United States
Environmental Protection
Agency
Office of Water
(4303)
EPA821-R-00-006
March 2000
Technical Development Document
for the Final Action Regarding
Pretreatment Standards for the
Industrial Laundries Point Source
Category (Revised March 2000)

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          TECHNICAL DEVELOPMENT DOCUMENT FOR

THE FINAL ACTION REGARDING PRETREATMENT STANDARDS

                              FOR THE

     INDUSTRIAL LAUNDRIES POINT SOURCE CATEGORY

                        (Revised March 2000)
                            Carol M.  Browner
                              Administrator

                             J.  Charles Fox
                   Assistant Administrator, Office of Water

                              Sheila Frace
                  Director, Engineering and Analysis Division

                            Marvin B. Rubin
                           Chief, Energy Branch

                              Marta Jordan
                         Work Assignment Manager
                      Engineering and Analysis Division
                      Office of Science and Technology
                    U.S. Environmental Protection Agency
                          Washington D.C. 20460
                              March 2000

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                              ACKNOWLEDGMENT

              This report has been reviewed and approved for publication by the Engineering
and Analysis Division, Office of Science and Technology.  This report was prepared with the
support of Eastern Research Group, Inc. under the direction and review of the Office of Science
and Technology.

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                                     FOREWORD

             This document includes technical support for the options considered during
rulemaking for the Industrial Laundries Point Source Category.

             After the Administrator signed the notice of final action, EPA received revised
analytical data for some of the samples measured for semivolatile organic compounds, due to
errors found in using dilution factors to calculate the sample concentrations.  The revised data did
not cause major changes, and provided a stronger basis for EPA's decision not to regulate this
industry. Based on revised analytical data for semivolatile organic compounds for two sampling
episodes conducted in 1996 and 1998, EPA revised this document in March 2000. The following
chapters and appendices have been revised:

•            Chapter 5
             —Table 5-11;
             —Table 5-12;
             —Table 5-14
             —Table 5-15; and
             —Table 5-16.

•            Chapter 7
             —Table 7-1;
             —Table 7-3;
             —Table 7-4;
             —Table 7-5;
             —Table 7-7;
             —Table 7-11; and
             —Tables 7-12 through 7-16.

•            Chapter 9
             —Table 9-1;
             —Table 9-4;
             —Tables 9-9 through 9-16.

•            Appendix C
             —Table C-3; and
             —Table C-4.

•            Appendix D, References D-4 through D-8.

•            Appendix E.

Throughout the document, EPA refers to many commonly used titles and phrases by their
acronyms to avoid spelling them out each time. As an aid to the reader, EPA has included in
Chapter 12 a glossary of commonly used acronyms and definitions of terms used throughout the
document.

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                               TABLE OF CONTENTS
CHAPTER 1
CHAPTER 2
CHAPTER 3
                                                             Page

SUMMARY	1-1

1.1    Introduction	  1-1
1.2    Scope and Definition of the Industrial Laundries Industry	1-1
1.3    Overview of the Industrial Laundries Industry	  1-2
1.4    Final Action for the Industrial Laundries Point Source
      Category 	  1-3

BACKGROUND  	2-1

2.1    Introduction	2-1
2.2    Legal Authority 	2-1
2.3    Background	2-1
2.3.1  Clean Water Act (CWA)  	2-1
      2.3.2   Pollution Prevention Act (PPA)	2-4
      2.3.3   Regulatory Flexibility Act (RFA) as Amended by the
             Small Business Regulatory Enforcement Fairness Act
             of 1996 (SBREFA)  	2-4
      2.3.4   Prior Regulation of the Industrial Laundries Point Source
             Category 	2-5

DATA COLLECTION METHODOLOGY AND INFORMATION
SOURCES 	3-1

3.1    Introduction	3-1
3.2    Summary of Data Collection Prior to 1992	3-2
      3.2.1   1971 Survey  	3-2
      3.2.2   1975 Data Collection	3-2
      3.2.3   1977 Data Collection Portfolio (DCP)	3-3
      3.2.4   1978 Sampling Program	3-3
      3.2.5   1979 Laundries Survey  	3-4
      3.2.6   Industrial Technology Division (ITD)/Resource
             Conservation and Recovery Act (RCRA)  Sampling Program
             and Development of the Preliminary Data Summary (1985
             through 1987)  	3-5
3.3    Summary of Industrial Laundries Questionnaire Activity
      After 1992  	3-5
      3.3.1   Screener Questionnaires	3-6
      3.3.2   1994 Industrial Laundries Industry Questionnaire (Detailed
             Questionnaire)	3-8

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                         TABLE OF CONTENTS (Continued)

                                                                                  Page


                          3.3.3   Detailed Monitoring Questionnaire	3-11
                    3.4   Summary of EPA's Site Visit Program (1993-1998)	3-12
                          3.4.1   Criteria for Site Visit Selection	3-13
                          3.4.2   Types of Information Collected 	3-13
                    3.5   Summary of EPA's Sampling Program (1993-1998)	3-13
                          3.5.1   Criteria for Sampling Site Selection	3-14
                          3.5.2   Information Collected  	3-14
                          3.5.3   Sample Collection and Analysis	3-15
                    3.6   Summary of EPA's Method  1664 Characterization Study .... 3-16
                    3.7   Other Industry-Supplied Data	3-16
                          3.7.1   Data Submitted Prior to 1992  	3-16
                          3.7.2   Trade Associations Solicitation of Data	3-17
                          3.7.3   Data Included with Comments on the Proposed Rulemaking
                                 and Notice of Data Availability  	3-18
                          3.7.4   Request for Substantiation of Claims Made in
                                 Comments	3-18
                          3.7.5   The Trade Associations Split-Sampling Efforts  	3-19
                    3.8   POTW Data	3-19
                          3.8.1   AMSA Questionnaire	3-19
                          3.8.2   Data Submittals Related to POTWs with Comments
                                 on the Proposed Rulemaking and Notice of Data
                                 Availability	3-20
                    3.9   Summary of Literature Searches	3-21
                    3.10  Summary of Other Data Sources 	3-22
                          3.10.1  Ri sk Reduction Engineering Laboratory Treatability
                                 Database  	3-22
                          3.10.2 Fate of Priority Pollutants in Publicly Owned Treatment
                                 Works Database	3-23
                          3.10.3  The Domestic  Sewage Study	3-23
                          3.10.4 Canadian Studies	3-23
                          3.10.5  Industrial Pollution Prevention Project	3-24
                    3.11  References	3-25

CHAPTER 4        INDUSTRY PROFILE	4-1

4.1                  Introduction	4-1
                    4.2   Overview of the Industry  	4-2
                          4.2.1   Geographic Distribution of Facilities  	4-2
                          4.2.2   SIC Codes Reported 	4-2
                          4.2.3   Facility Size	4-2
                          4.2.4   Items Laundered  	4-7
                          4.2.5   Customers	4-7

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                         TABLE OF CONTENTS (Continued)

                                                                                   Page

                    4.3   Laundering Processes	4-12
                          4.3.1    Water-Using/Wastewater-Generating Processes	4-12
                          4.3.2    Processes with Minimal Wastewater Discharge  	4-14

                          4.3.3    Chemicals Used in Industrial Laundries  	4-16
                    4.4   Facilities and Equipment	4-16
                          4.4.1    Washers, Extractors, and Washer-Extractors	4-20
                          4.4.2    Tunnel Washers	4-20
                          4.4.3    Dry-Cleaning Units   	4-20
                          4.4.4    Equipment Use and Age	4-21
                    4.5   Pollution Reduction Activities  	4-21
                    4.6   Trends in the Industry	4-26
                          4.6.1    Trend  Away From Drycleaning  	4-26
                          4.6.2    Trend  of Small Facilities Being Purchased by Larger
                                  Firms	4-26
                          4.6.3    Trends in Equipment and Technologies  	4-27
                    4.7   Treatment Technologies in Use	4-27
                    4.8   Industry Definition	4-27
                    4.9   References	4-32

CHAPTER 5        WATER USE, WASTEWATER CHARACTERIZATION , AND
                    POLLUTANTS OF CONCERN,	5-1

                    5.1   Introduction	5-1
                    5.2   Sources of Service Water and Water Use	5-2
                          5.2.1    Sources  of Service Water at Industrial Laundries	5-2
                          5.2.2    Use of Service Water at Industrial Laundries	5-2
                    5.3   Wastewater Volume by Type of Discharge	5-5
                    5.4   Water Conservation Measures  	5-10
                    5.5   Pollutants Analyzed in Industrial Laundry Wastewater	5-10
                    5.6   Identification of Pollutants of Concern  	5-15
                    5.7   Characterization  of Raw Wastewater by Item Laundered  .... 5-27
                    5.8   Characterization  of Total, Heavy, and Light Raw Wastewater
                          Streams 	5-27
                    5.9   Characterization  of Method  1664 Constituents	5-27
                    5.10  References	5-42
                                           in

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                          TABLE OF CONTENTS (Continued)

                                                                                   Page

CHAPTER 6         POLLUTION PREVENTION, RECYCLING, TREATMENT, AND
                     DISPOSAL TECHNOLOGIES EMPLOYED BY THE INDUSTRIAL
                     LAUNDRIES INDUSTRY	6-1

                     6.1   Introduction	6-1
                     6.2   The Environmental Management Hierarchy  	6-1
                     6.3   Pollution Prevention/Source Reduction in the Industrial Laundries
                          Industry 	6-3
                          6.3.1    Preprocess Pollution Prevention Activities	6-4
                          6.3.2    In-Process Pollution Prevention Activities  	6-8
                     6.4   Waste Recycling/Resource Conservation and the Industrial
                          Laundries Regulatory Development Process	6-12
                          6.4.1    Water Conservation in the Industrial Laundries
                                  Industry	6-12
                          6.4.2    Energy Conservation in the Industrial Laundries
                                  Industry	6-13
                          6.4.3    Dry Cleaning of Solvent Laden Items Prior to Water
                                  Washing	6-13
                          6.4.4    Steam/Air Tumbling of Solvent Laden Items Prior to
                                  Water Washing 	6-13
                          6.4.5    Centrifuging of Solvent Laden Items Prior to Water
                                  Washing	6-17
                          6.4.6    Pressing Solvent Laden Items Prior to Water
                                  Washing	6-18
                     6.5   Wastewater Treatment Technologies in the Industrial Laundries
                          Industry 	6-18
                          6.5.1    Gravity Settling	6-19
                          6.5.2    Stream Splitting	6-19
                          6.5.3    Screening	6-21
                          6.5.4    Equalization	6-24
                          6.5.5    Chemical Emulsion Breaking	6-25
                          6.5.6    Chemical Precipitation	6-27
                          6.5.7    Dissolved Air Flotation  (DAF)	6-32
                          6.5.8    Sludge Dewatering	6-33
                          6.5.9    pH Adjustment	6-39
                          6.5.10  Ultrafiltration/Microfiltration	6-39
                          6.5.11  Centrifugation  	6-40
                          6.5.12  Oil/Water Separation	6-41
                          6.5.13  Media Filtration	6-42
                          6.5.14  Carbon Adsorption  	6-42
                          6.5.15  Air Stripping 	6-43
                                           IV

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                         TABLE OF CONTENTS (Continued)

                                                                                  Page

                          6.5.16 Wastewater Treatment Technologies Used by the
                                 Industrial Laundries Industry in 1998	6-45
                    6.6   Pollution Disposal Practices in the Industrial Laundries
                          Industry  	6-45
                          6.6.1   Wastewater Disposal	6-45
                          6.6.2   Waste Organic Material Disposal	6-47
                          6.6.3   Sludge Disposal	6-47
                    6.7   References	6-48

CHAPTER 7        TREATMENT PERFORMANCE DATA USED FOR THE
                    DEVELOPMENT OF CANDIDATE PRETREATMENT
                    STANDARDS	7-1

                    7.1   Introduction	7-1
                    7.2   Sources of Treatment Technology Performance Data From Well-
                          Designed and Well-Operated Treatment Systems  	7-1
                          7.2.1   Industrial Laundry  Sampling Program Data  	7-2
                          7.2.2   Detailed Monitoring Questionnaire (DMQ) Data	7-4
                          7.2.3   Other Industry-Supplied Data  	7-5
                    7.3   Evaluation of Treatment Performance Data  	7-5
                          7.3.1   Assessment of Treatment System Performance and
                                 Identification of Process Upsets	7-6
                          7.3.2   Identification of Pollutants Not Treated by the Treatment
                                 Technology 	7-6
                          7.3.3   Identification of Pollutants Not Present in Influent Samples
                                 at Sufficient Concentrations to Evaluate Treatment
                                 Effectiveness	7-7
                          7.3.4   Identification of Treatment Performance Data With
                                 Inconsistent Detection Limits	7-7
                          7.3.5   Identification of Treatment Performance Data Considered a
                                 Lower Limit of the Actual Value	7-7
                    7.4   Calculation of Long-Term Average Concentrations for the
                          Pollutants of Concern	7-7
                    7.5   Methodology for Determining Pollutants of Concern Selected for
                          Candidate Pretreatment Standards Development	7-8
                          7.5.1   Elimination of Treatment Chemicals	7-12
                          7.5.2   Elimination of Pollutants Not Treated or Below Treatable
                                 Concentrations	7-12
                          7.5.3   Elimination of Pollutants that Do Not Pass Through or
                                 Otherwise Interfere with Publicly Owned  Treatment Works
                                 (POTWs)	7-12

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                         TABLE OF CONTENTS (Continued)

                                                                                  Page

                          7.5.4   Pollutants of Concern Selected for Candidate Pretreatment
                                 Standards Development	7-33
                    7.6   Long-Term Average and Variability Factors for the Five
                          Technology Options	7-36
                    7.7   Mass-Based Standards	7-38
                    7.8   References	7-46

CHAPTER 8        DEVELOPMENT OF TECHNOLOGY CONTROL OPTIONS .. 8-1

                    8.1   Introduction	8-1
                    8.2   Initial Technology Control Options Considered  	8-1
                          8.2.1   Postlaundering Wastewater Treatment Technology Control
                                 Options  	8-2
                          8.2.2   Prelaundering Organics Control (OC-Only) Technology
                                 Control Option 	8-5
                    8.3   Inclusion of Pollution Prevention in the Technology Control Opl8eh2
                    8.4   Exclusion of Wastewater Recycling Activities from the Technology
                          Control Options	8-13
                    8.5   Subcategorization Analysis	8-13
                          8.5.1   Disproportionate Economic Impacts 	8-14
                          8.5.2   Laundry Processes and Water Use Practices	8-14
                          8.5.3   Plant Age	8-15
                          8.5.4   Plant Location	8-15
                          8.5.5   Plant Size	8-15
                          8.5.6   Raw Materials	8-16
                          8.5.7   Non-Water Quality Environmental Impacts  	8-16
                          8.5.8   Type of Item Laundered  and Wastewater
                                 Characteristics	8-16
                    8.6   Initial Technology Control Options Not Further Considered ..  8-17
                    8.7   Additional Technology Control Options Considered	8-18
                          8.7.1   Industrial Laundry Wastewater (IL) Technology Control
                                 Options  	8-18
                          8.7.2   Towel (TWL) Technology Control Options	8-18
                          8.7.3   Combination (Combo) Technology Control Options  .  8-19
                          8.7.4   Towel Only Technology  Control Option 	8-21
                          8.7.5   No Regulation Option 	8-22
                    8.8   Technology Control Options Eliminated from Further Considera$k2ฃ
                    8.9   Regulatory Control Options Considered for the Final Action  .  8-23
                    8.10  References	8-23
                                           VI

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                        TABLE OF CONTENTS (Continued)
CHAPTER 9
                                                                               Page
POLLUTANT LOADING AND REMOVAL ESTIMATES  	9-1

9.1   Introduction	9-1
9.2   Data Sources 	9-2
9.3   Methodology Used to Estimate Pollutant Loadings and
     Removals	9-3
     9.3.1   Methodology Used to Estimate Industry Untreated
            Pollutant Loadings	9-4
     9.3.2   Methodology Used to Estimate Industry Baseline
            Wastewater Loadings	9-7
     9.3.3   Methodology Used to Estimate Industry Postcompliance
            Wastewater Loadings	9-13
     9.3.4   Methodology Used to Estimate POTW Baseline and
            Postcompliance Wastewater Loadings	9-18
     9.3.5   Methodology Used to Estimate Industry and POTW
            Pollutant Removals  	9-18
9.4   Pollutant Loadings and Removals	9-22
9.5   Pollutant Loadings and Removals Estimated from 1998 Facility
     Treatment-In-Place Data   	9-23
9.6   References	9-25
CHAPTER 10
NON-WATER QUALITY ENVIRONMENTAL IMP ACTS	10-1

10.1   Introduction	  10-1
10.2   Non-Water Quality Environmental Impacts of the CP-IL and DAF-
      IL Options Considered as the Bases for PSES and PSNS  	  10-1
      10.2.1 Energy Consumption Impacts 	  10-2
      10.2.2 Air Emissions Impacts	  10-4
      10.2.3 Solid Waste Impacts 	  10-8
      10.2.4 Non-Water Quality Environmental Impacts of the
            Regulatory Options Considered for PSNS  	  10-8
10.3   References	  10-10
CHAPTER 11
COSTS OF TECHNOLOGY BASES FOR REGULATORY
OPTIONS	11-1
                    11.1  Introduction	 11-1
                    11.2  Costing Methodology	 11-3
                         11.2.1  Cost Model Development and Structure	 11-4
                         11.2.2  Components of the Cost of Compliance	 11-5
                         11.2.3  Treatment-in-Place Credit Methodology  	 11-10
                         11.2.4  Optimization Cost Allowance	 11-15
                                        vn

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                         TABLE OF CONTENTS (Continued)

                                                                                Page

                    11.3  Cost Modeling	 11-16
                         11.3.1  Cost Model Driver	 11-16
                         11.3.2  Stream Splitting	 11-17
                         11.3.3  Pumps	 11-18
                         11.3.4  Screening	 11-19
                         11.3.5  Equalization	 11-20
                         11.3.6  Dissolved Air Flotation  	 11-21
                         11.3.7  Chemical Precipitation	 11-23
                         11.3.8  Sludge Dewatering	 11-26
                         11.3.9  pHAdjustment	 11-27
                         11.3.10 Treatment System Building 	 11-28
                         11.3.11 Contract Haul In Lieu of Treatment On Site	 11-29
                         11.3.12 Compliance Monitoring	 11-30
                    11.4  Engineering Costs for the Regulatory Options  	 11-31
                    11.5  Compliance Costs Estimated from 1998 Facility Treatment-In-Place
                         Data	 11-31
                    11.6  References	 11-36

CHAPTER 12       GLOSSARY OF TERMS	12-1
Appendix A - Tables Referenced in Chapter 3
Appendix B - Tables Referenced in Chapter 4
Appendix C - Tables Referenced in Chapter 5
Appendix D - Tables Referenced in Chapter 7
Appendix E - Tables Referenced In Chapter 9
                                         Vlll

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                                  LIST OF TABLES

                                                                                  Page

4-1                 Geographic Distribution of Industrial Laundries by EPA Region
                    and State  	4-4

4-2                 Industrial Laundry Size Distribution  	4-6

4-3                 Types of Items Laundered 	4-8

4-4                 Typical Customers for Each Type of Item Laundered	4-9

4-5                 Laundering Processes Reported in the Detailed Questionnaire  	4-13

4-6                 Industrial Laundering Wash Formula Chemicals Reported in the
                    Detailed Questionnaire	4-17

4-7                 Amounts of Detergent Added Per 1,000 Pounds of Laundry for Items
                    Most Often Laundered	4-18

4-8                 Age of Facilities and Startup of Laundry/Dry-Cleaning Operations
                    (Estimated Percentage of Total Facilities in Each Time Period)	4-19

4-9                 Types of Laundry Processing Equipment Reported in the Detailed
                    Questionnaire	4-22

4-10                Age of Laundry Processing Equipment Reported in the Detailed
                    Questionnaire (Percentage of Equipment Type Installed in Each Time
                    Period)	4-23

4-11                Preprocess Pollution Reduction Activities	4-24

4-12                In-Process Pollution Reduction Activities	4-25

4-13                Comparison of Linen Facility and Industrial Laundry Facility Mean
                    Pollutant Log Concentrations	4-29

4-14                Comparison of Linen Facility and Denim Prewash Facility Mean
                    Pollutant Log Concentrations	4-30

5-1                 Service Water Sources	5-3

5-2                 Service Water Use  	5-4
                                          IX

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                             LIST OF TABLES (Continued)

                                                                                   Page


5-3                 Item-Specific Water Use	5-7

5-4                 Discharge Practices of Industrial Laundries	5-9

5-5                 Water Conservation Practices and Water Use Reduction 	 5-12

5-6                 Pollutants Not Detected in Any Samples Analyzed during the
                    1993-1996 Industrial Laundries Sampling Program	 5-16

5-7                 Pollutants Detected in Less Than 10 Percent of Samples Analyzed
                    During the 1993-1996 Industrial Laundries Sampling Program	5-19

5-8                 Semiquantitative Metal and Elemental Pollutants Excluded from the
                    Pollutants of Concern for the Industrial Laundries Industry	 5-20

5-9                 Average Influent Concentrations, Effluent Concentrations, and
                    Removals for Phosphorous and Surfactants by Chemical Precipitation
                    or Dissolved Air Flotation Technologies	 5-22

5-10                Pollutants of Concern for the Industrial Laundries Industry	 5-23

5-11                Wastewater Characterization for Item-Specific Wastewater at
                    Industrial Laundries  	 5-28

5-12                Wastewater Characterization Data for Heavy Wastewater Streams at
                    Industrial Laundries  	 5-33

5-13                Wastewater Characterization Data for Light Wastewater Streams at
                    Industrial Laundries  	 5-36

5-14                Wastewater Characterization Data for Total Raw Wastewater Streams
                    at Industrial Laundries 	 5-39

5-15                Summary of the Semivolatile Organic Pollutants Detected in Influent
                    Samples during the EPA Method 1664 Characterization Study	5-43

5-16                Summary of the Semivolatile Organic Pollutants Detected in Effluent
                    Samples during the EPA Method 1664 Characterization Study	5-45

6-1                 Number of Industrial Laundries, by Production Category, Reporting
                    Preprocess Pollution Prevention Activities in the Detailed Questionnaire
                    for the 1993 Operating Year	6-5

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                            LIST OF TABLES (Continued)

                                                                                  Page
6-2                 Types of Preprocess Pollution Prevention Activities Reported in the
                    Detailed Questionnaire for the 1993 Operating Year	6-6

6-3                 Number of Industrial Laundries, by Production Category, Reporting In-
                    Process Pollution Prevention Activities in the Detailed Questionnaire for
                    the 1993 Operating Year  	6-9

6-4                 Types of In-Process Pollution Prevention Activities Reported in the
                    Detailed Questionnaire for the 1993 Operating Year	6-10

6-5                 Steam Stripping Performance Data Collected from a Sampled
                    Facility Processing Printer Towels in a Steam Tumbler Prior to
                    Water Washing	6-15

6-6                 Number of In-Scope Facilities Responding to Detailed
                    Questionnaire Using Wastewater Treatment Technologies in the
                    1993 Operating Year 	6-20

6-7                 Comparison Between Treatment Technologies Reported in 1993
                    and 1998  	6-46

7-1                 Long-Term Average (LTA) Effluent Concentrations for the Five
                    Treatment Options for the Pollutants of Concern 	7-9

7-2                 Selected Pollutants of Concern for Treatment Options Considered in
                    Developing Long-Term Averages and Variability Factors	7-13

7-3                 Pollutants Eliminated from Further Consideration From the
                    Pass-Through Analysis Because They Are Not Treated or They Are
                    Below Treatable Concentrations	7-14

7-4                 Comparison of the Chemical Precipitation Treatment Technology
                    and POTW Percent Removals for the Industrial Laundries Pass-Through
                    Analysis	7-18

7-5                 Comparison of the DAF Treatment Technology and POTW Percent
                    Removals for the Industrial Laundries Pass-Through Analysis	7-21

7-6                 Generic Removal for w-Alkanes  	7-26

7-7                 POTW Pollutant Removals Based on a Revised POTW Removal
                    Efficiency for Nonvolatile w-Alkanes (Entire Industry - No Cutoff) . . 7-28
                                          XI

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                            LIST OF TABLES (Continued)

                                                                                  Page


7-8                 EPA and PhRMA Sampling Results for Primary Treatment at
                    Barceloneta POTW Data from Method 1671  	7-30

7-9                 WATERS Modeling Results for Primary and Secondary Treatment at
                    Barceloneta Wastewater Treatment Plant	7-31

7-10                Percent Biodegradation for Industrial Laundries Pollutants of Concern
                    Found to Be Volatile 	7-32

7-11                Pollutants Considered for Regulation for Chemical Precipitation and
                    DAF after the Pass-Through Analysis	7-34

7-12                Chemical Emulsion Breaking (CEB)	7-39

7-13                Dissolved Air Flotation - Heavy (DAF-Heavy)	7-40

7-14                Chemical Precipitation - Heavy (CP-Heavy)	7-41

7-15                Dissolved Air Flotation - All (DAF-A11) 	7-42

7-16                Chemical Precipitation - All (CP-A11)  	7-44

8-1                 Technology Control Options Initially Considered for the Industrial
                    Laundries Proposed Rule  	8-3

8-2                 Definitions of Additional Technology Control Options Considered
                    for PSES and PSNS	 8-20

9-1                 Pollutant Loadings per Pound of Item Processed (mg Pollutant/lb
                    Laundry)  	9-5

9-2                 Analytical Data Transfers	9-6

9-3                 Treatment-In-Pi ace Scenarios for Model Facilities 	9-8

9-4                 Overall Target Average Concentrations for the Seven Technology
                    Control Options for the Pollutants of Concern Used as the Bases
                    for Calculation of Baseline Pollutant Loadings  	9-10

9-5                 Methodology Used to Estimate Baseline Loadings for the Industrial
                    Laundries Industry	9-14
                                          xn

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                            LIST OF TABLES (Continued)

                                                                                 Page
9-6                 Methodology Used to Estimate Postcompliance Loadings for the
                    DAF-IL Regulatory Option for the Industrial Laundries Industry  ... 9-16

9-7                 Methodology Used to Estimate Postcompliance Loadings for the
                    CP-IL Regulatory Option for the Industrial Laundries Industry	9-17

9-8                 POTW Pollutant Removal Efficiencies for the Pollutants of
                    Concern	9-19

9-9                 Summary of Baseline Pollutant Loadings, Postcompliance Pollutant
                    Loadings, and POTW Pollutant Removals from Industrial Laundries
                    Wastewater for CP-IL Entire Industry  	9-26

9-10                Summary of Baseline Pollutant Loadings, Postcompliance Pollutant
                    Loadings, and POTW Pollutant Removals from Industrial Laundries
                    Wastewater for DAF-IL Entire Industry	9-27

9-11                Summary of Baseline Pollutant Loadings, Postcompliance Pollutant
                    Loadings, and POTW Pollutant Removals from Industrial Laundries
                    Wastewater for CP-IL Excluding Facilities with Less than 1 Million
                    Pounds per Year Total Production and Less than 255,000 Pounds per
                    Year Shop and Printer Towel Production	9-28

9-12                Summary of Baseline Pollutant Loadings, Postcompliance Pollutant
                    Loadings, and POTW Pollutant Removals from Industrial Laundries
                    Wastewater for DAF-IL Excluding Facilities with Less than 1 Million
                    Pounds per Year Total Production and Less than 255,000 Pounds per
                    Year Shop and Printer Towel Production	9-29

9-13                Summary of Baseline Pollutant Loadings, Postcompliance Pollutant
                    Loadings, and POTW Pollutant Removals from Industrial Laundries
                    Wastewater for CP-IL Excluding Facilities with Less than 3 Million
                    Pounds per Year Total Production and Less than 120,000 Pounds per
                    Year Shop and Printer Towel Production	9-30

9-14                Summary of Baseline Pollutant Loadings, Postcompliance Pollutant
                    Loadings, and POTW Pollutant Removals from Industrial Laundries
                    Wastewater for DAF-IL Excluding Facilities with Less than 3 Million
                    Pounds per Year Total Production and Less than 120,000 Pounds per
                    Year Shop and Printer Towel Production	9-31
                                          xni

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                            LIST OF TABLES (Continued)

                                                                                Page


9-15                Summary of Baseline Pollutant Loadings, Postcompliance Pollutant
                    Loadings, and POTW Pollutant Removals from Industrial Laundries
                    Wastewater for CP-IL Excluding Facilities with Less than 5 Million
                    Pounds per Year Total Production and Less than 255,000 Pounds per
                    Year Shop and Printer Towel Production	9-32

9-16                Summary of Baseline Pollutant Loadings, Postcompliance Pollutant
                    Loadings, and POTW Pollutant Removals from Industrial Laundries
                    Wastewater for DAF-IL Excluding Facilities with Less than 5 Million
                    Pounds per Year Total Production and Less than 255,000 Pounds per
                    Year Shop and Printer Towel Production	9-33

9-17                POTW Pollutant Removal Comparison Between the Removals Estimated
                    at Proposal and Removals Incorporating UTSA/TRSA Survey Data for the
                    CP-IL and DAF-IL Regulatory Options Excluding Facilities with
                    Less than 1 Million Pounds per Year Total Production and Less than
                    255,000 Pounds per Year Shop and Printer Towel/Rag Production  .  9-34

9-18                Industry Pollutant Removal Comparison Between the Removals Estimated
                    at Proposal and Removals Incorporating UTSA/TRSA
                    Survey Data for the CP-IL and DAF-IL Regulatory Options
                    Excluding Facilities with Less than 1 Million Pounds per Year Total
                    Production and Less than 255,000 Pounds per Year Shop and Printer
                    Towel/Rag Production	9-36

10-1                Incremental Energy Consumption Increases Associated With
                    Implementation of the CP-IL and DAF-IL Regulatory Options  ....  10-3

10-2                Fugitive Air Emissions of Organic Pollutants From Industrial Laundry
                    Wastewater—Analysis of a Worst-Case Scenario	  10-6

10-3                Incremental Sludge Generation Increases Associated With Implementation
                    of the CP-IL and DAF-IL Regulatory Options 	  10-9

11-1                Capital Unit Costs Used by the Cost Model  	  11-6

11-2                Components of Total Capital Investment 	  11-9

11-3                Operation and Maintenance Unit Costs Used by the Cost Model ... 11-11

11-4                Components of Total Capital Investment Estimated for DAF Facilities
                    in the CP-IL Regulatory Option  	 11-14
                                         xiv

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                           LIST OF TABLES (Continued)

                                                                               Page


11-5                Summary of Engineering Costs for the Regulatory Options	  11-32

11-6                Summary of Annualized Engineering Costs for the Regulatory
                   Options 	  11-33

11-7                Capital and Annual O&M Compliance Cost Comparison Between the
                   Costs Estimated at Proposal and Costs Incorporating UTSA/TRSA
                   Survey Data for the DAF-IL and CP-IL Regulatory Options Excluding
                   Facilities with Less than 1 Million Pounds per Year Total Production and
                   Less than 255,000 Pounds per Year Shop and Printer Towel/Rag
                   Production	  11-35
                                        xv

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                                  LIST OF FIGURES

                                                                                   Page


4-1                 Geographic Distribution of Industrial Laundry Facilities	4-3

5-1                 Distribution of Facilities by Production Normalized Laundry Process
                    Water Use  	5-6

5-2                 Distribution of Facilities by Production Normalized Laundry Process
                    Water Discharge	 5-11

6-1                 Environmental Management Options Hierarchy  	6-2

6-2                 Shaker Screen 	6-23

6-3                 Batch Chemical Emulsion Breaking Unit 	6-26

6-4                 Continuous CEB Unit with Coalescing Plates	6-28

6-5                 Batch Chemical Precipitation System  	6-30

6-6                 Continuous Chemical Precipitation System	6-31

6-7                 Dissolved Air Flotation Unit	6-34

6-8                 Rotary Vacuum Filter	6-36

6-9                 Filter Press	6-37

6-10                Fixed Bed Activated Carbon Adsorption Column	6-44

8-1                 CEB-Heavy Option:  Chemical Emulsion Breaking of Heavy
                    Industrial Laundry Wastewater	8-6

8-2                 DAF-Heavy, DAF-IL, and DAF-TWL Options:  Dissolved Air
                    Flotation of a Portion of a Facility's Process Wastewater  	8-7

8-3                 CP-Heavy, CP-IL, and CP-TWL Options: Chemical Precipitation
                    of a Portion of a Facility's Process Wastewater	8-8

8-4                 DAF-A11 Option:  Dissolved Air Flotation of Total Facility Process
                    Wastewater  	8-9
                                          xvi

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                           LIST OF FIGURES (Continued)

                                                                                Page
8-5                 CP-A11 Option: Chemical Precipitation of Total Facility Process
                    Wastewater  	  8-10

8-6                 OC-Only Option: In-Process Organics Control  	  8-11
                                         xvn

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                                                                              Chapter 1 - Summary
                                       CHAPTER 1

                                       SUMMARY

1.1           Introduction

              This chapter presents a summary of the U.S. Environmental Protection Agency's
(EPA's) decisions regarding effluent limitations guidelines and standards for the Industrial
Laundries Point Source Category.  Section  1.2 presents the scope and definition of the industry;
Section 1.3 presents a brief overview of the industry; and Section 1.4 discusses EPA's final
action.

1.2           Scope and Definition of the Industrial Laundries Industry

              EPA has developed the following definition of industrial laundries:

                     An industrial laundry is any facility that launders industrial textile items
                     from off site as a business activity (i.e., launders industrial textile items for
                     other business entities for a fee or through a cooperative arrangement).
                     Either the industrial laundry facility or the off-site customer may own the
                     industrial textile  items. This definition includes textile rental companies
                     that  perform laundering operations. Laundering means washing with
                     water, including  water washing following dry cleaning. Laundering
                     exclusively through dry cleaning and oil cleaning of mops in a process that
                     does not use any water are not included in this definition of laundering.
                     Industrial textile items include, but are not limited to: industrial shop
                     towels, printer towels/rags, furniture towels, rags, uniforms, mops, mats,
                     rugs, tool covers, fender covers, dust-control items, gloves, buffing pads,
                     absorbents, and filters. If any of these items are used at  hotels, hospitals,
                     or restaurants, they are not  considered industrial textile items.

              A facility that performs any laundering of industrial textile items is classified as an
industrial laundry, even if the facility also performs activities that are not defined as industrial
laundering.  EPA does not include the following activities within the scope of the industrial
laundries industry: on-site laundering at industrial  facilities (e.g.,  a chemical manufacturer that
washes employee uniforms on site), laundering of industrial textile items originating from the
same business entity (e.g., a chain of auto repair shops that operates a central laundry for items
from individual shops), and exclusively laundering linen items, denim prewash items, clean room
items, new items (i.e., items directly from the textile manufacturer, not yet used for their intended
purpose), hotel, hospital,  or restaurant items, or any combination of these items. However, EPA
does consider hotels, hospitals, and restaurants to be within the scope of the industrial laundries
industry if they launder industrial textile items originating from industrial facilities.  Linen items
include sheets, pillowcases, blankets, bath towels and washcloths, hospital gowns and robes,
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                                                                             Chapter 1 - Summary
tablecloths, napkins, tableskirts, kitchen textile items, continuous roll towels, laboratory coats,
household laundry (such as clothes, but not industrial uniforms), executive wear, mattress pads,
incontinence pads, and diapers (this list is meant to be all-inclusive).

1.3           Overview of the Industrial Laundries Industry

              The industrial laundries industry includes facilities that launder industrial garments
and uniforms, shop towels, printer towels/rags, mops, mats, and dust-control items.  Either the
laundry facilities or their customers own the laundered items.  Many industrial laundries also wash
other items not classified as industrial laundry items, such as linen garments, linen flatwork,
health-care items, and miscellaneous other  items.

              Industrial laundries are located in all 50 states and all 10 EPA Regions. By state,
the largest number of laundries are located  in California. By EPA Region, the largest
concentration of laundries is in Region V.  Most of the laundering facilities are situated in large
urban areas. EPA estimates that there are 1,742 industrial laundry facilities nationwide.

              Industrial laundries vary in  size from one- to two-person shops to large
corporations that operate many facilities nationwide. The industry shows a correspondingly wide
range of annual laundry production.  Facilities laundering more than 15,000,000 pounds per year
account for approximately eight percent of the total industry, whereas facilities laundering less
than 3,000,000 pounds per year account for approximately  37 percent of the total industry.
Approximately 10 percent of the facilities that meet EPA's definition of an industrial laundry
launder less than  1,000,000 pounds per year.

              Facilities wash most items using a water-washing process. Water washing involves
washing items in water with detergents and other chemicals. Some facilities wash items using a
dry-cleaning process, which involves washing items in an organic solvent. In some cases, facilities
combine the two processes to wash items that have large amounts of both water-soluble and
organic solvent-soluble soils.  Dry cleaning followed by water washing of industrial textile items is
considered an industrial laundry process.  When water washing and dry cleaning are performed in
series without drying the items between the water and solvent phases, the process is called dual-
phase washing.  The order in which these processes are performed depends on the solvent used,
type of soil, and drying energy requirements.  Some mops are laundered through a combination of
water washing and oil treatment. The oil is applied to the mop to help collect dust during use.
Both dual-phase washing of industrial textile  items and water-washing/oil treatment of mops are
considered industrial laundry processes.

             Nationwide, industrial laundry facilities water-wash nearly 97 percent of their
items.  Approximately one percent of items are dry-cleaned, including items that are dry-cleaned
and then water-washed. Dual-phase washing and mop cleaning with water and oil each accounts
for less than one percent of the total production. The remaining laundry items are processed
using other cleaning operations (e.g.,  oil cleaning of mops in a process that does not use any
water).  Chemicals frequently used in laundering operations include alkaline solutions, detergents,
bleach, antichlor, sours, softeners, and starch. Other items  that are added to  some

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                                                                             Chapter 1 - Summary
wash formulas include enzymes, builders, oil treatment chemicals, water conditioners, dyes, stain
treatment chemicals, and bactericides.

              Based on data collected by EPA for the 1993 operating year, industrial laundries
use over 90 percent of all incoming service water as laundry process water, followed in
descending amounts by sanitary water, noncontact cooling water, and boiler water.  All of the
industrial laundries identified by EPA discharge their process wastewater to publicly owned
treatment works (POTWs). The primary pollutants discharged by industrial laundries to POTWs
include oil and grease, five-day biochemical oxygen demand (BOD5), and total suspended solids
(TSS), which are conventional pollutants, and a number of priority and nonconventional
pollutants, including copper, lead, zinc, ethylbenzene, toluene, and total petroleum hydrocarbons
(TPH), measured as silica gel treated-hexane extractable material (SGT-HEM)1.

1.4           Final Action for the Industrial Laundries Point Source Category

              EPA carefully considered all of the information in the Industrial Laundries
Administrative Record, and has decided not to promulgate national categorical  pretreatment
standards for the Industrial Laundries Point Source Category because industrial laundry
discharges to POTWs do not present a national problem warranting national regulation. EPA has
determined that indirect discharges from industrial laundries do not warrant national regulation
because of the small amount of pollutants removed by the pretreatment options determined to be
economically achievable and because EPA believes that POTWs are generally not experiencing
problems from industrial laundry discharges, and to the extent that isolated problem discharges
occur, they will be controlled by the existing pretreatment program.  EPA is not issuing effluent
limitations guidelines or new source performance standards for direct dischargers because there
are no direct discharging facilities in the industry and, therefore, EPA has no means to evaluate
performance and develop guidelines.

              Although EPA has decided not to promulgate national pretreatment standards,
EPA evaluated technology performance data that can be used by control authorities to develop
local limits on a best professional judgement (BPJ) basis.  These data can be found in Chapter 7 of
this document.
       ^GT-HEM is measured by Method 1664 (promulgated at 64 FR 26315; May 14, 1999). In this method, EPA
defines SGT-HEM as non-polar material (NPM). Throughout this document and the Industrial Laundries
Administrative Record, EPA refers to SGT-HEM as TPH.

                                            1-3

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                                                                           Chapter 2 - Background

2.0           BACKGROUND

2.1           Introduction

              This chapter presents background information supporting the development of
effluent limitations guidelines and pretreatment standards for the Industrial Laundries Point
Source Category. Section 2.2 presents the legal authority to regulate the industrial laundries
industry. Section 2.3 discusses the Clean Water Act, the Pollution Prevention Act, and the
Regulatory Flexibility Act as amended by the Small Business Regulatory Enforcement Fairness
Act, as well as prior regulation of the industrial laundries industry.

2.2           Legal Authority

              This final action for the Industrial Laundries Point Source Category is being
performed under authority of sections 301, 304, 306, 307, 308, and 501 of the Clean Water Act
(the Federal Water Pollution Control  Act Amendments of 1972, 33 U.S.C. 1251 et seq.. as
amended), also referred to as "the CWA" or "the Act."

2.3           Background

2.3.1          Clean Water Act (CWA)

              The Clean Water Act (CWA) established a comprehensive program to "restore and
maintain the chemical, physical, and biological integrity of the Nation's waters" (section 101(a)).
To implement the Act, EPA is to issue effluent limitations guidelines, pretreatment standards, and
new source performance standards for industrial dischargers.

              These guidelines and standards are summarized briefly below:

              1.    Best Practicable Control Technology Currently Available (BPT) (section
                    304(b)(l)  of the Act).

                    BPT effluent limitations guidelines are generally based on the  average of
                    the best existing performance by plants of various sizes, ages,  and unit
                    processes within the category or subcategory for control of pollutants.

                    In establishing BPT effluent limitations guidelines, EPA considers the total
                    cost of achieving effluent reductions in relation to the effluent reduction
                    benefits, the age of equipment and facilities involved, the processes
                    employed, process changes required, engineering aspects of the control
                    technologies, non-water quality environmental  impacts (including energy
                    requirements) and other factors as the EPA Administrator deems
                    appropriate (section 304(b)(l)(B) of the Act).  The Agency considers the
                    category- or subcategory-wide cost of applying the technology in relation
                    to the effluent reduction benefits. Where existing performance is
                                           2-1

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                                                             Chapter 2 - Background

       uniformly inadequate, BPT may be transferred from a different
       subcategory or category.

2.      Best Available Technology Economically Achievable (BAT) (sections
       304(b)(2)(B) and 307(a)(2) of the Act).

       In general, BAT effluent limitations represent the best existing
       economically achievable performance of plants in the industrial subcategory
       or category.  The Act establishes BAT as the principal national means of
       controlling the direct discharge of priority pollutants and nonconventional
       pollutants to navigable waters.  The factors considered in assessing BAT
       include the age of equipment and facilities involved, the process employed,
       potential process changes, and non-water quality environmental impacts,
       including energy requirements (section 304(b)(2)(B)).  The Agency retains
       considerable discretion in assigning the weight to be accorded these
       factors.  As with BPT, where existing performance is uniformly inadequate,
       BAT may be transferred from a different subcategory or category. BAT
       may include process changes or internal controls, even when these
       technologies are not common industry practice.

3.      Best Conventional Pollutant Control Technology (BCT) (section
       301(b)(2)(e)oftheAct).

       The 1977 Amendments added section 301(b)(2)(E) to the Act establishing
       BCT for discharges of conventional pollutants from existing industrial
       point sources. Section 304(a)(4) designated the following as conventional
       pollutants: biochemical oxygen demanding pollutants (BOD), total
       suspended solids (TSS), fecal coliform, pH, and any additional pollutants
       defined by the Administrator as conventional. The Administrator
       designated oil and grease as an additional conventional pollutant on July
       30,  1979 (44 FR 44501).

       BCT is not an additional limitation, but replaces BAT for the control of
       conventional pollutants.  In addition to other factors specified in section
       304(b)(4)(B), the Act requires that BCT limitations be established in light
       of a two-part "cost-reasonableness" test. [American Paper Institute v.
       EPA. 660 F.2d 954 (4th Cir.  1981)]. EPA's current methodology for the
       general development of BCT limitations was issued in 1986 (51 FR 24974;
       July 9, 1986).

4.      New Source Performance Standards (NSPS) (section 306 of the Act).

       NSPS are based on the best available demonstrated treatment technology.
       New plants have the opportunity to install the best and most efficient
       production processes and wastewater treatment technologies.  As a result,
                             2-2

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                                                                          Chapter 2 - Background

NSPS should represent the most stringent numerical values attainable through the application of
the best available demonstrated control technology for all pollutants (i.e., conventional,
nonconventional, and priority pollutants).  In establishing NSPS, EPA is directed to take into
consideration the cost of achieving the effluent reduction and any non-water quality environmental
impacts and energy requirements.

              5.     Pretreatment Standards for Existing Sources (PSES) (section 307(b) of the
                    Act).

                    PSES are designed to prevent the discharge of pollutants that pass through,
                    interfere with, or are otherwise incompatible with the operation of publicly
                    owned treatment works  (POTWs). The Act requires pretreatment
                    standards for pollutants that pass through POTWs or interfere with
                    POTWs' treatment processes or sludge disposal methods. The legislative
                    history of the 1977 Act indicates that pretreatment standards are to be
                    technology-based and analogous to the BAT effluent limitations guidelines
                    for removal of toxic pollutants.  For the purpose of determining whether to
                    promulgate national category-wide pretreatment standards, EPA generally
                    determines that there is pass through of a pollutant if the nationwide
                    average percent of a pollutant removed by well-operated POTWs achieving
                    secondary treatment is less than the percent removed by the BAT model
                    treatment system. EPA  retains discretion not to issue such standards
                    where the total amount of pollutants passing through is not significant.

                    The General Pretreatment Regulations, which set forth the framework for
                    the implementation  of categorical pretreatment standards, are found at 40
                    CFR Part 403. Those regulations contain a definition of pass through that
                    addresses localized rather than national instances of pass through and does
                    not use the percent removal comparison test described above (52 FR 1586;
                    January 14,  1987).

              6.     Pretreatment Standards for New Sources (PSNS) (section 307(b) of the
                    Act).

                    Like PSES,  PSNS are designed to prevent the discharges of pollutants that
                    pass through, interfere with, or are otherwise incompatible with the
                    operation of POTWs. PSNS are to be issued at the same time as NSPS.
                    New indirect dischargers, like the new direct dischargers, have the
                    opportunity to incorporate into their plants the best available demonstrated
                    technologies. The Agency considers the same factors in promulgating
                    PSNS as it considers in promulgating NSPS. EPA retains discretion not to
                    issue such standards where the total  amount of pollutants passing through
                    is not significant.

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                                                                           Chapter 2 - Background

2.3.2         Pollution Prevention Act (PPA)

              In the Pollution Prevention Act of 1990 (42 U.S.C. 13101 et secu, Pub.L. 101-508,
November 5, 1990), Congress declared pollution prevention to be the national policy of the
United States. The Act declares that pollution should be prevented or reduced whenever feasible;
where the generation of waste materials cannot be prevented, the waste materials should be
recycled or reused in an environmentally safe manner wherever feasible; waste materials that
cannot be recycled should be treated; and disposal or release into the environment should be
chosen only as a last resort. The PPA directs the Agency to, among other things, "review
regulations of the Agency prior and subsequent to their proposal to determine their effect on
source reduction" (Sec. 6604; 42 U.S.C. 13103(b)(2)).  EPA considered pollution prevention
during the development of this final action. Chapter 6 of this document describes the results of
this effort.

2.3.3         Regulatory Flexibility Act (RFA) as Amended by the Small Business
              Regulatory Enforcement Fairness Act of 1996 (SBREFA)

              Under the Regulatory Flexibility Act (RFA), 5 U.S. C. 601 et seq.. as amended by
the Small  Business Regulatory Enforcement Fairness Act (SBREFA), EPA generally is required
to conduct a regulatory flexibility analysis describing the impact of the regulatory action on small
entities as part of rulemaking.  EPA conducted an  initial regulatory flexibility analysis (IRFA) for
the proposal (62 FR 66181; December 17, 1997) for the industrial laundries industry. However,
under section 605(b) of the RFA, if EPA certifies that a rule will not have a significant economic
impact on a substantial number of small entities, EPA is not required to prepare a regulatory
flexibility analysis.  Because the Administrator has decided not to promulgate pretreatment
standards  for this industry, EPA did not prepare a final regulatory flexibility analysis because the
requirement in section 604 of the RFA to prepare a regulatory flexibility analysis when an agency
promulgates a final rule does not apply to this action.

              However, as part of EPA's decision not to promulgate pretreatment standards for
this industry, EPA conducted an analysis equivalent to a regulatory flexibility analysis addressing:

              •      The need for, objectives of, and legal basis for a rule.

              •      A description of, and where feasible, an estimate of the number of small
                     entities to which a rule would apply.

              •      The projected reporting, recordkeeping, and other compliance
                     requirements of a rule, including an estimate of the classes of small entities
                     that would be subject to a rule and the types of professional skills necessary
                     for preparation of the report or record.

              •      An identification, where practicable, of all relevant federal rules which may
                     duplicate, overlap, or conflict with a rule.
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                                                                           Chapter 2 - Background

              •       A description of any significant regulatory alternatives to a rule which
                     accomplish the stated objectives of applicable statutes and which minimize
                     any significant economic impact of a rule on small entities. Consistent with
                     the stated objectives of the CWA, the analysis discussed significant
                     alternatives such as:

                     -     Establishing differing compliance or reporting requirements or
                           timetables that take into account the resources available to small
                           entities.

                     -     Clarification, consolidation, or simplification of compliance and
                           reporting requirements under the rule for such small entities.

                           The use of performance rather than design standards.

                           An exclusion from coverage of a rule, or any part thereof, for such
                           small entities. Based on the regulatory flexibility analysis and other
                           factors, EPA considered an exclusion to eliminate disproportionate
                           impacts on small businesses which reduced the number of small
                           businesses that would be affected by a rule.

              Pursuant to the RFA as amended by SBREFA, EPA convened a Small Business
Advocacy Review Panel.  The Panel comprised representatives from three federal agencies: EPA,
the Small Business Administration,  and the Office of Management and Budget.  The Panel
reviewed materials EPA prepared in connection with the IRFA, and collected the advice and
recommendations of small entity representatives.  Small entity representatives included owners of
small industrial laundries and trade  association representatives. The Panel prepared a report
(available in the Industrial Laundries Administrative Record) that summarizes their outreach to
small entities and the comments submitted by the small entity representatives.  The Panel's report
also presented their findings on issues related to the elements of the IRFA.

2.3.4         Prior Regulation of the Industrial Laundries Point Source Category

              The Federal Water Pollution Control Act Amendments of 1972 established a
program to clean up the nation's waters that consisted of, along with other requirements, a
program of establishing technology-based effluent limitations guidelines for point source
dischargers by industry categories and a timetable for issuing these guidelines. Pursuant to a 1976
settlement agreement and the 1977 Clean Water Act Amendments, EPA was required to develop
a program and adhere to a schedule  in promulgating effluent limitations guidelines and
pretreatment standards for 65 "toxic" pollutants and classes of pollutants, for 21  major industries.
Moreover, the Agency is required by  section 301 (d) of the Federal Water Pollution Control Act
Amendments of 1972 and the Clean Water Act of 1977 to review and revise, if necessary, effluent
limitations promulgated pursuant to sections 301, 304, 306, 307, 308, and 501 of the Act.
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                                                                         Chapter 2 - Background

              The Auto and Other Laundries Category, of which industrial laundries was a
subcategory, was one of the categories mandated for study and possible effluent limitations
guidelines and standards development by the 1976 Settlement Agreement.  Several studies were
undertaken in 1977 through 1980 to collect more information about the industrial laundries
industry, including two surveys (1977 and 1979) and wastewater sampling and analysis programs
conducted in 1978. However,  in 1981, the Auto and Other Laundries Category, including the
industrial laundries subcategory, was excluded from regulation.  The industrial laundries
subcategory was excluded because, based on assessments made at that time, it was determined
that 95 percent of the industry  discharged pollutants that could be treated by POTWs and that did
not pass through, interfere with, or otherwise prove incompatible with the operation of POTWs.

              However, following these assessments, additional data were collected by the
Industrial Technology Division (ITD - now Engineering and Analysis Division (BAD)) as part of
work efforts in conjunction with EPA's Office of Solid Waste's Resource Conservation and
Recovery Act (RCRA) Program in 1985 through 1987. In 1986, EPA published its Domestic
Sewage Study (DSS), which identified industrial laundries as potential contributors of large
amounts of hazardous pollutants to the POTWs. Based on information gathered to that point,
EPA compiled a profile of the industrial laundries industry that was published as a Preliminary
Data Summary in  1989.

              Section 304(m) of the Clean Water Act (33 U.S.C. 1314(m)), added by the Water
Quality Act of 1987, requires EPA to establish schedules for (i) reviewing and revising existing
effluent limitations guidelines and standards ("effluent guidelines"), and (ii) promulgating new
effluent guidelines. On January 2, 1990, EPA published an Effluent Guidelines Plan (55 FR 80),
in which schedules were established for developing new and revised effluent guidelines for several
industrial categories.  In addition, the plan listed several industrial categories that were to be
studied to determine whether rulemakings to develop effluent guidelines and standards should be
initiated. One of those categories was the Industrial Laundries Point Source Category, based on
the results of the 1985 to 1987 work contained in the DSS.

             Natural Resources Defense Council, Inc. (NRDC) and Public Citizen, Inc.
challenged the Effluent Guidelines Plan in a  suit filed in U.S. District Court for the District of
Columbia rNRDC et al. v. Reilly. Civ. No. 89-2980).  The plaintiffs charged that EPA's plan did
not meet the requirements of section 304(m). A Consent Decree (the "304(m) Decree") in this
litigation was entered by the Court on January 31, 1992 (57 FR 19748), which established
schedules for, among other things, EPA's proposal and promulgation of effluent guidelines for a
number of categories, including the Industrial Laundries Point Source Category. The Effluent
Guidelines Plan update published on February 26, 1997 (62 FR 8726) required, among other
things, that EPA propose effluent limitations guidelines and pretreatment standards for the
Industrial Laundries Point Source Category by September 1997 and take final action by June
1999.  Further modification of the Decree in August 1997 set the proposal date no later than
November 7, 1997.

              On December 17, 1997 (62 FR 66181), EPA published proposed pretreatment
standards for the control of wastewater pollutants  from the industrial laundries industry. EPA
published a notice of data availability (NODA) on December 23, 1998 (63 FR 71054).  The

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                                                                           Chapter 2 - Background

NODA presented a summary of the data gathered or received from commenters since the
proposal, an assessment of the usefulness of the data in EPA's analyses, and a discussion of a
voluntary industry program submitted by the industry as part of comments on the proposal.
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                                                  Chapter 3 - Data Collection Methodology and Information Sources

                                      CHAPTER 3

      DATA COLLECTION METHODOLOGY AND INFORMATION SOURCES

3.1           Introduction

              In 1992, EPA published a notice in the Federal Register (57 FR 19748) indicating
its intent to develop effluent limitations guidelines and standards for the Industrial Laundries Point
Source Category. EPA collected information necessary for the development of these effluent
guidelines and standards from many sources.  EPA initially collected data on a broad group of
laundry facilities that included industrial laundries as well as linen laundries, denim prewash
facilities, and other laundry facilities. These data were necessary to define the scope of the
industry. Throughout this chapter, the term "laundry" is used to indicate that information was
collected from industrial laundries as well as other laundry  facilities, such as facilities that launder
only linen items.

              On December 17, 1997 (62  FR 66181), EPA published proposed pretreatment
standards for the Industrial Laundries Point Source Category, based on EPA's data collection
efforts.  In response to this proposal, EPA obtained data from industry and  publicly  owned
treatment works (POTWs), which were described in the Notice of Data Availability (NOD A)
published on December 23, 1998 (63 FR 71054). EPA received additional data from industry and
POTWs in comments on the NODA.

              This chapter summarizes the information collection activities undertaken and the
information sources used to develop the final action for the Industrial Laundries Point Source
Category, as presented below:

              •     Section 3.2 summarizes data collection efforts prior  to 1992;

              •     Section 3.3 discusses the questionnaire activities conducted after 1992;

              •     Section 3.4 summarizes EPA's site visit program conducted from 1993
                    through 1998;

              •     Section 3.5 discusses EPA's sampling program conducted from 1993
                    through 1998;

              •     Section 3.6 discusses EPA's Method 1664 Characterization Study;

              •     Section 3.7 presents  other industry-supplied data;

              •     Section 3.8 discusses data collected from POTWs;

              •     Section 3.9 summarizes literature searches performed on the industrial
                    laundries industry;
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              •       Section 3.10 summarizes other sources of data on the industrial laundries
                     industry; and

              •       Section 3.11 presents the references used in this chapter.

