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POLLUTION PREVENTION AT INDUSTRIAL LAUNDRIES;
A Collaborative Approach in Southern California
INTRODUCTION
This was one of four regional demonstration projects of EPA's Industrial Pollution
Prevention Project (IPS). It took place in Southern California. Its purpose was to demonstrate
how enhanced communication and coordination among federal, state, and local regulatory
agencies in a region of a state can be conducted to promote pollution prevention within a selected
industrial sector.
BACKGROUND
The large number of federal, state, and local laws, regulations, policies, and enforcement
practices regarding toxic pollutants is often overwhelming and sometimes conflicting, confusing,
and frustrating to many businesses in Southern California (and undoubtedly elsewhere also).
Recognizing the need for a pollution prevention (P2) program that is based on the unified efforts
of all the regulators, the IPS and EPA's Region 9 decided to conduct a demonstration project in
Southern California which would demonstrate how such a unified, collaborative P2 program
might work.
PHASES OF THE PROJECT
The first phase of the project was to collect and analyze in a cohesive way all of the
existing statutory, regulatory, and planning requirements affecting multi-media pollution
prevention in Southern California. Collecting, analyzing, and sorting out all these existing
requirements resulted in a summary of the laws and regulations currently in place in California
that create an incentive for industry and publicly owned treatment works (POTWs) to engage in
pollution prevention activities. (See A Summary of the Regulatory Incentives for Pollution
Prevention in the Appendices to this report).
The second phase was to establish the interagency multi-media P2 team that would be
able to bring about the sought-for unified and collaborative effort. All agencies (federal, state,
and local) with requirements affecting multi-media P2 in Southern California were formally
invited to participate in this project. Twenty-four different agencies attended and participated in
the project meetings. (For a list of the twenty-four agencies, see the Appendices to this report.)
The third phase was to implement the collaborative approach — in partnership with a
selected industry sector. This third phase is discussed in the remainder of this report.
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IMPLEMENTING THE COLLABORATIVE APPROACH
Implementing the collaborative approach involved a process, findings, conclusions,
project outputs, and lessons learned. Each is addressed in turn below:
Process
To control the scope of the project and keep it manageable, the interagency multi-media
team decided to select one industry and limit the geographical area of the demonstration to the
South Coast Basin in Southern California. The industry selected by the interagency team was
industrial laundries. Industrial laundries were chosen for this demonstration project, for four
primary reasons:
(1) industrial laundries were experiencing some compliance problems.
(2) the industrial laundries were willing to be active partners in the project.
(3) U.S. EPA is in the process of developing effluent guidelines for industrial
laundries. (The guidelines can include standards based on pollution prevention;
therefore, it was important to all of the partners in the project to understand what
pollution prevention practices are available to industrial laundries.)
(4) industrial laundries are a service industry and are not so much generators of
pollution as they are receptors of their customers' pollution problems; therefore,
laundries represent a good opportunity for a program design that involves
technical outreach (spreading P2 not just to the laundry sector but also to its
customers, i.e., other industries) and a coordinated regulatory approach.
The project began with a general meeting to which all the project participants (EPA, state
agencies, local agencies, and industrial laundries) were invited. Over 50 participants attended,
representing 4 POTWs, 5 local agencies, 8 state agencies, 5 industrial laundries, and U.S. EPA.
The project's aims were presented to the group, and the floor was opened for discussions on
"What are the issues?" By the end of the day, the group reached a consensus about how the
project should proceed. As a result of this general meeting, the project's strategy, milestones, and
products were established. (See the Appendices to this report for the agenda, minutes, attendance
list, and materials of this February 9,1993 general meeting of the Multi-Agency Work Group.)
The multi-agency group's consensus was that the project should include (1) establishment
of a core focus group comprised of POTWs, industrial laundries, state media agencies (air and
solid waste), and local health agencies to meet regularly and more frequently than the larger
Work Group; (2) preparation of discussion papers, meetings, and a final report; (3) workshops on
P2 for industrial laundries and their customers; and (4) facility assessments at industrial
laundries to identify opportunities for P2 — with the findings to be presented at the workshops.
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The core focus group was established. It met regularly and frequently .and discussed
various aspects of the industrial laundry business and areas where opportunities could be found
for pollution prevention practices. (See the Appendices to this report for the core focus group
meeting agendas and minutes, and see the "findings" section below for some of the results of the
discussion meetings.)
Detailed facility assessments were conducted at industrial laundries throughout the
region, and the findings and results of these assessments were presented at a big workshop held
in June 1993. (For all of the findings and results of the industrial laundry assessments, see the
IP3's EPA publication (EPA-820-R-95-0010), Pollution Prevention at Industrial Laundries:
Assessment Observations and Waste Reduction Options. July 1995. For some of the findings,
see the "findings" section below.)
The June 1993 workshop was developed as a blueprint for future workshops. The
workshop took a multi-media approach and was conducted in partnership with the industrial
laundries. Presenters at the workshop were from regulating agencies and industrial laundries.
(See the Appendices to this report for the workshop agenda, attendance list, and materials.)
Findings
General — Discussions with industrial laundry operators and management during facility
site visits and during the project meetings revealed several key points:
(1) Industrial laundries have coped with the problem of non-compliance with local
toxic organics and oil and grease limits (notably in Orange County) by
discontinuing the laundering of shop towels and shop uniforms at the facilities
subject to stringent limits. Instead, the materials are taken to facilities not subject
to stringent limits.
(2) The major source of pollutants is from outside the industrial laundry facility,
namely the customer's facility.
'•_ (3) Industrial laundries, in general, are applying a few basic measures that promote
; internal pollution prevention, including waste heat recovery, automated detergent
feed, and, in some cases, waste segregation.
(4) Industrial laundries are subject to conflicting, single-media regulations and
inconsistent requirements which result in overall reluctance to take the "risk" of
pollution prevention innovations.
Regulatory — Whereas, the first phase of this project looked at all the existing statutory,
regulatory, and planning requirements affecting multi-media pollution prevention in California
(see page 1 of this report and Summary of the Regulatory Incentives for Pollution Prevention in
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the Appendices to this report), this third phase of the project identified those regulatory areas that
have an impact specifically on industrial laundries and their customers and are in need of
coordination for a multi-media pollution prevention program targeted to industrial laundries.
The Report on Areas in Need of Coordination (in the Appendices to this report) identifies
and discusses specific air quality, water quality, solid/hazardous waste, and other regulatory
programs that need coordination under any unified approach to pollution prevention in Southern
California. These include the U.S. EPA air toxics regulations (MACT standards), several
California air toxics regulations (e.g., T-BACT standards for TACs under AB 1807 and "Hot
Spots" under AB 2588), several local air toxics regulations based on health risk assessments
(e.g., SCAQMD rules 223 and 1401), regulations controlling Criteria Air Pollutants such as
VOCs, NOx, SOx, and particulates (e.g., SCAQMD has one of the most stringent programs in
the nation for the control of VOCs), U.S. EPA effluent guidelines (currently under development
for industrial laundries), local effluent limits set by POTWs, U.S. EPA hazardous waste
regulations under RCRA, U.S. EPA sludge regulations, California sludge regulations, U.S.
OSHA regulations, California OSHA regulations, California Proposition 65, U.S. DOT
hazardous materials transport regulations, and more.
Of greatest concern to industrial laundries is that they need resolution of the "shop towels
as hazardous waste" issue. Serious problems and inconsistencies are faced by industrial
laundries when shop towels are considered to be a regulated hazardous waste under RCRA. (For
details of this issue and how two states have resolved it, see the minutes of the February 9, 1993
meeting of the Multi-Agency Work Group in the Appendices to this report.)
The EPA Region 9 position is that towels with listed solvents on them are, by virtue of
the "mixture rule," hazardous waste under RCRA. Region 9 cites lack of national guidance on
this issue, the problem of setting legal precedent, and the fact that the matter is being treated as a
low enforcement priority. The response from laundries is that just saying it's a "low enforcement
priority" does not help; they are still open to possible NOVs, liability concerns, and suits by
public interest groups. Laundries cannot go on with that uncertainty. One of the largest laundry
chains in California has made a corporate decision no longer to accept inkers from printers, in
part due to the atmosphere of uncertainty as to whether or not these towels could be considered
hazardous waste.
The California state RCRA program must be at least as stringent as the federal RCRA
program. So everyone in California must look to U.S. EPA for interpretation of this "shop
towels as hazardous waste" issue.
Although it was understood that this project was not the appropriate forum for ultimately
resolving that issue, there was definite shared benefit from allowing the issue to be put on the
table as a problem of primary concern to the regulated community. Furthermore, the discussion
which took place may serve as a catalyst leading to a solution.
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Pollutants of concern — Some of the specific pollutants of concern for industrial
laundries and probable sources of'those pollutants are:
lindane
tri methyl benzene
(agriculture, pest control companies)
(not clear)
bis (2 ethylhexyl) phthalate (cutting oils, furniture manufacturing, machine
shops, maintenance of machinery)
methylene chloride
copper
silver
zinc
chromium
TCE
TCA
nickel
benzene
chloroform
MEK
xylenes '
cadmium
(maintenance of machinery, auto repair, printers,
graphics, furniture manufacturing)
(printers, metal finishers)
(printers, metal finishers, photo processors)
(agriculture, pest control, laundry chemicals, auto
repair)
(metal finishers)
(printers, automotive, metal finishers, aerospace)
(printers, automotive, metal finishers, aerospace)
(auto repair)
(auto repair, printers, refineries)
(health services)
(auto repair, printers, labs)
(auto repair, printers, labs)
(printers, graphics)
For a more detailed "cross-walk" of principal waste management problems encountered
by laundries and the probable major sources of those problems, see Industrial Sector Customers
and Probable Problems/Pollutants for Laundries in the Appendices to this report.
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The usual discharges to the environment from industrial laundries are washwater draining
to sewers, solvents from fabrics evaporating to the air, filter cakes taken to landfills, and oil from
water/oil separators taken to recyclers. The facility assessments confirmed that, while there are
sources of pollutants internal to the laundry (e.g., detergent residues, truck cleaning, etc.), the
bulk of pollutants found in the laundries' discharges originate in the material received from
customers. Toxic organic compounds and oil and grease were the two pollutants most causing
the industrial laundries to be in non-compliance with environmental regulations. The greatest
contributor of those two pollutants were shop towels (and rags and uniforms) impregnated with
solvents and oil. (Restaurant linen was also a considerable source of grease and oil (of animal
and vegetable origin).)
Water reuse issues —The issues surrounding water conservation and reuse in laundries
focused, in general, on cost effectiveness, potential for cross-media transfer, and limitations on
how far one can go with conservation measures before pretreatment limits that are concentration-
based become problematic. Points included:
What can Sanitation Districts tolerate in effluent to allow for reuse? (e.g., the
Chino/San Bernardino/Riverside area POTWs cannot take effluent with high TDS
because of need to reuse treated water for agricultural purposes in those basins.)
While not all water efficiency measures require large inputs of energy, many do
and this can become a limiting factor. Right now, energy costs limit water reuse.
If cost of water goes up, however, then water reuse may become more cost-
effective.
Cross-media impacts exist and cannot be overlooked when thinking about water
reuse (especially if energy usage is involved).
Laundries are already quite efficient now, in terms of water use. Price increases
for water (from $638/acre-foot to $16927 acre-foot) have already created an
incentive to be water-efficient. Many laundries already reuse water. Segregation
of wastewaters within the laundry can make water reuse easier.
Pretreatment issues — The key issues surrounding pretreatment limits for laundries were
focused on the problem of concentration-based versus mass-based standards and the problem
associated with total toxic organic (TTO) limits that may be technically infeasible to reach with
pretreatment. (While low TTO limits might be seen as a motivator for pollution prevention,
laundries have another way to address such limits and that is to ship the shop towels to another
plant in a less restrictive district. Many are doing that. Some are shipping them even to
Mexico.) Points on pretreatment issues included:
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Concentration-based limits may impair further improvements in water reuse.
However, mass-based limits can be difficult to implement by the Sanitation
Districts. One needs to be able to meter the flow of effluent.
TTO limits and safety are a concern for industrial laundries accepting solvent-
laden towels. One major Southern California laundry has decided to no longer
accept inkers from printers.
Need realistic limits. (The general feeling among launderers is that Orange
County's TTO limit of 0.58 ppm is unrealistically low.)
TTO limits — may be addressable by pollution prevention.
There is a problem with POTW limits differing in different districts. Hard to
provide a consistent message to customers. Customers and/or the laundries can
shift business to less restrictive districts; or, smaller laundries with no
pretreatment requirements can end up getting the dirtiest accounts.
- Some POTWs simply ban shop towels in their districts. San Bernardino said "no
shop towels" and effluent at one laundry facility went from 17 ppm (xylenes) to
non-detectable (all organics); but it was not really an environmental benefit
because the laundry sends the shop towels to its Los Angeles facility instead.
P2 options —The project showed that there are pollution prevention opportunities
available for both laundries and their customers. For both, the establishment of and adherence to
a set of best management practices (BMPs), followed by continuous improvement in searching
for ways to minimize the generation of pollutants, is the key. (See the project document,
Pollution Prevention at Industrial Laundries: Assessment Observations and Waste Reduction
Options, referred to on page 3 above.)
There is a range of laundry processes and activities which could be candidates for an in-
house look at pollution prevention opportunities at industrial laundries. (See the flowcharts in
the Appendices to this report.) For example, the use of laundering chemicals in the prespotting,
washing, bleaching, or other textile treatment steps should be looked at because they could
contribute toxics such as phenolic compounds, chloroform, and zinc, as well as cause problems
with conventional pollutants such as high pH and BOD.
.- The Multi-Agency Work Group agreed, however, that one of the biggest problems for
laundries and the area of most concern for regulatory agencies is dealing with shop towels. The
pollution prevention options for laundries that process shop towels could include:
1) education of their customers on P2 opportunities to prevent shop towel
contamination;
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2) use of BMPs at the customer's site prior to transportation to minimize the amount
of solvent in the material accepted by the laundry for washing; and
3) use of BMPs for the safe handling of solvent-laden shop towels, which might
include:
Requirement of no free liquids
Use of the paint filter test (used by some states)
Use of a wring test (hard to standardize)
Collection containers with mesh bag (to allow free liquids to settle)
Weigh towels and reject those above certain weight
Centrifuges mounted on trucks
A more complete and detailed list of BMPs for shop towels, both for the laundries and for
the customer, was produced by the project — along with two pages of points on why BMPs are
important and how they are beneficial for the laundries. (See the Appendices to this report for
these project outputs.) They were developed for the workshops and were disseminated to the
laundries and their customers.
In certain states, the use of BMPs has provided regulatory relief to industrial launderers:
In Minnesota, the Minnesota Pollution Control Agency policy since 1989 has
been that if generators of reusable textiles containing hazardous waste solvents
wring them out, either by hand or with a mechanical wringer, to remove the
maximum amount of liquid, the wrung-out reusables may be transported without
manifesting. (If that generator elects not to wring out towels, they must be
managed as a RCRA hazardous waste and cannot be laundered.) If a launderer
elects to install and operate a centrifuge or some other method of extracting
liquids prior to laundering, no hazardous waste facility permit is needed.
In Washington, the Washington Department of Ecology since 1992 has provided
that used shop towels contaminated with hazardous substances which may be
designated as "dangerous" under state law, may nevertheless be exempted from
compliance with dangerous waste requirements — if both generator and launderer
follow specific BMPs. If soiled textiles are handled according to BMPs, facilities
are not subject to generator, transporter, or permitted TSDF requirements, and the
textiles are not "counted" as hazardous or dangerous waste.
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Besides the importance to the Southern California industrial laundries of resolving the
national "shop towels as hazardous waste" issue, there also needs to be ongoing interaction
between the local POTWs and the laundries. Laundries want to know what causes problems for
POTWs (e.g., What are their contaminants of concern? What's hard for them to treat?)
there needs to be a dialogue and a cooperative effort between POTWs and laundries to
help identify whether or how the laundries' customers are contributing to POTW problems and
what can be done about it. Laundries and POTWs need to focus on ways of transferring
information, making sure that information gets to small laundries too.
Finally, it is important that laundries and regulatory agencies work cooperatively together
in providing to customers training and periodic retraining in P2 and the use of BMPs.
Conclusions
General - The project concluded the following:
(1) Any effective P2 program for industrial laundries needs to extend into the
customer's shop. The customer is an integral part of the industrial laundries'
environmental compliance program. (This reality was a major reason industrial
laundries were selected as the industry for this demonstration - because involving
the one industry (industrial laundries) in a P2 emphasis naturally leads to
', involving many other industries as well.)
(2) Customer education and outreach must be done in such a way so as not to
endanger the laundry's business with that customer.
(3) The transfer of solvents, oils, and other pollutants to towels, rags, and uniforms by
the customer should be considered emissions to the environment and should be
accounted for in the customer's overall emissions.
(4) A P2 program for customers needs to be .applied universally and consistently to
retain competitiveness of individual laundering facilities.
(5) Industrial laundries' control of emissions from customers to the laundering facility
needs to be done in partnership with the customer - and with the support of
regulators.
The challenge for regulators and industry is to find a mechanism, both regulatory and
administrative, to extend P2 beyond the industrial laundry facility into the customer's shop and
incorporate the customer (i.e., the generator of the pollutants) into the P2 program. The basis for
developing such a mechanism should be a partnership among laundry, customer, and regulator,
supported by a mix of regulatory mandates and incentives.
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A P2 strategy - The interagency multi-media team, in cooperation with management
and personnel representatives of industrial laundries, developed a strategy which an industrial
laundry could adopt for the P2 program:
(1) Make everyone a part of the same P2 team - internal team members would
include laundry operating personnel, staff and management, distributors and route
drivers; external team members would be the laundry's customers.
(2) Develop best management practices (BMPs) for internal and external handling of
laundry - at the laundry and at the customer's shop.
(3) Train and periodically retrain internal staff and customers.
(4) Use route representatives and salesmen to disseminate BMPs and ensure that
these practices are consistently applied in the customer's shop at pick-up transfer
and delivery.
(5) Develop an awards program.
The workshop held in June 1993 put forth ideas and materials industrial laundries and
regulatory agencies can use to implement this strategy (see the Appendices to this .report).
Project Outputs
As a result of this project, five major products were developed for the use of industrial
laundries and regulators. (See the Appendices to this report for the first four of the following.)
(l) A Summary of the Regulatory Incentives for Pollution Prevention in California
and a Report on Areas in Need of Coordination in regulating industrial laundries.
(2) Best management practices for industrial laundries and their customers.
(3) A strategy for the dissemination of best management practices to customers.
(4) A workshop and materials for industrial laundries to inform and educate industrial
laundries and regulators in P2 practices and issues for laundries.
(5) Pollution Prevention at Industrial Laundries: Assessment Observations and Waste
Reduction Options, My 1995 (EPA-820-R-95-0010).
In addition, the project brought together in Southern California all the different regulatory
agencies and industry for the first time - as a team. It institutionalized a new ongoing dialogue
10
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among all the regulatory players. It can serve as a model for how this collaborative, team
approach can be done in other regions.
Some Broad Lessons Learned from this Demonstration Project
Lesson 1 ~ When regulators regulate industry they must acquire a thorough
understanding of individual industries and tailor regulatory mandates based on the requirements,
issues, and constraints of the industry. One stakeholder who has such a complete understanding
is industry. Industry needs to be at the table with regulators. There should be an understanding
on both sides that pollution prevention is both environmentally and economically beneficial.
Industry and regulators each must be able to answer, in a way that is satisfactory to each other,
the question, "What's in it for me?" This stakeholder partnership should include trade
associations and labor representation, such as trade unions.
Lesson 2 —Years of command-and-control adversary relationships between
environmental regulators and industry have created a high level of mistrust between these two
stakeholders. Industries, especially medium-sized and small, are reluctant to deal with regulators
and feel ill-equipped to "fight" what has been known as a battle. Large industries may be easier
to involve in a partnership. Their help as leaders and "mentors" for the smaller companies can be
tapped to attract smaller businesses into partnerships. Any partnership project with industry will
require lengthy negotiations and discussions. Awareness and sensitivity to the competitive
forces between companies is an important element of such partnerships.
Lesson 3 -- Regulatory uncertainty and the patchwork of local regulations and limits are a
barrier to P2. Industrial laundries deal with a variety of regional and local requirements, often
unrelated to one another. Because of this, laundries face different competitive and market forces
from region to region that create a condition of inequity among laundries that operate in different
regions. There is no uniform incentive to apply P2 with the customer. There is reluctance to
become strict with a customer, while another laundry, in another region, does not have to be
strict because the discharge limits allow that laundry to be more lax.
Lesson 4 — Industrial laundries are a unique industry and require unique, innovative
regulatory approaches. (This is probably true of any service industry.) Ail industrial laundry's
(or any other service industry's) approach to attaining compliance should include a customer
"source control." Laundries and similar service industries, in order to attain compliance, need to
have a program that combines treatment of waste with source control or pollution prevention in
their customer's shop. Service industries, however, need equitable regulatory support to integrate
pollution prevention and source control into their environmental compliance program. The
requirements placed on laundries and their customers need to be equitable and universally
applied, not only to avoid geographic transfers of pollutants to a less regulated area, but also so
that each laundry can retain its market and competitive edge.
