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ASSESSMENT OBSERVATIONS AND OPTIONS
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
reduction.
THE PLANTS
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
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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
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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.
PRETREATMENT PROCESSES
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
diagrams.
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
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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
once-a-month.
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.
RESOURCE CONSERVATION PROGRAMS
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.
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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?
Energy
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.
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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);
and
$11,000 ($132,000 annually).
Water
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
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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
assessments.
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
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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
POTW.
HAZARDOUS WASTES GENERATED
The hazardous wastes generated by laundry and treatment processes are:
filter cake:
RCRA hazardous;
California List; and
Non-hazardous;
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.
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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.
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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).
NON-HAZARDOUS SOLID WASTES GENERATED
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.
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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
recycling."
Steel drums "are picked up by the suppliers." The treatment chemical
supplier "picks up their drums." The chemical supplier "takes the drums
back."
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
WASTE REDUCTION OPPORTUNITIES
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.
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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:
CONSERVE RESOURCES AND PROTECT THE ENVIRONMENT
SUBSTANTIAL ECONOMIC RETURN
REDUCED LIABILITY
EASE OF REGULATORY COMPLIANCE
GOOD PUBLIC IMAGE AND MARKETING TOOL
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
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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
image.
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
reside?
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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.
14
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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
safety.
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
15
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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.
16
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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
lost.
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.
17
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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
including:
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).
18
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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
regulations.
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.
19
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6. Inaugurate a Comprehensive Paper and Paper Products Recycling
Program
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
suppliers.
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.
20
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8. Reduce. Recover and Reuse Solvent from the Dry cleaning
Process.
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
21
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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
stored.
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
door.
Repairing holes in air and exhaust ducts.
Checking hose connections and couplings.
Cleaning lint screens to avoid clogging fans and condensers.
22
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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
correctly.
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
purchase.
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.
23
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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
successes.
24
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INDUSTRIAL LAUNDRIES WITH VEHICLE MAINTENANCE
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.
25
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APPENDICES
APPENDIX A — Waste Reduction Planning Program
APPENDIX B — Pollution Prevention Bibliography
APPENDIX C — Summary: Best Management Practices (BMPs) for Soiled
Textiles
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
Processes
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APPENDIX A
Waste Reduction Planning Program
The essential elements of an effective company-wide program are:
TOP MANAGEMENT COMMITMENT AND SUPPORT
EXPLICITLY DEFINED PROGRAM AND OBJECTIVES
ACCURATE ACCOUNTING OF WASTE STREAMS AND THEIR
TRUE COSTS
A PERVASIVE WASTE REDUCTION ETHIC
INFORMATION AND TECHNOLOGY SOURCES
PERIODIC PROGRAM EVALUATION AND REASSESSMENT OF
WASTE REDUCTION OPPORTUNITIES
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.
UNDERSTANDABLE.
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 ENVIRONMENTAL POLICY
[ 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
quality.
_Reuse and recycling of materials has been and will
be given first consideration prior to classification as waste
for treatment and disposal.
[ Corporate Official ]
Signed:
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
estimates.
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.
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APPENDIX B
Pollution Prevention Bibliography
-------
POLLUTION PREVENTION RESOURCE DOCUMENT LIST
Industry
Auto Repair
Printer*
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
Recycling
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
Cal-EPA
DTSC
L.A. City
HTM
L.A. City
HTM
Cal-EPA
DTSC
Cal-EPA
DTSC
Cal-EPA
DTSC
Cal-EPA
DTSC
U.S. EPA
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
Cal-EPA
DTSC
L.A. City
HTM
L.A. City
HTM
Cal-EPA
DTSC
L.A. County
San. District!
-------
POLLUTION PREVENTION RESOURCE DOCUMENT LIST
(p. 2 of 4)
Metal Finisher*
(can't)
Metal Fabricators
Aerospace
Printed Circuit
Boards
Furniture
Refinishen
Jewelry
Paint
Metal Finishing: Pollution
Prevention Opportunities Guidelines
Hazardous Waste Reduction
Checklist & Assessment
Manual for the Metal Finishing
Industry
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
Manufacturers
Printed Circuit Board
Manufacturing: Pollution
Prevention Opportunities
Guidelines
Printed Circuit Board
Manufacturing: Pollution
Prevention Opportunities
Checklist
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
Guidelines
Orange County
San. Districts
Handbook & Checklist Cal-EPA
DISC
Case Studies
Guidelines
Factsheet
Fact Sheet
Fact Sheet
Guidelines
Factsheet
Fact Sheet
Case Study
Fact Sheet
Fact Sheet
Directory
HTM
Cal-EPA
DTSC/L.A.