3.2           Summary of Data Collection Prior to 1992

              Prior to 1992, EPA conducted several studies  of the laundries industry. These
efforts consisted of the following:

              •       The 1971 EPA survey of 160 industrial laundries, linen services, and diaper
                     services (Section 3.2.1);

              •       The 1975 data collection at 73 facilities (Section 3.2.2);

              •       The 1977 data collection portfolio (DCP) for approximately 70 facilities
                     (Section 3.2.3);

              •       The 1978 screening and verification analysis of samples from
                     approximately 10 facilities for priority pollutants (Section 3.2.4);

              •       The 1979 laundries survey (Section 3.2.5); and

              •       The 1985 through 1987 Industrial Technology Division (ITD)/Resource
                     Conservation and Recovery Act (RCRA) sampling program and
                     development of the Preliminary Data Summary for the Industrial Laundries
                     Industry (1) (Section 3.2.6).

              Sections 3.2.1 through 3.2.6 describe each of these data-gathering efforts in more
detail.

3.2.1          1971 Survey

              EPA's first study of the industrial laundries industry, initiated in 1971, involved
sending a survey to 160 facilities. These facilities were all members of the Institute of Industrial
Launderers (IIL, now the Uniform and Textile Service Association (UTSA)) or the Linen Supply
Association of America (LSAA, now the Textile Rental Services Association of America
(TRSA)) and included industrial laundries, linen services, and diaper services. In addition to
wastewater analytical data obtained from the survey, EPA analyzed wastewater samples  it had
collected at a small number of facilities for conventional and nonconventional pollutants  and some
metals.

3.2.2          1975 Data Collection

              In 1975, EPA initiated sampling  and analysis of wastewaters generated by the
Auto and Other Laundries Point Source Category, of which the industrial laundries industry was

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identified as a subcategory.  These early programs concentrated primarily on collecting data on
conventional and nonconventional pollutants and trace metals. EPA collected samples at 73
laundries for conventional pollutants (pH, biochemical oxygen demand (BOD5), total suspended
solids (TSS), and oil and grease) and nonconventional pollutants (chemical oxygen demand
(COD), total organic carbon (TOC), and phosphorus).

3.2.3          1977 Data Collection Portfolio (DCP)

              In 1977, EPA sent a data collection portfolio (DCP) to a number of laundry
facilities including industrial laundries (SIC Code 7218), power laundries (SIC Code 7211), linen
supply laundries (SIC Code 7213), and institutional laundries. Completed DCPs were received
from approximately 70 industrial laundries. The survey requested the following types of
information:

              •      Type of laundry;

              •      Number of hours/day and days/year of operation and number of employees;

              •      Types of processes;

              •      Production information;

              •      Types of customers serviced;

              •      Laundering chemicals used;

              •      Water usage;

              •      Effluent discharge;

              •      Information on wastewater treatment and in-plant controls;

              •      Recommendations for design features;

              •      Space available for treatment;

              •      Available priority pollutant data; and

              •      Unique features.

3.2.4          1978 Sampling Program

              In 1978, EPA initiated a sampling program to determine the presence and
concentrations of 129 priority pollutants, which were identified from the 65 toxic pollutants and
classes of pollutants (and subsequently reduced to 126 priority pollutants), as defined by the
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1976 Consent Decree (see Section 2.3.4 of this document for discussion of the Consent Decree),
in wastewaters from facilities in the Auto and Other Laundries Point Source Category.  EPA
sampled a total of 40 facilities for toxic and conventional pollutants using automatic time-
compositing equipment during operating hours at each facility. In most cases, sampling was for
one day only. At facilities where wastewater treatment was in place, EPA collected samples of
both treatment system influent and effluent.  Over a one-month period, EPA also sampled an
industrial laundry that used a dissolved air flotation (DAF) treatment system to obtain data on the
variability of treatment efficiency for this type of technology.

3.2.5          1979 Laundries Survey

              In 1979, EPA sent a survey to 31 industrial laundries and 14 linen laundries in five
major cities to determine the availability of sufficient space for installation of treatment  systems.
Approximately 50 percent of the survey dealt specifically with available space at facilities without
treatment. Other information obtained included:

              •      Business classification;

              •      Number of hours/day and days/year of operation and number of employees;

              •      Processes used;

              •      Production information;

              •      Water usage;

              •      Effluent discharge;

              •      In-plant controls used; and

              •      Wastewater treatment practiced.

              EPA conducted the Industrial Technology Division (ITD)/Resource Conservation
and Recovery Act (RCRA) Sampling Program and the Preliminary Data Study in response to a
recommendation made in the Domestic Sewage Study and because of concern for the potential
discharge of toxic pollutants. In 1981, EPA decided not to establish effluent limitations guidelines
and standards for the Auto and Other Laundries Point Source Category, of which industrial
laundries were a subcategory, because EPA  determined that 95 percent of the discharged
pollutants were amenable to treatment by POTWs and did not pass through, interfere with, or
prove otherwise incompatible with the operation of POTWs. Therefore, no further data
collection efforts were undertaken until 1985.
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3.2.6          Industrial Technology Division (ITD)/Resource Conservation and Recovery
              Act (RCRA) Sampling Program and Development of the Preliminary Data
              Summary (1985 through 1987)

              EPA conducted a program to obtain wastewater and solid waste samples at five
industrial laundries located in different regions of the U.S. EPA used information obtained during
previous data-gathering efforts in conjunction with advice and assistance from the UTSA (known
as the Institute of Industrial Launderers (IIL) at the time) to select seven laundries for site visits.
Four of these facilities were sampled in 1986 and 1987.  The fifth facility was sampled in 1985 as
part of the Domestic Sewage Study (discussed in Section 3.10.3 of this document).

              At the industrial laundry sampled in 1985, EPA collected composite samples of the
final effluent from a settling basin over the course of one operating day. EPA collected samples
of untreated wastewater streams and final effluent at the four other industrial laundry facilities.
EPA sampled these four facilities for two consecutive days and composited the wastewater over
the course of each operating day.  EPA collected final effluent samples from two DAF systems,
one ultrafiltration system, and a settling basin.

              EPA analyzed the samples for conventional pollutants, priority and
nonconventional organic pollutants, metal pollutants, and other nonconventional pollutants.

              Other EPA activities to collect information about the industrial laundries industry
investigated during this time period included:

              •       Telephone interviews with, and visits to, personnel at EPA regional and
                     state offices, industry trade associations, and representative industrial
                     laundries;

              •       Telephone interviews with POTW representatives;  and

              •       Literature review, including research reports, journals and magazines,
                     computer-based abstract databases, and computer-based censuses.

The information collected during 1985 to 1987 was used to prepare the Preliminary Data
Summary for the Industrial Laundries Industry (1) and formed the basis for EPA's decision to
initiate work on effluent limitations guidelines and standards for the Industrial Laundries Point
Source Category in 1992.

3.3            Summary of Industrial Laundries Questionnaire Activity After 1992

              EPA's first step in developing a rule for the industrial laundries industry was to
gather current data from the industry, under the authority of section 308 of the Clean Water  Act.
EPA conducted a screener survey by sending questionnaires to four different segments of the
laundry industry between 1993 and 1995. The screener questionnaires requested information to
be used in identifying the population of the laundry industry, developing the scope of the
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regulation, and determining which facilities should receive a more detailed questionnaire.  Based
on data collected from the screener survey and a search of the Dun & Bradstreet listing for
laundry facilities, EPA identified a representative subset of laundries to receive a detailed
questionnaire. Based on the responses to this detailed questionnaire, EPA sent an additional
questionnaire to a subset of the facilities that had received the detailed questionnaire to obtain
effluent monitoring data. These data-gathering efforts are described in more detail below.
Additional details on the data-gathering efforts are also contained in the Statistical Support
Document for Proposed Pretreatment Standards for Existing and New  Sources for the Industrial
Laundries Point Source  Category (2).  Copies of completed nonconfidential questionnaire
responses are contained  in the Industrial Laundries Administrative Record.

3.3.1          Screener Questionnaires

              EPA conducted four separate mailings of slightly different screener questionnaires
to collect data it could use to define the scope of the industrial laundries industry, identify the
population of the industry, and select facilities to receive the more detailed questionnaire.  EPA
also used the screener questionnaires to characterize the industry and to determine the size of the
industrial laundries population. More details on determining the industrial laundries population
are provided in the Statistical Support Document (2).  Summarized  industry characterization data
are provided in Chapters 4, 5, and 6 of this document. The four different screener questionnaires
and their mailings are discussed in the following sections.

3.3.1.1        The 1993 Industrial Laundries Industry Screener Questionnaire

              In 1993, EPA developed  and mailed out the two-page 1993 Industrial Laundries
Industry  Screener Questionnaire to 1,751 industrial laundries to solicit updated information on the
industry.  The screener questionnaire requested information on the relative amounts and types of
items received for laundering, the type of waste treatment operations, the amount of water used,
and wastewater disposal practices.  A blank copy of the questionnaire, along with copies of the
nonconfidential portions of the completed screener questionnaires, are contained in Section 6.2 of
the Industrial Laundries  Administrative Record.

              EPA sent the screener questionnaire to a total of 1,751 facilities. EPA selected
1,745 of these facilities from the UTSA customer and prospective customer lists, the Textile
Rental Service Association (TRSA) mailing list, and the Occupational Safety and Health
Administration's (OSHA) list of violations for industrial laundries. EPA added six facilities to the
list as a result  of companies requesting screeners for their facilities that had not received one.

              Of the 1,751  screener questionnaires mailed, 1,543 were returned. In addition,
three facilities that were not  on the mailing list received a copy of the screener from their parent
company, and returned the completed copy, bringing  the total of completed screener
questionnaires returned to  1,546.  A summary of the results of the screener questionnaire mailings
is shown in the following table.
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Status of 1993 Screener Questionnaire
Returned
Screener undeliverable or facility known to be out of
scope
Nonresponsive
Duplicate facilities found
Total
Number of Questionnaires
1,546'
86
122
462
1,754
'Three facilities not on the original mailing list completed and returned the questionnaire at the request of their parent
company.
2This number is included in the number of screeners returned.

              EPA received the screener questionnaire responses, reviewed them for
completeness and accuracy, and entered the information into a database.  EPA contacted by
telephone respondents who provided incomplete or contradictory technical information to obtain
correct information.
3.3.1.2
1993 Industrial Laundries Industry Supplemental Screener Questionnaire
              The Dun & Bradstreet listing was used to identify industrial laundries not captured
by the trade association mailing lists developed for the original screener questionnaire. Facilities
listed in Dun & Bradstreet with primary SIC codes of 7218 (industrial laundries) or 7213 (linen
supply laundries) and facilities with secondary SIC codes of 7218 were identified and compared to
the original screener questionnaire mailing list. EPA selected 200 facilities identified from the
Dun & Bradstreet listing to receive the supplemental screener questionnaire to obtain more data
representative of the entire industry as follows:  100 facilities with a primary SIC code of 7218;
60 facilities with a primary SIC code of 7213; and 40 facilities with a secondary SIC  code of
7218. The table below summarizes the results of the supplemental screener questionnaire mailing.
Status of D&B Screener Questionnaires
Returned
Screener undeliverable
Nonresponsive
Total
Number of Questionnaires
134
34
32
200
              EPA received the screener questionnaire responses, reviewed them for
completeness and accuracy, and entered the information into a database.  EPA contacted by
telephone respondents who provided incomplete or contradictory technical information to obtain
correct information.
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3.3.1.3        Large Industrial Laundry Screener

              Abbreviated screener questionnaires were sent to five large industrial laundry
companies to identify facilities owned by these five companies that were not identified from the
original screener questionnaire or the supplemental screener questionnaire.  Abbreviated screener
questionnaires were also sent to four additional facilities that were not included on the mailing list
for the original screener due to lack of address information.  Information from the abbreviated
screener, along with information from the other screener questionnaire, was used to determine the
industrial laundry industry population.

3.3.1.4        1995 Industrial Laundries Industry Screener (On-Site) Questionnaire

              In response to comments from industrial laundry and linen trade associations, EPA
mailed 100 modified screener questionnaires in January 1995 to hospitals, hotels, and prisons that
potentially operate on-site laundries.  These facilities are not traditional industrial laundry
facilities, but generate wastewater from laundering. EPA randomly selected 25 facility addresses
from each of the following four sources:

              •      A list provided by the  TRSA;

              •      A list provided by the  UTS A;

              •      Responses to Question 25 (Q25) in Part B of the 1994 Industrial Laundries
                    Industry Questionnaire; and

              •      National Association of Institutional Linen Management (NAILM)
                    members.

              The 1995 screener questionnaire requested the following information:  discharge
status (i.e., direct, indirect, zero), water use information, amount of laundry accepted from off
site, the amount of total laundry processed, number of employees,  SIC  code, percentage of items
laundered (both generated on site and accepted from off site), and type of treatment system. The
main goal of this effort was to obtain a snapshot of the activities of on-site laundries to determine
if they should be included in the scope of the industrial laundries industry. EPA received 86
responses to the  1995 screener questionnaire.

3.3.2          1994 Industrial Laundries Industry Questionnaire (Detailed Questionnaire)

              EPA designed the 1994 Industrial Laundries Industry Questionnaire (detailed
questionnaire) to collect detailed technical and economic information from industrial laundry and
linen facilities. EPA sent the detailed questionnaire to laundries statistically selected from the
1993 Industrial Laundries Industry  Screener Questionnaire database (screener questionnaire
database) and from the  Dun &  Bradstreet database. Additional information concerning the
selection of facilities to receive the  detailed questionnaire is presented in the Statistical Support
Document (2). EPA used the information reported by the respondents in the detailed
questionnaire to develop an industry profile,  characterize industry production and water use,
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develop pollutant loadings and reduction estimates, and develop compliance cost estimates, as
discussed throughout this document. A blank copy of the detailed questionnaire and copies of the
nonconfidential portions of the completed detailed questionnaires are contained in the Industrial
Laundries Administrative Record.

3.3.2.1        Detailed Questionnaire Recipient Selection and Mailing

              EPA mailed the detailed questionnaire in June and July of 1994 to 250 selected
laundries. EPA selected 24 facilities from the Dun & Bradstreet database and 226 facilities from
the industrial laundries industry screener database. After mailing the questionnaires, EPA
deactivated the questionnaires for one of the selected Dun & Bradstreet facilities and three of the
selected screener questionnaire facilities because they were closed, out of scope, or otherwise
unable to respond to the questionnaire.  EPA replaced these facilities with other facilities not
previously selected. The methods used to select the recipients of the detailed questionnaires are
described in the Statistical Support Document (2). A summary of the results of the mailout of the
254 detailed questionnaires is shown in the following table.
Activity
Mailed detailed questionnaire (four questionnaires were mailed to replace four facilities
determined to be inactive within a few days of the initial mail-out)
Questionnaires received
Questionnaires not received
Questionnaires deactivated (deactivated because facility closed, facility was a pretest
facility, facility destroyed by fire, facility did not generate laundry wastewater, or
otherwise could not provide the necessary information)
Questionnaires with sufficient technical and economic information to perform the
analyses necessary to conduct a final action
Number of Sites
2541
231
23
16
(Not received- 12)
(Received-4)
208
'EPA originally selected 250 recipients of the detailed questionnaire and later selected another four to replace facilities
that had been deactivated.

              In addition, EPA mailed pretest questionnaires to nine facilities in November 1993.
Although not identical, the pretest questionnaire contained questions similar to the questionnaire
mailed in June and July of 1994.  EPA received eight pretest questionnaire responses.

3.3.2.2       Information Collected by the Detailed Questionnaire

              This section describes the information collected in each part of the detailed
questionnaire and the reasons this information was collected. The Information Collection Request
(ICR) (3) for this project contains further details on the types of information collected and the
potential use of the information.

              EPA developed the detailed questionnaire in conjunction with the industrial
laundries trade associations (TRSA and UTS A), EPA's Office of Pollution Prevention and
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Toxics, and EPA's Office of Solid Waste to collect information necessary to develop effluent
limitations guidelines and standards for the industrial laundries industry. EPA sent a draft version
of the questionnaire to nine pretest facilities, and incorporated comments from these facilities into
the final version of the detailed questionnaire.

              The detailed questionnaire comprised the following parts:

              •      Part A: Technical Information
                            Section 1: Facility Identification,
                            Section 2: Operating Information; and
              •      Part B: Financial and Economic Information
                            Section 1: Facility Financial Information,
                            Section 2: Owner Company Financial Information,
                            Section 3: Parent Company Financial Information.

              Part A, Section 1 requested information necessary to identify the site and to
determine wastewater discharge locations (to surface water or POTWs).  The information
requested in this section included site name, address, parent company name, address, site contact,
age of facility, major modifications made to the facility, operating hours and days, permits held by
the facility, and wastewater discharge location.

              Part A, Section 2 was divided into the following subparts:

              •      Process Operations and Production Information;
              •      Water Use and Conservation Practices; and
              •      Wastewater Treatment Operations.

              The section on process operations and production information requested detailed
information on laundering processes, types of items laundered, production of laundered items,
types of customers, laundering formulas, laundering chemicals, laundering equipment, and
pollution reduction activities.  EPA used the information collected in this section to determine the
types and amounts of each item laundered at a facility, the types  of customers a facility has, the
amount of laundering chemicals and water used for laundering each item type, and pollution
reduction practices at laundry facilities.

              The section on water use and conservation practices requested detailed
information on water intake amounts for various uses, water conservation practices in place,
wastewater generation and discharge locations, and a facility process diagram showing a water
balance for the facility and wastewater treatment in place. EPA used this information to evaluate
the overall water use and wastewater discharge for the site.

              The section on wastewater treatment operations requested detailed information on
wastewater treatment operations, costs of wastewater treatment  equipment, wastewater sample
collection, wastewater treatment residual types and generation amounts, costs of residual

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disposal, and space availability at the facility. EPA used this information to evaluate current
treatment in place at industrial laundries and the costs of operating this treatment.

              Part B requested detailed financial and economic information for each site and the
owner companies of each site. Detailed information on this section is presented in the Economic
Assessment for the Final Action Regarding Pretreatment Standards for the Industrial Laundries
Point Source Category (4).

3.3.2.3        Data Review and Data Entry

              EPA completed a detailed engineering review of Part A of the detailed
questionnaires to evaluate the accuracy of information provided by the respondents.  During
engineering review, responses to questions were coded to facilitate data entry into the detailed
questionnaire database. The Data Element Dictionary for the Industrial Laundries Industry
Questionnaire Part A Database (5) contains the codes used by reviewers.  EPA contacted, by
telephone, respondents who provided incomplete or contradictory technical information to obtain
correct information.

              EPA developed a database for the technical information provided by the detailed
questionnaire respondents. After engineering review and coding, data from the detailed
questionnaires were double-key entered using a data entry and verification system.  Reviewers of
the questionnaire verified errors in the double-key entry. EPA entered basic information (i.e.,
name, address, telephone number, etc.) for all 254 facilities into the database.  EPA entered other
information provided by the 231 facilities responding to Part A. EPA also entered the information
for three pretest facilities.

3.3.2.4        Compilation of Respondent Data

              EPA compiled information reported in the detailed questionnaire and summaries of
this information are located in Chapters 4, 5, and 6 of this  document. These chapters include
information on facility location, process and production information, water use and discharge
practices, and wastewater characteristics and treatment.

3.3.3         Detailed Monitoring Questionnaire

              In  1995, EPA mailed a detailed monitoring questionnaire (DMQ) to 37 industrial
laundries that had received the detailed questionnaire in 1994.  After reviewing responses to the
detailed questionnaire, EPA identified facilities with available monitoring data that could be used
to identify effluent discharge quality after certain treatment technologies and in conjunction with
laundering certain industrial items.  EPA selected the industrial laundries that would receive the
DMQ based on the following criteria:

              •      Facilities that EPA had sampled;

              •      Facilities with paired monitoring data (i.e., facilities that monitor both
                     influent and effluent pollutant concentrations);


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              •      At least one facility with each technology being considered for inclusion in
                     the treatment technology options; and

              •      Facilities that had no treatment (or that have gravity settling and screens
                     only) to characterize untreated industrial laundry wastewater and current
                     pollutant discharge loadings.

              The DMQ requested that facilities submit analytical data they had reported (but
not submitted) in their detailed questionnaire responses and any additional data that were available
(e.g., raw wastewater data,  POTW data, chemical vendor data, wastewater treatment vendor
data, disposal company data). The facilities were also asked to include a process diagram for
verification of sampling points.  All 37 recipients completed and returned their DMQ.

3.3.3.1        Data Review and Data Entry

              EPA completed a detailed engineering review of the DMQs to evaluate the
accuracy of information provided by the respondents. The engineering review also included
coding of responses to questions to facilitate data entry  into the DMQ database.  The Data
Element Dictionary for the  DMQ Database (6)  contains the codes used by reviewers. EPA
contacted, by telephone, respondents who provided incomplete or contradictory technical
information to obtain correct information.

              EPA developed a database for the technical information provided by the DMQ
respondents.  After engineering  review and coding, data from the DMQ were double-key entered
using a data entry and verification system. Reviewers of the questionnaires verified errors in the
double-key entry. EPA entered  information for all 37 facilities into the DMQ database.

3.3.3.2        Compilation of  Respondent Data

              EPA compiled information reported in the DMQ responses and summarized it in
Chapter 5 of this document, which includes information on wastewater characteristics. DMQ
data were also used to develop summaries reflecting wastewater control technology  performance
for the industrial laundries industry, as presented in Chapter 7 of this document.

3.4           Summary of EPA's Site Visit Program (1993-19981

              EPA conducted 38 site visits to industrial laundries between 1993 and 1998 to
collect information about industrial laundry processes, water use practices, pollution reduction
practices, wastewater treatment technologies, and waste disposal methods. EPA also visited
these sites to evaluate potential sampling locations (as described in Section 3.5 of this document).
EPA visited a range of laundry facilities, such as industrial laundries, linen facilities, hospital
cooperative laundries, clean room facilities, and denim prewash facilities, to collect data it could
use to define the scope of the industry.
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3.4.1          Criteria for Site Visit Selection

              EPA based site selection on information in responses to the screener and detailed
questionnaires and information obtained from the industrial laundries trade associations. In
addition to choosing sites of varying sizes, EPA used the following general criteria to select sites
that encompassed the range of processes and treatment technologies within the industrial
laundries industry:

              •       The site laundered a broad range of industrial textile items;

              •       The site performed specific operations, such as denim prewashing or dry
                     cleaning followed by water washing;

              •       The site had wastewater treatment technologies that were believed to be
                     representative of the "best" within the industry;

              •       The site split heavy and light wastewater streams; and

              •       The site practiced water reuse.

3.4.2          Types of Information Collected

              EPA documented information for each site visit in a site visit report; these reports
are contained in the Industrial Laundries Administrative Record. During the site visits, EPA
collected the following information for each facility:

              •       Types of laundering processes conducted and the types of items laundered,
                     as well as the production volume  of each item;

              •       Types of customers served;

              •       Types and sizes of laundering equipment used;

              •       Types, amounts, and disposition of wastewater generated;

              •       Types of pollution reduction activities performed;

              •       Types of wastewater treatment technologies operated; and

              •       Logistical information for sampling.

3.5           Summary of EPA's Sampling Program (1993-1998)

              EPA conducted sampling episodes at nine facilities between 1993 and 1998 to
obtain data on the characteristics of industrial laundry wastewaters and to assess the following:
the amount of pollutants discharged to POTWs from industrial laundries; the effectiveness of
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technologies designed to reduce and remove pollutants from industrial laundry wastewater; and
the variation of wastewater characteristics across item type.

3.5.1          Criteria for Sampling Site Selection

              EPA used information collected during industrial laundry site visits to identify
candidate sites for sampling. EPA used the following general criteria to select sites for sampling:

              •      The site accepted a variety of items for laundering; and

              •      The site operated in-process source reduction or end-of-pipe treatment
                     technologies that were considered for treatment technology option
                     development.

              After selecting a site for sampling, EPA prepared a detailed sampling and analysis
plan, based on the information obtained during the site visit and follow-up contact with the site.
The sampling and analysis plans were prepared to ensure collection of samples that would be
representative of the sampled waste streams, and contained the following types of information:
site-specific selection criteria for sampling; information about site operations; sampling point
locations and sample collection, preservation,  and transportation procedures; site contacts; and
sampling schedules.

3.5.2          Information Collected

              In addition to wastewater samples, EPA collected the following types of
information during each sampling episode:

              •      Dates and times of sample collection;

              •      Flow data corresponding to  each sample;

              •      Production data corresponding to each wastewater sample;

              •      Design and operating parameters for source reduction and treatment
                     technologies characterized during sampling;

              •      Information about site operations that had changed since the site visit or
                     that was not included in the  site  visit report; and

              •      Temperature and pH of the sampled wastewater  streams.

              EPA documented all data collected during sampling episodes in the Sampling
Episode Report (SER) for each sampled site; these reports are contained in the Industrial
Laundries Administrative Record.  The  sampling episode reports also contain preliminary
technical analyses of treatment system performance.
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3.5.3          Sample Collection and Analysis

              All samples were collected, preserved, and transported according to EPA
protocols as specified in EPA's Sampling and Analysis Procedures for Screening of Industrial
Effluents for Priority Pollutants (7). This document is contained in the Industrial Laundries
Administrative Record.

              In general, EPA collected composite samples from the wastewater streams from
laundering operations over the course of the operating day. Most facilities were sampled for a
consecutive five-day period. For item-specific sampling, EPA collected wastewater samples from
individual laundered loads during each discharge from the washer and composited the samples.
EPA collected the required types of quality control  samples as  described in the Industrial
Laundries Quality Assurance Project Plan (QAPP),  such as blanks and duplicate samples, to verify
the precision and accuracy of sample analyses.

              EPA had samples shipped via overnight air transportation to EPA-approved
laboratories, which analyzed the samples for metal and organic pollutants and additional
parameters (including several water quality parameters).  The laboratories analyzed metal
pollutants using EPA Method  1620 (8), volatile organic pollutants using EPA Method 1624 (9),
and semivolatile organic pollutants using EPA Method 1625 (10). Tables A-l and A-2 in
Appendix A of this document list the metal and organic pollutants, respectively, analyzed using
these methods.  The laboratories analyzed oil and grease and total petroleum hydrocarbon (TPH)
using EPA Method  1664 (11), which is now promulgated at 40 CFR, Part 136. Method 1664
measures oil and grease as n-hexane extractable material  (HEM) and measures TPH as silica gel
treated-hexane extractable material  (SGT-HEM1).  Method 1664 may extract a different fraction
of oil and grease and TPH than is extracted by the fireon methods. The amount extracted by n-
hexane and freon is  dependent upon the composition of oils and grease in the samples. Sludge
samples were analyzed using both the regular wastewater methods and the Toxicity Characteristic
Leaching Procedure (TCLP), using  SW-846, Method 1311 (12). Table A-3 in Appendix A of this
document lists other parameters analyzed during the sampling program and the methods by which
they were analyzed (13, 14).

              Quality control (QC) measures used  in performing all analyses complied with the
guidelines specified  in the analytical methods and in the QAPP. EPA reviewed all analytical data
to ensure that these measures were followed and that the resulting data were within the QAPP-
specified acceptance criteria for accuracy and precision.

              As discussed previously, upon receipt and review of the analytical data for each
site, EPA wrote a sampling episode report (SER) to document the sampling episode, the data
collected during sampling, the analytical results, and the technical analyses of the results. The
SERs include sampling and analysis plans and correspondence with  site personnel as appendices.
'In Method 1664 (promulgated at 64 FR 26315; May 14, 1999), EPA defines SGT-HEM as non-polar material (NPM).
Throughout this document and the Industrial Laundries Administrative Record, EPA refers to SGT-HEM as TPH.

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3.6           Summary of EPA's Method 1664 Characterization Study

              In response to comments on the proposed rule, EPA conducted a characterization
study of wastewater generated at industrial laundries to determine the specific constituents of oil
and grease and TPH, measured using EPA Method 1664. EPA collected influent and effluent
samples from six facilities that operate DAF or chemical precipitation, and were previously
sampled by EPA.

              Samples from the facilities were analyzed for volatile organics by Method 1624,
semivolatile organics by Method 1625, and oil and grease and TPH by Method 1664.  Two
additional oil and grease/TPH aliquots were collected for the Method 1664 characterization study
analysis.  These aliquots were subjected to the Method 1664 oil and grease and TPH analytical
protocols, and the oil and grease and TPH residues were subsequently dissolved  in an appropriate
solvent and analyzed for volatile organics by modified Method 1624 and semivolatile organics by
modified Method 1625. These analyses allow for comparison between the organic constituents
measured in the wastewater and the organic constituents of the fractions measured as oil and
grease and TPH. The analytical protocols prepared by EPA's Sample Control Center (SCC) used
in this characterization study are presented in The Study Plan for Determination of the
Components of n-Hexane Extractable Material (HEM) and  Silica Gel Treated n-Hexane
Extractable Material (SGT-HEM: Non-polar Material) in Discharges from Selected Industrial
Laundry Facilities (15).

              All samples were collected, preserved, and transported according to EPA
protocols as specified in EPA's Sampling and Analysis Procedures  for Screening of Industrial
Effluents for Priority Pollutants (7) and the Industrial Laundries QAPP.  All samples were
preserved on site and shipped via overnight air transportation to the EPA-approved laboratories.

              Quality control (QC) measures used in performing all analyses complied with the
guidelines specified in the analytical methods and in the QAPP. EPA reviewed all analytical data
to ensure that these measures were followed and that the resulting data were within the QAPP-
specified acceptance criteria for accuracy and precision.

              The results and data collected during this study are presented in Chapter 5 of this
document and Section 16.2 of the Industrial Laundries Administrative Record.

3.7           Other Industry-Supplied Data

              The industrial laundry trade associations, the Uniform and Textile Service
Association  (UTSA), and the Textile Rental Services Association (TRSA), as well as individual
laundries and other interested parties, submitted data to be used in the development of the
proposed rule and in the final actionA

3.7.1          Data Submitted Prior to 1992

              In 1977, TRSA sponsored a wastewater study of linen and industrial laundries. In
addition to pH, this study analyzed wastewater for the following 10 pollutants: BOD5, TSS, oil

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                                                 Chapter 3 - Data Collection Methodology and Information Sources

and grease, lead, mercury, nickel, cadmium, zinc, total chromium, and TOC. The two-part study
first analyzed untreated wastewater from 20 laundries and then analyzed untreated and treated
wastewater from five laundries.

              The first part of the study presented sampling and analytical data from 20 linen and
industrial laundries. Samples were collected for untreated wastewater at 15-minute intervals
during an 8- to 10-hour period and composited based on the flow rate at the time of sampling.
The wastewater flow was calculated from process water meter readings and flow readings in the
wastewater treatment system. The process water flows were used to calculate maximum
pollutant loadings.  These are maximum loadings because all of the water metered into the facility
is not discharged as wastewater. The production-normalized pollutant loading level was based on
the maximum pollutant loading level and the actual poundage of laundry produced on the
sampling days.  The types of items laundered on the sampling days were not reported;  soil
classification provided information on the soil loading only.  Also, from the sampling point
location information, it was difficult to  determine the exact location of the sampling point and the
source of wastewater sampled.  In some cases, the untreated wastewater sampled may have
passed through settling pits or screens before sampling.

              The second part of the TRSA study presented data from five linen and industrial
laundries.  All of these laundries had treatment systems in place.  Four facilities had DAF systems
and one facility had a proprietary filter  system. Sampling was conducted  as described for the first
part of the study, except that both untreated and treated wastewater samples were collected.
Process water flows were used to calculate maximum pollutant loadings, and wastewater flows in
the treatment system were used to calculate actual pollutant loadings. The production-normalized
pollutant loading level was based on the maximum pollutant loading level and the average
poundage of clean, dry laundry produced per week at the facility.

              This study included information on the percentages of different types of items
laundered at sampled laundries, although no information was provided on the types of articles
laundered during the sampling days.  Also, the descriptions of the sampling point locations were
more extensive than those presented in the first part of the study. Diagrams of the wastewater
treatment systems were provided and the operations of the treatment systems were  discussed
briefly.  Several of the facilities sampled experienced difficulties with their treatment system
during the sampling days. Also, unlike in the first part of the study, the production-normalized
pollutant loading levels were based on  average production levels instead of actual production
levels.

3.7.2          Trade Associations Solicitation of Data

              After the publication of the proposed rule, the industrial laundries trade
associations, UTS A and the TRSA, solicited data from all of the  facilities that were sent a  detailed
questionnaire.  The purpose of the solicitation, as stated by UTS A and TRSA, was  to provide
EPA with updated data to calculate new baseline information on the industry, because the  EPA
questionnaire data are for the 1993 operating year.
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                                                 Chapter 3 - Data Collection Methodology and Information Sources

              The trade associations' solicitation requested the following information: the year
the data were supplied, the average flow rate of wastewater, modifications to treatment system
since 1993, the year modifications to treatment system occurred, a description of the current
wastewater treatment system, the portion of the wastewater treated, the facility's discharge permit
limits and the facility's average discharge concentration for 13 parameters, the weekly production
of the facility, the average percentage of total pounds per item laundered, whether a subcontractor
is used to process towels, the amount of towels subcontracted out for processing, whether the
subcontractor water-washes or dry-cleans the towels, and whether the subcontractor's wash
water from the laundering of the towels is treated.

              Of the 193 facilities that EPA used to model compliance costs and pollutant
loading reductions for the proposed rule, 165 responded to the UTSA/TRSA survey. EPA
reviewed the data from the survey and compared, for each facility, the treatment system
description contained in the UTSA/TRSA solicitation to the treatment system components
reported in the detailed questionnaire.

3.7.3         Data Included with Comments on the Proposed Rulemaking and Notice of
              Data Availability

              In response to the proposal published on December 17, 1997 and the NODA
published on December 23,  1998, EPA received additional data from the industrial laundries in
individual comment submittals. The data received included: industrial laundry effluent loadings,
treatment technology costs, the constituents of TPH, data on the analytical variability of bis(2-
ethylhexyl) phthalate, local limits for specific laundries, and POTW treatability of specific
pollutants.  Costs submitted by commenters included: general annual and capital costs for both
chemical precipitation and DAF, the annual costs associated with treating  1,000 gallons of
wastewater with DAF, analytical costs, the costs associated with the construction of a new
building for an industrial laundry, and facility-specific cost information.

              The industrial laundries industry and its trade  associations also submitted reports
and case studies. Reports and studies submitted by commenters ranged in content from data
pertaining to the calculation of the toxic weighting factor for TPH to general economic and
industry profiles for the industrial laundries industry.

              These data are contained in Section 14 of the Industrial Laundries Administrative
Record. Data  submitted with comments and used by EPA as part of specific analyses are
described in more detail in other sections of this document.

3.7.4         Request for Substantiation  of Claims Made in Comments

              Many of the  commenters on the proposed rule stated that EPA underestimated
compliance costs and that EPA overestimated the treatment performance of chemical precipitation
and DAF. However, many commenters did  not present data to substantiate these claims.
Without additional data to support these claims, EPA would have to rely on data obtained prior to
proposal (vendor quotes, previously submitted cost data and comment
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                                                  Chapter 3 - Data Collection Methodology and Information Sources

submittals, and sampling data) and data acquired since proposal through EPA's data collection
activities.

              To obtain data to support unsubstantiated comments made on the proposed rule,
EPA contacted some commenters directly to request additional information. EPA developed a set
of four questions that requested specific information that would enable EPA to consider the
commenter's information in development of the final action.

              EPA requested the following information: a diagram presenting the facility's
wastewater treatment system, including all treatment units, average and residual flows, chemical
addition locations; a description of the facility's operations including total production and item-
specific production, average operation days and hours per year; and specific wastewater treatment
system capital and annual costs.

              To comply with the Paperwork Reduction Act, EPA sent letters to nine of the
commenters that submitted unsubstantiated comments. EPA selected commenters to receive
letters based on the content of their comments, the number of comments submitted, whether or
not the comment was a standard letter prepared by the trade associations, and the size of the firm.
The methodology used to select these nine letter recipients and copies of the letters  sent to each
of them are presented in Section 14.6.1 of the Industrial Laundries Administrative Record. EPA
also solicited comments from the public on these issues in the NODA.

3.7.5          The Trade Associations Split-Sampling Efforts

              The industrial laundries trade associations split samples with EPA during one of
the nine facility sampling episodes (Episode 4900) and several of the Method 1664
Characterization Study sampling episodes.  The data collected by the industry during Episode
4900 were supplied to EPA in a comment submittal; these data are located in Section 14 of the
Industrial Laundries Administrative Record. The industry did not supply EPA with the  split
sample data collected during the Method 1664 Characterization Study.

3.8            POTW Data

              Several POTWs submitted data and comments that were used for the final action,
and are discussed below.

3.8.1          AMSA Questionnaire

              The Association of Metropolitan Sewerage Agencies (AMSA), in an effort to
assist EPA in collecting data for the development of effluent limitations guidelines and standards
for the industrial laundries industry, developed and distributed a questionnaire to its  member
POTWs in 1993. The questionnaire asked the POTWs to provide already collected data on
industrial laundries, which were defined as facilities with the  SIC code of 7218 (facilities that
supply laundered and dry-cleaned work uniforms, wiping towels, safety equipment (such as
gloves, flame-resistant clothing), dust covers and cloths, and  other items to commercial and
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industrial facilities). The questionnaire asked the POTWs for the following information about the
industrial launderers that discharge to their facilities:

              •       Identify facilities that discharge to the POTW that do industrial laundering
                     on a contract basis (outside of their normal business classification) that are
                     not classified as an industrial laundry (i.e., hotels, hospitals, prisons, etc.);

              •       Identify whether facilities discharge directly or indirectly to the POTW;

              •       Specify what numerical discharge standards the POTW applies to industrial
                     laundries (i.e., local limits, category-specific local limits, other limits); and

              •       Provide the following specific information for each industrial laundry that
                     discharges to the POTW:

                     —    Industrial user information (facility location information, average
                           daily wastewater discharge in gallons per day, and permit
                           information);

                     —    Industrial discharge sampling information, including the following:
                           whether the sample point contained only industrial laundry
                           wastewater, and, if not, what other types of waste streams; whether
                           the wastewater was treated prior to the sampling point; types of
                           treatment used; and the types of pollution prevention techniques
                           used at the facility; and

                     —    Sampling data for each sampling point (either POTW or Industrial
                           User (IU) self-monitoring data) for calendar year 1992 (including
                           parameter, measurement, type of sample, whether an EPA-
                           approved method was used to analyze the sample, and, if not, what
                           type of method was used).

              Approximately 280 POTWs returned completed questionnaires. EPA analyzed the
data included in the responses to the questionnaires and used the data to evaluate current local
limits imposed on industrial laundries.  The completed questionnaires are located in Section 6.6 of
the Industrial Laundries Administrative Record.

3.8.2          Data Submittals Related to POTWs with Comments on the Proposed
              Rulemaking and  Notice of Data Availability

              EPA received comment submittals from numerous commenters pertaining to
POTW data related to the pass-through analysis.  These commenters included:  individual
POTWs, local control authorities, and AMSA, along with the industry's trade associations.
Individual POTWs primarily provided data related to the following subjects: the method used to
measure TPH, estimated POTW pollutant removal efficiencies, influent and effluent
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concentration values to be used in the calculation of POTW pollutant removal efficiencies for the
pass-through analysis, industrial laundry facility monitoring data, and local limits covering
industrial laundries. These data and results of any evaluations of these data are contained in
Sections 14 and 17 of the Industrial Laundries Administrative Record, respectively.

3.9           Summary of Literature Searches

              EPA conducted several searches of the open literature throughout the development
of the rule to provide information on the industrial laundries industry. The sources searched
included the following:

              •       Journal articles and technology brochures (early  1970 through 1986);

              •       Census of Service Industries, Department of Commerce (1982);

              •       Computerized databases containing information on treatment technologies
                     for industrial laundries (1986);

              •       Lists of industrial laundries from various on-line  searching methods (1986);
                     and

                     POTW and State Water Quality Agency lists  (1986).

              EPA conducted additional literature searches in 1993 to gather publicly available
information  on the industrial laundries industry.  EPA conducted one literature search to obtain
information  about industrial laundry wastewater, wastewater treatment  technologies, operations,
and costs of operations, and also a search to obtain information about printer towels/rags, wipers,
and shop towels.

              The literature searches focused on the following topics:  waste streams, waste
treatment technologies, operations, and costs of operation.  The following databases were
searched:


        Database                                Description

        Water Resources Abstracts                Water resources topics

        Waternet                                Index of the American Water Works
                                                 Association Publications

        NTIS                                    Government-sponsored research,
                                                 development,  and engineering reports and
                                                 analysis

        COMPENDEX                           Engineering and technology applications

        ENVIRONLINE                         Environmental Sciences
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                                                  Chapter 3 - Data Collection Methodology and Information Sources

        Database                                Description

        Pollution Abstracts                        Pollution control and research

        Books in Print                            Books in print, forthcoming books, and
                                                 books going out of print in the U.S.

        LC Mark                                 Library of Congress catalogued
                                                 publications

        Textile Technology Digest                 Worldwide coverage of textiles and
                                                 related subjects

        World Textiles                            Textiles in areas of technology and
                                                 management

              As part of the literature search, EPA identified three trade journals important in the
industrial laundries industry:  Textile Rental. Industrial Launderer. and Laundry News. These
journals provide up-to-date information on the industrial laundries industry.  EPA conducted
regular reviews of these journals during the development of this final action.

              EPA conducted a separate literature search for data on pollution prevention in the
industrial laundries industry by examining various on-line databases, including EPA's Pollution
Prevention Information Exchange System (PIES).

3.10          Summary of Other Data Sources

              In developing the industrial laundries effluent guidelines, EPA also evaluated the
following existing data sources:

              •      The Office of Research and Development (ORD) Risk Reduction
                     Engineering Laboratory (RREL) treatability database;

              •      The Fate of Priority Pollutants in Publicly Owned Treatment Works (50
                     POTW Study) database;

                     The Domestic Sewage Study (DSS);

              •      Canadian studies; and

              •      Industrial Pollution Prevention Project.

These data sources and their uses in the development of the final action are discussed below.

3.10.1         Risk Reduction Engineering Laboratory Treatability Database

              EPA's ORD developed the RREL treatability database to provide data on the
removal and destruction of chemicals in various types of media, including water,  soil, debris,

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                                                 Chapter 3 - Data Collection Methodology and Information Sources

sludge, and sediment.  This database contains treatability data from POTWs for various
pollutants.  This database includes physical and chemical data for each pollutant, the types of
treatment used to treat the specific pollutants, the type of wastewater treated, the size of the
POTW, and the treatment concentrations achieved. EPA used this database to assess POTW
removal efficiencies of various pollutants.

3.10.2        Fate of Priority Pollutants in Publicly Owned Treatment Works Database

              In September 1982, EPA published the Fate of Priority Pollutants in Publicly
Owned Treatment Works (16), referred to as the 50 POTW Study. The purpose of this study was
to generate, compile, and report data on the occurrence and fate of the 129 priority pollutants in
50 POTWs. The report presents all of the data collected, the results of preliminary evaluations of
these data, and the results of calculations to determine the following:

              •      The quantity of priority pollutants in the influent to POTWs;

              •      The quantity of priority pollutants discharged from the POTWs;

              •      The quantity of priority pollutants in the effluent from intermediate process
                    streams; and

              •      The quantity of priority pollutants in the POTW sludge streams.

EPA used the data from this study to assess POTW removal efficiencies of various pollutants.

3.10.3        The Domestic Sewage Study

              In February 1986,  EPA issued the Report to Congress on the Discharge of
Hazardous Wastes to Publicly Owned Treatment Works (17), referred to as the Domestic Sewage
Study (DSS). This report, which was based in part on the 50 POTW Study, demonstrated that a
significant number of sites discharging pollutants to POTWs were a threat to the treatment
capability of these POTWs and were not regulated by national categorical pretreatment standards.
Among the unregulated sources were industrial laundries, which at the time were estimated to
discharge significant quantities of toxic and hazardous pollutants on a facility-specific basis.
During the  course of the DSS, EPA contacted a number of state and local agencies to obtain toxic
pollutant data and other relevant data.  EPA used the information in the DSS in developing the
Preliminary Data Summary for the Industrial Laundries Industry (1).

3.10.4        Canadian Studies

              EPA studied other sources of data, as described below, to obtain as comprehensive
a picture of the industrial laundries industry as possible. One of these sources was the Ministry of
the Environment and Energy (MOEE) of Canada.  As in the U.S., industrial laundries in Canada
have been found to be a source of oil and grease in sewer systems.  The MOEE's
Municipal/Industrial Strategy for  Abatement (MISA) section and the Ontario, Canada industrial
laundry associations conducted a  survey of Canadian industrial laundries to assess the

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                                                  Chapter 3 - Data Collection Methodology and Information Sources

amount of oil and grease and other pollutants discharged into sewer systems.  The survey was
conducted to obtain an overview of the industrial laundries industry, sources of contamination,
and treatment used to reduce the pollutant loads to sewers.

              The laundries surveyed in this report included industrial laundries, linen
establishments, and commercial launderers and excluded retail-only, coin-operated, dry cleaning,
and health-care facilities. The industrial laundries processed industrial garments and wiper towels,
which, according to this survey, were considered major sources of oil and grease.  The survey
showed that many industrial laundries in this study used some wastewater pretreatment; however,
only four facilities used advanced pretreatment techniques, and several facilities did not pretreat
their wastewater.

              In addition, the Ontario Laundry Industry Pollution Prevention Task Force has
been meeting regularly to discuss pollution prevention measures in the laundries industry and how
to promote those practices.  The Task Force consists of the following entities: the Ontario
Ministry of Environment and Energy, the Metropolitan Area of Toronto, the City of Brantford,
and several Canadian laundries,  some of which represent the laundry associations Dry Cleaners
and Launderers Institute (DCLI) and Textile Rental Institute of Canada (TRIO).  In 1994, the
Task Force held a workshop on  pollution prevention in the laundries industry, which discussed
pollution prevention in general,  how using pollution prevention practices benefits industrial
laundries, and approaches to and techniques for reducing waste in the industry.

3.10.5        Industrial Pollution Prevention Project

              EPA has undertaken several pollution prevention-related activities involving the
industrial laundries industry. Some of the efforts were Agency-wide, including ORD and EPA's
Region IX, while other efforts were part of the engineering studies in the development of the
proposed rule.

              The Agency-wide efforts, called the Industrial Pollution Prevention Project (IP3),
were multimedia and examined  how industrial pollution prevention can be incorporated into
EPA's regulatory framework and how the pollution prevention ethic can be promoted throughout
industry, the public, and government.  A report summarizing the results of these efforts, entitled
Industrial  Pollution Prevention Project (IP3) - Summary Report (18), included the results of two
case studies involving industrial laundries. More detailed discussions of the two studies are
contained in the individual reports, Pollution Prevention at Industrial Laundries: Assessment
Observations and Waste Reduction Options (19), and Pollution Prevention at Industrial
Laundries: A Collaborative Approach in Southern California (20). These studies identified a
number of "best management practices" (BMPs) and water and energy savings technologies as
potential pollution prevention at industrial laundries.

              Similarly, during the engineering study phase of the development of a final action,
EPA identified a number of potential pollution prevention  practices and technology applications.
Section VT of the preamble to the proposed rule and Chapters 6 and 8 of this document discuss
the pollution prevention technologies and practices and their uses with respect to the final action.
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                                                Chapter 3 - Data Collection Methodology and Information Sources

3.11         References

1.            U.S. Environmental Protection Agency. Preliminary Data Summary for the
             Industrial Laundries Industry. EPA 440/1-89/103, September 1989.

2.            U.S. Environmental Protection Agency. Statistical Support Document for
             Proposed Pretreatment Standards for Existing and New Sources for the Industrial
             Laundries Point Source Category. EPA-821-R-97-006, Washington, D.C.,
             November 1997.

3.            U.S. Environmental Protection Agency. Information Collection Request. U.S.
             Environmental Protection Agency 1994 Industrial Laundries Industry
             Questionnaire. March 3, 1994.

4.            U.S. Environmental Protection Agency. Economic Assessment for the Final
             Action Regarding Pretreatment Standards for the Industrial Laundries Point
             Source Category (Revised February 20001 EPA-821-R-00-004, Washington,
             D.C., February 2000.

5.            Eastern Research Group, Inc. Data Element Dictionary for the Industrial
             Laundries Industry Questionnaire Part A Database. Prepared for the U. S.
             Environmental Protection Agency, Office of Water, Washington, D.C.,  November
             1997.

6.            Eastern Research Group, Inc. Data Element Dictionary for the DMQ Database.
             Prepared for the U.S.  Environmental Protection Agency, Office of Water,
             Washington, D.C.,  November 1997.

7.            U.S. Environmental Protection Agency. Sampling and Analysis Procedures for
             Screening of Industrial Effluents for Priority Pollutants. April 1977.

8.            U.S. Environmental Protection Agency. Method 1620 Draft - Metals by
             Inductively Coupled Plasma Atomic Emission Spectroscopy and Atomic
             Absorption Spectroscopy.  September 1989.

9.            U.S. Environmental Protection Agency. Method 1624 Revision C - Volatile
             Organic Compounds by Isotope Dilution GCMS. 40 CFR 136, Appendix A, June
             1989.

10.          U.S. Environmental Protection Agency. Method 1625 Revision C - Semivolatile
             Organic Compounds by Isotope Dilution GCMS. 40 CFR 136, Appendix A, June
             1989.
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                                                Chapter 3 - Data Collection Methodology and Information Sources

11.          U.S. Environmental Protection Agency. Method 1664:  N-Hexane Extractable
             Material (HEM) and Silica Gel Treated N-Hexane Extractable Material TSGT-
             HEM) by Extraction and Gravimetry (Oil and Grease and Non-polar Material).
             EPA-821-B-94-004b, April 1995.

12.          U.S. Environmental Protection Agency.  SW-846: Test Methods for Evaluating
             Solid Waste. Physical/Chemical Methods: Method 1311. Toxicity Characteristic
             Leaching Procedure.  63 FR 32452, June 13, 1997.

13.          U.S. Environmental Protection Agency. Methods for Chemical Analysis of Water
             and Wastes. EPA-800-4-79-020, Revised March 1983.

14.          Standard Methods for the Examination of Water and Wastewater. A.D. Eaton,
             L.S. Clesceri and A.E. Greenberg, eds.  19th Edition.  American Public Health
             Association, Washington, D.C., 1995.

15.          DynCorp Environmental. The Study Plan for Determination of the Components  of
             n-Hexane Extractable Material (HEM) and Silica Gel Treated n-Hexane
             Extractable Materials (SGT-HEM: Non-polar Material) in Discharges from
             Selected Industrial Laundry Facilities.  Prepared for the U.S. Environmental
             Protection Agency, Office of Water, Washington, D.C., July 1998.

16.          U.S. Environmental Protection Agency. Fate of Priority Pollutants in Publicly
             Owned  Treatment Works.  EPA 440/1-82/303, September 1982.

17.          U.S. Environmental Protection Agency. Report to Congress on the Discharge of
             Hazardous Wastes to Publicly  Owned Treatment Works. EPA-530-SW-86-004,
             February 1986.

18.          U.S. Environmental Protection Agency. Industrial Pollution Prevention Project
             OP3VSummary Report.  EPA-820-R-95-007, July 1995.

19.          U.S. Environmental Protection Agency. Pollution Prevention at Industrial
             Laundries:  Assessment Observations and Waste Reduction Options.  EPA-820-R-
             95-010, July 1995.

20.          U.S. Environmental Protection Agency. Pollution Prevention at Industrial
             Laundries:  A Collaborative Approach in Southern California.  EPA-820-R-95-
             012, July 1995.
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                                                                           Chapter 4 - Industry Profile

                                        CHAPTER 4

                                  INDUSTRY PROFILE

4.1           Introduction

              Chapter 4 discusses the processes, items, customers, chemicals, facilities and
equipment, and pollution reduction activities found in the industrial laundries industry.  This
chapter also provides a definition of the industrial laundries industry.  Most of the data presented
in this chapter are from facility responses to the 1994 Industrial Laundries Industry Questionnaire
(detailed questionnaire), additional data are from  the 1993 Industrial Laundries Screener
Questionnaire.  EPA sent the detailed questionnaires to 250 facilities,  and 231 facilities returned
the questionnaire, as described in Section 3.3.2 of this document.  Two hundred eight (208)
facilities that responded to the detailed questionnaire provided sufficient data to perform complete
technical and economic analyses. The percentages and number of facilities performing various
processes discussed in this section were estimated based on the responses from all facilities
determined to be industrial laundries.  The data for these facilities were then extrapolated to
represent the industry population of 1,747 facilities, using appropriate survey weights. The survey
weights calculated for each of the facilities can be found in the Statistical Support Document for
the proposed rule (1).  Three facilities of the 193 identified industrial laundries were later
determined to be out-of-scope because they process only clean room items (see Section 4.8). The
following topics are discussed in this section:

              •       Section 4.2 discusses the geographic location, relative size, types of items
                      laundered, customers, and  Standard Industrial Classification (SIC) code
                      distribution of facilities in the industrial laundries industry;

              •       Section 4.3 discusses general information on industrial laundering
                      processes and chemicals used  in the laundering processes;

              •       Section 4.4 discusses facilities and equipment used at industrial laundries;

              •       Section 4.5 presents pollution reduction activities;

              •       Section 4.6 discusses trends within  the industry;

              •       Section 4.7 lists treatment technologies in use;

              •       Section 4.8 provides EPA's definition of the industry; and

              •       Section 4.9 presents the references used in this section.
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                                                                          Chapter 4 - Industry Profile

4.2           Overview of the Industry

              This section provides an overview of the industrial laundries industry.  This
overview includes general information pertaining to the industry, including geographic location,
SIC codes, facility size, types of items laundered, and customers.

4.2.1          Geographic Distribution of Facilities

              Information on geographic distribution was based on the 1993 Industrial Laundries
Screener Questionnaire. This questionnaire was completed by 1,500 industrial laundries that EPA
identified using trade association mailing lists.  Since there were no direct discharging industrial
laundries identified by the questionnaire responses, only industrial laundries that reported
generating laundry process wastewater and discharging a wastewater to a publicly owned
treatment works (POTW) were used to determine the geographic distribution of facilities. These
facilities are located in all 50 states and in all 10 EPA Regions, as well as several U.S. territories.
Figure 4-1  and Table 4-1 present the geographic distribution of these facilities.  By state, the
greatest number of in-scope laundries (102 facilities) are in California.  By EPA region, the
greatest number of in-scope laundries (203 facilities) are in Region V, followed by Region IV,
which has 181 facilities. Most of the laundries are located in large urban areas.

4.2.2          SIC Codes Reported

              The facilities responding to the detailed questionnaire reported 7218 (Industrial
Laundries) and 7213 (Linen Supply Laundries)  as their primary SIC codes. Other secondary and
tertiary SIC codes reported were 7211 (Power Laundries, Family and Commercial), 7216 (Dry-
cleaning Plants,  except rug cleaning), and 7219  (Laundry and Garment Services, not elsewhere
classified).

4.2.3          Facility Size

              Industrial laundries vary in size from one- to two-person shops to large
corporations that operate many facilities nationwide. For the purpose of this section, EPA based
the relative size of each facility on the pounds of dirty (as-received) laundry washed per year.

