate. Toxics use reduction in all  process and


  treatment chemicals should be reviewed periodically with your suppliers and vendors.
  Management, environmental/safety staff, and suppliers need to continue asking why
  are these chemicals used and how can their hazards and toxicity be reduced for the
  laundries and their customers. At one plant assessed, management made the
  decision to quit applying oil to dust mops and customers have not noticed the change.
  You should always take into consideration the cost of treatment and disposal when
  you are deciding what raw materials to purchase and use in laundering.

  Standard procedures for inventory controls should be implemented or improved to
  ensure review of all chemical usage in the plant. Material and waste tracking systems
  including good inventory controls seemed to be in-place at the facilities assessed.
  Laundry process and treatment chemical usage at the laundries visited was well
  documented including MSDSs  and amounts of chemicals used over periods  of time.
  Laundries should use just-in-time inventory controls where possible with usage of
  chemicals on a first-in, first-out basis to prevent storage of products beyond their shelf
  life which creates waste.

  Procedures for inventory control implemented should ensure review of all chemical
 usage in aerosol cans throughout the plant.  Aerosol cans offer industry a wide variety
 of products in a very convenient package. Currently, many landfill authorities are
 beginning to address aerosol cans that they manage.  The following are waste
 reduction recommendations:

       Order aerosol products according to demand.  Expired shelf life may require
       excess inventories to be disposed.

       Control inventories by dispensing aerosol cans through  one person  in one
       location to prevent unnecessary usage.

       Keep aerosols away from moisture, sunlight, and extreme heat and cold to
       increase sherf-life.

       Keep protective caps on  containers when not in use to prevent contamination,
      rusting of the container top, and nozzle damage.

      Purchase alternative aerosol products that do not contain CFCs.

Vendor/supplier certification  and procurement procedures should  include
considerations and requirements for reducing solid waste from shipping and
packaging materials.  Better specifications in  contracting can save money in reduced
solid waste costs and ensure the reuse, recyclability,  and high post-consumer content
of all shipping and packaging materials received.

 Good  Housekeeping

 Good housekeeping measures can greatly decrease the amount of wastes that are
 generated.  To reduce excess waste production:

             Keep tight fitting lids and bungs on containers to prevent loss of
             chemicals through evaporation or spillage.  Keeping lids on containers
             also prevents contamination with water, dirt or other materials.

             Use spigots and pumps when dispensing new maten'als and funnels
             when transferring wastes to storage containers to reduce the possibility
             of spills.

             Inspect spigots routinely to reduce leaking and clean up time. If
             adsorbents are used, a waste is being generated and raw materials are

             Store products in locations that will preserve their shelf life.
             Accumulate wastes indoors or in a covered area to prevent moisture from
             seeping in.

             Never mix different types of waste together.  Mixing wastes may make
             recycling impossible, or make waste disposal much more expensive.

             Make sure that personnel are well trained and aware of operating
             practices that reduce waste generation.

Large amounts of solid and/or hazardous waste may be generated through spills and
leaks, improper storage practices, inefficient production start-up or shut-down,
scheduling problems, lack of emergency procedures and preventive maintenance, or
poorly calibrated devices for pollution control processes. New manuals of standard
procedures and routine training and retraining can eliminate this problem.  These
procedures may significantly reduce waste at the source.

If you are using adsorbents, select adsorbents that are wringable and can be reused
more than once to reduce raw materials loss, disposal costs, and clean up time.  Some
adsorbents have been used as much as 17 times.  Consider adsorbents such as
special formulated peat moss that will not easily leach in landfills. Adsorbents  have
been developed from sawdust, wood fibers, and corn cobs. Sand and clay have been
used in the past but new concerns about them leaching absorbed materials should be
considered carefully.  Check with your landfill authorities to determine if they will
accept certain adsorbents containing chemicals.  Some restrictions may apply.

  Maintenance and Preventative Maintenance

  The laundries visited during these assessments had major maintenance operations for
  laundry and dry cleaning equipment, treatment processes, boilers, and fleet vehicles.
  More effort should be focused on the waste streams generated by these activities. The
  solvents, oils and greases generated during these procedures should be separated
  and handled properly.  They don't need to go through on-site waste treatment systems
  where lint, sludges, and waste water will be impacted.

  Reducing wastes  through good operating practices can be achieved by using
  maintenance and  preventative maintenance to reduce incidents of equipment
  breakdowns,  inefficiency, or process fluid and chemical leakage. Liquid and laundry
  chemical leaks can be eliminated by conducting a regular maintenance program

             Periodically replacing the seals on the washers and the door gasket.

             Checking hose connections and couplings.

             Cleaning lint screens to avoid clogging.

 Corrective maintenance, such as resetting control valves or adjusting process
 temperatures, will  increase efficiency and prevent raw material and energy loss
 through waste streams. At one facility visited, maintenance costs for a 5 week period
 were approximately $5,000. The  production manager, plant engineer and general
 manager track major equipment and/or recurring problems.  Preventive maintenance
 helps reduce down-time and wastes produced during the procedure.

 Another waste stream generated by maintenance activities are aerosol cans. Paints,
 cleaners,  greases,  silicones, etc. are used and empty aerosol cans are disposed of in
 the solid waste dumpsters.  Standard procedures for inventory controls and  reduction
 of waste from aerosol products have been mentioned earlier.

 5-     Reduce the Number of Empty  Cans. Bags. Drums and Pallets

 It was observed that practically all of the laundry, treatment and dry cleaning
 chemicals, etc. are received in bags, cardboard boxes and all types of drums. The
 quantity is great enough that alternate packaging in larger containers would  cause a
 large reduction in the amount of solid waste  being landfilled and empty containers to
 be handled.  A chemical use report on daily usage figures was provided by one of the
 plants assessed. If all of these chemicals came in 55 gallon drums, there would be an
equivalent of 9 empty drums generated as solid waste per week (although some
chemicals come in  bags and smaller fiber drums).

 Determine the number of drums generated and track their handling and storage
 procedures and costs. Negotiate with your supplier to use returnable drums or bulk
 containers to ship materials. The concept of bulk or semi-bulk packaging bears
 exploration, even if some changes in the procedures used to distribute to the point of
 use or to dispense for use are necessary. Returnable "tote bins" may be impractical
 because of current equipment and accessibility, but If the current package is a
 standard steel drum, the number of empty containers generated could be reduced
 significantly, potentially 90%. The number of incoming disposable pallets would als*>
 be considerably reduced.  Automated, liquid injection systems may also allow the use
 of reusable, bulk containers - totes - which reduce solid waste after chemical usage
 (by 6 - 7 drums).

 For reusing and recycling 55 gallon drums, businesses usually return empty drums to
 the chemical supplier or deal with a cooperage company who reconditions and sells
 them. If your supplier will not accept empty drums, determine if a drum reclamation
 company will recondition your drums for resale.  Drum reconditioners recycle steel
 drums which contain residues of organic materials by burning them out before
 straightening and repainting. Investigate drum recycling  sites to ensure that your
 drums are managed responsibly and lawfully according to all local, state, and federal

 If drum disposal is necessary, consider sending empty containers to scrap metal
 vendors.  Visit your local scrap metal vendors to note how scrap is  handled.  Tour the
 company to monitor how the containers are managed.  Ask questions on how your
 scrap should be stored and transported and  how it is received and  processed.

 You may want to consider crushing or cutting the drums and other  metal containers to
 ensure that they are not being reused for storing or transporting others materials. If
 you generate large numbers of drums the supplier will not take, you should determine
 the feasibility of purchasing a drum crusher.  Before  cutting or crushing drums,
 determine if the drum contained flammable materials. These drums may contain an
 explosive mixture of air and vapor.  Drums should be thoroughly purged before cutting
 or crushing.