City HTM
Orange County
San. Districts
L.A. County
San. Districts
Cal-EPA
DISC
Cal-EPA
DISC
Orange County
San. Districts
Orange County
San. Districts
L.A. City
HTM
U.S EPA
RREL
L.A. City
Cal-EPA
DISC
L.A. City
HTM
-------
POLLUTION PREVENTION RESOURCE DOCUMENT LIST
(p. 3 of 4)
Paint (con't)
Pesticides
Waste Minimization for Fact Sheet
Auto Paint Shops
Formulators (Paint, Pesticides, Guidelines
Aerosols): Pollution Prevention
Opportunities Guidelines
Formulators (Paint & Pesticides) Factsheet
Pollution Prevention Opportunities
Checklist
Waste Minimization for Fact Sheet
Pesticide Formulating
Industry
Formulators (Paint, Pesticides, Guidelines
Aerosols): Pollution Prevention
Opportunities Guidelines
Formulators (Paint & Pesticides) Factsheet
Pollution Prevention Opportunities
Checklist
Cal-EPA
DTSC
Orange County
San. Districts
L.A. Count)'
San. Districts
Cal-EPA
DTSC
Orange County
San. District
L.A. County
San. Districts
-------
POLLUTION PREVENTION RESOURCE DOCUMENT UST (p. 4 of 4)
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
ALSO CONSIDER:
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
C
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
details.)
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)
255-2369.
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!
3
-------
cal
MAX
916-255-2369 • SOO-553-2962
MATERIALS LISTING/CONTACT FORM
NAME Of NONHAZARDOUS MATEHAL
D AVAJUVBLE Ofi D WANTED IN:
Ctty/Mgion
IF AVAILABLE IS MATERJA1. O FREE OR D FOPCHARGfc
Prt» or Charge
AMOUNT:
D ONE Tlfct ONLY OR D RECURSNG:
DESCRIBE YOUR MATERIAL BELOW:
, votum* or oorrtairwr •&•
tf recurring. hc%* often
Check the appropriate category for this material or product: check one box only
D CONSTRUCTOR
O COMAKERS
a DURABLE GOODS
D ELECTRONC
D GLASS
O METAL
D OQGANCS
D PAJNT/WAX
O PAUfB
O PAPER
Q PLASnC
D RusaEfi
O TEXTILE
D WOOD
D MSCEUANEOUS
The CALMAX Catalog advertises listings by region and by material type. Please check the appropriate region where your
material is available or wanted:
D BAXERSFIELD/FRESNO
D BSHOPAONE PINE/VTCTOWILLE
PALMDAL£VBAfiSTOW
D EL CENTRO/INOO
D EUREXAyCR£SC€NfT CJTY
Q LOSANGQfS/lONGBEACH/ANAHEM
D MONTEREY/SANTA CRUZ
D RS>OWG
a SACRAME^fTO/STOC^aON
D SAN BERNARONO/RfVERaDE
D SAN FRANCSCO/SAN X»E
SANTA ROSA/OAKLAND
D DO NOT RaEASE MY UST1NG INfORfMTJON ON NATONWtOC COMPLfTEfilZED BULLETT1N BOARD
D SANTA BARBARA/VENTURA
SANLUSO6SPO
D SUSANVUE/AITURAS
D TAHOE/RENO
D OUT OF STATE
D Ail OF CAJJFORNA
CONTACT NAME.
TTTLE/POSDON:.
NAME Of BUSINESS:.
ADDRESS:
TYPE OF BUSINESS:
CITY:.
STATE:
2P:
CA COUNTY:
PHONE: < L
COUNTRY:
FAX
9GNATURE:
MAIL OR FAX THIS FORMTO:
CALMAX-CIWMB
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
CONSTRUCTION
CONTAINERS
DURABLE GOODS
(furniture, appliances,
machinery etc,..)
ELECTRONIC
GLASS
METAL
ORGANICS
PAJNT/WAX
PALLETS
PAPER
PLASTIC
RUBBER
TEXTILE
WOOD
MISCELLANEOUS
IKEY TO LISTINGS
^p^T<<^»jr^™»Y^WV*-"^^* ?*^i Z'i ~ ' t^^
l|pot»caMK*^M;
'^^ss^^msi^^mm^^s^^^^^^^^^^^SM^m^^mii^m^^^msi^s^i
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 ^=======^====
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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
Merced/Modesto
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
Sierra
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
Tri-County
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
62
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APPENDIX E
-------
-------
A Cooperate Prelect
the
U.S.
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
B
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*.
Background
•P^
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.
Change
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
adequately
• 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
company
and per-
formed
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
Improvements
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
depleters.
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
considered.
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
workplace.
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.
-------
Reduce
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
Environment
Approach
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
or
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
Fax:202-260-0178
-------
APPENDIX F
A Fact Sheet on "National Emission Standards for Hazardous
Air Pollutants from Dry Cleaning Facilities
-------
-------
NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS
FROM DRY CLEANING FACILITIES
FACT SHEET
pACKGROUKD
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
solvent.