              Table 4-2 presents the national estimates of the number of industrial laundries by
production category.  Annual laundry production per facility ranges from 44,100 to 32,600,000
pounds and the total annual industry production is 9,360,000,000 pounds. Although there are a
fewer percentage of large facilities exist (more than 15 million pounds/year (Ibs/yr) production)
than small facilities (less than 1 million Ibs/yr production), the larger facilities represent a
significant percentage of the total industry production. One hundred thirty-eight (138) facilities
launder more than 15 million Ibs/yr each. These facilities represent 8 percent of the facilities in the
industry, but their combined production (2,660,000,000 Ibs/yr) accounts for 28 percent of the
total industry production. Facilities laundering less than 1 million Ibs/yr represent  10 percent of
the facilities in the industry and account for less than 1 percent of the total industry production.
                                            4-2

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                                                                                   Chapter 4 - Industry Profile
Figure 4-1. Geographic Distribution of Industrial Laundries

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                                          Chapter 4 - Industry Profile
              Table 4-1

Geographic Distribution of Industrial
 Laundries by EPA Region and State
Region/State
Region I
Connecticut
Maine
Massachusetts
New Hampshire
Rhode Island
Vermont
Region II
New Jersey
New York
Puerto Rico
Region III
Delaware
District of Columbia
Maryland
Pennsylvania
Virginia
West Virginia
Region IV
Alabama
Florida
Georgia
Kentucky
Mississippi
North Carolina
South Carolina
Tennessee
Region V
Illinois
Indiana
Michigan
Number of Facilities in Region/State1
55
11
4
29
6
4
1
72
19
51
2
101
4
o
J
17
49
21
7
181
14
42
28
27
6
35
13
16
203
42
33
36
                 4-4

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                                                                                                Chapter 4 - Industry Profile
                                          Table 4-1 (Continued)
Region/State
Minnesota
Ohio
Wisconsin
Region VI
Arkansas
Louisiana
New Mexico
Oklahoma
Texas
Region VII
Iowa
Kansas
Missouri
Nebraska
Region VIII
Colorado
Montana
North Dakota
South Dakota
Utah
Wyoming
Region IX
Arizona
California
Guam
Hawaii
Nevada
Region X
Alaska
Idaho
Oregon
Washington
Number of Facilities in Region/State1
17
56
19
131
18
16
10
15
72
57
14
8
24
11
36
16
3
1
4
6
6
136
14
102
3
8
9
39
4
8
14
13
'Number of facilities is based on number of facilities identified by the 1993 Industrial Laundries Screener Questionnaire that reported generating
laundry process wastewater and discharging that wastewater to a POTW.
                                                         4-5

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                                                                                   Chapter 4 - Industry Profile
                                             Table 4-2

                                       Industrial Laundry
                                        Size Distribution
Production Category
(Ibs/yr)
< 1,000,000
1,000,000 to < 3, 000,000
3, 000,000 to < 6,000,000
6,000,000 to <9,000,000
9,000,000 to < 15,000,000
> 15,000,000
Total
Estimated
Number of
Facilities1
167
475
629
199
139
138
1,747
Estimated
Percentage of Total
Number of Facilities
Reporting
Production Data
10
27
36
11
8
8
100
Total Estimated
Production for
this Category
(Ibs/yr)
76,600,000
886,000,000
2,740,000,000
1,390,000,000
1,600,000,000
2,660,000,000
9,360,000,000
Estimated
Percentage of
Total
Production
<1
10
29
15
17
28
100
'Number of facilities is estimated using the detailed questionnaire, based on 193 in-scope facilities extrapolated to
represent the entire industry (including three facilities that were later determined to be out-of-scope because they process
only clean room items).
Source:  1994 Industrial Laundries Industry Questionnaire.
                                                 4-6

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                                                                         Chapter 4 - Industry Profile

4.2.4         Items Laundered

              As reported by the 193 facilities, industrial laundries wash a variety of items.  The
three main types of items reported in the detailed questionnaire responses were industrial laundry
items, linen laundry items, and other items. Typically, industrial laundry items include industrial
garments, shop towels, printer towels, floor mats, and fender covers. Linen items typically
include linen garments, flatwork/full dry linen, and health-care items.  Other items are specialty
items or items that are not generally considered to be either industrial laundry items or linen items.
Brief descriptions of industrial laundry,  linen items, and other items are provided in Chapter 5 of
this document.

              Table 4-3 presents the number of facilities that launder each item and the
percentage of total production by item. Many facilities reported laundering several items.  The
total extrapolated item-specific production reported in the detailed questionnaire is 9,360,000,000
Ibs/yr (calculated by summing the item-specific subtotals reported in the detailed questionnaire
and extrapolating the data to represent the entire industry).

              The detailed questionnaire requested production data for twelve specific items
(questionnaire category codes B01 through B12), as listed on Table 4-3.  EPA requested facilities
to report any items laundered that did not fall in the B01 through B12 categories and place them
in category B13 (Other Items). Based on item types and descriptions provided by the facilities,
EPA created supplemental categories B14 through B24 for these "other" B13 items.  Items that
could not be classified in categories B14 through B24 remained in the B13 "other" category.
Because the data for category codes B13 through B24 were collected through "write-in"
responses rather than through pre-printed selections, EPA believes that the data for category
codes B13 through B24 may not represent total industry production for the items identified in
these categories.

4.2.5         Customers

              Industrial laundries wash items for many different types of customers, ranging from
gasoline stations to restaurants.  The pollutants present on an item laundered depend primarily on
the customer who used the item and the specific use of the item.  For instance, a shop towel from
a gasoline station is more likely to have a high concentration of oil and grease or total petroleum
hydrocarbon than a napkin from a restaurant. Table 4-4 lists the laundered items reported in the
detailed questionnaire responses, the typical customers using these items, and the percentage of
the total industry production of each item laundered from each customer. For example,
automobile repair, services, dealers, and gas stations represent  31.1 percent of the customers who
use industrial garments.
                                           4-7

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                                                                                        Chapter 4 - Industry Profile
                                               Table 4-3
                                    Types of Items Laundered
Item Type1
Industrial Garments (B01)
Shop Towels, Industrial Wipers, etc. (B02)
Pnnter Towels (BOS)
Floor Mats (B04)
Mops, Dust Cloths, Tool Covers, etc. (B05)3
Linen Garments (B06)
Linen Flatwork/Full Dry Linen (B07)
Health-Care Items (BOS)
Fender Covers (B09)
Continuous Roll Towels (BIO)3
Clean Room Garments (B 1 1 )
Clean Wipes (B 12)
Other Items (B13)4
Laundry Bags (B14)
Family Laundry (B15)
Absorbents (B 16)
New Items (B 17)
Executive Wear (B 18)
Miscellaneous Not Our Goods (NOG) (B19)
Rewash Items (B20)
Airline Carpet and Seat Covers (B22)
Filters (B23)
Buffing Pads (B24)
Total
Estimated Number
of Facilities
Laundering Item
1,441
1,332
480
1,644
1,400
942
1,364
648
687
927
28
-
31
28
84
-
74
43
14
38
-
7
6
-
Estimated
Percentage of
Total
Facilities
82.5
76.2
27.5
94.1
80.1
53.9
78.1
37.1
39.3
53.1
1.6
-
1.8
1.6
4.8
-
4.2
2.5
<1
2.2
-
<1
<1
-
Estimated
Percentage of
Total
Production2
24.4
3.7
1.4
19.3
1.3
2.9
35.2
7.9
<1
1.2
<1
-
<1
<1
<1
-
1.6
<1
<1
<1
-
<1
<1
100
'The codes in parentheses are from the detailed questionnaire and were used in the questionnaire database.
2Total industry production is estimated based on data from the detailed questionnaire from the 193 in-scope facilities,
extrapolated using appropriate survey weights to represent the entire industry (including three facilities that were later
determined to be out-of-scope because they process only clean room items).
3One facility (with a survey weight of 1.3333) did not report production for this item; therefore, the estimated percentage
of total production may be less than the actual amount processed.
4Includes items not specified in detailed questionnaire responses.
Source:  1994 Industrial Laundries Industry Questionnaire.
                                                    4-8

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Chapter 4 - Industry Profile
                                                                                 Chapter 4 - Industry Profile
                                                                  Table 4-4
                                     Typical Customers for Each Type of Item Laundered
              Item Type1
                           Customers1
     Percentage
of Total Production of
Item from Customer2
 Industrial Garments (B01)
Automobile Repair, Services, Dealers, Gasoline Stations (C01)
Special Trade Contractors for Building Construction (C02)
Dwellings and Other Building Services (COS)
Industrial Metal, Machinery, and Equipment Manufacturing (C04)
Chemicals and Allied Products Manufacturing (COS)
Transportation, Communication, Utility, and Sanitary Services (C07)
Eating/Drinking Establishments, Food/Beverage Manufacturing and
Processing, and Food Stores (COS)
        31.1
        10.2
        5.49
        17.2
        9.65
        10.5
        11.1
 Shop Towels, Industrial Wipers, etc.
 (B02)
Automobile Repair, Services, Dealers, Gasoline Stations (C01)
Special Trade Contractors for Building Construction (C02)
Dwellings and Other Building Services (COS)
Industrial Metal, Machinery, and Equipment Manufacturing (C04)
Chemicals and Allied Products Manufacturing (COS)
Transportation, Communication, Utility, and Sanitary Services (C07)
        48.1
        6.74
        5.14
        19.6
        7.52
        6.12
 Printer Towels (BOS)
Publishing and Printing Industries (C06)
Other Laundries (C20)
        86.1
        13.4
 Floor Mats (B04)
Automobile Repair, Services, Dealers, Gasoline Stations (C01)
Dwellings and Other Building Services (COS)
Industrial Metal, Machinery, and Equipment Manufacturing (C04)
Chemicals and Allied Products Manufacturing (COS)
Transportation, Communication, Utility, and Sanitary Services (C07)
Eating/Drinking Establishments, Food/Beverage Manufacturing and
Processing, and Food Stores (COS)
        26.8
        11.0
        11.4
        5.92
        6.63
        24.7
 Mops, Dust Cloths, Tool Covers, etc.
 (BOS)
Automobile Repair, Services, Dealers, Gasoline Stations (C01)
Dwellings and Other Building Services (C03)
Industrial Metal, Machinery, and Equipment Manufacturing (C04)
Transportation, Communication, Utility, and Sanitary Services (C07)
Eating/Drinking Establishments, Food/Beverage Manufacturing and
Processing, and Food Stores (COS)
Health Services (CIO)
         15.4
         23.1
         8.17
         7.37
         20.2

         7.46

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Chapter 4 - Industry Profile
                                                     Table 4-4 (Continued)
Chapter 4 - Industry Profile
Item Type1
Linen Garments (B06)
Linen Flatwork/Full Dry (B07)
Health-Care Items (BOS)
Fender Covers (B09)
Continuous Roll Towels (BIO)
Clean Room Garments (B 1 1 )
Laundry Bags (B14)
Family Laundry (B15)
Customers1
Eating/Drinking Establishments, Food/Beverage Manufacturing and
Processing, and Food Stores (COS)
Eating/Drinking Establishments, Food/Beverage Manufacturing and
Processing, and Food Stores (COS)
Hotel and Lodging Establishments (C09)
- Health Services (CIO)
Customer Not Reported (C 1 1 )3
Automobile Repair, Services, Dealers, Gasoline Stations (C01)
Industrial Metal, Machinery, and Equipment Manufacturing (C04)
Transportation, Communication, Utility, and Sanitary Services (C07)
Automobile Repair, Services, Dealers, Gasoline Stations (C01)
Special Trade Contractors for Building Construction (C02)
Dwellings and Other Building Services (COS)
Industrial Metal, Machinery, and Equipment Manufacturing (C04)
Transportation, Communication, Utility, and Sanitary Services (C07)
Eating/Drinking Establishments, Food/Beverage Manufacturing and
Processing, and Food Stores (COS)
Industrial Metal, Machinery, and Equipment Manufacturing (C04)
Chemicals and Allied Products Manufacturing (COS)
Customer Not Reported (C 1 1 )3
Electronics Industry (C 1 8)
Automobile Repair, Services, Dealers, Gasoline Stations (C01)
Special Trade Contractors for Building Construction (C02)
Industrial Metal, Machinery, and Equipment Manufacturing (C04)
Publishing and Printing Industries (C06)
Transportation, Communication, Utility, and Sanitary Services (C07)
Eating/Drinking Establishments, Food/Beverage Manufacturing and
Processing, and Food Stores (COS)
Industrial Metal, Machinery, and Equipment Manufacturing (C04)
Eating/Drinking Establishments, Food/Beverage Manufacturing and
Processing, and Food Stores (COS)
Families (C23)
Percentage
of Total Production of
Item from Customer2
91.1
85.2
14.1
90.8
8.65
77.1
11.6
8.24
21.1
7.31
8.33
9.51
9.23
29 2
17.2
21.2
28.2
30.3
23.7
9.34
5.82
7.52
39.2
9.25
8.92
8.33
69.8

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Chapter 4 - Industry Profile
Chapter 4 - Industry Profile
                                                            Table 4-4 (Continued)
Item Type1
Absorbents (B 16)
New Items (B 17)
Executive Wear (B 18)
Miscellaneous Not Our Goods (NOG)
(B19)
Rewash Items (B20)
Filters (B23)
Buffing Pads (B24)
Customers1
Industrial Metal, Machinery, and Equipment Manufacturing (C04)
Publishing and Printing Industries (C06)
- Retail/Wholesale Stores (C 1 2)
Miscellaneous Service Industries (CIS)
Agricultural Industry (C 16)
Miscellaneous Manufacturing (C 1 9)
- Retail/Wholesale Stores (C 1 2)
Miscellaneous Manufacturing (C 1 9)
Textile Manufacturing (C24)
Other Laundries (C20)
- General Off ices (C21)
Families (C23)
Eating/Drinking Establishments, Food/Beverage Manufacturing and
Processing, and Food Stores (COS)
Transportation, Communication, Utility, and Sanitary Services (C07)
Chemicals and Allied Products Manufacturing (COS)
Wood Product/Furniture Manufacturing (C 1 4)
Eating/Drinking Establishments, Food/Beverage Manufacturing and
Processing, and Food Stores (COS)
Percentage
of Total Production of
Item from Customer2
13.2
6.79
19.3
19.9
5.61
16.8
31.8
27 2
41.0
56.3
36.2
5.47
96.0
94.0
17.3
82.7
100
'The codes in parentheses are from the detailed questionnaire and were used in the questionnaire database.
2Customers representing less than 5 percent of the total production for an item are not shown in the table; therefore, the percentages may not add up to 100 percent for
each item.
3 Production data were provided for these items; however, the percentage of customers not reported by the facilities was greater than 5 percent.
Source:  1994 Industrial Laundries Industry Questionnaire.

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                                                                         Chapter 4 - Industry Profile

4.3           Laundering Processes

              For all laundering processes, the methods by which the items are received, sorted,
and transported to the washing area are similar. Industrial laundries receive soiled items in trucks
and weigh the items before washing. These items are typically sorted based on item type, fabric
type, color, degree and/or type of soil, and ownership. Sorted items are then placed in slings or
carts, which are either automatically or manually moved to the washing area.  The items  are then
cleaned using the appropriate process.

              Table 4-5 presents laundering processes reported by the facilities responding to the
detailed questionnaire, as well as the percentage of total production laundered by each process
and the number of facilities performing each process. Many facilities reported conducting more
than one of the listed processes.  One process included in Table 4-5, dyeing of new fabrics is not
considered a laundering process by EPA. EPA reviewed laundry processes and associated water
use and wastewater discharge practices to determine if facilities that used and/or discharged little
or no water could be eliminated  from the scope of the rule.  Only water-washing laundering
processes are included in the scope of the rule.  EPA does not consider dyeing of new items to be
a laundering process; therefore, it is also excluded from the scope of the proposed rule. Dyeing of
used textile items such as shop and printer towels/rags, which is often performed as part of the
washing process, is included in the scope of the rule.  The remaining  processes listed in Table 4-5
can be divided into two basic categories: processes that generate wastewater and processes that
generate little or no wastewater.  The individual processes within these categories are described in
more detail below.

4.3.1          Water-Using/Wastewater-Generating Processes

              Laundering processes that use significant amounts of water and generate
wastewater include water-washing processes and dual-phase washing.  Almost all (97 percent) of
the industry's production involves water-washing processes. Of the 1,747 in-scope facilities
(including three facilities that were later determined to be out-of-scope because they process only
clean room items), EPA estimates that 1,443 perform water washing on 100 percent of their
production.  Water washing is performed on almost all items.  Brief descriptions of the different
water-using processes are provided below.

4.3.1.1        Water Washing
              Water washing involves the washing of soiled items in a water/chemical solution.
The concentration, type, and amount of chemicals added during the water-washing process
depend on the item type and the degree to which items are soiled. Wash formulas are used to
determine the different washing cycles used in water washing, including the chemicals added.
Wash formulas are also used to set the order, number, and duration  of each wash cycle that is
performed during the water-washing process. The typical order of these cycles and brief
descriptions of the processing operations that occur in each cycle are described below.
                                          4-12

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                                                                                   Chapter 4 - Industry Profile
                                             Table 4-5

                                     Laundering Processes
                          Reported in the Detailed  Questionnaire
Process1
Water Washing (A01)
Dual-Phase Washing - Petroleum solvent wash followed by
water washing (A02)
Dual-Phase Washing - Water wash followed by
perchloroethylene solvent wash (A03)
Dry Cleaning - Charged system (A04)
Dry Cleaning - Fresh soap added to each load (A05)
Dry Cleaning - No soap added (A06)
Dry Cleaning Followed by Water Washing (drying between
steps) (A 12)
Dust Control Mop Treatment - Water wash followed by oil
treatment applied outside wash wheel (A 10)
Dust Control Mop Treatment - Water wash followed by oil
treatment applied inside wash wheel (Al 1)
Dust Control Mop Treatment- Water wash followed by
unspecified oil treatment (A07)
Dust Control Mop Treatment - Oil only (A08)
Stone/Acid Washing of Denim (A13)
Dyeing (A14)3
Total
Estimated
Number of
Facilities
Performing the
Process
1,725
18
0
125
80
80
29
692
67
22
57
11
1
-
Estimated
Percentage of
Facilities
Performing
the Process
99
1
0
7
5
5
2
40
4
1
3
1
<1
-
Estimated
Percentage of
Total
Production2
97
<1
0
<1
<1
<1
<1
1
<1
<1
<1
1
<1
100
'The codes in parentheses are from the detailed questionnaire and were used in the questionnaire database.
Percentages reported are estimated based on the 193 in-scope facilities (including three facilities that were later
determined to be out-of-scope because they process only clean room items), extrapolated using appropriate survey
weights to represent the entire industry.
3This process is not considered a laundering process by EPA.
Source:  1994 Industrial Laundries Industry Questionnaire.
                                                4-13

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                                                                         Chapter 4 - Industry Profile

              In typical water-washing processes, the first cycle is the flush, which is defined as
any rinsing operation prior to bleaching.  This cycle removes loosely attached solids and a portion
of the water-soluble soils.  The next cycle is the break, during which items are treated with an
alkali solution that swells the cellulosic fibers, allowing the soil to be more readily removed.
Detergents may also be added during the break cycle. Sudsing occurs after the break cycle and is
the cycle in which the actual washing of the items occurs.  During sudsing, detergent is added in
varying concentrations and the items are agitated until they are clean. After sudsing, a bleaching
cycle may be performed, during which the detergent is replaced with a bleach solution and
agitation continues.  Following the sudsing and bleaching cycles,  a rinsing cycle is typically
performed, which removes the excess alkali  and soap from the items. Additional  chemicals are
added in the blueing/brightening cycle to whiten/brighten the items.  The final operation in water
washing is the finish, which involves souring or acidifying the final bath water to a pH of 5, which
prevents the yellowing of fabrics by sodium bicarbonate during pressing.

4.3.1.2        Dual-Phase Processing

              Some facilities combine the water-washing and dry-cleaning processes to wash
items that have large amounts of both organic-solvent-soluble and water-soluble soils.  When
these processes are performed in series, without drying the item between the solvent and water
phases, the process is called dual-phase processing. The order in which these processes are
carried out is determined by the solvent used, type of soil,  and drying energy requirements. Dual-
phase processing involving a petroleum solvent wash followed by water washing is used by only
one percent of the industry.  None of the facilities responding to the detailed questionnaire
reported performing dual-phase processing involving water washing followed by  solvent wash.

4.3.1.3        Water-Washing of Mops

              This process entails first water washing mops and then applying oil to the mops by
a sprayer either outside or inside the washer. This method of washing mops generates
wastewater.

4.3.2         Processes with Minimal Wastewater Discharge

              There are several laundering processes that generate minimal to no wastewater.
Dry cleaning is a processes that generates minimal amounts of wastewater.  Data from the
detailed questionnaire indicate water use associated with dry cleaning typically ranges from zero
gallons of process water per pound of laundry processed to 0.25  gallons of process water per
pound of laundry processed. (Water use associated with water washing ranges between 1.5 and
3.6 gallons of process water per pound of laundry, for over 60 percent of the industry.) Dust
control mop treatment using only oil is the only industrial laundry process that generates no
wastewater.  Each of the processes represents less than one percent of the total industry
production and is described in more detail below.
                                           4-14

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                                                                          Chapter 4 - Industry Profile

4.3.2.1        Dry Cleaning

              Dry cleaning involves the use of an organic solvent instead of an aqueous
detergent solution to clean laundry items.  Water washing of certain items causes hydrophilic
fibers to swell and undergo dimensional changes,  causing wrinkles and shrinkage that can be
avoided by the use of dry-cleaning solvents.  These solvents dissolve soils at low temperatures
and under relatively mild conditions, unlike water washing, which usually involves high
temperatures and the use of harsh chemicals, such as alkalis and bleaches. The primary solvents
used by industrial laundries are perchloroethylene ("perc") and petroleum-based solvent. Because
these solvents are typically expensive and are considered hazardous wastes, they are commonly
recycled and reused in subsequent dry-cleaning loads. During dry cleaning, the solvent becomes
contaminated with dirt, oil, and grease removed from the items processed. To minimize the
solvent contamination, industrial laundries use multiple solvent rinses to process items.  As with
water washing, the first few rinses typically contain the most pollutants,  and subsequent rinses
become less contaminated.

              The general process steps for dry cleaning are similar to those for water washing.
The items may be washed  and dried in the same unit or washed in one unit and manually
transferred to a dryer.  In the drying step, steam is injected into the unit to volatilize the solvent.
The steam and solvent are captured in a condenser.  The water/solvent mixture is transferred to a
phase separator where the solvent and water are separated. The solvent is either reused or
contract hauled off-site for disposal.  The water is discharged to a POTW either with or without
pretreatment.  The three major methods of dry cleaning items at industrial laundries are listed
below.

              1)     Charged system: A small percentage of water and detergent (between 0.5
                     percent and 4 percent) is added to the dry-cleaning solvent.  The water and
                     detergent concentration in  the solvent is maintained throughout the
                     washing processes by using conductivity meters to control the addition of
                     water and detergent automatically.

              2)     Fresh soap added to each load: A given amount of soap or detergent is
                     added at the beginning of each load; no additional detergent is added
                     during the cleaning cycle.  Because the process is not monitored as closely
                     as the charged system, excess water, soap, and energy may be expended
                     with this system.

              3)     No  soap added: This method uses only a dry-cleaning solvent.

4.3.2.2        Oil Treatment of Dust Mops

              At some facilities, dust mops are not water-washed but are cleaned and treated
with heated oil instead of water.  After cleaning, the oil is extracted from the mops, leaving them
coated with the desired quantity of treatment oil.  The dirty oil is then purified by filtration and is
reused.  This is a closed-loop processing system that uses no process water.
                                           4-15

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                                                                         Chapter 4 - Industry Profile

4.3.3          Chemicals Used in Industrial Laundries

              Industrial laundries use a variety of chemicals in their laundering processes.
Chemicals that are frequently added to wash formulas include:

              •       Alkaline solution - to swell the fibers in the items;
              •       Detergent - to remove soil from the items (including sodium hypochlorite
                     and hydrogen peroxide);
              •       Bleach - to brighten the items (including sodium sulfites);
              •       Antichlor - to remove excess bleach from the items;
              •       Sour - to reduce the pH of the water to prevent yellowing of the items
                     (including acetic acid and sodium silica fluorides);
              •       Softener - to soften the items; and
              •       Starch - to finish the items.

A variety of other chemicals are added to some wash formulas, including enzymes, builders, oil
treatment chemicals, water conditioners, dyes, stain treatment chemicals, and bactericides.

              Table 4-6 lists, based on the detailed questionnaire, the types of chemicals that are
added during laundering operations, the number of facilities that add each chemical, the amount
of each chemical added per year and the number of facilities that reported using the chemical but
did not report the amount of the chemical used.  Facilities that did not report chemical amounts
were included  in the number of facilities that added the chemicals, but they were not reflected in
the amounts of chemicals added per year. As shown in Table 4-6, the two chemicals added most
frequently to industrial laundering processes (besides detergent) are bleach and sour.  The
majority of the facilities (89 percent) use bleach as part of their laundering process. Eighty-one
percent of the facilities use sour to prevent the yellowing of laundered items.

              Some facilities reported using a chemical for more than one purpose.  For these
facilities, Table 4-6 includes only the primary purpose of the chemical.  The amounts of mop oil
treatment and dry cleaning solvents listed in Table 4-6  are lower than actual use because many
respondents who reported conducting mop  oil treatment or dry cleaning processes did not report
the amounts of chemicals used in these processes.

              Table 4-7 presents the average amount  of detergent added per 1,000 pounds of
laundry for the items laundered in the greatest amounts. Buffing pads, filters, shop towels, and
printer towels require on average the highest amounts of detergent per pound  of laundry, whereas
health-care items and floor mats require significantly less detergent per pound of laundry.

4.4           Facilities and Equipment

              Table 4-8 presents the history of industrial laundries construction and startup from
before 1940 to 1995.  Facility construction refers to the year the building that  the facility operates
in was built. Facility startup refers to the year that actual industrial laundry processing began. As
shown in the table, construction of laundries has  fluctuated to some degree over the years.  In the
1940s, construction of facilities dipped, then rose in the 1960s, and has declined somewhat into

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                                                                                Chapter 4 - Industry Profile
                                           Table 4-6

                   Industrial Laundering Wash Formula Chemicals
                         Reported in the Detailed Questionnaire
Type of Chemical
Detergent
Bleach
Sour
Antichlor
Softener/Antistatic
Starch
Alkaline Solution
Mildewcide/B actericide
Solvent-Based Detergent
Dye Products
Builder
Oil Treatment Chemical
Stain Treatment Chemical
Water Conditioner
Miscellaneous Others2
Solvent (Dry Cleaning)
Enzymes
Denim Treatment
Estimated
Number of
Facilities Adding
Chemical
1,742
1,562
1,419
1,059
990
972
547
533
470
436
275
258
157
141
105
116
55
9
Total Estimated
Amount
Added
(gal/yr)1
3,923,590
5,603,861
639,586
200,546
329,038
198,754
2,018,373
81,304
530,513
46,127
851,861
1,552,455
3,879
53,920
239,056
244,278
861
23,018
Total Estimated
Amount Added
(Ib/yr)1
105,087,072
3,768,844
4,942,014
2,144,738
1,074,365
8,741,770
7,256,211
955,824
0
456,012
1,962,176
33,314
124,059
1,467,531
32,140
0
42,160
12,874
'Some facilities reported using a specific type of chemical but did not provide the amount added per year.  Therefore, the
total amounts added per year do not necessarily represent the total industry chemical use. In the detailed questionnaire,
facilities were given the choice of reporting the amount of a chemical in either pounds per year or gallons per year.
2This category includes chemicals such as pH adjusters, lubricants, fabric coatings, emulsifiers, dispersants, and
desizers.
Source: 1994 Industrial Laundries Industry Questionnaire.
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                                                                              Chapter 4 - Industry Profile
                                          Table 4-7
            Amounts of Detergent Added Per 1,000 Pounds of Laundry
                            for Items Most Often Laundered
Item1
Industrial Garments (B01)
Shop Towels, Industrial Wipers, etc. (B02)
Pnnter Towels (BOS)
Floor Mats (B04)
Mops, Dust Cloths, Tool Covers, etc. (BOS)
Linen Garments (B06)
Linen Flatwork/Full Dry (B07)
Health-Care Items (BOS)
Fender Covers (B09)
Continuous Roll Towels (BIO)
Clean Room Garments (B 1 1 )
Other (B 13)
Laundry Bags (B 14)
Family Laundry (B15)
New Items (B 17)
Executive Wear (B 18)
Miscellaneous NOG (not our goods) (B19)
Rewash Items (B20)
Filters (B23)
Buffing Pads (B24)
Average Gallons of
Detergent Added per 1,000
Pounds of Laundry2
1.66
11.2
23.7
0.393
2.59
2.23
1.77
0.575
1.89
1.23
2.99
0.500
—
0.667
0.696
1.36
7.71
—
—
48.9
Average Pounds of Detergent
Added per 1,000 Pounds of
Laundry2
23.5
32.2
35.5
5.37
21.3
21 2
22.8
8.98
23.0
14.2
12.3
—
20.2
12.4
6.05
8.65
—
31.4
48.6
—
'The codes in parentheses are from the detailed questionnaire and were used in the questionnaire database.
^Facilities were given the choice of reporting the amount of detergent in either pounds per year or gallons per year.
These averages reflect the average amount of detergent added, for facilities/formulas that add either liquid detergent or
powdered detergent, not a combination of the two.
Source: 1994 Industrial Laundries Industry Questionnaire.
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                                                                            Chapter 4 - Industry Profile
                                         Table 4-8
       Age of Facilities and Startup of Laundry/Dry-Cleaning Operations
          (Estimated Percentage of Total Facilities in Each Time Period)
Time Period
Before 1940
1940-1949
1950-1959
1960-1969
1970-1979
1980-1989
1990-1995
Not Specified
Total2
Estimated Number of Facilities
Constructed1
478 (27%)
108 (6%)
199(11%)
318(18%)
207 (12%)
178 (10%)
113(6%)
147 (8%)
1,747(100%)
Estimated Number of Facilities
Starting Laundry or Dry-Cleaning
Operations
385 (22%)
107 (6%)
192(11%)
365 (21%)
247 (14%)
274 (16%)
164 (9%)
14 (<1%)
1,747(100%)
'Percentages reported are estimated based on the 193 in-scope facilities, extrapolated using appropriate survey weights
to represent the entire industry (including three facilities that were later determined to be out-of-scope because they
process only clean room items).
2Totals may not equal 100% due to rounding.
Source: 1994 Industrial Laundries Industry Questionnaire.
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                                                                         Chapter 4 - Industry Profile

the 1990s. The time periods for the start of laundering operations generally parallel the facility
construction time periods.

              Industrial laundries typically operate five days per week with one or two shifts per
day. Based on information provided in responses to the detailed questionnaire, the average
number of operating hours per day is 11 (the range is 5 to 24 hours) and the average number of
operating days per year is 261 (the range is 203 to 365 days).

              The types of laundering equipment used at these facilities include washing
equipment, drying equipment, and finishing equipment.  In addition, some facilities have machines
specially designed to launder specific items, such as continuous roll towels, mats and rugs, and
mops.  The most common types of washing equipment used in the industry are washers,
extractors, washer-extractors, tunnel washers, and dry-cleaning units; descriptions of these five
equipment types are provided below.

4.4.1          Washers, Extractors, and Washer-Extractors

              Washers in industrial laundries wash and rinse items without removing excess
water.  Extractors remove excess rinse water from items after laundering or, in some cases,
remove excess liquids from dirty items. Some washers automatically deposit the wash load into
adjacent extractors, but others must be emptied manually at the completion of the washing cycle
and the laundry transferred into an extractor. Washer-extractors come equipped with an internal
extractor where both the washing and extraction of excess liquids occurs in one machine.

              Conventional washers used in industrial  laundries can handle loads of 15 to 1,200
pounds, as reported by facilities responding to  the detailed questionnaire. The average capacity
reported by facilities in the detailed questionnaire is 421 pounds per load. A conventional washer
consists of a perforated horizontal  cylinder rotating in a shell. The cylinder is equipped with ribs
that lift the items as the cylinder rotates and drops them back into the washing solution.
Conventional washers are traditionally equipped with thermometers for temperature control,
gauges for control of water levels, timers, and  devices to reverse the direction of rotation every
four or five revolutions.

4.4.2          Tunnel Washers

              Tunnel washers are washers that operate in a continuous mode.  In a tunnel
washer, the items move forward through the washer by an "Archimedes screw" arrangement.
Rinse water at the discharge end of the washer is recycled back to  the first section of the washer.
Water, steam, and laundry chemicals are mechanically injected into the washer, and, following
washing, the load is moved by conveyer to extractors and dryers.

4.4.3          Dry-Cleaning Units

              Dry-cleaning units  are  similar to those used in water washing, except that the
fabrics are cleaned in an organic solvent instead of a detergent solution.  Standard dry-cleaning
equipment consists of a rotating cylinder in a stationary shell and one or more solvent storage

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                                                                           Chapter 4 - Industry Profile

tanks, a filter system for cleaning the solvent as it is used, a solvent/water separator, distillation
equipment for solvent purification, and often a device for recovering solvent vapors (a condenser
or an activated carbon filter).  The water separated from the solvent is discharged with other
process wastewater.

4.4.4         Equipment Use and Age

              Tables 4-9 and 4-10 present information on the types of laundry process
equipment reported by industrial laundries and the age of this equipment, respectively. As shown
in Table 4-9, 95 percent of the facilities have washer-extractors and 42 percent of the facilities
own separate washers and extractors.  Overall, separate washers and extractors are slightly older
than washer-extractors.  Facilities reported few tunnel washers and, of those reported, most were
purchased in the 1980s  or 1990s.  Most of the dry-cleaning units reported were also purchased in
the 1980s and 1990s.  Table 4-10 indicates that, in 1993,  68 percent of all laundry equipment was
reported to be 15 years old or less, even though only 16 percent of the facilities were built in the
past 15 years and only 25 percent of the facilities started  laundering operations in the past 15
years.

4.5           Pollution Reduction Activities

              Based on the detailed questionnaire responses, extrapolated to represent the entire
industry, 503 facilities have a written pollution reduction policy. Seven hundred forty (740)
facilities of the 1,747 extrapolated facilities conduct pollution prevention activities prior to the
laundering process (preprocess activities) and 473 of these facilities conduct pollution prevention
activities during the laundering process (in-process activities).

              Tables 4-11 and 4-12 list the types of preprocess and in-process pollution
prevention activities, respectively, reported in responses to the detailed questionnaire. Chapter 6
of this document discusses these activities in greater detail. Although the detailed questionnaire
specifically requested that wastewater treatment and water reuse/reduction  information not be
reported in response to these  particular questions, several facilities provided this information.
(Water reuse/reduction information was specifically requested by the detailed questionnaire in  a
different section and is discussed in greater detail in Chapter 5 of this document).

              Table 4-11 shows that the preprocess pollution reduction activity that was
performed by most facilities was the refusal of items with free liquids. These items are commonly
shop towels and printer towels.

              This industry  has a potential to incorporate preprocess and in-process reduction
practices such as the activities presented in Tables 4-11 and 4-12. In addition, industrial laundries
have an opportunity to recycle/reuse water and conserve  energy, helping to conserve natural
resources and reduce the need for end-of-pipe treatment or disposal. However, the pollution
reduction activities are so varied that identifying one set of BMPs to apply to all facilities is not
practical.
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                                                                              Chapter 4 - Industry Profile
                                          Table 4-9
        Types of Laundry Processing Equipment Reported in the Detailed
                                       Questionnaire
Type of Equipment1
Washer-Extractors (D02)
Separate Washers (D01)
Separate Extractors (DOS)
Dry-Cleaning Units (D04)
Tunnel Washers (DOS)
Continuous Roll Towel (CRT) Washers (DOT)
Closed-Loop Oil Washers (DOS)
Other (Unspecified) (D06)
Dip Tanks (D 10)
Mat/Rug Washers (D09)
Estimated Number of
Facilities Reporting
Equipment2
1,668
737
740
252
39
35
34
8
6
0
Estimated Percentage
of Total Facilities
Reporting Equipment
95.5
42.2
42.4
14.4
2.23
2.00
1.95
<1
<1
0
'The codes in parentheses are from the detailed questionnaire and were used in the questionnaire database.
Percentages and number of facilities reported are estimated based on the 193 in-scope facilities, extrapolated using
appropriate survey weights to represent 1,747 facilities.
Source: 1994 Industrial Laundries Industry Questionnaire.
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                                                                                                        Chapter 4 - Industry Profile
                                                          Table 4-10

                                           Age of Laundry Processing Equipment
                                           Reported in the Detailed Questionnaire
                               (Percentage of Equipment Type Installed in Each Time Period)
Time
Period
Before 1960
1960-1969
1970-1979
1980-1989
1990-1995
Not Specified
Total1
Estimated Number of Units Installed
Washers
43(1.3%)
529 (15.4%)
1,323(38.6%)
924 (26.9%)
524 (15.3%)
86(2.5%)
3,429
Washer-
Extractors
0
114(1.3%)
1,452(16.9%)
3,763 (43.7%)
2,930 (34%)
357(4.1%)
8,616
Extractors
22(1.2%)
193 (10.7%)
341 (18.9%)
857 (47.6%)
347 (19.3%)
42 (2.3%)
1,802
Dry-
Cleaning
Units
0
18(3.2%)
63(11.3%)
253
(45.4%)
219
(39.3%)
4 (<1%)
557
Tunnel
Washers
0
0
0
28 (45.2%)
34(54.8%)
0
62
CRT
Washers
0
4 (10.8%)
14(37.8%)
17(45.9%)
2 (5.4%)
0
37
Closed-
Loop Oil
Washers
0
1 1 (32.4%)
1 (2.9%)
22 (64.7%)
0
0
34
Mat/
Rug
Washers
0
0
0
0
0
0
0
Dip
Tanks
0
0
0
0
0
6 (100%)
6
Other
(Unspeci-
fied)
0
0
8 (100%)
0
0
0
8
Total
65 (<1%)
869 (6.0%)
3,202
(22%)
5,864
(40.3%)
4,056
(27.9%)
495 (3.4%)
14,551
to
   'Totals may not equal 100 percent due to rounding.
   Source: 1994 Industrial Laundries Industry Questionnaire.

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                                                                                    Chapter 4 - Industry Profile
                                             Table 4-11
                         Preprocess Pollution Reduction Activities
Activity
Items with Free Liquids Refused
Certain Items Refused
Miscellaneous Activities2
Items Centrifuged to Remove Liquids
Items Sent to Another Site with Wastewater Treatment
Steam/Air Stripping of Volatile Organics from Items
Items Dry-Cleaned Before Water Washing
Items Presorted to Remove Objects
Estimated Number
of
Facilities
Performing Activity
447
273
26
6
67
2
24
32
Estimated Percentage
of
Total Number of
Facilities Reporting
Pre-Laundering
Activities1
26
16
1
<1
4
<1
1
2
'Percentages are estimated based on the 193 in-scope facilities extrapolated using appropriate survey weights to
represent the entire industry.
Miscellaneous activities include a combination of the specific activities listed in the table.
Source:  1994 Industrial Laundries Industry Questionnaire.
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                                                                                       Chapter 4 - Industry Profile
                                              Table 4-12
                          In-Process Pollution Reduction Activities
Activity
Change in Laundering/Dry-Cleaning Chemicals Used2
Liquid Injection System for Wash Chemical Addition2
Wastewater Treatment
Improved Housekeeping2
Improved Training of Employees2
Water Softening2
Equipment Modifications/Installations
Removal of Lint Before Air Venting to Atmosphere
Miscellaneous Activities3
Reduced Fuel Consumption
Recycling of Laundry Materials
Estimated Number of
Facilities Performing
Activity
132
109
79
49
149
46
43
26
25
6
3
Estimated Percentage of
Total Number of Facilities
Reporting In-Process
Activities1
8
6
4
3
8
3
2
1
1
<1
<1
'Percentages are estimated based on the 193 in-scope facilities extrapolated using appropriate survey weights to
represent the entire industry.
2Data for these specific in-process pollution reduction activities were specifically requested in the detailed questionnaire.
Miscellaneous activities include a combination of the specific activities listed in this table.
Source:  1994 Industrial Laundries Industry Questionnaire.
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                                                                          Chapter 4 - Industry Profile

              The detailed questionnaire requested data for five specific in-process pollution
reduction activities. Facilities were requested to report any additional in-process pollution
reduction activities; these activities were labeled as "other." Based on descriptions provided by
the facilities, supplemental pollution prevention categories were then created for these "other"
activities. Table 4-12 presents data for the five activities specified in the questionnaire, as well as
for the remaining seven activities. According to responses to the detailed questionnaire, the
facilities reporting pollution prevention activities are equally distributed through all production
category sizes.

4.6           Trends in the Industry

              Several business and operating trends are emerging in the industrial laundries
industry, including changes in industrial laundry processes, facility size, and pollution reduction
technologies. These trends are discussed in greater detail below.

4.6.1         Trend Away from Dry Cleaning

              Based on information supplied by the industry and gathered by EPA on site visits,
EPA has determined that many facilities are moving away from dry-cleaning because of the
hazardous nature of the dry cleaning solvents and the expense of their disposal. Nineteen percent
of the facilities  responding to the detailed questionnaire reported owning dry-cleaning units. In
addition, the largest percentage (45 percent) of dry-cleaning units was purchased in the  1980s;
only 39 percent of all dry-cleaning units in operation today were purchased between  1990 and
1995, as shown in Table 4-10. The facilities that do operate dry cleaning units have moved away
from perchlorethylene as a solvent and are now using petroleum-based solvents.

4.6.2         Trend of Small Facilities being Purchased by Larger Firms

              In the past several years, there has been a trend toward large firms purchasing
smaller firms. Larger firms realize an economy of scale in their  operations and can often offer
lower prices than smaller companies. Many smaller single-owner companies are finding it difficult
to compete with the larger multi-facility firms due to the rising costs of both washroom  and
treatment equipment, the difficulty in raising capital, the utilization of new technologies, and the
requirement of more professional management (2).  Because of this increased difficulty to
compete, these smaller facilities are being purchased by the  larger firms.

              There are many reasons that the larger firms  are purchasing smaller facilities.  One
of the benefits of a large firm is that they have the capability to offer many specialized laundering
services, (e.g., laundering of clean room items). In essence, the larger firms are more diversified
and thus have the capability to process laundry and treat the wastewater generated from a variety
of customers. A 1997 analysis showed that the largest five  firms controlled about 55 percent of
the market (2).
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                                                                          Chapter 4 - Industry Profile

4.6.3         Trends in Equipment and Technologies

              The industry as a whole is moving towards automation in the washing, drying,
folding, and packaging of items laundered.  This includes practices ranging from installing
automatic detergent dispensers in the washers to purchasing washer-extractors instead of separate
washers and extractors.  Another trend is the installation of tunnel washers; these washers have a
built-in "reuse cycle" where the final rinse water is automatically cycled back to the first rinse.
The use of these washers lowers the average water used per pound of item laundered and thus
saves the facilities money.

               The preprocess pollution prevention activities reported by facilities responding to
the detailed questionnaire were initiated primarily in the late 1980s to 1994. The trend within the
industry appears to be to continue and increase pollution prevention activities.  Some of these
pollution prevention activities include the installation of more efficient washers and extractors,
detergents that allow for lower wash temperatures and a lower pH for the removal of oils and
grease  from the items which may result in lower residual solids volume and less energy use.
Chapter 6 of this document discusses pollution prevention practices in more detail.

4.7           Treatment Technologies in Use

              The principal types of wastewater treatment reported by industrial laundries in the
detailed questionnaire include gravity settling, screens, equalization/neutralization, air flotation,
clarification, and oil/water separation. Chapter 6 of this document discusses wastewater
treatment technologies used by the industry in greater detail.

4.8           Industry Definition

              One  of the steps in developing the proposed pretreatment standards and the final
action for the industrial laundries industry was to define the scope of the industry. EPA reviewed
data collected  from  responses to the detailed questionnaires, during site and sampling visits to
industrial laundries, and in previous Agency efforts to regulate this industry to define the scope of
the industry.

              Initially, EPA reviewed laundry processes and associated water use and
wastewater discharge practices to determine if facilities that used and/or discharged little or no
water could be eliminated from the scope of the industry.  Processes generating minimal or no
wastewater would have little to no pollutants being discharged into the wastewater stream
requiring control. Based on the data collected by EPA, 97 percent of all laundering performed by
industrial laundries is water washing. As discussed in this Chapter and Chapter 5, industrial
laundry treated by oil-only dust control mop treatment generates no wastewater. Therefore, EPA
excluded oil-only dust control mop treatment from the scope of the industry. Industrial laundry
treated by dry  cleaning generates little wastewater (ranging from zero gallons per pound of
laundry processed to 0.25 gallons per pound of laundry processed).  Because this process
generates an insignificant amount of wastewater, EPA excluded it from the scope of the industry.
Only water-washing laundering processes are included in the scope of the industry. In addition,
one facility reported dyeing of new items. EPA does not consider dyeing of new items to be  a

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                                                                         Chapter 4 - Industry Profile

laundering process; therefore, it is also excluded from the scope of the industry. Dyeing of used
textile items such as shop and printer towels/rags, which is often performed as part of the washing
process, is included in the scope of the industry.

              EPA looked at the types of items that were water-washed to determine if any
specific items should be excluded from the scope. EPA performed a statistical comparison of raw
wastewater from facilities laundering primarily linen items and raw wastewater from facilities
laundering primarily industrial laundry items. EPA also performed a statistical comparison of raw
wastewater from facilities laundering primarily linen items and raw wastewater from facilities
performing denim prewashing. A  summary of the statistical comparison is presented below and a
detailed discussion is presented in the Statistical Support Document (1).

              Data from EPA's sampling program and the detailed monitoring questionnaire
(DMQ) were used in comparing raw linen wastewater to raw industrial laundry wastewater.  EPA
used data from facilities processing between 60 and 99 percent linen items to represent raw linen
wastewater; EPA did not have data available for facilities processing 100 percent linen items.
EPA first performed a statistical analysis of the linen wastewater data and a statistical analysis of
the industrial laundry wastewater data to determine whether the data were statistically different.
If data for a pollutant were determined to be significantly different among the linen wastewater
data or among the industrial laundry wastewater data, that pollutant was not included in the
comparison. Based on this analysis,  a comparison of linen wastewater data and industrial laundry
wastewater data could be performed for eight pollutants.  These pollutants and the results of the
comparison are shown in Table 4-13. Table 4-13  shows that industrial laundry raw wastewater
concentrations are significantly different from linen raw wastewater concentrations for all eight
pollutants. Also, the  industrial laundry wastewater mean concentration is consistently at a
significantly higher value than the  linen wastewater mean concentration for all eight pollutants.
Although the linen facilities were processing less than 100 percent linen, EPA assumes that the
results of the statistical comparison would be valid if these facilities were processing  100 percent
linen items.

              Data from EPA's sampling program, the DMQ, and data obtained from a site visit
were used in comparing raw linen wastewater to raw denim prewash wastewater.  Raw denim
prewash wastewater data were available for only one facility.  EPA performed a statistical analysis
of the linen wastewater data to determine whether the data were statistically different. Based on
this analysis, a comparison of linen wastewater data and denim prewash wastewater data could be
performed for seven pollutants.  These pollutants  and the results of the comparison are shown on
Table 4-14.  Table 4-14 shows that raw linen wastewater concentrations are significantly higher
than raw denim prewash wastewater concentrations for cadmium, chromium, and copper, but the
concentrations are similar for the other five pollutants.

              Based on the results of the statistical analyses and the relatively low pollutant
concentrations found in linen and denim prewash wastewater, EPA decided to exclude linen and
denim prewash items from the scope of the industrial laundries industry.
                                           4-28

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                                                                          Chapter 4 - Industry Profile
                                       Table 4-13
 Comparison of Linen Facility and Industrial Laundry Facility Mean Pollutant
                                  Log Concentrations
Analyte
TPH (as
SGT-HEM)
Oil and
Grease (as
HEM)
Total
Suspended
Solids
Cadmium
Chromium
Copper
Iron
Zinc
Type of
Facility
Industrial
Laundry
Linen
Industrial
Laundry
Linen
Industrial
Laundry
Linen
Industrial
Laundry
Linen
Industrial
Laundry
Linen
Industrial
Laundry
Linen
Industrial
Laundry
Linen
Industrial
Laundry
Linen
Sample
Size
30
5
8
8
34
9
34
15
34
15
34
15
34
5
34
17
Mean log
Concentration
6.05
2.64
7.18
4.56
7.10
5.08
-2.66
-4.33
-1.47
-3.19
0.85
-1.54
3.23
1.00
1.47
1.15
Mean
Concentration
(mg/L)
425
14
1310
96
1206
161
.070
.013
.230
.041
2.32
.21
25.2
2.71
4.16
0.32
P-value
0.0001
0.0012
O.0001
0.0001
O.0001
0.0001
O.0001
0.0001
Significant at
a=0.01?
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Source: U.S. Environmental Protection Agency. Statistical Support Document for Proposed Pretreatment Standards for
Existing and New Sources for the Industrial Laundries Point Source Category. EPA 821-R-97-006, Washington, DC,
November 1997.
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                                                                          Chapter 4 - Industry Profile
                                       Table 4-14
Comparison of Linen Facility and Denim Prewash Facility Mean Pollutant Log
                                     Concentrations
Analyte
Oil and Grease (as
HEM)
Total Suspended
Solids
Cadmium
Chromium
Copper
Iron
Zinc
Type of
Facility
Linen
Denim
Prewash
Linen
Denim
Prewash
Linen
Denim
Prewash
Linen
Denim
Prewash
Linen
Denim
Prewash
Linen
Denim
Prewash
Linen
Denim
Prewash
Sample
Size
8
7
9
15
15
13
15
13
15
13
5
12
17
8
Mean log
(Cone)
4.56
2.96
5.08
6.15
-4.33
-5.68
-3.19
-4.47
-1.54
-2.85
1.00
-0.69
-1.15
-2.87
Mean
Concentration
(mg/L)
95
19
161
470
0.013
0.003
0.04
0.01
0.21
0.06
2.71
0.50
0.32
0.06
p-value
0.018
0.021
0.0001
0.0014
0.001
0.027
0.114
Significant
at a=0.01?
No
No
Yes
Yes
Yes
No
No
Source: U.S. Environmental Protection Agency. Statistical Support Document for Proposed Pretreatment Standards for
Existing and New Sources for the Industrial Laundries Point Source Category. EPA 821-R-97-006, Washington, DC,
November 1997.
                                           4-30

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                                                                          Chapter 4 - Industry Profile

              As part of comments on the proposed rule, EPA received data including
wastewater monitoring data on clean room items.  The term "clean room items" refers to specialty
items used in particle- and static-free environments by computer manufacturing, pharmaceutical,
biotechnology, aerospace, and other industrial customers. EPA evaluated the data and
determined that the concentrations of pollutants found in clean room item wastewater were lower
than the concentrations found in wastewater from most other items defined as industrial laundry
items in the proposed rule, and the characteristics of the clean room wastewater were similar to
linen wastewater. Thus, the data support the removal of clean room items from the definition of
industrial textile items, which excludes laundering of clean room items from the scope of the
industry. The clean room data are presented in Section 17 of the Industrial Laundries
Administrative Record.

              EPA also excluded on-site laundries from the applicability of the rule. The focus
of the rulemaking effort was industrial laundries that function independently of other industrial
activities that generate wastewater. EPA believes it is more appropriate to address on-site
laundry discharges at industrial facilities as part of the effluent controls from the facility as a
whole, for several reasons. First, many such facilities commingle laundry wastewater with
wastewater from other processes. Second, EPA anticipates  that contaminants removed from
laundered items  can best be treated with process wastewater containing similar contaminants.
EPA has already established categorical effluent guidelines and standards for 51 industries, as
listed in Appendix B of this document. These regulations generally apply to process-
contaminated wastewaters generated from the facility operations, including on-site laundering.
For example, the OCPSF effluent guidelines control discharges from garment laundering at
OCPSF facilities. For industries not yet covered by effluent limitations guidelines and standards,
EPA will examine these industries and their wastewater treatment processes in the context of the
entire industrial facility, not just the laundering portion of the facility.  Addressing on-site
laundering discharges along with other industrial discharges  in an industry allows EPA to examine
all of the production and processing equipment used by the industry, all of the discharges in an
industry, all the potential wastewater treatment applicable to the industry, and all of the economic
impacts of any such national regulation for the industrial category (or subcategory) as a whole.

              Based on these analyses, EPA developed the  following definition of industrial
laundries:

              An industrial laundry is any facility that launders industrial textile items from off
              site as a business activity (i.e., launders industrial textile items for other business
              entities for a fee or through a cooperative agreement).  Either the industrial
              laundry or the  off-site customer may own the industrial textile items.  This
              definition includes textile rental companies that perform laundering operations.
              Laundering in this definition means washing with water, including water washing
              following dry cleaning. Laundering exclusively through dry cleaning and oil
              cleaning of mops in a process that does not use any water are not included in this
              definition of laundering, even if these operations are conducted by an industrial
              laundry. Industrial textile items include, but are not limited to: industrial shop
              towels, printer towels/rags, furniture towels,  rags, uniforms, mops, mats, rugs,
                                           4-31

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                                                                          Chapter 4 - Industry Profile

              tool covers, fender covers, dust-control items, gloves, buffing pads, absorbents,
              and filters. If any of these items are used at hotels, hospitals, or restaurants, they
              are not considered industrial items.

              A facility that performs any laundering of industrial textile items is classified as an
industrial laundry, even if the facility  also performs activities that are not defined as industrial
laundering.  EPA does not include the following within the scope of the industrial laundries
industry: on-site laundering at industrial facilities (e.g., a chemical  manufacturer that washes
employee uniforms on site), laundering of industrial textile items originating from the same
business entity (e.g., a chain of auto repair shops that operates a central laundry for items from
individual shops), and exclusively laundering linen items, clean room items, denim prewash items,
new items (i.e., items directly from the textile manufacturer, not yet used for their intended
purpose), hospital, hotel,  and restaurant items or  any combination  of these items. However, EPA
does consider hotels, hospitals, or restaurants to be within the scope of the industrial laundries
industry if they launder industrial textile items originating from industrial facilities. Linen items
are sheets, pillow cases, blankets, bath towels and washcloths, hospital gowns  and robes,
tablecloths, napkins, tableskirts, kitchen textile items, continuous roll towels, laboratory coats,
household laundry (such as clothes, but not industrial uniforms), executive wear, mattress pads,
incontinence pads, and diapers.  EPA intends this to be an all-inclusive  list of linen items.

4.9           References

1.            U.S. Environmental Protection Agency. Statistical Support Document for
              Proposed Pretreatment Standards  for Existing and New Sources for the Industrial
              Laundries Point Source Category.  EPA-821-R-97-006, Washington, DC,
              November 1997.

2.            K. Koepper. "Don't Count Out More Public Company Acquisitions."  Industrial
              Launderer. August 1997:  page 24.
                                           4-32

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                                           Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern

                                       CHAPTER 5

                WATER USE, WASTEWATER CHARACTERIZATION,
                           AND POLLUTANTS OF CONCERN

5.1           Introduction

              This chapter discusses water use practices for the industrial laundries industry and
presents raw wastewater characterization data for item-specific and total wastewater streams at
industrial laundries.  This chapter also presents pollutants analyzed and pollutants of concern for
the industrial laundries industry. The water use data presented in this chapter are from 193
facilities responding to the  1994 Industrial Laundries Industry Questionnaire (detailed
questionnaire) that were considered in scope for the proposed rule.  These facilities include three
clean room facilities that are out of scope for the final action (the industry definition is presented
in Chapter 4 of this document).  Where appropriate, these data have been extrapolated using
statistically-derived survey weights to represent the entire industry.  The wastewater
characterization data presented in this chapter are from EPA sampling episodes and facility self
monitoring data from the Detailed Monitoring Questionnaire (DMQ).

              The remainder of this chapter is presented as follows:

              •      Section 5.2  discusses the sources of industrial laundry service water and
                     the uses of service water within the industry;

              •      Section 5.3  discusses wastewater volume by type of discharge;

              •      Section 5.4  discusses water conservation measures implemented by some
                     industrial laundries;

              •      Section 5.5  discusses the pollutants analyzed  in industrial laundry
                     wastewater;

              •      Section 5.6  identifies the pollutants of concern for the industrial laundries
                     industry;

              •      Section 5.7  discusses characterization of raw wastewater by item
                     laundered;

              •      Section 5.8  discusses characterization of total, heavy, and light raw
                     wastewater  streams; and

              •      Section 5.9  presents the characterization of EPA Method 1664
                     constituents.

              •      Section 5.10 presents the references used in this chapter.
                                            5-1

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                                           Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern

5.2           Sources of Service Water and Water Use

              This section provides information on sources of service water and water use
breakdown as reported by industrial laundries responding to the detailed questionnaire.

5.2.1         Sources of Service Water at Industrial Laundries

              Service water in the industrial laundries industry refers to any water used at a
facility, ranging from sanitary water to laundry process water. The primary source of service
water at industrial laundries is a water authority or municipal source. Well water is also used  as
service water at some facilities. None of the industrial laundries that responded to the detailed
questionnaire reported surface water as the direct intake source of their service water.  Table  5-1
presents the sources of service water for the industrial laundries industry; these data have been
extrapolated to represent the entire industry.

5.2.2         Use of Service Water  at Industrial Laundries

              Industrial  laundries use service water for a variety of purposes. Table 5-2 presents
the various uses of service water, the number of facilities reporting each use, and the percentage
of the total industry service water represented by each use. These amounts are based on the first
use of the service water.  Water recycle/reuse is not included in Table 5-2. Table 5-2 is based on
available data from the detailed questionnaire extrapolated to represent the entire industrial
laundries industry.

              Laundry  Process Water Use

              The majority of service water is used for laundry processes. As discussed in
Chapter 4 of this document, the laundering processes that use water and generate wastewater
include:

              •      Water washing;
              •      Dual-phase washing; and
              •      Dust control mop treatment (water washing of mops followed by oil
                     treatment).