 When asked about pallets during the assessments, most replied, "they are taken by
 someone except the damaged ones which go to the dumpster."  More focus should be
placed on this waste stream by contacting suppliers about pallet reuse or elimination
altogether. Pallets are a candidate for advertising in Waste Exchanges. The amounts,
sizes and frequency can be advertised as an available material for reuse at a
reasonable cost.

  6.     Inaugurate  a  Comprehensive  Paper  and  Paper  Products  Recycling

  Recycling paper products can reduce disposal costs.  In almost every landfill, paper
  products represent the largest volume of waste present.  As landfill space becomes
  more valuable, recycling paper products has great potential to extend the life of
  landfills.  Recycling paper has not always been encouraged by paper mills, largely
  because they lacked capacity to handle the recycled material. This is no longer the
  case. Most will now buy corrugated board and some 35 grades of paper. High grade,
  office paper should be used on both-sides and then be separated and recycled.

  Reuse of cardboard boxes can be accomplished by purchasing contracts which
  encourage the reuse of raw material shipping containers. Reuse of corrugated
  packaging has been accomplished by many suppliers to all types of industry.  Some
  may require liners to enhance reuse but this option should be pursued with your

 Some facilities that generate large amounts of cardboard have found it economically
 feasible to bale and sell their cardboard.  Businesses with small amounts of cardboard
 usually give it away to a business or charity willing to pick it up.  We suggest you
 contact your current or local recycler about the feasibility of upgrading the present
 recycling program or initiating one.  For a directory of industrial recyclers call  Cal
 EPA's Department of Toxic Substance Control (DTSC) at 916/322-3670.

 7.    Utilize Waste  Exchanges.

 There is a growing interest in services known as Waste  Exchanges.  Basically, a waste
 exchange distributes information among subscribers about waste materials available,
 or waste materials wanted.  Often, a waste for one company is a useful raw material for
 another. The waste exchange allows you to find someone who can make good use of
 materials which would otherwise be discarded Many companies have found that
 pallets can be exchanged locally to reduce solid wastes to the landfill.

 Another example are companies who sell used lubricating oil to  a fuel blender for a
 few cents a gallon.  Space heaters which burn untreated, used oil are now available,
 and some companies who once paid for waste oil  disposal are now seeking to acquire
 or purchase additional used oil through the waste exchanges.

 Appendix D contains names and addresses of local and out-of-state Waste Exchanges
 and reuse programs. Calmax would be your closest contact and specific information
 on their purpose has been provided.  Also included are  agencies and groups which
provide resource assistance.

 8.    Reduce. Recover  and  Reuse  Solvent from the Dry cleaning

 Industrial laundries which also are dry cleaners are prime candidates for waste
 reduction. Typical wastes generated by dry cleaners include spent perchloroethylene
 (perc), still bottoms from distillation of solvents, spent filter cartridges, cooked powder
 residue and water contaminated with perc. These hazardous wastes must be
 managed and disposed of legally.

 In approximately 10% of industrial laundries, dry cleaning with perchloroethylene (or
 perc) or other solvents is used on garments, shirts and pants.  There were both dry-to-
 dry and regular transfer machines which had capacities of 170 - 180 pounds per load.
 The dirty  solvent mixture passes through a solvent/water separator and generates 50 -
 60 gallons/day of water and soluble materials which are recycled back into the launcry
 water wash cycle for reuse.  Laundries should determine if this practice could be
 impacting oil  and TTOs in the waste water. The solvent from the separator passes
 through a distillation unit before reuse.

 By 1994,  regulations will probably require ventless systems and dry-to-dry technology
 or transfer enclosures. Some laundries will retrofit their dry cleaning machines to meet
 the new standards, while many will have to buy new equipment or discontinue dry
 cleaning.  It is the writer's understanding that new Maximum Achievable Control
 Technologies (MACTs) will be published in the Code of Federal Register on July 17,
 1993 (but we all  know how that goes).

 Establishments who use perc and solvents should review use of all containers
 including sewer lines and septic tanks which may contain  or may have contained perc.
 Special attention should be paid to perc-contaminated condensates and prior or
 current disposal  of still bottoms to ensure that contamination is not continuing.
 Cracked sewer lines which  leaked heavier-than-water perc  have caused groundwater
 contamination.  All tanks and piping systems  should be checked after earthquakes and
 heavy freezing.

 There are a variety of ways that laundries with dry cleaning can reduce the amount of
 waste that you generate and in turn reduce your operating costs.  These waste
 reduction  techniques for dry cleaners include:

 Good  Housekeeping

Good housekeeping measures can greatly decrease the amount of wastes that are
generated. To reduce excess waste production:

      Keep tight fitting lids and bungs on containers to prevent loss of chemicals
      through evaporation or spillage.  Keeping lids on containers also prevents


        contamination with water, dirt or other materials.

        Use spigots and pumps when dispensing new materials and funnels when
        transferring wastes to storage containers to reduce the possibility of spills.

        Inspect spigots routinely to reduce leaking and clean up time.  If adsorbents are
        used, a waste is being generated and raw materials are lost.

        Provide secondary containment in areas where perc and perc wastes are

       Store products in locations that will preserve their shelf life.  Use just-in-time
       inventory controls where possible and usage of chemicals should be on first-in,
       first-out basis to prevent storage products beyond shelf life.

       Accumulate wastes indoors or in a covered area to prevent moisture from
       seeping in.

       Never mix different types of waste together. Mixing wastes may make  recycling
       impossible, or make waste disposal much more expensive.

       Make sure that personnel are well trained and aware of operating practices that
       reduce waste generation.

Maintenance and  Preventative  Maintenance

Reducing wastes through good operating practices can be  achieved by using
maintenance and preventative  maintenance to  reduce  incidents of equipment
breakdowns, inefficiency, or process fluid and chemical leakage.  Corrective
maintenance, such as resetting control valves or adjusting process temperatures, will
increase efficiency and prevent raw material loss through waste streams. In dry '
cleaning, both liquid and vapor leaks  can be eliminated by  conducting a regular
maintenance program including:

      Periodically replacing the seals on the dryer deodorizer and aeration valves,
      the door gasket on the button trap, and the gasket on the cleaning machine

      Repairing holes in air and exhaust ducts.

      Checking hose connections and couplings.

      Cleaning lint screens to avoid clogging fans and condensers.

       Checking baffle assembly in cleaning machine.

       Checking air relief valves for proper closure.

       Monitoring for vapor losses with solvent leak detectors.

       Checking to see that your water/solvent separator is working correctly.  If there
       is an unusually large amount of perc in your collection bucket, it is not working

 Substitute  Raw Materials

 Consider replacing your current raw materials with others that reduce the amount or
 toxicity of the waste that you generate.  For example, if you use a solvent other than
 perc, use one which is not considered ignitable with a flash point of 140 degrees F.
 Check with your supplier/vendor for more information.  You should always take into
 consideration the cost of disposal when your are deciding what raw  materials to

 Modify  or Replace Your Dry cleaning Process

 In wet-to-dry units you lose solvents in the transfer process.  Several other
 technologies which have been developed recently to control perc emissions during
 transfer are termed transfer enclosures.  A transfer enclosure captures or collects perc
 emissions during clothing transfer at dry cleaning facilities using transfer machines.
 Transfer enclosures have been subclassified into two types,  hamper enclosures and
 room enclosures.  If you are currently using a wet-to-dry cleaning unit, consider
 replacing it with a dry-to-dry unit which eliminates the need for clothing transfer.