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EPILOGUE
The valuable lessons learned from this demonstration project have been disseminated in a
number of ways. The findings from the project were presented at the Water Environment
Federation Conference hi October 1993, at the annual conference of the Institute of Industrial
Launderers in November 1993, at the California Local Government Pollution Prevention
Conference in October 1994, and at other conferences. The Institute of Industrial Laundries has
disseminated information from the project to its members by including project findings and
materials in its publications. The materials from the project have been given to U.S. EPA
Headquarters for consideration, as EPA works on new effluent guidelines for industrial laundries.
There have undoubtedly been many other ways word has been spread about the results of this
collaborative partnership.
It was and continues to be the intent of EPA's Industrial Pollution Prevention Project
(IP3), which spawned this demonstration project, that the collaboration and cooperation that was
instituted by this project will continue on into the future. Especially with EPA continuing to
work on developing effluent guidelines for industrial laundries, it is important to maintain the
partnerships established in this project.
For example, it is important to: (1) continue with the core focus group meetings with
industrial laundries and local agencies to assess progress in implementing BMPs, to serve as a
sounding board for the U.S. EPA's effluent guidelines work group, to work on other existing and
emerging issues, and to conduct any issue-specific meetings of value to participants; (2) have
local agencies, with the laundries, jointly coordinate P2 outreach (e.g., a joint letter from
different regulatory agencies emphasizing BMPs) to the laundries' customers; and (3) continue -
as a team ~ to publicize and disseminate the findings and materials from the project.
Also, as a follow up to the IP3's demonstration project, U.S. EPA Region 9 has initiated
an industrial laundry showcase project under its Merit Pollution Prevention Partnership program.
The showcase project brings together representatives of U.S. EPA, Los Angeles County, and a
Southern California industrial laundry. The project seeks to measure the effectiveness of three
P2 approaches: (1) BMPs at the laundry, (2) in-process recycling and treatment at the laundry,
and (3) a customer outreach program. Results of this project will be disseminated throughout the
regulating community and to industrial laundries across the country.
In summary, the overall message of the IP3's "collaborative approach in Southern
California" is that the best way to get good things done is through partnerships. In order to be
most effective in promoting the implementation of pollution prevention, we need a sense of
partnership among the various regulators, among the regulators and the regulated, between
POTWs and their users, and between industrial laundries and their customers. This project has
demonstrated that these parties can work successfully together in a spirit of collaboration and
cooperation. It is important that this spirit that has been established in Southern California
continue there and be fostered in other places as well.
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APPENDICES
O A Summary of the Regulatory Incentives for Pollution Prevention
O Regulatory and Pollution Prevention Contacts at Key Governmental Agencies
O Report on Areas in Need of Coordination
O The 24 members of the interagency multi-media team
O The February 9,1993 general meeting of the multi-agency work group
O The core focus group meetings
O Industrial Sector Customers and Probable Problems/Pollutants for Laundries
i
O Laundry process flowcharts
O Best Management Practices (BMPs) for industrial laundries and their customers
(and why BMPs are important and beneficial)
O Strategy for the dissemination of BMPs to customers
O Industrial laundries P2 workshop and selected workshop materials
(Note: Workshop materials included or cited elsewhere in this report or in the appendices
to this report are not included here in this appendix.)
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A Summary of the Regulatory Incentives for Pollution Prevention
AIR QUALITY
U.S. Environmental Protection Agency (USEPA)
Clean Air Act Amendments
Air pollution control agencies have not historically regulated toxic chemicals
released into the air except for their ability to create smog. The Clean Air Act
Amendments of 1990 will dramatically increase the scope and number of chemicals
regulated as air toxics. The USEPA will soon be promulgating a series of regulations
requiring the implementation of the maximum achievable control technology for
189 hazardous air pollutants. As emitters of some of these compounds, Publicly
Owned Treatment Works (POTWs) may face new regulation as a result of the 1990
amendments. Like other air quality regulations, it is probable that local and regional
air quality agencies will actually enforce the regulations developed by the USEPA.
As emissions control at the POTW itself is difficult, POTWs may choose to
minimize the inflow of the hazardous constituents via a pollution prevention
effort in order to avoid the regulations.
State. Regional and Local Air Quality Control Agencies
The State Air Resources Board (ARB) regulates the production and emission of air
pollutants. The bulk of air regulations are implemented by local agencies called Air
Pollution Control Districts (APCDs). In an attempt to manage air quality on a
regional or air basin-wide scale, Air Quality Management Districts (AQMDs) operate
as APCDs on a multicounty basis. APCDs promulgate rules and limits relevant to
maintaining air quality in their particular jurisdiction and issue permits. They are
responsible for enforcing rules established by the USEPA and ARB and operate
semi-autonomously in their pursuit of air protection.
APCDs regulate each of the three main phases of Publicly Owned Treatment Works
(POTW) wastewater treatment. When wastewater first enters the facility, and
throughout the treatment processes, it has the potential to constitute a public
nuisance by virtue of its annoying odors. Residual solids extracted from wastewater
are also odorous. Most APCDs have established rules which mandate odor control.
In addition, drganics in the wastestream are often volatilized when they go through
turbulent treatment processes. Sludges may also contain organics which volatilize.
Because some organics are toxic, and therefore constitute a health risk, the levels of
Volatile Organic Chemicals (VOCs) emitted are also regulated.
If the POTW uses an anaerobic digester to treat sludge, as many do, methane and
other gases produced may be burned in a boiler and used for on-site energy
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cogeneration, or flared. These processes are regulated by APCDs for health risk, as
well as for their smog contributing constituents. If there is a visible plume from
oxidation, the facility is also subject to air opacity limits.
Beyond setting limits and granting permits, some APCDs require POTWs to
inventory all of the VOCs and odors resulting from their processes. Additionally, in
some severely impacted districts, any new source of emission in the basin is
required to offset its contribution by some means. POTWs, as public service facilities,
qualify for exemptions to some rules on a case by case basis.
Air Toxics and "Hot Spots"
The ARB has a program in place to identify and control toxic air contaminants
(TACs). As of September 1992, eighteen substances have been identified as TACs.
Air control measures have been adopted for five of the identified TACs. Over 2,000
stationary sources statewide will be impacted by the control measures. The control
measures advocate the use of pollution prevention whenever possible to help
reduce emissions of TACs.
The ARB also implements the Air Toxics "Hot Spots" Information and Assessment
Act, passed in 1987. Under the Air Toxics "Hot Spots" Act, stationary sources are
required to report the type and quantity of certain air contaminants their facilities
routinely release. Air releases of interest are those that result from the routine
operation of a facility or that are predictable, including but not limited to continuous
and intermittent releases and process upsets or leaks. The Act requires owners or
operators of facilities to prepare and submit a variety of documents to APCDs. These
documents include an air toxics emission inventory plan, a subsequent emission
inventory, and for high priority facilities, a health risk assessment. If, when
reviewing inventories, the APCD judges that significant health risks are posed by a
facility's emissions, the operator must notify all persons exposed.
The ARB has also developed a program to make the emission data collected under
the "Hot Spots" Program available to the public. A list of substances posing a chronic
or acute health threat when present in the air is compiled and maintained. Facilities
meeting criteria to prepare ah1 toxics emission inventory plans and subsequently,
emission inventory reports must submit emission data to their APCD.
Facilities are categorized into high, intermediate, and low priority. Facilities
designated high priority must submit a health risk assessment to the district for
approval. Facilities which are subject to inventory reporting requirements are also
charged a fee by their APCD to recover the costs of operating the "Hot Spots"
program.
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Pollution Prevention & Air Quality Regulation
Although neither the ARB or the APCDs usually mandate pollution prevention
activities, it is strongly advocated as a measure to reduce emission of controlled
TACs. In addition, as with regulations for most environmental media, businesses
have the opportunity to get out of the "regulatory loop" by reducing wastestreams
through the use of pollution prevention. In many instances, the desire to avoid the
regulations altogether by removing regulated constituents from their wastestream is
one of the most powerful motivations for pollution prevention. Additionally,
APCDs may include pollution prevention or source control techniques as part of
"Best Management Practices" that facilities are required to implement.
From the POTW perspective, pollution prevention can play a role in addressing air
quality regulations. If an air pollutant if found in high concentrations at a POTW,
agency staff can attempt to determine where the pollutant is entering the system and
work with the discharger to reduce the inflow to the system. Moreover, if a class of
compounds, like VOCs, are creating an air quality problem for the POTW, a
pollution prevention effort can be focussed on the whole universe of dischargers of
VOCs.
Given the huge quantities of air emissions resulting from wastewater treatment,
however, hazardous constituents may often be present only in small undetectable
quantities. When a pollutant is not detected in a facility's emissions, APCDs
sometimes choose to assume that the pollutant is present at a concentration of one-
half of the detectable limit. This one-half concentration, when multiplied by the
large volumes of air emitted by a POTW, can result in fairly high numbers when
conducting an assessment under the "Hot Spots" Act. It may be difficult for
pollution prevention to address this particular problem.
The public disclosure provisions under the "Hot Spots" Act also provide an
incentive for both industrial facilities and POTWs to minimize their emissions.
Having to notify your neighbors that your facility is creating a health risk that air
quality agencies have determined is significant is a task that few facilities are likely
to cherish. Avoiding the need, to do so by reducing air emissions is an option many
facilities will pursue.
WATER QUALITY
United States Environmental Protection Agency
The Federal Clean Water Act established much of the laws and subsequent
regulations limiting the discharge of pollutants into the nation's waterways. A
series of guidelines have been established that limit discharges based on available
technology and type of business. In California, the State Water Resources Control
Board and local POTWs implement most of the law.
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State Water Resources Control Board
The State Water Resources Control Board (SWRCB) of the California
Environmental Protection Agency regulates the use and protection of surface and
groundwater in the State of California. The Water Resources Control Board
implements most of its water pollution control laws through subsets called
Regional Water Quality Control Boards (RWQCB).
POTWs regularly discharge water resulting from the treatment process to surface
water bodies. As dischargers to surface waters they are regulated under the federal
National Pollutant Discharge Elimination System (NPDES). The State Water
Resources Control Board has been authorized by the U.S. EPA to implement the
NPDES program in California. The NPDES Program requires the State to monitor
the volume and constituents of wastewaters that are discharged. Using information
gained from the monitoring, RWQCBs grant permits to direct dischargers, either
large industrial entities, or POTWs, based on the pollutant load that bodies of water
can withstand. Permits usually specify the volume and concentration of pollutants
allowable in the discharge of each permit recipient.
Large industrial facilities may discharge to surface waters, and therefore be regulated
under the NPDES program as well. However, most businesses do not qualify to
discharge directly to bodies of water, and instead simply discharge to sanitary sewers.
As will be discussed in the Publicly Owned Treatment Works section, those that
discharge to sanitary sewers are regulated by the operator of the sewer system.
RWQCBs have the power to mandate the use of best management practices for
selected dischargers. These practices may include the use of pollution prevention or
waste minimization techniques to achieve lower discharges. In the San Francisco
Bay, the RWQCB has required POTWs to implement pollution prevention
programs as a condition of their permit.
Publicly Owned Treatment Works and Sanitation Districts
Under the NPDES Program implemented by SWRCB, RWQCBs set limits to a
POTWs discharge. In order to meet their requirements, POTWs have implemented
permit systems for industrial facilities which discharge into the POTWs sanitary
sewer systems. Therefore, businesses are limited in the amount and concentration
of constituents of their discharge to the system.
Pollution Prevention & Water Quality Regulation
In order to meet discharge limits, business and POTWs may implement pollution
prevention programs to reduce discharges. Unlike wastewater treatment, businesses
may find that pollution prevention technologies will allow them to reduce their
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discharges without creating sludges that are difficult to dispose of. From the POTWs'
perspective, pollution prevention may be the only way to deal with some problems
in a cost-effective way.
SLUDGE REGULATION
POTWs generate vast quantities of sludge through their treatment processes. Sludge
programs may be implemented by states through existing NPDES programs,
through solid waste programs that manage land disposal or through air programs
that manage sewage sludge incinerators. When standards are finalized for the
beneficial use and disposal of sludge in mid-1993, the State will again have the
opportunity to delegate the sludge program to either a water, solid waste or air
department. Currently, the SWRCB implements a U.S. EPA sludge regulation
program for California under 40 CFR Part 123 Rules.
The federal sludge regulatory program, established pursuant to amendments to the
Clean Water Act, requires the imposition of specific permitting requirements for the
beneficial use and disposal of sludge. Section 405 of the Clean Water Act requires
EPA to promulgate technical standards, referred to as Part 503 Rules, for the use and
disposal of sewage sludge that p>rotect public health and the environment. The
SWRCB permits sludge generators, users and disposers.
To maintain compliance with sludge specifications, POTWs may implement
pollution prevention programs to augment their pretreatment programs. In doing
so, the POTW may be able to reduce the level of hazardous compound found in
their sludge without passing additional regulations.
SWRCB implemented sludge regulations may affect businesses that create sludge
through the use of onsite wastewater treatment systems. As mentioned, unlike
POTWs, most industrial facilities discharge to sanitary sewer systems, operated by
POTWs or municipalities. To achieve acceptable levels of toxics in wastewater for
discharge to the sanitary sewer system, many facilities must apply some sort of
treatment to their wastewater. Depending upon what types of residuals are present
in the wastewater, it is common to create sludge when purifying discharges. Unlike
POTW sludge, industrial sludge often has high levels of hazardous constituents
which make it difficult and expensive to dispose of. Pollution prevention
technologies that eliminate the need to treat wastewater will eliminate the need for
businesses to dispose of sludge.
SUPERFUND
Title ni of the Superfund Amendments and Reauthorization Act (SARA), known as
the Emergency Planning and Community Right-to-Know Act (EPCRA) of 1986,
establishes requirements for federal, state and local governments and facilities
regarding emergency planning .and community "right-to-know" reporting on a
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number of chemicals. Chemicals subject to this law include Occupational Safety and
Health Acts chemicals; hazardous substances under the Comprehensive
Environmental Response, Compensations and Liability Act (CERCLA); extremely
hazardous substances under EPCRA Section 302; and the chemicals listed as toxic
under EPCRA Section 313.
The community right-to-know provisions build upon EPA's Chemical Emergency
and Preparedness Program (CEPP) and are aimed at increasing the public availability
of information about the presence and environmental releases of chemicals in the
community. SARA Title in contains four major sections, including emergency
planning, emergency release information, community right-to-know reporting
requirements, and toxic and chemical release inventory reporting.
Section 313, addressing toxic and chemical release inventory reporting, requires EPA
to establish an inventory of the toxic chemical releases and transfers of certain
facilities. Facilities subject to TRI (Toxics Release Inventory) reporting requirements
must complete report information on their releases for each year to states and the
EPA. Then, the EPA is required to compile an inventory of reported releases.
Within the TRI Report, the EPA lists the top fifty facilities that reported emission to
air, land, surface water and underground injection wells, public sewage and off-site
transfers.
The TRI Report and community right-to-know reports of SARA Title in provide
valuable information to public health and advocacy groups. This information has
been used in the past to tarnish corporate images and retard public relations. Hence,
companies participate in pollution prevention and waste minimization in an
attempt to avoid being one of the listed top fifty emitters.
WORKER SAFETY RULES
U.S. Occupational Safety and Hazard Agency
Businesses which use materials classified as hazardous by the Occupational Safety
and Hazard Agency (OSHA) must meet certain requirements for worker safety.
These requirements include providing workers with proper protection against
harmful substances, providing workers with information regarding materials to
which they are exposed, and performing a variety of other worker safety oriented
activities. As the activity and reporting requirements for OSHA can be burdensome,
businesses can avoid OSHA regulation altogether by using pollution prevention
technologies to replace hazardous materials, which many times result in hazardous
wastes, with nonhazardous materials. Pollution prevention is the result of replacing
hazardous items with more benign substitutes.
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HAZARDOUS WASTE MANAGEMENT REGULATION
State Department of Toxic Substances Control
The Department of Toxic Substances Control (DTSC) is a department of the State of
California's Environmental Protection Agency. The Department regulates
hazardous waste generation, treatment, and disposal as well as controls on the land
disposal of certain hazardous wastes.
The problems and costs associated with the disposal of hazardous waste are the most
frequently cited reason for implementing source reduction activities by TRI
companies. The disposal of hazardous waste requires extensive effort on the part of
the generating facility's operator. It is necessary for them to find a qualified hauler
and meet regulations on storage, handling, and tracking. In addition to the amount
of time it demands of an operator, it is expensive to dispose of hazardous waste.
Relatively, it is much more expensive for small and medium sized firms. In order
to escape the "regulatory loop" (and associated time demands and uncertainty) as
well as to avoid exorbitant disposal costs, many facilities are turning toward
pollution prevention.
Limits on the land disposal of certain wastes create problems for businesses
generating these wastes. These businesses are left with the option of paying for
expensive waste treatment or incineration technologies. Producing less waste
through the implementation of a pollution prevention program is another option
that can save businesses money. In California, the waste generation fee charged by
DTSC is another economic incentive for pollution prevention.
DTSC also implements SB 14, the Hazardous Waste Reduction and Management
Review Act of 1989. The Act requires facilities which generate 12,000 kilograms or
more of hazardous waste annually to review their operations for potential waste
reduction measures and to prepare plans showing an implementation schedule for
feasible measures. These Hazardous Waste Management Plans are called in by DTSC
by industry type. Companies are made aware of economically feasible pollution
prevention activities by the process of preparing the Report. Conceivably, when
feasible alternatives are recognized, they will be implemented.
SB 1726, passed in 1992, extends the prohibition date of hazardous waste land
disposal for specific hazardous wastes. In addition, SB 1726 expands the application
of SB 14 to include any generator that routinely produces more than 5,000 kilograms
if hazardous waste per year, lowering the threshold substantially from 12,000
kilograms per year. All generators of 5,000 kilograms or more are required to file a
new document which shows the progress of a facility's source reduction measures.
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HAZARDOUS MATERIALS
Hazardous materials (as classified by federal, state and local governments) used by
industrial facilities are subject to storage requirements in order to minimize fire and
public health hazards. In California, hazardous materials are regularly controlled
through a program implemented-by local agencies. Processes which use hazardous
materials often create hazardous waste as a by-product. By reducing the use of
hazardous materials, operators minimize hazardous material regulation
requirements. Therefore, it is possible to use pollution prevention product
substitution techniques to reduce hazardous materials use as well as hazardous
waste generation.
OTHER INFLUENCES
Fear of Long Term Superfund Liability
Businesses face a number of uncertainties and hidden costs in the operation of a
facility. One of these uncertainties regards long term liabilities resulting from
business operations. Businesses which use hazardous materials and create
hazardous wastes may be liable for the contamination of land and water resulting
from the mismanagement of wastes. Settlements could potentially be very costly,
possibly resulting in the operation's closure. By avoiding the production of
hazardous waste, potentially through the use of pollution prevention, facilities
nearly guarantee freedom from environmental contamination liabilities. This
reasoning is most often cited by large firms as small firms are more concerned with
meeting their current payroll than long-term liability.
Uncertainties in Regulation
Hidden or unexpected costs are one of the greatest fears of business operators.
Because legislation, and therefore regulations, change annually, there is a great deal
of uncertainty regarding meeting requirements. A business may spend a large
amount of money to alter a process so that they can come into compliance with a
new regulation. However, changes in the following year may make those alterations
unnecessary. Therefore, money has been wasted on an ever-changing regulatory
framework. The uncertainty can be avoided if a facility moves out of the "regulatory
loop," by avoiding regulated substances or by-products in its processes. Pollution
prevention is an effective means by which to avoid regulated hazardous materials
and wastes.
8
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Regulatory and Pollution Prevention Contacts
at Key Governmental Agencies
Federal Agencies
United States Environmental Protection Agency (US EPA)
Air, Hazardous Waste, Water
The United States Environmental Protection Agency implements federal
environmental protection laws, including the Clean Water Act, the Clean Air Act,
and the Resource, Conservation, and Recovery Act (RCRA). In California, the
authority to implement many of these programs has been delegated to state
agencies.
• For questions concerning RCRA and Superfund, contact the Superfund
Hotline at 800-424-9346.
• For questions regarding upcoming pollution prevention events and resources
available through the EPA, contact the Pollution Prevention Information
Center (PPIC) Reference and Referral Line at 202-260-1023.
• With pollution prevention, technical and regulatory compliance questions,
contact the Small Business Ombudsman Hotline at 800-368-5888.
State Agencies ,
California Air Resources Board
Air
The California Air Resources Board regulates the emission of air pollutants. The
bulk of air regulations are implemented by subsets of the statewide organization,
known as Air Pollution Control Districts (APCDs). APCDs promulgate rules and
limits relevant to maintaining air quality in their particular jurisdiction. They
assure that these thresholds are not surpassed by issuing permits limiting each
emitter's contribution. They are responsible for enforcing rules established by the
ARB and operate semi-autoriomously in their pursuit of air protection. Some
businesses are required to assess and report the health risks associated with their
emissions to the ARB.
• For questions regarding regulations which you may apply to your business,
contact the information hotline at 800-242-4450.
Please see the South Coast Air Quality Management District section (Page 3) for
regional air regulations applying to businesses in Southern California.