              Facilities use varying amounts of laundry process water per pound of laundry
processed due to the following  factors:

              •      Type of items laundered;
              •      Customers;
              •      Soil loading on  items;
              •      Laundering chemicals used in wash formulas; and
              •      Laundry processing equipment used.
                                            5-2

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                                                   Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern
                                                Table 5-1
                                       Service Water Sources
Service Water Source
Water Authority /Municipal Source Only
Private Well Only
Water Authority /Municipal Source and Private
Well
Surface Water (Directly)
Total
Estimated Number of
Facilities By Source1
1,572
1
174
0
1,747
Estimated Percentage of Total
Facilities By Source
90
<1
10
0
100
'Based on responses to the detailed questionnaire from the 193 facilities that were in scope for the proposed rule
(including three clean room facilities determined to be out of scope for the final action), extrapolated to represent the
entire industrial laundries industry.
Source: 1994 Industrial Laundries Industry Questionnaire.
                                                     5O

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                                                    Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern
                                                 Table 5-2
                                           Service Water Use
Service Water Use
Laundry Process Water
Sanitary Water
Floor/Equipment Washing
Boiler Water
Vehicle Washing
Noncontact Cooling Water
Water Softener Regeneration Water
Other Uses Not Reported
Wastewater Treatment
Air Conditioning
Landscaping
Dish Washing
Irrigation
Total
Estimated
Number of Facilities By Use1
1,745
1,670
956
599
584
490
94
72
37
26
25
22
1
-
Estimated Percentage of Total
Service Water By Use
92.1
3.1
<1
1.8
<1
1.4
<1
<1
<1
<1
<1
<1
<1
100
'Number of facilities reporting water use is based on the responses to the detailed questionnaire from 193 facilities that
were in scope for the proposed rule (including three clean room facilities determined to be out of scope for the final
action), extrapolated to represent the entire industrial laundries industry.  The number of facilities reporting each service
water use is based on the first use of the service water; recycle/reuse is not included in Table 5-2. One facility reported
using service water first as noncontact cooling water, then as process water.  This facility has a survey weight of 2.
Source: 1994 Industrial Laundries Industry Questionnaire.
                                                      5-4

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                                          Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern

              The amount of process water used at a facility is most directly related to the
quantity of items laundered.  Figure 5-1 shows the distribution of facilities by amount of laundry
process water used per pound of laundry processed.  Water used in laundry processing comprises
the service water that is allocated to laundry processing, the process water that is reused before
and/or after wastewater treatment, and the water from other processes that is reused as laundry
process water (e.g., noncontact cooling water).  This water use was normalized to account for all
laundry production from processes that generate wastewater.  The average amount of wastewater
discharged per pound of laundry processed is 2.74 gallons per pound. Over 86 percent of the
industry uses between 1 and 4 gallons of process water per pound of laundry that is water-
washed.

              Water use is also related to type of item laundered. An analysis of item-specific
water use per pound of laundry processed (gal/lb) was conducted using data from facility
responses to the detailed questionnaire.  Table 5-3 presents the item-specific water use in gallons
of water per pound of laundry (gal/lb) by process.  These amounts were calculated from
information provided in the wash formulas reported by facilities in the detailed questionnaire. For
most items, EPA calculated a median water use ranging from 2.40 to 3.30 gal/lb.  Denim
prewashing of new items requires the highest use of water with a median value of 5.40 gal/lb.
Water washing  of buffing pads requires the  least amount of water (0.50 gal/lb), but this amount is
based on information from only one facility.

              Other Industrial Laundry Water Uses

              Although most of the incoming  service water used at industrial laundries (92.1
percent) is used as laundry process water, there are a number of other service water uses,  as
presented in Table 5-2. After laundry process water, sanitary water accounts for the second
largest amount  (3.1 percent) of total service water used at industrial laundries. Boiler water
accounts for the third most significant use of service water (1.8 percent), followed by noncontact
cooling water (1.4 percent).  Noncontact cooling water includes water used in evaporative
coolers and other heat exchangers.  Approximately 95 percent of the facilities that reported
noncontact cooling water use recycle their noncontact cooling water. In many instances, the
recycled water is used as laundry process water. Other uses of service water at industrial
laundries include vehicle washing, floor/equipment washing, and water used in wastewater
treatment systems. These uses each represent less than one percent of the total service water used
at industrial laundry facilities.

5.3           Wastewater Volume  by Type of Discharge

              All of the 193 facilities responding to the detailed questionnaire were considered in
scope for the proposed rule.  None of the facilities reported discharging laundry process
wastewater or noncontact cooling water directly to surface water. Residual wastewater found in
the sludge and oil wastes generated during wastewater pretreatment is also not discharged
directly, but disposed of off site or land applied. Table 5-4 presents process wastewater discharge
practices reported by the facilities that responded to the detailed questionnaire.
                                            5-5

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                                                                                             Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern
                                                      Average Gallons of Water Used Per Pound of Laundry Processed (gal/lb)
                    Figure 5-1.  Distribution of Facilities by Production-Normalized Laundry Process Water Use1
'Based on responses to the detailed questionnaire from the 193 facilities that were in scope for the proposed rule (including three clean room facilities determined to be
out of scope for the final action), extrapolated to represent the entire industrial laundries industry.

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                               Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern
          Table 5-3
Item-Specific Water Use1
Item2
Industrial Garments (B01)
Shop Towels (B02)
Pnnter Towels (BOS)
Floor Mats (B04)
Mops, Dust Cloths, Tool Covers, etc. (BOS)
Linen Supply Garments (B06)
Linen Flatwork/Full Dry (B07)
Health-Care Items (BOS)
Fender Covers (B09)
Continuous Roll Towels (BIO)
Clean Room Garments (B 1 1 )
Other (B 13)
Laundry Bags (B14)
Family Laundry (B15)
Process3
A01
A02
A01
A01
A02
A01
A02
A01
A07
A01
A01
A01
A01
A01
A01
A01
A01
A01
Mean
(gal/lb)
2.66
3.73
4.18
4.12
3.70
1.87
2.10
3.00
3.03
3.51
3.03
2.53
3.55
2.88
2.93
4.00
1.45
3.35
Median
(gal/lb)
2.40
2.80
3.10
3.60
3.80
1.60
2.10
2.80
2.90
3.30
2.80
2.40
2.70
2.40
3.00
4.00
1.45
3.05
Standard
Deviation
(gal/lb)
1.47
2.46
8.73
2.32
0.29
0.98
—
1.57
1.58
1.62
1.34
1.02
3.65
4.32
0.52
—
0.45
1.28
Estimated Number of
Facilities in Calculations
148
3
126
65
3
163
1
83
45
99
121
67
65
79
9
1
2
6

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                                                                                                    Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern
                                                                   Table 5-3 (Continued)
Item2
New Items (B 17)
Executive Wear (B 18)
Miscellaneous NOG (Not Our Goods) (B19)
Rewashed Items (B20)
Filters (B23)
Buffing Pads (B24)
Process3
A01
A13
A01
A01
A01
A01
A01
Mean
(gal/lb)
3.00
5.63
4.74
3.00
2.18
4.20
0.50
Median
(gal/lb)
2.75
5.40
2.90
3.00
2.10
4.20
0.50
Standard
Deviation
(gal/lb)
1.17
1.76
4.67
	
0.77
1.20
—
Estimated Number of
Facilities in Calculations
6
3
5
1
5
2
1
       1 The process/item gallon-per-pound ratios were calculated from water-washing formula data provided in Table C of the detailed questionnaire. This analysis was
^     performed using data from 193 facilities that were in scope for the proposed rule (including three clean room facilities determined to be out of scope for the final
oo     action); the data were not extrapolated to represent the entire industry. The ratios for each formula at a facility were calculated and the ratios were averaged for each
       item/process combination at individual facilities.  The number of times the formula was used per day was taken into account. The facility-specific ratios were then
       used to calculate an industry mean and median gallon/pound ratio for each item/process combination. There were no usable data to calculate the water use
       requirements for absorbents, clean wipes, or airline carpet and seat covers.
       2 The codes in parentheses reflect the item codes used in the detailed questionnaire.
       3 Process codes used in the detailed questionnaire:
                       A01 - Water Washing
                       A02 - Dual Phase Washing: Petroleum solvent wash followed by water washing
                       A07 - Dust Control Mop Treatment: Water washing followed by oil treatment
                       A13 - Denim Prewash.
       Source: 1994 Industrial Laundries Industry Questionnaire.

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                                                 Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern
                                              Table 5-4
                       Discharge Practices of Industrial Laundries1
Discharge Practice
Discharge to POTW
Off-Site Disposal
Land Application
Discharge to Surface Water
Estimated Number of
Facilities Discharging
Laundry Process
Wastewater
(Percent of Facilities)
1,747 (100%)
221 (13%)
84 (5%)
0 (0%)
Estimated Number of
Facilities Discharging
Noncontact Cooling Water
(Percent of Facilities)
313 (18%)
0 (0%)
0 (0%)
0 (0%)
'Based on responses to the detailed questionnaire from 193 facilities that were in scope for the proposed rule (including
three clean room facilities that were determined to be out of scope for the final action), extrapolated to represent the
entire industrial laundries industry.
Source: 1994 Industrial Laundries Industry Questionnaire
                                                   5-9

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                                          Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern

              Figure 5-2 shows the distribution of facilities by amount of laundry process
wastewater discharged per pound of laundry processed. The total wastewater discharged
comprises the laundry process wastewater that is discharged to a POTW, the laundry process
wastewater that is land applied, and the laundry process wastewater that is shipped off site for
disposal. This calculated wastewater discharge was normalized for all  laundry production from
processes that generate wastewater.  Over 60 percent of the facilities discharge between 1.5 and
3.5 gallons of process wastewater per pound of laundry that is water-washed.

              A comparison of the values in Figures 5-1 and 5-2 shows that more laundry
process water is used than is discharged. This difference is due to evaporation losses and laundry
process wastewater recycle/reuse before and after wastewater treatment. (The average
evaporation loss reported by facilities in the detailed questionnaire was approximately 10 percent.
For 81 percent of the facilities, the difference between laundry process water use and discharge is
less than 0.5 gal/lb. Most of the reported amounts of laundry process wastewater discharged are
estimates; less than 15 percent of the facilities measure the amount of wastewater that is
discharged at their facilities.

5.4           Water Conservation Measures

              Approximately 85 percent of the facilities that responded to the detailed
questionnaire reported performing some type of water conservation practice. Table 5-5 presents
activities that were reported as standard water conservation techniques at industrial laundries.
Table 5-5 also presents the reported water use reduction due to implementation of these
conservation practices. As shown in the table, prompt attention to faulty equipment, leaks, and
other problems is practiced by the greatest number of laundries, followed by routine monitoring of
water use. Chapter 6 provides additional information on wastewater recycle/reuse.

5.5           Pollutants Analyzed in Industrial Laundry Wastewater

              EPA collected data to determine the conventional, priority, and nonconventional
pollutants to be regulated for the industrial laundries proposed rule. Conventional pollutant
parameters are defined in section 304(a)(4) of the Clean Water Act (CWA) and in 40 CFR Part
401.16 and include biochemical oxygen demand (BOD5), total suspended solids (TSS), total
recoverable oil and grease, pH, and fecal coliform. These pollutants are subject to regulation as
specified in sections 301(b)(2)(E) and 304(b)(4)(B) of the CWA. Toxic or priority pollutants are
defined in section 307(a)(l) of the CWA.  The list of priority pollutants, presented in Table C-l in
Appendix C of this document, consists of 126 specific pollutants  listed in 40 CFR Part 423,
Appendix A.  Sections 301(b)(2)(C) and 304(b)(2)(B) of the CWA authorize EPA to regulate
priority pollutants. Nonconventional pollutants are those that are neither priority pollutants or
conventional  pollutants.  Sections 301(b)(2)(F), 301(g), and 304(b)(2)(B) of the CWA give EPA
the authority to regulate  nonconventional pollutants.

              EPA considered four conventional,  98 priority, and 213 nonconventional organic,
metal, and elemental pollutant parameters for potential  control for the industrial laundries
industry. Three hundred twelve (312) of these pollutants are listed in The Industrial
                                           5-10

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                                                                                           Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern
                    400
                    100
                                                Average Gallons of Water Discharged Per Pound of Laundry Processed (gal/lb)
             Figure 5-2.  Distribution of Facilities by Production-Normalized Laundry Process Wastewater Discharge1
'Based on responses to the detailed questionnaire from the 193 facilities that were in scope for the proposed rule (including three clean room facilities determined to be
out of scope for the final action), extrapolated to represent the entire industrial laundries industry.

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                                               Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern
                                            Table 5-5
              Water Conservation Practices and Water Use Reduction
Water Conservation Practice
Prompt Attention to Faulty Equipment, Leaks, and Other
Problems
Routine Monitoring of Water Use
Installation of Laundering Equipment That Uses Less
Water
Implementation of Alternative Laundry Wash Formulas
That Require Less Water
Reuse of Noncontact Cooling Water as Process Makeup
Water
Recycling/Reuse of Laundry Wastewater Before
Treatment
Implementation of Alternative Production Processes
That Require Less Water
Other Practices
Installation of Automatic Monitoring and Alarm Systems
on In-plant Discharges
Recycle/Reuse of Laundry Wastewater After Treatment
Reuse of Nonlaundry Wastewater as Laundry Process
Water
Water
Reduction
Range
(gal/day)
0 - 25,000
0 - 57,693
16 - 165,000
6 - 26,000
150-31,623
60 - 53,000
82 - 20,000
200 - 6,000
500 - 7,985
3,000 - 29,000
8,967
Estimated
Number of
Facilities
With This
Practice1
1,180
996
266
261
246
155
44
19
17
13
4
Percentage
of Total
Facilities
With This
Practice1
68%
57%
15%
15%
14%
9%
2%
1%
1%
1%
<1%
'Based on responses to the detailed questionnaire from 193 facilities that were in scope for the proposed rule,
extrapolated to represent entire industry.
Source:  1994 Industrial Laundries Industry Questionnaire.
                                                5-12

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                                          Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern

Technology Division List of Analytes, which was derived from the List of Lists (1). Three
pollutants not on this list were also considered for regulation. EPA analyzed industrial laundry
wastewater for these 315 pollutants during the industrial laundries sampling program, which is
discussed in Chapter 3 of this document.  Table C-2 in Appendix C lists the 315 pollutants
analyzed by EPA in industrial laundry wastewater during this sampling program. EPA used data
collected from seven industrial laundries during the period of 1993-1996 for selecting pollutants
of concern.

              EPA used EPA Method 1664 to analyze oil and grease and total  petroleum
hydrocarbons because the other approved methods (EPA Methods 413.1, 413.2, and 415.1) use
fireon, which is being phased out of use in EPA's CWA and RCRA programs. Method 1664
measures oil and grease as hexane extractable material (HEM) and measures TPH as silica gel
treated hexane extractable material (SGT-HEM)2.

              Several conventional and priority pollutants were not considered for regulation for
the industrial laundries industry based on the following: information  collected during the 1985-
1987 industrial laundries sampling program, described in Chapter 3; information collected from
the Detailed Monitoring Questionnaire (DMQ), described in Chapter 3; and EPA's knowledge of
industrial laundry wastewater. The DMQ was sent to 37 facilities selected from respondents to
the 1994 Industrial Laundries Industry Questionnaire.  The DMQ recipients submitted monitoring
data collected at their facility during 1993.

              EPA did not consider the following conventional and priority pollutants for
regulation for the industrial laundries industry:

              •      Fecal coliform;

              •      Asbestos;

              •      2,3,7,8-Tetrachlorodibenzo-p-dioxin (TCDD);

              •      Twenty-five (25) pesticides and PCBs (pollutants 89 through 113 on Table
                    C-l in Appendix C); and

              •      Cyanide.

              EPA does  not expect fecal coliform bacteria to be present in industrial  laundry
wastewaters because the laundering chemicals added to laundry process water and the
temperature of the water will likely destroy fecal coliform that may have been present on
laundered items.
2In Method 1664 (promulgated at 64 FR 263125 on May 14, 1999), EPA defines SGT-HEM as non-polar matenal
(NPM).  Throughout this document and the Industrial Laundries Record, EPA refers to SGT-HEM as TPH.

                                          5-13

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                                           Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern

              EPA does not expect asbestos to be present in industrial laundry wastewaters
because it is not expected to be present on items laundered by industrial laundries or generated
during the washing process.

              EPA does not expect dioxins and furans, including 2,3,7,8-TCDD, to be present
on industrial laundry items and EPA does not expect dioxins and furans to be formed during
industrial laundry processes. Dioxins and furans were not detected in available industrial laundry
wastewater samples collected during three sampling episodes during the 1985-1987 sampling
program (dioxins and furans were not analyzed for during the other two episodes). One facility
responding to the DMQ questionnaire submitted data for 2,3,7,8-TCDD; this compound was not
detected at the facility.  A review of POTW permits for 92 industrial laundries indicated that none
of the permits includes limits for dioxins and furans.

              EPA did not consider PCBs for regulation because PCBs were not detected in
available industrial laundry wastewater samples  from four sampling episodes during the 1985-
1987 sampling program (PCBs were not analyzed for during one other episode). Four facilities
responding to the DMQ submitted data for up to seven PCBs; PCBs were not detected at any of
the four facilities. A review of publicly owned treatment works (POTW) permits for 92 industrial
laundries indicated that only one of the permits includes limits for PCBs.

              EPA did not consider any pesticides for regulation because most of the priority
pollutant pesticides were detected in less than 10 percent of available industrial laundry
wastewater samples and the presence of pesticides in industrial laundry wastewater is a site-
specific issue related to a particular customer base. Pesticides are best addressed through case-
by-case review of specific circumstances rather than a national regulation. Industrial laundry
wastewater was analyzed for pesticides at four facilities during the 1985-1987 sampling program.
In addition, 10 DMQ facilities submitted pesticide data.  Of the 18 priority pollutant pesticides,
the following three pesticides were detected in 10  percent or greater of industrial laundry
wastewater samples:

              •       Heptachlor (10 percent);
              •       delta-BHC (14 percent); and
              •       Endosulfan sulfate (14 percent).

              Heptachlor was detected at 2 facilities (sampled at  14 facilities),  delta-BHC was
detected at 2 facilities (sampled at 11 facilities),  and endosulfan sulfate was detected at 4 facilities
(sampled at 11 facilities).  Endosulfan sulfate and dieldrin were the only priority pollutant
pesticides detected at concentrations greater than 0.1  mg/L, and detections at these
concentrations occurred at only one facility of 11 facilities  sampled for each pesticide. Also,
review of POTW permits for 92 industrial laundries indicated that  only one of the permits includes
limits for pesticides.

              EPA did not consider cyanide for regulation because cyanide was detected  at most
facilities at insignificant concentrations. Cyanide was analyzed at five facilities during the 1985-
1987 sampling program, and 16 DMQ facilities  submitted cyanide data. Only two of these
facilities reported detected concentrations of cyanide greater than 1 mg/L and only one of these

                                           5-14

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                                           Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern

facilities had an average detected concentration greater than 1 mg/L. Cyanide was not detected at
five facilities, and cyanide was detected at average concentrations of less than 0.1 mg/L at eight
facilities.  The maximum contaminant level for cyanide, as established in the National Primary
Drinking Water Regulations (40 CFR Part 141), is 0.2 mg/L, as free cyanide. Only one DMQ
facility reported an average cyanide concentration greater than 0.2 mg/L. This facility did not
report the analytical method used.  Two facilities from the 1985-1987 sampling program had
average cyanide concentrations greater than 0.2 mg/L, but these concentrations were measured as
total cyanide.

5.6           Identification of Pollutants of Concern

              In assessing the 315 pollutant parameters analyzed during the  1993-1996 industrial
laundries sampling program, EPA used the following criteria to identify pollutant parameters of
concern. EPA reduced the list of 315 pollutants to 72 pollutants for further consideration using
the following criteria:

              •      Pollutants never detected in any samples collected during seven sampling
                     episodes during the 1993-1996 industrial laundries sampling program.
                     Table 5-6 lists the  175 pollutants meeting this criterion.

              •      Pollutants detected in less than 10 percent of samples collected during
                     seven sampling episodes during the 1993-1996 industrial laundries
                     sampling program.  Table 5-7 lists the 50 pollutants meeting this criterion.

              •      Pollutants identified during screening, but not quantified due to a lack of an
                     acceptable analytical method. EPA used analytical Method 1620 (ICP) to
                     quantitate certain metals and elemental pollutants. Eight metal and
                     elemental pollutants that were detected in industrial laundry samples
                     greater than 10 percent of the time were not analyzed in a quantitative
                     manner.  Analyses for these pollutants were not  subject to the quality
                     assurance/quality control (QA/QC) procedures required by analytical
                     Method 1620. These results were used for screening purposes only and the
                     metals and elements detected were excluded from the pollutants of concern
                     because they are not quantified. Table 5-8 lists these metal pollutants.

              •      Pollutants detected in  source water at comparable concentrations to
                     industrial laundry raw wastewater. Three nonconventional metal pollutants
                     (calcium, magnesium, and sodium) were excluded because EPA  believes
                     that these pollutants are not present in industrial laundry wastewater at
                     significant levels.
                                           5-15

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                            Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern
                         Table 5-6

Pollutants Not Detected in Any Samples Analyzed during the
     1993-1996 Industrial Laundries Sampling Program
Pollutant
Acenaphthene
Acenaphthylene
Anthracene
Benzidine
Benzo (a) anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(ghi)perylene
Benzo(k)fluoranthene
Bis(2-chloroisopropyl)ether
Bromomethane
Chloroethane
Chloromethane
Chrysene
Di-n-propylnitrosamine
Dibenzo(a,h)anthracene
Fluoranthene
Fluorene
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclopentadiene
Hexachloroethane
Indeno(l ,2,3-cd)pyrene
N-Nitrosodimethylamine
Nitrobenzene
Pyrene
Tribromomethane
Diethyl Ether
Diphenyldisulfide
Class Code
TXO
TXO
TXO
TXO
TXO
TXO
TXO
TXO
TXO
TXO
TXO
TXO
TXO
TXO
TXO
TXO
TXO
TXO
TXO
TXO
TXO
TXO
TXO
TXO
TXO
TXO
TXO
NCO
NCO
Pollutant
Vinyl Chloride
1 , 1 ,2-Trichloroethane
1 ,2-Dichlorobenzene
1 ,2-Dichloropropane
1 ,2,4-Trichlorobenzene
1 , 3 -Dichlorobenzene
1 ,4-Dichlorobenzene
2-Chloronaphthalene
2,4-Dinitrotoluene
3,3' -Dichlorobenzidine
4-Bromophenyl Phenyl Ether
4-Chlorophenylphenyl Ether
Aniline, 2,4,5-Trimethyl
Aramite
Benzanthrone
Benzenethiol
Benzonitrile, 3,5-dibromo-4-
hydroxy-
Beta-Naphthylamine
Biphenyl, 4-Nitro
Carbazole
Carbon Bisulfide
Chloroacetonitrile
cis- 1 ,3-Dichloropropene
Crotonaldehyde
Crotoxyphos
Dibenzothiophene
Dibromomethane
Phenacetin
Phenothiazine
Class Code
TXO
TXO
TXO
TXO
TXO
TXO
TXO
TXO
TXO
TXO
TXO
TXO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
                            5-16

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           Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern
Table 5-6 (Continued)
Pollutant
Ethane, Pentachloro-
Ethyl Cyanide
Ethyl Methacrylate
Ethyl Methanesulfonate
Ethylenethiourea
Hexachloropropene
lodomethane
Isosafrole
Longifolene
Malachite Green
Mestranol
Methapyrilene
Methyl Methanesulfonate
N-Nitrosodi-N-butylamine
N-Nitrosodiethylamine
N-Nitrosomethylethylamine
N-Nitrosomethylphenylamine
N-Nitrosopiperidine
N,N-Dimethylform amide
o-Anisidine
o-Toluidine
o-Toluidine, 5-Chloro-
p-Chloroaniline
p-Dimethylaminoazobenzene
p-Nitroaniline
Pentachlorobenzene
Perylene
1,3,5-Trithiane
1 ,4-Dinitrobenzene
1 ,4-Naphthoquinone
1 ,5-Naphthalenediamine
2-(Methylthio)benzothiazole
Class Code
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
Pollutant
Pronamide
Pyridine
Resorcinol
Squalene
Thianaphthene
Thioacetamide
Thioxanthe-9-one
Toluene, 2,4-diamino
Trans- 1 ,4-dichloro-2-butene
Triphenylene
Vinyl Acetate
1 -Bromo-2-chlorobenzene
1 -Bromo-3-chlorobenzene
1 -Chloro-3-nitrobenzene
1 -Naphthylamine
1 -Phenylnaphthalene
1,1,1 ,2-Tetrachloroethane
1 ,2-Dibromo-3 -chloropropane
1 ,2-Dibromoethane
1 ,2,3 -Trichlorobenzene
1 ,2,3 -Tri chloropropane
1 ,2,3-Trimethoxybenzene
1 ,2,4,5-Tetrachlorobenzene
1 ,2,3,4-Diepoxybutane
1,3 -Butadiene, 2-Chloro
1 ,3-Dichloro-2-propanol
1 , 3 -Dichloropropane
Bismuth
Cerium
Dysprosium
Erbium
Europium
Class Code
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCM
NCM
NCM
NCM
NCM
            5-17

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                                               Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern
                                     Table 5-6 (Continued)
Pollutant
2-Isopropylnaphthalene
2-Methylbenzothioazole
2-Nitroaniline
2-Phenylnaphthalene
2-Picoline
2-Propen-l-ol
2-Propenenitrile, 2-Methyl-
2,3-Benzofluorene
2,3 -Dichloronitrobenzene
2,3,4,6-Tetrachlorophenol
2,6-Di-tert-butyl-p-benzoquinone
2,6-Dichloro-4-nitroaniline
2,6-Dichlorophenol
3 - Chloropropene
3-Methylcholanthrene
3 -Nitro aniline
3,3' -Dimethoxy benzidine
3 ,6-Dimethy Iphenanthrene
4-Aminobiphenyl
4-Chloro-2-nitroaniline
4,4'-Methylenebis(2-chloroaniline)
4,5-Methylene Phenanthrene
5-Nitro-o-toluidine
7, 1 2-Dimethy lbenz(a)anthracene
Thulium
Tungsten
Uranium
Class Code
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCO
NCM
NCM
NCM
Pollutant
Gadolinium
Gallium
Germanium
Gold
Hafnium
Holmium
Indium
Lanthanum
Lutetium
Neodymium
Niobium
Osmium
Palladium
Platinum
Praseodymium
Rhenium
Rhodium
Ruthenium
Samarium
Scandium
Tantalum
Tellurium
Terbium
Thorium
Ytterbium
Zirconium

Class Code
NCM
NCM
NCM
NCM
NCM
NCM
NCM
NCM
NCM
NCM
NCM
NCM
NCM
NCM
NCM
NCM
NCM
NCM
NCM
NCM
NCM
NCM
NCM
NCM
NCM
NCM

NCM - Nonconventional metal or element.
NCO - Nonconventional organic.
TXO - Toxic organic.
                                                5-18

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                                   Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern
                                 Table 5-7

Pollutants Detected in Less Than 10 Percent of Samples Analyzed During the
             1993-1996 Industrial Laundries Sampling Program
Priority Organics
Acrylonitrile
Benzene
Bis(2-chloroethoxy)methane
Bis (2-chloroethyl)ether
Bromodichloromethane
2-Chloroethylvinyl ether
2-Chlorophenol
Dibromochloromethane
1 . 1 -Dichloroethane
1 ,2-Dichloroethane
1 , 1 -Dichloroethene
2,4-Dichlorophenol
Diethyl phthalate
2,4-Dimethylphenol
Dimethyl phthalate
2,4-Dinitrophenol
2,6-Dinitrotoluene
2-Nitrophenol
4-Nitrophenol
N-Nitrosodiphenylamine
Pentachlorophenol
Phenanthrene
Phenol,2-Methyl-4,6-Dinitro-
2-Propenal
1 , 1 ,2,2-Tetrachloroethane
Tetrachloromethane
Trans- 1 ,3-Dichloropropene
2,4,6-Trichlorophenol
Nonconventional Organics
Acetophenone
Aniline
Biphenyl
Dibenzofuran
2,3 -Dichloroaniline
Dimethyl sulfone
1,4-Dioxane
Diphenylamine
Diphenyl ether
2-Hexanone
Isobutyl alcohol
1 -Methylfluorene
1 -Methylphenanthrene
Methyl methacrylate
N-Nitro somorpholine
o-Cresol
Safrole
Styrene
Trichlorofluoromethane
2, 3 ,6-Trichlorophenol
2,4,5-Trichlorophenol
Tripropyleneglycol methyl ether






                                    5-19

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                                        Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern
                                     Table 5-8
Semiquantitative Metal and Elemental Pollutants Excluded from the Pollutants
                of Concern for the Industrial Laundries Industry
                               Nonconventional Metals and
                                       Elements
                                        Iodine
                                        Indium
                                        Lithium
                                      Phosphorus
                                       Potassium
                                        Silicon
                                       Strontium
                                        Sulfur
                                        5-20

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                                           Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern

              •      Pollutants likely to be regulated on a case-by-case basis by POTWs. The
                     following six pollutants were eliminated from the pollutant-of-concern list:

                            pH:  this pollutant is typically regulated as necessary by POTWs.
                            pH is not considered for national regulation for the industrial
                            laundries industry.

                            Total orthophosphate, total phosphorous, and total hydrolyzable
                            phosphate: Table 5-9 presents the average influent concentrations,
                            effluent concentrations, and percent removals for these pollutants
                            by both the dissolved air flotation (DAF) and chemical precipitation
                            treatment technologies (based on six sampling episodes between
                            1993-1998).  These pollutants were not considered for national
                            regulation for the industrial laundries industry since they would be
                            removed incidentally by the DAF and chemical precipitation
                            treatment technologies.

                            Surfactants (nonionic (CTAS) and anionic (MBAS)):  Table 5-9
                            presents the average influent  concentrations, effluent
                            concentrations, and percent removals for these pollutants by both
                            the dissolved air flotation and chemical precipitation treatment
                            technologies  (based on six sampling episodes between 1993-1998).
                            These pollutants were analyzed to evaluate the effect of emulsions
                            on treatment technologies for the industrial laundries industry.
                            Surfactants are not considered for national regulation for the
                            industrial laundries industry since they would be removed
                            incidentally by the DAF and chemical precipitation treatment
                            technologies.

              In addition to the pollutants  above, EPA eliminated total solids from further
consideration. Total solids is a measure of total  dissolved solids and total suspended  solids.
Industrial laundry wastewater contains both total suspended solids and total solids.  Because the
measurement of total solids includes total suspended solids  and because the treatment
technologies under consideration as the bases of the regulation are designed to remove the total
suspended solids but not the dissolved solids, EPA eliminated total solids from further
consideration.

              Of the 315 pollutants considered for regulation, 72 were identified as pollutant
parameters of concern, including 31 priority pollutants (18 organic pollutants and 13 metal and
elemental pollutants), three conventional pollutants, and 38  nonconventional pollutants (24
organic pollutants, 11 metal and elemental pollutants, and three other nonconventional
pollutants).  Table 5-10 presents these 72 pollutants, along with the number of times each
pollutant was analyzed and detected in untreated industrial laundry wastewater, and the
corresponding mean, minimum, and maximum concentrations based on data collected between
1993 and 1996 (seven facilities).
                                            5-21

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                            Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern
                          Table 5-9

  Average Influent Concentrations, Effluent Concentrations,
      and Removals for Phosphorous and Surfactants by
Chemical Precipitation or Dissolved Air Flotation Technologies
Pollutant
Average Influent
(mg/L)
Average Effluent
(mg/L)
Average Percent
Removal
Chemical Precipitation
Total Hydrolyzable
Phosphorous
Total Orthophosphate
Total Phosphorous
Surfactants (anionic)
Surfactants (nonionic)
75.6
2.80
30.8
12.0
149
9.43
1.70
6.83
6.23
116
88
39
78
48
22
Dissolved Air Flotation
Total Hydrolyzable
Phosphorous
Total Orthophosphate
Total Phosphorous
Surfactants (anionic)
Surfactants (nonionic)
10.8
6.88
21.4
7.64
446
5.15
2.95
8.94
0.818
202
52
57
58
89
55
                             5-22

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                                                                               Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern
                                                            Table 5-10
                                Pollutants of Concern for the Industrial Laundries Industry1
Pollutant of Concern
Number of
Times
Analyzed
Number of
Times
Detected
Percent
Detected
(%)
Concentration in Untreated Wastewater (mg/L)
Minimum
Maximum
Mean
Conventionals
Biochemical Oxygen Demand 5-Day (BOD,)
Oil and Grease (measured as HEM)
Total Suspended Solids (TSS)
46
48
46
46
48
45
100.00
100.00
97.83
218.00
71.50
4.00
9810.00
11790.00
7000.00
2343.50
1943.92
1773.93
Priority Organics
1,1,1 -Trichloroethane
1 ,2-Diphenylhydrazine
4-Chloro-3-methylphenol
Bis(2-ethylhexyl) Phthalate
Butyl Benzyl Phthalate
Chlorobenzene
Chloroform
Di-w-butyl Phthalate
Di-w-octyl Phthalate
Ethylbenzene
Isophorone
Methylene Chloride
Naphthalene
Phenol
Tetrachloroethene
Toluene
trans- 1 ,2-Dichloroethene
Trichloroethene
48
47
47
47
47
48
48
47
47
48
47
48
47
47
48
48
48
48
22
5
8
43
20
8
25
20
25
38
5
25
42
23
35
44
1
7
45.83
10.64
17.02
91.49
42.55
16.67
52.08
42.55
53.19
79.17
10.64
52.08
89.36
48.94
72.92
91.67
2.08
14.58
0.01
0.02
0.01
0.04
0.01
0.01
0.01
0.01
0.01
0.01
0.01
0.01
0.01
0.01
0.01
0.01
0.01
0.01
156.64
41.32
2.06
42.01
74.42
1.41
1.19
9.98
2.61
18.74
1.00
16.26
18.75
0.96
46.22
90.97
0.10
20.00
4.01
1.14
0.14
6.80
2.69
0.08
0.07
0.73
0.30
1.24
0.12
0.63
2.59
0.15
1.97
6.72
0.03
0.48
to

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                                                                                            Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern
                                                             Table 5-10 (Continued)
Pollutant of Concern
Number of
Times
Analyzed
Number of
Times
Detected
Percent
Detected
(%)
Concentration in Untreated Wastewater (mg/L)
Minimum
Maximum
Mean
Nonconventional Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pentanone
ซ-Terpineol
Benzoic Acid
Benzyl Alcohol
Hexanoic Acid
w-Xylene
w-Decane
w-Docosane
w-Dodecane
w-Eicosane
w-Hexacosane
w-Hexadecane
w-Octacosane
w-Octadecane
w-Tetracosane
w-Tetradecane
w-Triacontane
o-&/?-Xylene
/7-Cresol
/7-Cymene
Pentamethy Ibenzene
48
47
48
48
47
47
47
47
48
47
47
47
47
47
47
47
47
47
47
47
48
47
47
47
32
32
46
26
17
34
21
14
40
41
31
40
43
27
43
21
42
25
37
29
40
1
16
11
66.67
68.09
95.83
54.17
36.17
72.34
44.68
29.79
83.33
87.23
65.96
85.11
91.49
57.45
91.49
44.68
89.36
53.19
78.72
61.70
83.33
2.13
34.04
23.40
0.05
0.01
0.05
0.05
0.01
0.05
0.01
0.01
0.01
0.01
0.01
0.01
0.01
0.01
0.01
0.01
0.01
0.01
0.01
0.01
0.01
0.01
0.01
0.01
272.29
2.24
603.15
65.27
5.20
12.23
12.52
1.81
25.29
712.40
3.04
105.57
84.57
3.73
91.57
1.44
19.36
8.34
41.58
1.00
17.80
0.20
19.81
2.33
9.07
0.41
20.95
2.65
0.33
1.77
0.81
0.12
2.29
51.60
0.35
14.37
4.06
0.36
6.70
0.19
1.92
0.46
4.39
0.19
1.59
0.06
1.43
0.22
to

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                                                                                            Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern
                                                             Table 5-10 (Continued)
Pollutant of Concern
Number of
Times
Analyzed
Number of
Times
Detected
Percent
Detected
(%)
Concentration in Untreated Wastewater (mg/L)
Minimum
Maximum
Mean
Priority Metals and Elements
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
47
47
47
47
47
47
47
47
47
47
47
47
47
34
15
18
44
45
47
45
28
45
12
24
6
46
72.34
31.91
38.30
93.62
95.74
100.00
95.74
59.57
95.74
25.53
51.06
12.77
97.87
0.01
0.010
0.010
0.010
0.010
0.04
0.03
0.010
0.01
0.010
0.010
0.010
0.010
8.24
0.18
0.02
0.70
7.31
14.90
23.80
0.01
2.87
0.26
0.17
0.13
29.40
0.26
0.02
0.003
0.10
0.46
3.17
1.71
0.001
0.27
0.03
0.02
0.01
5.02
Nonconventional Metals and Elements
Aluminum
Barium
Boron
Cobalt
Iron
Manganese
Molybdenum
Tin
Titanium
Vanadium
Yttrium
47
47
47
47
47
47
47
47
47
47
47
47
47
36
37
47
47
43
32
45
31
15
100.00
100.00
76.60
78.72
100.00
100.00
91.49
68.09
95.74
65.96
31.91
0.03
0.03
0.03
0.000
0.06
0.02
0.010
0.02
0.01
0.010
0.010
20.99
6.26
37.20
3.10
96.60
1.77
5.17
0.58
1.32
0.19
0.04
7.96
1.51
2.31
0.24
27.70
0.56
0.53
0.11
0.23
0.04
0.01
to

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                                                                                                Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern
                                                                Table 5-10 (Continued)
Pollutant of Concern
Number of
Times
Analyzed
Number of
Times
Detected
Percent
Detected
(%)
Concentration in Untreated Wastewater (mg/L)
Minimum
Maximum
Mean
Bulk Nonconventionals
Chemical Oxygen Demand (COD)
Total Organic Carbon (TOC)
Total Petroleum Hydrocarbon (measured as
SGT-HEM)
47
47
43
47
47
43
100.00
100.00
100.00
80.00
106.00
7.00
212000.00
37800.00
4543.00
12730.57
2208.32
880.86
            'Results are based on sampling data collected between 1993 and 1996 from seven industrial laundries facilities.
to

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                                          Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern

5.7           Characterization of Raw Wastewater by Item Laundered

              As discussed in Chapter 4 of this document, items laundered at industrial laundries
can have significantly different pollutant loads based on item type and customer. This section
presents raw wastewater characterization data for specific items laundered for the 72 pollutants of
concern detected in industrial laundry wastewater.  Table 5-11 presents for the 72 pollutants the
mean pollutant concentration by item type.  Table C-3 in Appendix C of this document presents
for the 72 pollutants the minimum, maximum, and mean concentrations, as well as the number of
times each pollutant was analyzed, the number of times the pollutant was detected,  and the
percentage of times the pollutant was detected, by item type based on sampling data from nine
facilities and DMQ data.

5.8           Characterization of Total. Heavy, and Light Raw Wastewater Streams

              This section presents raw wastewater characterization data for total, heavy, and
light raw wastewater streams at industrial laundries. The heavy and light wastewater streams
were designated as such by the sampled facilities; generally, the heavy wastewater stream is
generated from laundering items with high pollutant loadings and the light wastewater stream is
generated from laundering items with low pollutant loadings. At some facilities, the heavy stream
is generated from wastewater from the first several breaks of laundering a variety of items. The
heavy stream is typically treated and combined with the untreated light stream prior to discharge
to  a POTW.

              EPA sampling program data and detailed monitoring questionnaire (DMQ) data
from facilities  that do not split their heavy and light wastewater streams were used to characterize
total raw wastewater streams. The total stream is then discharged, with or without treatment, to
a POTW. EPA sampling program data from facilities that split their wastewater streams were
used to characterize heavy and light wastewater streams.

              Tables 5-12 through 5-14 present for 72 pollutants of concern the mean
concentrations for heavy, light, and total raw wastewater streams based on data collected through
EPA's sampling program (nine facilities) and data from the detailed monitoring questionnaire.
Table C-4 in Appendix C of this document presents for the 72 pollutants of concern the minimum,
maximum, and mean concentrations, as well as the number of times the pollutant was analyzed,
the number of times the pollutant was detected, and the percentage of times the pollutant was
detected. In general, the concentrations of pollutants in heavy wastewater streams  are greater
than the concentrations of pollutants in total wastewater streams, and the concentrations of
pollutants in total wastewater streams are greater than the concentrations of pollutants in light
wastewater streams.

5.9           Characterization of Method 1664 Constituents

              In response to comments on the proposed rule, EPA conducted a characterization
study on wastewater generated at industrial laundries to determine the specific  constituents of oil
and grease and TPH, measured using EPA Method 1664. EPA collected  influent and effluent
                                          5-27

-------
                             Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern
                          Table 5-11
Wastewater Characterization for Item-Specific Wastewater
                    at Industrial Laundries
Pollutant of Concern
Mean Concentration (mg/L)1
Industrial
Garments
Shop Towels
Printer Towels
Mats
Conventionals
Biochemical Oxygen Demand 5-Day (BOD5)
Oil and Grease (measured as HEM)
Total Suspended Solids (TSS)
350
149
304
2,780
3,250
4,450
3,940
5,890
1,250
179
105
690
Priority Organics
1, 1, 1-Trichloroethane
1,2-Diphenylhydrazine
4-Chloro-3-methylphenol
Bis(2-ethylhexyl) Phthalate
Butyl Benzyl Phthalate
Chlorobenzene
Chloroform
Di-ซ-butyl Phthalate
Di-ซ-octyl Phthalate
Ethylbenzene
Isophorone
Methylene Chloride
Naphthalene
Phenol
Tetrachloroethene
Toluene
trans- 1,2-Dichloroethene
Trichloroethene
0.0400
0.110
0.130
0.838
0.111
0.0400
0.0400
0.0736
0.0583
0.104
0.194
0.0406
0.107
0.0544
0.0400
0.0486
0.0400
0.0400
4.13
1.07
0.795
3.63
1.46
0.252
0.292
0.558
0.538
5.27
9.58
4.22
2.91
0.310
8.92
5.33
0.367
0.247
4.50
1.00
0.433
19.0
5.55
0.467
0.370
3.20
1.24
13.2
0.500
0.614
9.64
0.500
3.92
20.5
0.371
0.476
0.860
0.0200
0.0100
1.70
0.0350
0.0100
0.0100
0.114
0.0369
0.147
0.186
0.226
0.0172
0.0134
0.0676
0.654
0.0100
0.0100
Nonconventional Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pentanone
ฐ<-Terpineol
Benzoic Acid
Benzyl Alcohol
Hexanoic Acid
m-Xylene
ซ-Decane
ซ-Docosane
ซ-Dodecane
ซ-Eicosane
ซ-Hexacosane
ซ-Hexadecane
ซ-Octacosane
0.200
0.102
0.226
0.200
0.0550
0.353
0.132
0.0962
0.0100
0.807
0.271
1.26
0.471
0.117
0.602
0.0821
5.40
0.826
3.98
1.88
0.956
2.55
9.26
0.305
2.12
42.2
1.10
19.1
25.1
1.40
10.0
0.858
3.09
0.836
49.7
2.07
1.07
3.30
0.500
0.433
1.44
90.6
0.668
23.1
1.29
2.01
9.51
0.402
0.314
0.0100
1.10
0.254
0.0463
0.156
0.0520
0.0611
0.265
0.995
0.0175
0.0654
0.0206
0.0211
0.0206
0.0134
                              5-28

-------
           Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern
Table 5-11 (Continued)
Pollutant of Concern
Mean Concentration (mg/L)1
Industrial
Garments
Shop Towels
Printer Towels
Mats
Nonconventional Organics (Continued)
ซ-Octadecane
ซ-Tetracosane
ซ-Tetradecane
ซ-Triacontane
o-&p-Xylene
p-Cresol
p-Cymene
Pentamethylbenzene
0.445
0.281
0.612
0.123
0.0100
0.0417
0.0873
0.0550
11.2
1.95
15.0
0.719
1.47
0.305
2.05
0.534
2.43
0.605
7.89
0.626
1.08
0.433
12.4
0.500
0.0160
0.0394
0.0145
0.0292
0.151
0.0100
0.0100
0.0100
Priority Metals and Elements
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
0.312
0.00907
0.000605
0.0269
0.0959
0.688
0.238
0.000395
0.0999
0.00767
0.0146
0.00293
1.50
0.198
0.0224
0.000890
0.358
0.490
6.48
6.52
0.00183
0.599
0.0145
0.139
0.00390
13.5
0.0556
0.00313
0.00100
0.0253
2.65
11.0
8.91
0.000230
0.101
0.0177
0.207
0.00767
3.62
0.0204
0.00905
0.000775
0.0147
0.167
1.31
0.711
0.00142
0.152
0.00305
0.0168
0.00680
2.42
Nonconventional Metals and Elements
Aluminum
Barium
Boron
Cobalt
Iron
Manganese
Molybdenum
Tin
Titanium
Vanadium
Yttrium
4.85
0.273
0.187
0.0134
10.9
0.148
0.0213
0.0722
0.150
0.00707
0.00178
13.1
4.08
1.99
0.288
55.8
1.09
0.382
0.370
0.232
0.0420
0.00794
8.22
4.53
0.670
0.614
8.51
0.898
2.10
0.0990
0.184
0.00900
0.00570
10.3
0.376
0.0818
0.0184
24.7
0.318
0.0321
0.0938
0.364
0.0273
0.00675
Bulk Nonconventionals
Chemical Oxygen Demand (COD)
Total Organic Carbon (TOC)
Total Petroleum Hydrocarbon (measured as SGT-
HEM)
1,170
367
47.4
13,300
2,030
1,760
16,900
2,740
1,730
515
111
48.5
            5-29

-------
           Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern
Table 5-11 (Continued)
Constituent Name
Mean Concentration (mg/L)1
Mops
Steam-Tumbled
Printer Towels
Items Dry Cleaned
Prior to Water
Washing
Linen Supply
Items
Conventionals
Biochemical Oxygen Demand 5-Day (BOD5)
Oil and Grease (measured as HEM)
Total Suspended Solids (TSS)
1,150
286
1,100
1,440
1,720
1,320
113
NA
82
881
108
269
Priority Organics
1, 1, 1-Trichloroethane
1,2-Diphenylhydrazine
4-Chloro-3-methylphenol
Bis(2-ethylhexyl) Phthalate
Butyl Benzyl Phthalate
Chlorobenzene
Chloroform
Di-ซ-butyl Phthalate
Di-ซ-octyl Phthalate
Ethylbenzene
Isophorone
Methylene Chloride
Naphthalene
Phenol
Tetrachloroethene
Toluene
trans- 1,2-Dichloroethene
Trichloroethene
1.04
0.200
0.100
1.10
0.895
0.0550
0.0565
0.434
0.108
0.0550
0.100
0.0767
0.471
0.100
0.0550
0.0597
0.0550
0.0550
0.0118
0.0800
0.0400
8.77
0.366
0.0100
0.0100
0.117
0.325
0.0100
0.0400
0.0100
0.226
0.0432
0.0100
0.0436
0.0100
0.0100
NA
NA
NA
NA
NA
NA
NA
NA
NA
0.0458
NA
NA
NA
NA
NA
0.225
NA
NA
0.00833
0.0200
0.0100
0.574
0.0944
0.00833
0.889
0.0306
0.0572
0.00833
0.0100
0.0112
0.108
0.0674
0.00833
0.0241
0.00833
0.00833
Nonconventional Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pentanone
ฐ<-Terpineol
Benzoic Acid
Benzyl Alcohol
Hexanoic Acid
m-Xylene
ซ-Decane
ซ-Docosane
ซ-Dodecane
ซ-Eicosane
ซ-Hexacosane
ซ-Hexadecane
1.13
0.432
2.22
0.275
0.100
2.35
0.610
0.216
0.100
0.965
0.157
8.07
0.291
0.210
1.07
0.0500
0.0400
0.681
0.0500
0.0400
0.977
0.819
0.384
0.0151
0.499
0.131
2.65
3.05
0.0904
91.6
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
0.0500
0.0164
0.0607
0.0500
0.0339
0.150
0.202
0.0279
0.0100
2.63
0.0392
0.270
0.0862
0.0267
0.160
            5-30

-------
           Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern
Table 5-11 (Continued)
Constituent Name
Mean Concentration (mg/L)1
Mops
Steam-Tumbled
Printer Towels
Items Dry Cleaned
Prior to Water
Washing
Linen Supply
Items
Nonconventional Organics (Continued)
ซ-Octacosane
ซ-Octadecane
ซ-Tetracosane
ซ-Tetradecane
ซ-Triacontane
o-&p-Xylene
p-Cresol
p-Cymene
Pentamethylbenzene
0.221
0.875
0.100
1.47
0.163
0.100
0.100
0.100
0.100
0.0633
1.48
0.0724
12.8
0.0587
0.0146
0.0400
0.0400
0.0400
NA
NA
NA
NA
NA
NA
NA
NA
NA
0.0212
0.0720
0.0630
0.140
0.0551
0.0100
0.0100
0.108
0.0100
Priority Metals and Elements
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
0.0294
0.0102
0.00100
0.0212
0.101
1.97
0.903
0.00466
0.106
0.0123
0.0111
0.00620
3.00
0.0261
0.00380
0.00100
0.0358
0.275
4.86
0.957
0.000200
0.0372
0.0230
0.0653
0.0120
2.10
NA
0.00500
NA
0.0825
0.0933
0.668
0.519
0.000150
0.0200
NA
0.00500
NA
0.450
0.114
0.156
0.00100
0.0219
0.0492
0.527
0.151
0.00165
0.0771
0.151
0.0291
0.00700
0.381
Nonconventional Metals and Elements
Aluminum
Barium
Boron
Cobalt
Iron
Manganese
Molybdenum
Tin
Titanium
Vanadium
Yttrium
9.78
0.571
0.190
0.0360
17.9
0.358
0.0612
0.0785
0.184
0.0220
0.004500
2.80
1.63
0.0500
0.202
2.62
0.277
2.64
0.0761
0.0178
0.0221
0.00500
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
3.08
0.301
0.0970
0.00990
3.26
0.0812
0.0263
0.0290
0.0654
0.00990
0.00470
            5-31

-------
                                                  Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern
                                      Table 5-11 (Continued)
Constituent Name
Mean Concentration (mg/L)1
Mops
Steam-Tumbled
Printer Towels
Items Dry Cleaned
Prior to Water
Washing
Linen Supply
Items
Bulk Nonconventionals
Chemical Oxygen Demand (COD)
Total Organic Carbon (TOC)
Total Petroleum Hydrocarbon (measured as SGT-HEM)
5,410
518
111
9,000
1,770
468
638
NA
NA
844
401
12
'The detection limit concentration was used in calculations for data points reported as nondetects.
NA - Not available.  No data were available for this constituent.
                                                   5-32

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                            Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern
                         Table 5-12
Wastewater Characterization Data for Heavy Wastewater
              Streams at Industrial Laundries
Pollutant of Concern
Mean Concentration1
(mg/L)
Conventionals
Biochemical Oxygen Demand 5-Day (BOD5)
Oil and Grease (measured as HEM)
Total Suspended Solids (TSS)
4,160
2,950
2,320
Priority Organics
1,1,1 -Trichloroethane
1 ,2-Diphenylhydrazine
4-Chloro-3-methylphenol
Bis(2-ethylhexyl) Phthalate
Butyl Benzyl Phthalate
Chlorobenzene
Chloroform
Di-w-butyl Phthalate
Di-w-octyl Phthalate
Ethylbenzene
Isophorone
Methylene Chloride
Naphthalene
Phenol
Tetrachloroethene
Toluene
trans- 1 ,2-Dichloroethene
Trichloroethene
1.16
2.60
0.260
11.3
8.89
0.271
0.296
1.30
0.599
3.65
0.207
0.854
4.76
0.303
1.79
9.69
0.271
1.27
Nonconventional Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pentanone
ซ-Terpineol
25.5
0.892
8.49
5.82
0.379
                            5-33

-------
           Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern
Table 5-12 (Continued)
Pollutant of Concern
Mean Concentration1
(mg/L)
Nonconventional Organics (Continued)
Benzoic Acid
Benzyl Alcohol
Hexanoic Acid
w-Xylene
w-Decane
w-Docosane
w-Dodecane
w-Eicosane
w-Hexacosane
w-Hexadecane
w-Octacosane
w-Octadecane
w-Tetracosane
w-Tetradecane
w-Triacontane
o-&/>-Xylene
/>-Cresol
/>-Cymene
Pentamethy Ibenzene
3.36
1.56
0.210
4.47
86.5
0.504
29.5
4.28
0.354
9.11
0.370
4.00
0.289
7.23
0.366
3.59
0.204
3.16
0.412
Priority Metals and Elements
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
0.788
0.0125
0.00142
0.121
0.296
5.37
1.60
0.000816
0.266
0.0174
0.199
            5-34

-------
                                      Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern
                          Table 5-12 (Continued)
Pollutant of Concern
Mean Concentration1
(mg/L)
Priority Metals and Elements (Continued)
Thallium
Zinc
0.00989
7.79
Nonconventional Metals and Elements
Aluminum
Barium
Boron
Cobalt
Iron
Manganese
Molybdenum
Tin
Titanium
Vanadium
Yttrium
9.97
3.63
4.93
0.449
42.1
1.51
0.668
0.130
0.344
0.0381
0.0101
Bulk Nonconventionals
Chemical Oxygen Demand (COD)
Total Organic Carbon (TOC)
Total Petroleum Hydrocarbon (measured as SGT-HEM)
13,700
2,790
1,440
'The detection limit concentration was used in calculations for data points reported as
nondetects.
                                       5-35

-------
                            Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern
                         Table 5-13
Wastewater Characterization Data for Light Wastewater
             Streams at Industrial Laundries
Pollutant of Concern
Mean Concentration1
(mg/L)
Conventionals
Biochemical Oxygen Demand 5-Day (BOD5)
Oil and Grease (measured as HEM)
Total Suspended Solids (TSS)
568
154
344
Priority Organics
1,1,1 -Trichloroethane
1 ,2-Diphenylhydrazine
4-Chloro-3-methylphenol
Bis(2-ethylhexyl) Phthalate
Butyl Benzyl Phthalate
Chlorobenzene
Chloroform
Di-w-butyl Phthalate
Di-w-octyl Phthalate
Ethylbenzene
Isophorone
Methylene Chloride
Naphthalene
Phenol
Tetrachloroethene
Toluene
trans- 1 ,2-Dichloroethene
Trichloroethene
0.0160
0.220
0.0411
1.10
0.0690
0.0160
0.0455
0.104
0.0667
0.0620
0.0400
0.0213
0.358
0.105
0.0977
0.0553
0.0160
0.0160
Nonconventional Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pentanone
ซ-Terpineol
0.147
0.0566
0.518
0.240
0.123
                            5-36

-------
           Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern
Table 5-13 (Continued)
Pollutant of Concern
Mean Concentration1
(mg/L)
Nonconventional Organics (Continued)
Benzoic Acid
Benzyl Alcohol
Hexanoic Acid
w-Xylene
w-Decane
w-Docosane
w-Dodecane
w-Eicosane
w-Hexacosane
w-Hexadecane
w-Octacosane
w-Octadecane
w-Tetracosane
w-Tetradecane
w-Triacontane
o-&/>-Xylene
p-Creso\
p-Cymene
Pentamethy Ibenzene
0.306
0.102
0.0557
0.0555
0.354
0.0591
0.973
0.124
0.0465
0.330
0.0432
0.0850
0.0680
0.103
0.0492
0.0765
0.0400
0.0473
0.0787
Priority Metals and Elements
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
1.32
0.00653
0.000938
0.0211
0.113
0.858
0.348
0.000715
0.101
0.0133
0.00432
            5-37

-------
                                                 Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern
                                     Table 5-13 (Continued)
Pollutant of Concern
Mean Concentration1
(mg/L)
Priority Metals and Elements (Continued)
Thallium
Zinc
0.00313
1.47
Nonconventional Metals and Elements
Aluminum
Barium
Boron
Cobalt
Iron
Manganese
Molybdenum
Tin
Titanium
Vanadium
Yttrium
4.65
0.421
0.391
0.0264
10.3
0.184
0.0357
0.0625
0.206
0.0138
0.00313
Bulk Nonconventionals
Chemical Oxygen Demand (COD)
Total Organic Carbon (TOC)
Total Petroleum Hydrocarbon (measured as SGT-HEM)
1,410
338
85
'The detection limit concentration was used in calculations for data points reported as nondetects.
                                                  5-38

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                              Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern
                           Table 5-14

Wastewater Characterization Data for Total Raw Wastewater
                Streams at Industrial Laundries
Pollutant
Mean Concentration1
(mg/L)
Conventionals
Biochemical Oxygen Demand 5-Day (BOD5)
Oil and Grease (measured as HEM)
Total Suspended Solids (TSS)
933
1,670
1,200
Priority Organics
1,1,1 -Trichloroethane
1 ,2-Diphenylhydrazine
4-Chloro-3-methylphenol
Bis(2-ethylhexyl) Phthalate
Butyl Benzyl Phthalate
Chlorobenzene
Chloroform
Di-w-butyl Phthalate
Di-w-octyl Phthalate
Ethylbenzene
Isophorone
Methylene Chloride
Naphthalene
Phenol
Tetrachloroethene
Toluene
trans- 1 ,2-Dichloroethene
Trichloroethene
0.283
0.0918
0.0684
4.99
0.140
0.131
0.0359
0.245
0.0910
0.634
0.154
0.366
1.47
0.0777
3.91
2.64
0.0204
0.0346
Nonconventional Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pentanone
ซ-Terpineol
2.51
0.166
10.9
1.67
0.258
                               5-39

-------
           Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern
Table 5-14 (Continued)
Pollutant
Mean Concentration1
(mg/L)
Nonconventional Organics (continued)
Benzoic Acid
Benzyl Alcohol
Hexanoic Acid
w-Xylene
w-Decane
w-Docosane
w-Dodecane
w-Eicosane
w-Hexacosane
w-Hexadecane
w-Octacosane
w-Octadecane
w-Tetracosane
w-Tetradecane
w-Triacontane
o-&/>-Xylene
p-Creso\
p-Cymene
Pentamethy Ibenzene
0.648
0.143
0.125
4.35
73.6
0.659
6.16
1.97
0.413
4.76
0.0853
1.78
1.51
4.44
0.144
2.48
0.0585
0.138
0.242
Priority Metals and Elements
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
0.0913
0.0183
0.00598
0.0641
0.315
1.74
0.955
0.00128
0.305
0.0550
0.0316
            5-40

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                                      Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern
                          Table 5-14 (Continued)
Pollutant
Mean Concentration1
(mg/L)
Priority Metals and Elements (continued)
Thallium
Zinc
0.0190
2.85
Nonconventional Metals and Elements
Aluminum
Barium
Boron
Cobalt
Iron
Manganese
Molybdenum
Tin
Titanium
Vanadium
Yttrium
8.24
1.31
0.689
0.169
39.5
0.627
0.363
0.278
0.251
0.0678
0.0199
Bulk Nonconventionals
Chemical Oxygen Demand (COD)
Total Organic Carbon (TOC)
Total Petroleum Hydrocarbon (measured as SGT-HEM)
6,090
1,160
682
'The detection limit concentration was used in calculations for data points reported as nondetects.
                                       5-41

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                                          Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern

samples from six facilities that operate DAF or chemical precipitation and that were previously
sampled by EPA.  See Chapter 3 of this document for a description of EPA's Method 1664
Characterization Study.