 A fact sheet on "National Emission Standards for Hazardous Air Pollutants from Dry
 cleaning Facilities'1 can be found in  Appendix F.  It includes the recommended
 standards for pollution prevention practices, operational and maintenance practices,
 and reporting and recordkeeping. As mentioned earlier, MACT standards will be
 published on July 17, 1993  in the Code of Federal  Register.

 Reduce,  Recover and Reuse Solvent from the  Waste Stream

There are several methods you can use to reclaim  perc from  your system. Perc and
other cleaning solvents are  expensive, so the more of it you can recover and reuse,
the more money you will save.  Recycling methods include:

      Distilling your spent perc in a distillation unit.

        Capturing the perc vapors which are vented from your machine, and passing
        them through an activated carbon filter. The perc is then reclaimed by passing
        steam, in reverse,  through the carbon filter.

        Using "sniffers" to  draw in the perc vapors from the shop or transfer enclosures,
        and then using the same carbon filter process to reclaim the perc.

 9-     Solvents  Recovery With  VOC Stripper  and  Centrifuge

 During these assessments, the  issue of handling and laundering shop towels was
 discussed with laundry personnel.  Two methods for solvent recovery prior to water
 washing are centrifuging  and Volatile Organic Compound (VOC) stripping. A VOC
 Stripper, the first of it's kind in full operation, was observed. The "bugs of doing 4 or 5
 daily loads were being worked out."  Operating procedures and sling loading of the
 800 - 1000 pounds of shop towels had been modified to improve the cycle times.

 The VOC Stripper processes the soiled shop towels by injecting  live steam at
 controlled temperatures to release the solvents from the fabric. The steam and VOC
 vapors are  drawn off through a condenser to a separator where the VOCs are
 recovered.  A cold water rinse cycle quickly lowers the temperature of the shop towels
 for unloading.  The recovered solvents are stored in tanks.

 After installing the VOC Stripper, an impact on washing efficiency was observed.  In
 general, there has been an increase in wash cycle time, temperature, and chemicals
 needed to clean the shop  towels in the absence of the solvents.  Shop towels (heavy
 soil) require a flush cycle while the shirts (light soil) go directly to the break cycle.  For
 shop towels, wash temperatures of 180 degrees F are used to remove heavy, oily
 soils.  Normal wash temperatures are 140-150 degrees F. The  shop towels also
 require longer rinsing cycles, sometimes for 2 hours while normal soil rinsing cycles
 are less than an hour.

 If solvents recovery is implemented, marketing/sales staff, route salespeople, and
 environmental/safety staff  should investigate the option of returning recovered VOCs to
 the customer/generator for reuse at their facility.  Local, state,  and federal regulators
 should provide guidance for solvent materials reuse in cleaning and other processes
 and  toxics use reduction by the customers. EPA's Design for The Environment
 Printing Project's "Case Study  1: Managing Solvents and Wipes" can be found in
 Appendix E.  This is a model example of a supplier/customer partnership which
 resulted in solvents recovery using a centrifuge and continuous improvement of
processes at both facilities. It is the goal of this P2 Industrial Laundry Workgroup to
help facilitate adaption of these types of pollution prevention and waste reduction


It is apparent from the assessments that fleet maintenance is performed on-site and
that typical vehicle maintenance waste streams are generated. These wastes are
generated at this plant and a central garage facility. Many state and federal pollution
prevention  programs have developed vehicle maintenance manuals, fact sheets, and
checklists for reducing toxic materials use and wastes.  These are being included in
the pollution prevention bibliography found in Appendix B.  These should be used for
educating laundry customers in this business sector who use shop towels, but also
should be used by the laundries themselves.

Training for mechanics is necessary to ensure proper handling, storage, reduction,
and disposal of these wastes. Pollution prevention manuals for vehicle  maintenance
can be found in the bibliography in Appendix B.  Vehicle maintenance waste streams
are identified and discussed in these manuals and waste reduction recommendations
are offered.


 APPENDIX A —    Waste Reduction Planning Program
 APPENDIX B —    Pollution Prevention Bibliography
 APPENDIX C —    Summary:  Best Management Practices (BMPs) for Soiled
APPENDIX D —    Waste Exchange Information:  Calmax
APPENDIX E —   EPA's Design for The Environment Printing Project's "Case
                 Study 1:  Managing Solvent and Wipes"
APPENDIX F —   A Fact Sheet on "National Emission Standards for
                 Hazardous Air Pollutants from Dry Cleaning Facilities*
APPENDIX G ~-   Flow Diagrams for Pretreatment and Dry Cleaning


                              APPENDIX A

                   Waste Reduction  Planning Program

The essential elements of an  effective company-wide program are:

           TRUE COSTS

None of the elements is measurably more important than another, and a program will
rarely be more than partially effective unless all those listed are present.

The program must have a set of GOALS which should be:

           ACCEPTABLE to those who  will work to achieve them.
           FLEXIBLE to adapt to changing requirements.
           MEASURABLE over time.
           SUITABLE  to the overall corporate goals.
           ACHIEVABLE with a practical level of effort.

Top management commitment can best be communicated by a formal policy
statement from the C.E.O. or from the Directors. An example is:


     [ Corporate Name ]
     	is committed to continued excellence,
      leadership and stewardship in protecting the environment
      Environmental protection is a primary management responsibility, as well
      as the responsibility of every employee.

      In keeping with this policy,  our objective as a company is to reduce waste
      and achieve minima! adverse impact upon the air, water and land
      through excellence in environmental control.

         The Environmental Guidelines include the following points:

                    .Environmental protection is a line responsibility and
              an important measure of employee performance.  In
              addition, every employee is responsible for environmental
              protection in the same manner as he or she is for safety.

                    .Minimizing or eliminating the generation of waste
              has been and continues to be a prime consideration in
              research, process design, and plant operation; and
              management considers it as important as safety, yield, and

                    _Reuse and recycling of materials has been and will
              be given first consideration prior to classification as waste
              for treatment and disposal.
                               [ Corporate Official ]
 Defining a  waste reduction  program  ideally involves a company-wide
 assessment  of waste generation by as diverse a TASK FORCE" of employees as can
 be assembled. The task force should determine:

             What wastes are generated;
             What operations or processes generate them;
             Quantity and cost of each  waste stream; and
             Corporate priority for attacking reduction efforts, according to the
             stated goals.

 Each opportunity must be individually evaluated to determine the action to be
 taken. As a result of the assessment, a number of OPPORTUNITIES  similar to those
 listed in this report will have been identified.  Once identified, evaluation by smaller
 teams of persons most familiar with the operation involved usually reveals several
 options for dealing  with each opportunity.  An evaluation team can then judge the
 options according to such criteria as cost to implement, disruption of  normal
 operations, technical difficulty, etc. and recommend an implementation plan.

 Sources of technical  information are many, but include, among  others State
 Technical Assistance Programs such as: Cal EPA's Department of Toxic Substance
Control (DTSC); EPA Region 9's information services and publications; equipment
chemical and environmental services vendors and suppliers; and consulting firms '

The final element of  a successful  waste reduction  program is continuing
evaluation and updating. To plan future pollution prevention and waste reduction
efforts, companies must establish a means of documenting and evaluating current and
past efforts.  Such analyses should consider:

            The program's actual costs and savings compared with initial program

            The impact of waste reduction efforts on:

                  »The composition of the waste streams;

                  »The quantities of the waste streams;

                  »The cost of waste  management;

                  "Production capacity and product quality;

                  «Production costs, including raw materials;

                  »Utility and maintenance costs;

                  »Health and safety exposure of workers and community; and

                  "Corporate environmental, health and safety liability.