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California Department of Toxic Substances Control
Hazardous Waste
The Department of Toxic Substances Control regulates hazardous waste generation,
treatment, and disposal. The Department has been granted the authority by the US
EPA to implement certain federal hazardous waste regulations. It also implements a
variety of other state laws. Through the Department you may obtain a US EPA
generator identification number and the proper forms for documenting hazardous
waste. °
• For information regarding hazardous waste generation, disposal, or pollution
prevention assistance, contact the duty officer of your regional Department
office. Contact the Glendale Office, serving the counties of Los Angeles,
Ventura and Santa Barbara at 818-551-2830. Contact the Long Beach Office
serving the counties of Riverside, San Diego, San Bernardino, and Imperial as
well as Torrance, Carson, Long Beach, Harbor City and Cerritos at 310-590-
4968.
The Department also operates an exchange program through which
businesses can exchange hazardous materials among one another as a
disposal cost savings mechanism. Contact the California Waste Exchange
(CWE) at 916-324-1807. S
California Integrated Waste Management Board
Nonhazardous Solid Waste
The California Integrated Waste Management Board regulates the siting and
operation of California landfills, as well as local governments' waste reduction and
recycling efforts among others. Although they do not.regulate businesses directly
(except those in industries related to waste management), they offer recycling and
materials reuse assistance.
• For recycling information, contact the Recycling Hotline at 800-553-2962.
• To participate in a statewide materials reuse and recycling program, contact
the California Materials Exchange (CALMAX) at 916-255-2369.
California Occupational Safety and Health and Administration
Worker Safety ~~~
The State of California has been granted the authority to implement federal worker
safety program through the California Occupational Safely and Health
Administration. Businesses are required to meet specifications for worker safetv
which they report to Cal/OSHA. "
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• For information regarding Cal/OSHA requirements or worker safety
consultations services, contact the Los Angeles office Consultation Service at
310-944-9366.
California State Water Resources Control Board
Water, Stormwater, Nonpoint Source
the State Water Resources Control Board protects the State's water resources. Water
Board laws are implemented through semi-autonomous regional governing bodies
known as Regional Water Quality Control Boards. Regional Boards permit large
industrial facilities and Publicly Owned Treatment Works (POTWs) to discharge
into the State's surface waters in accordance with water quality goals. Most small
and medium-sized businesses discharge to POTWs, not directly to surface waters,
and are therefore not directly regulated by the State or Regional Boards, but rather by
their POTW. See the POTW discussion under the regional and local governing
agencies section for POTW requirements.
• If you believe your business may be regulated by the State or Regional Board,
contact the Los Angeles Regional Water Quality Control Board office at 213-
266-7594 or the Santa Ana office at 909-782-3234 for assistance. As well, you
should contact the Regional Boards with questions regarding nonpoint and
Stormwater requirements.
California Department of Water Resources
Water Conservation
The Department of Water Resources regulates the use of California's water
resources. They do not, in most instances, regulate industry directly. However, they
do provide water conservation assistance to commercial and industrial facilities.
• For water conservation information, contact Charlie Pike, Industrial and
Commercial Water Conservation, at 916-327-1649.
Regional Agencies (Southern California)
South Coast Air Quality Management District
Air
The South Coast Air Quality Management District regulates air pollution in the
South Coast region. For regulatory and. pollution prevention information, contact
the Small Business Assistance Center at 800-388-2121.
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Local Agencies
Hazardous Waste Control
Health ***«««**
« • » C°ntro1 Law and
generation inspections annually.
be authorized to implement
P«form hazardous waste
"«,«
™ al?Ut yOUr StatUS M a hazard°us waste generator, desire
permit or disposal information, or are interested in receiving pollution
prevention assistance, contact your County Environmental Health
Department.
Imperial County Environmental Health Department
619-339-4203 F
Orange County Department Environmental Health
714-667-3629
Riverside County Department of Environmental Health
909:358-5055
San Bernardino Department of Environmental Health Services
714-387-3080
Santa Barbara County Environmental Health Services
805-346-8484
Ventura County Environmental Health
805-654-5040
In Los Angeles County, hazardous wastes are regulated by
2^890^045 COUnty Fire Department' Health ^ Hazardous Materials
In addition some cities have agencies that regulate hazardous waste or
provide pollution prevention assistance.
Hazardous Waste/Pollution Prevention Programs of Cities
Publk Utilities Department Waste Minimization Program
City of. Long Beach Environmental Health Department
310-427-7421
City of Los Angeles, HTM Office
213-237-1209
City of Pasadena Environmental Health Department
818-405-4390
City of Vernon Environmental Health Program
213-583-8811
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Hazardous Materials Storage
Many hazardous materials storage programs are operated through emergency
response programs of fire departments. For information regarding hazardous
materials storage requirements which may apply to your business, contact your local
fire department.
Your Publicly Owned Treatment Works (POTW)
Water
Many POTWs are city owned and operated. Depending upon the volume and
constituents of your wastewater, your business may be permitted to discharge by
your local POTW. POTWs permit dischargers in order to assure that the POTWs
comply with their own discharge permit. Beyond permits, most POTWs have
specifications of what can and cannot be discharged to the sewer system. Most
POTWs have pretreatment programs in order to reduce the quantity or toxicity of
waste they receive, operated in conjunction with a waste minimization program.
• If you are concerned about your discharges and desire compliance
information or are interested in finding out about your POTWs waste
minimization/pollution prevention assistance program, contact your local
facility.
• The regulatory, business, or pollution prevention assistance telephone
numbers of water treatment agencies serving the Southern California region
are:
City of Burbank
(818)953-9515
Camarillo Sanitation District
(805)388-5332
Chino Basin Municipal Water District
(909)987-1712
City of Corona
(714)782-4130
Eastern Municipal Water District
(909)725-7676
Irvine Ranch Water District
(714)453-5300
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Las Virgenes Municipal Water District
(818)591-1207
City of Los Angeles, Department of Public Works
(213)485-7580
Los Angeles County Sanitation Districts
(310)699-7411 ext. 2900
Orange County Sanitation Districts
(714)962-2411
City of Oxnard, Department of Public Works
(805)488-3517
City of Redlands
(714)798-7506
City of Rialto
(714)877-4215
City Of Riverside
(714)351-6140
City of San Bernardino
(714)384-5383
City of San Buenaventura
(805)642-4739
Simi Valley County Sanitation District
(805)583-0393
Thousand Oaks Utility Department
(805)497-8611 ext 312
Your Utility Provider
Energy Conservation, Water Conservation
• If you are a Southern California Edison customer, contact the Action Line at
800-952-5062 for energy conservation information and assistance.
• If you are a customer of the Los Angeles Department of Water and Power,
contact the Customer Assistance Line at 800-342-5397 for water and energy
conservation information.
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KERR & ASSOCIATES, INC.
2634 Wild Cherry Place • Reston, Virginia 22091 • -(70S) 476-0710
January 4, 1993
To: Jim Lund, Office of Water (WH-551)
From: Bob Kerr, Kerr & Associates, Inc.
Subject: Key Areas in Need of Coordination
: Region 9 Pilot Project (IPS)
Ref.: EPA Contract #68-WO-0025, Work Assignment #230
Task 2.1
The attached report summarizes the key environmental issues which either currently impact, or could
prospectively impact, industrial laundries, as well as listing other regulatory/statutory areas which, in
some cases, could be of importance. Because of the decentralization of implementation of
environmental authority in California among a range of state and local agencies, all agencies with
significant responsibilities will need to be involved in the workgroup process to make it meaningful.
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Report OB Areas in Need of Coordination
BACKGROUND
This task focused on analysis of regulatory, voluntary, and
statutory programs that might need to be coordinated in order to
promote multi-media approaches to pollution prevention. The
Local Government Commission (LGC), in a report prepared under
Task 1-1, summarized information on existing requirements
relevant to multi-media pollution prevention programs and
activities in California. Titled "Summary of Regulatory
Incentives for Pollution Prevention," it looked at pollution
prevention opportunities within the context of major federal,
state, and local environmental regulations that affect both POTWs
and their service industries. This report looks at a single
industrial sector — industrial laundries — in order to raise
issues for discussion, with the goal of identifying regulatory
areas in need of coordination for a multi-media pollution
prevention program targeted to industrial laundries.
In California, industry is finding it increasingly
challenging, and often confusing, to keep track of the
numerous — and often complexly related -- federal, state, and
local laws, regulations, policies, and enforcement practices with
which they must comply. Pollution prevention activities in
California, including those activities carried out by more
progressive POTWs, have been both useful and successful within
the scope of industries or pollutants of concern for the
individual projects. Where most successful, they provide a way
for many companies to deal with a wide range of environmental
problems in a cost-effective manner.
But more remains to be done to meet future environmental
demands. There is a need for a unified effort, one involving
both regulators and industry, one that looks at media-specific
program concerns but does so within a multi-media context.
Laundries were chosen in this pilot project as a target industry
because, like POTWs, they are a service industry and are not so
much generators of pollution as they are receptors of their
customers' pollution problems. Therefore, laundries present a
good opportunity for a program design that involves technical
outreach and a coordinated regulatory approach.
,The objectives of the pilot project are to: 1) promote
coordination among regulatory agencies and POTWs in southern
California; and 2) develop a model pollution prevention program
for industrial laundries that would address solid waste,
hazardous waste, wastewater, and air emissions in a unified and
coordinated manner. In order to better define the areas in need
of coordination in such a project, it makes sense to look at the
array of current and near-future regulatory programs that might
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have an impact on industrial laundries and their customers. The
following discussion briefly outlines some of the regulatory
intersection areas that need to be considered for coordination in
a model program targeted to industrial laundries.
AIR QUALITY
Air Toxics
The U.S. EPA has recently published a list of about 180
industrial toxic emission source categories, pursuant to section
112(c)(l) of the Clean Air Act Amendments (CAAA) of 1990. For
each industrial source on the list, EPA must develop "maximum
achievable control technology" (MACT) emission standards and
promulgate these over the next 10 years. While only major
sources1 in any given listed category will be subject to these
new MACT standards, area sources for which a finding is made of a
threat of adverse effects on human health and the environment
would also be subject to MACT regulation. The following are some
of the listed source categories with upcoming MACT standards
which may be relevant for POTWs, industrial laundries, and their
clients:
o
o
o
o
o
o
o
POTW Emissions
Industrial Dry Cleaning (Perc)
Halogenated Solvent Cleaners
.Paint Stripper Users
Printing, Coating, Dying of Fabrics
Printing/Publishing
Wood Furniture (Surface Coating)
In addition to the MACT technology-based standards, EPA may
have to promulgate health-based standards after the year 2000 if
risk is not adequately lowered through national MACTs.
At the state level , California already has in place several
programs addressing air toxics. With the enactment of AB 1807,
the California Air Resources Board (CARB) was given the authority
to identify and control toxic air contaminants on a compound by
compound basis. Eighteen substances have been identified as
Toxic Air Contaminants (TACs) for control under this program.
Estimates are that over 2,000 stationary sources statewide will
be subject to Toxics Best Applicable Control Technology (T-BACT)
standards. Another state toxics program, the air toxics "Hot
Major source emits 10 tons per year (tpy) or more of
single hazardous air pollutant (HAP) or 25 tpy or more of
combination of HAPs.
any
any
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Spots" program (AB 2588) , calls for air quality districts to
collect data on over 550 different air toxics and, in some cases,
notify the public of potential adverse health effects from a
facility. While larger facilities, including POTWs, must prepare
detailed inventories (called "Air Toxics Plans"), many small
businesses, such as dry cleaners, laundries, auto-bpdy paint
shops, furniture refinishes, etc., will participate in generic
industrywide surveys, and need not complete site specific
inventories.
In addition, several local air districts within the state
control toxics on the basis of health risk assessments, such as
in the South Coast area (SCAQMD rules 223 and 1401). The health
risk to be prevented in these rules is based on protecting the
maximally exposed individual for a lifetime exposure of 70 years.
The rules provide that permits will be issued for new and
modified sources with a risk of less than one-in-one million.
Public notice requirements are also part of this rule.
Preliminary data indicates that some California POTWs may
emit air toxics in amounts that exceed this level. Because air
toxics enter POTWs from a variety of sources, including
industrial laundries and their customers, industrial pretreatment
programs provide one avenue open to POTWs to help control their
industrial sources of air toxics. The Region 9 project should
provide a model useful to POTWs looking to integrate a multi-
media pollution prevention approach into an air toxics source
control effort for their plants.
Criteria Air Pollutants
These include VOCs. (to control ground-level ozone), NOx,
SOx, and PM-10 (particulates). Of these, changes in VOC and NOx
standards would be most relevant to industrial laundries and
their customers. SCQAMD, facing the most severe air quality
problems in the country, has one of the most stringent programs
for the control of VOCs in the nation, including product bans and
work place standards to promote the use of low-VOC chemicals.
Many VOCs are also air toxics and subject to control under the
above described toxics programs as well. Industrial laundries
utilize on-site boilers to heat water necessary for cleaning;
these generate NOx emissions. In districts such as South Coast,
all boilers (even residential boilers) are subject to permits.
As NOx standards tighten, there is incentive for energy and water
use efficiency in high water use industries such as laundries.
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WATER QUALITY
Federal Effluent Guidelines
On January 31, 1992, the U.S. EPA and the National Resource
Defense Council (NRDC) entered into a Consent Decree that will
guide EPA effluent guideline rulemaking activities over the next
decade. Industrial laundries are one of the four additional
industries that were specifically designated in the Decree as
being subject to new effluent guidelines. EPA has already begun
the rulemaking process and intends to complete an industry survey
within the next two years. According to the Decree, the
guidelines must be proposed by 1996 and in place by 1998.
Although EPA is still in the early stages of the rulemaking
process, focusing mainly on information collection activities,
laundries need to be made aware that if categorical standards
that set minimum pretreatment requirements are forthcoming, they
would affect almost all industrial laundries in one way or
another. In its May 1992, Proposed Effluent Guidelines Biennial
Plan (55 FR 19748), EPA estimated "the priority and
nonconventional loadings from this category [industrial
laundries] to be approximately 34 million pounds annually, [and
that] the discharge of these pollutants into sewage systems,
especially solvents from shop towels, potentially affects POTW
operations and discharges to receiving waters." Furthermore, EPA
states that "the economic impacts of some regulatory options on
this category may be relatively high, because many facilities are
small businesses."
A central goal of this pilot project is to explore
alternatives, such as Best Management Practices (BMPs) for both
laundries and their client facilities, along with other pollution
prevention focused activities such as waste minimization audits
that, if in place, might alleviate the need for some of the more
stringent categorical regulatory options (e.g., high-tech
pretreatment systems such as ultrafiltration). In any case,
reducing the incoming pollutant load to laundries, especially
solvents and oil and grease carried in on shop towels and rags,
could only improve a laundry's position with respect to any
upcoming categoricals. And since it takes time to get such
culture-changing options in place, now is the time to start.
Local Limits
Of course, all POTWs have the ability to impose local limits
in the absence of any federal effluent guidelines (in many cases,
local limits are much more stringent than categoricals anyway).
For industrial laundries, one of the most problematic local
limits is Total Toxic Organics (TTO). Laundries that accept shop
towels and printers' wipes are the ones that find the TTO limit
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most,difficult to meet. Also, there is often a big difference in
the limit's numerical value among different sanitation districts.
For example, Orange County has a TTO limit of 0.58 ppm, while
nearby L.A. County's is much higher, 5.0 ppm. This can lead to
geographical shifting of the problem: customers and/or the
laundries can either shift their business to less restrictive
districts, or smaller laundries with no local limit requirement
can take the dirtiest customer accounts.
In San Bernardino, where one laundry had continued high
levels of exceedances of the TTO limit (in spite of installing a
centrifuge/extractor which, however, frequently did not work) the
POTW threatened to disconnect the plant from the sewer unless it
solved its compliance problems. The plant began trans-shipping
its towels to another pdant without the same compliance problems.
Thereafter, the San Bernardino POTW found that the TTOs at the
facility dropped to non-detectable. But it is questionable if
this!is an overall environmental benefit since the shop towels
are how being laundered elsewhere, with additional transportation
impacts and no reduction in any air releases from the towels.
The challenge of this pilot project then is to identify ways
of working cooperatively to prevent such shifting from getting
out of hand. Some laundries actually ship their dirtiest
textiles to Mexico. If BMPs and other source reduction
activities can reduce the incoming solvent load, laundries may
not have to avoid "low limit" jurisdictions.
SOLID/HAZARDOUS WASTE
Hazardous Waste
, Since the passage of RCRA in 1976, there has been regulatory
uncertainty over the issue of whether shop towels contaminated
with listed RCRA solvents should be considered hazardous waste.
No definitive regulatory determination has been forthcoming from
EPA Headquarters, and most EPA Regions have more or less had to
"fend for themselves." Some, like Regions 4,7 & 8, take the
regulatory position thait towels which are destined for laundering
are not solid waste (destined for disposal or discard), and
therefore not within the realm of hazardous waste regulation
under RCRA.
: A few states (Minnesota and Washington state, in Regions 5 &
10, respectively) have taken a pragmatic approach. They have
formulated policies by which, if both laundries and their
customers follow certain Best Management Practices (BMPs) to
minimize the free-liquid solvents carried in on shop towels, the
towels may be managed without worrying about complying with full
RCRA hazardous waste memifesting and TSDF permitting
requirements.
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For California laundries, the target industry in this Pilot
Project, the Region 9 position remains that towels with listed
solvents on them are, by virtue of the "mixture rule," hazardous
waste under RCRA. That stated, however, Region 9 continues to
use enforcement discretion to consider this determination a low
priority. In principle, strict enforcement combined with the
Region 9 interpretation of the hazardous status of such towels
would force manifesting of the towels, and permitting of the
laundries as TSDFs. A possible result would be that laundries
would no longer accept such towels (many have already eliminated
the towel portion of their business to avoid regulatory risk),
and customers would switch to disposable wipes (increasing the
burden of solid and hazardous waste reguiring management and
disposal). Clearly, this is a key area to be fully explored and
coordinated in the course of designing this multi-media pollution
prevention Pilot Project.
Sludge Rules
EPA recently finalized its sludge use and disposal
standards, covering sludge which is applied to the land, disposed
in landfills, or incinerated. The final rule will affect more
than 35,000 entities, mostly POTWs. The rule includes specific
sludge limits for heavy metals, such as arsenic, chromium,
copper, lead, mercury, nickel, and zinc. For sludge that is to
be incinerated, there is also a total hydrocarbon limit. These
limits will all be incorporated into new NPDES permits for
affected facilities.
While POTWs have a range of options open to them to decrease
the metals and hydrocarbon loadings in the sludge they generate
from wastewater treatment activities, one may include looking at
upstream source reduction for targeted industrial users, such as
printers, vehicle repair shops, or industrial laundries. The
laundries themselves may be affected by the new sludge rules if
they generate sludge from their own pretreatment eguipment. If
the sludge does not meet the required metals and hydrocarbon
limits, local septage haulers may not be able to take it.
Currently, California sludge rules reguire TCLP and bioassay
testing. The new federal sludge testing may not be much more
stringent than that. Nevertheless, reducing metals coming into
laundries on shop towels, especially printers' wipes, is one way
of making sludge more acceptable to haulers. Also, lower metals
may mean less costly disposal options become available, such as
landfarming.
OTHER REGULATORY PROGRAMS
The following is a list of other federal, state, and local
6
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programs that might need to be considered for coordination in
this industrial laundry pilot project. We suggest that these
areas be further explored during the course of the project's
design to determine the extent to which there are any key
coordinating concerns.
o WORKER SAFETY/RIGHT-TO-KNOW
Federal OSHA
CalOSHA
Calif. Prop. 65
o U.S. DOT/HAZARDOUS MATERIALS TRANSPORT
o SUPERFUND
o RCRA LUST Program
o CWA Stormwater Program
r o FIFRA
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The 24 Members of the Interagencv Multi-media Team
State
Local
U.S. EPA, Headquarters
Office of Water
U.S. EPA, Region 9
Air and Toxics Division
Hazardous Waste Management Division
Water Management Division
California Department of Toxic Substances Control
California Department of Water Resources
California Environmental Protection Agency
California State Water Resources Control Board
Los Angeles Regional Water Quality Control Board
San Francisco Bay Regional Water Quality Control Board
Santa Ana Regional Water Quality Control Board
South Coast Air Quality Management District
CityofChino
City of Los Angeles
City of Riverside
City of San Bernardino, Water Reclamation
Eastern Municipal Water District
Los Angeles County Sanitation Districts
Orange County Sanitation Districts
City of Los Angeles Hazardous and Toxic Materials Program
City of Los Angeles, Office of Water Reclamation
Metropolitan Water District of Southern California
Orange County Environmental Health Department
Orange County Water District
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KERR & ASSOCIATES, INC.
2634 Wild Cherry Place • Reston, Virginia 22091 • (703) 476-0710
February 23, 1993
To: - Jim Lund, Office of Water (WH-551)
From: Bob Kerr, Kerr & Associates, Inc.