For the study, EPA analyzed wastewater samples for HEM, SGT-FIEM, volatile organics, and
semivolatile organics. EPA also analyzed extracts from the HEM and SGT-HEM procedures for
volatile organics and semivolatile organics. The data from this study are in the Industrial
Laundries Administrative Record.

Volatile organics were only detected in the HEM extracts at one facility; the only volatile organics
detected in the HEM extracts were o-xylene and m-&p-xylene. Semivolatile organics were
detected in all HEM and SGT-HEM extracts. Tables 5-15 and 5-16 show, for influent and
effluent samples, respectively, the semivolatile organics detected in the extracts  and the number of
detects and average concentration of the detects in the wastewater, HEM extract, and SGT-HEM
extract samples. Tables 5-15 and 5-16 also show the HEM and SGT-HEM concentrations. For
one facility,  no effluent concentrations are reported because there were zero percent recoveries in
the matrix spike/matrix spike duplicate samples.  The effluent results for this facility were
excluded due to matrix interference.

The analytes that were detected in the influent samples for both the HEM and SGT-HEM extracts
were 2-methylnaphthalene, bis(2-ethylhexyl) phthalate, w-decane, w-docosane, w-dodecane, n-
eicosane, w-hexacosane, w-hexadecane, w-octacosone,  w-octadecane, w-tetracosane, w-tetradecane,
and naphthalene. The highest concentrations detected in the influent samples for both the HEM
and SGT-HEM extracts were for bis(2-ethylhexyl) phthalate, w-decane, w-dodecane, n-
hexadecane, w-octadecane, and w-tetradecane.  Only bis(2-ethylhexyl) phthalate, w-eicosane, n-
hexadecane, w-octadecane, and w-tetradecane were detected in the effluent samples for both the
HEM and SGT-HEM extracts. These analytes were detected in lower concentrations in the
effluent samples than in the influent samples.

Based on the characterization study,  EPA was able to identify several constituents measured as
part of the SGT-HEM (TPH) parameter. Most of the constituents identified in the influent
samples were w-alkanes, as well as naphthalene, bis(2-ethylhexyl) phthalate and  2-
methylnaphthalene.  The identified constituents, however, represent only a small portion of the
total SGT-HEM (TPH) measurement.

5.10          References

1.             U.S. Environmental Protection Agency. List of Lists: A Catalog of Analytes and
              Methods.  121W-4005. Washington, DC, August 1991.
                                           5-42

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                                                         Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern
                                       Table 5-15

Summary of the Semivolatile Organic Pollutants Detected in Influent Samples during the
                       EPA Method 1664 Characterization Study
Pollutant
HEM
SGT-HEM
1 ,2-Diphenylhydrazine
2-Methylnaphthalene
4-Chloro-3-methylphenol
Acetophenone
oc-Terpineol
Aniline
Benzoic Acid
Benzyl Alcohol
Bis(2-ethylhexyl)
Phthalate
Butyl Benzyl Phthalate
Di-w-butyl Phthalate
Di-w-octyl Phthalate
Diethyl Phthalate
Diphenylamine
Fluoranthene
Fluorene
Total
Number of
Wastewater
Samples
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
Total Number
of Nondetects
for Pollutant
in Wastewater
Samples
0
0
3
4
3
5
0
6
2
2
I
0
0
5
5
4
5
5
Average
Concentration
in Wastewater
Sample1 (ug/L)
1,920,000
391,000
2,380
1,180
420
1,360
340
1,340
2,270
1,090
4,780
299
912
1,390
1,340
1,350
1,180
1,180
Total Number
of HEM
Extract
Samples
NA
NA
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
Total Number
of Nondetects
for Pollutants
in HEM
Extracts
NA
NA
5
3
6
6
3
6
6
6
0
1
3
4
6
6
6
6
Average
Concentration
in HEM
Extracts1
(ug/L)
NA
NA
299
173
111
111
224
111
556
111
1,400
139
363
232
111
111
111
111
Total
Number of
SGT-HEM
Extract
Samples
NA
NA
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
Total
Number of
Nondetects
for
Pollutants in
SGT-HEM
Extracts
NA
NA
6
4
6
6
6
6
6
6
1
6
6
6
6
6
6
6
Average
Concentration
in SGT-HEM
Extracts1
(ug/L)
NA
NA
222
109
111
111
111
111
556
111
321
111
111
111
111
111
111
111

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                                                                                                           Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern
                                                                       Table 5-15 (Continued)
Pollutant
Hexanoic Acid
Isophorone
w-Decane
w-Docosane
w-Dodecane
w-Eicosane
w-Hexacosane
w-Hexadecane
w-Nitrosodiphenylamine
w-Tetradecane
Naphthalene
o-Cresol
/>-Cresol
p-Cymene
Phenanthrene
Phenol
Pyrene
Tripropyleneglycol
Methyl Ether
Total
Number of
Wastewater
Samples
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
Total Number
of Nondetects
for Pollutant
in Wastewater
Samples
3
4
0
0
0
0
2
0
4
0
0
4
6
2
2
0
3
1
Average
Concentration
in Wastewater
Sample1 (ug/L)
539
1,520
26,800
1,660
20,500
3,720
1,400
9,750
2,680
6,320
1,240
1,450
507
793
212
91.8
1,180
182,000
Total Number
of HEM
Extract
Samples
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
Total Number
of Nondetects
for Pollutants
in HEM
Extracts
6
5
0
1
0
0
2
0
6
0
2
6
6
4
6
6
6
6
Average
Concentration
in HEM
Extracts1
(ug/L)
111
117
2,330
240
1,590
777
206
1,290
222
1,570
583
111
111
296
111
111
111
1,100
Total
Number of
SGT-HEM
Extract
Samples
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
Total
Number of
Nondetects
for
Pollutants in
SGT-HEM
Extracts
6
6
3
0
0
0
-3
3
0
6
0
2
6
6
6
6
6
6
6
Average
Concentration
in SGT-HEM
Extracts1
(ug/L)
111
111
1150
210
1180
705
193
1220
222
1400
217
111
111
111
111
111
111
1100
'The detection limit concentration was used in calculations for data points reported as nondetects.

NA - Not applicable.
HEM - Hexane extractable material.
SGT-HEM - Silica gel treated-hexane extractable material.

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                                                         Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern
                                       Table 5-16

Summary of the Semivolatile Organic Pollutants Detected in Effluent Samples during the
                       EPA Method 1664 Characterization Study
Pollutant
HEM
SGT-HEM
1 ,2-Diphenylhydrazine
2-Methylnaphthalene
4-Chloro-3-methylphenol
Acetophenone
oc-Terpineol
Aniline
Benzoic Acid
Benzyl Alcohol
Bis(2-ethylhexyl)
Phthalate
Butyl Benzyl Phthalate
Di-w-butyl Phthalate
Di-w-octyl Phthalate
Diethyl Phthalate
Diphenylamine
Fluoranthene
Fluorene
Hexanoic Acid
Isophorone
Total
Number of
Wastewater
Samples
5
4
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
Total Number
of Nondetects
for Pollutant
in Wastewater
Samples
0
0
3
5
I
5
0
3
0
2
I
3
5
4
5
5
5
5
I
I
Average
Concentration
in Wastewater
Sample1 (ug/L)
45,900
11,000
27.5
10
99.2
10
274
13.8
1,130
292
154
10.2
10
10.2
10
10
10
10
331
289
Total Number
of HEM
Extract
Samples
NA
NA
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
Total Number
of Nondetects
for Pollutants
in HEM
Extracts
NA
NA
5
5
5
5
1
5
5
5
1
4
5
5
5
5
5
5
5
4
Average
Concentration
in HEM
Extracts1
(ug/L)
NA
NA
48
24
24
24
25.4
24
120
24
67.4
26
24
24
24
24
24
24
24
42
Total
Number of
SGT-HEM
Extract
Samples
NA
NA
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
Total
Number of
Nondetects
for
Pollutants in
SGT-HEM
Extracts
NA
NA
5
5
5
5
5
5
5
5
3
5
5
5
5
5
5
5
5
5
Average
Concentration
in SGT-HEM
Extracts1
(ug/L)
NA
NA
48
24
24
24
24
24
120
24
29.1
24
24
24
24
24
24
24
24
24

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                                                                                                  Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern
                                                               Table 5-16 (Continued)
Pollutant
w-Decane
w-Docosane
w-Dodecane
w-Eicosane
w-Hexacosane
w-Hexadecane
w-Nitrosodiphenylamine
w-Octacosane
w-Octadecane
w-Tetracosane
w-Tetradecane
Naphthalene
o-Cresol
/>-Cresol
p-Cymene
Phenanthrene
Phenol
Pyrene
Tripropyleneglycol Methyl
Ether
Total
Number of
Wastewater
Samples
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
Total Number
of Nondetects
for Pollutant
in Wastewater
Samples
1
1
1
1
1
1
5
5
2
I
1
0
1
2
3
5
0
5
1
Average
Concentration
in Wastewater
Sample1 (ug/L)
502
38
250
67.2
53.9
116
20
10
90.5
37.1
134
90.3
120
24.5
13.1
10
175
10
11,800
Total Number
of HEM
Extract
Samples
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
Total Number
of Nondetects
for Pollutants
in HEM
Extracts
4
5
4
4
5
3
5
5
3
5
4
4
5
5
5
5
5
5
5
Average
Concentration
in HEM
Extracts1
(ug/L)
30.1
24
38.5
28.3
24
47.2
48
24
34.8
24
37.8
25.1
24
24
24
24
24
24
238
Total
Number of
SGT-HEM
Extract
Samples
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
Total
Number of
Nondetects
for
Pollutants in
SGT-HEM
Extracts
5
5
5
4
5
4
5
5
4
5
4
5
5
5
5
5
5
5
5
Average
Concentration
in SGT-HEM
Extracts1
(ug/L)
24
24
24
27
24
36.2
48
24
30.7
24
27.3
24
24
24
24
24
24
24
238
'The detection limit concentration was used in calculations for data points reported as nondetects.

NA - Not applicable.
HEM - Hexane extractable material.
SGT-HEM - Silica gel treated-hexane extractable material.

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                                                                Chapter 6 - Pollution Control Technologies

                                      CHAPTER 6

     POLLUTION PREVENTION, RECYCLING, TREATMENT, AND DISPOSAL
   TECHNOLOGIES EMPLOYED BY THE INDUSTRIAL LAUNDRIES INDUSTRY

6.1           Introduction

              The Pollution Prevention Act of 1990 and EPA's  1991 Pollution Prevention
Strategy established an environmental management hierarchy that includes (in order of highest
priority) pollution prevention, recycling, treatment, and disposal or release. Presented in this
chapter are the pollution control technologies applicable to the industrial laundries industry for
each step of the environmental management hierarchy.  This chapter presents the following
discussions:

              •       Section 6.2 discusses the environmental management hierarchy established
                     by the Pollution Prevention Act;

              •       Section 6.3 discusses the pollution prevention measures used in the
                     industrial laundries industry;

              •       Section 6.4 discusses the waste recycling measures used in the industrial
                     laundries industry;

              •       Section 6.5 discusses the major wastewater treatment technologies used by
                     the industry;

              •       Section 6.6 discusses the waste disposal measures used by the  industrial
                     laundries industry; and

              •       Section 6.7 presents the references used.

              At the time of proposal, EPA considered 193 facilities that responded to the 1994
Industrial Laundries Industry Questionnaire (detailed questionnaire) to be in scope, including
three facilities that process only clean room items.  After proposal, EPA determined that clean
room items should not be classified as industrial laundry items (see Section 4.8 of this document)
and the three clean room facilities are no longer considered to be in scope.  Information in  this
chapter on the pollution prevention, recycling, wastewater treatment, and disposal  practices
reported by the industry are presented on the basis of 190 in-scope facilities.

6.2           The Environmental Management Hierarchy

              As it applies to industry, the environmental management hierarchy (outlined in
Figure 6-1) stipulates that:
                                           6-1

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                                                             Chapter 6 - Pollution Control Technologies
  I.      Source Reduction

         A.     Product Changes
                1.     Design for Less Environmental Impact
                2.     Increased Product Life

         B.     Process Changes

                1.     Input Material Changes
                      •      Material Purification
                      •      Substitution of Less Toxic Materials

                2.     Technology Changes
                      •      Layout Changes
                      •      Increased Automation
                      •      Improved Operating Conditions
                      •      Improved Equipment
                      •      New Technology

                3.     Improved Operating Practices
                      •      Operating and Maintenance Procedures
                      •      Management Practices
                      •      Stream Segregation
                      •      Material Handling Improvements
                      •      Production Scheduling
                      •      Inventory Control
                      •      Training
                      •      Waste Segregation

  II.     Recycling

         A.     Reuse

         B.     Reclamation

  III.    Treatment
Reference:  United State EPA, Office of Research and Development. Facility Pollution
Prevention Guide, EPA/600/R-92/088, May 1992.

               Figure 6-1. Environmental Management Options Hierarchy
                                          6-2

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                                                                 Chapter 6 - Pollution Control Technologies

              Facilities should reduce pollution at the source whenever feasible;

              •      Facilities should recycle waste materials that cannot be reduced in an
                     environmentally safe manner whenever feasible;

              •      Facilities should treat pollution that cannot be reduced or recycled in an
                     environmentally safe manner whenever feasible; and

              •      Facilities should only dispose or release pollutants into the environment as
                     a last resort. Facilities should conduct this practice in an environmentally
                     safe manner.

              EPA examined pollution prevention, recycling, treatment and disposal practices
applicable to the industrial laundries industry in an effort to incorporate the environmental
management hierarchy into the industrial laundries regulatory options development process. As
part of the Industrial Pollution Prevention Project (IPS) (1), a joint effort of EPA, state agencies,
local agencies, and industrial laundries, EPA determined that industrial laundries can best identify
pollution prevention and recycling opportunities by identifying all sources of pollution at their
facilities, including hazardous wastes, solid wastes, air emissions, and water discharges. Then
facility personnel and their customers can work together to find solutions which reduce or
eliminate the generation of the wastes through source reduction, reuse, and recycling. Specific
waste reduction opportunities at industrial laundries identified by EPA during the IPS are
presented in Sections 6.3 and 6.4 of this document. The information EPA collected on pollution
prevention, recycling, treatment and disposal practices as part of the industrial laundries
regulatory development process and the IPS is presented in Sections 6.3 through 6.6 of this
document.

6.3           Pollution Prevention/Source Reduction in the Industrial Laundries Industry

              Pollution prevention, established as the most desirable pollution control option in
the environmental management hierarchy, is defined as the use of materials, processes, or
practices that reduce or eliminate the generation of pollutants or wastes at the source. Also
known as source reduction, pollution prevention includes practices that reduce the use of
hazardous and nonhazardous materials, energy, water, or other natural resources.  End-of-pipe
pollution control and waste-handling measures (including waste treatment, off-site recycling,
volume reduction (e.g., sludge dewatering), dilution, and transfer of constituents to another
environmental medium) are not considered pollution prevention because such measures are
applied only after wastes are generated. With the Pollution Prevention Act of 1990, Congress
established pollution prevention as a national goal, declaring that the generation of pollutants
should be prevented or reduced during the production cycle whenever feasible.

              In the detailed questionnaire, EPA asked industrial laundries to provide
information on the types of pollution prevention activities performed at their facilities during the
1993 operating year.  Of the 190 in-scope industrial laundries and three clean room item laundries
responding to the detailed questionnaire (in-scope facilities are those that meet the definition of an
industrial laundry as presented in Chapter 4 of this document), 44 industrial

                                            6-3

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                                                                 Chapter 6 - Pollution Control Technologies

laundries reported having a pollution prevention policy (42 of these facilities attached copies of
the plans to the questionnaire), and 53 industrial laundries stated that they planned to implement
additional pollution prevention activities in the near future.

              A total of 105 in-scope industrial laundries reported conducting pollution
prevention activities prior to the laundering process (preprocess activities), during the laundering
process (in-process activities), or both.  The information reported by the facilities for preprocess
and in-process pollution prevention activities is presented in Sections 6.3.1 and 6.3.2 of this
document.

6.3.1         Preprocess Pollution Prevention Activities

              Seventy-nine in-scope industrial laundries responding to the detailed questionnaire
reported conducting some type of preprocess pollution prevention activities during the 1993
operating year.  Table 6-1 presents the number of industrial laundries, by production category,
that reported preprocess pollution prevention activities. EPA analyzed the data in the
questionnaire responses to determine if facility size was a factor in the performance of preprocess
pollution prevention activities.  For each production category, EPA calculated the percentage of
industrial laundries that reported these activities by  dividing the number of industrial laundries
reporting activities by the total number of industrial laundries listed in that production category.
As shown in Table 6-1, the performance of preprocess pollution prevention activities does not
appear to be related to facility size, with approximately 30 to 50 percent of the facilities in each
production category reporting preprocess pollution prevention activities.

              Table 6-2 lists all of the preprocess pollution prevention activities reported by
industrial laundries in the detailed questionnaire.  The most common preprocess pollution
prevention activities reported were the refusal of items with free liquids (68 percent) and the
refusal of certain items (52 percent).  The items most often refused by the industrial laundries
were shop and printer towels/rags. Sixteen industrial laundries reported other preprocess
activities, including centrifugation of items to remove liquids, dry cleaning of items before water
washing, presorting of items to remove trash/objects, and steam/air stripping of volatiles from
items.  During the IP3, EPA identified preprocess pollution prevention practices that could be
implemented by industrial laundries.  In addition to the preprocess pollution prevention activities
already presented in this section, EPA determined that industrial laundries could reduce the
amount of solid waste generated at their facilities by having laundering/dry cleaning/wastewater
treatment chemicals shipped to the facilities in bulk containers or in drums that could be returned
to the chemical manufacturers.

              Centrifugation, steam/air stripping, and dry cleaning are used to remove liquid
solvents and volatile organic compounds (VOCs) from items prior to water washing.  These
technologies facilitate the recovery and recycle of solvents and other materials contained on
heavily soiled items, such as shop and printer towels/rags.  Although these technologies are
                                            6-4

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                                                                        Chapter 6 - Pollution Control Technologies
                                      Table 6-1

    Number of Industrial Laundries, by Production Category, Reporting Preprocess
Pollution Prevention Activities in the Detailed Questionnaire for the 1993 Operating Year
Production Category
(Ib/yr)
< 1,000,000
1,000,000 to < 3, 000,000
3, 000,000 to < 6,000,000
6,000,000 to < 9,000,000
9,000,000 to < 15,000,000
> 15,000,000
Total
Number of
Facilities
Reporting
Activities
9
14
23
17
10
6
79
Total Number of
Facilities in
Production
Category
19
37
58
33
25
18
190
Percentage of
Facilities Reporting
Activities in
Production Category
47%
38%
40%
52%
40%
33%
—
Total Production for
Facilities Reporting
Activities
(Ib/yr)
5,810,000
27,900,000
102,000,000
123,000,000
115,000,000
118,000,000
492,000,000
Percentage of Total
Production for
Facilities Reporting
Activities
1%
6%
21%
25%
23%
24%
100%

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                                                                         Chapter 6 - Pollution Control Technologies
                                             Table 6-2
            Types of Preprocess Pollution Prevention Activities Reported
              in the Detailed Questionnaire for the 1993 Operating Year
Activity
Refusal of Items with Free Liquids
Refusal of Certain Items
Centrifugation of Items to Remove Liquids
Items Dry-Cleaned Before Water Washing
Items Presorted to Remove Objects
Steam/Air Stripping of Volatile Organics from Items
Number of
Facilities
Performing
Activity
54
41
62
53
o
6
i4
Percentage of Total Number of
Facilities Reporting Preprocess
Activities1
28%
22%
3%
3%
2%
1%
'Percentages are based on 190 in-scope industrial laundries.
2Some of these facilities reported that their customers were "pressing," "squeezing," "extracting," or "centrifuging" the
items prior to sending them to the laundry.
3Three of these facilities did not report dry cleaning before water washing as a preprocess pollution prevention activity.
This information was obtained from their reported laundering processes.  One additional facility dry cleans items before
water washing, but the industrial laundry did not include this information in its detailed questionnaire. EPA obtained
this information during a site visit to the facility.
4One additional facility reported steam/air stripping of volatile organics from items; however, the particular activities
reported at this facility do not meet the definition of steam/air stripping.
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                                                                  Chapter 6 - Pollution Control Technologies
actually waste recycling techniques with treatment, they were presented in the detailed
questionnaire as preprocess pollution prevention techniques.  For this reason, the information
provided by the industry on these technologies in the detailed questionnaire are included in this
section. Centrifugation, steam/air stripping, dry cleaning, and other waste recycling/treatment
technologies are discussed in greater detail in Section 6.4 of this document.

              Facilities responding to the detailed questionnaire reported initiating preprocess
pollution prevention activities primarily in the late 1980s and early  1990s. However, several
facilities initiated refusal of certain items and the refusal of items with free liquids many years
before (the late 1950s and early 1980s, respectively).  Facilities that reported these two practices
tended to refuse the same  items, as shown in the following table:
Items refused
Shop towels
Printer towels/rags
Industrial garments
Percentage of Facilities Refusing Items
Facilities Refusing Items with Free Liquids
48%
28%
15%
Facilities Refusing Certain Items
27%
32%
12%
              Of the six facilities that reported centrifugation to remove liquids, four performed
this activity on shop or printer towels/rags (the centrifugation technology is discussed in greater
detail in Section 6.4.5 of this document).  Likewise, both of the facilities that reported steam/air
stripping of volatile organics from items performed this activity on shop or printer towels/rags.
None of the facilities that presorted items to remove trash/objects or dry cleaned items before
water washing reported performing these activities on shop or printer towels/rags.

              In the detailed questionnaire, EPA asked facilities to report whether performing
preprocess pollution prevention activities had a negative impact on the quality of their service.
The facilities reported a negative impact most frequently for steam/air stripping of volatile
organics from items (100 percent), the refusal of items with free liquids (65 percent), and the
refusal of certain items (54 percent). These negative impacts generally included the following:

              •      Increased burden and costs for the facility (e.g., training of customers,
                     installation of equipment);

              •      Increased burden and costs for the customers (e.g., purchase of equipment,
                     restricted use of certain items, payment of penalty fees);

              •      Delayed service; and

              •      Loss of business/limits to growth.

EPA collected analytical data on two preprocess pollution prevention technologies, dry cleaning
prior to water washing and steam stripping (steam tumbling), during site visit and sampling
activities.  EPA collected additional information on air stripping, centrifugation, and hydraulic
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                                                                 Chapter 6 - Pollution Control Technologies

pressing from vendors of the equipment.  Section 6.4 of this document discusses these
technologies and their application in the industry in more detail.

6.3.2         In-Process Pollution Prevention Activities

              Fifty industrial  laundries reported conducting some type of in-process pollution
prevention activities during the 1993 operating year.  Table 6-3 presents the number of industrial
laundry facilities, by production category, that reported in-process pollution prevention activities.
EPA analyzed the data in the questionnaire database to determine if facility size was a factor in the
performance of in-process pollution prevention activities.  For each production category, EPA
calculated the percentage of facilities that reported activities by dividing the number of facilities
reporting activities by the total number of facilities listed in that production category. As shown
in Table 6-3, the performance  of in-process pollution prevention activities does not appear to be
related to facility size, with 15 to 35 percent of the facilities in each production category reporting
in-process pollution prevention activities.

              Table 6-4 lists all in-process pollution prevention activities reported by industrial
laundries in the detailed questionnaire for the 1993 operating year.  The most common types of
in-process pollution prevention activities reported by the industrial laundries  were:

              •      A change in the use of laundering/dry-cleaning chemicals (11 percent);

              •      Improved training of employees (i.e., chemical safety,  proper handling of
                     equipment) (10 percent); and

              •      Installation of a liquid injection system to add the exact amount of wash
                     chemicals required by the wash formula (10 percent).

              A smaller number of facilities reported other in-process activities (improved
housekeeping, water softening, implementation of water reuse/reduction, equipment
modifications/installations, recycling of laundry materials, removal of lint before air venting to
atmosphere, and reduced fuel consumption).  During the IP3, EPA identified in-process pollution
practices that could be implemented by industrial laundries.  In addition to the in-process pollution
prevention activities already presented in this section, EPA determined that industrial laundries
could also technically implement the following in-process practices:

              •      Use calcium  extracted from incoming water during water softening to
                     replace  the lime used in wastewater treatment/sludge dewatering
                     operations;

              •      Separate nonhazardous and hazardous waste streams;

              •      Improve standard operating procedures;

              •      Establish an inventory control system;
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                                                                         Chapter 6 - Pollution Control Technologies
                                      Table 6-3

    Number of Industrial Laundries, by Production Category, Reporting In-Process
Pollution Prevention Activities in the Detailed Questionnaire for the 1993 Operating Year
Production Category
(Ib/yr)
< 1,000,000
1,000,000 to < 3, 000,000
3, 000,000 to < 6,000,000
6,000,000 to < 9,000,000
9,000,000 to < 15,000,000
> 15,000,000
Total
Number of
Facilities
Reporting
Activities
5
13
14
10
4
4
50
Total Number of
Facilities in
Production
Category
19
37
58
33
25
18
190
Percentage of
Facilities Reporting
Activities in
Production Category
26%
35%
24%
30%
16%
22%
—
Total Production for
this Category for
Facilities Reporting
Activities
(Ib/yr)
3,280,000
23,000,000
62,300,000
76,700,000
51,100,000
93,100,000
309,000,000
Percentage of Total
Production for
Facilities Reporting
Activities
1%
7%
20%
25%
17%
30%
100%

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                                                           Chapter 6 - Pollution Control Technologies
                                    Table 6-4
         Types of In-Process Pollution Prevention Activities Reported
           in the Detailed Questionnaire for the 1993 Operating Year
Activity
Change in Laundering/Dry Cleaning Chemicals Used
Improved Training of Employees
Liquid Injection System for Wash Chemical Addition
Improved Housekeeping
Water Softening
Equipment Modifications/Installations
Recycling of Laundry Materials
Removal of Lint Before Air Venting to Atmosphere
Reduced Fuel Consumption
Number of
Facilities
Performing
Activity
20
19
18
10
6
3
1
1
1
Percentage of Total
Number of Facilities
Reporting In-Process
Activities1
11%
10%
10%
5%
3%
2%
1%
1%
1%
'Percentages are based on 190 industrial laundries.
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                                                                  Chapter 6 - Pollution Control Technologies

              •      Perform routine and preventative maintenance on facility equipment;

              •      Utilize waste exchange programs; and

              •      Reuse solvent from dry-cleaning operations.

              Facilities responding to the detailed questionnaire reported initiating most in-
process pollution prevention activities primarily in the late 1980s and early 1990s. However, one
facility reported initiating improved training of employees in 1983.

              All of the in-process pollution prevention activities reported by the facilities reduce
pollution and reduce operating costs by optimizing facility operations.  The installation of
alternative washers and automated liquid injection systems for washers, the use of alternative
washing chemicals, the use of water softening, and the implementation of water reuse/reduction
all can reduce the amount of water and/or chemicals that a facility uses.  A significant number of
facilities have improved employee training and housekeeping standards; these activities can also
decrease water and chemical  use. In addition, changes in laundering chemicals were reported to
improve treatability of the wastewater by forming emulsions that are more easily broken.

              In the detailed questionnaire, EPA asked facilities to report whether performing
pollution prevention activities had a negative impact on the quality of their service.  While most of
the industrial laundries reported no negative impacts for the in-process activities, several facilities
did report a negative impact on their quality of service from in-process pollution prevention
activities.  These negative impacts generally included the following:

              •      Increased burden and costs for the facility (e.g., training of employees,
                     purchase of more expensive liquid chemicals, installation of equipment/
                     processes, disposal of recovered materials);

              •      Increased costs to the customers  (i.e., increased facility costs were passed
                     on to customers); and

              •      Decreased quality of service (e.g., graying of clothes).

              The in-process pollution prevention activities were more widely practiced on the
different items laundered than were the preprocess pollution prevention activities.  Since most of
the in-process activities affect all washing operations,  this wide distribution among all of the item
types is to be expected. For example, in-process activities such as liquid injection usually apply to
all laundry operations and item types at a facility.
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                                                                Chapter 6 - Pollution Control Technologies

6.4           Waste Recycling/Resource Conservation and the Industrial Laundries
              Regulatory Development Process

              As established in the environmental management hierarchy, if the generation of
waste materials cannot be prevented or reduced in an environmentally safe manner, these
materials should be recycled whenever feasible. Waste recycling conducted in an environmentally
safe manner shares many of the advantages of pollution prevention/source reduction.  Waste
recycling helps to conserve natural resources, such as energy and water. In addition, pollution
recycling reduces the need for end-of-pipe treatment or disposal, the two least desirable pollution
control measures in the environmental management hierarchy.

              During the IPS, EPA determined that most industrial laundries use heat exchangers
to conserve energy. But, EPA determined that many industrial laundries do not recycle any
process water.  As part of the industrial laundries regulatory development process, EPA asked
industrial laundries receiving the detailed questionnaire and the 1993  Screener Questionnaire for
the Industrial Laundries Industry to provide information on the types of pollution
recycling/resource  conservation activities performed at their facilities. The information reported
by the facilities for water reuse and energy reuse is summarized in  Sections 6.4.1  and 6.4.2 of this
document.  Also included in this  section is information pertaining to technologies used to remove
liquid solvents and VOCs from items prior to water washing (Sections 6.4.3 through 6.4.6).
These technologies facilitate the recovery and recycle of solvents and other materials contained on
heavily soiled items, such as shop and printer towels/rags. The recovered materials may then be
reused by the industrial laundry customers or blended into fuel.

6.4.1          Water Conservation in the Industrial Laundries Industry

              Industrial laundries have a variety of opportunities to recycle/reuse water at their
facilities. Industrial laundries can recycle or reuse the following sources of water used at the
facility as process water or cooling water:  laundry wastewater before treatment, laundry
wastewater after treatment, noncontact cooling water, contact cooling water, and nonlaundry
wastewater.

              Forty-five of the 190 in-scope industrial laundries (24 percent) responding to the
detailed questionnaire reported reusing a portion of the water used  by the facility as process
makeup water.  Twenty-seven industrial laundries (60 percent) reported reusing noncontact
cooling water as process makeup water.  Nineteen facilities (42 percent) reported reusing laundry
wastewater in the water-washing process before the wastewater had been treated. One of the
industrial laundries reported reusing the final rinse from the water-washing process as noncontact
cooling water.  The noncontact cooling water was then reused at the  first rinse in the water-
washing process. Eight facilities (18 percent) reported recycling/reusing laundry wastewater back
into the water-washing process after the wastewater had been treated. One facility (2 percent)
reported reusing nonlaundry wastewater as laundry process water.  This facility did not specify
the source of the nonlaundry wastewater. No facilities responding  to the detailed questionnaire
reported reusing contact cooling water.
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                                                                Chapter 6 - Pollution Control Technologies

6.4.2         Energy Conservation in the Industrial Laundries Industry

              EPA asked facilities to indicate in the screener questionnaire whether they
conserve energy by operating a heat reclaimer.  Heat reclaimers at industrial laundries typically
operate by transferring heat from the process waste stream to preheat incoming service water.
The service water that has been preheated is then used in the wash process. Six hundred sixty-
three of the 1,500 facilities responding to the screener questionnaire (44 percent) reported
operating a heat reclaimer at their facility.

6.4.3         Dry Cleaning of Solvent Laden Items Prior to Water Washing

              General Description

              Dry cleaning  effectively removes volatile organic compounds (VOCs) from laundry
items prior to water washing, thereby reducing the introduction of VOCs into industrial laundry
wastewater.  Dry cleaning involves cleaning soiled items with an organic-based solvent that
removes  VOCs as well as heavy organic pollutants (e.g., oil and grease). The pollutants usually
are separated from the solvent through distillation and are then disposed. The distilled solvent
may then be reused in subsequent dry cleaning processes.  Depending on the purity of the
pollutants removed from the cleaning solvent, there may be a potential for  recycling these for
reuse by  the customer or for fuel blending.

              Industry Application

              Five of the 190 in-scope industrial laundries responding to the detailed
questionnaire (three percent) reported dry cleaning items before water washing. Four of these
facilities  reported that they dispose of residual solvent as hazardous  waste  (one facility did not
include this information in its detailed questionnaire response).  Three of the four facilities
reported  that they were large-quantity generators (disposing of greater than 1,000 kilograms of
waste per month) and the other facility reported that it was a small-quantity generator (disposing
of between 100 and 1,000 kilograms  of waste per month).

              One of the facilities reuses a significant portion of its cleaning solvent by reusing
the solvent from the final rinse from one load as the initial rinse in a subsequent load. In  addition,
the facility reclaims much of the used solvent by fractionating it in an on-site distillation column.
The facility collects the mid-range fractions for reuse and disposes of the light and heavy ends to a
hazardous waste incinerator (2).

6.4.4         Steam/Air Tumbling of Solvent Laden Items Prior to Water Washing

              General Description

              Steam or air tumbling is used to remove VOCs from laundry items prior to water
washing  to reduce  the amount of VOCs introduced into the laundry wastewater.  In steam
tumbling, soiled items are agitated within a modified washer/extractor while steam is injected into
the extractor chamber.  The heat from the steam causes the VOCs to evaporate from the

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                                                               Chapter 6 - Pollution Control Technologies

surfaces of the items. The steam and volatilized VOCs are then removed from the tumbler
chamber.  The steam and volatilized VOCs are sent to a condensing unit where the steam is
condensed and the VOCs are recovered through a phase separation. Air tumbling works similarly
to steam tumbling, except hot air is used as the source of heat to evaporate the VOCs and phase
separation is not required.  The VOCs are simply condensed out of the hot air stream.  Depending
on the purity of the VOC (solvent) recovered from the steam or air tumbling operation, it may be
reused by the customer or sent away for fuel blending.

              One equipment manufacturer estimates that 90 to 95 percent of the VOC solvent is
recovered using its equipment and claims that some customers have achieved a removal efficiency
of 98 percent (3).  EPA also collected samples of wastewater discharged after processing a load
of printer towels/rags that was steam-tumbled prior to water washing and from a load that  was
not steam-tumbled prior to water washing.

              EPA used these samples to identify pollutants removed by steam tumbling by
comparing the pollutant concentrations in the washer wastewater from non-steam-tumbled
towels/rags to that of towels/rags that were steam tumbled prior to washing to demonstrate
changes in the untreated wastewater characteristics from steam tumbling.  The data are presented
in Table 6-5.  All volatile organic pollutants for which a removal could be calculated (pollutant
removals for seven volatile organics could not be calculated because the pollutant was not
detected in the influent) had greater than 90 percent removal.  Therefore, EPA considered organic
pollutants with greater than 90 percent removal to be removed by steam tumbling.  Based on this
criterion, EPA considered all volatile organic pollutants (14 of the 72 pollutants of concern) to be
removed by steam tumbling.  Ten semivolatile organic pollutants from the list of 72 pollutants of
concern for which a removal could be calculated (pollutant removals for eight semivolatile  organic
pollutants could not be calculated because the pollutant was not detected in the influent) also had
greater than 90 percent removal. EPA considered these 10 semivolatile organic pollutants  to be
removed by steam tumbling.  A more detailed discussion of the steam tumbler treatment
performance data  can be found in Chapter 9 of the Technical Development Document for the
proposal rule (4).

              However, this data are limited in its usefulness because it is not a direct
comparison of the pollutants contained on the printer towels/rags before and after processing
them in the steam tumbler. In addition, the results of this comparison show that although steam
tumbling removes volatile and semivolatile pollutants, it does not effectively remove nonvolatile
pollutants, as evidenced by only 10 percent removal of total petroleum hydrocarbon (measured by
SGT-HEM)1.
'Silica gel treated-hexane extractable material (SGT-HEM) is measured by Method 1664 (promulgated at 64 FR 26315;
May 14, 1999). In this method, EPA defines SGT-HEM as non-polar material (NPM). Throughout this document and
the Industrial Laundries Administrative Record, EPA refers to SGT-HEM as total petroleum hydrocarbon (TPH).

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                                                 Chapter 6 - Pollution Control Technologies
                             Table 6-5

 Steam Stripping Performance Data Collected from a Sampled Facility
Processing Printer Towels in a Steam Tumbler Prior to Water Washing
Pollutant of Concern
Printer Towel/Rag
Raw Wastewater
Concentration
(mg/L)
Steam Tumbled
Printer Towel/Rag
Raw Wastewater
Concentration
(mg/L)
Percent
Removal
Bulk Nonconventionals
Total Petroleum Hydrocarbon (measured as SGT-HEM1)
Total Organic Carbon
519
2480
468
1770
10%
29%
Priority Organics
1,1,1 -Trichloroethane
Butyl Benzyl Phthalate
Chlorobenzene
Chloroform
Ethylbenzene
Methylene Chloride
Naphthalene
Tetrachloroethene
Toluene
trans- 1 ,2-Dichloroethene
Trichloroethene
4.24
6.30
<0.1
<0.1
9.78
0.161
3.73
3.21
14.2
<0.1
<0.1
0.0118
0.366
<0.01
<0.01
<0.01
<0.01
0.226
<0.01
0.0436
<0.01
<0.01
100%
94%
90%
90%
100%
94%
94%
100%
100%
90%
90%
Nonconventional Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pentanone
ฐ<-Terpineol
w-Xylene
w-Decane
w-Dodecane
w-Hexacosane
w-Octacosane
2.24
0.699
23.4
<0.5
1.58
<0.1
158
41.8
1.30
1.01
<0.05
<0.04
0.681
<0.05
<0.04
0.0151
0.499
2.65
0.0904
0.0633
98%
94%
97%
90%
97%
85%
100%
94%
93%
94%
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                                                                        Chapter 6 - Pollution Control Technologies
                                      Table 6-5 (Continued)
Pollutant of Concern
Printer Towel/Rag
Raw Wastewater
Concentration
(mg/L)
Steam Tumbled
Printer Towel/Rag
Raw Wastewater
Concentration
(mg/L)
Percent
Removal
Nonconventional Organics (Continued)
w-Triacontane
o-&/>-Xylene
/7-Cymene
0.777
<0.1
19.8
0.0587
0.0146
<0.04
92%
85%
100%
'Silica gel treated-hexane extractable material (SGT-HEM) is measured by Method 1664 (promulgated at 64 FR 26315;
May 14, 1999).  In this method, EPA defines SGT-HEM as non-polar material (NPM).  Throughout this document and the
Industrial Laundries Administrative Record, EPA refers to SGT-HEM as total petroleum hydrocarbon (TPH).
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                                                               Chapter 6 - Pollution Control Technologies

              Industry Application

              One of the 190 in-scope industrial laundries responding to the detailed
questionnaire reported steam tumbling printer towels/rags before water-washing. This facility
reported that it was a large-quantity hazardous waste generator (disposing of greater than 1,000
kilograms of waste per month) and that the hazardous waste residuals collected from the steam
tumbler were disposed to fuel blending.  Another facility (as noted in Table 6-2) reported "airing
out" wet items prior to water washing, however, EPA does not consider this to be acceptable air
stripping technology because the VOCs removed from the items are not collected.

              EPA sampled the facility that steam-tumbled its printer towels/rags. Table 6-5
compares the pollutant concentrations in the washer wastewater (i.e., raw wastewater) from non-
steam-tumbled towels to that of towels that were steam tumbled prior to washing.

6.4.5          Centrifuging of Solvent Laden Items Prior to Water Washing

              General Description

              Centrifugation is used to remove VOCs from laundry items before water washing.
In centrifugation, items to be laundered are placed in a mesh bag or perforated basket. The bag or
basket is placed in a centrifuge chamber, which is designed to spin around a central axis. The
centrifugal forces generated by the spinning chamber act on both the laundry items and the solvent
in the items. The bag or basket retains the laundry items while the solvent is forced through the
mesh  or perforations. The recovered solvent may be reused or recycled, depending on its purity.

              In a test performed by EPA on an industrial centrifuge, the solvent removal
efficiency ranged from 88 to 99 percent (5).  Variables that affected removal  efficiency during the
test were the vapor pressure and boiling point of the solvent, the type of towel or wiper, and the
presence of ink, water, dirt, oil, and other contaminants in the solvent. Additionally, vendor
literature indicates 85 to 95 percent removal efficiency for centrifugation (6).

              In a case study conducted by EPA, a printing facility centrifuged its towels before
they were sent to the laundry, between 2.5 and 3.5 gallons of solvent were recovered for every
220 wipers (7). The facility used the recovered solvent to clean press ink trays. Solvent
recovered from the cleaning operation was sent to a fuel blender.

              Industry Application

              None of the industrial laundries responding to the detailed questionnaire reported
using  centrifugation to remove VOCs from laundry items prior to water washing and the extent of
its use in the industrial laundry industry is not known at this time. However,  available information
indicates that centrifugation is used in the printing industry to remove solvents from printer
towels/rags before they are sent to a laundry (8). As noted in Table 6-2, there are six industrial
laundries that reported washing centrifuged items (these items were sometimes
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                                                                Chapter 6 - Pollution Control Technologies

reported as "extracted," "pressed," or "squeezed").  Most of these facilities reported that this
activity was performed by their customers.

6.4.6         Pressing Solvent Laden Items Prior to Water Washing

              General Description

              Another way in which industrial laundries can remove excess liquid solvent and
VOCs from items prior to water washing is by using a hydraulic ram extractor. Solvent laden
items are placed into a perforated chamber.  The items are then squeezed by a hydraulic ram that
is actuated to compress the items within the chamber. The excess liquid solvents contained on the
items flow through the perforations and into a collection system. As described previously, the
recovered solvents may be processed for reuse or disposed by the laundry.

              Industry Application

              EPA knows of two facilities that use hydraulic presses to remove excess liquids
from towels and adsorbents prior to water washing.  One facility, sampled by EPA, disposes of
the collected liquids with other waste oil collected from its wastewater treatment system to a
hazardous waste fuel blender (9).  The other facility, visited by EPA, also sends its extracted
material to a fuel blender.  This facility estimates that 30 to 70 pounds (5.5 gallons on average) of
material is extracted for each 350-pound load of towels (10).

6.5           Wastewater Treatment Technologies  in the Industrial Laundries Industry

               This section describes major wastewater treatment technologies used in the
industrial laundries industry, based on  responses to the detailed questionnaire. Sections 6.5.1
through 6.5.15 of this document describe the wastewater treatment technologies used in the
industry, as reported in the detailed questionnaire.  These treatment technologies include:
                     Gravity settling (Section 6.5.1);
                     Stream splitting (Section 6.5.2);
                     Screening (Section 6.5.3);
                     Equalization (Section 6.5.4);
                     Chemical emulsion breaking (Section 6.5.5);
                     Chemical precipitation (Section 6.5.6);
                     Dissolved air flotation (DAF)  (Section 6.5.7);
                     Sludge dewatering (Section 6.5.8);
                     pH adjustment (Section 6.5.9);
                     Ultrafiltration (Section 6.5.10);
                     Centrifugation (Section 6.5.11);
                     Oil/water separation (Section  6.5.12);
                     Media filtration (Section 6.5.13);
                     Carbon adsorption (Section 6.5.14); and
                     Air stripping (Section 6.5.15).
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                                                                 Chapter 6 - Pollution Control Technologies

              Each technology section includes a general description of how the technology
works, the types of pollutants the technology treats, and the application of the technology in the
industrial laundries industry as of 1993.  Table 6-6 presents the total number of facilities out of
190 in-scope facilities responding to the detailed questionnaire that reported using each of these
technologies.  Section 6.5.16 of this document presents updated information on the wastewater
treatment technologies currently used by the industrial laundries industry that was collected in
1998 by the industrial laundries trade associations.

6.5.1          Gravity Settling

              General Description

              Gravity settling, or sedimentation, is primarily used to remove suspended solids
from industrial laundry process wastewater. The wastewater is typically collected in a catch basin
where the water is detained for a period of time, allowing solids with a higher specific gravity to
settle to the bottom of the tank and solids with a lower specific gravity to float to the surface.
The effectiveness of solids settling depends upon the characteristics of the laundry wastewater and
the length of time the wastewater is held in the catch basin.  Properly designed and operated
settling tanks are capable of achieving significant reductions of suspended solids and 5-day
biochemical oxygen demand (BOD5) (11).

              The solids that  settle out or float  to the surface may be removed from the basin
continuously using automated  rakes or augers that scrape the solids into a collection unit for
subsequent dewatering or disposal.  Alternatively, the basins may be periodically shut down and
the solids pumped out and collected for disposal.

              Industry Application

              It was assumed that a facility reporting a catch basin with an amount of solids
removed had gravity settling.  Although only 51 percent of in-scope industrial laundries
responding to  the detailed questionnaire (97 of 190) reported treating their wastewater through
gravity settling, every  facility visited by EPA has a settling basin in place.  Therefore, EPA
believes all industrial laundries have settling basins in place and can incorporate gravity settling
and solids removal as  part of their treatment train without modification of their wastewater
treatment equipment.  The gravity settling units used at these 97 facilities have an average
residence time of 2.3 hours. Ten industrial laundries add chemicals to their gravity settling unit,
most frequently sulfuric acid (added by six facilities) and polymer (added by two facilities).

6.5.2          Stream Splitting

              General Description

              Segregating process wastewater streams provides a means of treating a portion of
the total process wastewater generated at industrial laundries.  Stream splitting may be used to
isolate and treat a stream with  a high pollutant load, while a stream with a lower load is either
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                                                           Chapter 6 - Pollution Control Technologies
                                    Table 6-6
  Number of In-Scope Facilities Responding to Detailed Questionnaire Using
       Wastewater Treatment Technologies in the 1993 Operating Year
Technology
Gravity Settling
Stream Splitting
Screening
Equalization
Chemical Emulsion Breaking
Chemical Precipitation
Dissolved Air Flotation
Sludge Dewatering
pH Adjustment
Ultrafiltration
Centrifugation
VOC Removal Technologies
Oil/Water Separation
Media Filtration
Number of Facilities Using
Technology
97
20
146
98
9
21
35
52
42
2
6
12
24
10
Percentage of Total Number of
Industrial Laundries Responding to
the Detailed Questionnaire1
51%
11%
77%
52%
5%
11%
18%
27%
22%
1%
3%
6%
13%
5%
'Percentages are based on the 190 in-scope industrial laundries that responded to the detailed questionnaire.
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                                                                Chapter 6 - Pollution Control Technologies

recycled and reused or discharged directly to the publicly owned treatment works (POTW)
without treatment.  This segregation allows a facility to install a smaller treatment system than
would be necessary if the total process wastewater stream was treated. In addition, facilities can
reduce overall process water use if they can reuse the less concentrated wastewater in place of a
portion  of fresh service water.

              A divided trench and sump system is used to split process wastewater streams.
This system is installed as two completely separate trenches and/or sumps, or an existing system
may be  modified to accommodate two separate wastewater streams.  One modification to an
existing system entails placing a dividing wall down the center of the existing trench and/or sump.
This wall may be constructed of concrete, coated metal plates, or other impervious material.
Alternatively, one stream may be hard piped to a specific treatment unit or collection tank while
the other stream flows through the existing trench and sump. Pipe made of polyvinyl chloride
(PVC) is generally used because of its compatibility with industrial laundry process wastewater
pH and  temperatures.  Facilities often need to install additional collection tanks and transfer
pumps to accommodate the two process wastewater streams (12).

              In addition to splitting the  facility's process wastewater trench and sump system,
the washer, extractor,  and/or washer-extractor machines must either be capable of releasing
process wastewater into separate conduits or be used as dedicated machines for washing a
specific item or group of items so the wastewater discharge can be directed to the appropriate
trench.  Machines can be purchased having multiple water discharge ports and control valves to
allow each process break or rinse to be released to a separate location according to the wash
formula. For example, the operator may program the washer/extractor to release the initial wash
breaks containing the dirtier water to the treatment system to be treated and discharged, while
routing the final rinses to a storage tank to be recycled in subsequent washing processes or to be
discharged without treatment. Existing machines that do not currently have this capability can be
retrofitted with control and discharge valves.  Another method of segregating process wastewater
is to identify items that generate the more polluted water and those that generate cleaner water.
The facility may then designate certain machines to wash a specific group of items and direct all of
the process wastewater from those machines to the desired location.

              Industry Application

              Eleven percent of in-scope industrial laundries responding to the detailed
questionnaire (20 of 190) reported segregating their process wastewater streams to treat a portion
of the total process wastewater generated  at  their facilities.  One additional facility responding to
the detailed questionnaire reported having the capability to segregate its  process wastewater
stream but did not report treating any portion of this process wastewater.

6.5.3         Screening

              General Description

              Wastewater is often screened prior to subsequent treatment to remove grit and
suspended solids that may potentially damage or clog process equipment located downstream.

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Coarse screening is often performed using a bar screen, constructed of flat steel bars welded
together in a grid pattern.  The bar screen is designed to allow free flow of effluent while
removing large objects from the wastewater stream (13).  Bar screens can be automatically or
manually cleaned to remove the entrapped objects. If performed on a regular basis, manually
cleaned bar screens are often the most cost-efficient (14).

              Fine screening is performed using lint screens. These screens are constructed of
wire mesh or perforated metal plates and are often installed downstream from bar screens.  Lint
screens are designed to remove lint and other particles, such as sand or grit, from wastewater
(13).  Hydros!eve or static screens are installed in the process wastewater line and trap the
entrained particles as the water passes through the screen.  Static screens must be routinely
cleaned or changed out to prevent excessive clogging of the wastewater line. This task is often
performed manually. The static screen is relatively inexpensive to maintain and operate.

              Shaker and rotary screens are mechanically equipped to remove the entrained
solids from the screen apparatus to ensure continuous operation. Shaker or vibratory screens
operate by intermittently vibrating about the center of mass, forcing the solids from the screen
surface, outward toward the periphery, and around to a port through which the solids are
removed and collected in a sack or bin. These screens may also include accessories, such as
brushes, rakes, and water sprayers, to remove solids and to enhance the performance of the
continuous screen cleaning mechanism (15). Figure 6-2 presents a diagram of a shaker screen.

              A rotary  screen consists of a cylindrical screen that rotates within a chamber. The
wastewater passes through the screen as it rotates and the solids are collected on the surface of
the screen. The solids are removed from the screen surface by means similar to those of  shaker
screens (i.e., brushes or water sprays).  The rotary screen can be operated either by passing the
water from the outside of the rotating screen toward the center of the chamber, with solids
collection on the exterior surface, or by passing the wastewater from the center of the chamber
toward the exterior, with solids collection on the interior surface of the screen (11).

              Most screens are placed at the beginning of the wastewater treatment train.  Bar
screens, in particular, are most often located at the end of the wastewater trenches that carry the
water discharged from the wash room to the treatment system (if present) and the final discharge
point. As stated in Section 6.5.1 of this document, EPA believes that all facilities have an initial
catch/settling basin located at the  end of the trench.  Fine screening (either static or mechanical)
may be performed either before or after the water is collected in the catch basin. The advantage
to screening the water before initial collection is that the amount of solids that will settle  and
accumulate within the catch basin is reduced,  lowering the maintenance costs associated with
periodic cleaning of the  catch basin.

              Industry  Application

              The majority of in-scope industrial laundries (77  percent) perform at least one
screening operation before  discharging their wastewater (146 out of 190 in-scope facilities
responding to the detailed questionnaire reported having a screen(s)). Thirteen facilities perform
coarse screening only, using a bar screen.

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                                                                                                                      Chapter 6 - Pollution Control Technologies
                                                                                  raw wastewater
to
                                                              Figure 6-2.  Shaker Screen

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              Forty-three facilities reported at least one type of static screen (e.g., lint screen,
box screen, or strainer). The most prevalently used fine screen is the lint screen (reported by 38
facilities); box screen and strainer use was reported much less frequently.

              More than half (52 percent) of the facilities reporting a screening operation have at
least one mechanical screen. Ninety-two facilities reported having a shaker screen, six facilities
reported having a rotary screen, and one facility reported having both types of mechanical screens

              Five facilities use coarse screening with a static fine screen; six facilities use coarse
screening with a mechanical fine screen; five facilities use both static and mechanical fine
screening; and two facilities use all three types of screens:  coarse, static fine, and mechanical fine
screening.

6.5.4         Equalization

              General Description

              Equalization is used to control fluctuations in flow and pollutant loadings in
process wastewater prior to treatment to overcome operational problems that may result from the
fluctuations, reduce the size and cost of the downstream treatment units, and improve the overall
performance of these units.  Equalization systems are typically designed to eliminate variations in
the wastewater, (e.g., flow, pollutant load, and pH) by retaining the wastewater until it can be
discharged at a constant rate having uniform characteristics.  In this way, facilities can  size and
operate the downstream treatment units on a continuous-flow basis with minimal disruption in the
treatment conditions. The amount of time required to achieve optimum effects depends upon the
specific characteristics and daily flow patterns of the wastewater. Equalization units are often
equipped with agitators (e.g., impeller mixers and air spargers) to further mix the wastewater and
to prevent excessive solids settling at the bottom of the unit.  Chemicals may also be added to the
equalization units to adjust the pH and otherwise prepare the wastewater for further treatment
(16).  Section 6.5.9 of this document (pH Adjustment) discusses equalization units that use pH-
adjusting chemicals.

              Industry Application

              It was assumed that a facility reporting at least one vessel from which no solids are
collected and to which no chemicals were  added had equalization.  Fifty-two percent of the in-
scope industrial laundries responding to the detailed questionnaire (98 of 190) reported treating
their wastewater through equalization.  Thirty percent of these facilities reported using at least
one mixer to agitate the wastewater. The equalization units reported in the detailed questionnaire
have an average residence time of 7.6 hours.
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6.5.5         Chemical Emulsion Breaking

              General Description

              Chemical emulsion breaking is used primarily to remove oil and grease, as well as
other related pollutants, from process wastewater streams. Chemical emulsion breaking is
effective in treating wastewater streams having stable oil-in-water emulsions.  In a stable
emulsion, oil is dispersed within the water by way of attractive electrical charges that exist, often
as a result of other constituents (e.g., emulsifying agents and surfactants) present in the water.
These emulsions require acid addition to lower the pH of the wastewater and neutralize the
electrical charges between the oil and water, enabling the oil to form a distinct and separate phase
within the water. Chemical emulsion breaking units add demulsifying agents to aid in forming the
oil phase and subsequently remove it from the wastewater stream.