          APPENDIX B
Pollution Prevention Bibliography


Auto Repair
litle                                   Type

Waste Minimization for                  Fact Sheet
Automotive Repair Shops

Automotive Maintenance                 Fact Sheet
Industry: Basic Environmental
& Business Requirements

Radiator Repair Industry:                 Fact Sheet
Basic Environmental &
Business Requirements

Hazardous Waste Reduction              Handbook
Assessment for Automotive
Repair Shops

Used Oil: Handling,  Storage              Fact Sheet
& Transport for Recycling

Used Oil Filters: Handling,               Fact Sheet
Storage & Transport for

Waste Minimization for                  Fact Sheet
Commercial Printing Industry

Mangaging Solvents & Wipes             Case Study
                       Printing: Pollution Prevention            Factsheet
                       Opportunities Checklist

                       Commercial Printing:  Pollution           Guidelines
                       Prevention Opportunities Guidelines
Prepared By


L.A. City
                                                                                             L.A. City


DfE Project

L.A. County
San. District!!

Orange County
San. District*!
Metal Finishers
Waste Minimization for                  Fact Sheet
Metal Finishers

What Should I Do With My              Fact Sheet
Electroplating Sludge?

Plating with Trivalent Chrome            Fact Sheet
                       Decorative Plating with Tri-              Fact Sheet
                       valent Chrome

                       Metal Finishers: Pollution               Factsheet
                       Prevention Opportunities Checklist

L.A. City

L.A. City


L.A. County
San. District!

                                                                                 (p. 2 of 4)
 Metal Finisher*
 Metal Fabricators
Printed Circuit
 Metal Finishing: Pollution
 Prevention Opportunities Guidelines

 Hazardous Waste Reduction
 Checklist & Assessment
 Manual for the Metal Finishing

 Waste Minimization Opportunity
 Assessments: East L.A. Enterprise
 Zone Metal Plating Facilities

 Metal Fabricators:  Pollution
 Prevention Opportunities  Guidelines

 Metal Fabricators:  Pollution
 Prevention Opportunities  Checklist

 Waste Minimization for
 Aerospace Industry

 Waste Minimization for
 Printed Circuit Board

 Printed Circuit Board
 Manufacturing:  Pollution
 Prevention Opportunities

 Printed  Circuit Board
 Manufacturing:  Pollution
 Prevention Opportunities

 Furniture Reftnishers-
 Regulatory Requirements

 Waste Minimization Assessment
 for a Manufacturer of
 Military Furniture

Jewelry Manufacturers:
 Basic Environmental &
Business Requirements

Waste Minimization for
Paint Formulaton

Paint Collection Facilities
for Businesses
                                 Orange County
                                 San. Districts
                                                                 Handbook & Checklist    Cal-EPA
                                                                 Case Studies
 Fact Sheet
 Fact Sheet
Fact Sheet

Case Study

Fact Sheet

Fact Sheet

 City HTM

 Orange County
 San. Districts

 L.A. County
 San. Districts


                                                                                                Orange County
                                                                                                San. Districts
                                                                                                Orange County
                                                                                                San. Districts
L.A. City

                                                                                                L.A. City

                                                                                                L.A. City

                                                        (p. 3 of 4)
Paint (con't)
Waste Minimization for                   Fact Sheet
Auto Paint Shops

Formulators (Paint, Pesticides,             Guidelines
Aerosols):  Pollution Prevention
Opportunities Guidelines

Formulators (Paint & Pesticides)           Factsheet
Pollution Prevention Opportunities

Waste Minimization for                   Fact Sheet
Pesticide Formulating

Formulators (Paint, Pesticides,             Guidelines
Aerosols):  Pollution Prevention
Opportunities Guidelines

Formulators (Paint & Pesticides)           Factsheet
Pollution Prevention Opportunities

Orange County
San. Districts
                                                                                                L.A. Count)'
                                                                                                San. Districts
                                                                                                Orange County
                                                                                                San. District
                                                                                                L.A. County
                                                                                                San. Districts


 The publications on this list are available to the public free of charge.  To order, call or write:

 CaLEPA                California Environmental Protection Agency
 DTSC                   Department of Toxic Substances Control
                         Pollution Prevention & Regulatory Assistance Division
                         Technology Clearinghouse
                         P.O. Box 806
                         Sacramento.  CA 95812-0806

                         (916) 322- 3670

 I~A.  City                City of Los Angeles
 HTM                   Hazardous and Toxic Materials Office
                         Board of Public Works
                         200 N. Spring Street. Room 353
                         Los Angeles. CA 90012

                         (213) 237-1209          (213) 237-1445 (FAX)

 I~A.  County              Los Angeles County                      contact: Theresa Dodge
 San. Districts            Sanitation Districts
                         P.O. Box 498
                         1955 Workman Mill Road
                         Whittier. CA  90607

                         (310) 699-7411          (310) 692-5103 (FAX)

 Orange County   Orange County                  contact: Adriana Renescu
 San. Districts            Sanitation Districts
                         P.O. Box 8127
                         10844 Ellis Avenue
                        Fountain Valley. CA  92728-8127

                         (714)962-2411          (714)962-6957 (FAX)

 U.S. EPA                U.S. Environmental Protection Agency
DJE Project             Design for the Environment Project
                        Pollution Prevention Information Clearinghouse

                        (202) 260-1023          (202) 2604178  (FAX)

                APPENDIX  C
Summary:   Best Management Practices  (BMPs)
             for  Soiled Textiles


             Best Management Practices (BMPs) for Shop Towels*

  BMPs for the Customer

  DO:        o Use non-hazardous cleaning solvents whenever possible

              o Use cloth or other durable material shop towels

              o Wring out soiled towels before placing in collection drums

              o Use centrifuge or mechnical ringer, if appropriate

              o Make sure no towels bearing free liquids are placed in drums

              o Make sure liner system (nylon or mesh bag) is in good working
                order and hangs at correct height

              o If excess liquid collects at bottom of drum, decant into waste solvent
                collection drum; manage the liquid appropriately

              o  If collected liquid meets RCRA criteria (listed, characteristic, etc.),
                manage  as a hazardous solvent waste

             o  Always collect, store, and transport in closed containers

             o  Manage  containers holding flammable materials according to
                all local fire department standards

             o Share your Material Safety Data Sheets with route salespeople
       NEVER:    o Air dry soiled shop towels

                   o Pick up spills of hazardous liquids with towels

                   o Dispose of excess chemicals by pouring onto  towels

                   o Put towels with free liquids in collection system

                   o Allow towels in drum to contact excess liquid (liner
                     should always hang high enough to prevent this)

                   o Pre-wash or launder shop towels on your own
      1 BMPs summarized (in shortened form) from Washington State Dept. of Ecology
(DOE) July 1992 Focus handout; Minnesota Pollution Control Agency (MPCA) Oct. 1989
memo; and Institute of Industrial Launderers (IIL) and Textile Rental Services Association
(TRSA) 1992 brochure "Management Practices for Soiled Reusable Textile Handling."

            Best Management Practices (BMPs) for Shop Towels2
 BMPs for the Laundries

 DO:        o  Let your customers know that you cannot accept shop towels
               bearing free liquids

             o  Work with customers to outline acceptable and non-acceptable
               practices to minimize free liquids on towels (start with the
               summary of customer BMPs provided)

             o  Educate route salespeople on both customer and laundry BMPs; set
               minimum standards for them to accept or refuse pickup

             o  If refusal notice is given, have follow-up discussion with the
               customer so they know how to avoid future refusals

             o  Establish in-house procedures for the safe receipt, handling,
               and processing of soiled shop towels

             o Make sure all activities associated with transporting and  handling
               industrial textiles  comply with applicable EPA, OSHA, DOT, and
               other federal, state, and local regulations

             o Incorporate BMP instruction into training of all laundry employees


            o Telling your customers about state and local pollution prevention
               programs that could help them minimize their wastes

            o Handing out free industry-specific pollution prevention brochures
              that have been developed by state and local agencies
      NEVER:   o Accept free liquid bearing towels

                  o Transport or store soiled shop towels in open containers

                  o Allow mis-management of solvent which collects in drum
                    (e.g., do not pour down drain)
      2 BMPs summarized (in shortened form) from Washington State Dept. of Ecology
(DOE) July 1992 Focus handout; Minnesota Pollution Control Agency (MPCA) Oct. 1989
memo; and Institute of Industrial Launderers (IIL) and Textile Rental Services Association
(TRSA) 1992 brochure "Management Practices for Soiled Reusable textile Handling."