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
vents.
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
annually.
RECOMMENDED STANDARDS
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
machines.
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
machines.
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
emissions.
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
permitted.
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
recorded.
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
consumption.
For both major and area sources, an initial
statement of compliance is required stating type
of control device used to achieve compliance.
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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.
IHPACTS
?€yene missions: reduction of 16 ooo
tons) from projected 1996 emission levels.
Energy
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^ '
Wastewater
, -...^.. 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
Noise
No incremental impacts.
Annualized Cost
Capital Cost
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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.
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APPENDIX G
Flow Diagrams for Pretreatment and Dry Cleaning Processes
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Water Wash (100%)
SW: Bags, Boxes,
Drums, Pallets,
etc.
Acid Added if
Needed
Receiving:
• Laundry Chemicals
• Soiled Materials Sorted
Suppliers
Water Wash
Machines
Extractor: Water
to Treatment
Product to
Customer
I
Pit 1
Pit 2
5
Finishing: Drying,
Pressing, & Folding
Shaker
Screen
Pit 3
Pit 4
Heat
Exchanger
Tank w/ Oil
Skimmer
Settling Pit
Water to
-^ [ Sewer
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SW: Bags,
Drums,
Cardboard
Boxes, Pallets,
etc.
Terpene
Cleaner
Shop Towels
Water Wash
Receiving:
• Laundry Chemicals
• Treatment Chemicals
• Soiled Materials Sorted
Water
Preheated
Elec. & Gas
Extractor: Centrifuge
& Hydraulic Press
SW: Lint from
Collector
^\
SW: Old Uniforms
to Rag Manuf.
Finishing: Drying,
Pressing & Folding
Wash Water
Holding Tank
Shaker
Screen
ime (Floccing)-
cid (Cracking) ^
Batch
Treatment
Suppliers
Others
Water Wash
Extractor
Product to
Customer
Oil Holding Tank
(2,400 gal.)
HW: 300 gal./day
HW:
Sludge
Cake
Clarifier w/
Oil Skimmer
Water to
Sewer
-------
Water Wash (84%)
Receiving:
• Laundry Chemicals
• Soiled Materials Sorted
Suppliers
1
Water Wash
Machines
Extractor
Water
Product to
Customer
i
Finishing: Drying,
Pressing, & Folding
Collection
Basin
Shaker
Screen
2 Chamber
Baffle Basin
T
/ Water to \
-------
Two Dry Cleaning Units (16%)
75 oz Water/load
15 oz Detergent/load
Soiled Garments
170lbs.
Solvent Storage
PERC
Rotating
Cylinder
Dirty Solvent
Distillation
PERC
Solvent/Water
Separator
HW: Still Bottoms
4 or 5 16-gal.
drums/mo.
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
ReUse
Coagulant &
pH Control
Receiving:
• Laundry Chemicals
• Soiled Materials Sorted
• Treatment Chemicals
Suppliers
Water Wash
Machines
Extractor:
Water to
Treatment
Shaker
Screen
Equalization
Basin
Water
Primary Separator, 3
Chambers, Induced Air
Flotation w/ Oil Skimmer
Product to
Customer
Finishing: Drying,
Pressing, & Folding
Water to
Sewer
Sludge
Tank
Rotary
Vacuum Drum
Filter
HW: Filler
Cake or Non-
hazardous 8.5
Tons/month
-------
SW: Bags, Boxes?
Drums, Pallets,
etc.
Water Wash W/ 25% Shop loweis
f~
voc
Stripper
«
25%
Shop
Towels
Receiving:
• Laundry Chemicals
• Soiled Materials Sorted
Water Wash
Machines
Acid
Cracking
Equalization
Tank w/ Mixer
30,000 gals.
Treatment
pH2-3
Oil/Water
Separator
Fenous Sutfate& Lime
>>
Anionic Polymer
Rapid Mix Tank
Slow Mix Tank
HW: Filter
Cake 60
Tons/mo.
Suppliers
HW:
Solvents to
Fuel
Blending
2,000
Gate./mo.
Extractor
Underground
Surge Tanks
Shaker Screen
HW: Lint
4 Drums/mo
Product to
Customer
Finishing: Drying,
Pressing, & Folding
Water
Acid
Neutralization
Tank
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Dry Cleaning (25%)
Two Dry-to-Dry Units
75-oz. Water/load
15-oz. Detergent/load
Soiled Garments
ISOIbs.
Solvent Storage
PERC
Rotating
Cylinder
Dirty Solvent
t
Distillation
PERC
Solvent/Water
Separator
HW: Still Bottoms
3 16-gal. drums/mo
55-gal./day Water &
Soluble Matls.
ReUsed in Wash
Cycle
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