              Various reactive cations are effective as demulsifying agents to break emulsions
(e.g., hydrogen (H +1), aluminum (Al +3),  and iron (Fe +3)).  Sources of these cations include
acids, alum, ferrous salts, and various cationic polymers.  The demulsifier is added to the
wastewater stream and allowed to react with the water long enough to cause the oil to
agglomerate to form a distinct oil phase.  Mechanical mixing increases the effectiveness of the
demulsifier by dispersing the chemical into the water rapidly and uniformly.  Mixing also aids
demulsification by causing molecular collisions that help agglomerate oil droplets and
subsequently help to break the  emulsion.

              In batch-mode units, the treated wastewater is allowed to stand long enough to
allow the oil droplets, having a lower specific gravity, to rise and form a layer on the surface.
This layer may be removed by  controlling the water level within the unit, such that the oil layer is
raised above a weir and overflows into the collection unit while water underflows the weir. The
oil layer may also be removed by manually or mechanically raking the surface  over a weir with a
skimming device.

              Skimming devices typically work by continuously contacting the oil with a
material, usually an oleophilic belt or rope,  onto which the oil readily adheres.   As the material
passes through the oil layer, the oil coats the surface of the material. The oil-coated material then
passes through a mechanism that scrapes the oil from the material into an oil-collection unit. This
process uses a motorized drive to continuously remove oil from the wastewater surface. Figure
6-3 presents a diagram of a batch chemical emulsion breaking unit. Batch chemical emulsion
breaking systems can remove significant amounts of oil and grease from process wastewater, if
they are designed with optimized residence times and the oil-removal devices are properly
operated and maintained.

              Continuous chemical emulsion breaking units are equipped with various
hydrodynamic structures that physically separate entrained oil droplets from wastewater and
pump them to a collection unit while allowing the water to pass through without interruption.
These units usually comprise a series of corrugated and/or inclined plates arranged parallel to one
another and transverse to the flow of water. They are often built of materials that attract oil away
from the water. As the oil droplets impinge on the surfaces of the plates, they coalesce into a

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                                               Chapter 6 - Pollution Control Technologies
Figure 6-3.  Batch Chemical Emulsion Breaking Unit
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layer of oil that flows or is pumped from the unit.  Figure 6-4 presents a diagram of a continuous
chemical emulsion breaking unit with coalescing plates.

              Continuous chemical emulsion breaking units do not require long residence times,
as do batch systems, and thus are more compact and space efficient.  However, they do require
uniform wastewater conditions in terms of flow rate and oil and grease loads, which may not be
easily achieved in some wastewater treatment systems. In addition, the plates often require
routine maintenance to ensure proper operation and to prevent clogging.  The effectiveness of
batch or continuous systems is highly dependent upon the specific characteristics of the process
wastewater (17).

              Industry Application

              Nine of the 190 in-scope industrial laundry facilities responding to the detailed
questionnaire reported treating their wastewater through chemical emulsion breaking and adding
acid as a demulsifying agent.  Rope skimmers, decant tanks, and gravity separation were reported
most frequently (at six of the facilities) to collect the demulsified oil from the surface of
wastewater. These six facilities demulsify the oil in a batch process with a median residence time
of seven hours. The remaining three facilities run chemical emulsion breaking continuously, using
coalescing plates or plate separators.  These continuous-process chemical emulsion breaking units
have a much lower median residence time (less than one hour).  Six of the facilities demulsify all
of their process wastewater, and three demulsify only heavy wastewater (the portion of the
wastewater with the highest concentration of contaminants). Chemical emulsion breaking is often
used as a pretreatment to other technologies; four of the nine facilities reported using chemical
emulsion breaking as a pretreatment to either dissolved air flotation (three facilities) or chemical
precipitation (three facilities).  Eight of the nine facilities that use chemical emulsion breaking
reported disposing of the demulsified oil at an oil reclaimer.
              Some facilities responding to the detailed questionnaire reported using oil/water
separation technologies without adding demulsifying agents to their wastewater. Oil/water
separation and the facilities performing this treatment are described in Section 6.5.12  of this
document.

6.5.6         Chemical Precipitation

              General Description

              Chemical precipitation is one of the most commonly used processes in water
treatment (18).  Specifically, chemical precipitation is used to remove organics,  oils, and dissolved
pollutants from process wastewater. Precipitation aids, such as lime, work by reacting with the
cations (e.g., metals) and some anions to convert them into an insoluble form (e.g., metal
hydroxides).  The pH of the wastewater affects how much pollutant mass is precipitated, as
various pollutants will precipitate only within specific pH ranges. Therefore, the pH of the
wastewater is often increased  to facilitate maximum pollutant precipitation. Lime and other
caustic materials increase the  pH of the wastewater stream and  react with the dissolved ions to
form insoluble compounds, making them good precipitation aids (17).
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         treated
       wastewater

         effluent
to
oo
                                                                                                                                oily
                                                                                                                             wastewater

                                                                                                                               influent
                             Figure 6-4. Continuous Chemical Emulsion Breaking Unit with Coalescing Plates

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              In chemical precipitation units, coagulation and flocculation aids are usually added
to facilitate the formation of large agglomerated particles that are simpler to remove from the
wastewater.  The precipitants as well as other suspended solids often have like or neutral surface
charges that repel one another. Coagulants bind to the particles in the wastewater stream and
essentially convert the surface charges; as a result, opposite charges form between the particles,
which causes them to agglomerate. Examples of coagulants include cationic polymers and
various inorganic salts, such as ferric chloride (FeCl3), and aluminum sulfate  or alum
(A12(SO4)3ป 18 H2O). Flocculent aids, typically anionic polymers, are added to further enhance the
agglomeration of the particles (16).

              Like chemical  emulsion breaking units, chemical precipitation units may use
various mechanisms to remove the agglomerated floe from the wastewater. In batch chemical
precipitation systems, the treated wastewater is held in the unit long enough to allow the solids to
settle out. The water is then pumped from the unit, and the remaining sludge is removed for
further dewatering and subsequent disposal. Figure 6-5 presents a diagram of a batch chemical
precipitation system. In a batch system, chemical addition and residence time are easily adjusted
based on the particular conditions of the process wastewater. Batch systems usually require the
use of two water-holding units connected in parallel (i.e., one is used to treat the process
wastewater while the other collects the wastewater to be treated in the next batch) and therefore
generally require more space than continuous systems.

              Continuous units often use hydrodynamic structures that push the solids
downward as the water flows past. These structures usually comprise a series of parallel plates
arranged tangentially to the flow of water.  As the water flows between them, the heavy particles
impinge against the plates and lose enough momentum that they are forced to sink to the bottom
of the unit.  Continuous units also include pumps or augers that remove the settled solids from the
unit. Because of their single unit design and relatively short required retention time, continuous
chemical precipitation units are space efficient.  However, the performance of continuous systems
can be disrupted if wastewater conditions are varied. Figure 6-6 presents a diagram of a
continuous chemical precipitation system.

              Industry Application

              Eleven percent of the in-scope industrial laundry facilities responding to the
detailed questionnaire (21 of 190) reported treating their wastewater using chemical precipitation.
These can be divided into two groups:  facilities that use chemical precipitation to treat their
entire wastewater stream (16 facilities) and facilities that use chemical precipitation to treat only a
portion of the wastewater stream generated from laundering of heavily soiled items such as shop
towels (5 facilities).

              Chemicals added during chemical precipitation include lime, anionic polymers, and
cationic polymers.  Facilities using chemical precipitation fall into two categories, or "schemes,"
depending on the chemicals added during chemical precipitation.
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                                                           Chapter 6 - Pollution Control Technologies
      chemical
       addition
   raw
wastewater
            Figure 6-5. Batch Chemical Precipitation System
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             chemical
             addition
    raw -
wastewater
— treated
wastewater
                                                                                                                wastewater flow
                                                                                                                sludge flow
                                   Figure 6-6.  Continuous Chemical Precipitation System

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                                                                 Chapter 6 - Pollution Control Technologies

The following table shows the distribution of facilities within each scheme that either treat only
the portion of their wastewater stream generated from laundering heavily soiled items or their
entire wastewater stream.
Scheme
Scheme A
Scheme B
Chemicals Added
Polymer, lime
Polymer
Number of Facilities
Treating Only Heavy
Waste Stream
4 (13%)
1 (5%)
Number of Facilities
Treating Entire Waste
Stream
6 (29%)
10(48%)
              There are 18 facilities using chemical precipitation that reported operating a
continuous treatment unit.  Three facilities reported using a batch chemical precipitation
operation.
6.5.7
Dissolved Air Flotation (DAF)

General Description
              Dissolved air flotation (DAF) is used to remove suspended solids, emulsified oil,
and some dissolved pollutants from process wastewater. DAF treatment involves coagulating and
agglomerating the solids and emulsified oil and floating the resulting floe to the surface using
pressurized air injected into the unit. During this process, chemicals such as ferric and aluminum
salts, activated silica, and cationic polymers are typically added to alter the repellant surface
charges of the particles in the wastewater and cause them to agglomerate (13).  Certain dissolved
pollutants (e.g., metals) may be precipitated by reacting with the inorganic salts to form insoluble
particles that also agglomerate with the floe.  Flocculent aids (typically anionic polymers) are  also
added to DAF treatment systems to further enhance the formation of large particles.

              DAF uses a dissolved air stream injected into the bottom of the unit to provide the
flotation mechanism.  Air is injected into a water tank under sufficient pressure to dissolve the air
within the water.  As the water is injected into the DAF unit, the pressure is decreased and the air
is brought out of solution, creating many small bubbles.  The large floe particles attach to the
rising bubbles and are brought to the surface of the unit. Injected air flotation (IAF) systems (also
referred to as induced air flotation) work in a similar fashion, but do not use pressurized air.
Instead, the air is  injected directly into the IAF unit. DAF units use rakes that scrape the floe
from the surface and into a sludge collection vessel, where it is subsequently pumped to a
dewatering unit and later disposed of.   Some solids are expected to settle to the bottom of the
unit; therefore, some units also have bottom  sludge removal rakes or augers (13).

              DAF is used in the water treatment industry to remove fat, oils, fibers, and grease
from wastewater and algae from nutrient-rich reservoir water. DAF is commonly used to treat
water when sedimentation treatment proves ineffective. Water with low turbidity or low alkalinity
or colored water may not be effectively treated through sedimentation. DAF units are
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typically operated on a continuous basis and incorporate the chemical mix tanks, flotation vessels,
and sludge collection into a single unit.  Figure 6-7 presents a diagram of a DAF unit.

              Industry Application

              Eighteen percent of the in-scope industrial laundry facilities responding to the
detailed questionnaire (35 of 190) reported treating their wastewater using DAF. All of these
facilities add chemicals to the DAF and collect the DAF float sludge. (Two additional facilities
that reported using DAF were excluded because they do not collect float sludge.)  In addition, 10
of the facilities reported that they also collect bottom sludge.

              Chemicals added to the DAF unit include sulfuric acid, inorganic coagulants (metal
salts), anionic polymers, cationic polymers, and flocculents. Facilities using DAF fall into four
categories, or "schemes,"  depending on the chemicals added during treatment:
Scheme
Scheme A
Scheme B
Scheme C
Scheme D
Chemicals Added
Polymer, inorganic coagulant (e.g., metal
salt)
Polymer
Polymer, flocculent
Polymer, flocculent, inorganic coagulant
(e.g., metal salt)
Number of Facilities Treating Waste Stream
11 (31%)
9 (26%)
7 (20%)
6 (17%)
Note: EPA did not receive treatment chemical information for all of the DAF facilities, so the total does not add up to
100 percent.

              Thirteen facilities also add sulfuric acid to the wastewater before it enters the DAF
unit.

6.5.8         Sludge Dewatering

              General Description.

              Sludge dewatering processes remove water from sludge that is generated from the
wastewater treatment process. Sludge dewatering provides the following benefits to a facility's
operations:

              •      Substantially reduces the costs for sludge disposal by reducing the sludge
                     volume;

              •      Allows for easier handling than thickened or liquid sludge; dewatered
                     sludge may be transported via manual shoveling, tractors fitted with
                     buckets and blades, and belt conveyors;

              •      Reduces the requirements for supplemental bulking agents or amendments
                     added to sludge prior to composting;


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                                                rake
chemical
addition
                                                   \
                                                                                                                 treated
                                                                                                                 effluent
                                                                                                                hold tank
sludge
(to dewatering)
                                                                                                        air injection
                                                                                                    wastewater flow
                                                                                                    sludge flow
                                               Figure 6-7.  Dissolved Air Flotation Unit

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              •      May be a requirement for sludge disposal to render the sludge odorless and
                     nonputrescible; and

              •      May be a requirement for landfill disposal of sludge to reduce leachate
                     production at the landfill site (11).

              Dewatering may involve simple techniques, such as natural evaporation or drying
of sludge using heat. Various mechanical techniques may also be used to remove water from
sludge more rapidly, such as filtration, squeezing, capillary action, vacuum withdrawal, and
centrifugal separation and compaction (11). The two most prevalent mechanical dewatering
devices reported in the industrial laundries industry are the rotary vacuum  filter and the plate and
frame filter press.

              The rotary vacuum filter is a cylindrical drum with a filter medium (e.g., natural
fiber cloth or screen) around its perimeter.  The drum is horizontally suspended within a vessel
and is partially submerged in the sludge. The drum is rotated and the drum filter surface contacts
the sludge within the vessel while a vacuum is drawn from within.  This draws the water through
the filter medium from the outside of the drum toward the axis of rotation and discharges it
through a filtrate port. The solids become trapped against the  filter medium, forming a dewatered
filter cake around the outside of the drum.  Rotary vacuum filters typically include a knife or a
blade, which continuously scrapes the dewatered cake from the outside of the drum and into a
collection bin.  These types of filters can obtain a reasonably dry cake appropriate for disposal;
however filter aid materials (e.g., diatomaceous earth or perlite) are usually required to precoat
the filter (11). Figure 6-8 presents a diagram of a rotary vacuum filter.

              Filter presses use positive pressure to drive the water through the filter medium.
This type of unit comprises a series of recessed plates affixed with a filter medium (e.g., filter
cloth) that are stacked together horizontally on a frame. During operation, the plates are forced
together by a hydraulic ram or powered screw. The plates form a series of spaces separated by
the filter medium and are otherwise sealed to withstand the internal pressures created during the
filtration cycle. As the sludge is forced through the system, the water passes through the filter
medium and is discharged through the filtrate port while the solids become trapped within the
spaces, forming a dewatered cake against the filter medium. When the cycle is over, the plates are
separated and the dewatered cake is released into a collection  bin.  The operator often has to
remove the cake from the filter medium manually. Filter presses are usually able to achieve a drier
filter cake than rotary drum filters and do not require precoating with a filter aid.  The filtrate that
results from either of these operations is usually piped back to the beginning of the treatment
system or is simply discharged with the effluent water. Figure 6-9 presents a diagram of a filter
press.
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Oi
OJ
Oi
                         scraper
dewatered
  sludge
 disposal
                                                                                                                                      filtrate
                                                                                                                                  — vessel
                                                                                                                                    holding
                                                                                                                                  wet sludge
                                                           Figure 6-8.  Rotary Vacuum Filter

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                                                                                                      Chapter 6 - Pollution Control Technologies
sludge
flow in
             filtrate
              flow
               out
                                                               plates
                                                                and
                                                              frames
                                               de watered
                                               sludge (cake)
                                               unloaded
                                                    Figure 6-9. Filter Press

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                                                                 Chapter 6 - Pollution Control Technologies
              Industry Application
              Twenty-seven percent of the in-scope industrial laundry facilities responding to the
detailed questionnaire (52 of 190) reported dewatering their sludge before disposal. The types of
dewatering devices reported include:
Dewatering Device
Plate and frame filters
Rotary vacuum filters
Sludge dryers
Bag filters
Other
Number of Facilities
32 facilities (62%)
12 facilities (23%)
3 facilities (6%)
2 facilities (4%)
4 facilities (8%)
        Note:  One facility reported both a rotary vacuum filter and a sludge dryer.

              In the industrial laundries industry, most of the sludge that is dewatered comes
from DAF or chemical precipitation units. More than half of the dewatering devices (27 of 52
facilities) process sludge from a DAF unit.  Sixteen dewatering devices process sludge from a
chemical precipitation unit. The remaining dewatering devices process sludge from other sources.

              Characteristics of industrial laundry sludge are highly dependent on the items
washed, water conditions, and upstream treatment. Facilities responding to the detailed
questionnaire that generate sludge reported an average solids content of 17 percent for the
undewatered sludge. Facilities that dewater a sludge reported an average solids content of 40
percent for the dewatered sludge.

              Fifty-four percent of facilities that dewater sludge add one or more chemicals that
aid in dewatering.  The chemicals commonly added to aid in industrial laundry sludge dewatering
are:
Chemical Added
Lime
Polymer
Diatomaceous earth
Perlite
Ferric chloride
Number of Facilities
12 (43%)
10 (36%)
5(18%)
5(18%)
3(11%)
Note that facilities that add more than one chemical are represented twice in the above table.
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6.5.9          pH Adjustment

              General Description

              Because many treatment technologies used in the industrial laundries industry are
sensitive to pH fluctuations, pH adjustment may be required as part of an effective treatment
system. In addition, the pH of the final effluent from these technologies must often be adjusted
prior to discharge to meet POTW regulatory limits. A pH adjustment system normally consists of
a small tank in which the wastewater pH is adjusted by chemical addition controlled by a pH
meter and mixing. To adjust the pH of the wastewater, either caustics or acids are  added to the
mixing tank.  Some treatment technologies require a high pH (e.g., chemical precipitation), while
others require a low pH (e.g., chemical emulsion breaking).

              Industry Application

              It was generally assumed that facilities reporting at least one vessel into which
either acid or base was added had pH adjustment.  Twenty-two percent of in-scope  facilities
responding to the detailed questionnaire (42 of 190) reported treating their wastewater with pH
adjustment.  Several industrial laundries reported operating more than one pH adjustment unit.
Therefore, the facilities responding to the questionnaire reported operating a total of 46 pH
adjustment units.  Acid (usually sulfuric) is added to the pH adjustment unit most frequently (41
of 46). However, sodium hydroxide (4 of 46), and lime (2 of 46) are also added to the pH
adjustment units.  Seventy percent of the pH adjustment units discussed in the detailed
questionnaire (32 of 46) have one or more mixers.  The average residence time of all 46 units at
the 41 facilities is 2.1 hours.

6.5.10        Ultrafiltration/Microfiltration

              General Description

              Ultrafiltration and microfiltration use semipermeable polymeric membranes to
separate emulsified or colloidal materials suspended in the process wastewater stream by
pressurizing the wastewater so that it permeates the membrane. The membrane of an ultrafilter or
a microfilter forms a screen that retains molecular particles based on their differences in  size,
shape, and chemical structure. The membrane allows solvents and lower molecular weight
molecules to pass through.

              In an ultrafiltration or microfiltration process, the wastewater is pumped through
the membrane.  Water and some low-molecular-weight materials pass through the membrane
under the applied pressure (e.g., 10 to 100 psig). Emulsified oil droplets and suspended particles
are retained, concentrated, and removed continuously (17). Ultrafiltration and microfiltration
have the benefit of removing entrained solids and oils from wastewater with lower capital costs
than chemical treatment (19). However, the limitations of the technologies include  fairly narrow
optimum operating conditions in terms of pH and temperature. In addition, if the wastewater has
a high concentration of suspended solids, the wastewater will require substantial pretreatment to
remove the solids to avoid excessive clogging of the membrane and increased maintenance costs.

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                                                                 Chapter 6 - Pollution Control Technologies

              Industry Application

              One facility responding to the detailed questionnaire reported operating an
ultrafiltration unit and one facility reported operating a microfiltration unit (one percent total).
EPA has since contacted these facilities to determine the effectiveness of ultrafiltration/
microfiltration in treating industrial laundry wastewater.  At the facility reporting use of the
ultrafiltration unit, facility personnel reported that the ultrafiltration unit effectively treats
wastewater generated at the facility. The filter membrane was changed out after 4.5 years of
operation in 1997.  Facility personnel did not report difficulties with membrane clogging. The
wastewater from the facility is treated with a screen and pH adjustment prior to the ultrafiltration
unit. At the facility reporting use of the microfiltration unit, facility personnel reported that they
have since discontinued use of the microfiltration unit because the microfilter clogged whenever
wastewater containing high levels of oil and grease was treated. Because of this clogging, the
facility could not attain the required flow rate through the microfiltration unit.

6.5.11         Centrifugation

              General Description

              Centrifugation applies centrifugal forces to settle and separate higher density solids
from process wastewater.  The two most common types of centrifuges are the solid bowl decanter
and the basket-type centrifuge.  The solid bowl decanter consists of a long bowl, mounted
horizontally and tapered at one end. The sludge or wastewater is introduced at one end
continuously while the bowl rotates, and solids concentrate on the inner wall of the bowl as a
result of the centrifugal forces caused by the bowl's rotation.  A helical scroll,  spinning at a
slightly  different speed, moves the accumulated sludge toward the tapered end. The sludge is
then discharged. The basket centrifuge operates on a batch basis. The sludge or wastewater is
introduced into a vertically mounted spinning bowl.  The solids accumulate against the wall of the
bowl and the water is decanted by being forced over the bowl's outer lip.  When the bowl has
reached its capacity in solids collection, the spinning is stopped and a scraper is used to remove
the solids. The basket-type centrifuge is well suited for sludges containing fine solids that are
difficult to filter or where the nature of the solids varies widely (11).

              Centrifugation may be  combined with certain wastewater treatment chemicals that
act to bring additional pollutants out of solution and form an insoluble floe (e.g., as in chemical
precipitation) that is  also separated from the wastewater by the centrifugal forces.

              Industry Application

              Three percent of in-scope industrial laundries responding to the detailed
questionnaire (6 of 190) reported treating their wastewater with Centrifugation.  Two of these
facilities treat their wastewater with chemical precipitation and use Centrifugation to remove the
sludge from the treated wastewater.  The remaining four facilities reported using centrifuges to
remove  lint from their raw wastewater. While only five of the six facilities reported removing
sludge generated during Centrifugation, EPA believes that all facilities treating their wastewater
with Centrifugation remove the  sludge generated.

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6.5.12        Oil/Water Separation

              General Description

              Like chemical emulsion breaking units, oil/water separators are used primarily to
remove oil and grease, as well  as other related pollutants, from process wastewater streams.
Oil/water separators are similar to batch chemical emulsion breaking units except that no
chemicals are added to an oil/water separator to enhance separation.

              During oil/water separation, the wastewater is allowed to stand long enough to
allow the oil droplets, having a lower specific gravity, to rise and form a layer on the surface.
This layer may be removed by controlling the water level within the unit, such that the oil layer is
raised above the weir and overflows into the collection unit while water underflows the weir. The
oil layer may also be removed by manually or mechanically raking the surface over a weir with a
skimming device.

              Skimming devices typically work by continuously contacting the oil with a
material, usually an oleophilic belt or rope, onto which the oil readily adheres. As the material
passes through the oil layer, the oil coats the surface of the material.  The oil-coated material then
passes through a mechanism that scrapes the oil from the material into an oil-collection unit. This
process uses a motorized drive to continuously remove oil from the wastewater surface.  The
skimming device shown in Figure 6-3 is similar to the type of skimming device used in oil/water
separators.

              Industry Application

              Thirteen percent of industrial laundries responding to the detailed questionnaire
(24 of 190) report treating their wastewater through oil/water separation.  None of these facilities
add demulsifying agents (e.g., acid)  to their wastewater and are therefore not considered to treat
their wastewater with chemical emulsion breaking, as described in Section 6.5.5 of this document.
These facilities employ various devices to remove the oil that has risen to the surface of the
wastewater. These include:

              •       Oil skimmer (63 percent);
              •       Oil mop (17 percent);
              •       Coalescer (13 percent); and
              •       Decanter (4 percent).

              The average residence time of the wastewater in the oil/water separation units is
8.5 hours.
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6.5.13        Media Filtration

              General Description

              Media filtration is used primarily to remove suspended solids from process
wastewater streams.  During the filtration process, wastewater flows through a filter medium
causing solids suspended in the water to become trapped in the medium.  Filter media are usually
beds of granular particles such as sand, anthracite, garnet, or carbon.  The speed at which
wastewater flows through the  filter medium controls the size and number of suspended particles
removed from the wastewater stream. To control the wastewater flow rate through the filter
medium, the wastewater may  flow horizontally or vertically through the filter bed, or the
wastewater may be pumped under pressure through the filter bed.

              As wastewater flows through the filter medium, suspended solids removed from
the wastewater become trapped in the interstitial spaces between the granular particles of the filter
bed.  Over time, this may cause the filter medium to become clogged. Therefore, some media
filtration units may be periodically backwashed to unclog the filter medium.

              Industry Application

              Ten of the 190 in-scope industrial laundries responding to the detailed
questionnaire (five percent) reported operating a media filtration unit. Two of these facilities
reported operating two media  filtration units, resulting in 12 total media filtration units operated
by the in-scope industrial laundries responding to the detailed questionnaire. Sand was the most
commonly filter medium reported (7 of 12; 58 percent).  Four media filtration units used sand
alone (33 percent); three media filtration units operated with sand, anthracite, and garnet as the
filter media (25 percent). Seventeen percent of the media filtration units (2 of 12) used cloth as
the filter medium. One media filtration unit operated with carbon as the filter medium.  Another
media filtration unit operated with clay as the medium.  The final media filtration unit operated
with metal filings  as the medium. Ninety-two percent of the media filtration units (11 of 12)
operate under pressure. Eight media filtration units are periodically backwashed to prevent
clogging of the filter media. All seven sand media filtration units and the metal filings media
filtration unit are periodically backwashed.  Facilities operating media filtration with backwash
reported an average backwash cycle of 10 minutes, which occurs an average of three times per
day.

6.5.14        Carbon Adsorption

              General Description

              Carbon adsorption uses activated carbon to remove dissolved VOCs from process
wastewater.  Activated carbon consists of an amorphous form of carbon that has been specifically
treated with an oxidizing gas to form  a highly porous structure having a large internal surface
area.  Granulated forms of this carbon are often used in a fixed-bed column. The wastewater is
admitted into the unit from the top and is allowed to flow downward though a bed of the
granulated activated carbon that is held in place within the column.  As the water comes in

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contact with the activated carbon, the dissolved VOCs adsorb onto the surface of the activated
carbon. Figure 6-10 presents a diagram of a fixed-bed activated carbon adsorption column.

              As the activated carbon becomes increasingly saturated with VOCs, the
effectiveness of the unit decreases and the carbon must be regenerated. In this process, the spent
activated carbon is oxidized which removes the adsorbed VOCs from the surfaces.  This process
may destroy some of the activated carbon and decrease the performance of the rest. Therefore,
the activated carbon must be periodically replaced for the adsorption unit to continue to operate
effectively.

              To maximize the performance and life of the activated carbon bed, all materials
contained in the wastewater (e.g., suspended particles and heavy organics) that may foul the bed
by "clogging" the pores of the carbon particles must be removed prior to this treatment process.
In addition, the performance of the units may be improved by periodically backflushing the units.
Fixed-bed carbon adsorption units may be operated singly, in series, or in parallel.

              Industry Application

              Two of the 190 industrial laundries (one percent) reported operating activated
carbon adsorption columns to remove VOCs from their process wastewater.

6.5.15        Air Stripping

              General  Description

              Air stripping is usually performed in a countercurrent, packed tower or tray tower
column.  The wastewater is introduced at the top of the column and allowed to flow downward
through the packing material or trays. Air is simultaneously introduced at the bottom of the
column and blows upward through the water stream.  Volatile organics are stripped from the
water stream, transferred to the air stream, and carried out of the top of the column with the air.
The treated water is discharged out of the bottom of the column.  Because the air stream now
contains the VOCs, an air emission control device (e.g., a carbon adsorption unit) may be
required to remove the  VOCs before the air is released to the atmosphere.

              Industry Application

              Three of the 190 in-scope industrial laundries responding to the detailed
questionnaire (two percent) reported operating air strippers  to remove VOCs from their process
wastewater.  However,  through site visits EPA is aware that one of these facilities does not
operate its air stripper.
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                                                            Chapter 6 - Pollution Control Technologies
  influent
dispersion
mechanism
     bed
  support
   screen
                                                                            influent
effluent
            Figure 6-10. Fixed-Bed Activated Carbon Adsorption Column
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6.5.16        Wastewater Treatment Technologies Used by the Industrial Laundries
              Industry in 1998

              As discussed in Section 3.7.2, the industrial laundries trade associations (the
Uniform and Textile Service Association (UTSA) and the Textile Rental Services Association
(TRSA)) solicited updated data on wastewater treatment practices from industrial laundries sent
EPA's detailed questionnaire.  Of the 190 in-scope facilities, 162 responded to the UTSA/TRSA
survey. Table 6-7 summarizes the difference in the use of each major type of wastewater
treatment (e.g., chemical emulsion breaking, DAF, and chemical precipitation) reported in the
detailed questionnaire for the 1993 operating year and in the UTSA/TRSA survey for the 1993
operating year.

              Because the treatment system descriptions reported in the survey often did not
include design parameters or the portion of wastewater treated, EPA made several assumptions in
order to use the data provided by the trade associations.  EPA determined that 18 facilities that
did not have treatment at the time of the detailed questionnaire subsequently installed wastewater
treatment for all or part of their wastewater flow. Most facilities that have installed treatment
since 1993  (13 of the 18) have installed DAF.  Other types of treatment installed include chemical
emulsion breaking (at two facilities), chemical  precipitation (at two facilities), and biological
treatment (at one facility) (20).

              In addition, some facilities changed their main treatment technology since 1993:
four  facilities changed from chemical precipitation to DAF, one facility changed from chemical
emulsion breaking to DAF, and one facility changed from microfiltration to chemical emulsion
breaking (20).

6.6           Pollution Disposal Practices in the Industrial Laundries Industry

              This section presents information on the various types of wastewater, solvent, and
sludge wastes that may be generated at industrial laundries and the disposal practices reported in
the detailed questionnaire or observed by EPA during site visits and sampling episodes.

6.6.1         Wastewater Disposal

              All 190 in-scope industrial laundries responding to the detailed questionnaire
reported discharging their wastewater to a publicly owned treatment works (POTW), a privately
owned treatment works (PrOTW), a federally owned treatment works (FOTW), or a centralized
treatment works (CTW).  Three percent of the facilities discharging wastewater (5 of 190) also
reported disposing of a portion of their wastewater by land application.

              Contract hauling of facility wastewater, in lieu  of on-site treatment, may be a cost-
effective and technically feasible option for some industrial laundries. Wastewater to be hauled
off site could be stored in above ground storage tanks and hauled off site in 5,000 gallon
increments, which is the capacity of most vacuum tankers used to haul the wastewater.
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                                                           Chapter 6 - Pollution Control Technologies
                                     Table 6-7
   Comparison Between Treatment Technologies Reported in 1993 and 1998
Major Wastewater Treatment
Unit Used and Portion of
Wastewater Treated
Chemical Emulsion Breaking
Chemical Precipitation of part of the facility's
wastewater
Chemical Precipitation of all facility wastewater
Dissolved Air Flotation of part of the facility's
wastewater
Dissolved Air Flotation of all facility
wastewater
Microfiltration of part of the facility's
wastewater
Ultrafiltration of all facility wastewater
No treatment
Number of Facilities from
EPA's 1994 Detailed
Questionnaire
5
5
12
2
30
1
1
106
Number of Facilities from
UTSA/TRSA's 1998
Survey
7
4
11
8
42
0
1
891
'One facility from the UTSA/TRSA survey may be operating biological treatment.
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The frequency of bulk wastewater pickups would depend on the amount of time required to
generate 5,000 gallons of wastewater. The wastewater, handled as nonhazardous waste, may be
hauled off site for treatment to a Treatment, Storage, and Disposal Facility (TSDF) or to a
Centralized Waste Treater (CWT) (21).  There were an additional 13 percent (25 of 190) that
reported a very small portion of wastewater being shipped off site for disposal.  However, it is
believed that this wastewater is contained in the sludge collected from the treatment system and
disposed off site.

6.6.2          Waste Organic Material Disposal

              Some industrial laundries generate waste organic material that is either collected
from incoming items or from the wastewater treatment system.  Facilities that generate this type
of waste launder heavily soiled items (e.g., shop towels, printer towels/rags,  and furniture towels)
as a large portion of their total production. By water washing these items, the organic material
that was contained on them is transferred to the process wastewater. One method of collecting
the  waste organic material from the wastewater is through phase separation in equipment that is
designed to collect the organic phase from the water.  The wastewater may also be treated  with
chemicals that aid in removing emulsified organic material from the water. Many of these
techniques were described previously in Sections 6.5.5 and 6.5.12 of this document.  Some
facilities also collect waste organic material that floats to the top of sludge collected from the
wastewater treatment system (e.g., DAF or chemical precipitation).  In some cases, industrial
laundries may remove this waste organic material from the items prior to water washing, as
described in Section 6.4 of this document.

              Most industrial laundries dispose of the collected waste organic material by
shipping it to off site hazardous waste disposal facilities for incineration or for fuel blending.  In
fuel blending, the waste organic material is mixed with other materials and used as a fuel.
Theoretically, the incineration or fuel combustion process destroys the waste organic  material.

              In some cases, depending on the customer source and use of the  items, the
collected waste organic material may be pure enough to be reused, especially that collected from
the  items prior to water washing. Material that cannot be reused directly may need further
processing in a distillation unit where the organic material is separated from other contaminating
pollutants.  The distillation is often performed by a commercial  recycler but can also be performed
on site at the industrial laundry facility.  After distillation, the organic material may be reused by
the  industrial laundries' customers that use the items.

6.6.3          Sludge Disposal

              Industrial laundries generate sludge from a variety of sources. These sources
include trenches, catch basins, settling pits, or other structures that retain the process wastewater
prior to discharge;  shaker or rotary screens; and wastewater treatment units such as DAF or
chemical precipitation that are designed to remove solids.

              EPA believes that all laundries have  trenches and at least one  catch basin that
receive the wastewater from the wash room prior to treatment (if present) or discharge.

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Depending on the retention time of the wastewater within these structures, solids will almost
always accumulate over time. These solids may include large objects, sand, grit, and some lint
that is removed from the items during the water washing.  Laundries will periodically will clean
this sludge from the catch basin and dispose of it, usually in a nonhazardous landfill.

              Many industrial laundries (77 percent of the 190 in-scope facilities) also screen
their wastewater prior to discharge. Lint is collected from these screens regularly and is disposed,
usually in a nonhazardous landfill.

              Some facilities (29  percent of the 190 in-scope facilities) treat their wastewater
with either DAF or chemical precipitation prior to discharge. These technologies coagulate and
agglomerate of organic and metal pollutants to remove them from the wastewater.  The
agglomerate (or floe) is removed from the treatment unit and collected as sludge (the sludge
collection for each of these units was described in Sections 6.5.6 and 6.5.7 of this document).
This sludge comprises some lint and other particles  from the wastewater, metal compounds that
were precipitated from the wastewater, and agglomerated organic materials.  Chemical
precipitation typically uses lime as a coagulant, which contributes to the sludge amount that is
removed from these units.  Based on available data,  EPA estimates that DAF units generate a
median of 0.031 pounds of sludge  per gallon of wastewater and chemical precipitation units
generate  a median of 0.039 pounds of sludge per gallon of wastewater (22).  This sludge is not
usually considered to be hazardous waste, although  some municipalities require it to be disposed
within an industrial waste landfill.  Depending upon  the facility's item mix, this sludge may contain
a significant amount of organic material that makes the sludge suitable for incineration or fuel
blending.

6.7           References

1.            U.S. Environmental Protection Agency. Pollution Prevention at Industrial
              Laundries:  Assessment Observations and Waste Reduction Options. EPA 820-R-
              95-010, Washington, DC, July 1995.

2.            Eastern Research Group, Inc.  Final  Site Visit Report for Confidential Facility.
              Prepared for the U.S.  Environmental Protection Agency, Office of Water,
              Washington, DC, October 1995.

3.            Telecon. "Steam Tumbler Vendor Information."  January 5, 1999.

4.            U.S. Environmental Protection Agency. Technical Development Document for
              Proposed Pretreatment Standards for Existing and New Sources for the Industrial
              Laundries Point Source Category.  EPA-821-R-97-007, Washington, DC,
              November 1997.

5.            Science Applications  International Corporation.  Evaluation of the Solvent
              Extraction Efficiency of an Industrial Centrifuge on a Variety of Shop Towels and
              Wipers.  Prepared for the U.S. Environmental Protection Agency, Office  of Solid
              Waste, Crystal City, VA.

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                                                              Chapter 6 - Pollution Control Technologies
6.            Newspaper Association of America TechNews, Jan-Feb 1997, Take Your Rags for
             a Spin,  http://www.naa.org/technews/tn970102/pl7rags.html.  January 5, 1999.

7.            U.S. Environmental Protection Agency, Design for the Environment.  Lithography
             Case Study 1: Managing Solvents and Wipes.  EPA 744-K-93-001, Washington,
             DC, October 1995.

8.            Telecon. "Centrifugation of Printer Towels."  March 13, 1997.

9.            Eastern Research Group, Inc. Final Sampling Episode Report for Confidential
             Facility. Prepared for the U.S. Environmental Protection Agency, Office of Water,
             Washington, DC, July 1997.

10.           Eastern Research Group, Inc. Final Site Visit Report for Confidential Facility.
             Prepared for the U.S. Environmental Protection Agency, Office of Water,
             Washington, DC, October 1998.

11.           Metcalf and Eddy, Inc. Wastewater Engineering: Treatment. Disposal, and Reuse.
             Third Edition. McGraw-Hill Inc., 1991.

12.           Eastern Research Group, Inc. Stream Splitting Cost Module Documentation for
             the Industrial Laundries Cost Model.  Prepared for the U.S. Environmental
             Protection Agency, Office of Water, Washington, DC, June 14, 1996.

13.           U.S. Environmental Protection Agency. Guidance Document for Effluent
             Discharges from the Auto and Other Laundries Point Source Category. Effluent
             Guidelines Division, Office of Water and Waste Management, Washington, DC,
             February 1982.

14.           The Dober Group. Presenting the Concepts of Wastewater Pretreatment
             Equipment for the Denim and Industrial Laundry Industries. Frank Prendergast,
             Process Engineer, December 12, 1993.

15.           Eastern Research Group, Inc. Shaker Screen Cost Module Documentation for the
             Industrial Laundries Cost Model. Prepared for the U.S.  Environmental Protection
             Agency, Office of Water, Washington, DC, June 14, 1996.

16.           Eckenfelder, W. Wesley, Jr. Industrial Water Pollution Control. Second Edition.
             McGraw-Hill Co., 1989.

17.           U.S. Environmental Protection Agency.  Development Document for Effluent
             Limitations Guidelines and Standards for the Aluminum Forming Point Source
             Category. EPA 440/1-84/073, Washington, DC, June 1984.
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18.          American Water Works Association.  Water Quality and Treatment: A Handbook
             of Community Water Supplies.  Frederick W. Pontius. McGraw-Hill, Inc., 1990.

19.          Abcor, Inc. Ultrafiltration for Dewatering of Waste Emulsified Oils. Steven D.
             Pinto, June 7, 1978.

20.          Memorandum. "Revised Summary of Responses to Wastewater Treatment System
             Upgrade Questions from the UTSA/TRSA Questionnaire." November 12, 1998.

21.          Eastern Research Group, Inc. Contract Haul Cost Module Documentation for the
             Industrial Laundries Cost Model.  Prepared for the U.S. Environmental Protection
             Agency, Office of Water, Washington, DC, October 1997.

22.          Memorandum.  "Comparison of Dissolved Air Flotation (DAF) and Chemical
             Precipitation Dewatered Sludge Generation Rates and Disposal Costs as Reported
             by Industry and as Calculated by the Industrial Laundries Cost Model." June 30,
             1999.
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                           Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards

                                       CHAPTER 7

     TREATMENT PERFORMANCE DATA USED FOR THE DEVELOPMENT OF
                     CANDIDATE PRETREATMENT STANDARDS

7.1           Introduction

              This chapter discusses the treatment performance data available to EPA for use in
developing candidate pretreatment standards for the pollutants of concern. Chapter 5 of this
document discusses the pollutants of concern.  The following information is presented in this
chapter:

              •       Section 7.2 describes the sources of the treatment performance data from
                     well-operated and well-designed treatment systems used by EPA in the
                     calculation of the long-term averages, variability factors, and candidate
                     pretreatment standards and classifies these sources into five postlaundering
                     treatment options;

              •       Section 7.3 describes the data-editing procedures used to identify data
                     points considered appropriate for calculating long-term averages,
                     variability factors, and candidate  pretreatment standards for the five
                     postlaundering treatment options;

              •       Section 7.4 presents the long-term averages for the five postlaundering
                     treatment options for the pollutants of concern;

              •       Section 7.5 presents the methodology for determining pollutants of concern
                     selected for candidate pretreatment standards development and the  pass
                     through analysis;

              •       Section 7.6 presents the long-term average concentrations and variability
                     factors developed for the five treatment options for the pollutants of
                     concern, which can be used to develop local limits based on best
                     engineering judgement;

              •       Section 7.7 presents EPA's analysis on the development of candidate mass-
                     based standards; and

              •       Section 7.8 presents the references used.

7.2           Sources of Treatment Technology Performance Data From Well-Designed
              and Well-Operated Treatment  Systems

              EPA used three sources of treatment performance data to calculate the long-term
average concentrations, variability factors, and candidate pretreatment standards for industrial
laundries wastewater treatment options: 1) EPA industrial laundry sampling data, 2) Detailed

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                           Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards

Monitoring Questionnaire (DMQ) data, and 3) other industry-supplied data. Chapter 3 of this
document describes these sources. EPA first considered sampling data it had collected from
industrial laundries with well-designed and well-operated treatment systems representing the
various treatment options. Chapter 6 of this document describes the treatment technologies used
by the industrial laundries industry. EPA also considered DMQ and other industry-supplied data
from facilities using treatment technologies equivalent to the treatment technologies sampled by
EPA.  Sections 7.2.1, 7.2.2, and 7.2.3 discuss the EPA industrial laundry sampling data, the DMQ
data, and the other industry-supplied data used to develop candidate pretreatment standards.

7.2.1         Industrial Laundry Sampling Program Data

             EPA considered industrial laundry wastewater data from two Agency sampling
programs for use in calculating long-term average concentrations, variability factors, and
candidate pretreatment standards: 1) the 1985-1987 Industrial  Technology Division
(ITD)/Resource Conservation and Recovery Act (RCRA) Sampling Program and 2) the EPA
Office of Water 1993-1998 sampling program.  EPA did not use data from the 1985-1987
ITD/RCRA  Sampling Program to calculate long-term averages, variability factors, and candidate
pretreatment standards. Instead, EPA did use data from the 1993-1998 sampling program in
these  calculations. The identification of sampling data representative of well-designed and well-
operated treatment systems from these  sampling programs is presented below.

7.2.1.1       1985-1987 ITD/RCRA Sampling Program

             EPA collected wastewater samples from five industrial laundries between 1985 and
1987  as part of the ITD/RCRA Sampling Program. EPA reviewed the ITD/RCRA Sampling
Program data to identify facilities with  well-designed and well-operated treatment systems
representative of wastewater treatment technologies used as the basis for the candidate
pretreatment. EPA determined that none of the ITD/RCRA Sampling Program data could be
used to calculate long-term average concentrations, variability factors, or candidate pretreatment
standards, for the following reasons. One facility used a dissolved air flotation unit that was not
operating properly during the sampling episode.  EPA decided that the sampling data from this
facility could not be used because the treatment system was not well operated.  At a second
facility, grab sample water was added to some of the composite samples to make up for
insufficient volume of the composite samples. EPA decided that sampling data for this facility
were not representative of the wastewater from the facility. A third facility used microfiltration as
its main treatment technology.  EPA does not consider microfiltration to be an  easily operated
treatment technology for industrial laundry  wastewater because the filter is easily clogged from oil
and grease in the wastewater. This is supported by several industrial laundries  that tried using
microfiltration without the appropriate  pretreatment  of oil and grease and total  suspended solids
(TSS), and have subsequently replaced the microfilter with a different technology. The final two
facilities used only settling basins; however, EPA does not consider settling basins to represent
effective treatment for the pollutants of concern in industrial laundry wastewater.  Therefore, EPA
decided that sampling data from these five facilities could not be used to develop candidate
pretreatment standards.
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                           Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards

7.2.1.2        1993-1998 EPA Sampling Program

              EPA collected wastewater samples from nine industrial laundries between 1993
and 1998 as part of the data-gathering effort for development of an effluent guideline for the
industrial laundries industry. Facilities for sampling were selected based on site visits and
responses to the  1994 Industrial Laundries Industry Questionnaire (detailed questionnaire). One
sampling episode was performed at each facility. The  sampling data collected by EPA included
both influent and effluent wastewater data representing the major treatment technology used by
each facility. At each facility, EPA collected pollutant concentration data for all of the pollutants
of concern.  The nine sampled industrial laundries used at least one of the following major
wastewater treatment technologies as part of their overall treatment system:

              •       Chemical emulsion breaking;
              •       Dissolved air flotation (DAF);
              •       Chemical precipitation;
              •       Ultrafiltration;
              •       Vacuum degassing; and
              •       Organics control (steam tumbling).

              EPA classified the data from the nine sampled facilities by the treatment
technology used by the facility and the type  of wastewater treated by the treatment technology.
Some of the sampled facilities treated all of their process wastewater while others treated only
heavy wastewater (i.e., wastewater from the washing of heavily soiled items (e.g., shop and
printer towels/rags) or wastewater containing high pollutant concentrations from certain breaks in
the washing cycle).

              EPA's sampling data for microfiltration represent one day of treatment of
wastewater from laundering of only printer towels.  In addition, as discussed earlier in this
section,  microfilters are easily clogged from  oil and grease in industrial laundry wastewater. The
data obtained by EPA during a sampling episode at an industrial laundry using vacuum degassing
do not demonstrate effective treatment of industrial laundry wastewater. Vacuum degassing is
used to remove volatile organics from wastewater.  The sampling data for vacuum degassing did
not demonstrate effective removal of volatile organics. Because vacuum degassing were not
found to be effective in treating industrial laundry wastewater, and EPA did not have enough  data
for microfiltration to evaluate treatment performance and because of operational complexities,
EPA did not calculate long-term average concentrations, variability factors, or candidate
pretreatment standards for these treatment technologies.

              EPA had limited data available for steam tumbling, from one load of steam-
tumbled printer towels  and from one load of non-steam-tumbled printer towels. EPA developed
target effluent concentrations for this prelaundering treatment technology instead of long-term
averages, variability factors, and candidate pretreatment standards. Chapter 6 of this document
presents the treatment performance data for steam tumbling.

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                            Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards

               The remaining sampling data represented the following five treatment options
based on the treatment technology used by the facility and whether the facility sampled was
treating all of its process wastewater or only heavy wastewater:
                     Chemical emulsion breaking treatment of heavy wastewater;
                     DAF treatment of heavy wastewater;
                     Chemical precipitation treatment of heavy wastewater;
                     DAF treatment of all facility process wastewater; and
                     Chemical precipitation treatment of all facility process wastewater.
              Sampling data from the seven facilities representing these five treatment options
were used to calculate long-term average concentrations, variability factors, and candidate
pretreatment standards.  The number of sampled facilities representing each treatment option is
presented in the following table.
Number of EPA Sampled Facilities Representing Each Treatment Option
Chemical Emulsion
Breaking Treatment
of Heavy Wastewater
1
DAF
Treatment of
Heavy
Wastewater
1
Chemical
Precipitation of
Heavy
Wastewater
1
DAF Treatment of
All Facility Process
Wastewater
2
Chemical
Precipitation of All
Facility Process
Wastewater
2
7.2.2
Detailed Monitoring Questionnaire (DMQ) Data
              In 1995, EPA developed and mailed the DMQ to 37 industrial laundries
throughout the United States (as described in Chapter 3 of this document). In response to this
questionnaire, these industrial laundries provided EPA with all available 1993 facility monitoring
data.  DMQ data generally represented fewer pollutants than were analyzed for during the
sampling program, and most of the data provided were for final effluent only, without
corresponding influent data to evaluate treatment system pollutant removals.  EPA reviewed the
DMQ data to determine if the data could be used to represent any of the five treatment options
sampled by EPA.

              EPA determined that 17 of the 37 DMQ facilities did not provide data
representative of the treatment technologies that were considered bases for candidate
pretreatment standards.  Facility diagrams for the remaining 20 facilities using one of these three
treatment technologies were examined to determine if the sampling points for which data were
reported represent final effluent from the treatment technology. EPA determined that data from 9
of the 20 facilities did not meet this criterion. The remaining 11 facilities provided data
representing wastewater effluent concentrations for either DAF treatment of all facility process
wastewater (five facilities) or chemical precipitation treatment of all facility process wastewater
(six facilities). One of the five DAF facilities did not provide any data for pollutants of concern
and one of the six chemical precipitation facilities only provided two data points for each pollutant
of concern; therefore, data from these facilities were not used to calculate long-term averages,
variability factors, or candidate pretreatment standards. Data from four DAF facilities
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                           Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards

and five chemical precipitation facilities were used in conjunction with EPA's sampling data to
calculate long-term average concentrations, variability factors, and candidate pretreatment
standards. For the four DAF facilities, three operated induced air flotation (IAF) systems.

7.2.3         Other Industry-Supplied Data

              Based on an analysis on all treatment performance data submitted in comments and
gathered through EPA's data collection activities (excluding the DMQ), EPA determined that
data from one facility were adequate to incorporate into EPA's loading estimates. Facilities that
did not provide production amounts and types, portion of wastewater stream treated by the
technology, the type  of wastewater treatment technology operated, or total flow at the facility
were determined to have not submitted enough data for EPA to perform a proper analysis of the
data.

              The data EPA used were from a towel only facility operating IAF.  The final
effluent data from this facility were used in conjunction with data previously gathered to represent
treatment performance for facilities operating DAF and only treating wastewater from the water-
washing of shop and or printer towels/rags.

7.3           Evaluation of Treatment Performance Data

              After  identifying available treatment performance data, EPA identified specific  data
points that could not be used to evaluate treatment system performance.  These data were not
used to calculate long-term averages, variability factors, and candidate pretreatment standards.
The following criteria were used to identify these data  points:

              •      Assessment of the treatment system performance at facilities identified
                     above, including identification of process upsets during sampling that
                     impacted the performance of the treatment system;

              •      Identification of pollutants not treated by the treatment technology;

              •      Identification of pollutants not present in influent samples at sufficient
                     concentrations to evaluate treatment effectiveness of the treatment
                     technology;

              •      Identification of treatment performance data with inconsistent detection
                     limits; and

              •      Identification of data considered a lower limit of the actual value.

              These criteria are further described in Sections 7.3.1 through 7.3.5 of this
document.
                                            7-5

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                           Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards

7.3.1          Assessment of Treatment System Performance and Identification of Process
              Upsets

              EPA reviewed the available data to determine if the treatment systems for which
effluent data were available were well operated at the time samples were collected. Data that did
not meet this evaluation criterion were flagged as unusable. To determine good system operation,
EPA used the following parameters, which are indicative of proper operation of the three major
treatment technologies for which data were available:

              •      Chemical Emulsion Breaking:  proper pH and removal of oil and grease;

              •      DAF:  removal of TSS and oil and grease; and

              •      Chemical Precipitation: removal of TSS and oil and grease.

For EPA sampling episodes, EPA reviewed sampling episode reports to determine if any process
upsets occurred during one or more days of each sampling episode and if the treatment systems
showed good performance based on removal of the parameters listed above.  For DMQ and
industry-supplied data, EPA used the following design and operating criteria to evaluate treatment
system performance:

              •      Chemical Emulsion Breaking-pH of wastewater is adjusted with acid and
                    an oil removal mechanism is in place.

              •      DAF—flocculation and coagulation chemicals are added, and an air
                    injection mechanism and a removal system for float sludge are in place.

              •      Chemical Precipitation-flocculation and coagulation chemicals are added
                    and a settling mechanism is in place.

Pollutant removals from DMQ and industry-supplied data could not be calculated because none of
the facilities representing  one of the three major wastewater treatment technologies provided
paired influent and effluent data.

7.3.2          Identification of Pollutants Not Treated by the Treatment Technology

              EPA reviewed the data for each EPA sampling episode to identify pollutants that
were not treated by the treatment technology sampled.  If the average concentration of the
pollutant in the effluent samples from a facility was greater than or equal to the average
concentration of the pollutant in the influent samples, the data were flagged as unusable.  The
DMQ and industry-supplied data could not be evaluated using this criterion because no paired
influent and effluent data were provided.
                                           7-6

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                           Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards

7.3.3         Identification of Pollutants Not Present in Influent Samples at Sufficient
              Concentrations to Evaluate Treatment Effectiveness

              EPA reviewed the data for each EPA sampling episode to determine if a pollutant
was not detected in sufficient concentrations to evaluate treatment effectiveness. If the pollutant
was never detected in influent samples at a facility or if the average concentration of a pollutant in
the influent samples collected from a facility was less than 10 times the method detection level for
that pollutant, the data for that pollutant at that facility were flagged as unusable for calculating
long-term averages, variability factors, and candidate pretreatment standards.  For calculating the
target average concentrations used to determine pollutant loadings and removals, EPA did not use
the 10 times method detection level criterion.  The DMQ and industry-supplied data could not be
evaluated using this criterion because no facilities provided paired influent and effluent data.

7.3.4         Identification of Treatment Performance Data With Inconsistent Detection
              Limits

              EPA reviewed the data for each pollutant at each sampling episode to identify
results showing inconsistent detection limits. If an analytical method used for a pollutant during a
particular episode gave inconsistent detection limits due to laboratories having different
instruments to measure pollutant concentrations, the data for this pollutant and episode were
flagged as unusable.  EPA identified data from three sampling episodes for four organic pollutants
(toluene, naphthalene, tetrachloroethene, and ethylbenzene) that showed inconsistent detection
limits. EPA did not use these data in calculating long-term averages and variability factors.

7.3.5         Identification of Treatment Performance Data Considered a Lower Limit of
              the Actual Value

              EPA reviewed the sampling data to identify pollutant concentrations qualified with
a greater than (>) sign. For these pollutants, EPA considered the reported concentration value to
be a lower limit of the actual concentration value.  EPA did not use the data from these samples
to calculate long-term averages and variability factors.

7.4           Calculation of Long-Term Average Concentrations for the Pollutants of
              Concern

              EPA used the data meeting the review criteria presented in Section 7.3 of this
document to calculate long-term average concentrations for the 72 pollutants of concern for each
of the five postlaundering treatment options. Long-term averages for each pollutant of concern
for each sampling episode were calculated using equations derived from an adapted delta-
lognormal model that accounts for effluent samples with a pollutant concentration at the detection
limit. The detection limit concentration was used in calculations for data points reported as
nondetects.  The Statistical Support Document for Proposed Pretreatment Standards for Existing
and New Sources for the Industrial Laundries Point Source Category (1) presents the
methodology used to calculate long-term averages.  EPA calculated the overall long-term
                                            7-7

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                           Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards

average concentrations for each pollutant of concern by finding the median of the episode long-
term average concentrations. When sampling, DMQ, and industry-supplied data met the data
review criteria for a specific pollutant for a treatment technology group, EPA used these data to
calculate long-term average concentrations.  When only EPA sampling data met the data review
criteria, EPA used only data from EPA-sampled facilities to calculate long-term average
concentrations. When only DMQ and/or industry-supplied data met the data review criteria,  EPA
did not calculate long-term average concentrations for that pollutant for that treatment technology
group because no facilities provided raw waste data. Therefore, EPA could not determine if the
pollutant was present in the raw wastewater.

              Table 7-1 presents the long-term average concentrations for each pollutant of
concern for each of the five treatment options.  The treatment technology options listed in Table
7-1 are defined as follows:

              •       CEB-Heavy represents data from facilities using chemical emulsion
                     breaking treatment of heavy wastewater;

              •       DAF-Heavy represents data from facilities using DAF treatment of heavy
                     wastewater;

              •       CP-Heavy represents data from facilities using chemical  precipitation
                     treatment of heavy wastewater;

              •       DAF-A11 represents data from facilities using DAF treatment of all facility
                     process wastewater; and

              •       CP-A11 represents data from facilities using chemical precipitation
                     treatment of all facility process wastewater.