           APPENDIX  D
Waste Exchange Information:  Calmax


                            ALMAX UPDATE
                        Joyce Mason
                CALMAX Coordinator
              ALMAX First-Year Totals Soar.
              Your eyes are not deceiving you!
 Since the last Update, reports on the amount of
 waste diverted during the first year of publication
 of the CALMAX catalog  sprocketed, from an
 estimated 6400 tons to nearly 112,000! (See Match
 of the Catalog, September/ October 1992, for

        That's the good news. The
 "bad" (or at least limiting) news
 is that since neither the
 California Integrated Waste
 Management Board (Board) nor
 the Local Government Commission
 (LGC)  is directly involved in the business-to-
 business exchanges CALMAX helps bring about,
 we will probably never know all the numbers.

       The  LGC is a nonprofit, nonpartisan
 membership organization of local elected officials.
 As you may know,  the LGC  jointly operates
 CALMAX under contract with the Board and is
 directly involved in many day-to-day CALMAX
 program operations, including receipt of your
 Successful Exchange Forms. After your listings run
 two catalogs, an LGC/CALMAXstaff member will
 call you to find out if you want to continue your
 listing—and whether or not you have made any
 successful exchanges that you have not yet reported
 to us.

       But in a busy world with finite resources,
 we have limited call-back  capabilities on those
participants not reached in the first few tries. Fred
WetzeTs successful transactions, connections made
 through CALMAX, illustrate what a difference just
 one participant's report can make. Your reports are
 absolutely essential to us to keep this program
 going and growing. We hope it s a small price to
 pay for our free resource matchmaking service.
 Thanks for keeping us informed

       User Survey. We have had few, but very
 positive responses so far on the survey printed in
 the last catalog. We will follow up with a telephone
 survey to a representative sample of our subscriber
 list in the near future.  Thanks  for taking a few
 minutes to talk to us when we call

       User Group. One of our subscribers recently
             suggested we start a CALMAXuser
                group. A possible way to begin
                  might be with semiiannual
                  meetings in Northern  and
                 Southern California, focused
            on how to maximize trades through
 the catalog and other ways to reduce, reuse, and
 recycle. If you are interested in this concept or have
 ideas to add, please call me at (916) 255-2369.

      Conferences and Events. We brought the
 CALMAX booth to Eco Expo in LA, Mardi, 12-14.
 I'll be speaking and chairing a reuse panel at the
 Pacific Recycler's Expo in San Jose, April & If you
 haven't seen  the  CALMAX   slide show or
 information table, stop in and meet us. I'm idso on
 the agenda for the May 21  California Resource
 Recovery Association (CRRA) luncheon in Fremont,
 forking with Reuse Industries." For information
 on any of these events, call us at  CALMAX (916)

      This month's catalog ushers in the Spring
Season, that wonderful time of year for cLan-up
and new beginnings. It's the perfect time to find
new materials to list in the CALMAX catalog. Plant
a seed for reuse and watch it  grow!

   916-255-2369 • SOO-553-2962

                                                                 Prt» or Charge

                        , votum* or oorrtairwr •&•

                              tf recurring. hc%* often
 Check the appropriate category for this material or product: check one box only
D  RusaEfi
The CALMAX Catalog advertises listings by region and by material type. Please check the appropriate region where your
material is available or wanted:
            D  RS>OWG
            a  SACRAME^fTO/STOC^aON
            D  SAN FRANCSCO/SAN X»E
               SANTA ROSA/OAKLAND
                          D SANTA BARBARA/VENTURA
                          D SUSANVUE/AITURAS
                          D TAHOE/RENO
                          D OUT OF STATE
                          D Ail OF CAJJFORNA

                             TYPE OF BUSINESS:

    c/o Local Government Commission
    90912th Street, Suite 205
    Sacramento, CA 95814
    (916) 448-1198 • FAX (916) 44S-8246
         CALMAX raerws OM ri^ht to not list a m*l«rlja, or to «lit
              Womudon provicUd by th* lutu\g pvty.
                                                  LISTINC DEADLINES:
                                    Received bj:
                         MAY/JUNE       4/21y93
                         JULY/AUO        6/23/93
                         SEPT/OCT        8/25^3
                         NOV/DEC       1CV2Q/93

                        I!  OW TO USE THIS CATALOG
Listings are divided into three main sections.

   * Available listings
   * Wanted listings
   * Regional listings — abbreviated versions of all listings from the first two sections organized
   into tne regions sKown on the next page.

Within the three sections, listings are grouped
into the 15 Material Categories below.
Material Categories

 (furniture, appliances,
 machinery etc,..)
 ^p^T<<^»jr^™»Y^WV*-"^^* ?*^i Z'i ~ ' t^^
To Place a Listing with CALMAX

If you are looking for, or want to get rid of a nonhazardous material,
and would like to advertise with CALMAX use the Listing/Contact
Form on the last page of this catalog.
Making an Exchange

All arrangements are worked out between the interested parties. Any costs, charges/ prices, etc are negotiab
between the parties. For instance a material may be offered for free/for hauling costs or for a price.
Please refer to the disdabner on pagel.

 6    	^=======^====

                                      1ST OF THE MONTH
                                     SMALL BUSINESS DEVELOPMENT
                                        CENTERS OF CALIFORNIA

 The Office of Small Business of the California Department of Commerce provides management and
 technical assistance to small businesses, primarily through the numerous Small Business Development
 Centers located throughout the State. Information and resources covering initial start-up requirements,
 financing options, marketing, and manufacturing as well as other forms of assistance are available
 through the Center*. Contact your local Center, listed below, for more information and assistance.
    Central Coast
    Small Business Development Center
    6500 Soquel Drive
    Aptos, CA 95003             (408) 479-4136

    East Bay
    Small Development Center
    2201 Broadway, Suite 814
    Oakland, CA 94612           (510)893-4114

    East Los Angeles
    Small Business Development Center
    363 S. Park Avenue, Suite 105
    Pomona, CA 91766           (714)629-2247

    Gavilan College
    Small Business Development Center
    5055 Santa Teresa Boulevard
    Gilroy,CA  95020             (408)847-0373

    Greater Sacramento
    Small Business Development Center
    1787 Tribute Road, Suite A
    Sacramento, CA 95815         (916) 920-7949

    Lake and Mendodno County
    The Business Development Center of Lake and
    Mendodno Counties
    341 North Main Street
    Lakeport, CA 95453          (707) 263-0630

    Small Business Development Center
    1012 Eleventh Street, Suite 300
   Modesto, CA 95354          (209) 521-6177

   Napa Valley College
   Small Business Center
   100 Coombs Street
   Napa, CA 94559             (707) 253-3210
 North Coast
 Small Business Resource Center
 882 H Street
 Crescent City, CA 95531      (707) 464-2168

 San Diego
 Small Business Development Center
 402 W. Broadway, Suite 1000
 San Diego, CA 92101         (619) 544-1350

 San Joaquin
 Small Business Development Center
 5151 Pacific Avenue
 Stockton, CA 95207          (209) 474-5089