Subject: Minutes of Multi-Agency Work Group Meeting
Region 9 Pilot Project (IPS)
Ref.: EPA Contract #68-WO-0025, Work Assignment #230
Task 2.3
Enclosed are the draft minutes for the first meeting of multi-agency work group for the IPS Region 9
pilot project, held February 9, 1993, at the Orange County Sanitation Districts headquarters in Fountain
Valley, California. As you know, the purpose of the meeting was to bring together representatives of
various federal, state, and local regulatory agencies and industrial laundries to discuss multi-media
approaches to pollution prevention for laundries and their customers. Over 50 people attended the one
day meeting, with representatives from EPA Headquarters (Office of Water), Region 9 EPA, state and
local agencies, sanitation districts, and industrial laundries. The group's consensus was that the next
phase of the project should include:
o Establishment of a smaller focus group of POTWs, industrial laundries, state media agencies
(solid waste and air), and local health agencies.
o Two workshops on pollution prevention and best management practices (BMPs) for industrial
laundries and their customers;
o Facility assessments at industrial laundries to identify opportunities for pollution prevention,
findings to be presented at the workshops; and
o Discussion papers and final report.
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"COLLABORATIVE APPROACHES TO POLLUTION PREVENTION"
MULTI-AGENCY WORK GROUP MEETING
February 9, 1993
Orange County Sanitation Districts Office
10844 Ellis Avenue
Fountain Valley, CA 92708
-- DRAFT MINUTES --
I. Welcome, Introductions, Overview of Project
Virginia Cummings
.U.S. EPA Region IX
Introductory remarks were given by Ginny Cummings, the project's coordinator from
Region IX. Ms. Cummings said that the purpose of today's meeting was to bring together various
south coast POTWs, environmental agencies, and industrial laundries in a cooperative effort to: (1)
understand the different waste minimization and pollution prevention opportunities available to
industrial laundries; and (2) develop a multimedia pollution prevention pilot project that would
explore these opportunities in a more specific way. Pollution prevention was defined as "the use of
processes, practices, or products that reduce or eliminate the generation of pollutants," and may
include such activities as improved housekeeping and best management practices, process
modifications, and product reformulation (e.g., chemical substitutes). Where elimination of the
source of pollution is not possible, some forms of recycling—in-house, closed-loop measures which
return pollutants for reuse within a production process—may be considered pollution prevention.
For laundries that may mean water reuse, as well as other reuse and energy efficiency measures.
Bob Kerr
Kerr & Associates, Inc.
As moderator of the work group meeting, Mr. Kerr led the introductions, requesting that
each participant give their name, affiliation, and brief perspective on his or her interest in this
project. After the introductions, Mr. Kerr talked briefly about the background of the Regional
Project, its relationship to EPA headquarters Industrial Pollution Prevention Project (IPS), and its
context within some of EPA's other pollution prevention activities. He also outlined the scope of
today's meeting and reviewed the agenda.
II. Presentation on POTW Perspective
Adriana Renescu
Orange County Sanitation Districts
Ms. Renescu gave an overview of pollution prevention from the point of view of the
POTWs and talked about the unique opportunities and challenges industrial laundries present in
pollution prevention. Industrial laundries were selected as the "example" industry in this project
-------
because they are a service industry and are not so much generators of pollution as they are a
receptor of others industries' pollution. In this respect, laundries are similar to POTWs. As such,
the sphere of pollution prevention must extend beyond the laundry (as it must extend beyond the
POTW) and into the customer's facilities. The need, therefore, is to build a model program-a sort
of "blueprint" for future cooperative projects with industry-that would involve not only the POTWs
and industrial laundries, but other media agencies, in outreach and training directed at printers,
machine shops, and other facilities which use laundries to clean uniforms, shop towels, mats,
wipers, etc., and which are therefore indirect contributors of pollution.
Overall, the message is that we need to build partnerships with our customers. For
POTWs, that means their users, including laundries and contributors to laundries; for laundries, that
means their clients. We need to work cooperatively with all appropriate regulatory agencies to
design optimum pollution prevention approaches, which do not merely shift pollution around; and to
build a national, state, and regional consensus and spirit of cooperation in order to ensure a primary
role for pollution prevention in all our environmental activities.
III. Presentation on Industrial Laundries
Cam Metcalf
University of Tennessee, Center for Industrial Services
Mr. Metcalf, Manager of Training at the Center for Industrial Services, helped develop a
large, on-site pollution prevention technical assistance auditing program based heavily on the
support of retired engineers trained in pollution prevention. The Center is based within the
University of Tennessee. In addition to conducting site audits, Mr. Metcalf has held three national
video conferences (at least one day each) on specific types of industrial pollution prevention
opportunities, and has designed numerous training workshops for different industrial sectors
focusing on pollution prevention. Mr. Metcalf s presentation today gave an overview of industrial
laundries and their typical clients and customers. Industrial laundries receive most of their toxic and
volatile organic loadings from shop towels (also known as "rags" by non-industry speakers).
Auto/vehicle maintenance facilities (those in SIC 75 and other dealers/service stations) account for
42% of industrial laundry business. Shop towels from printers, while perhaps the most
contaminated items laundries accept in terms of organics and heavy metals from inks, represent only
5% of indutrial laundry business.
Mr. Metcalf outlined some of the pollution prevention opportunities available to both
laundries and their customers. For both, the establishment of and adherence to a set of best
management practices (BMPs), followed by continuous improvement in searching for ways to
minimize the generation of pollutants, is the key. He presented the results of a case study which
was done for EPA as part of its Design for the Environment initiative. The salient feature of that
case study was the development of partnerships: 1) chemical supplier partnerships for solvent re-
evaluation and substitution; 2) laundry service partnerships for material recovery and reuse by
centrifuge and other BMPs; and 3) multimedia regulatory partnerships.
On the regulatory issues side, Mr. Metcalf outlined some of the problems and
inconsistencies faced by industry when shop towels are considered to be a regulated hazardous
-------
waste. ;He briefly outlined the statutory and regulatory history of the issue, and talked about other
state and EPA Regional perspectives. Specifically, he told the work group about two efforts, one in
Minnesota and the other in Washington state, where regulatory agencies and industrial laundries
developed memoranda of understanding whereby as long as the laundries adhere to certain best
management practices, the shop towels would not be considered solid waste for the purposes of
RCRA regulation and control.
Finally, Mr. Metcalf presented a number of flowcharts showing the range of laundry
processes and activities which could, be candidates for an in-house look at pollution prevention
opportunities. For example, laundering chemicals used in the prespotting, washing, bleaching, or
other textile treatment steps, could contribute toxics such as phenolic compounds, chloroform, and
zinc, as well as cause problems with conventional pollutants such as high pH and BOD.
IV. Short Discussion of Issues/Concerns
Following Mr. Metcalf s presentation, Mr. Kerr conducted a brief discussion of the issues
raised so far in the morning session. There was a general feeling that while most of the large
issues, such as the shop towels as hazardous waste and the laundries' concern that increased
regulatory pressure will only lead to shifting the problem elsewhere (e.g., to less restrictive districts
or even to Mexico), had been touched upon, they needed to be explored more in depth. It was
recognized that no final answer would be forthcoming from this meeting, but that a process of
shared dialogue had been started and that it needed to continue to evolve. Issues and concerns
raised during this brief discussion are summarized under the writeup of the afternoon's more
complete discussion.
V. Lunch
The work group broke for lunch at 12:30 and re-convened at 1:30 P.M.
VI. Afternoon Discussion
The afternoon session was devoted to a wide-ranging discussion that explored many of the
areas of concern brought out in the morning session. The key issue areas the work group discussed
fell into the following general categories:
o Best Management Practices (BMPs)
o Shop towels as hazardous waste
o Water conservation/reuse
o Pretreatmenl; limits
mass v. concentration-based limits
Total Toxic Organics (TTO) limits
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A. Best Management Practi^s
The group concurred that one of the biggest problems for laundries and the area of most
concern for regulatory agencies is dealing with shop towels. Pollution prevention options for
laundries that process shop towels could include: 1) education of their customers on P2
opportunities to prevent shop towel contamination; and 2) use of BMPs at the customer's site prior
to transportation to minimize the amount of solvent in the material accepted by the laundry for
washing. The group discussed a range of BMPs for the safe handling of solvent-laden shop towels
which might include:
Requirement of no free liquids
Use of the paint filter test (used by some states)
- Use of a wring test (hard to standardize)
- Collection containers with mesh bag (to allow free liquids to settle)
— Weigh towels and reject those above certain weight
Centrifuges mounted on trucks
Other discussion points with respect to BMPs:
* Some contamination is unavoidable - gasoline, motor oil, beauty shops.
* Towels are sometimes used to pickup spills. Customers also use towels instead of brushes
(e.g., furniture refmishers). Need to educate operaters to minimize use of
solvents/paints/varnishes.
* Problem used to be worse. AQMD regulations on VOCs have reduced the inflow of
pollutants to the laundries (e.g., they are already seeing switchovers to soy based inks).
* Additonal improvement may be necessary. A first step would be to segregate saturated
towels. Laundries do segregate materials as they come in. However, it must be recognized
that they have a broad mix of customers.
* While much discussion has focused on ink wipers used by printers, not all solvents getting
to laundries come from printers. For example, TCA comes mostly from auto repair shops
and body shops.
* Need to recognize that printers are not a majority of everyone's business. Also, that toxics
are not everything. Laundries have to deal with conventional pollutants too, like TSS. This
too can be a problem.
* Need ongoing interaction between POTWs and laundries. Laundries want to know what
causes POTW's problems. What are their contaminants of concern? What's hard for them
-------
B.
to treat? Want to work cooperatively to help identify if their customers are contributing to
the problem. Need to start a dialogue.
Training — many agencies are providing it — everyone should. But who should be
responsible for training customers? Laundries? Agencies? Need to work cooperatively.
Public image can be an incentive for some laundries (want to "do the right thing"
environmentally). May not be important for smaller laundries, however.
Shop Towels as Hazardous Waste
The general perspective from industrial laundries is that they need resolution of the
hazardous waste issue. Although it was understood that this work group was not the appropriate
forum for dealing with that issue, there was some shared benefit from allowing the issue to be put
on the table as a problem of primary concern to the regulated community.
Background of the classification of shop towels as hazardous waste:
* Regions 4,7 & 8 regulatory position is that towels which are laundered are not solid waste,
therefore not within realm of hazardous waste regulation under RCRA
* Region 9 position is that towels with listed solvents on them are, by virtue of the "mixture
rule," hazardous waste under RCRA
They cite problem of setting legal precedent
Lack of national guidance on the issue
Region 9 will continue to use their discretion to consider this a low priority (i.e., not
enforcing to letter of the law)
Need to push EPA Headquarters for interpretation/guidance
* EPA Headquarters has established a Solid Waste Task Force (met for the first time Feb. 1,
1993) which may consider this issue. Most likely will say that it is a Regional/State
decision. There may be a letter forthcoming from Headquarters clarifying this.
* The California state RCRA program must be at least as stringent as the federal RCRA
program. So must look to EPA for consistency in interpretation of regulatory issues
surrounding rags.
In general, the response from laundries was that just saying it's a "low priority" doesn't help. At
least in Region 9, they are still open to possible NOVs, liability concerns, and suits by public
interest groups. Can't go on living with that uncertainty. For example, Mission Industries, one of
the largest chains operating on the west coast., has made a corporate decision to no longer accept
inkers from printers, in part due to the atmosphere of uncertainty as to whether or not these towels
could be considered hazardous waste.
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c.
Water Conservation/Reuse
In general, the issues surrounding water conservation and reuse in laundries focused on cost
effectiveness, potential for cross-media transfer, and limitations on how far one can go with
conservation measures before pretreatment limits that are concentration-based become problematic.
Discussion points included:
* What can Sanitation Districts tolerate in effluent to allow for reuse? (e.g., the Chino/San
Bernadino/Riverside area POTWs cannot take effluent with high TDS because of need to
reuse treated water for agricultural purposes in those basins.)
* While not all water efficiency measures require large inputs of energy, many do and this can
become a limiting factor.
* Right now, energy costs limit water reuse. If cost of water goes up, then water reuse may
become more cost-effective.
* Cost of water will continue to increase. The Metropolitan Water District says they are
considering a 20% increase in water rates. POTWs say the cost of wastewater discharge is
going up as well.
* Cross-media impacts exist and cannot be overlooked when thinking about water reuse
(especially those involving energy usage).
* Laundries are already efficient now, in terms of water use. Water used to cost $638/acre-
foot, now up to $1692/acre-foot. Price increases have created incentive to be water-
efficient. Many laundries have water reuse already. Segregation of wastewaters within the
laundry may make water reuse easier.
* Some state and local agencies are working with their water users, providing money for
water efficiency measures, and educating them about conservation. Water utilities and
electric utilities are a good model for outreach as a service industry for dissemination of
information on conservation and pollution prevention.
D.
Pretreatment Limits
The key issues surrounding pretreament limits for laundries were focused on the problem of
concentration-based v. mass-based standards, and the problem associated with total toxic organic
CTTO) limits that may be technically infeasible to reach with pretreatment. While low TTO limits
might be seen as a motivator for pollution prevention, laundries have other ways to address such
limits and that is to ship shop towels to another plant in a less restrictive district. Many are doing
just that. Some are shipping them as far as Mexico.
Discussion points included:
* Concentration-based limits may impair further improvements in water reuse. However,
-------
mass-based limits can be difficult to implement by the sanitation districts. Need to be able
to meter the flow of effluent.
Total Toxic Organics (TTO) limits and safety are a concern for industrial laundries
accepting solvent-laden towels. Mission Industries has decided to no longer accept inkers
from printers.
TTO limits — pollution prevention may be able to address.
Need realistic limits. (General feeling among launderers is that Orange County's TTO limit
of 0.58 ppm is unrealistically low).
Problem with POTW limits differing in different districts. Hard to provide a consistent
message to customers. Problem with shifting of problem: 1) customers and/or the laundries
can shift business to less restrictive districts; 2) smaller laundries with no pretreatment
requirements can end up getting the dirtiest accounts.
Some POTWs simply ban shop towels in their districts. San Bernadino said "no shop
towels" and effluent at one facility went from 17 ppm (xylenes) to non-detectable (all
organics); but not really an environmental benefit because the laundry just ships the shop
towels to its L.A. facility.
VII. Summary of Action Items
The following were some of the suggestions for next steps the group might want to consider:
Agencies sponsor workshops for laundries to help them in working with their
customers.
Focus on ways of transfering information; need to get information out to small
laundries too, Find ways of working with your regulatory agencies.
Develop BMPs and communicate to Washington about problem with hazardous
waste definition of shop towels. '
Issue papers dealing with: 1) Areas that need resolution; and 2) Ways to work
cooperatively towards improvements
Do facility assessments, work with laundries to identify their problematic waste
streams. Could feed into workshop process.
Group's Consensus on Action Items:
1) Issue paper to examine regulatory issues and changes that are needed, from federal down to
the local level. Document problem with definition of shop towels as hazardous waste.
-------
8
2) Workshop to help laundries develop outreach to their customers on pollution prevention and
BMPs.
3) Workshop to help laundries do in-house pollution prevention and BMPs for the shop floor.
VIII. Adjournment
The meeting was adjourned at 4:00 P.M.
IX. List of Attendees
See attached.
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ceiteteaawABi8roMhi>tqPoa>itloriPi»v«ntteB'Frtryary9.lW UpMrtfibnivyX, IMS
Susan April
Kerr and Associates, Inc.
2634 WUdCheny Place
Reeton,VA 22091
Phone 703-476-0710 ., t
Ken Amopole
Arnopole and Associates
6433 Topang* Cyn Blvd/ Stc 294
Canoga Park, CA 91303 ;
Phone 818-888-9408
KathzynBarwick
DT5C
P.O. Box 806
Sacramento, CA 95812-0806
Phono 916-323-9560
Jesse Baskir
US EPA Region IX
75 Hawthorne Street
San Francisco, CA 94105
Phone 415-744-2190
Jim Bennett
SWRCB, Office of Holity Development
901 T Street
Sacramento, CA 95814
Phone 916-657-1287
Joe Brancatelli
L&N Uniform
1634E. EdingerSt
Santa Ana, CA 92705
Phone 714-558-3392
Helen Burke
US EPA Region IX
75 Ilawthome Street
San Francisco, CA 94109
Phone 415-744-1069
Susan Burrie
US EPA Headquarters
40JMSt.,SW
Washington, DC 90460
Phone 202-260-0935
Donna Chen
City of I.A HTM Offlee
200 N. Spring St., Rm. 356
Los Angeles, CA 90012
Phone 213-237-1209
John Chen
Unitog
101 West llth Street
Kansas City, MO 64105-1856
Davi«l ClannpiU
Instl tute of Industrial Laundaries
1730 M Street, NW
Washingto^, DC 20036
Phone 202-29^6-6744
Prentice Clinton
City of San Bernardino, Water Reclamation
Department
299 Blood Bank Road
Son Bernardino, CA 92408
Phone 909 384-5383
Ginny Cummlngs
US EPA Region IX
75 Hawthorne Street
San Francisco, CA 94105
Phone 415-744-1937
\
Howard Dickson
Angelica Healthcare
300 Ranger Street
Brea,CA 92671
Phone 714.579-0909
Theresa Dodge
Los Angeles County Sanitation Districts
1955 Workman Mill Road
Whittier,CA 90601
Phone 310-699-7411
John Dunlap
DISC
P.O. Box 806
Sacramento, CA 95812-0806
Phone 916-322-0506
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1993
Jot Bubankc
Unitog
101 Wa*t llth Street
Kansas City, MO 6*105-1856
Phone 816-474-7000
Anthony Eulo
Local Government CommiMion
90912th Str*«t, Suite 205
Sacram«nto,CA 95814
Ph«rus 916-448-1198
Sherri Fairbanki
SCAQMD
21865 Cast Copley Drive
Diamond Bar, CA 91765-4182
Phone 909-396-2383
Sergio Fierro
Department of Water Resources
P.O. Box 29068
Glendale,CA 91209-9068
Phone 818-543-4625
Mikt Gilbert
L&N Uniform
1634E,EdingerSt.
Santa Ana, CA 92705
Phone 714-538-339Z
John Hlnton
DISC
245 W. Broadway, Ste 350
Long Beach, CA 90802
Phone 310-590-4864
Pearl Hoftiezer
Orange County Environmental Health
2009 E. Bdinger
Santa Ana, CA 92705
Phone 714-667-3629
Farouk Ismail
SWRCB
P.O. Box 944212
Sacramento, CA 94244.2120
Phone 916-323-9021
Kathryn Karrer
SWRCB
901 T' Street
Sacramento, CA 95814
Phone 916-637-UVIO
Bob Ken
Kerr and Associates, Inc.
2634 Wad Cherry Place
Rcston,VA 22091
Phone 703-476-0710
Judy Lankey
Easlern Munidpol Water District
P.O. Box 8300
SanJacinto,CA 92518-8300
Phone 714-923-7676
Mike Leebert
Western Municipal Water District
P.O. Box 5286
Riverside, CA 92517-5286
Phone 714-780-2450
Rod Lessley
Mission Industries
619 E. Monticttto St.
Santa Barbara, CA 93103
Phone 805-»63-1841
Julie Lie
Metropolitan Water District of Southern
California
P.O. Box 54153
Los Angeles, CA 90054
Phone 213-250-6380
Mark Liner
US EPA Headquarters
401MSt.,SW
Washington, DC 90460
Phone 202-260-0935
lara Lusk ••
City of Loc Angeles, Bureau of Sanitation
46UU Colorado Blvd.
Los Angeles, CA 90039
Phone 213-237-0806
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Cam Metcalf
University of Tennessee, Center for Industrial
Serv.ces
226 Capitol Blvd. Building, Ste. 4101
Nashville, IN 37219-1804
Phone 615-242-4816
RodMUlican
SCAQMn
21865 East Copley Drive
Diamond Bar, CA 91765
Phone 909-396-2591
Traci Minamlde
City of Los Angeles, Bureau of Sanitation
4600 Colorado Blvd.
I.o* Angeles,CA 90039
Phone 213-237-0802
Andrew Murray
Local Government Commission
90912th Street, Suite 205
Sacramento, CA 95814
Phone 916-448-U98
Mohsen Nazemi
SCAQMD
21865 East Copley Drive
Diamond Bar, CA 91765
Phone 909-396-2662
Joe O'Connell
Environmental Resolutions Inc.
9272 Jeronimo Road, Ste 106
Irvine, CA 92718
Phone 714-457-8950
AlPielin
City of Riverside
5950 Acorn Street
Riverside, CA 92504
Phone 909-351-6140
Charlie Pike
Depaanent of Water Resources
1416 9th Street, Rn\ 804
Sacramento/ CA 95814
Phone 916-633-5584
Michael Plasencia
City of Riveraide
5950 Acorn Street
Riverside, CA 92504
Phone 909-351-6140
Bill Preston
Santa Ana Watershed Project Authority
11615 Sterling Av«.
Riverside, CA 92503
Phone 714-785-5411
Saul Rackauskas
Mission Industries
619E. MonticetoSt
Santa Barbara, CA 93103
Phone 805-963-1841
Adrian* Renefcu
Orange County Sanitation Districts
10844 Ellis Ave
Fountain Valley, CA 92708
Phone 714-962-2411
David Robblns
Best Washington Uniform Supply
Box 22690
Long Beach, CA 90801
Phone 310-498-6626
John Shaffer
Environmental Resolutions Inc.