7.5           Methodology for Determining Pollutants of Concern Selected for Candidate
              Pretreatment Standards Development

              This section presents the methodology used to select pollutant parameters for
which candidate pretreatment standards were calculated for the Industrial Laundries Point Source
Category. These parameters were chosen from the list of 72 pollutants of concern presented  in
Chapter 5 of this document. Although all 72 pollutants of concern were used to estimate
pollutant loading and pollutant reductions, only certain parameters were selected for calculating
candidate pretreatment standards. Because monitoring for all 72 pollutants of concern is not
necessary to ensure that industrial laundry wastewater pollutants are adequately controlled, EPA
chose a subset of the 72 pollutants since a number of the pollutants do not pass through POTWs
and many of the  rest  of the  pollutants originate from similar sources and have similar properties
and would be incidently removed by control of a smaller number of pollutants.  EPA selected the
pollutants for which  candidate  pretreatment standards were calculated to represent the entire
population of the pollutants of concern; they include metals, organic compounds, and SGT-HEM

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                      Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards

                                 Table 7-1

Long-Term Average (LTA) Effluent Concentrations for the Five Treatment
                   Options for the Pollutants of Concern
Pollutant of Concern
Median LTA (mg/L)1
CEB-Heavy2
DAF-Heavy3
CP-Heavy4
DAF-A115
CP-A11'
Conventionals
Biochemical Oxygen Demand 5-Day (BOD5)
Oil and Grease (measured as HEM)
Total Suspended Solids (TSS)
1,040
268
259
1,310
230
487
1,390
38.2
56.3
497
37.8
85.5
399
28.5
117
Priority Organics
1, 1, 1-Trichloroethane
1,2-Diphenylhydrazine
4-Chloro-3-methylphenol
Bis(2-ethylhexyl) Phthalate
Butyl Benzyl Phthalate
Chlorobenzene
Chloroform
Di-ซ-butyl Phthalate
Di-w-octyl Phthalate
Ethylbenzene
Isophorone
Methylene Chloride
Naphthalene
Phenol
Tetrachloroethene
Toluene
trans- 1,2-Dichloroethene
Trichloroethene
—
—
0.205
0.462
—
—
—
0.0100
0.0307
0.305
—
—
0.104
—
0.286
0.543
—
—
—
—
—
0.604
—
—
—
0.173
—
1.37
—
—
0.803
—
—
6.35
—
—
—
45.2
—
0.0469
0.0100
—
—
0.0100
—
0.0931
—
—
0.114
—
0.127
0.818
—
0.0529
0.0277
—
0.220
0.144
—
0.0280
0.185
0.125
0.236
0.189
—
0.546
0.0764
0.211
0.250
0.711
—
—
0.471
—
—
0.0691
0.0100
—
—
—
0.0342
0.154
0.297
—
0.0583
—
0.421
0.973
—
0.0363
Nonconventional Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pentanone
ฐ<-Terpineol
Benzoic Acid
Benzyl Alcohol
Hexanoic Acid
m-Xylene
ซ-Decane
ซ-Docosane
—
0.0458
1.21
0.0722
0.0100
—
—
0.128
0.366
0.279
0.0347
4.68
0.129
7.42
9.55
0.471
—
—
—
—
1.26
0.110
—
0.0100
—
—
—
—
—
—
0.104
0.0240
0.0120
17.4
0.116
13.6
0.595
0.472
1.58
—
—
0.595
0.469
0.0232
3.23
0.0114
1.54
1.96
—
—
0.342
0.203
0.241
0.0873
0.0113
                                     7-9

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Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards
      Table 7-1 (Continued)
Pollutant of Concern
Median LTA (mg/L)1
CEB-Heavy2
DAF-Heavy3
CP-Heavy4
DAF-A115
CP-A11'
Nonconventional Organics (Continued)
ซ-Dodecane
ซ-Eicosane
ซ-Hexacosane
ซ-Hexadecane
ซ-Octacosane
ซ-Octadecane
ซ-Tetracosane
ซ-Tetradecane
ซ-Triacontane
o-&p-Xylene
p-Cresol
p-Cymene
Pentamethylbenzene
0.574
0.0779
0.0100
0.0417
0.0100
0.0560
—
0.116
—
0.359
—
—
—
—
0.148
—
0.489
—
0.422
—
0.979
—
—
—
0.608
—
0.0100
0.0382
0.0122
0.0315
0.0100
0.0100
0.0329
0.612
0.0341
0.0940
—
0.0208
0.0100
0.195
0.0477
0.0195
0.0842
—
0.0694
0.0219
0.0754
0.0100
0.271
—
0.0700
—
1.46
0.150
0.0144
0.0413
0.0168
0.0308
0.0121
0.0394
0.0138
0.197
—
0.0100
—
Priority Metals and Elements
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
0.195
—
—
0.132
0.153
0.437
0.914
—
0.255
—
—
—
6.78
—
—
—
—
0.0715
1.45
0.237
—
—
—
0.0846
—
0.903
—
—
—
0.00500
0.0147
0.534
0.0473
—
—
—
—
—
0.0637
0.0800
—
—
0.0161
0.0695
0.478
0.175
—
0.0544
0.0524
—
—
0.837
—
—
—
0.00774
0.0463
0.270
0.0993
0.000329
0.0436
—
—
—
0.303
Nonconventional Metals and Elements
Aluminum
Barium
Boron
Cobalt
Iron
Manganese
Molybdenum
Tin
Titanium
Vanadium
6.33
—
1.64
—
47.3
0.596
0.205
—
0.0818
—
1.34
0.702
—
—
19.0
0.884
—
—
0.0927
—
0.0804
0.145
11.4
—
0.366
0.00768
0.774
—
0.00453
—
1.31
—
—
—
2.79
0.0340
0.119
0.0972
0.0192
—
1.33
—
—
—
1.78
0.0318
0.275
0.0495
0.0461
—
                  7-10

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                                 Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards
                                       Table 7-1  (Continued)
Pollutant of Concern
Median LTA (mg/L)1
CEB-Heavy2
DAF-Heavy3
CP-Heavy4
DAF-A115
CP-A11'
Nonconventional Metals and Elements (Continued)
Yttrium
—
—
—
—
—
Bulk Nonconventionals
Chemical Oxygen Demand (COD)
Total Organic Carbon (TOC)
Total Petroleum Hydrocarbon (measured as SGT-HEM)7
2,460
626
200
3,320
1610
42.1
2,510
910
7.20
998
326
13.7
1,270
310
10.2
'LTAs for these pollutants of concern, for all options, were not calculated for one or more of the following reasons: the
pollutant was not treated by the technology; the pollutant was detected below treatable concentrations in the wastewater
influent; the pollutant was not detected in the influent wastewater; there was a process upset at the time samples were
collected; the treatment performance data had inconsistent detection limits, or data considered a lower limit of the actual
value. See Section 7.3 of this chapter for more details related to the data editing criteria.
2CEB-Heavy represents data from facilities using chemical emulsion breaking treatment of heavy wastewater.
3DAF-Heavy represents data from facilities using DAF treatment of heavy wastewater.
4CP-Heavy represents data from facilities using chemical precipitation treatment of heavy wastewater.
5DAF-A11 represents data from facilities using DAF treatment of all facility process wastewater.
6CP-A11 represents data from facilities using chemical precipitation treatment of all facility process wastewater.
7SGT-HEM is measured by Method 1664 (promulgated at 64 FR 26315; May 14,  1999).  In this method, EPA defines
SGT-HEM as non-polar material (NPM). Throughout this document and the Industrial Laundries Administrative
Record, EPA refers to SGT-HEM as total petroleum hydrocarbon (TPH).

HEM-Hexane Extractable Material.
SGT-HEM - Silica Gel Treated-Hexane Extractable Material.
                                                   7-11

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                           Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards
(TPH)1 (as an overall indicator pollutant of effective control).  Table 7-2 presents the selected
pollutants of concern. The rationale for selecting these pollutants is discussed below.
7.5.1          Elimination of Treatment Chemicals

              EPA eliminated aluminum and iron from the list of selected pollutants for
candidate pretreatment standards development because aluminum and iron are commonly added
to wastewater as treatment chemicals in the industrial laundries industry. Potential regulation of
aluminum and iron could interfere with their beneficial use as wastewater treatment additives.

7.5.2          Elimination of Pollutants Not Treated or Below Treatable Concentrations

              EPA eliminated pollutants from the list of pollutants of concern when they were
not removed by the treatment technologies that were the bases for the technology options. EPA
also eliminated pollutants when the pollutants were present below treatable concentrations in
wastewater influent to the treatment systems, and therefore would not be substantially removed
by the treatment technologies under consideration.  For the purposes of this analysis, EPA used
only influent data greater than 10 times the method detection level for each pollutant to reliably
evaluate treatment effectiveness within the consistent operating range of the main treatment
technologies considered.

              EPA considered two main technologies as the bases  for the regulatory options (see
Chapter 8 of this document for a description of the regulatory options). The two technologies are
chemical precipitation and DAF. Pollutants were not selected for candidate pretreatment
standards development if they were not detected or were detected below treatable concentrations
in either DAF or chemical precipitation influent wastewater. Table 7-3 presents these pollutants
and the reasons the pollutants were eliminated.

7.5.3          Elimination of Pollutants that Do Not Pass Through or Otherwise Interfere
              with Publicly Owned Treatment Works (POTWs)

              Section 307(b) of the Clean Water Act authorizes EPA to promulgate
pretreatment standards for indirect dischargers to control pollutants that pass through, interfere
with, or are incompatible with the operation of POTWs.  Pollutants shown to pass through a
POTW  may be regulated by categorical pretreatment standards.  This section presents a brief
background of EPA's guidance and methods used for evaluating pass through, and the results of
the pass-through evaluation.
^GT-HEM is measured by Method 1664 (promulgated at 64 FR 26315; May 14, 1999).  In this method, EPA defines
SGT-HEM as non-polar material (NPM). Throughout this document and the Industrial Laundries Administrative
Record, EPA refers to SGT-HEM as total petroleum hydrocarbon (TPH).

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                     Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards

                                 Table 7-2

Selected Pollutants of Concern for Treatment Options Considered in
      Developing Long-Term Averages and Variability Factors
                                  Pollutant
                              Priority Organics
                                Ethylbenzene
                              Tetrachloroethene
                         Nonconventional Organics
                                 OT-Xylene
                                o-&/?-Xylene
                               Priority Metals
                                   Copper
                                    Zinc
                           Bulk Nonconventionals
            Total Petroleum Hydrocarbon (measured as SGT-HEM)1
 1 SGT-HEM is measured by Method 1664 (promulgated at 64 FR 26315; May 14, 1999). In this method, EPA
 defines SGT-HEM as non-polar material (NPM). Throughout this document and the Industrial Laundries
 Administrative Record, EPA refers to SGT-HEM as total petroleum hydrocarbon (TPH).

 SGT-HEM - Silica Gel Treated-Hexane Extractable Material
                                        7-13

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               Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards

                          Table 7-3

Pollutants Eliminated from Further Consideration From the
 Pass-Through Analysis Because They Are Not Treated or
         They Are Below Treatable Concentrations
Pollutant
Reason Excluded
Priority Organics
1 ,2-Diphenylhydrazine
4-Chloro-3-methylphenol
Butyl Benzyl Phthalate
Chlorobenzene
Chloroform
Di-H-butyl Phthalate
Isophorone
Methylene Chloride
Phenol
trans- 1 ,2-Dichloroethene
Trichloroethene
Pollutant not detected in CP and DAF influents.
Pollutant detected below treatable concentrations in CP
influent.
Pollutant detected below treatable concentrations in DAF influent.
Pollutant detected below treatable concentrations in CP
Pollutant detected below treatable concentrations in CP
Pollutant detected below treatable concentrations in CP
influent.
influent.
influent.
Pollutant not detected in DAF influent.
Pollutant detected below treatable concentrations in CP
influent.
Pollutant not treated by CP technology.
Pollutant not detected in CP influent and pollutant not treated by DAF
technology.
Pollutant not treated by DAF technology.
Nonconventional Organics
ฐ= -Terpineol
Benzoic Acid
Benzyl Alcohol
Hexanoic Acid
w-Octacosane
/>-Cresol
Pentamethy Ibenzene
Pollutant detected below treatable concentrations in CP
influent.
Pollutant not treated by CP technology.
Pollutant not treated by DAF technology.
Pollutant not detected in DAF influent.
Pollutant detected below treatable concentrations in DAF influent.
Pollutant not detected in CP influent and pollutant detected below treatable
concentrations in DAF influent.
Pollutant not detected in CP and DAF influents.
Priority Metals and Elements
Antimony
Arsenic
Beryllium
Mercury
Selenium
Silver
Thallium
Pollutant detected below treatable concentrations in CP
Pollutant detected below treatable concentrations in CP
Pollutant detected below treatable concentrations in CP
detected in DAF influent.
influent.
and DAF influents.
influent and pollutant not
Pollutant detected below treatable concentrations in DAF influent.
Pollutant detected below treatable concentrations in CP
Pollutant detected below treatable concentrations in CP
influent.
and DAF influents.
Pollutant not detected in CP influent and pollutant detected below treatable
concentrations in DAF influent.
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                                Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards
                                      Table 7-3 (Continued)
Pollutant
Reason Excluded
Nonconventional Metals and Elements
Barium
Boron
Cobalt
Vanadium
Yttrium
Pollutant
Pollutant
Pollutant
Pollutant
Pollutant
detected
detected
detected
detected
detected
below treatable concentrations in
below treatable concentrations in
below treatable concentrations in
below treatable concentrations in
below treatable concentrations in
CP
CP
CP
CP
CP
andDAF
andDAF
andDAF
andDAF
andDAF
influents.
influents.
influents.
influents.
influents.
Source: Industrial Laundries Treatment Performance Data.
CP - Chemical Precipitation
DAF - Dissolved Air Flotation
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                          Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards

7.5.3.1       Background

             To promulgate pretreatment standards for a specific industry, EPA examines
whether the pollutants discharged by the industry pass through  a POTW to waters of the U.S. or
interfere with POTW operation or sludge disposal practices. Generally, in determining whether
pollutants pass through a POTW, EPA compares the percentage of the pollutant removed by
well-operated POTWs achieving secondary treatment with the percentage of the pollutant
removed by candidate meeting best available technology (BAT) or pretreatment technology
options.

             For specific pollutants, such as volatile organic compounds or highly
biodegradable compounds, EPA may use other means to determine if POTWs provide effective
treatment. For volatile compounds, a volatile override test based on the Henry's Law Constant is
used to determine pass through. For the volatile compounds that are also highly biodegradable,
the pass-through determination may be conducted using engineering modeling, such as WATERS,
to determine biodegradation rates representing POTW treatment.

             For the industrial laundries industry, where only pretreatment standards are being
considered (since EPA has not identified any direct dischargers) EPA compared the POTW
pollutant removal efficiency with pollutant removal efficiencies  estimated using the candidate
PSES technology representing BAT factors. EPA finds that a pollutant passes through when the
average removal efficiency achieved nationwide by well-operated POTWs (those meeting
secondary treatment requirements) is less than the average removal efficiencies achieved by
facilities meeting the candidate PSES for that pollutant, considering the factors listed in Sections
301 and 304 of the Clean Water Act.

             For this final action, EPA determined that a pollutant that has a Henry's Law
Constant greater than 1  x  10"5 atm-m3/mol will be sufficiently volatile such that a significant
portion of the compound would not be treated by the POTW because a significant portion of the
compound volatilizes to the air. EPA further determined the extent to which pollutants are
degraded at POTWs.  For such volatile compounds, EPA determined POTW  percent removal
based on the POTW removal model for the pollutant with the most similar Henry's Law Constant,
as presented in the Development Document for the Pharmaceutical Manufacturing Industry
Effluent Limitations Guidelines and Standards (63 FR 50388) using a combination of POTW
empirical data and the WATERS biodegradation model as described in Section 7.5.4.7 of this
chapter.

             EPA eliminated three conventional pollutants, biochemical oxygen demand
(BOD5), total suspended solids (TSS), and oil and grease (measured as HEM), from consideration
for the pass-through analysis without conducting the percent removal comparison because
POTWs are designed to treat these parameters.  EPA does not consider these three conventional
pollutants to pass through. EPA also eliminated TPH (measured as SGT-HEM) from
consideration, because instead of examining TPH, EPA conducted a pass-through analysis of the
individual compounds (w-alkanes and several others) that were found to compose TPH from the
EPA Method 1664 Characterization Study data. For the pass-through analysis, EPA
                                          7-16

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                           Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards

evaluated 39 pollutants from the list of 72 pollutants of concern.  Tables 7-4 and 7-5 present the
POTW removals used in the pass-through analysis.  The following sections present the
methodology and results from the pass-through analysis performed for both chemical precipitation
and DAF candidate pretreatment technology options.

7.5.3.2        Methodology for Determining Treatment Technology Percent Removals

              Industrial laundry wastewater treatment performance data for chemical
precipitation and dissolved air flotation were obtained during the industrial laundries sampling
program. EPA obtained influent and effluent data from two chemical precipitation facilities and
from two DAF facilities.  EPA used these data to determine whether a pollutant passes through a
POTW. For conducting the pass-through analysis, EPA edited the data as described in Section
7.3 of this chapter for calculating the long-term average concentrations.  This editing included
excluding influent and the corresponding effluent data that were associated with treatment or
process upsets, excluding data for pollutants that were never detected in influents to treatment
systems, excluding data for pollutants not treated by the treatment technology, and excluding data
with influent concentrations less than 10 times the method detection level. Using these editing
criteria allowed for the possibility that low percent removals reflected low influent concentrations,
not poor treatment technology performance.

              After editing the data, EPA used the following methodology to calculate a percent
removal:

              1)     The remaining influent data and effluent data for a sampled facility were
                     averaged for each pollutant, to give an average influent concentration and
                     an  average effluent concentration for each pollutant.

              2)     EPA calculated percent removals from the average influent and average
                     effluent concentrations for each pollutant for a sampled facility using the
                     following equation:
                                        Influent  -  Effluent
                    Percent Removal  =  	^	^  x  100
                                               Influent
                                                      ave
              3)     EPA calculated the median percent removal for each pollutant for each
                     technology from the facility-specific percent removals.

7.5.3.3        Methodology for Determining POTW Percent Removals

              The primary source of the POTW percent removals data was the Fate of Priority
Pollutants in Publicly Owned Treatment Works TSO POTW Study) (2).  However, the 50 POTW
Study did not contain data for all pollutants for which the pass-through analysis was to be
performed. Therefore, EPA obtained additional data from the Risk Reduction Engineering
Laboratory (RREL) Treatability Database (3). Biodegradation data estimated using WATERS
were obtained from the Final POTW Pass-Through Analysis for the Pharmaceutical
Manufacturing Point Source Category (4). Additional information on these sources is presented

                                           7-17

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                                                           Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards
                                                      Table 7-4

                Comparison of the Chemical Precipitation Treatment Technology and POTW Percent
                            Removals for the Industrial Laundries Pass-Through Analysis
Pollutant
(Median)
Chemical
Precipitation
Percent
Removal
(Median)
Percent
POTW
Removal
Source of POTW
Removals
Chemical
Precipitation
Removal Greater
than POTW
Removal?
Henry's Law
Constant Greater
than 1.0x10 5 atm-
nrVmol?
Pass Through?
Bulk Nonconventionals
Chemical Oxygen Demand
(COD)
Total Organic Carbon (TOC)
88
45
82
71
SOPOTW(IOXDL)
SOPOTW(IOXDL)
Yes
No
NA
NA
Yes
No
Priority Organics
1,1,1 -Trichloroethane
Bis(2-ethylhexyl) Phthalate
Di-H-octyl Phthalate
Ethylbenzene
Naphthalene
Tetrachloroethene
Toluene
35
98
94
69
88
85
45
24
60
33
33
18
33
33
WATERS
SOPOTW(IOXDL)
WATERS
WATERS
WATERS
WATERS
WATERS
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Nonconventional Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pentanone
w-Decane
w-Docosane
w-Dodecane
8
96
15
21
98
96
84
18
28
85
18
33
94
33
WATERS
RREL 5 (All WW)
WATERS
WATERS
WATERS
Generic Removal
WATERS
No
Yes
No
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
No
Yes
No
Yes
No
Yes
Yes
Yes
Yes
oo

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                                                                              Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards
                                                                Table 7-4 (Continued)
Pollutant
(Median)
Chemical
Precipitation
Percent
Removal
(Median)
Percent
POTW
Removal
Source of POTW
Removals
Chemical
Precipitation
Removal Greater
than POTW
Removal?
Henry's Law
Constant Greater
than 1.0x10 5 atm-
nrVmol?
Pass Through?
Nonconventional Organics (Continued)
w-Eicosane
w-Hexacosane
w-Hexadecane
w-Octadecane
w-Tetracosane
w-Tetradecane
w-Triacontane
w-Xylene
o-&/>-Xylene
/7-Cymene1
98
92
98
94
98
98
91
80
71
92
33
94
33
33
94
33
94
33
33
99
WATERS
Generic Removal
WATERS
WATERS
Generic Removal
WATERS
Generic Removal
WATERS
WATERS
RREL5 (All WW)
Yes
No
Yes
Yes
Yes
Yes
No
Yes
Yes
No
Yes
No
Yes
Yes
No
Yes
No
Yes
Yes
NA
Yes
No
Yes
Yes
Yes
Yes
No
Yes
Yes
No
Priority Metals and Elements
Cadmium
Chromium
Copper
Lead
Nickel
Zinc
94
93
94
96
97
96
91
91
84
92
52
77
SOPOTW(IOXDL)
SOPOTW(IOXDL)
SOPOTW(IOXDL)
SOPOTW(IOXDL)
SOPOTW(IOXDL)
SOPOTW(IOXDL)
Yes
Yes
Yes
Yes
Yes
Yes
NA
NA
NA
NA
NA
NA
Yes
Yes
Yes
Yes
Yes
Yes
VO

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                                                                              Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards
                                                                Table 7-4 (Continued)
Pollutant
(Median)
Chemical
Precipitation
Percent
Removal
(Median)
Percent
POTW
Removal
Source of POTW
Removals
Chemical
Precipitation
Removal Greater
than POTW
Removal?
Henry's Law
Constant Greater
than 1.0x10 5 atm-
nrVmol?
Pass Through?
Nonconventional Metals and Elements
Manganese
Molybdenum
Tin
Titanium
97
46
92
90
41
52
65
69
RREL5 (All WW)
RREL5 (Dom WW)
RREL5 (All WW)
RREL5 (All WW)
Yes
No
Yes
Yes
NA
NA
NA
NA
Yes
No
Yes
Yes
to
o
'Henry's Law Constant data were not available for this pollutant.
WATERS - Percent biodegradation calculated because pollutant has a Henry's Law Constant greater than 1.0 x 10"5 atm-mVmol.
50 POTW (10XDL) - 50 POTW Study, using 10 times the method detection level editing criterion.
RREL5 (All WW) - RREL Treatability Database Version 5.0, using domestic and industrial wastewater editing criterion.
RREL5 (Dom WW) - RREL Treatability Database Version 5.0, using domestic wastewater editing criterion.
Generic Removal - Based on reported POTW removal values for two n-alkanes, w-Dodecane and w-Eicosane.
NA - Not applicable.

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                                                           Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards

                                                       Table 7-5
                         Comparison of the DAF Treatment Technology and POTW Percent
                            Removals for the Industrial Laundries Pass-Through Analysis
Pollutant
(Median)
DAF Percent
Removal
(Median)
Percent
POTW
Removal
Source of POTW
Removals
DAF Removal
Greater than
POTW
Removal?
Henrys Law
Constant Greater
than 1.0x10 5 atm-
nrVmol?
Pass Through?
Bulk Nonconventionals
Chemical Oxygen Demand
(COD)
Total Organic Carbon (TOC)
82
66
82
71
SOPOTW(IOXDL)
SOPOTW(IOXDL)
No
No
NA
NA
No
No
Priority Organics
1,1,1 -Trichloroethane
Bis(2-ethylhexyl) Phthalate
Di-H-octyl Phthalate
Ethylbenzene
Naphthalene
Tetrachloroethene
Toluene
75
>99
91
94
93
74
48
24
60
33
33
18
33
33
WATERS
SOPOTW(IOXDL)
WATERS
WATERS
WATERS
WATERS
WATERS
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Nonconventional Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pentanone
w-Decane
w-Docosane
w-Dodecane
w-Eicosane
29
97
36
48
99
91
99
98
18
28
85
18
33
94
33
33
WATERS
RREL 5 (All WW)
WATERS
WATERS
WATERS
Generic Removal
WATERS
WATERS
Yes
Yes
No
Yes
Yes
No
Yes
Yes
Yes
No
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
No
Yes
Yes
No
Yes
Yes
to

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                                                                              Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards
                                                                Table 7-5 (Continued)
Pollutant
(Median)
DAF Percent
Removal
(Median)
Percent
POTW
Removal
Source of POTW
Removals
DAF Removal
Greater than
POTW
Removal?
Henrys Law
Constant Greater
than 1.0x10 5 atm-
nrVmol?
Pass Through?
Nonconventional Organics (Continued)
w-Hexacosane
w-Hexadecane
w-Octadecane
w-Tetracosane
w-Tetradecane
w-Triacontane
w-Xylene
o-&/>-Xylene
/7-Cymene1
98
99
97
98
98
94
95
66
94
94
33
33
94
33
94
33
33
99
Generic Removal
WATERS
WATERS
Generic Removal
WATERS
Generic Removal
WATERS
WATERS
RREL5 (All WW)
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
No
No
Yes
Yes
No
Yes
No
Yes
Yes
NA
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
No
Priority Metals and Elements
Cadmium
Chromium
Copper
Lead
Nickel
Zinc
87
92
91
92
87
90
91
91
84
92
52
77
SOPOTW(IOXDL)
SOPOTW(IOXDL)
SOPOTW(IOXDL)
SOPOTW(IOXDL)
SOPOTW(IOXDL)
SOPOTW(IOXDL)
No
Yes
Yes
No
Yes
Yes
NA
NA
NA
NA
NA
NA
No
Yes
Yes
No
Yes
Yes
to
to

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                                                                              Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards
                                                                Table 7-5 (Continued)
Pollutant
(Median)
DAF Percent
Removal
(Median)
Percent
POTW
Removal
Source of POTW
Removals
DAF Removal
Greater than
POTW
Removal?
Henrys Law
Constant Greater
than 1.0x10 5 atm-
nrVmol?
Pass Through?
Nonconventional Metals and Elements
Manganese
Molybdenum
Tin
Titanium
92
52
73
93
41
52
65
69
RREL5 (All WW)
RREL5 (Dom WW)
RREL5 (All WW)
RREL5 (All WW)
Yes
No
Yes
Yes
NA
NA
NA
NA
Yes
No
Yes
Yes
to
'Henry's Law Constant data were not available for this pollutant.
WATERS - Percent biodegradation calculated because pollutant has a Henry's Law Constant greater than 1.0 x 10"5 atm-mVmol.
50 POTW (10XDL) - 50 POTW Study, using 10 times the method detection level editing criterion.
RREL5 (All WW) - RREL Treatability Database Version 5.0, using domestic and industrial wastewater editing criterion.
RREL5 (Dom WW) - RREL Treatability Database Version 5.0, using domestic wastewater editing criterion.

Generic Removal - Based on reported POTW removal values for two n-alkanes, w-Dodecane and w-Eicosane.
NA - Not applicable.

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                           Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards

below. EPA gave these data sources the following priority in determining the percentage removal
of pollutants by POTWs nationwide:

              1)      50 POTW Study;
              2)      RREL Treatability Database; and
              3)      Generic pollutant group removal.

7.5.3.4        50 POTW Study

              EPA edited the 50 POTW Study data to eliminate influent and the corresponding
effluent data where the average influent concentration at a POTW was less than 10 times the
method detection level, to allow for the possibility that low percent removals reflected low
influent concentrations, not POTW treatment technology performance. EPA used the method
detection levels reported at the time of the 50 POTW Study to edit the data.

              In cases where no data remained after conducting the ten times the method
detection level edit, EPA used less stringent editing criteria. In these cases, influent data and the
corresponding effluent data were eliminated where the influent concentrations were less than 20
|ig/L or less than the method detection level for pollutants where the method detection level is
greater than 20 jig/L. EPA selected 20 jig/L because, for pollutants with low influent
concentrations (i.e., less than 20 |ig/L or the method detection limit), the effluent concentrations
were consistently below the method detection level and could not be precisely quantified.

              After editing the POTW data, EPA used the following methodology to calculate
POTW percent removal:

              1)      The remaining influent data and effluent data for each POTW were
                     averaged for each pollutant to give an average influent concentration and
                     an average effluent concentration for each pollutant.  EPA determined that
                     the minimum concentration at which a pollutant can be accurately
                     measured is the method detection level. Therefore, if the average effluent
                     concentration was less than the method detection level, EPA set the
                     average effluent concentration to the method detection level before
                     calculating the average effluent concentration.

              2)      Percent removals were calculated from the average influent and average
                     effluent concentrations for each pollutant  for the POTW using the equation
                     in Section 7.5.3.2 of this document.

              3)      The median percent removal was calculated for each pollutant from the
                     POTW-specific percent removals.

7.5.3.5        RREL Treatability Database

              If the POTW percent removal for a pollutant could  not be calculated using the 50
POTW Study data, EPA used data from the RREL Treatability Database to determine the POTW

                                           7-24

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                           Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards

percent removal. Because individual influent/effluent pairs were not provided in the database, the
data-editing criteria used for the 50 POTW Study could not be used. EPA edited the RREL
Treatability Database using the following criteria:

              1)      Only data pertaining to domestic wastewater were used, unless there were
                     less than three data points available.

              2)      If there were less than three data points available using the domestic
                     wastewater edit, a  combination of domestic wastewater and industrial
                     wastewater data was used.

              3)      Only full-scale and pilot-scale data were used; bench-scale data were not
                     used.

              4)      Only data from a peer-reviewed journal, a government report, or a
                     government database were used. However, data from the 50 POTW Study
                     (a government report) reported in the RREL Treatability Database were
                     not used. These data points were not used because if the RREL
                     Treatability Database was being examined, it meant that the data for a
                     pollutant did not meet the editing criteria for the 50 POTW Study, as
                     outlined above.

              5)      Only data from treatment technologies representing secondary treatment of
                     wastewater were used.  These technologies included activated sludge,
                     aerated lagoon, sedimentation followed by activated sludge, and activated
                     sludge followed by activated sludge treatment.

              After applying these editing criteria, EPA calculated percent removals for each
data source for each pollutant, using the equation in Section 7.5.3.2 of this document.  EPA then
took the median of the percent removals for each pollutant to obtain a median POTW percent
removal from the RREL Treatability Database.

7.5.3.6        Generic Removal

              After the editing of the 50 POTW Study and RREL Treatability Database, data for
some of the w-alkanes were  still not available.  In order to determine an appropriate POTW
percent removal for these pollutants, the available data for the 72 pollutants of concern were
reviewed. EPA determined that one source of POTW removal data for specific w-alkanes would
be the generic group removal  of the w-alkanes for which data were available. Table 7-6 presents
this source of w-alkanes removal data which were used to calculate the percent removal for

specific w-alkanes without POTW percent removal data.  The percent removal for w-decane in this
database was excluded from this analysis  because it reported only a minimum percent removal.
The generic percent removal of 94 percent was obtained from w-dodecane and
w-eicosane. This percentage removal was transferred to four other alkanes, w-docosane,
w-hexacosane, w-tetracosane, and w-triacontane.  Because the w-dodecane and w-eicosane were

                                          7-25

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                              Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards

                                            Table 7-6

                             Generic Removal for #-Alkanes
Pollutant
w-Decane
w-Dodecane
w-Eicosane
Average Group Removal
POTW Removal (%)
>9'
95
92
94
Source of Data
RREL Treatability Database -
Industrial Wastewater Edit
RREL Treatability Database -
Industrial Wastewater Edit
RREL Treatability Database -
Industrial Wastewater Edit
Domestic and
Domestic and
Domestic and

'The POTW percent removal for w-decane was not used in calculating the average group removal because the removal
represents a reported minimum value only; the actual removal may be between nine and >99 percent.
                                               7-26

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                           Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards

subsequently determined to be volatile organic compounds (see Section 7.5.3.7 below), and
therefore POTW removal for them did not represent POTW removal for nonvolatile w-alkanes.
EPA estimated POTW removal for the nonvolatile w-alkanes based on the 74 percent removal of
TPH discussed in the NOD A. Since the four alkanes using the transferred removals were
determined to be non-volatile alkanes, and were identified as constituents of TPH, a POTW
removal of greater than 74 percent was identified, based on the removal of TPH in comments to
the proposal. Thus, the removal of the four alkanes were evaluated based on a removal range of
74 to 94 percent. A comparison of the differences in pollutant removals (in pounds and toxic
weighted pounds) based on the two removal rates is shown in Table 7-7.  These results show very
minimal changes (less than one percent in pounds; only one toxic pound equivalent) in the
loadings. The magnitude of these changes would not affect the overall decision  that no national
regulation is warranted.

7.5.3.7       Biodegradation Rates for Volatile Organics

             EPA's pass-through analysis for industrial laundries included a volatility analysis.
At proposal, pollutants that had a Henry's Law Constant greater than 2.4 x 10"5  atm-m3/mol were
determined to volatilize prior to reaching the POTW and therefore were considered to pass
through the POTW. No credit was given for the biodegradation of these compounds and the
POTW percent removal was  set to zero. Based on  comments and additional  data gathered by
EPA through other rulemaking activities, EPA determined that a portion of all the volatile
compounds is biodegraded at the POTWs. In addition, EPA determined for the final action that
pollutants with Henry's Law Constants greater than 1 x 10"5 atm-m3/mol  are considered volatile.

             The primary source of the biodegradation data is based on the methodology
incorporating empirical data with WATERS modeling results for primary and secondary treatment
at a POTW. During the Pharmaceuticals Manufacturing Point Source Category  Effluent
Limitations, Guidelines, and Standards rulemaking  (63 FR 50388) data concerning volatility  and
biodegradation were gathered for seven pollutants;  four of these pollutants overlapped  with
pollutants of concern for the industrial laundries (chloroform, 2-propanone2, methylene chloride,
and toluene). EPA also obtained data for three additional pollutants (methanol,  ethanol, and
isopropanol). These data were based on pharmaceutical sampling data and modeling information
to determine the overall percent biodegradation for these pollutants.

             EPA adopted this analysis approach in the pharmaceuticals rulemaking and for the
industrial laundries final action in order to  be consistent with the MACT standards which consider
water soluble compounds less likely to volatilize than compounds that are partially soluble. The
following data sources were used in this analysis:

             •      EPA and Pharmaceutical Research and Manufacturers Association
                    (PhRMA) wastewater samples collected from the primary treatment works
                    at the Barceloneta POTW in Barceloneta, Puerto Rico;
 For the pharmaceuticals manufacturing point source category, 2-propanone was referred to as acetone.

                                          7-27

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                            Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards

                                         Table 7-7

POTW Pollutant Removals Based on a Revised  POTW Removal Efficiency for
                                 Nonvolatile w-Alkanes1
                             (Entire Industry - No Cutoff)
Pollutant group
Pollutant
Removal
with 94%
Pollutant
Removal
with 74%
Toxic Weighted
Pollutant Removal
with 94%
Toxic Weighted
Pollutant Removal
with 74%
DAF-IL
Total Nonconventional Organics2
Total Pollutants3
519,692
857,876
529,450
867,633
2,248
35,245
2,249
35,245
CP-IL
Total Nonconventional Organics3
Total Pollutants3
528,732
894,618
538,808
904,695
2,321
42,917
2,321
42,918
'Pollutants that changed percent removal from 94% to 74% include w-docosane, w-hexacosane, w-tetracosane,
w-triacontane.
2The nonconventional organic group is the only pollutant group where the pollutant removal changed.
3The total does not include bulk conventionals and bulk nonconventionals.
                                            7-28

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                           Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards

              •       WATERS air emissions modeling of the Barceloneta POTW;

              •       A pharmaceutical industry submitted literature study evaluating
                     volatilization potential in sewers; and

              •       A pharmaceutical industry submitted study evaluating volatilization
                     potential in an enclosed equalization tank.

              EPA and PhRMA conducted sampling at the Barceloneta POTW to obtain data on
the removal of several volatile organic compounds (chloroform, methylene chloride, 2-propanone,
and toluene) and certain alcohols (methanol, ethanol, and isopropanol) in the primary treatment
works of a POTW.  The Barceloneta POTW was selected for sampling because the influent
wastewater to this POTW was known to contain measurable quantities of VOCs and alcohols and
other pollutants for which pharmaceutical industries pretreatment standards were proposed in
May 1995.

              Samples were collected in the influent and effluent from treatment units. Percent
loss across the treatment units was calculated from the influent and effluent mass from the unit.
Percent losses were assumed to be due to two major fate pathways: biodegradation and
volatilization.  Knowing the overall percentage loss and the loss estimated to be attributed to
biodegradation (both aerobic and anoxic), EPA estimated the percent of loss attributed to
volatilization.  The sampling results shown in Table 7-8 indicate the range of percent loss of
alcohols in the primary treatment units due to volatilization.

              In addition, EPA performed WATERS air emissions modeling of the Barceloneta
POTW using the sampled pollutant influent concentrations in order to obtain an estimate of how
much volatilization of volatile organic pollutants occurs throughout the entire POTW system.
The results of the modeling study shown in Table 7-9 show less volatilization in the primary
treatment portion than the measured data from the Barceloneta POTW sampling episode
suggests.

              EPA also evaluated an industry submitted study evaluating sewer losses for water
soluble compounds. The results of this study indicate that volatilization of methanol and ethanol
in closed sewers is expected to be minimal with maximum emission rates of 0.03 and 0.19 percent
being projected under most sewer conditions, respectively. However, under open sewer
conditions, volatilization percentages of methanol and ethanol could be as high  as  6.5 and 20
percent, respectively.

              Based on these biodegradation rates, EPA determined that the POTWs do treat
volatile pollutants to some degree.  These percent removals were transferred to  the industrial
laundries pollutants  of concern based on an analysis of Henry's Law Constants.  Pollutants with
similar constants were assigned the same overall percent biodegradation rate.

              Table 7-10 presents the industrial laundries pollutants of concern that were found
to volatilize, their respective Henry's Law Constants, their assigned overall percent
biodegradation, and the data source for the percent biodegradation.

                                           7-29

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               Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards

                          Table 7-8

EPA and PhRMA Sampling Results for Primary Treatment
                   at Barceloneta POTW
                  Data from Method 1671
Pollutant
Methanol
Ethanol
Isopropanol
Chloroform
Toluene
Methylene
2-Propanone
1996 Primary Treatment Data
(Aerated Grit Chamber and
Primary Clarifier)
Percent Loss
19.1
25.3
11.4
44.2
29.0
27.8
10.3
1996 Primary Clarifier Only Data
Percent Loss
8.1
15.2
5.9
45.6
22.4
20.8
14.7
                             7-30

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                               Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards

                                           Table 7-9

         WATERS Modeling Results for Primary and Secondary Treatment at
                         Barceloneta Wastewater Treatment Plant
Pollutant
Methanol
Ethanol
Isopropanol
2-Propanone1
Chloroform
Methylene
Chloride
Toluene
Percent
Volatilization
in Primary %
2.1
2 2
4.2
8.0
40.9
38.9
46.1
Percent
Biodegradation
in Primary %
0.0
0.0
0.0
0.0
0.0
0.0
0.0
Percent
Volatilization
in Secondary
%
2.0
0.5
10.8
3.2
58.7
70.4
36.9
Percent
Biodegradation
in Secondary
%
90.8
97.7
74.0
94.9
40.5
28.6
62.7
Percent Overall
Volatilization %
4.0
2.7
14.3
10.7
71.2
78.2
60.4
Percent Overall
Biodegradation
%
90.5
92.9
77.0
84.8
23.9
17.8
32.4
'2-Propanone was referred to as acetone in the PhRMA data.
Note: Volatilization and biodegradation percentages may not add up to 100% since some of the compound remains in the
effluent and some goes out with the sludge.
                                             7-31

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                            Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards

                                         Table 7-10

                  Percent Biodegradation for Industrial  Laundries
                      Pollutants of Concern Found to Be  Volatile
Analyte
1,1,1 -Trichloroethane
2-Propanone
Di-n-Octyl Phthalate
Ethylbenzene
Naphthalene
Tetrachlorethene
Toluene
2-Butanone
4-Methyl-2-Pentanone
w-Decane
w-Dodecane
w-Eicosane
w-Hexadecane
w-Octadecane
w-Tetradecane
w-Xylene2
ocฃ/>-Xylene2
ฐ= -Terpineol
Henry's Law
Constant
3.67 x ID'3
2.10 x ID'5
1.37 x lO'1
8.44 x 10'3
4.83 x ID'4
1.56x ID'2
5.90 x 10'3
2.70 x ID'5
4.95 x 10'5
6.90
7.40
1.5x ID'3
1.28 x ID'1
1.44x ID'2
7.14 x ID'1
7.00 x ID'3
7.00 x ID'3
6.09 x ID'5
Overall Percent
Biodegradation
24
85
33
33
18
33
33
18
18
33
33
33
33
33
33
33
33
18
Data Source for Percent
Biodegradation
Transferred from chloroform.
Pharms pass-through analysis1
Transferred from toluene.
Transferred from toluene.
Transferred from methylene chloride.
Transferred from toluene.
Pharms pass-through analysis1
Transferred from methylene chloride.
Transferred from methylene chloride.
Transferred from toluene.
Transferred from toluene.
Transferred from toluene.
Transferred from toluene.
Transferred from toluene.
Transferred from toluene.
Transferred from toluene.
Transferred from toluene.
Transferred from methylene chloride.
     I on the Final POTW Pass-Through Analysis for the Pharmaceutical Manufacturing Point Source Category (4)
(WATERS Modeling Results for Primary and Secondary Treatment at Barceloneta Wastewater Treatment Plant).
2Henry 's Law Constant provided for total xylenes.
                                             7-32

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                           Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards

7.5.3.8        Results of the POTW Pass-Through Analysis

              Tables 7-4 and 7-5 present a comparison of the treatment technology percent
removal with the POTW percent removal for chemical precipitation and DAF, respectively. If the
treatment technology percent removal is greater than the POTW percent removal, the pollutant is
considered to pass through the POTW. A pollutant with a Henry's Law Constant greater than 1
x 10"5 atm-m3/mol was determined to pass through if its percent biodegradation was less than the
removal obtained by the treatment technology. For chemical precipitation, 31 of the 39 pollutants
analyzed passed through.  For DAF, 29 of the 39 pollutants analyzed passed through.

7.5.4          Pollutants of Concern Selected for Candidate Pretreatment Standards
              Development

              Based on the results of the pass-through analysis, EPA considered the pollutants
shown in Table 7-11 as pollutants for candidate pretreatment standards development for the
chemical precipitation and DAF technologies. To further streamline permitting  and monitoring
requirements, EPA considered using regulating "indicator" pollutants to control a broader set of
pollutants. Because many of the pollutants originate from similar sources and have similar
treatability properties, EPA concluded that indicator pollutants are appropriate for controlling
discharges from industrial laundries to POTWs.  In selecting indicator pollutants to reflect control
of a broader set of pollutants, EPA chose pollutants that were detected most frequently, detected
in the higher concentrations, and are most toxic. The following paragraphs describe the rationale
for selecting the pollutants for regulation.

              EPA considered three bulk parameters, TPH (measured as SGT-HEM), TOC, and
COD, for candidate pretreatment standards development. EPA believes that controlling one bulk
parameter in industrial laundries wastewater is sufficient to ensure the appropriate level of control
of the effluent from industrial laundries.  TPH is a measure of the mineral oil fraction of carbon-
containing compounds and mineral oils are treated less effectively by POTWs than many other
carbon-containing compounds; therefore, EPA has selected TPH for regulation.  Because TPH
measures a variety  of organic compounds, as demonstrated by the EPA Method 1664
Characterization  Study, it can also serve as an indicator pollutant for other organic pollutants
shown on Table 7-11.

              EPA is not specifically controlling the following ten straight chain alkane (n-
alkanes) pollutants  or two semivolatile compounds  because EPA's TPH study indicated that
these pollutants comprise a portion of TPH, measured as SGT-HEM, and thus would be
controlled by EPA's regulation of TPH:

              •      w-Decane;
              •      w-Docosane;
              •      w-Dodecane;
              •      w-Eicosane;
              •      w-Hexacosane;
              •      w-Hexadecane:
                                          7-33

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                       Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards
                                  Table 7-11

Pollutants Considered for Regulation for Chemical Precipitation and DAF
                      after the Pass-Through Analysis
Pollutant
Passes Through for
Chemical Precipitation
Passes Through for
DAF
Bulk Nonconventionals
Chemical Oxygen Demand (COD)
Total Organic Carbon (TOC)
Total Petroleum Hydrocarbon (TPH)1
X

—


—
Priority Organics
1,1,1 -Trichloroethane
Bis(2-ethylhexyl) Phthalate
Di-w-octyl Phthalate
Ethylbenzene
Naphthalene
Tetrachloroethene
Toluene
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Nonconventional Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pentanone
w-Decane
w-Docosane
w-Dodecane
w-Eicosane
w-Hexacosane
w-Hexadecane
w-Octadecane
w-Tetracosane
w-Tetradecane
w-Triacontane
w-Xylene
o-&/>-Xylene
/>-Cymene

X

X
X
X
X
X

X
X
X
X

X
X

X
X

X
X

X
X
X
X
X
X
X

X
X

                                     7-34

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                            Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards
Pollutant
Passes Through for
Chemical Precipitation
Passes Through for
DAF
Priority Metals and Elements
Cadmium
Chromium
Copper
Lead
Nickel
Zinc
X
X
X
X
X
X

X
X

X
X
Nonconventional Metals and Elements
Manganese
Molybdenum
Tin
Titanium
X

X
X
X

X
X
'TPH was considered for regulation, although a pass-through analysis was not performed for this pollutant (a
pass-through analysis was performed on the individual compounds that compose TPH).
                                                7-35

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                           Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards

              •      w-Octadecane;
              •      w-Tetracosane;
              •      w-Tetradecane;
              •      w-Triacontane;
              •      Bis (2-ethylhexyl) Phthalate; and
              •      Naphthalene.

              EPA also believes that controlling TPH will also control the remaining
semivolatile organic pollutants shown on Table 7-11.

              EPA believes that controlling the following volatile organic pollutants will control
the remaining volatile organic pollutants shown on Table 7-11 to some extent. However, the
most effective way to treat items containing solvents, which contain these volatile organic
compound, is to pretreat the items prior to the water washing process.

              •      Ethylbenzene;
              •      Tetrachloroethene;
              •      m-Xylene; and
              •      0-&p-Xylene.

These pollutants represent a cross-section of chlorinated and aromatic compounds that are the
majority of the volatile pollutants on Table 7-11.

              EPA believes that controlling the following metal pollutants that pass through will
control the remaining metal and elemental pollutants on Table 7-11:
              •      Copper; and
              •      Zinc.
These metals were selected because the minimum solubilities of their associated metal hydroxides
span a pH range sufficient to control the other pollutants within this pH range. Most metals will
be treated by chemical precipitation or DAF within this range. These metals were also selected
because they were detected most frequently (in nearly 100 percent of untreated wastewater
samples) and in the highest concentrations.

7.6           Long-Term Average and Variability Factors for the Five Technology Options

              EPA collected analytical sampling data for the purpose of evaluating treatment
performance of several technology options. The data were collected from the following three
sources:
              1.      The EPA wastewater sampling effort;
              2.      The self-monitoring data submitted by the facilities in response to the
                     detailed monitoring questionnaire; and
              3.      Other industry-supplied data.

                                           7-36

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                            Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards
              EPA used all of the data representative of well-designed and well-operated
treatment systems to calculate long-term averages and variability factors for facilities with
Chemical Emulsion Breaking (CEB), Dissolved Air Flotation of heavy wastewater (DAF-Heavy),
Dissolved Air Flotation of all process wastewater (DAF-All), Chemical Precipitation of heavy
wastewater  (CP-Heavy), and Chemical Precipitation of all process wastewater (CP-A11).  EPA
applied the data-editing procedures described in  Section 7.3.  The long-term averages and
variability factors can be used to calculate local limits based on best engineering judgement.

              EPA calculated the long-term average of a pollutant for each facility based on
either an arithmetic average or the expected value of the distribution of the samples, depending on
the number of total samples and the number of detected samples for the pollutant at that facility.

              EPA calculated variability factors by fitting a statistical distribution to the data.
The distribution was based on an assumption that the furthest excursion from the LTA that a well-
operated facility using the given technology could be expected to make on a daily basis was a
point below which 99% of the data for that facility falls, under the assumed distribution. The
daily variability factor (1-day VF) for each pollutant at each facility is the ratio of the estimated
99th percentile of the distribution of the daily pollutant concentration values divided by the
expected value  of the distribution of the daily values.

              EPA also calculated 4-day variability factors based on an assumption that the
furthest excursion from the LTA that a well-operated facility using the given technology could be
expected to make on a monthly basis was a point below which 95 percent of the data for that
facility falls, under the assumed distribution. The 4-day variability for each pollutant at each
facility is the ratio of the estimated 95th percentile of the distribution of monthly pollutant
concentration values divided by the expected value of the distribution of the monthly values. (The
monthly values were based on an assumed monitoring frequency of 4 times per month.)

              By accounting for these reasonable excursions above the LTA, EPA's use of
variability factors results in standards that are generally well  above the actual LTAs.  Thus if a
facility operates its treatment system to meet the relevant LTA, EPA expects the facility to be able
to meet the standards. Variability factors assure that normal fluctuations in a facility's treatment
are accounted for in the standards.

              The methodology used for calculating candidate pretreatment standards for
industrial laundries consists of a daily maximum  for all pollutants and an additional monthly
average for TPH . The daily maximum limitation was the product of the pollutant long-term
average and the pollutant 1-day variability factor. The monthly  average limitation (for pollutants
assumed to be monitored 4 times per month) was a product of the pollutant long-term average
and the pollutant 4-day variability factor.  The pollutant long-term average and the pollutant
variability factor were both defined as the median of all of the well-operated facilities using that
treatment technology.
                                            7-37

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                           Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards

              For a more complete description of the data review, data aggregation, and the
estimation of the long-term averages and variability factors under the modified delta-lognormal
model, please refer to Appendix D.

              In Tables 7'-12 to 7'-16 below, we present facility-level statistics for each of the five
treatment technologies for the following eight pollutants:  TPH (measured as SGT-HEM or non-
polar material), ethylbenzene, tetrachloroethene, m-xylene, 0-&/?-xylene, copper, lead, and zinc.
These same statistics can be found for all 72 pollutants of concern in Appendix D.

              These tables provide influent and effluent information for individual facilities as
well as a median value for long-term averages and variability factors for all facilities of that
treatment type for each of the eight pollutants. No additional data have been added to the record
since the Notice of Data Availability (NODA); therefore, this is the same data used to calculate
the pretreatment standards in the public record at the time EPA published the NODA (DCN
L14000). The only change reflected in the Tables 7-12 to 7-16 is the elimination of toluene based
on the lack of data demonstrating effective treatment by the DAF or CP technology, and the
elimination of naphthalene and bis(2-ethylhexyl)phthalate because they comprise a portion of TPH
(measured as SGT-HEM).

7.7           Mass-Based Standards

              EPA considered mass-based standards for the industrial laundries industry. A
mass-based standard  is the product of the concentration-based standards and a wastewater flow
rate divided by a production rate. Mass-based standards require information about flow and
production both to set the standards and to enforce them,  but have the advantage of encouraging
flow reduction. Two methodologies were considered for developing mass-based standards.  One
methodology bases the mass-based standards on an average number of gallons of wastewater
discharged per pound of laundry washed for the total wastewater flow and total production  from
facilities. The other methodology bases the standards on an average number of gallons of water
used per pound of laundry washed calculated from individual item data. EPA used annual data
provided in the detailed questionnaire to evaluate these approaches.

              Based on total wastewater flow and total production, EPA identified the seventy-
fifth percentile and the ninetieth percentile production-normalized flows as potentially appropriate
for calculating mass-based standards.  The seventy-fifth percentile production-normalized flow is
3.13 gallons of wastewater per pound of production and the ninetieth percentile production
normalized flow is 4.06 gallons of wastewater per pound of production. However, EPA found no
strong relationship between gallons of wastewater used per pound of laundry and items washed,
total production, or the amount of recycle/reuse that could be used as a basis for developing
mass-based standards. Therefore, EPA decided not to develop mass-based candidate
pretreatment standards for the industrial laundries industry.
                                           7-38

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                                                                               Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards

                                                                         Table 7-12
                                                        Chemical Emulsion Breaking (CEB)
Analyte
Copper
Ethylbenzene
Lead
•w-Xylene
9-cfe/>-Xylene
Tetrachloroethene
Total Petroleum Hydrocarbon (as SGT-HEM)
Zinc
Episode
SI
SI
SI
SI
SI
SI
SI
SI
Inf#
Obs
5
5
5
5
5
5
5
5
Inf#
ND
0
0
0
0
0
1
0
0
InfEst.
LTA (mg/1)
4.4
0.87
2.49
2.52
2.59
3.3
3090
8.71
Eff#
Obs
4
4
4
4
4
4
4
4
Eff#
ND
0
0
0
0
0
0
0
0
Eff
Est. LTA
(mg/1)
0.44
0.31
0.91
0.37
0.36
0.29
200
6.78
Eff 1-Day
VF
1.76
4.74
1.32
1.61
1.72
2.91
3.51
1.33
Eff 4-Day
VF
1.23
1.91
1.1
1.19
1.22
1.51
1.64
1.11
VO
        Inf # Obs - The total number of influent samples.
        Inf # ND - The total number of nondetected values in the influent.
        Inf Est. LTA - The estimated influent long-term average.
        Eff # Obs - The total number of effluent samples.
        Eff # ND - The total number of nondetected values in the effluent.
        Eff Est. LTA - The estimated effluent long-term average.
        Eff 1 -day VF - The estimated 1 -day effluent variability factor.
        Eff 4-day VF - The estimated 4-day effluent variability factor.

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                                                                       Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards

                                                                 Table 7-13
                                          Dissolved Air Flotation - Heavy (DAF-Heavy)
Analyte
Copper
Ethylbenzene
Lead
Tetrachloroethene
Total Petroleum Hydrocarbon (as SGT-HEM)
Zinc
Episode
S2
Q10
S2
Median
Q10
S2
Median
Q10
S2
S2
Inf#
Obs
5
NA
5
NA
NA
5
NA
NA
5
5
Inf#
ND
0
NA
0
NA
NA
0
NA
NA
0
0
Inf
Est. LTA
(mg/1)
8.03
NA
5.82
5.82
NA
1.83
1.83
NA
263
6.45
Eff
#Obs
4
9
4

9
4

4
4
4
Eff#
ND
0
0
1

0
0

3
0
0
Eff
Est. LTA
(mg/1)
1.45
1.18
1.56
1.37
0.11
0.36
0.24
0.14
42.1
0.9
Eff 1-Day
VF
1.9
2.59
2.86
2.73
2.69
6.18
4.43

2.31
2.68
Eff
4-Day
VF
1.27
1.43
1.48
1.46
1.46
2.23
1.84

1.37
1.45
Inf # Obs - The total number of influent samples.
Inf # ND - The total number of nondetected values in the influent.
Inf Est. LTA - The estimated influent long-term average.
Eff # Obs - The total number of effluent samples.
Eff # ND - The total number of nondetected values in the effluent.
Eff Est. LTA -  The estimated effluent long-term average.
Eff 1 -day VF - The estimated 1 -day effluent variability factor.
Eff 4-day VF -  The estimated 4-day effluent variability factor.

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                                                                      Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards

                                                                Table 7-14
                                          Chemical Precipitation - Heavy (CP-Heavy)
Analyte
Copper
Ethylbenzene
Lead
w-Xylene
9-cฃp-Xylene
Tetrachloroethene
Total Petroleum Hydrocarbon (as SGT-HEM)
Zinc
Episode
S3
S3
S3
S3
S3
S3
S3
S3
Inf
#Obs
5
5
5
5
5
4
5
5
Inf#ND
0
1
0
0
0
0
0
0
InfEst.
LTA
(mg/1)
3.42
0.96
1.55
1.36
1.24
2.06
2330
9.03
Eff#Obs
5
5
5
5
5
5
5
5
Eff#ND
0
1
4
1
0
2
4
0
EffEst
LTA
(mg/1)
0.53
0.09
0.05
0.1
0.09
0.13
7.2
0.06
Eff 1-Day
VF
4.06
4.37

2.66
3.63
4.48

6.19
Eff
4-Day
VF
1.76
1.8

1.42
1.67
1.9

2.23
Inf # Obs - The total number of influent samples.
Inf # ND - The total number of nondetected values in the influent.
Inf Est. LTA - The estimated influent long-term average.
Eff # Obs -  The total number of effluent samples.
Eff # ND - The total number of nondetected values in the effluent.
EffEst. LTA - The estimated effluent long-term average.
Eff 1 -day VF - The estimated 1 -day effluent variability factor.
Eff 4-day VF - The estimated 4-day effluent variability factor.