 Small Business Development Center
 550 High Street, Suite 3
 Auburn, CA 95603           (916) 885-5488

 Solano County
 Small Business Development Center
 320 Campus Lane
 Suisun, CA 94585            (707) 864-3382

 Southwestern College
 Small Business and International Trade Center
 7101 Siempre Viva Road, Suite 200
 Otay Mesa, CA 92173         (619) 661-1135

 Small Business Assistance Center
 260 Cohassett Avenue
 Chico, CA  95926             (916) 895-9017

 Weill Institute
Small Business Development Center
2101 K Street Mall
Bakersfidd, CA 93301         (805) 395-4148



             A Cooperate Prelect
             Protection tyncy
                                                                                 :h« way in which U searched out safer alter-
                                                                                 natives illustrate* how printers tan achieve
                                                                                 iignlfvcont environmental reiuln.
                                                                                        In particular, this fasc study ulu»-
                                                                                 trotiK                       ..    . .
                                                                                  . How a self-audit of solvent* used la print-
                                                                                  Ing operations led to the »ut*tttufcoo of
                                                                                  more rfivtronmentaUy appropriate scivgno.
                                                                                  • How the use of a <:enT^^^ig« to extract sol-
                                                                                  vents fiom industrial wipen pnor to laun-
                                                                                        rauJted in i«duad solvent in the
                                            MANAGING SOLVENTS
                                                     AND WIPES
                                                 eing responsive to the «nviror.m«m
                                                 meal* lwr*ing new proctdures and
                                                   r.Q new too*! to do the icroe .<*>
    uiir.Q new too*! to o te icroe .
w\th taw haiOJd, D«dsSon* about the par-
chcuc of equipment and chemicals for pr«J-
So^s or Soi P^Olor. F"^"-^
not only on oat. avoRabUliy, and perfor-
                      r ^v\n>nmen-aJ
                                             not only on oat. avoRabUliy,
                                             nonet, but also on whether ^v\n>n
                                             Sjuiiintnttconbf mtt. »«'
                                             mental r^iUements mtcni u
                                             *« comparative human ana1 eeo.ogjeal
                                             riiki of the olt£mauv« b«^9 considered.
                                             °      Tlus c«. study is brought to you
                                             by the U.S. tnvironm«nlal
                                    •   e  this company wv^ money
                                    its efTcrtt lo ax safer jolventi and reduc*

                                    The itoiy of thii comparV* expertenC*. end
                                    the  «te?« U follows! show how prt>b:ero»
                                    can 'Deeome opportunltiw and how environ-
                                    mental planmng oart be good for buime*.

                                            The John Robtru Company u a
                                     commercial printer of aonual "F***
                                     brochures, cntalogi. forms, Umited edition
                                     f.ne crt pnnu. and ducct moU piects uring
                                     both sSeet-fcd offeel and w«b oft^r printing
                                     proased towels 01 wlperx for pce« deanup.
                                                                                     H>« comply was wnding «• l:oi«d toweU

 to on industrial laundry for cleanly,
 and wl*Jj them went a great deal of
 ink and "spent* solvents. The pret-
 ence of the** joints In the wipers
 was orating g problem for the laun-
 dry ond for the local sanitary xwtr
 system that handles the effluent from
 the laundry. The two mojor concerns
 were volatlUly and flamrnoWlity.
    T?K local regulatory agency
   of preached the induitrial laundry
   because too much nthml utu being
   muted out a/TV f
v«nt left in thj toweU.
 The Nature
 OfThe Solvents

 Finding An Alternative
         The first step wtu to examine
 the nature of the solvent! u«ed to
 clean the pro*** to »*« If a l*u
 volatile (ubstitutt could bf ascd.
 More information wu< needed about
 the taski voKtnts must accoroplbh
 and the condition* under which thu^
 solvent* perform.
        A* a result of thorough dil-
 cutrioo Mth everyone involved in the
 process, the company prepared a Ust
 of neccMary solvent criteria:
        •  For washing pr*« blan-
 kets, a solvent must work qmckly to
 cut ink, leavne the blanket free of cny
 oily retidu*. and djy almost uximecU«
 oteJy. Time and the  aWllty to get
 bock up to color quickly 1* critical
 during a press run.
        • For deantog the metal
 para of a press,  a slower-working sol*
 vent would be suitable a* a general
 preu wash.
        •  For dear.ing the chain of
 ink rollers, a solvent  that is slow to
 evaporate is needed.  Thu solvent
 mart not flash off beta* It ha* gone
 through the entire sequence of rollers
 or it will rail to dean them
        •  On a limited basis, a very
 aggressive solvent Is needed for
 removing hardened Ink that some-
 times collects en the press.
        In light  of these criteria, the
 company's tint task was to find a
 blanket wo«h that balanced these
 production needs with the environ-
 mental needs of  leu volatility and
Horn mobility.
        Press operator* prefer sol-
 vents that (loth off quickly ond do
 not require a lot of wiping oc leave
 behind an oily film. Unfartuaottry,
 most solvents with these desirable
 properties aUo create problems far
 ir.dustna! laundnej by exceeding the
 Li: level. When the John Roberts
 Company audited its operations, it
 discovered that press operators had
 been using a highly volatile solvent
 called rype wain 05 a general, aE-
 purpose solvent, indudjng for blan-
 ket dcanlng.  Th^ product was a
 blend of acetone, toluene, methyl
 ethyl ketone (MtK). and ixjprooyl
 alcohol and contributes not only to
 in-plant volatile oryarm; compounds
 (VOCi) in the air, but also to prob-
 lems with the laundry^ effluent
        ThJ» solvent was never
 Intended for all-purpose us*,  but
 using the solvent had become a habit
 that was hard to break.  Because it
 /lashed off so readily, no time wax
 lost by press personnel. It wa< easy to
 see why the solvent was so popular.
       As the company ana-
 lyzed the product's proper-
 ties farther, however, It
 found that almost
 one-half the total
 volume of the
solvent was
 wasted. It
simply evap-
orated before

 -ie work could be performed!  The
 ool was to find a substitute solvent
 nat was better matched to the tasks
 : was to perform and that did not
 ubstanually affect work procedures
 >r productivity.

 Work Together
 To Implement Changes

       It Is important to recognize
that it was not sufficient to simply
look for a technical solution to the
problem.  For success to be  possible,
the support of upper management
was vital, as well as the cooperation
and understanding of press person*
nel. Management gave 1U support by
assuring plant personnel that learn-
ing to work with new solvent* might
Involve some procedural changes
that could affect productivity slightly,
but that *maU  losses would not reflect
negatively on overall performance
evaluations. Input was sought from
each press person and floor helper.
The reasons why it was necessary to
change solvent* and how the change
was to be accomplished were
explained to them.
        The raising of awareness in
the effort to find a substitute resulted
in a reduction  in the misuse of the
type wash solvent. Typ« wash usage
was reduced from 152 to 5 fifty-five-
  gallon drums in the first year. The
       company still usei type wash,
           but only where its use
              can be justified. A
                new replacement
                  solvent, an ultra-
                    fast blanket
                     wash, was
                     blended espe-
                      cially for the
                       and per-
                       wtll with
                       respect to
                       speed and
                       lack of an
                      oily film.
Only 38 ftfty-five-gallon drums of this
new blanket wash were purchased in
the first year. Even after including
the purchase of the replacement sol-
vent, the John Roberts Company real-
ized a savings of more than $18,000
in the first year by chang-
ing solvents and using
them more prudently.
More importantly, by
selecting a replacement
solvent blend with a lower
evaporation rate and by strictly limit-
ing the use of type wash, the contri-
bution of vapors from the John
Roberts Company to the laundry's
effluent no longer exceeded the LEL
and was no longer a concern.