9272 Jeroninuo Road, Ste 106
Irvine, CA 92718
Phone 714.457-8950
Bahman Sheikh
City of Los Angeles, Office of Water Recla-
mation
200 N. Main Street, City Hall Bast, Rm. 570
Los Angeles, CA 90012
Phone 213.237-0887
Ditas Shiklya
SCAQMD
21865 East Copley Drive
Diamond Bar, CA 91765-4182
Phone 909-396 3060
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Prudential Overall Supply
P.O. Boat 11210
Irvine, CA 92714
Phone 714-250-4855
RieHVaille
US EPA Region IX
75 Hawthorne Street
SanFrand*co/CA 94105
Phone 41S-744-2090
Vincent V«nh
City of Los Angeles, Bureau of Sanitation
4600 Colorado Blvd.
Lo» Angelep/ CA 90039
Phono 213-237-0802
Evelyn Wachtel
US EPA Region IX
75 Hawthorne Street
San Frandsco, CA 94105
Phones 415-744-1943
Jantea Walton
Qty of San Bernardino, Water Reclamation
D«partment
299 Blood Bank Road
San Bernardino, CA 92408
Phone 909-3M4-53K3
Bob Wilde
Angelica Healthcare
300 Ranger Street
Br@a,CA 92621
Phone 714-579.0909
Joe Zapalac
Welch'* Uniform Rental
5950 Alcoa Avenue
Vernon, C A 90058
Phon* 213-587-3941
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KERR & ASSOCIATES. INC.
2634 Wild Cherry Place • Reston, Virginia 22091 • (703) 476-0710
February 2, 1993
To: Jim Lund, Office of Water (WH-551) ;
From: Bob Kerr, Kerr & Associates, Inc.
Subject: Overheads for Presentation of Industrial Laundry Pollution Prevention Options
Region 9 Pilot Project (IPS)
Ref.: EPA Contract #68-WO-0025, Work Assignment #230
Task 2.2
The attached overheads summarize waste generation and pollution prevention options for industrial
laundries. They will be used at the February 8th meeting.
-------
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Solvents Reduction &
Reuse
Customer
Alternative cleaners
Wring, centrifuge or strip for reuse
Industrial laundry
Dry cleaning processes
Semi-aqueous cleaners in wash cycle
(terpenes/d-limonene, etc,)
Centrifuge & recover for reuse or fuel
Strip & recover for reuse or fuel
Reuse by WHOM and HOW legally?
Generator/Customer
Industrial Laundry/Generator
Associations
Local/state/federal staff
Waste Exchanges
-------
Regulatory Barriers to P2
End-of-Pipe Focus
Media-Specific Focus
D Regulatory Program Evaluation Criteria
D Regulatory Inflexibility
Regulatory Uncertainty
Pollution Fees
Data Gathering and Management
-------
Resource Conservation
Programs
Using the latest technology may require less
energy, water and chemicals and cycle times are
reduced.
CJ Monitoring water, gas and electric costs is
necessary.
Identify peaks and valleys and what
measures might reduce usage.
Determine if activities could be reduced
during non-production hours.
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?
-------
Resource Conservation
Water
What percentage of small & large laundries are
reusing wash water?
Does one washer or method of washing use
more water than others?
O How is the liquid removed when the cycle is
complete?
D Can the various cycle discharges be separated?
-------
Resource Conservation
Water
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?
-------
Hazardous Wastes
Generated
O Filter Cake
D Waste Oil
O Still bottoms from the distillation of Perc
O Recovered Solvent
D Lint
O Vehicle Maintenance Wastes
-------
Solid Wastes Generated
Shipping and packaging materials
Cardboard boxes
Plastic and Paper bags
Fiber, Plastic and Steel Drums
Pallets
Lint
Nonhazardous Sludges
Textiles taken out-of-service
Hangers
-------
Waste Reduction Options
D Separate and maintain control of waste streams
O Establish a Waste Reduction Program
CJ Implement BMPs for laundries & customers
O Implement better Standard Operating
Procedures
Purchasing (substitue) raw materials
Inventory control
Good housekeeping
Maintenance and Preventative Maintenance
Reduce shipping and packaging wastes
O Implement paper and paper products recycling
O Utilize Waste Exchanges
Recover and Reuse Solvents
-------
Incentives for Waste
Reduction Program
p Conserve resources
P Substantial economic return
P Reduced liability
P Regulatory compliance
P Protect the environment
P Good public image
P Good marketing tool
-------
Best Management
Practices (BMPs)
Policy deployment on BMPs & Monitoring
Guide for serving heavy soil customers
O Checklist for identifying soil types and
pollutants of concern
Improve marketing
Use water & energy conservation programs
Identify positive benefits for the customers
-------
Better Standard Operating
Procedures
Toxics use reduction
Proper handling and storage to avoid leaks and
spills
Inventory control (Shelf-life)
Avoid inefficient production start-up or
shut-down *
Identify scheduling problems
Emergency procedures which minimize waste
Preventative maintenance to reduce downtime
and wastes
Maintain calibrated devices on laundy and
treatment processes
Select adsorbents that can be reused
-------
Major Maintenance
Operations
O Laundry equipment
n Dry cleaning equipment
D Treatment systems
D Boilers
Fleet vehicles
Facility and property
-------
Maintenance &
Pre ventative Maintenance
O Reduce incidents of equipment breakdowns
Reduce inefficiency and downtime by
implementing corrective actions
Reduce process fluids and chemicals leakage
Periodically replace seals
Check hose connections & couplings
Cleaning lint screens to avoil clogging and
handling the lint properly
Corrective Maintenance to prevent raw material
& energy loss
Resetting control valves
Adjusting process temperatures
-------
Supplier Partnerships and
Involvement
D Negotiate for returnable drums & bulk
containers
O Negotiate for reuse or elimination of pallets
D Recondition drums for reuse
Sending drums to scrap metal vendors
-------
Paper Products Recycling
Programs
High grade office paper
Cardboard and Bags
"Super Saks"
Reuse of boxes & gaylords
Bale & Sell
Recycle with vendors & charities
Utilize Waste Exchanges
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SUMMARY
Focus Group Meeting
March 11, 1993
Los Angeles County Sanitation Districts
Welcome and Introductions
In attendance were Theresa Dodge & Mischelle Mische of the Los Angeles
Sanitation Districts, Adriana Renescu of the Orange County Sanitation
Districts, Dave MacKenzie of the Western Textile Services Association, Joe
Zapalac of Welch's Uniform Rental, Tara Lusk and Bill Warren of the City of
Los Angeles, Larry Snow of Reliable Textile, Ginny Cummings of the U.S.
EPA, and Tony Eulo of the Local Government Commission. Attachment A is
the agenda from the meeting.
Background on the Project
Ginny Cummings gave a brief overview of the history of the project that
included both a summary of the February 9 meeting and an analysis of how
the project fits into the "big picture"
Solving Common Problems in the Present and Future
Representatives from sanitation agencies listed some of the pollutants that
were either presently creating regulatory or operational problems for their
facilities or were anticipated to create problems in the future. With the
knowledge and insight of the laundry representatives, participants identified
the likely prime sources for nearly all of the pollutants. The results of this
discussion are listed in Attachment B.
Pollution Prevention Opportunities
Several members of the group described how existing pollution prevention
efforts in governmental agencies have worked to reduce the generation and
release of pollutants into the environment. Discussion ensued on how the
laundries could participate in this effort to reduce the pollutant loading they
receive at their facilities. Several key areas of agreement were reached.
These include:
- Laundries Publicize Agency Pollution Prevention Programs and other
programs, e.g., HTM Office in LA, and the Business Environmental
Assistance Center
- Agencies Develop a Package of Outreach Materials and List of Resources
that Laundries Could Distribute to Their Customers
- Use Trade Association Newsletters to Publicize How Laundries Can Work
With Their Customers to Prevent Pollution
-------
Co°rdinate Their Pollution Prevention and Enforcement Efforts
With Those of the Laundries, e.g., talk about their use of towels spill
prevention, alternatives to using disposable paper rags pollution
prevention plans)
Planning the Workshop Agenda
It was proposed that the morning sessions of the workshops focus on ways
the laundries can work with their customers and that the afternoon sessions
locus on ways the laundries can prevent pollution within their own
operations. There was some question as to the value of the afternoon session
and concern that participants may be uninterested in the afternoon session
It was decided that we would wait until after Cam Metcalf completes his
assessments to determine the anticipated value in the afternoon sessions. If
there is little value anticipated, the workshops could end at noon
Attachment C is the workshop agenda developed at the meeting.
Planning a Workshop Outreach Strategy
Several key outreach activities were outlined. These include:
- Dave Mackenzie will mail out the workshop flyer to the laundries and
mention the workshops at upcoming meetings
" ^iPf0 ^? notify the Institute of Industrial Laundries and ask them to
publicize the workshops
- The Sanitation Agencies will mail out workshop announcements to the
laundries discharging to their systems
Scheduling Future Focus Group Activities
The workshop planning focus group will meet again on March 31 to discuss
the afternoon session, monitor planning progress, and review the outreach
strategy.
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Attachment A
Focus Group Meeting
March 11, 1993
Los Angeles County Sanitation Districts
9:00 - 9:15
9:15 - 9:20
9:20 - 10:00
10:00 - 10:30
10:30 - 10:40
10:40 - 10:50
10:50 - 11:20
11:20 - 11:50
11:50 - 12:00
Welcome and Introductions
Background on the Project
Solving Common Problems in the Present and Future
« What are the pollutants of concern?
• What are the sources of these pollutants?
Pollution Prevention Opportunities
'• What pollution prevention approaches have
worked in the past?
• How can governmental agencies and laundries
work together to reduce the pollutants of concern
at the source?
Break
Introduction to the Laundry Workshops
Planning the Workshop Agenda
« What are the issues that need to be discussed?
« Identifying content, materials, and potential
speakers for the workshops
Planning a Workshop Outreach Strategy
Scheduling Future Focus Group Activities
-------
Attachment B
POLLUTANTS OF CONCERN & PROBABLE SOURCES
• Hndane (agriculture, pest control companies)
• tri methyl benzene (?)
• bis ( 2 ethylhexyl) phthalate (cutting oils, furniture
manufacturing, machine shops, maintenance of machinery)
• methylene chloride (maintenance of machinery, auto repair,
printers, graphics, furniture manufacturing)
• copper (printers, metal finishers)
• silver (printers, metal finishers, photo processors)
• zinc (agriculture, pest control, laundry chemicals, automotive
repair)
• chromium (metal finishers)
• TCE (printers, automotive, metal finishers, aerospace)
• TCA (printers, automotive, metal finishers, aerospace)
• nickel (automotive repair)
• benzene (automotive repair, printers, refineries)
• chloroform (health services)
• MEK (automotive repair, printers, labs)
• xylenes (automotive repair, printers, labs)
• cadmium (printers, graphics)
-------
Attachment C
Draft Workshop Agenda
WHY ARE WE HERE?
Regulatory mandates (Broad spectrum of current and future) Dave
MacKenzie
Pollution Prevention Introduction (It's not the treatment or transfer
of pollutants) Adriana Renescu
Pollution Prevention is Good for Business (Getting Back Customers,
Staying in Business, Increasing Business, Increasing
Profits) Joe and Dave will find a laundry person
POLLUTANTS OF CONCERN AND SOURCES
Present our findings
Solicit additional information
Theresa Dodge
OPPORTUNITIES TO WORK TOGETHER WITH CUSTOMERS ON POLLUTION
PREVENTION ACTIVITIES
Providing information to customers, publicizing assistance
programs, use as a facet of marketing efforts Joe and
Dave will find a laundry person
RESOURCES AVAILABLE TO SUPPORT POLLUTION PREVENTION EFFORTS
Donna Chen, Kathy EJarwick, BEAC, Edison Representative
LUNCH BREAK
The afternoon sessions will be established after Cam conducts his
assessments with the laundries
-------
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SUMMARY
Focus Group Meeting
March 31. 1993
Los Angeles County Sanitation Districts
Welcome and Introductions
In attendance were Theresa Dodge of the Los Angeles Sanitation Districts,
Adriana Renescu of the Orange County Sanitation Districts, Lalo Bakhoum of
the South Coast Air Quality Management District, Dave MacKenzie of the
Western Textile Services Association, Joe Zapalac of Welch's Uniform
Rental, Tara Lusk and Donna Chen of the City of Los Angeles, Larry Snow of
Reliable Textile, Eileen Sheehan of the U.S. EPA, and Tony Eulo of the Local
Government Commission. Attachment A is the agenda from the meeting.
Update on Program Activities: Report on the Laundry Assessments
Representatives of the laundries and sanitation agencies discussed their
experiences during the laundry assessments performed by Cam Metcalf. The
laundries visited had a fairly wide variety of operations with different
customers and different environmental regulatory agencies to deal with.
Eileen reported that, based on what he saw, Cam felt that the three areas
that could be addressed were energy conservation, water conservation, and
process chemicals. Laundry representatives felt that most laundry owners
knew about the potential improvements available from these ideas but were
either already implementing them or unable to implement them for
financial reasons. Old facilities can be very difficult to retrofit and an 18
month payback period or less is needed to make a project viable for this
industry.
Another point that Cam asked Eileen to raise was the importance of the
laundry drivers in communicating the pollution prevention message. Laundry
representatives brought up two important issues:
• They are not called drivers but are instead called route salespeople.
They are the only field representatives the laundries have. Their
territories are exclusive and any time not spent actually servicing
customers is spent finding new customers;
• The route salespeople work on pure commission and, therefore, have
a very limited interest in monitoring the "cleanliness" of the soiled
towels and uniforms. They are most interested in making their service
calls as quickly as possible. In addition, being on commission, they
cannot be made to attend trainings unless the laundry owner is going
to pay them for doing so. Some laundries have had success in getting
route salespeople to a training if a dinner is included and it doesn't
-------
Hmlt their field time.
These two points led the group to conclude that:
• The route salespeople are still very important to this effort - especially
if they are the only field representatives that the laundries have;
• The workshops need to address how to develop better training
programs for route salespeople; and
• Route salespeople should be brought into the effort at some point to
get their feedback.
Two other ideas mentioned for presenting pollution prevention ideas in a
manner that is likely to generate the interest of route salespeople is to
present these ideas as "Tips for better serving customers" and to potentially
develop a bonus program for preventing pollution and protecting the laundry
facility.
Finalizing the Workshop Agenda: Reevaluation of the Afternoon Session
The group wanted to wait until Cam has submitted his report to determine
whether or not a session on laundry operations would be useful. The report
is due April 17. *
Other afternoon agenda items are:
• The Importance of Route Salespeople and
• Technical Resources and Training / Marketing Training To & For
Route Salespeople
Ending the workshops at 2 pm was suggested to minimize the time spent in
the afternoon.
To develop these agenda items, it was brought up that the laundries have
people who are responsible for training and motivating laundry staff. These
people will be experts in developing approaches that will garner the interest
of the target audience. Project staff will contact these people to introduce
them to the workshops and obtain their input.
Some specific strategies were identified for working with route salespeople
These included:
• Having checking systems at the laundries;
• Providing route salespeople with incentives;
• Providing route salespeople with brochures;
• Mandating that the route salespeople do a better job of working with
their customers; and
-------
• Designing a "Reference Checklist" that the route salespeople could
keep in their trucks. The checklist would clearly describe what the
salespeople should be doing at each stop to appropriately screen the
materials that they're picking up.
Dave is going to speak to the Teamsters and get them involved in this effort
in order to brief them on the issues that the laundries are facing in this area
and gain their cooperation 'in working with the route salespeople.
Finalizing the Workshop Agenda: Update on Speaker Solicitation
Tony informed the group that Kathy Barwick and Donna Chen had already
agreed to speak. Other speakers had not yet been contacted.
Dave and Joe were going to find speakers for the two items they agreed to
find speakers for before the next planning meeting. Attachment B is the
updated workshop agenda.
Outreach Strategy Update
Project staff had not yet done the workshop flyer because the workshops
have been postponed. The flyer will be completed in the coming weeks.
Developing Resources to Facilitate the Exchange of Pollution Prevention
Information Between Laundries and Their Customers
Ideas for developing these resources were discussed. Participants indicated
that it would be best if the project staff developed these resources. UC
Riverside, the LA HTM Office, and the EPA were all mentioned as sources
for model bibliographies. Orange County and Los Angeles County Sanitation
Districts were mentioned as potential sources for identifying model
checklists. A reference list of governmental employees (who, where, what
they do) will be developed for the workshop as well.
Scheduling Future Focus Crroup Activities
The workshop planning focus group will meet again on April 27 to discuss
the afternoon session, monitor planning progress, and review the outreach
strategy. We will plan on doing a "dry run" of the workshop at this session.
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Attachment A
F'ocus Group Meeting
March 31, 1993
Los Angeles County Sanitation Districts
2:00 - 2:10
2:10 - 2:25
Welcome and Introductions
Update on Program Activities
• Update on General Programmatic Activities
• Report on the Laundry Assessments
2:25 -3:00
Finalizing the Workshop Agenda
• Reevaluation of the Afternoon Session
• Update on Speaker Solicitation
3:00-3:10
3:10-3:40
Outreach Strategy Update
Developing Resources To Facilitate The
Exchange of Pollution Prevention Information
Between Laundries and Their Customers
3:40 - 3:55
3:55 - 4:00
Scheduling Future Focus Group Activities
Meeting Evaluation and Adjournment
-------
Attachment B
Draft Workshop Agenda
WHY ARE WE HERE?
Regulatory mandates (Broad spectrum of current and future) Dave
MacKenzie
Pollution Prevention Introduction (It's not the treatment or transfer
of pollutants) Adriana Renescu
Pollution Prevention is Good for Business (Getting Back Customers,
Staying in Business, Increasing Business, Increasing
Profits) Joe and Dave will find a laundry person
POLLUTANTS OF CONCERN AND SOURCES
Present our findings
Solicit additional information
Theresa Dodge
OPPORTUNITIES TO WORK TOGETHER WITH CUSTOMERS ON POLLUTION
PREVENTION ACTIVITIES
Providing information to customers, publicizing assistance
programs, use as a facet of marketing efforts Joe and
Dave will find a laundry person
RESOURCES AVAILABLE TO SUPPORT POLLUTION PREVENTION EFFORTS
Donna Chen, Kathy Barwick, BEAC, Edison, Ecosa Representatives
LUNCH BREAK
THE IMPORTANCE OF ROUTE SALESPEOPLE
MARKETING TRAINING TO AND FOR ROUTE SALESPEOPLE
Both of these items should be covered by a laundry representative
The need for additional afternoon sessions will be established after Cam
completes his report on the laundry assessments
-------
SUMMARY
Focus Group Meeting
April 27, 1993
Los Angeles County Sanitation Districts
Welcome and Introductions
In attendance were Theresa Dodge of the Los Angeles Sanitation Districts,
Grade Tucker of the South Coast Air Quality Management District, Dave
MacKenzie of the Western Textile Services Association, Lee Terry of
Prudential, Tara Lusk of the City of Los Angeles Bureau of Sanitation, Bill
Warren of the City of Los Angeles HTM Office, Bob Kerr of Kerr and
Associates, and Tony Eulo of the Local Government Commission. Attachment
A is the agenda from the meeting.
Update on Workshop Planning Activities
Eulo summarized the planning activities to date. Facilities at the City of
Commerce and City of Anaheim have been obtained. Most of the speakers
have been solicited and have agreed to speak.
Finalizing the Workshop Agenda
Kerr distributed copies of Cam's preliminary report. The group did not have
time to fully review them before this discussion. The group wanted to wait
until they had reviewed the report to determine whether or not a session on
laundry operations would be useful.
It was decided that it would be more appropriate if Lee Terry gave the
discussion on regulatory mandates since he is already more familiar with
them than Dave MacKenzie and that Dave would be the perfect speaker for
the Pollution Prevention is Good for Business item.
Other speakers were mentioned for the Providing Information to Customers
item. MacKenzie will solicit them or forward their names to Eulo.
With regards to the afternoon session on strategies for involving route
salespeople and professional salespeople, it was decided to convene a
meeting on May 10 with trainers and sales managers from the laundries to
ask them for their ideas and guidance.
Attachment B is the updated workshop agenda.
Outreach Strategy Update
A draft flyer was reviewed and commented upon by the group. Staff will redo
the flyer and send photo-ready originals to MacKenzie and the
representatives from the three POTWs for mailing.
-------
Developing Resources to Facilitate the Exchange of Pollution Prevention
Information Between Laundries and Their Customers
Warren shared a listing that the HTM Office has developed that listed many
of the fact sheets that are available and instructions on how to obtain them
It was decided that the fact sheets of the three POTWs would be added to '
this list and that the list would be slightly reorganized. This finished product
would be the resource bibliography- ' F
Given differences among POTW fact sheets that are based on local concerns
IV^a£Ldeoid_ed that a PackaSe of fact sheets from the California Department'
of Toxic Substances control would be the resource package given to
participants.
Workshop Handouts
Staff distributed a list of handouts proposed to be distributed at the
workshops. The BMP summary prepared by Susan April was reviewed and
accepted as an exceUent handout. The amended list of handouts is
Attachment C to this summary.
Scheduling Future Focus Group Activities
The workshop planning focus group will meet again on May 10 to discuss
trie altemoon session. All other communications will occur via phone, mail,
and lax.
-------
Attachment A
Focus Group Meeting
April 27, 1993
Los Angeles County Sanitation Districts
8:00 - 8:10
8:10 - 8:25
Welcome and Introductions
Update on Workshop Planning Activities
• Logistical Arrangements
• Speaker Solicitation
• Other
8:25 - 9:00
9:00-9:15
Finalizing the Workshop Agenda
• Reevaluation of the Afternoon Session
• Identifying Additional Speakers
Outreach Strategy
• Review of Promotional Flyer
• Analysis of Overall Outreach Strategy
9:15-9:30
Update on Developing Resources To Facilitate
The Exchange of Pollution Prevention
Information Between Laundries and Their
Customers
9:30-9:45
9:45-9:50
9:50-9:55
9:55 - 10:00
Review of Workshop Handouts
Future Planning Tasks
Scheduling Future Focus Group Activities
Meeting Evaluation and Adjournment
-------
Attachment B
Draft Workshop Agenda
9:00 WELCOME AND INTRODUCTIONS
9:15 WHY ARE WE HERE?
Regulatory mandates (Broad spectrum of current and future) Lee Terry
Pollution Prevention Introduction (It's not the treatment or transfer of
pollutants) Adriana Renescu
Pollution Prevention is Good for Business (Getting Back Customers,
Staying in Business, Increasing Business, Increasing Profits) Dave
MacKenzie
10:00 POLLUTANTS OF CONCERN AND SOURCES
Present our findings
Solicit additional information
Theresa. Dodge
10:30
10:45
11:15
12:00
1:00
2:00
BREAK
CUSTOMERS °N
Providing information to customers, publicizing assistance programs, use as a
facet of marketing efforts/** and Dave will find a laundry person
RESOURCES AVAILABLE TO SUPPORT POLLUTION
PREVENTION EFFORTS
Donna Chen, Kathy Barwick, BEAC, Edison, Ecosa Representatives,
o C/AQMD
LUNCH BREAK (Lunch Provided)
THE IMPORTANCE OF ROUTE SALESPEOPLE AND
SALESPEOPLE and DESIGNING TRAINING FOR
3:00
Both of these items should be covered by a laundry representative
™™^?£N PREVENTION OPPORTUNITIES IN LAUNDRY
\Ji JERATIONS
Cam Metcalf
ADJOURNMENT
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Attachment C
Draft: list of Workshop Handouts
Meeting Agenda
Participants List
Evaluation Form
Government Resource List
Resource Document Listing
Sample Resource Packet
BMP Brief
Pollutants of Concern
Summary of Key Points
The Hazardous Waste Issue:
A Summary of Key Points
IIL Manual
Assessment Summary
The agenda for the workshop.
A listing of all workshop attendees.
A form to assess the quality of the
workshop and the participant's interest
in future pollution prevention activities.
A 1-2 page listing describing what local,
state and federal government agencies
do and who are the key contacts for each
program. Addresses and phone numbers
will be provided.
A brief bibliography identifying 3-10 key
written resources for each type of
business. It will be organized by business
type.
A package of DTSC Fact Sheefs that are
available for immediate handout by
laundry staff.
A brief summary of BMP's developed by
other states.
A summary of the pollutants that are
causing problems for POTWs and the
industries that are most likely to be
generating them.
Summaries provided by the speakers
that outline the key points in their
presentation.
A paper describing the major points
related to hazardous waste hauling and
treatment issues affecting industrial
laundries.
The manual prepared by the IIL for their
members.
The summary of the site assessments
performed by Cam Metcalf
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SUMMARY
Focus Group Meeting
May 10, 1993
Los Angeles County Sanitation Districts
Welcome and Introductions
In attendance were Theresa Dodge of the Los Angeles Sanitation Districts
Adriana Renescu of the Orange County Sanitation Districts, Tara Lusk of the
City of Los Angeles Bureau of Sanitation, Butch Wuth of Reliable Textile Joe
Zapalac and Tom Robison of Welch's Uniform Rental, Bob Rohrbough of
Mission Industries, Rick Dumas of L & N Uniform, and Tony Eulo of the
Local Government Commission.
Description of the Project
• - . s
Eulo gave a brief overview of the project for the new attendees. He explained
that the explicit purpose of this meeting was to gain the insights of those
employed by laundries to motivate salespeople. The purpose of the project
and planned activities were included in this summary. P™ject
Rather than just focussing on the Route Salespeople, it was brought up that
the project should address the Professional Salespeople as well because thev
typicaUy have more time to spend with the customers. y
Description of Strategies
The group brainstormed about the different strategies laundries have
employed to motivate salespeople. These included:
Providing Information at Meetings: The route salespeople usually have
w?5kly meetings and the Professional salespeople meet nearly daily
with their supervisors. These meetings are opportunities to provide
information on pollution prevention.
Videos: Some laundries have produced videos on pertinent topics e g
safety, OSHA, etc.. A pollution prevention video could be developed as
well. Welch s developed an excellent video for approximately $400 due
to the fact that they have an employee with professional video
equipment. Having a test after the video promotes a more attentive
audience.
Train by Example: On-the-job training is commonly used to show new
employees how to do their job. Hands-on pollution prevention
assistance training could be provided.
-------
Incentive Programs: Many laundries have incentive programs for safety.
Cash prizes are commonly used as the incentive. While it is easy to see
how incentives can be used for safety, they may be difficult to use for
pollution prevention.
One incentive would be to incorporate providing pollution prevention
assistance into the employee's evaluation. This could be done via
random field checks of customers or through customer service
surveys done through the mail.
War Stories/Positive Case Studies: Examples of how a particular employee
has helped a customer could be shared with other employees as a
means of encouraging them. The employee with the success story
could receive some type of reward as well.
Reinforcing The Message: It was brought up that the pollution prevention
message must be reinforced over time. Having cards in the trucks that
change periodically would be one way to do this. The message on the
cards could rotate between pollution prevention, safety, and sales
motivation. The card could be changed on a set schedule.
It was decided that all of these ideas have merit and should be presented at
the workshops.
Additional Points
Other points made were
1) Route salespeople could refer customers with complex pollution
prevention issues to facility engineers of professional salespeople who have
more time; and
2) Materials handed to customers should be available in several languages.
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KERR & ASSOCIATES, INC.
2634 Wild Cherry Place • Reston, Virginia 22091 • (703)476-0710
April 15, 1993
To: Jim Lund, Office of Water (WH-551)
From: Bob Kerr, Kerr & Associates, Inc.
Subject: Principal Sources of Waste Management Problems for Industrial Laundries
Region 9 Pilot Project (IPS)
Ref.: EPA Contract #68-WO-0025, Work Assignment #230
Task 1.3
Attached is a cross-walk of principal waste management problems encountered by laundries and the
probable major sources of those problems. These would potentially be the primary focus for the kind
of BMP pollution prevention approach supported by both the original workgroup and the focus group
meetings.
-------
MEMO
To: Eileen Sheehan
From: Susan April
F 4/14/93
^^-r^i^SK=ft^^t^^ss-a
SIC
75
55
27
35
34
Name of Industrial Sector
Auto Repair, Services, Parking
Auto Dealers & Service Stations
Printing & Publishing (includes
graphic arts)
Industrial Machinery & Equipment
(machine shops)
Fabricated Metal Products (metal
finishers)
25 Furniture & Fixtures
37 Transportation Equipment
(aerospace)
80 Health Services (hospitals.etc.)
07 Agricultural Services
01 Agricultural Production (crops)
29 Petroleum & Coal Products
(refineries)
73 Business Services (photo processors)
73 Business Services (pest control)
Problem/Pollutants
shop towels/rags with
chlorinated solvents;
heavy metals (nickel, zinc);
other VOCs (MEK, benzene,
xylenes)
same as above
inkers/wipes with chlorinated
solvents; heavy metals (silver,
cadmium, copper, lead);
other VOCs (MEK, benzene,
xylenes)
bis-2-ethylhexyl-phthalate;
some chlorinated solvents
heavy metals (copper,
silver, chromium); some
chlorinated solvents
(TCA/TCE)
bis-2-ethylhexyl-phthalate;
methylene chloride
TCA/TCE
chloroform
lindane, other pesticides
same as above
benzene
silver
zinc, lindane
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KERR & ASSOCIATES, INC.
2634 Wild Cherry Place • Reston, Virginia 22091 • -(703) 476-0710
January 29, 1993
To: Jim Lund, Office of Water (WH-551)
^ : * '
From: Bob Kerr, Kerr & Associates, Inc.
Subject: Process Diagrams for Industrial Laundry Operations/Waste Management Practices
Region 9 Pilot Project (IPS)
Ref.: EPA Contract #68-WO-0025, Work Assignment #230
Task 1.2
Attached are process diagrams on industrial laundry operations and waste management practices which
.have been prepared for the workgroup meeting of state and local agency, Region 9, POTW and
"industrial laundry representatives on February 8th at the offices of the Orange County Sanitation
Districts. These will be used during a discussion of current practices and available source reduction
alternatives.
-------
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Dry Cleaning Processes
Water &
Detergent
Conductivity
Meter
Solvent Storage
Rotating
Cylinder
Distillation
t
Solvent /Water
Seperator
Dirty
Solvent
Filter
Still Bottoms
Lint
Grit
Organic
&
Inorganic
Solvents
Water
Soluble
Materials
Solvent
-------
Dust Mops
Dirty Dust Mops
Heat
Treatment Oil
Washer/Extractor
No Water
Discharge
Dirty Oil
Filtration
? Filters, lint,
sand, grit
-------
Dual-Phase or Dual -Stage Processing is Being
Phased Out as a Laundry Process
Water
Detergent
Phase I: Water wash
Water Soluble Soils Y_>
Oil & Grease f
Order of Processing
Determined by:
1. Solvent Used
2. Type of Soil
3. Drying Energy
Requirements
Phase 2:
Solvent Wash
Dry Cleaning
Solvent in
Wastewater
Dirty Solvent
Cycle
-------
Typical Treatment Systems
Water
Uniforms
Settling Basin
Shaker
Screen
Settling Basin
Shop Towels
Disc Strainer
Equalization
Basin:
Oil Skimmer
Concentrate
Tank
Ultra
Filter
T
/Wastewater to\ * ?oli
HW Sludge:
•FP 52°C
»Exceeded proposed]
perc limit
Tramp Oil:
•FP<60°C
•Incinerated
HW:
•FP<60°C
• TCLP/Pb
• Cd approaching
TCLP level
• Cyanide at 600 ug/l
• Semivolatile
Organics
Solids are disposed of as HW.
• Tramp oil is incinerated.
-------
Typical Treatment Systems
Laundries A&B:
Screen
Equalization
Basin
DAF
Water
Laundry C:
w
Settling
Basins
Sediments:
FP=60°C
Exceeded Proposed
TCLP level for PERC
Wastewater
to Sewer
Wastewater
to Sewer
/"
/ Thickened
f Sludge:
I FP57°C&
V 60°C
^^k
Solids are not disposed of as hazardous waste
-------
Load Into Water Washing Machine-3 Types
Conventional
High Water
Tunnel
Modular
Washing Machine Cycles
• Temp Control • Timing Devices
• Water Level Control • Rotation Reverse Device
LJOW Water
Alkali Solution
Detergent
Low Water
Detergent
High Water
Low Water
Bleach Solution
High Water
Flush: Rinsing Before Bleaching
Break: 1st Supply Operation
Sudsing til Clean
Flush
Bleach Cycle
Rinsing Cycles: # Varies
Loose solids
Water soluble soils
Soils, lint
laundry chems
(soaps/detergents)
High pH
priority pollutants
Other hazardous
pollutants
Chlorinated
hydrocarbons
Reduce alkali
Detergent content
Low Water
Souring or Acidiiying
Mildistat
Softener
Blueing/Brightening Cycle
Finish
Zinc compounds
Phenolic
compounds
-------
Typical Treatment Systems
Lint Screens
Disc Strainer
Settling Basins
Waste Solids:
• Lint
• Soiids
Sediments
Oil Skimmers
Dissolved Air Flotation
Ultrafiltration
Wastewater
Final
Concentrate
-------
Water Washing Machine Cycles
Plant & Equipment
Cleaning
Extractor:
• Centrifuge
Hydraulic Press
Sanitary
10%
Water
Excess
Water
70-85%
Live
Steam @ |
40 psi '
Drying/
Airfinishing
Finishing: Drying, Pressing and Folding
(Hot Air Tumblers for Towels and Mats)
10%
Water
Evaporated
Destaining
Minor Repairs
Storage/Shipping to Customer
-------
Pollutant Sources
Soiled
Materials
80% Others
Treat Water
Separately
20% Shop Towels
• Soils>50% of dry weight
• Considerable Quantities
of Organic Solvents
POLLUTANTS:
• Volatile Organics
-Toluene, methylene chloride, TCA
& Ethylbenzenie
• Semivolatile Organics
-Naphthalene, Isophorone
• Toxic Metals & Elements
-Lead & Chromium
• Nonconventional Volatile Pollutants
-Acetone & MEK
• Nonconventional nonvolatile long-chain alkane
compounds
• Conventional Pollutants
-BOD5, TSS., pH & oil and grease
-------
Pollutant Sources
( Water W
Soiled Textiles
20% Shop Towels +
80% Others
Cleaning Processes
Used
Laundering Process
Chemicals
Typical
Pretreatment
Systems
-------
Receiving: Soiled Materials Sorted
Soil Type
Fabric Type
Ownership
Garment Type
Color
Destaining
I.D. Prespotting &
Destaining Needed
Acids
Bleaches
Organic Solvents
Soaking
Cold Water
Process Depends On:
• Soil Classification
• Item Type
•Composition of Fabrics
oils
Loose Solids
Lint
aundry Chems.
Solvent
Water Wash
Laundering
82%
Dry Cleaning
13%
Dual-Phase
Processing
5%
-------
Effluents, Sludges, and Solids
70-85% Wastewater
+
10% Plant & Equipment
Cleaning and Sanitary
Typical Pretreatment Systems
•Lint screens
• Disc Strainer
• Setting Basins with Short Detention
Time
• Oil skimmers
• Dissolved Air Flotation System
• Ultrafiltration
Wastewater
Characteristics
Waste Solids
Characteristics
-------
Reusable Textiles Cycle
Customer Use:
Soiled Textiles
Collection System
Clean Shipped
to Customer
Storage
\
Finishing: Drying,
Pressing& Folding
Soiled Transported
to Laundry
Receiving/Sorting
Water Washing
Cycles
Dry Cleaning
Extractor
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BEST MANAGEMENT PRACTICES (BMP) FOR SHOP TOWELS
-------
-------
KERR & ASSOCIATES, INC.
2634 Wild Cherry Place • Reston, Virginia 22091 • (703) 476-0710
i May 4, 1993
To: Jim Lund, Office of Water (WH-551)
From: Bob Kerr, Kerr & Associates, Inc.
Subject: Alternative Approaches to Waste Reduction for Industrial Laundries
Region 9 Pilot Project (IPS)
Ref.: EPA Contract #68-WO-0025, Work Assignment #230
Task 1.3
Attached are three pieces prepared in response to requests from participants in the workgroup meetings.
..These statements summarize both an alternative approach for industrial laundries to meeting
environmental management objectives, and the rationale for the approach. They are prepared as
succinct statements which could be used in training programs and workshops (such as the one to be held
in June). The first summarizes BMPs for both the industrial laundries and their customers in handling
shop towels (generally the worst source of pollution). These are succinct derivations of BMPs
developed by the Institute of Industrial Laundries (IIL) and the states of Washington and Minnesota.
To make these work, buy-in is needed by all parties (regulated and regulator). The other two pieces
briefly state why BMPs are important, and how they are beneficial for the laundries.
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Best Management Practices (BMPs) for Shop Towels 1
BMPs for the Cust
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."
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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."
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WHY ARE BEST MANAGEMENT PRACTICES (BMPs) IMPORTANT?
They are important because:
Everyone needs to work together to foster the use of
reusable textiles which—unlike disposables—contribute
very lutle to the solid waste stream, and when handled
properly, are the most environmentally beneficial.
The status of soiled reusables such as shop towels and
wipes which might contain RCRA hazardous waste solvents
is an issue yet to be resolved. Clearly, the need to
regulate shop towels as hazardous waste diminishes if
environmental agencies are made aware that laundries
are using BMPs to minimize health and environmental
threats.
Sharing knowledge and information on BMPs with your
laundry customers is one positive way to promote
cooperation and concern for the environment.
Liability concerns may be lessened if you follow BMPs
because you would not allow potentially dangerous free
liquids to be transported in your vehicles.
Cost savings can be realized by customers when managing
shop towels according to the "no free liquid" BMPs.
More solvent product would be recovered at the customer
site which could then be re-used or recycled.
When customers share their Material Safety Data Sheets
(MSDSs) with laundries, both benefit because the
laundry can more appropriately handle the textiles
knowing what contaminants may be on them, and the
customer can be assured he has followed the spirit of
"right to know," so that people who handle their soiled
textiles are informed of any toxics or potential
hazards.
Following the BMPs, and encouraging your customers to
follow the BMPs, may decrease your laundry's Total
Toxic Organics (TTOs); this is a simple, cost-
effective, non-technological way to help you meet your
Sanitation District's TTO limits.
_
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HOW HAVE OTHER STATES USED BMPs TO PROVIDE REGULATORY RELIEF TO
LAUNDERERS?
In Minnesota:
Since 1989, Minnesota Pollution Control Agency (MPCA)
policy is that if generators of reusable textiles
containing hazardous waste solvents wring them out,
either by hand or with a mechanical wringer, to remove
maximum amount of liquid, the wrung-out reusables may
be transported without manifesting.
— If that generator elects not to wring out towels, they
must be managed as a RCRA hazardous waste and cannot be
laundered.
If a launderer elects to install and operate a
centrifuge or some other method of extracting liquids
prior to laundering, no hazardous waste facility permit
is needed.
In Washington:
Since 1992, Washington Department of Ecology provides
that used shop towels contaminated with hazardous
substances which may designate as "dangerous" under-
state law, may nevertheless be exempted from compliance
with dangerous waste requirements—if both generator
and launderer follow specific BMPs.1
If soiled textiles are handled according to BMPs,
facilities are not subject to generator, transporter,
or permitted TSDF requirements, and the textiles are
not "counted" as hazardous or dangerous waste.
If generators use disposable cloth rags or paper wipes
that are considered "dangerous" waste, they must be
managed as hazardous waste and are subject to all RCRA
manifest and permitting requirements.
1 Summarized in the handouts: 'BMPs for Customers" and "BMPs for Laundries" in this workshop packet.
-------
-------
Strategy for the Dissemination of BMPs to Customers
-------
-------
Opportunities for Pollution Prevention
Facing regulatory constraints, some laundries have discontinued servicing some
customers because their uniforms and towels are "too dirty" for the laundry to
handle. The customer may use another local laundry service, begin using disposable
rags, use a laundry from Mexico, or wash their own uniforms and towels at a local
coin operated laundry. Along with the obvious reductions in laundry revenues
associated with these decisions., many of these options have a questionable impact on
the environment.
It is possible for laundries to work cooperatively with the customers on pollutant
prevention programs. By assisting their customers in reducing the amount and the
toxicity of pollutants the customer puts oh the rented products, it is possible for the
laundries to keep the customer's business, help the customers themselves in dealing
with worker safety and environmental issues, and reduce the level of pollutants found
in the laundry's discharges. To assist the laundries in this process, there are many
resources that have already been developed.
Specific opportunities that the laundries have include the following:
1. Have route salespeople distribute technical resources as a service to the
customers;
2. Provide referrals to customers about the different pollution prevention
assistance and regulatory compliance programs available;
3. Have professional salespeople (full-time salespeople) distribute technical
resources and provide specific technical information to the customers as part
of the process associated with setting up an account;
4. Coordinate with the local environmental enforcement agencies to ensure that
the laundries and the agencies are providing the same message to the
customers;
5. When a customer is contributing pollutants to a, laundry's system that are
causing operational or environmental problems, work cooperatively with the
customer on pollution prevention measures that can eliminate the problems.
-------
Strategies For Training Industrial Laundry Field
Representatives
Providing Information at Meetings: The route salespeople usually have
weekly meetings and the professional salespeople meet nearly daily
with their supervisors. These meetings are opportunities to provide
information on pollution prevention.
Videos: Some laundries have produced videos on pertinent topics, e.g.,
safety, OSHA, etc.. A pollution prevention video could be developed as
well. One laundry developed an excellent, video for approximately
$400 due to the fact that they have an employee with professional
video equipment. Having a test after the video promotes a more
attentive audience.
Train by Example: On-the-job training is commonly used to show new
employees how to do their job. Hands-on pollution prevention
assistance training could be provided.
Incentive Programs;. Many laundries have incentive programs for safety.
Cash prizes are" commonly used as the incentive. While it is easy to see
how incentives can be used for safety, they may be difficult to use for
pollution prevention.
One incentive would be to incorporate providing pollution prevention
assistance into the employee's evaluation. This could be done via
random field checks of customers or through customer service
surveys done through the mail.