Make Additional
       Thert were, however, some
lingering concerns with the new sol-
vent  One ingredient in the new
blanket wash was 1,1,1
trichloroethane (TCA), which gave
the blend some of Its performance
characteristics, but is being phased
out because it is an ozone depleter
and a suspected health hazard. TCA
will soon be banned by the Montreal
Protocol, an international treaty to
eliminate the manufacture of o*one
        The company therefore con-
tinued it* Investigation of alterna-
tives, this time with an emphasis on
reduction of fugitive VOC emLwions.
It reformulated its blanket wa«h to a
less volatile press wash that contains
no TCA, The company approached
its scorch for a substitute with
reduced VOC emissions with toe real-
ization that vapor pressure plays an
important role. A solvent with a
lower vapor pressure will evaporate
less readily and wllJ release leis VOC
emissions to the air Therefore, whtn
the goal is reduction of fugitive VOC
emissions, volatility should be
        Early results from this
change show that because consider-
ably less solvent is  lost to the air
through evaporation, the company is
purchasing four fewer drums of sol-
vent each month.  However, four
more drums of spent solvent are
removed from the ragi and sent off-
sate for fuel blending.  In
spite of the costs to
manifest and chip this
solvent the company
still sav«s $100 per
month. In addition, the
John Roberts Company has lower
fugitive emissions and a  healthier
        During trials for new solvent
blends, the company's management
came to a critical realization:  the
wa^ in which a product is used is key
to its performance.  The company
found that testing the same p.roduct
on different presses using different
aews produced widely varying
results. The success of tht solvent
changes the company made was due
largely to the development of a very
specific procedure  for solvent use,
which was developed by the press
operators themselves.

 The Volume
 Of Solvent

        The second objective was to
 reduce the volume of solvents left in
 the towel*. With the help of its trade
 association, the Printing Industry of
 Minnesota. Inc. (P1M), the company
 began to explore ways to "wring out"
 the wipers.
        The first step was to make
 jure efforts to train employees not to
 dump excess solvent in the pile of
 used wipers hod not eroded.
 Confident that training had awured
 that the rags put in the used rag con-
 tainer retained the "minimum"
 amount of solvent, the company
 explored the use of a commercial
 grade laundry centrifuge to sepa-
 rate out any remaining solvent.
 The company was surprised to learn
 that the "minimum1' amount of sol-
 vent retained in the wipers was much
 more than originally thought.
        Now, before wipers are sent
 to the laundry, they arc spun  In a
 safe, explosion-proof centrifuge,
 which extracts between 2*/2 and
 3*/2 gallons of "spent* solvent for
 every load of approximately 220
 wipers. This amounts to quite a lot  of
solvent over time. The recovered sol-
vent is now reused throughout the
 plant In a series of parts washers to
 clean press ink trays, instead of going
 out with the laundry, and the spent
solvent is then sent to a fuel blender.
 Reuse of this solvent eliminated the
purchase of more than one drum a
week of virgin solvent for use in parts
washers throughout the
plant. The centrifuge
recovery program has
saved the company
more than 534,000 in
 ihe first year alone,
 resulting in a quick pay-
back on the $15,000 centrifuge. The
centrifuge has also resulted in a sue-
ablc reduction in the volume of soU
vent sent to the sewer system. Using a
centrifuge for this purpose might not
be allowed in all states, but other
options could & available.

The Design

For The



   This cote study described how a
   company systematically assessed
   a problem, applied knowledge
   acquired through that assessment
   (along with the assistance of its
   trade association),  and dealt with
   the problem In in context.
        The result is a methodology
that is affordable, effective, readily
adaptable, and can be trans/erred to
other printers. Environmental bene-
fits demonstrated in this case study
include reduced fugitive air emis-
sions, less solvent discharged to the
water system, and decreased toxic
chemical purchases. Waste solvent u
being used for energy recovery.  In
addition, the company has complete-
ly eliminated its use of TCA, and the
safety  of its work environment was
greatly improved.
        The methodical evaluation
of a problem, leading to solutions
aimed at reducing the creation of
pollutants at their source, is what
EPA's  Design for the Environment
program is seeking to encourage.
While  this story illustrates a method
for evaluating alternatives, the com-
pany did not have access to impor-
tant risk information.  The OfE
Printing Project seeks to provide  infor-
mation to industries and companies
(often  through their trade associa-
tions) on the comparative riik and
performance of alternative chemicals,
processes, and technologies, so that
printers are able  to make more
informed decisions. EPA will make this
information available Jn the form of a
"Substitutes Assessment" later in  1993.
        The search for alternative
chemicals and new technologies
begins with today's success. Assisting
in the search for and evaluation of
alternatives is the goal of EPA's DflE
program. With this case itudy and
others like it, we hope to Illustrate the
application of this goal and the pur-
suit of continuous improvement
        If you would like more
 information about the John Roberts
Company's experience, contact:

Jeff Adrian
John Roberts Company
9687 East River Road
Minneapolis, MN 55433
Telephone: 612-755-5500
Fax: 612-755-0394
  If you have a success story to
  share, and would like us to help
  you publicize it
  if you would like more informa-
  tion about the Design for the
  Environment program, contact

  The Pollution Prevention
  Information Clearinghouse
  at the U.S. EPA
  Phone: 202-260-1023

                       APPENDIX F
A Fact Sheet on  "National Emission Standards for  Hazardous
         Air Pollutants from  Dry Cleaning Facilities



                            FACT  SHEET


          Under Section 111 of the Clean Air Act (CAA). a new
          source performance standard to limit emissions of
          vo^aUle organic compounds from perchloroethylene (PCE)
          dry cleaners proposed on November 25, 1980
          (45 FR 78174).

          Intent to  list PCE as a potential toxic air pollutant
          fSr regulation under Section 112 of the CAA published
          on December 26, 1985 (50 FR 52880).

          Private  citizen's group from Oregon, Francis P. Cook,
          et al.,  petitioned the Administrator of the EPA to
          regulate PCE dry  cleaners.

          A Consent  Decree  was issued on March 16,  1990-, in which
          the EPA  Administrator  agreed to  sign P^^atlonal
          Emission Standards  for Hazardous Air Pollutants
          SfiSSil? under  Section 112.for PCE  dry cleaners within
          1 year and promulgate  within 2 years following
          enactment  of  the  new amendments  to  the CAA.

          Affected sources:  Dry cleaning  dryers,  dry:to-dry
          machines,  transfer  machine systems,  and  auxiliary
          equipment  at dry  cleaning  facilities that use PCE as a

          Projected  growth:  At  present,  there are approximately
           25?200 dry cleaning facilities.   Of these, 9,700
           existing commercial and  industrial dry cleaning
           faculties are uncontrolled and would be subject to to
           regulation.  In addition,  7,400 new dry cleaning
           machines  (replacing those that have retired) are
           projected to beginoperations between 1991 and 1996.
           Those machines purchased after 1991 will require
           controls  and will emit fewer pollutants from process
           A major source dry-to-dry machine is one  that consume!,
           3,100 gallons per year  (gal/yr) or more of  PCE. and a
           ™»ior source transfer machine systems  is  one that
           consumes  2?000 gal/yr or more of PCE.  Area sources are

          those machines consuming less than these amounts of PCE
          Equipment standard to limit process vent emissions of
          PCE and pollution prevention practices to limit
          fugitive PCE emissions from dry cleaning facilities.

          Requires use of a carbon adsorber,  refrigerated
          condenser, or equivalent control device (95 percent
          control) for both major and area source dry-to-dry

          Requires use of a carbon adsorber or equivalent control
          device  (95 percent control) for new, reconstructed, or
          uncontrolled major and area source transfer machines.