War Stories/Positive Case Studies: Examples of how a particular employee
has helped a customer could be shared with other employees as a
means of encouraging them. The employee with the success story
could receive some type of reward as well.
Reinforcing The Message: It was brought up that the pollution prevention
message must be reinforced over time. Having cards in the trucks that
change periodically would be one way to do this. The message on the
cards could rotate between pollution prevention, safety, and sales
motivation. The card could be changed on a set schedule.
-------
KERR & ASSOCIATES, INC.
2634 Wild Cherry Place • Reston, Virginia 22091 • (703)476-0710
June 21, 1993
To: Jim Lund, Office of Water (WH-551)
From: Bob Kerr, Kerr & Associates, Inc.
Subject: Summary of Industrial Laundry Workshop
Region 9 Pilot Project (IPS)
Ref.: EPA Contract 068-WO-0025, Work Assignment #230
Task 2.3
Attached is the summary of the workshop for industrial laundries held in Anaheim on June 14, 1993.
-------
-------
SURVIVAL IN THE 90'S
POLLUTION PREVENTION STRATEGIES
FOR INDUSTRIAL LAUNDRIES
June 14,1993
WORKSHOP SUMMARY
INTRODUCTIONS
Eileen Sheehan, Pollution Prevention Coordinator for the Water Program, Region
9, EPA:
This workshop represents a new effort by EPA to find ways to work
cooperatively with industry and local agencies to solve environmental problems.
Economic and environmental issues have become increasingly intertwined. EPA
believes joint efforts such as this one will achieve better environmental results than
confrontation, as well as leading to more efficient economic alternatives. EPA looks
forward to continuing to work with industrial laundries over the coming months.
Anthony Eulo, Policy Director, Local Government Commission:
The principal purpose of the workshop is to provide ideas on how industrial
laundries can work with their customers to promote pollution prevention - to reduce
some of the environmental problems which result from excessive contaminants on
shop towels and other materials to be laundered. While regulatory issues provide
a necessary background to the workshop, particular regulatory problems cannot be
resolved at the workshop, and should not become the focus of discussion.
WHY ARE WE HERE?
Bob Kerr, Kerr & Associates:
Regulations are becoming increasingly stringent - both at the state and federal
level Laundries will need to work actively with then- customers to reduce the
volume and toxicity of wastes being sent to them if they are to avoid ever increasing
treatment and control costs. Reducing pollutants at the source is economically
preferable for all those involved - especially the laundries. (Overheads from the
presentation, which reviews current and potential future regulatory requirements,
is included as an attachment).
-------
Adnana Renescu, Special Projects Engineer, County Sanitation Districts of Orange
Pollution prevention is a new way of tackling environmental problems It
considers releases to air, water and ground all at once, focusing on the LurcTrf the
releases and how to avoid them, instead of looking at each waL stream Slat on
and focusing only on how to treat or dispose of it. Because it includes consideration
str±ff T6 °Perati°n' rather than ignorin* ^thing except the waste
streams, it provides an opportunity to achieve both economic and environmental
gams, rather than sacrificing either one of the other. (Overhead's which expTain
more about pollution prevention and how to achieve it are mdudedTan
attacnment/ .
Dave McKenrie, Executive Director, Textile Rental Services Association:
™,,io P0lluti.on Preve«tion approach, and cooperative efforts like this with the
regulatory agencies, are good for the industrial laundries. In negotiating with the
Teamsters on behalf of industrial laundries, Mr. McKenzie noted That he w^te two
results: (1) get as much flexibility in the contract as possible, and (2) getThe ^on
on the same side of the bargaining table, so that the union leadership wnl adVocT
the proposed settlement. Both of these objectives are good models for dealing with
environmental problems. This process with EPA and the local agencies, and™
workshop, are steps in the right direction. -s«""i», ana mis
POLLUTANTS OF CONCERN AND SOURCES
usk, Associate Environmental Engineer, Bureau of Sanitation, City of Los
PnTWP(?JW ^gulations of «dustrial laundries are based on requirements that the
POTWs themselves must meet. Like industrial laundries, POTWs do not generate
po ufemts; their job is to treat or dispose of pollutants generated by *
Pollutants coming into a POTW can cause problems for three bask reasons:
o they may exceed the treatment capabilities of the POTW, and cause the water
discharged from the POTW to violate the standards that the POTW W,st
o
they may persist in the sludge generated by the POTW, and make it difficult
or impossible to dispose of or utilize the sludge cost-effectively; or
-------
o they may upset the operations of the POTW.
For the City of Los Angeles, the primary concern with respect to the kinds of
pollutants which could come from laundries is with the latter two problems. Oil and
grease is a major issue, since it can cause upsets at the treatment plant. Metals such
as molybdenum, selenium and lead cause problems with the sludge.
OPPORTUNITIES TO WORK TOGETHER WITH CUSTOMERS ON
POLLUTION PREVENTION ACTIVITIES
Joe Zapalac, Regional Engineer, Welch's Uniform Rental:
The pollution prevention approach is good business for industrial laundries.
As an example, one of Welch's largest customers (a printer) was causing serious
compliance problems for the laundry. Welch's was left with 3 options:
o stop servicing the customer;
0 invest, at great expense, in more treatment at the laundry; or
o work with the customer to develop other process alternatives.
Obviously the first two alternatives were not desirable, so Welch's went to the
third. The printer changed to a soybean ink which could be cleaned off the presses
with water and soap. The laundry didn't provide the only incentive for the printer
to change its process, but it was important as one of a set of motivations.
It is important for laundries to establish open communications with their
customers. It's not that hard to identify the sources of pollution problems at the
laundries. For example, you should ask for the MSDSs of whatever is being used
on the printing line. You should ask for tours of your customers' facilities. The
customers are under pressure already from the regulatory agencies (POTWs,
AQMD, etc.). You're less threatening to them, but you may succeed in reinforcing
the message. .
The laundries are currently looking at the possibility of writing the BMP
approach into law in California. The BMP program is actually included in a
California Senate bill.
-------
The bottom line? The more you work with your customers, the happier your
customers will be. That's good business.
RESOURCES AVAILABLE TO SUPPORT POLLUTION PREVENTION EFFORTS
Donna Chen, Director, HTM Office, Cily of Los Angeles
Kathy Barwick, Pollution Prevention Specialist, California Department of Toxic
Substances
Diane Garcia, California Business Environmental Center
Noel Eurai, Executive Director, Environmental Compliance Support Association of
California
Moustafa Elsherif, Program Manager, Small Business Assistance, South Coast Air
Quality Management District
Each of the organizations in this panel provides some form of support to
businesses. Copies of brochures providing information on their services and roles
are attached. The offices represented by Donna Chen and Kathy Barwick provide
technical support and information to businesses, and are non-regulatory (although
DTSC itself is a regulatory agency). Both offices provide technical documents, and
HTM also provides on-site technical assistance.
The Small Business Assistance organization in SCAQMD provides loans for
companies to invest in equipment to reduce emissions, so long as the company meets
the criteria for a small business (under 500 people, under $3 million gross) The
maximum loan is for $250,000, and the maximum period is for seven years (whereas
most commercial loans are limited to three years). This group is non-regulatory, and
provides on-site technical assistance. It will not report non-compliance to the
regulatory people at SCAQMD so long as compliance is achieved within a specified
period. r
The California Business Environmental Center and the Environmental
Compliance Support Association of California are non-profit organizations which
provide free services to businesses. The Environmental Compliance Support
Association of California, staffed by people with business backgrounds, is business-
oriented, and serves as a buffer between the private sector and government It
provides a Ma! from government; there is no reporting of compliance problems It
-------
is supported by major industries which are concerned with the erosion of their
customer and supplier base. There is a membership fee of $100-400/year, depending
on the size of the company.
Mr. Kurai noted that he had previously worked in the petroleum, mining and
chemical products industries. He commented that when he worked in those
industries, people frequently stuffed contaminated towels in with the clothes for
industrial laundries and never thought about it. To the best of his knowledge, the
companies were never approached by an industrial laundry to indicate that this was
creating a problem.
THE IMPORTANCE OF ROUTE SALESPEOPLE AND PROFESSIONAL
SALESPEOPLE AND DESIGNING TRAINING FOR SALESPEOPLE
Rick Dumas, District Manager, L&N Uniform Supply Company
Route salespeople tend to deal more with smaller customers, while the
dedicated sales staff deal with larger customers. It is important to emphasize to
route salespeople that they need to make it clear that they are providing a service to
the customers. Most route salespeople are trained by example, by riding with
current drivers. One way of getting a handle on what a route salesperson is doing
is through complaints and/or questions about new programs from the customers.
Sales meetings are good times to get to the sales force with environmental
training. Videos are a particularly good mechanism. (Welch's has used them for
salespeople on how to help customers). It is important that the salesperson be well
enough informed to be able to make any point clearly, thoroughly and quickly. It
is important to keep changing the message, so the salesperson doesn't begin to ignore
it.
All businesses are becoming sensitive to environmental problems. Providing
environmental support and information is an added way of keeping your customer,
protecting yourself against competitors. If the laundry helps the customer clean up
an environmental problem, both can use this in their PR with clients and the
community. Several agencies and POTWs will support or encourage PR about
positive environmental or pollution prevention measures.
-------
Incentives are an important part of an effective program. For example, if the
reward for some kind of environmental achievement with a customer is a dinner for
two, the family may encourage get behind promoting the activity. It is important
to emphasize rewards which can be widely distributed (not just to a couple of people
on the staff); perhaps use a team approach.
POLLUTION PREVENTION OPPORTUNITIES IN LAUNDRY OPERATIONS
Cam Metcalf, Training Manager, University of Tennessee's Center for Industrial
Services
Pollution prevention assessments of individual laundries indicated that there
are a number of ways in which laundries could both avoid environmental problems
and save costs. These findings are summarized both in, the overheads from this
presentation, and the overview report on the assessments, both of which are
attached.
-------
PARTICIPANT
SURVEY
SURVIVAL IN THE 90\s
POLLUTION PREVENTION STRATEGIES
FOR INDUSTRIAL LAUNDRIES
Dear Workshop Participant:
In order for us to more effectively assist you in the future, it is imperative that we receive
your input. Your opinion is of great value and will affect future workshops and assistance
efforts. Therefore, we would greatly appreciate it if you would fill out this survey and
return it to the workshop coordinators. Thank you for your participation.
1. How would you rate the overall quality of the workshops?
Q excellent Q good Q fair Q poor
2. How did you find the presentations?
Q very useful/informative
Q useful/informative
Q moderate
Q unuseful/uninformative
Q very unuseful/uninformative
3. The workshop helped me to understand these topics: (check all that apply)
Q current issues facing industrial laundries
Q incorporating environmented issues into your marketing approach
Q preparing for future regulatory mandates
Q providing trainingto field representatives
Q resources available to support pollution prevention efforts
4. What did you like most about the workshop?
5. What did you like least about the workshop?
-------
6. What suggestions do you have for improving future workshops?
7. What specific skills and/or knowledge did you gain from the workshop?
8. What specific programs, incorporating pollution prevention into your operations
are you now considering as a result of the workshop?
9. Would you attend a similar pollution prevention workshop in the future, if it cov-
ered new material?
Q yes Q no
10. What issues would you like to see addressed in the future?
11. Please discuss the current needs of your business and industry as related to pollu-
tion prevention. v
-------
AGENDA
9:00 WELCOME AND INTRODUCTIONS
Eileen Sheehan, Pollution Prevention Coordinator, Water Program, U.S.
Environmental Protection Agency
Anthony Eulo, Policy Director, Local Government Commission
9:15 WHY ARE WE HERE?
Regulatory Mandates: Current Realities and Future Trends
Bob Ken, President, Ken and Associates
Pollution Prevention: An Introduction For Industrial Laundries
Adriana Renescu, Special Projects Engineer, County Sanitation Districts of
Orange County
Pollution Prevention Is Good For Business
Dave MacKenzic, Executive Director, Textile Rental Services Association
10:00 POLLUTANTS OF CONCERN AND SOURCES
Which Customers Are Contributing To The Problem?
Tara Lusk, Associate Environmental Engineer,
Bureau of Sanitation, City of Los Angeles
10:30 BREAK
10:45 OPPORTUNITIES TO WORK TOGETHER WITH CUSTOMERS ON
POLLUTION PREVENTION ACTIVITIES
Pollution Prevention Is Good For Business:Opportunities For Industrial Laundries
Joe Zapalac, Regional Engineer, Welch s Uniform Rental
11:15 RESOURCES AVAILABLE TO SUPPORT POLLUTION PREVENTION
EFFORTS
Donna Chen, Director, HTM Office, City of Los Angeles
Kathy Banvick, Pollution Prevention Specialist, California Department of Toxic
Substances Control
Diane Garcia, California Business Environmental Assistance Center
Noel Kurai, Executive Director, Environmental Compliance Support
Association of California
Moustafa Elsherif, Program Manager, South Coast Air Quality Management District
12:00 LUNCH BREAK (Lunch Provided)
1:00 THE IMPORTANCE OF ROUTE SALESPEOPLE AND PROFESSIONAL
SALESPEOPLE AND DESIGNING TRAINING FOR SALESPEOPLE
Rick Dumas, District Manager, L & N Uniform Supply Co.
2:00 POLLUTION PREVENTION OPPORTUNITIES IN LAUNDRY
OPERATIONS
Cam Metcdlf Training Manager, University of Tennessee's Center For
Industrial Services
3:00
ADJOURNMENT
-------
Participant List • Pollution Prevention Strategies For Industrial Laundries
Fred Antman
Kleen Kraft Services
5801 Sheila Street
Commerce, CA 90091-1209
Robert Brothers
Sacramento County Water Quality Industrial Waste
9660 Ecology Lane
Sacramento, CA 95827
Mih Burns
Kleen Kraft Services
5801 Sheila Street
Commerce, CA 90091-1209
Moustafa Elsherif
South Coast Air Quality Management District
21865 Copley Dr.
Diamond Bar, CA 91765
Kirk Freeman
Sacramento County Water Quality Industrial Waste
9660 Ecology Lane
Sacramento, CA 95827
Bob Kerr
Kerr & Associates, Inc.
2634 Wild Cherry Place
Reston, VA 22091
E. Aaron Lazaroff
Stciner Company
17530 Palora
Encino, CA 91316
TaraLusk
Bureau of Sanitation, City of Los Angeles
4600. Colorado Blvd.
Los Angeles, CA 90039
Mike Markowski
Cintas Corporation
7735 So. Paramount
Pico Rivera, CA 90660
Cam Metcalf
Univ. of Tennessee's Center for Industrial Services
226 Capital Blvd. Building, Ste. 401
Nashville, TN 37219-1804
Kathy Barwick
California Department of Toxic Substances Control
PO Box 806
Sacramento, CA 95812-0806
Tim Buckner
The Dober Group
14461 S. Waverly
Midlothian, IL 60445
Donna Chen
HTM Office, City of Los Angeles
200 N. Spring St., Rm 356
Los Angele, CA 90012
Anthony Eulo
Local Government Commission
909 12th Street, Ste 205
Sacramento, CA 95814
Diane Garcia
California Business Environmental Assistance Center
100 S. Anaheim Blvd., Ste. 125
Anaheim, CA 92805
Noel Kurai
Environmental Compliance Support Assoc. of Calif
PO Box 5968
El Monte, CA 91734
Paul Litwin
American Textile Maintenance
1667 W. Washington Blvd
Los Angeles, CA 90007
Gwen Marclli
Southern California Gas Co.
9240 E. Firestone Blvd.
Downey, CA 90241
Thomas Marks
Western State Design, Inc.
28181 So. Wilmington Ave, Ste 414
Long Beach, CA 90810
Andrew Murray
Local Government Commission
909 12th Street, Ste 205
Sacramento, CA 95814
-------
Participant List • Pollution Prevention Strategies For Industrial Laundries
Manuel Nieto
Aratex Services
4422 E. Dunham Street
Los Angeles, CA 90023
Terry Philly
Reliable Textile Rental Services
3200 N. Figucroa
Los Angeles, CA 90065
Adriana Renescu
Orange County Sanitation District
10844 Ellis Ave.
Fountain Valley, CA 92708
Barry Sandier
Sandier Bros. Inc.
3621 Medford Street
Los Angeles, CA 90063
Eileen Sheehan
Water Program, US EPA Region IX
75 Hawthorne Street W-22
San Francisco, CA 94105
Pedro Soto
Express Wash Inc.
3214 E. Mines Ave
Los Angeles, CA 90023
Craig Winegar
Unitog Company
2829 Workman Mill Road
Whitter, CA 90601
Joe Zapalac
Welch's Uniform Rental
5950 Alcoa Ave.
Vernon, CA 90058
Jorge Patino-Patroni
Pacific Coast Laundry
3436 E. Olympic Blvd.
Los Angeles, CA 90023
Alan Pygn
Aratex
115 N. First Street
Burbank,CA 91503
Tony Richmond
Reliable Textile Rental Services
3200 N. Figueroa
Los Angeles, CA 90065
John Shaffer
Environmental Resolutions, Inc.
9272 Jeronimo Road #106
Irvine, CA 92718
Amy Songer
American Textile Maintenance
8695 W. Washington
Culver City, CA 90232
John Tucker
J.T.S., Inc.
11760 Sonrento Valley Road, Stc H
San Diego, CA 92130
Allen Yi
East West Apparel Inc.
14919 S. Figueroa Street
Los Angeles, CA 90248
-------
-------
POLLUTION PREVENTION
A NEW WAY OF THINKING
OR
"IT'S NOT THE OLD SHELL GAME"
-------
TRADITION
END-OF-PIPE POLLUTION CONTROL
TREATMENT TAKES POLLUTANTS
FROM
ONE MEDIUM (WATER, AIR, SOLIDS)
AND
PUTS IT IN ANOTHER MEDIUM
(WATER => SOLIDS, WATER «* AIR, ETC)
-------
DEFINITION
OF
POLLUTION PREVENTION
EPA Statement of Definition, May 28, 1992
REDUCE THE AMOUNT OF POLLUTANTS AND
TOXICITY OF POLLUTANTS ENTERING A
WASTESTREAM PRIOR TO RECYCLING,
TREATMENT AND DISPOSAL.
INCREASE EFFICIENCY IN THE USE OF RAW
MATERIALS, ENERGY, WATER AND OTHER
RESOURCES
CONSERVE NATURAL RESOURCES
-------
DEFINITION
OF
POLLUTION PREVENTION
IN PLAIN ENGLISH
REDUCE OR ELIMINATE (PREVENT) POLLUTION
BEFORE IT IS GENERATED
• PRODUCT MODIFICATION
=*Lower the toxicity of product
=>Make product recyclable
^Increase product life
• PROCESS AND TECHNOLOGY
MODIFICATION
=>Install equipment that produces little or no
waste
^Modify piping and plant layout
^Change operating conditions
^Redesign equipment and production lines
^Modify equipment to facilitate recycling
^Segregate waste
-------
• CONTROL THE SOURCE OF POLLUTANTS
• RAW MATERIAL USE
^Substitute toxic raw materials with less
toxic or non-toxic materials
^Control and reduce raw material
contamination
• RAW MATERIAL HANDLING
^Improve raw material receiving, storage and
handling
^Inventory and trace raw material use
• RAW MATERIAL REDUCTION
=>Optimize use
*
^Recycle and reuse
*BEWARE: IT COULD BE THE OLD SHELL GAME
AGAIN!
-------
LEGISLATIVE AND REGULATORY
ORIGINS
-------
THE OLD SHELL GAME
(END-OF-PIPE)
CLEAN AIR ACT
CLEAN AIR ACT
• ETC
-------
FEDERAL
1990 Pollution Prevention Act
Congress Finds:
> Pollution Prevention at the Source is More
Desirable Than Any Other Method of
Pollution Control
> Existing Regulations and Regulated Industry
Focus on "End-of-Pipe" Pollution Control
Congress Declares:
> Pollution Prevention to be the National
Policy of United States
Congress Sets Hierarchy:
1. Pollution Prevention
2. Recycle and Reuse
3. Treatment (Pre-Treatment)
4. Disposal (Landfill, Sewer, Air)
Congress Instructs:
> EPA To Develop A National Environmental
Protection Policy to Reduce Pollution at the
Source
-------
FEDERAL
National Pollution Prevention Strategy
(56 FR 7849; February, 1991)
Objectives:
> Make Pollution Prevention The Central
Part Of EPA's Mission
> Incorporate Pollution Prevention In EPA's
Existing Regulatory And Non-Regulatory
Programs
* Incorporate Pollution Prevention Into Every
Aspect Of EPA's Operations
> Make Pollution Prevention The First Choice
In All Environmental Activities
Strategy:
> Outreach And Training
> Incorporate Pollution Prevention In Permitting
And Enforcement
* Partnership With Industry
> Technology Research And Exchange
-------
FUTURE
-------
NEW CULTURE
NEW ADMINISTRATION HAS DECLARED
POLLUTION PREVENTION TO BE A "POLICY
GUIDELINE"
ENVIRONMENTAL GROUPS HAVE EMBRACED
POLLUTION PREVENTION (ZERO DISCHARGE)
WATERSHED POLICY MAKES POLLUTION
PREVENTION ITS MAIN POLICY ELEMENT
INDUSTRY HAS RECOGNIZED THAT POLLUTION
PREVENTION REDUCES THEIR
ENVIRONMENTAL LIABILITY
-------
WHAT DOES IT MEAN?