          Requires use of a refrigerated condenser or equivalent
          control device (85 percent control) for existing
          refrigerated-condenser controlled area source transfer

          Pollution prevention practices—such as conducting
          weekly leak inspections, storing all PCE and PCE wastes
          in tightly sealed containers which are impervious to
          the PCE and do not react with the PCE, and minimizing
          door opening time--are required to control fugitive PCE

          New dry cleaning facilities must achieve compliance
          upon startup.  Existing dry cleaning machines that are
          larger than 50 Ib (22.7 kg) must achieve compliance
          within 18 months of the 4ate of promulgation.  Existing
          dry cleaning machines that are 50 Ib \Ti.1 Kg) or
          smaller must achieve compliance within 36 months of the
          date of promulgation.

          Exemption:  Dry-to-dry machines consuming less than
          220 gal/yr of PCE and transfer machines consuming less
          than 300 gal/yr of PCE are exempt from the requirements
          of the standard, except for submitting an initial
          consumption report to show that they qualify for
          exemption status.

          Operation and Maintenance/Work Practices

               To ensure proper operation of a carbon adsorber,
               desorption is required at least each time the
               machine cleans 6.6 pounds (Ib) [3 kilograms  (kg)]
               of articles per 2.2 Ib (1 kg)  of activated carbon.
               Steam pressure must be at least 1.7 atmospheres
               (170 kiloPascals); air flow capacity must be at
               least 10.6 cubic feet per second (0.3 cubic meters

     per second) ;  and  no  bypass to the atmosphere is

     To ensure proper  operation of a refrigerated
     condenser,  no exhaust gases are ^lo^d.£°J*h
     vented  to the atmosphere or circulated through a
     ventless machine  until the
     temperature on the outlet side of ^
     condenser is less than or equal to  4

     Before  disposal,  cartridge  filters  must  be  drained
     in their  housings or in a sealed container  for at
     least 24  hours, or must be  dried in an enclosure
     vented  to the control device.

     A weekly  inspection for liquid and  vapor PCE leaks
     is required using either visual  inspection  or a
     portable  halogenated-hydrocarbon detector.   The
     components to search are:   hose  connections,
     unions, couplings, and valves; machine door
     gaskets and seat ings; filter head gasket and
     seatina;  pumps; solvent base tanks  and solvent and
     waste containers; water separators; filter  sludge
     recovery; distillation units; diverter valves; and
     cartridge filters.

     If any leaks are found, they must  be repaired or a
     purchase  order for repair  parts  must be initiated
     within 3  working days.

Report ing/Recordkeep ing

     Owners/operators must keep records of the amount
     of PCE solvent consumed,  the results of weekly
     inspections, and dates of when repairs are  made or
     purchase orders  for repair parts initiated.

     If using a  carbon  absorber for compliance,  the
     frequency  and  period of desorption must be

     An initial report is required from all  business
     owners or  operators, including name,  address,
     brief  description of dry cleaning  machine,
     operating  design capacity, and annual PCE  solvent

      For  both major and area sources, an  initial
      statement of compliance is required  stating type
      of control device used to  achieve  compliance.

                If  PCE  consumption level increases so thai-
                exemption  status no longer applies  a
                report  must  be  submitted to indicate tnar
                compliance with the standard is  ^/achieved.

                  ?€yene missions:  reduction of  16  ooo
                  tons) from projected 1996 emission  levels.


          Total maximum national increase in electricitv ,i«*  *
          4 gigawatt hours per year (GWh/vr? in iQQ<  * y  S  of
          facilities and 5 GWh/£r for nev^aciUties
          needed to  operate the control devic^     '

              , -...^.. wA^.A  */«  iuutea  to  ana  treat*»H Hvr * -. wi •  i
         owned treatment works.             Created by a publicly

         Solid Waste
                                         of 40 Mg  (40  tons)  in
         «..7.7u,  wuxtn win D€ Dicked nn Ki* _ u    j     wwn»;  xn
         collection service?         P  Y * hazard°us  waste


         No  incremental impacts.

         Annualized  Cost
       Capital  Cost

Projections including those existing facilities
subject to the exemption could be as low as
$26 million.

For a typical model facility,  such as a 35-lb
dry-to-dry machine, capital cost would be about
$6;800 if installing a carbon absorber or about
$6 300 if installing a refrigerated condenser.


                      APPENDIX G
Flow Diagrams for Pretreatment and Dry Cleaning Processes


       Water Wash (100%)
 SW: Bags, Boxes,
  Drums, Pallets,
Acid Added if
• Laundry Chemicals
• Soiled Materials Sorted
                     Water Wash
                     Extractor: Water
                     to Treatment
                                            Product to
                    Pit 1
 Pit 2
               Finishing: Drying,
               Pressing, & Folding
                    Pit 3
                    Pit 4
                 Tank w/ Oil
                   Settling Pit
                        Water to
                  -^ [   Sewer

        SW: Bags,
      Boxes, Pallets,
              Shop Towels
              Water Wash
                       • Laundry Chemicals
                       • Treatment Chemicals
                       • Soiled Materials Sorted
Elec. & Gas
             Extractor: Centrifuge
              & Hydraulic Press
    SW: Lint from
SW: Old Uniforms
 to Rag Manuf.
                            Finishing: Drying,
                           Pressing & Folding
                   Wash Water
                   Holding Tank
ime (Floccing)-
cid (Cracking)	^
Water Wash
                         Product to
              Oil Holding Tank
                (2,400 gal.)
             HW: 300 gal./day
                                                 Clarifier w/
                                                 Oil Skimmer
                                                     Water to

Water Wash (84%)
       • Laundry Chemicals
       • Soiled Materials Sorted
          Water Wash
                               Product to
                       Finishing: Drying,
                      Pressing, & Folding
     2 Chamber
     Baffle Basin

     /  Water to  \

 Two Dry Cleaning Units (16%)
   75 oz Water/load
  15 oz Detergent/load
          Soiled Garments
Solvent Storage
Dirty Solvent
  HW: Still Bottoms
   4 or 5 16-gal.
            Water & Soluble
           Matls. to Hot Water
            Tank for Reuse

                Water Wash  (75%)
     SW: Bags,
    Boxes, Drums,
     Pallets, etc.
  Water Preheated,
    Electric, Gas
      10-20% Clean
      Rinse Water
Coagulant &
 pH Control
 • Laundry Chemicals
• Soiled Materials Sorted
 • Treatment Chemicals
                             Water Wash
     Water to
                    Primary Separator, 3
                  Chambers, Induced Air
                  Flotation w/ Oil Skimmer
                                                   Product to
                                        Finishing: Drying,
                                        Pressing, & Folding
                                               Water to
                            Vacuum Drum
                                                        HW: Filler
                                                      Cake or Non-
                                                      hazardous 8.5

         SW: Bags, Boxes?
          Drums, Pallets,
                         Water Wash W/ 25% Shop loweis

           • Laundry Chemicals
           • Soiled Materials Sorted
                                  Water Wash
                           Tank w/ Mixer
                            30,000 gals.
   Fenous Sutfate& Lime
       Anionic Polymer
                        Rapid Mix Tank
     Slow Mix Tank
HW: Filter
Cake 60
          Solvents to
        Surge Tanks
                          Shaker Screen
            HW: Lint
          4  Drums/mo
                                       Product to
                                Finishing: Drying,
                                Pressing, & Folding

         Dry Cleaning  (25%)
        Two  Dry-to-Dry Units
  75-oz. Water/load
 15-oz. Detergent/load
                            Soiled Garments
Solvent Storage
Dirty Solvent
  HW: Still Bottoms
3 16-gal. drums/mo
                              55-gal./day Water &
                                 Soluble Matls.
                                ReUsed in Wash