INCORPORATE POLLUTION PREVENTION
PRACTICES AND PHILOSOPHY IN THE CLEAN
WATER ACT REAUTHORIZATION
INCORPORATE POLLUTION PREVENTION IN
EFFLUENT GUIDELINES STANDARDS AND
REQUIREMENTS
INCORPORATE POLLUTION PREVENTION IN
NPDES AND ENFORCEMENT ACTIONS
INCORPORATE POLLUTION PREVENTION
REQUIREMENTS IN POTWS PRE-TREATMENT
PROGRAMS
EXPAND TRI REPORTING (FORM R)
USE TSCA TO ENFORCE POLLUTION
PREVENTION
STATE PROGRAMS ARE REQUIRED TO INCLUDE
POLLUTION PREVENTION AS PRIORITY
ELEMENT
INDUSTRY IS ADOPTING POLLUTION
PREVENTION PROGRAMS
-------
THE NEW
VS.
THE OLD
REDUCING POLLUTANTS AT THE SOURCE
VS.
THE "SHELL GAME" OF POLLUTANTS
POLLUTION PREVENTION
VS.
COMMAND-AND-CONTROL
-------
"THE DIFFERENCE"
COMMAND AND
CONTROL
^ 4
POLLUTION
PREVENTION
Management Of
Generated Waste
End-Of-Pipe
Prescriptive
Limit Oriented
Single Media
Management of Waste
Generation
Holistic*
Flexibility
Goal Oriented
Multi Media
-------
"NEW THINKING"
^FLEXIBILITY
^INNOVATION
WOUTREACH
AND
»TOTAL QUALITY ENVIRONMENTAL MANAGEMENT
-------
TOTAL QUALITY ENVIRONMENTAL MANAGEMENT
> EXTERNAL CUSTOMERS
• Identify your customers
• users of your services
• regulatory agencies
• Identify your critical customers
INTERNAL CUSTOMERS
• Commit Management
• Involve and Commit Shop and Office
Personnel
• Suppliers
• Staff/personnel in contact with external
customers
CONTINUOUS IMPROVEMENT
• Internal Customers
• External Customers
WHOLE SYSTEM APPROACH
• Internal customers facility
• External customers facility
• AH environmental media
-------
THE ECONOMICS OF POLLUTION PREVENTION
THE BENEFITS
TIER O • CAPITAL AND O&M COSTS
Equipment and Installation
Raw Materials
Energy
Disposal
Maintenance
TIER 1 • HIDDEN REGULATORY COSTS
Reporting
Monitoring
Permit Requirements
Paperwork
TIER 2 • LIABILITY COSTS
Penalties and Fines
Transportation of Waste
Disposal to Landfill
Disposal to Sewer
TIER 3 • LESS TANGIBLE COSTS
Consumer Response
Employee Relations
Corporate Image
-------
WHERE DO YOU START?
DEFINE THE NEED
GAIN MANAGEMENT AND INTERNAL
CUSTOMER COMMITMENT
CONDUCT ENVIRONMENTAL ASSESSMENT
CONDUCT WASTE CHARACTERIZATION
DEVELOP PROGRAM
• Goal
• Technical Feasibility
• Financial Feasibility
• Benefits
SELL PROGRAM TO INTERNAL AND EXTERNAL
CUSTOMERS
IMPLEMENT
-------
Current Regulatory Mandates
-------
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This IP3 Demonstration Project
-------
Pollution prevention
demonstration project
Partnership
Agencies
- EPA
- state/local agencies
- POTWs
Industrial laundries
-------
To promote pollution prevention
- overcome old mindset
- flexibility
- partnership
- technical innovation
-------
EPA Office of Water
IPPP
Regional pilot project
San Francisco regional office
Objective of IPPP
promote pollution prevention
promote multi-media approach
look for alternatives to:
- end-of-pipe controls
- single medium approaches
-------
Principal stakeholders
- POTWs
- larger industrial laundries
-------
For pilot project, selected:
- southern California
- industrial laundries
o service industry
concentrates and transfers
pollutants (potential for
impacting laundry
customers)
o limited # of companies
o compliance problems
o EPA developing effluent
guidelines
-------
STEPS
o Participation
o General meeting
o Focus group
o Site assessments
o Workshop
-------
Primary Issue for Laundries
Status of towels contaminated
with waste solvents, metals,
etc.
loth a RCRA issue and a state
hazardous waste issue
No decision yet at EPA HQ;
could be left to EPA
regions/states
Implications:
TSDFs rather than just RCRA
hazardous waste generators
Manifesting requirements for
towels/clolthes to laundries
-------
Barriers to participation by
industrial laundries
o fear of enforcement focus
o lack of awareness of
opportunities
o doubts about agencies'
motives/ability to help
-------
Incentives for industrial laundries
o Current regulatory problems
- discharge limits (esp. TTOs,
oil & grease)
- hazardous waste
o Expected additional
regulations
-------
New categorical requirements
Industrial laundries category
new proposed rules by EPA
1996
final rule - 1998
Technology-based limits for
removal of metals, organics
(or could determine not
necessary)
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POLLUTANTS OF CONCERN & PROBABLE SOURCES
lindane (agriculture, pest control companies)
trl methyl benzene (?)
bis ( 2 ethylhexyl) phthalate (cutting oils, furniture
manufacturing, machine shops, maintenance of machinery)
methylene chloride (maintenance of machinery, auto repair,
printers, graphics, furniture manufacturing)
copper (printers, metal finishers)
silver (printers, metal finishers, photo processors)
zinc (agriculture, pest control, laundry chemicals, automotive
repair)
chromium (metal .finishers)
TCE (printers, automotive, metal finishers, aerospace)
TCA (printers, automotive, metal finishers, aerospace)
nickel (automotive repair)
benzene (automotive repair, printers, refineries)
chloroform (health services)
MEK (automotive repair, printers, labs)
xylenes (automotive repair, printers, labs)
cadmium (printers, graphics)
-------
SITE ASSESSMENTS
(P2, not compliance)
o Internal P2 opportunities
o Customer P2 opportunities
-------
Workshop
- benefits of P2
- educating customers
- training salespeople
-------
Internal Opportunities
o Water reuse
o Solid waste reduction
o Vehicle maintenance
Won't resolve major pollution
or compliance problems
-------
Customer Opportunities
o Best Management Practices
for laundries
o BMPs for customers
-Technical criteria
-Environmental objectives
-Simplicity
-Training/education
-Marketing
-Link to regulatory
requirements
-------
BMPs for Laundries
o Don't accept towels with free liquids
o Work with customers on acceptable practices to
minimize free liquids on towels
o Educate route salespeople; set minimum pickup
standards
o Establish in-house handling procedures for
towels
o BMP training for all employees
o Provide customes information on sources of
pollution prevention technical assistance
-------
BMPs for Customers
o Wring out or centrifuge towels
o No free liquids
o Appropriate management for extracted liquids
o Share MSDS sheets with route salespeople
o Don't pick up spills with shop towels
o Don't pour excess chemicals onto shop towels
o Don't pre-wash towels
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Benefits of BMPs
o for laundries
- marketing tool
- avoid fire-drill compliance
problems
- avoid high cost control/
treatment
o for agencies
- use laundries as outreach to
other industries
- build cooperative attitude
- avoid media-shifting
- more self-implementing
-------
Effectiveness of BMPs requires:
- enforcement of level playing
field
- either/or strategy
-------
Laundries' Concerns
o Cost of controls
o Non-compliance penalties
o Aggressive competition for
accounts
o Competition with paper
products
-------
General Lessons
- Value of partnership
- Time/effort required to develop
cooperation
- Equitable enforcement
- Value of MM perspective
- Importance of understanding
market/economic factors
- Importance of understanding
technical opportunities/
constraints
- Need for interagency
coordination
-------
Best Management
Practices by Customer
Institute of Industrial Launderers and Textile
Rental Services Association of America
4> Minimum Requirements designed to
eliminate free liquid from textiles prior to
transportation and laundering
O Waste Minimization Options for Printers
4> To Aid Industrial Laundries
O Design for the Environment Printing Project:
US EPA and Printing Industry Associations
Nationwide
Case Study 1: Managing Solvents and
Wipes
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Best Management
Practices by Customer
Institute of Industrial Launderers and Textile
Rental Services Association of America
Minimum Requirements designed to eliminate
free liquid from textiles prior to transportation
and laundering
Service Co./Customer Responsibilities
Textile Usage
Soiled Textile Collection
Soiled Textile Transport
On-going Pursuit of Compliance with All
Local, State, and Federal Regs
-------
BMPs by Customer
Waste Minimization Options for Printers to Aid
Industrial Laundries
Use more environmentally desirable
chemicals in printing and cleaning
Eliminate or minimize metals and heavy
metals in pigments
4" Separate wipes according to soils
Remove excess solvents
4- Multimedia Regulatory Partnerships which
ensure P2 information, handling, and
transport of liquid-free, soiled, reusable
textiles
-------
Continuous Improvement
by Customer
Design for the Environment Printing Project:
US EPA and PIA Nationwide
Case Study 1: Managing Solvents and Wipes
Chemical Supplier Partnerships for Solvent
Reevaluation and Substitution
Laundry Service Partnerships for Materials
Recovery/Reuse by Centrifuge or other
BMPs
Multimedia Regulatory Partnerships
What are MN & KS doing to facilitate this?
What was developed in Washington state in
cooperative effort with laundries?
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P2 Opportunities for
Customers
Service Stations/Vehicle Maintenance
"New" Safety Kleen Approach
Solvent blend at 155° F flashpoint
Will it pass TCLP after use?
4- Will this reduce loading to launderers?
Alternate cleaners (trade-offs)
Health & Safety
Environmental
Operations Procedures
-------
Waste Reduction Options for
Industrial Laundries
Use Environmentally Friendly Cleaning
Solutions (Not Dry-cleaning Chemicals)
Convert Industrial Wastewater into Usable,
Energy-efficient, High BTU Fuels for Fuels
Blending
Use a Continuous Wash System
D Water Use Reduction
Energy Use Reduction
Separate Shop Towels from Other Textiles and
Treat Wastewaters Separately
-------
Semi-Aqueous Acceptance
Health and Safety Trade-offs
4- Terpene cleaners containing d-limonene
(positive carcinogenicity tests after further
investigation)
4> Low flash points
D Environmental Trade-offs
+ Terpenes have high BOD & COD (if used
extensively, will likely require pretreatment
before discharge to POTW)
D Operational Trade-Offs
+ New operating or maintenance skills may be
needed
4- Tighter controls may be needed
Product quality and operating rates may be
affected
-------
P2 Program-in-Plaee
Top Management Commitment
Characterization of Wastestreariis
Assessment of P2 Options
Waste Cost Allocation System
Employee Involvement
Program Evaluation
-------
Top Management
Commitment
D P2 Policy: Continuous Improvement
Toxics Use Reduction
D Best Operating Procedures to Reduce
Unnecessary Wastes
Planning: Eliminate Waste in Energy and Water
Use
-------
Characterization of
Wastestreams
Wastewater
Waste solids
Air releases
Shop towels, wipes & rags (impact on
wastestreams)
O Others?
-------
Assessment of P2 Options
Water Use Reduction
O Water discharged depends on:
4- Efficiency of equipment
Efficiency of operations
Water conservation measures applied
Types of articles cleaned
Types and loadings of soils
Total amount of waterwashing vs.
dry-cleaning
-------
Waste Cost Allocation
System
Costs & Amounts of Laundry Process
Chemicals Used
Treatment Costs
Disposal Costs
Regulatory Fees
Oversight Costs
Water Costs
Energy Costs
-------
P2 Program-in-Place
Employee Involvement
Customer Oversight on Free Liquids
Training
D Program Evaluation
On-going Program with Someone in Charge
Measure Results & Set New Goals
-------
P2 Program-in-Place
Assessment of P2 Options
-------
Regulatory Barriers to P2
D End-of-Pipe Focus
Media-Specific Focus
Regulatory Program Evaluation Criteria
O Regulatory Inflexibility
Regulatory Uncertainty
Pollution Fees
Data Gathering and Management
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Wastewater
Characteristics
Soiled Materials from Processes & Operations
12 Volatile Organics
10 Semivolatile Organics
4 Pesticides & Herbicides
All Priority Metals
4- Cyanide found in all (several > 0.1 mg/1)
1989 US EPA Report
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Soiled Materials from
Processes & Operations
O 12 Volatile Organics
4> Ethyl benzene, Methylene chloride, Toluene
andTCA
D 10 Semivolatile Organics
4> Isophorone, naphthalene &
N-nitrosodi-n-propylamine
D 4 Pesticides & Herbicides ,
+ Endosulfan sulfate
All Priority Metals
Pb, Chrome, Cu & Zn (>1 mg./l)
Report
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Laundry Process
Chemicals
Phenolic Compounds (germicides, bacteriostats,
detergent additives, dust treating compounds)
Zinc Compounds (sours and germicides)
BOD5, Oil and Grease (soaps and detergents)
High pH (alkaline conditions)
Oils to Clean Dust Mops
Chlorine Bleaches
Cleaning Processes Used
Volatile Organics (dry-cleaning solvents)
1989 US EPA Report
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Waste Solids
Characteristics
D Pollutants:
Volatile Organics: "Exceeded Proposed
Level for Perc"
Semivolatile Organics
Toxic Metals & Elements
Cyanide Found in All Sludge Samples but
One
Pesticide Endosulfan Sulfate Found but No
Regs Available
Ignitability Exhibited by Sediments,
Screened Materials, DAF-thickened Sludge,
and Final Ultrafiltration Concentrate
Is there an approved flammability test for
solids?
(Results 1986-87 Sampling of 5 Laundries from 1989
EPA Report)
-------
Effectiveness of Typical
Treatment Systems
System Type Pollutant Removal
Bar and lint screens Ineffective
Settling Basins Ineffective
Dissolved air flotation clarifiers High
Membrane filtration systems High
1989 US EPA Report
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Pollutants
O Volatile Organics: Exceeded Proposed Level for Perc
Sludge from Disc Strainer (Shipped as HW)
Sediment from Settling Basins (?)
O Semivolatile Organics
4- TCLP extracts at low levels
O Toxic Metals & Elements
4- Cu, Pb, Ni, Zn at relatively high concentrations
4 Final concentrate from ultrafiltration (Shipped as
HW)
*> Pb> regulatory level
* Cd approaching regulatory level
O Cyanide found in all sludge samples but one
Solid wastes which exhibit the characteristic of toxicity or
ignitability are designated HW and must be handled and
disposed of in conformance with HW regulations.
1989 US EPA Report
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Key Industries Using Shop
Towels
Auto/Vehicle Maintenance- 42%
SIC 75 (25.5%)
Dealers & Service Stations (16.5%)
O Wholesale Trade/Durable Goods 6%
(SIC 50)
O Printing/Publishing 5%
(SIC 27)
O. Furniture <1%
Aerospace <1%
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Application of RCRA to
Soiled Textiles
O States:
Many have chosen to exempt soiled towels if managed
properly.
O Washington State Department of Ecology:
4- Reduce the amount of ignitable, volatile and toxic
chemicals used through substitution with less hazardous
chemicals, when effective.
4> Establish management practices that result in minimal
amounts of hazardous chemicals on used shop towels that
are sent to recyclers.
4- Allow towels that are recycled and handled according to
best management practices to be considered as managed in
compliance with hazardous waste requirements.
* Recyclers may process shop towels without being
permitted as a treatment facility under state and federal
hazardous waste regulations.
4- Ensure that hazardous wastes are safely managed from
"cradle to grave" preventing the release of hazardous
substances to the environment.
4 Save money, raw materials, and energy while keeping
hazardous chemicals out of your local landfill.
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Application of RCRA to
Soiled Textiles
O EPA Region 9:
Rags contaminated with listed spent solvent
are hazardous due to "mixture rule" if the
mixture continues to exhibit a characteristic.
If FOO1-FOO5 spent solvents, mixture is
subject to LDR and must be treated prior to
land disposal.
Also, listed spent solvent wastes generated
in the cleaning process would be a RCRA
waste.
Treatment by laundry facility preferable to
incineration, if transported and stored in
compliance with RCRA prior to cleaning
EPA Regions 4,7, & 8:
Towels that are laundered cannot be
characterized as solid waste and, therefore,
cannot be a hazardous waste.
-------
Application of RCRA to
Soiled Textiles
O EPA HQs:
When F001-F005 solvents are applied to a
surface, then cleaned off with rags, the solvents
are spent and the rags are covered by F001-F005
listing.
When solvents are applied to a rag prior to use,
the solvents are not spent and the rags are not '
covered by the spent solvent listing.
Both types of rags pose similar hazards and it is
hard for the land disposal facilities to distinguish
the difference. May choose not to accept solvent
rags unless they meet the treatment standards.
After these considerations, HQs recommends
that any rags contaminated with listed solvents
be managed as hazardous wastes.
HQs has not encouraged regions or states to
rigidly enforce.
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Application of RCRA to
Soiled Textiles
O IIL & TRSA Guidelines:
Soiled textiles containing free liquids that
may be listed or characteristically
hazardous, will constitute improper
management by the customer and SHOULD
BE CONSIDERED a hazardous waste by
the laundry.
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POLLUTION PREVENTION RESOURCE DOCUMENT LIST
Industry
Auto Repair
Printers
lifle 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 Bv
Cal-EPA
DISC
L.A. City
HTM
L.A. City
HTM
Cal-EPA
DISC
Cal-EPA
DTSC
Cal-EPA
DTSC
Cal-EPA
DTSC
U.S. EPA
DfE Project
L.A. County
San. Districts
Orange County
San. Districts
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. Districts
-------
POLLUTION PREVENTION RESOURCE DOCUMENT LIST
(p. 2 of 4)
Metal Finishers
(con't)
Metal Fabricators
Aerospace
Printed Circuit
Boards
Furniture
Refinishers
Jewelry
Paint
Metal Finishing: Pollution Guidelines
Prevention Opportunities Guidelines
Hazardous Waste Reduction
Checklist & Assessment
Manual for the Metal Finishing
Industry
Waste Minimization Opportunity Case Studies
Assessments: East L.A. Enterprise
Zone Metal Platin,g Facilities
Metal Fabricators: Pollution Guidelines
Prevention Opportunities Guidelines
Metal Fabricators: Pollution Factsheet
Prevention Opportunities Checklist
Waste Minimization for Fact Sheet
Aerospace Industry
Waste Minimization for Fact Sheet
Printed Circuit Board
Manufacturers
Printed Circuit Board Guidelines
Manufacturing: Pollution
Prevention Opportunities
Guidelines
Printed Circuit Board Factsheet
Manufacturing: Pollution
Prevention Opportunities
Checklist
Furniture Refinishers- Fact Sheet
Regulatory Requirements
Waste Minimization Assessment Case Study
for a Manufacturer of
Military Furniture
Jewelry Manufacturers: Fact Sheet
Basic Environmental &
Business Requirements
Waste Minimization for Fact Sheet
Paint Formulators
Paint Collection Facilities Directory
for Businesses
Orange County
San. Districts
Handbook & Checklist Cal-EPA
DTSC
HTM
Cal-EPA
DTSC/L.A.
City HTM
Orange County
San. Districts
L.A. County
San. Districts
Cal-EPA
DTSC
Cal-EPA
DTSC
Orange County
San. Districts
Orange County
San. Districts
L.A. City
HTM
U.S EPA
RREL
L.A. City
Cal-EPA
DTSC
L.A. City
HTM
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POLLUTION PREVENTION RESOURCE DOCUMENT LIST
(p. 3 of 4)
Paint (coa'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
DISC
Orange County
San. Districts
L.A. County
San. Districts
Cal-EPA
DISC
Orange County
San. Districts
L.A. County
San. Districts
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POLLUTION PREVENTION RESOURCE DOCUMENT LIST
(p. 4 of 4)
The publications on this list are available to the public free of charge. To order, call or write:
Cal-EPA
DTSC
L.A. City
HTM
L.A. County
San. Districts
California Environmental Protection Agency
Department of Toxic Substances Control
Pollution Prevention & Regulatory Assistance Division
Technology Clearinghouse
P.O. Box 806
Sacramento, CA 95812-0806
(916) 322- 3670
City of Los Angeles
Hazardous and Toxic Materials Office
Board of Public Works
200 N. Spring Street, Room 353
Los Angeles, CA 90012
(213) 237-1209
Los Angeles County
Sanitation Districts
P.O. Box 498
1955 Workman Mill Road
Whittier, CA 90607
(310) 699-7411
(213) 237-1445 (FAX)
contact: Theresa Dodge
Orange County Orange County
San. Districts Sanitation Districts
P.O. Box 8127
10844 Ellis Avenue
(310) 692-5103 (FAX)
contact: Adriana Renescu
U.S. EPA
DfE Project
Fountain Valley, CA 92728-8127
(714) 962-2411 (714) 962-6957 (FAX)
U.S. Environmental Protection Agency
Design for the Environment Project
Pollution Prevention Information Clearinghouse
(202) 260-1023
(202) 260-0178 (FAX)
*t).S. GOVERNMENT PRINTING OFFICE: 1995-624-582/82354
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