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                                                                         Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards




                                                                   Table 7-15
                                                 Dissolved Air Flotation - All (DAF-A11)
Analyte
Copper
ithylbenzene
^ead
w-Xylene
5-cฃp-Xylene
letrachloroethene
Episode
Qi
Q2
Q3
Q4
S4
S5
Median
Q2
S5
Median
Qi
Q2
Q3
Q4
S4
S5
Median
S5
S4
S5
Median
Qi
Q2
S4
S5
Median
Inf#0bs
NA
NA
NA
NA
5
5
NA
NA
5
NA
NA
NA
NA
NA
5
5
NA
5
5
5
NA
NA
NA
5
5
NA
Inf#ND
NA
NA
NA
NA
0
0
NA
NA
0
NA
NA
NA
NA
NA
0
0
NA
0
0
0
NA
NA
NA
0
1
NA
InfEst.
LTA
(mg/1)
NA
NA
NA
NA
3.4
2.14
2.77
NA
7.05
7.05
NA
NA
NA
NA
1.46
0.76
1.11
16.1
0.18
11.8
5.99
NA
NA
0.14
9.58
4.86
Eff#0bs
15
13
5
8
5
5

13
5

15
14
4
8
5
5

5
5
5

6
13
5
5

Eff#ND
0
1
0
0
0
0

10
0

1
3
2
8
2
2

0
0
0

2
4
0
0

EffEst
LTA
(mg/1)
0.67
0.59
0.57
0.39
0.36
0.17
0.48
0
0.37
0.19
0.22
0.23
0.32
0.1
0.14
0.06
0.18
0.6
0.12
0.42
0.27
25.1
0.02
0.07
0.43
0.25
Eff 1-Day
VF
6.4
4.52
6.95
3.15
3.07
1.59
3.83
3.54
4.16
3.85
5.05
2.99
1.55

3.72
1.39
2.99
3.55
3.15
4.07
3.61
15.4
4.97
3.08
5.87
5.42
Eff 4-Day
VF
2.28
1.87
2.4
1.56
1.54
1.18
1.72
1.9
1.78
1.84
1.99
1.57
1.47

1.75
1.13
1.57
1.65
1.56
1.76
1.66
3.87
2
1.54
2.16
2.08
to

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                                                                         Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards
                                                          Table 7-15 (Continued)
Analyte
Total Petroleum Hydrocarbon (as SGT-HEM)
^inc
Episode
S4
S5
Median
Qi
Q2
Q3
Q4
S4
S5
Median
Inf#Obs
5
5
NA
NA
NA
NA
NA
5
5
NA
Inf#ND
0
0
NA
NA
NA
NA
NA
0
0
NA
InfEst.
LTA
(mg/1)
318
683
500
NA
NA
NA
NA
4.69
3.07
3.88
Eff#Obs
5
5

15
12
5
8
5
5

Eff#ND
1
0

0
0
0
0
0
0

EffEst
LTA
(mg/1)
11.4
16
13.7
0.9
1.22
0.91
0.78
0.51
0.27
0.84
Eff 1-Day
VF
3.64
2.62
3.13
7.34
5.11
6.27
2.96
3.17
1.58
4.14
Eff 4-Day
VF
1.68
1.44
1.56
2.49
1.99
2.25
1.52
1.57
1.18
1.78
Inf # Obs - The total number of influent samples.
Inf # ND - The total number of nondetected values in the influent.
Inf Est. LTA - The estimated influent long-term average.
Eff # Obs - The total number of effluent samples.
Eff # ND - The total number of nondetected values in the effluent.
EffEst. LTA - The estimated effluent long-term average.
Eff 1 -day VF - The  estimated 1 -day effluent variability factor.
Eff 4-day VF - The  estimated 4-day effluent variability factor.

-------
                     Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards




                Table 7-16
Chemical Precipitation - All (CP-A11)
Analyte
Copper
ithylbenzene
^ead
w-Xylene
j-cฃp-Xylene
letrachloroethene
Episode
Q5
Q6
S6
S7
Median
Q7
Q9
S6
S7
Median
Q5
Q6
Q7
Q8
S6
S7
Median
S6
S7
Median
S6
S7
Median
Q9
S6
S7
Median
Inf
#0bs
NA
NA
5
5
NA
NA
NA
5
5
NA
NA
NA
NA
NA
5
5
NA
5
5
NA
5
5
NA
NA
5
5
NA
Inf
#ND
NA
NA
0
0
NA
NA
NA
1
0
NA
NA
NA
NA
NA
0
0
NA
1
0
NA
2
0
NA
NA
1
0
NA
InfEst.
LTA
(mg/1)
NA
NA
3.13
4.85
3.99
NA
NA
0.51
0.31
0.41
NA
NA
NA
NA
1.5
2.14
1.82
4.39
0.75
2.57
2.88
0.9
1.89
NA
1.68
5.13
3.4
Eff
#0bs
16
7
4
5

o
J
4
4
5

16
7
11
4
4
5

4
5

4
5

4
4
5

Eff
#ND
0
0
0
0

1
0
0
0

11
0
5
1
2
0

1
0

1
0

0
0
0

EffEst
LTA
(mg/1)
0.14
0.4
0.06
0.44
0.27
0.04
0.34
0.27
0.04
0.15
0.1
0.28
0.03
0.2
0.06
0.1
0.1
0.35
0.14
0.24
0.23
0.16
0.2
0.08
0.44
0.42
0.42
Eff
1-Day VF
1.71
1.56
3.57
2.37
2.04

9.68
2.47
2.72
2.72
1.29
1.52
3.89
2.66
5.29
5.22
3.27
3.84
1.89
2.87
4.12
1.92
3.02
7.56
5.65
2.1
5.65
Eff
4-Day VF
1.22
1.17
1.65
1.38
1.3

3.05
1.41
1.46
1.46
1.07
1.16
1.77
1.55
2
2.02
1.66
1.83
1.26
1.54
1.87
1.27
1.57
2.55
2.11
1.32
2.11

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                                                                         Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards
                                                          Table 7-16 (Continued)
Analyte
Total Petroleum Hydrocarbon (as SGT-HEM)
Line
Episode
S6
S7
Median
Q5
Q6
Q8
S6
S7
Median
Inf
#Obs
5
5
NA
NA
NA
NA
5
5
NA
Inf
#ND
0
0
NA
NA
NA
NA
0
0
NA
InfEst.
LTA
(mg/1)
164
991
578
NA
NA
NA
3.71
8.45
6.08
Eff
#Obs
4
5

16
7
4
4
5

Eff
#ND
0
0

0
0
0
0
0

EffEst
LTA
(mg/1)
10.8
9.51
10.2
0.1
1.72
0.3
0.05
0.52
0.3
Eff
1-Day VF
2.54
1.76
2.15
3.96
2.14
6.94
1.79
3.08
3.08
Eff
4-Day VF
1.42
1.23
1.32
1.74
1.33
2.4
1.24
1.54
1.54
Inf # Obs - The total number of influent samples.
Inf # ND - The total number of nondetected values in the influent.
Inf Est. LTA - The estimated influent long-term average.
Eff # Obs - The total number of effluent samples.
Eff # ND - The total number of nondetected values in the effluent.
EffEst. LTA - The estimated effluent long-term average.
Eff 1 -day VF - The  estimated 1 -day effluent variability factor.
Eff 4-day VF - The  estimated 4-day effluent variability factor.

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                           Chapter 7 - Treatment Performance Data Used for the Development of Candidate Pretreatment Standards

7.8           References

1.             U.S. Environmental Protection Agency. Statistical Support Document for
              Proposed Pretreatment Standards for Existing and New Sources for the Industrial
              Laundries Point Source Category. EPA 821-R-97-006, Washington, DC,
              November 1997.

2.             U.S. Environmental Protection Agency. Fate of Priority Pollutants in Publicly
              Owned Treatment Works (50 POTW Study! EPA-440/1-82/303. Washington,
              DC, September  1982.

3.             U.S. Environmental Protection Agency. The Risk Reduction Engineering
              Laboratory (RREL) Treatability Database.  Version 5.O., Cincinnati, OH.

4.             U.S. Environmental Protection Agency. Final POTW Pass-Through Analysis for
              the Pharmaceutical Manufacturing Point Source Category.
                                          7-46

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                                                        Chapter 8 - Development of Technology Control Options

                                       CHAPTER 8
              DEVELOPMENT OF TECHNOLOGY CONTROL OPTIONS

8.1           Introduction

              This chapter presents the regulatory options considered by EPA as the basis for the
candidate Pretreatment Standards for Existing Sources (PSES) and Pretreatment Standards for
New Sources (PSNS) for the industrial laundries industry.  This chapter presents the following
information:

              •      Section 8.2 presents the initial technology control options considered as the
                     bases for the candidate PSES and PSNS;

              •      Section 8.3 discusses the inclusion of pollution prevention in the
                     technology control options;

              •      Section 8.4 discusses the exclusion of wastewater recycling activities from
                     the technology control options;

              •      Section 8.5 presents the subcategorization analysis of the industrial
                     laundries industry;

              •      Section 8.6 presents initial technology control options considered but
                     rejected before the final action;

              •      Section 8.7 presents additional technology control options considered;

              •      Section 8.8 presents technology control options eliminated from further
                     consideration;

              •      Section 8.9 presents regulatory control options considered for the final
                     action; and

              •      Section 8.10 presents the references used.

8.2           Initial Technology Control Options Considered

              EPA considered the same set of technology control options as potential bases for
both PSES and PSNS.  As described in Chapter 7, EPA had data available for three major
postlaundering wastewater treatment technologies used at industrial laundries. As described in
Chapter 6, EPA had data available for one prelaundering treatment technology used by industrial
laundries, along with general information on pollution prevention activities at industrial laundries.
The data for the postlaundering treatment technologies represented five different treatment
options. These five different postlaundering treatment options and the one prelaundering
treatment technology, in addition to the general application of the pollution prevention activities,
formed the basis for EPA's six initial technology control options considered for the proposed rule.

                                            8-1

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                                                        Chapter 8 - Development of Technology Control Options

The following sections further discuss each of these initial technology control options.

              Table 8-1 summarizes the six initial technology control options and the number of
detailed questionnaire facilities that have equivalent or better treatment currently in place.

8.2.1          Postlaundering Wastewater Treatment Technology Control Options

              The five initial postlaundering wastewater treatment technology control options
considered by EPA are:

              •       CEB-Heavy — chemical emulsion breaking treatment of heavy wastewater;

              •       DAF-Heavy — dissolved air flotation (DAF) treatment of heavy
                     wastewater;

              •       CP-Heavy - chemical precipitation treatment of heavy wastewater;

              •       DAF-A11 - DAF treatment of all facility process wastewater; and

              •       CP-A11 - chemical precipitation treatment of all facility process
                     wastewater.

              The treatment train for each of the postlaundering wastewater treatment
technology control options includes the major wastewater treatment technology (i.e., chemical
emulsion breaking, DAF, or chemical precipitation), as well as other ancillary equipment. Based
on responses to the 1994 Industrial Laundries Industry Questionnaire (detailed questionnaire) and
EPA site visits to industrial laundries, EPA assumed that every facility has an initial catch basin in
which gravity settling occurs. Each option includes screening and equalization followed by the
major wastewater treatment technology.  Although they  do not directly impact final effluent
concentrations, screening and equalization are included in the technology control options because
they are necessary to remove solids and control fluctuations  in the process wastewater flow,
respectively.  They were also reported in the detailed questionnaire by most facilities that
currently treat their wastewater. Based on information obtained through site visits, EPA
determined that these technologies ensure proper operation of subsequent treatment technologies.
The options in which DAF and chemical precipitation are used also include dewatering of the
sludge generated.

              Based on detailed questionnaire and sampling data from industrial laundries that
use chemical emulsion breaking and chemical precipitation, as well as information on facilities'
local discharge limits, EPA expects that the pH of the treated wastewater streams from these
                                           8-2

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                                                               Chapter 8 - Development of Technology Control Options
                                            Table 8-1
            Technology Control Options Initially Considered for the
                          Industrial Laundries Proposed Rule
Technology
Control
Option
CEB-Heavy
DAF-Heavy
CP-Heavy
DAF-A11
CP-A11
OC-Only
Description
Chemical emulsion breaking of heavy
wastewater
Dissolved air flotation of heavy wastewater
Chemical precipitation of heavy wastewater
Dissolved air flotation of all facility process
wastewater
Chemical precipitation of all facility process
wastewater
Organics control (steam tumbling) of heavy
industrial textile items
Basis of
Standards1
CEB-Heavy
DAF-Heavy
CP-Heavy
DAF-A11
CP-A11
OC-Only
Number of Facilities
with Equivalent
Treatment
In Place2
5
2
63
33
174
O5
'Pollutant concentration data representing each treatment option is presented in Chapter 7 of this document.
2Data obtained from 190 in-scope facilities that responded to the detailed questionnaire. In-scope facilities are those
that meet the definition of an industrial laundry as presented in Chapter 4.
3One of these facilities operates a microfiltration unit to treat a portion of its process wastewater. Since
microfiltration, when operated properly, can achieve lower final effluent pollutant concentrations than chemical
precipitation (1), this facility is considered to have better treatment in place than the CP-Heavy option.
4One of these facilities operates an ultrafiltration unit to treat all of its process wastewater.  Since ultrafiltration, when
operated properly, can achieve lower final effluent concentrations than chemical precipitation (1), this facility is
considered to have better treatment in place than the CP-A11 option.
5Data from one facility were available for OC-Only, but this facility steam tumbles printer towels/rags only, not all
heavy industrial textile items.

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                                                        Chapter 8 - Development of Technology Control Options

technologies will be outside of facilities' locally permitted discharge range.  Therefore, the CEB
and chemical precipitation options also include pH adjustment of the final effluent prior to
discharge.  Technology control options in which a portion of the facility's wastewater is treated
with CEB or chemical precipitation also include combining the treated and untreated streams prior
to final pH adjustment and discharge.  The effluent from DAF is expected to be within facilities'
locally permitted discharge range for pH, because most facilities operating DAF adjust the pH to
within a range acceptable for discharge, based on detailed questionnaire and sampling data.
Therefore, the DAF treatment options  do not include final pH adjustment. Technology control
options in which a portion of the facility's wastewater is treated with DAF also include combining
the treated  and untreated streams prior to discharge.

              The five initial wastewater treatment technology control options treat either the
wastewater generated from washing "heavy" industrial laundry items only (i.e., those items with a
relatively high pollutant load) or the total facility process wastewater. EPA modeled the raw
wastewater treated in each option by considering the total raw wastewater flow reported by each
facility in the detailed questionnaire to consist of three streams, as follows:

              •      Heavy industrial;
              •      Light industrial; and
              •      Nonindustrial.

              The heavy industrial stream includes wastewater generated from water washing the
following items:

              •       Shop towels;
              •      Printer towels/rags;
              •      Mops;
              •      Fender covers; and
              •      Filters.

              The light industrial stream includes wastewater generated from water washing the
following items:
                     Industrial garments;
                     Floor mats;
                     Laundry bags; and
                     Buffing pads;
and wastewater generated from dry cleaning followed by water washing or dual-phase washing of
the following items:
              •      Industrial garments;
              •      Shop towels;
              •      Printer towels/rags;
              •      Mats;
              •      Mops;
                                            8-4

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                                                       Chapter 8 - Development of Technology Control Options

              •      Fender covers;
              •      Laundry bags;
              •      Filters; and
              •      Buffing pads.

              The nonindustrial  stream includes wastewater generated from water washing or
denim prewashing the following items (dry cleaning followed by water washing and dual-phase
washing were not reported for nonindustrial textile items):
                    Linen supply garments;
                    Linen flatwork/full dry;
                    Health-care items;
                    Continuous roll towels;
                    Clean room garments;
                    Family laundry;
                    New items;
              •      Executive wear; and
              •      Miscellaneous not our goods (items not owned by the laundry).

The wastewater generated from the washing of heavy industrial textile items ("heavy"
wastewater) contains higher concentrations of most pollutants than the wastewater generated
from the washing of light industrial and nonindustrial textile items ("light" wastewater). Figures
8-1, 8-2, and 8-3 illustrate the CEB-Heavy, DAF-Heavy, and CP-Heavy technology options,
respectively. Only heavy wastewater is treated in these options. Figures 8-4 and 8-5 illustrate the
DAF-A11 and CP-A11 technology options, respectively.  Total facility process wastewater is treated
in these options.

              EPA obtained specific performance data on the treatment of heavy industrial
laundry wastewater through wastewater sampling at industrial laundries, as discussed in Chapter 7
of this document. Estimated performance of the heavy  options is based on pollutant
concentrations obtained from the treated heavy wastewater, prior to combining with the light
wastewater stream, as shown in Figures 8-1, 8-2, and 8-3. Figures 8-1 through 8-3 also show
options  discussed in Section 8.7 of this document. Estimated performance of the options treating
total facility wastewater is based on pollutant concentrations obtained at the point of discharge
from treatment of the entire wastewater stream, as shown in Figures 8-4 and 8-5.

8.2.2         Prelaundering Organics Control (OC-Only) Technology Control Option

              The Prelaundering Organics Control (OC-Only) option, shown in Figure 8-6,
consists of steam tumbling treatment of facilities' heavy industrial laundry items to remove
organics prior to water washing of the items. EPA obtained data from one facility that could be
used to estimate the performance of steam tumbling of printer towels/rags; these data are
                                           3-5

-------
                                                                                            Chapter 8 - Development of Technology Control Options
                                                            -> Lint to Disposal
                           Light
     Process
     Wastewater
oo
                                        Fine Screening
                          Heavy
                 Waste Oil to Hazardous
                        Waste Disposal
                                                       Acid or
                                                       Other Demulsifier
                                                                                            Acid/Base
Equalization
Chemical
Emulsion
Breaking
                                                                                          pH Adjustment
                                              , Wastewater
                                                toPOTW
          KEY
                   Wastewater Flow

                   Sludge Flow

                   Waste Oil Flow

                   Sample point location for pollutant concentration
                   data representing the CEB-Heavy option.
               Figure 8-1. CEB-Heavy Option: Chemical Emulsion Breaking of Heavy Industrial Laundry Wastewater

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                                                                                               Chapter 8 - Development of Technology Control Options
                                                                           Lint to Disposal
                            Light
      Process
      Wastewater
oo
         KEY
                                         Fine Screening
                                              Acid
                           Heavy
                          Coagulants/Flocculents
Equalization
Dissolved Air
  Flotation
                                            Wastewater
                                           ' toPOTW
                   . Wastewater Flow

                   • Sludge Flow

                    Sample point location for pollutant concentration data
                    representing the DAF-Heavy and Towel only options.
                    Sample point location for the pollutant concentration data
                    representing the DAF-IL and DAF-TWL options.
                                                                                          Sludge Conditioner
                                                     Sludge
                                                   Dewatering
                                           Dewatered Cake to Disposal
                               Figure 8-2. DAF-Heavy, DAF-IL, DAF-TWL, and Towel Only Options:
                                 Dissolved Air Flotation of a Portion of a Facility's Process Wastewater

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                                                                                              Chapter 8 - Development of Technology Control Options
                            Light
      Process
      Wastewater
OO
OO
        KEY
                           Heavy
                                         Fine Screening
Equalization
                                                                  int to Disposal
                    Coagulants/Flocculents
                  . Wastewater Flow

                  - Sludge Flow
                   Sample point location for pollutant concentration
                   data representing the CP-Heavy option.
                   Sample point location for the pollutant concentration
                   data representing the CP-IL and CP-TWL options.
 Chemical
Precipitation
                                                                                               Acid/Base
                                                                                             pH Adjustment
                                                                                              Sludge
                                                                                            Dewatering
                                         Dewatered Cake to Disposal
                                                                          Wastewater
                                                                         * to POTW
      Figure 8-3.  CP-Heavy, CP-IL, and CP-TWL Options:  Chemical Precipitation of a Portion of a Facility's Process Wastewater

-------
                                                                                                 Chapter 8 - Development of Technology Control Options
      Process
      Wastewater
OO
        KEY
                     ->
                        Fine Screening
                   Wastewater Flow

                   Sludge Flow

                   Standards for DAF-AII apply here
                                                    > Lint to Disposal
                                                           Acid

Equalization
                           Coagulants/Flocculents

Dissolved Air
  Flotation
Wastewater
 toPOTW
                                                                                                     Sludge Conditioner
                                                                                                 Dewatered Cake to Disposal
                        Figure 8-4. DAF-A11 Option: Dissolved Air Flotation of Total Facility Process Wastewater

-------
                                                                                                  Chapter 8 - Development of Technology Control Options
      Process
      Wastewater
oo

o
         KEY
                                             -> Lint to Disposal
                                                                    Coagulants/Flocculents
Acid/Base

                  Wastewater Flow

                  Sludge Flow

                  Standards for CP-AII apply here
                                                                                Dewatered Cake to Disposal
                       Wastewater
                        to POTW
                         Figure 8-5.  CP-A11 Option: Chemical Precipitation of Total Facility Process Wastewater

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                                                                                               Chapter 8 - Development of Technology Control Options
OO
                                                                        r	^. Organic Waste to
                                                                        •       Hazardous Disposal
                                                Condenser
                        Shop and Printer
                        Towels/Rags
                                                                                                                Wastewater
                                                                                                                 toPOTW
                                       Steam
Water
                KEY
                          Wastewater Flow

                          Towel Transfer

                          Waste Organ ics Flow

                          Standards for OC-Only apply here
                                    Figure 8-6. OC-Only Option:  Prelaundering Organics Control

-------
                                                        Chapter 8 - Development of Technology Control Options

presented in Chapter 6.  The standards for the OC-Only option would be based on pollutant
concentrations obtained from the raw wastewater discharged from a load of steam-tumbled
printer towels/rags, as shown in Figure 8-6.

8.3           Inclusion of Pollution Prevention in the Technology Control Options

              Most of the preprocess pollution prevention activities reported in the detailed
questionnaire involve good  operating practices that any industrial laundry can technically
implement.  The two most commonly reported activities, refusal of items containing free liquids
and refusal of certain items, require that laundries work with their customers to reduce pollutant
loads.  This presents a challenge to laundries to maintain their customer base while still controlling
the amount of contaminants they take in.  Another commonly reported preprocess activity viewed
as a good operating practice is the reduction of free liquids in laundry items by centrifugation
before the items are water-washed. After centrifugation, the liquid removed from the items is
reused by the customer or disposed of as hazardous waste.  Either the customer or the industrial
laundry technically could perform this preprocess activity.

              All of the in-process pollution prevention activities reported by industrial laundries
reduce pollution at the facilities that implement them and reduce operating costs by optimizing
laundry operations. The installation of alternative washers and automated liquid injection systems
for washers, the use of alternative washing chemicals and water softening, and the implementation
of water reuse/reduction all can reduce the amount of water and/or chemicals that a laundry uses.
A significant number of industrial laundries have improved employee training and housekeeping
standards, which can also decrease water and chemical use.  In addition, changes  in laundering
chemicals were reported to  improve treatability of the wastewater by forming emulsions that are
more easily broken.

              Most of the industrial laundries from which EPA has gathered data used for the
development of DAF and chemical precipitation pretreatment standards practice refusal of items
containing free liquids to some degree. Therefore, EPA has included this preprocess pollution
prevention practice as a component of the technology options involving DAF or chemical
precipitation treatment of process wastewater. EPA evaluated the use of steam stripping as a
stand-alone technology for the OC-only technology control option, discussed in Section 8.2.2 of
this document.  Use of the other preprocess and in-process pollution prevention practices,
described in Chapter 6 of this document, as stand-alone technology control options were
considered, but reasonably rejected. These options were rejected because the practices varied too
greatly among individual facilities to construct an acceptable regulatory framework and because
the available data were insufficient to identify specific pollutant loading reductions and costs
associated with the use of these practices. In addition, EPA did not have sufficient facility-
specific information to evaluate how many facilities could afford to implement these preprocess or
in-process practices.
                                           8-12

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                                                        Chapter 8 - Development of Technology Control Options

8.4           Exclusion of Wastewater Recycling Activities from the Technology Control
              Options

              Some industrial laundries reported that they have incorporated wastewater
recycling activities into their processes, as described in Section 6.4 of this document.  EPA has
found that the use of wastewater recycling largely depends upon customer demands on product
quality, the facility's product mix, and the level of wastewater treatment at the facility.  In
addition, EPA has limited data that show wastewater recycling activities in the industrial laundries
industry do not necessarily result in a facility using less process water than a facility that does not
recycle, due to facility-specific factors (2). EPA concluded that it does not have sufficient data to
completely analyze the effects of wastewater recycling on costs or pollutant loadings.  Therefore,
EPA did not incorporate wastewater recycling activities into the technology options.

8.5           Subcategorization Analysis

              EPA typically  assesses several factors to determine whether segmenting or
subcategorizing an industrial category and considering different technology control options for
those segments or subcategories would be appropriate.  These factors were assessed for the
Industrial Laundries Point Source Category and are listed below:

              •       Disproportionate economic impacts;

              •       Laundry processes and water use practices;

              •       Plant age;

              •       Plant location;

              •       Plant size;

              •       Raw materials;

              •       Non-water quality environmental impacts (energy usage, air emissions, and
                     solid waste generation); and

              •       Type of item laundered and wastewater characteristics.

Based on the results of this examination, EPA determined that the Industrial Laundries Point
Source Category warrants no  formal Subcategorization other than regulatory exclusions for
certain smaller production facilities. Because costs of options may be dependent on all of the
above factors, consideration of these factors is incorporated into the costing analysis for the final
action. EPA did find that disproportionate economic impacts on small facilities warrant exclusion
of some of those facilities from the technology control options. Also, as discussed in Chapter 4  of
this document, EPA used laundry processes and water use practices and type of
                                           8-13

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                                                       Chapter 8 - Development of Technology Control Options

item laundered as the basis for defining the scope of the industry. The remainder of this section
discusses EPA's analysis of each of the factors listed above.

8.5.1         Disproportionate Economic Impacts

              EPA looked at production as a means of defining applicability of pretreatment
standards for this industry; EPA used production as a good indicator of size for industrial
laundries because it is easily measured and closely tracked by the industry.  In examining
production levels, EPA determined that larger industrial laundries have an advantage over small
facilities: they enjoy economy of scale in treating their wastewater and generally have more
economic resources than small facilities. Because of these differences in economy of scale and
economic resources, a disproportionate amount of negative economic impacts would occur at
small facilities from implementation of national pretreatment standards.  EPA evaluated three
exclusions based on production level for small facilities in conjunction with the final technology
control options and candidate pretreatment standards.  The Economic Assessment document (3)
and the Cost-Effectiveness Analysis  (4) present EPA's rationale for these exclusions. The
exclusions evaluated are:

              •       1 Million/255 K - Facilities processing less than 1,000,000 pounds of
                    incoming laundry and less than  255,000 pounds of industrial towels
                    annually would be excluded.

              •      3 Million/120 K - Facilities processing less than 1,000,000 pounds of
                    incoming laundry and less than  255,000 pounds of industrial towels
                    annually and facilities processing less than 3,000,000 pounds of incoming
                    laundry and less than 120,000 pounds of industrial towels annually would
                    be excluded.

              •      5 Million/255 K - Facilities processing less than 5,000,000 pounds of
                    incoming laundry and less than  255,000 pounds of industrial towels
                    annually would be excluded.

8.5.2         Laundry Processes and Water Use Practices

              EPA looked at laundering processes and water use practices in terms of a possible
basis for subcategorization. As discussed in Section 4.8 of this document, EPA examined laundry
operations and wastewater characteristics in defining the scope of the industry.  EPA examined
operations that generate wastewater and those that do not, and excluded those operations that do
not generate wastewater. EPA then  evaluated the wastewater characteristics for all water-
washing operations, which includes dry cleaning followed by water washing.  Based on the
evaluation, EPA determined that wastewater characteristics are similar for all laundry water-
washing operations, and therefore do not provide an adequate basis for subcategorization.
Wastewater characteristics are primarily a function of the types of items laundered, and not the
facility's laundering processes.
                                           8-14

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                                                        Chapter 8 - Development of Technology Control Options

8.5.3         Plant Age

              The age of an industrial laundry is an indefinite parameter primarily because of the
upgrading and modernization that most facilities do to remain competitive, as discussed in
Chapter 4 of this document.  EPA therefore did not consider plant age as a basis for
subcategorization.

8.5.4         Plant Location

              Industrial laundries are located throughout the United States and are not generally
limited to any one geographical location, as discussed in Chapter 4 of this document.  EPA did
not subcategorize based on geographical location because location would not affect the ability of
industrial laundries to comply with national pretreatment standards.

8.5.5         Plant Size

              In analyzing plant size as a basis for subcategorization and also as part of the
analysis to minimize any disproportionate economic impacts, EPA examined the following factors
to determine if any of them would be appropriate as a basis of subcategorization:  number of
employees, wastewater discharge flow rate, and production. The  analysis of each of these factors
is discussed below.

8.5.5.1        Number of Employees

              Raw materials, laundering processes, and wastewater  characteristics are
independent of the number of employees at a facility.  It is difficult to correlate the number of
employees to wastewater generation due to variations in laundry staffing. Fluctuations can occur
for many reasons, including shift differences, clerical and administrative support staff, maintenance
workers, efficiency of site operations, and market fluctuations.  For these reasons, EPA did not
subcategorize by number of employees.

8.5.5.2        Wastewater Discharge Flow Rate

              EPA did not subcategorize by wastewater discharge flow rate because the
wastewater characteristics for a facility are independent of the overall wastewater discharge flow
rate from a facility.  Wastewater characteristics are primarily a function of the types of items
laundered at a facility, and not the facility's overall wastewater discharge flow rate. For example,
a facility laundering 100 pounds of laundry and discharging 300 gallons per year of wastewater
would have wastewater characteristics similar to a facility processing 100,000 pounds of laundry
and discharging 300,000 gallons of wastewater per year, provided the facilities are laundering
similar items.

              EPA also considered wastewater flow rate per pound  of laundry processed as a
potential basis for subcategorization of the  industry. As shown in Figure 5-1 in Chapter 5 of this
document, most facilities in the industry have production-normalized water use of between 1.5
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                                                        Chapter 8 - Development of Technology Control Options

and 3.5 gallons per pound of laundry processed. Because of the narrow range of production-
normalized water use amounts, EPA did not subcategorize by this parameter.

8.5.5.3        Production

              As with wastewater discharge flow rate, wastewater characteristics for a facility
are independent of the overall production volume at a facility. Wastewater characteristics are
primarily a function of the types of items laundered at a facility, and not the facility's overall
production, as shown in the example discussed in the previous paragraph of this section.

              However,  as discussed in Section 8.5.1 of this document, EPA looked at
production in determining the applicability of the candidate pretreatment standards to the industry.
EPA evaluated several exclusions with regard to production; these exclusions were discussed in
Section 8.5.1 of this document.

8.5.6          Raw Materials

              The raw materials used in the industrial laundries industry primarily consist of
chemicals used in the laundering process.  Chemicals that are frequently used in the industry
include alkaline solutions, detergent, bleach, antichlor, sour, softener, and starch; other chemicals
used include enzymes, builders, oil treatment chemicals, water conditioners, dyes, stain treatment
chemicals, and bactericides. The chemicals most commonly used across the industry and on a
variety of laundry items are detergent, bleach, and sour.  Chemical usage varies from wash cycle
to wash cycle depending on product mix and equipment used for laundering.  Waste load and
wastewater treatability are not directly correlated to chemicals used in laundering.  Because of the
wide variety of chemicals and wash formulas used in the industry and the complexities involved in
laundering chemistry, EPA determined it was not appropriate to subcategorize based on chemicals
used in the laundering process.

8.5.7          Non-Water  Quality Environmental Impacts

              Non-water quality environmental impacts for the industrial laundries industry
include wastewater treatment residual and sludge disposal, air emissions, and energy
requirements.  As discussed in Chapter 10 of this document, EPA estimates that minimal non-
water quality impacts would result from implementation of the final technology control options
considered.  Therefore, EPA determined that these non-water quality environmental impacts are
not an adequate basis for  subcategorizing the industrial laundries industry.

8.5.8          Type of Item Laundered and Wastewater Characteristics

              As discussed in Section 4.8  of this document, the types of items laundered by
facilities in the scope of this industry as  defined by EPA include, but are not limited to, the
following industrial textile items: shop towels, printer towels/rags, furniture towels, rags,
uniforms, mops, mats, rugs, tool covers, fender covers, dust-control items, gloves, buffing pads,
and absorbents. Laundering of nonindustrial textile items is also covered when industrial textile
items are laundered at the same facility.

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                                                       Chapter 8 - Development of Technology Control Options

              EPA examined type of item as a possible basis of subcategorization, as wastewater
characteristics differ depending on items laundered. As presented in Chapter 5 of this document,
printer towels/rags, shop towels, and mops generally have concentrations of pollutants that are
greater than the concentrations for floor mats and industrial garments.  EPA determined that
laundering of printer towels/rags and  shop towels generates 34 percent of the toxic-weighted
wastewater pollutant load from the total industry production and 60 percent from total industrial
laundry production, although these items represent only 5 percent of the total industry production
and 10 percent of the total industrial laundry production (see Section 17.8 of the Industrial
Laundries Administrative Record).

              EPA considered requiring different wastewater standards for wastewater generated
from laundering printer towels/rags, shop  towels, and mops than for wastewater generated from
laundering other items. However, laundries typically clean a variety of items and typically
combine wastewater from all items laundered.  Thus, subcategorizing the industry by type of item
laundered with different standards for different types of items  would require segregation and
separate treatment of waste streams.  Most industrial laundries with wastewater treatment
currently operate only one treatment system, and monitor their effluent at only one discharge
point. Because of the  cost and recordkeeping burden that would be involved if the industry was
subcategorized by item type, EPA decided that item type is not a reasonable basis for
subcategorizing the industry.

              However, EPA did consider item type as a basis for reduced applicability of
pretreatment standards. As discussed in this chapter, EPA considered technology control options
that would cover only  facilities processing industrial textile items, heavy items, or industrial
towels as part of the overall analysis of technology control options. EPA considered these
options in order to evaluate the costs and economic impacts of controlling only the most
concentrated sources of wastewater pollutants.

8.6           Initial  Technology Control Options Not Further Considered

              EPA eliminated the Heavy options from further consideration because EPA
determined that, in these options, the  untreated light wastewater stream at some facilities  has
higher concentrations  of pollutants than the treated heavy wastewater stream. In addition, for
these technology options, standards would be applicable to only a portion of a facility's
wastewater flow. This presents a significant difficulty for the  permitting authorities and regulated
facilities in that these options would require an in-plant monitoring point. This also would be
coupled with a need for detailed record keeping by the facility and information collection by the
permitter regarding production and flow rates associated with  specific laundry items to assure
compliance with standards developed for the Heavy options. EPA ultimately concluded that in-
plant standards and this level of detailed data collection present an unacceptable compliance
burden and cost to the industrial laundries industry that is not  warranted, and would be more
difficult to enforce by  POTWs than the options covering all of the facility's wastewater.
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                                                       Chapter 8 - Development of Technology Control Options

8.7           Additional Technology Control Options Considered

              EPA considered additional alternative technology control options, which were
variations on the initial DAF and chemical precipitation technology options presented above, to
find the most effective option for the industry.  These additional options involve treating different
portions of the total facility process wastewater, then combining the treated and untreated
wastewater prior to monitoring and final discharge. These additional options are described in the
sections below.

              Table 8-2 summarizes the 12 additional technology control options considered for
PSES and PSNS.

8.7.1          Industrial Laundry Wastewater (IL) Technology Control Options

              The IL wastewater technology control options, DAF-IL and CP-IL, are similar to
the DAF-Heavy and CP-Heavy technology control options shown in Figures 8-2 and 8-3,
respectively, in that they treat a portion of the facility's wastewater stream. However, in the IL
options, wastewater from both heavy and light industrial textile items is treated. The treated
stream is combined  with the untreated nonindustrial wastewater stream prior to monitoring and
discharge. Thus, in Figures 8-2 and 8-3, the heavy and light industrial wastewater streams are
represented by the "heavy" stream in the diagram and the nonindustrial wastewater stream is
represented by the "light" stream in the diagram. The standards applied to the combined streams
would be based on treatment performance data for the DAF-A11 technology option (in the DAF-
IL option) and the CP-A11 technology option (in the CP-IL option).

              EPA has determined that the wastewater generated from laundering of
nonindustrial textile items has pollutant concentrations generally lower than the standards
developed from both DAF and chemical precipitation treatment of the total facility process
wastewater stream.  Therefore,  pollutant concentrations in the combined streams prior to final
discharge for the IL options would be lower than the standards based on treatment of the total
process wastewater  stream (DAF-A11 and CP-A11).  EPA concluded that nonindustrial wastewater
does not need treatment to meet those standards. EPA developed the IL wastewater technology
control options to treat the majority of pollutants in a facility's process wastewater (the pollutants
generated from industrial laundry) with a lower-cost treatment system than the All options.

8.7.2          Towel (TWL) Technology Control Options

              The TWL wastewater technology control options are nearly identical to the DAF-
Heavy and CP-Heavy technology options shown in Figures 8-2 and 8-3, respectively, including
treatment of wastewater generated  from washing heavy industrial laundry items, as defined in
Section 8.2.1 of this document. Light industrial and nonindustrial wastewater is discharged
without treatment.  Thus, in Figures 8-2 and 8-3, the heavy industrial wastewater stream is
represented by the "heavy" stream  in the diagram and the light industrial and nonindustrial
wastewater streams  are represented by  the "light" stream in the diagram.  However, the TWL
options incorporate  standards that  are applied to the combined untreated and treated streams prior
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                                                       Chapter 8 - Development of Technology Control Options

to discharge and that are based on treatment performance data for the DAF-A11 and CP-A11
technology control options.

8.7.3          Combination (Combo) Technology Control Options

              EPA also considered technology control options in which standards would be
based on a combination of the DAF-IL and CP-IL standards.  The combination options were
developed to provide industry with increased flexibility in the treatment technologies used,
resulting in more cost-effective technology options.  These combination options, Combo-IL and
Combo-IL-2LIM, are described below.
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                                                      Chapter 8 - Development of Technology Control Options
                                       Table 8-2
       Definitions of Additional Technology Control Options Considered
                                 for PSES and PSNS
Technology
Control Option
DAF-IL
CP-IL
Combo-IL
Combo-IL-2LIM
DAF-TWL
CP-TWL
Combo- TWL
Combo-TWL-
2LIM
Combo- All
Combo-All-2LIM
Towel Only
No Regulation
Description
Dissolved air flotation of wastewater from industrial laundry items.
Chemical precipitation of wastewater from industrial laundry items.
Dissolved air flotation or chemical precipitation of wastewater from industrial
laundry items. Facilities without treatment are costed for the less expensive
technology on an annualized basis.
Dissolved air flotation or chemical precipitation of wastewater from industrial
laundry items. Facilities without treatment are costed for chemical
precipitation.
Dissolved air flotation of wastewater from heavy industrial laundry items.
Chemical precipitation of wastewater from heavy industrial laundry items.
Dissolved air flotation or chemical precipitation of wastewater from heavy
industrial laundry items. Facilities without treatment are costed for the less
expensive technology on an annualized basis.
Dissolved air flotation or chemical precipitation of wastewater from heavy
industrial laundry items. Facilities without treatment are costed for chemical
precipitation.
Dissolved air flotation or chemical precipitation of all facility process
wastewater. Facilities without treatment are costed for the less expensive
technology on an annualized basis.
Dissolved air flotation or chemical precipitation of all facility process
wastewater. Facilities without treatment are costed for chemical precipitation.
Dissolved air flotation of wastewater from industrial towels.
No national categorical pretreatment standards.
Basis of Standards1
DAF-A11
CP-A11
The higher LTA between
DAF-A11 and CP-A11
DAF-A11 or CP-A11, based
on technology costed
DAF-A11
CP-A11
The higher LTA between
DAF-A11 and CP-A11
DAF-A11 or CP-A11, based
on technology costed
The higher LTA between
DAF-A11 and CP-A11
DAF-A11 or CP-A11, based
on technology costed
DAF-Heavy
—
'Pollutant concentration data representing each treatment option are presented in Chapter 7 of this document.
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                                                       Chapter 8 - Development of Technology Control Options

              The Combo-IL technology control option combines  both the DAF-IL and CP-IL
standards into one set of standards for the industrial laundries industry. These standards would be
established based on the less stringent of the standards for the two technology control options for
each pollutant. EPA's data show that, overall, chemical precipitation performs slightly better than
DAF in treating industrial laundry process wastewater.  However, many industrial laundries have
already installed DAF systems. Having one set of standards allows flexibility for facilities with
either technology currently in place to meet those standards. In developing cost  estimates for this
option, industrial laundries that already have DAF or chemical precipitation treatment systems
with enough capacity to treat the heavy wastewater stream (as defined above in the IL
Technology Options section) were assumed to continue to treat their wastewater using their
existing technology. Industrial laundries with little or no treatment (including facilities that treat
their wastewater with chemical emulsion breaking) were costed for  the least expensive technology
control option (based on a comparison of DAF-IL and CP-IL annualized costs) to treat their
industrial laundry wastewater.

              The Combo-IL-2LIM technology control option is similar to the Combo-IL
option. In this option, the standards for the DAF-IL option would apply to facilities using DAF
to treat their wastewater and the standards for the CP-IL option would apply to all other facilities.
This option also allows flexibility for facilities with DAF treatment in place (DAF is the most
common treatment in the industry) to comply with DAF-based standards, but requires all other
facilities to comply with slightly more stringent standards based on chemical precipitation.  In
developing cost estimates for this option, industrial laundries that already have DAF or chemical
precipitation treatment systems with enough capacity to treat the heavy wastewater steam (as
defined above in the IL Technology Control Options section) were  assumed to continue to treat
their wastewater using their existing technology. Industrial laundries with little or no treatment
(including facilities that treat their wastewater with chemical emulsion breaking)  were costed for
the CP-IL technology control option to treat their industrial laundry wastewater.

              EPA also considered Combo options in which all process wastewater  would be
treated (Combo-All and Combo-All-2LIM).  These  options  were modeled in a manner similar to
the Combo-IL and Combo-IL-2LIM options described above, but resulted in higher compliance
costs.

              As in the IL options, EPA also considered additional TWL technology options
(Combo-TWL and Combo-TWL-2LIM).  In these options,  standards are based on a combination
of the DAF-TWL and CP-TWL standards to allow for increased flexibility in the technologies
used by industry to treat their heavy industrial laundry wastewater, allowing for a more cost-
effective technology option.

8.7.4          Towel Only Technology Control Option

              Some commenters on the proposed rule indicated that EPA should consider
regulating only facilities that launder shop and printer towels/rags, because these items have the
highest pollutant loadings of all items laundered by industrial laundries. As a result of the
comments, EPA evaluated a modified heavy option  that would require only facilities  that launder
shop towels, printer towels, furniture towels, or other  industrial towels/rags to meet the proposed

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                                                       Chapter 8 - Development of Technology Control Options

standards. EPA referred to this option as the Towel Only option.  The Towel Only option is
based on treating only the wastewater from laundering industrial towels, then mixing the treated
wastewater with wastewater from laundering all other items prior to monitoring and discharge
from the facility. The modified option is based on DAF technology because EPA does not have
treatment performance data characterizing chemical precipitation treatment of only shop and
printer towels/rags. EPA presented the Towel Only option in the Notice of Data Availability
(NODA) published December 23, 1998 (63 FR 71054).

8.7.5          No Regulation Option

              EPA also considered a no regulation option, which entails having no national
categorical pretreatment standards. Facilities would only need to comply with applicable local
standards. EPA assumed there would be no compliance costs or pollutant removals associated
with this option.

8.8           Technology Control Options Eliminated from Further Consideration

              Based on technical and economic analyses, EPA  eliminated the following
technology control options from further consideration for the proposed rule:

                    DAF-TWL;
                    CP-TWL;
                    Combo-TWL;
                    Combo-TWL-2LIM;
                    DAF-A11;
                    CP-A11;
              •      Combo-All; and
                    Combo-All-2LIM.

The reasons for eliminating these options from further consideration are presented below.

              EPA eliminated the TWL options from further consideration because some of the
pollutant concentrations in the untreated light industrial  and nonindustrial wastewater streams can
be found at higher concentrations than the standards for these technology options.

              EPA eliminated the All options, shown above, from further consideration because,
although these options can achieve the same effluent pollutant concentrations as the DAF-IL and
CP-IL options, the costs to treat the total facility process wastewater in these All options are
higher than the costs for the IL options.

              The following five technology control options were considered for the industrial
laundries proposed rule:

                    DAF-IL;
                    CP-IL;
              •      Combo-IL;

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                                                       Chapter 8 - Development of Technology Control Options

                    Combo-IL-2LIM; and
                    OC-Only.

              These options became regulatory options considered as the basis for the proposed
PSES.  EPA performed detailed analyses of costs, pollutant removals, and economic impacts for
these options as described in Chapter 12 of the proposed Technical Development Document (5)
and the proposed Economic Assessment (EA) (6).

              After proposal, EPA eliminated the OC-Only option from further  consideration
because of the  small amount of nonvolatile pollutant removals achieved by the option relative to
the cost, and because of the limited data available to support the option. EPA eliminated the
Combo-IL and Combo-IL-2LIM options from further consideration because they did not remove
as many pollutants as the CP-IL option and had overall higher costs than the CP-IL option.  The
DAF-IL option was retained because of the predominance of DAF treatment in the industry and
the pollutant removals achieved by DAF, even though the DAF costs were high relative to the
other options.

              Based on comments on the NOD A, EPA decided that the Towel Only option was
complicated to implement and enforce and could result in significantly  increased  monitoring costs.
Facilities might be required to monitor one portion of their effluent for compliance with the
categorical standards and to monitor the remainder of their effluent for compliance with local
limits.  In addition, there was limited treatment performance data available from facilities treating
Towel  Only wastewater. Therefore, EPA eliminated the Towel Only option from further
consideration.

8.9           Regulatory Control Options Considered for the Final Action

              The regulatory control options considered by EPA for the final action were:

              CP-IL - Chemical precipitation of wastewater from industrial laundry items;

              DAF-IL - Dissolved air flotation of wastewater from industrial laundry items; and

              No Regulation - No national categorical pretreatment standards for the industry.

For the CP-IL and DAF-IL options, EPA also considered three exclusions, as discussed in Section
8.5.1 of this document.  Chapters 9 and 11 of this document, respectively, discuss pollutant
removals and costs for the regulatory options.
8.10
1.
References

Bartman, Gary H. Crossflow Microfiltration. A Cost Effective Approach to Treat
Metals. Oil and Grease in the Industrial Laundries and Metal Finishing Industries.
EPOC Filtration and Separation Systems, Fresno, CA, February, 1993.

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                                                      Chapter 8 - Development of Technology Control Options

2.            Memorandum: Preliminary Data for Calculating Mass-Based Limitations for the
             Industrial Laundries Industry, August 15, 1997.

3.            U.S. Environmental Protection Agency.  Economic Assessment for the Final
             Action Regarding Pretreatment Standards for the Industrial Laundries Point
             Source Category TRevised February 2000). EPA-821-R-00-004, Washington, DC,
             February 2000.

4.            U.S. Environmental Protection Agency.  Cost-Effectiveness Analysis for the Final
             Action Regarding Pretreatment Standards for the Industrial Laundries Point
             Source Category TRevised February 20001 EPA-821-R-00-005, Washington, DC,
             February 2000.

5.            U.S. Environmental Protection Agency.  Technical Development Document for
             Proposed Pretreatment Standards for Existing and New Sources for the Industrial
             Laundries Point Source Category. EPA-821-R-97-007, Washington, DC,
             November 1997.

6.            U.S. Environmental Protection Agency.  Economic Assessment for Proposed
             Pretreatment Standards for Existing and New Sources for the Industrial Laundries
             Point Source Category.  EPA-821-R-97-005, Washington, DC, November 1997.
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                                                         Chapter 9 - Pollutant Loading and Removal Estimates

                                      CHAPTER 9

                POLLUTANT LOADING AND REMOVAL ESTIMATES

9.1           Introduction

              This chapter presents annual pollutant loading and removal estimates for the
industrial laundries industry for each of the regulatory options considered for the final action. A
number of additional technology control options considered for development of a rule is described
in Chapter 8 of this document. Information on these options was contained in the Technical
Development Document for the proposed rule (1) and in the record for the Notice of Data
Availability (NODA) (63 FR 71054; December 23, 1998).  The estimated pollutant loadings and
removals for these options can be found in the Industrial Laundries Administrative Record.

              EPA estimated the pollutant loadings and removals from industrial laundries to
evaluate the effectiveness of the treatment technologies, to estimate benefits gained from the
removal of pollutants discharged through publicly owned treatment works (POTWs) to surface
water, and to evaluate the cost effectiveness of the regulatory options in reducing the pollutant
loadings. The regulatory options considered for the final action include dissolved air flotation of
industrial laundry wastewater (DAF-IL) and chemical precipitation of industrial laundry
wastewater (CP-IL).  In addition, EPA evaluated three exclusion scenarios for both of these
regulatory options, as described in Chapter 8 of this document.

              Untreated, baseline, and postcompliance pollutant loadings and pollutant removals
for the industry were estimated for 72 pollutants of concern using data obtained from the industry.
Data on wastewater treatment in place and production and wastewater flows were reported for
the 1993 operating year in the 1994 Industrial Laundries Industry Questionnaire (detailed
questionnaire). Untreated, baseline, and postcompliance pollutant loadings are defined as follows:

              •      Untreated loadings - pollutant loadings in industrial laundry raw
                    wastewater.  These loadings do not account for wastewater treatment
                    reported in the detailed questionnaire.

              •      Baseline loadings — pollutant loadings in industrial laundry wastewater
                    being discharged to POTWs in 1993. These  loadings do account for
                    wastewater treatment reported in the detailed questionnaire.

              •      Postcompliance  loadings - pollutant loadings in industrial laundry
                    wastewater after implementation of a rule. These loadings were calculated
                    assuming that all industrial laundries would operate the wastewater
                    treatment technologies and meet the long-term averages (LTAs) for the
                    pollutants contained in each of the regulatory options.
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                                                          Chapter 9 - Pollutant Loading and Removal Estimates

              The following information is presented in this chapter:

              •      Section 9.2 presents the data sources that were used to estimate pollutant
                     loadings and removals;

              •      Section 9.3 discusses the methodology used to estimate pollutant loadings
                     and pollutant removals;

              •      Section 9.4 presents the pollutant loadings and removals for each
                     regulatory option, including untreated, baseline, and postcompliance
                     pollutant loadings and removals of pollutants from baseline levels to
                     postcompliance levels;

              •      Section 9.5 presents the pollutant baseline and postcompliance loadings
                     and pollutant removals for each regulatory option estimated from updated
                     wastewater treatment information provided in a 1998 survey conducted by
                     the industrial laundries trade associations; and

              •      Section 9.6 presents the references used.

9.2           Data Sources

              EPA used data from several sources to estimate untreated, baseline, and
postcompliance loadings for industrial laundry wastewater.  These sources included EPA site
visits and sampling episodes at industrial laundries, detailed monitoring questionnaires (DMQ),
the Preliminary Data Summary (PDS), and data received in comments on the proposed rule.
Chapter 3 of this document discusses these data sources in detail.

              To estimate untreated pollutant loadings for the industrial laundries industry, EPA
estimated pollutant concentrations and loadings for 72 pollutants at 190 in-scope industrial
laundries that submitted sufficient information  in response to the detailed questionnaire (in-scope
facilities meet the definition  of an industrial laundry as presented in  Chapter 4 of this document).
In addition, EPA estimated the untreated loadings for three exclusion scenarios for each
regulatory option (discussed in Chapter 8 of this document). EPA then  extrapolated the loadings
to the entire industry based on the survey weights  developed for each facility.  The untreated
pollutant concentrations and loadings for each facility were estimated using analytical data
obtained by EPA for specific laundering processes and item types, and the process/item-specific
production reported in the detailed questionnaire.

              EPA collected data for specific process/item  combinations for individual loads
laundered at a facility or for an entire stream generated from the same process/item combination.
EPA used the following process/item data to estimate untreated pollutant loadings:

              •      Water washing of industrial garments - data from three loads of pants and
                     three loads of shirts collected during three sampling episodes;
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                                                         Chapter 9 - Pollutant Loading and Removal Estimates

              •      Water washing of shop towels — data from four loads of shop towels
                    collected during four sampling episodes and two days of data collected for
                    EPA's PDS from a shop-towel-only stream at a facility sampled between
                    1985 and 1987;

              •      Water washing of printer towels/rags — data from three loads of printer
                    towels/rags collected during three sampling episodes;

              •      Water washing of mats — data from three loads of mats collected during
                    two sampling episodes;

              •      Water washing of mops — data from two loads of mops (with either no oil
                    treatment or oil added outside of the washer) collected during two
                    sampling episodes;

              •      Steam tumbling followed by water washing of printer towels/rags  — data
                    from one load collected during a sampling episode;

              •      Water washing of linen items — three days of data for a linen-only stream
                    collected during a sampling episode and DMQ data for three facilities that
                    launder greater than 93 percent linen; and

              •      Dry cleaning followed by water washing of shop towels, printer
                    towels/rags, and gloves - facility-collected data obtained during a site visit
                    from a wastewater stream generated from dry cleaning followed by water
                    washing.

              EPA estimated baseline loadings for individual facilities from untreated or treated
loadings, based on the wastewater treatment in place reported by the facility in the detailed
questionnaire. The data that were used to calculate untreated loadings are described above. EPA
estimated treated loadings from the data presented in Sections 7.2.1, 7.2.2, and 7.2.3 of this
document for the five treatment options for which EPA had data.  These treatment options were
used to develop the technology control options discussed in Chapter 8 of this document.

              Postcompliance loadings were estimated for the regulatory options and exclusions
thereof. These regulatory options were developed using the data obtained for two of the
treatment options, as discussed in Chapters 7 and 8 of this document.

              Section 9.3 of this document presents details on the methodology used to estimate
the pollutant loadings and removals.

9.3           Methodology Used to Estimate Pollutant Loadings and Removals

              This section presents the methodology used to estimate untreated, baseline, and
postcompliance pollutant  loadings and removals of pollutants from baseline levels to
postcompliance levels.

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                                                           Chapter 9 - Pollutant Loading and Removal Estimates

9.3.1         Methodology Used to Estimate Industry Untreated Pollutant Loadings

              EPA estimated untreated pollutant loadings for each of the 190 in-scope facilities
using the process/item-specific data discussed in  Section 9.2 of this document, and extrapolated
these loadings to represent the entire industry using the appropriate survey weights. Untreated
pollutant loadings do not account for pollutant removals by wastewater treatment technologies in
place at industrial laundries in 1993, as  reported in the detailed questionnaire.

              The amount of pollutant generated per pound of laundry was estimated from the
process/item-specific data.  EPA estimated the pollutant loadings per pound of item laundered for
each process/item combination using the following  equation:

           Concentration       x    Flow (L, for process/item)      Amount of pollutant generated
     (mg/L, for process/item data)    Production (Ibs, for process/item)  ~ Per Pound  of laundry (mg/lb)

              EPA calculated the pollutant loading per pound of item for each item-specific
stream for which data were available. If data from more than one load or more than one facility
represented a process/item combination, an average of the individual load or facility's pollutant
loadings was calculated. If a specific pollutant was never detected or never analyzed for on a
particular item, the pollutant loading for that process/item/pollutant combination was set to zero
milligrams of pollutant per pound of laundry.  Table 9-1 presents the pollutant loading generated
per pound of item for several pollutants and groups of pollutants (e.g., toxic organic pollutants)
for the process/item combinations presented in Section 9.2 of this document.

              Pollutant concentration data were  not  obtained for all of the process/item
combinations reported by the 190 in-scope facilities in the detailed questionnaires.  To estimate
the pollutant loadings for all facilities, EPA transferred pollutant concentration data from the
process/item combinations with data available to  other process/item-specific combinations for
which data were not available.  Table 9-2 presents these data transfers.  The process/item-specific
pollutant concentrations were transferred to items having similar customers and/or uses, similar
degrees of pollutant loadings, and being laundered with similar types of chemicals.

              For each of the 190 in-scope facilities, EPA then calculated the untreated
wastewater pollutant concentrations and loadings from the amount of pollutant generated per
pound of laundry for each process/item  combination and process/item-specific production and
flow data.  The production and flow data were obtained from the information reported by each
facility in the detailed questionnaire.  The following equation was used to calculate the pollutant
concentrations for each facility:

      Amount of pollutant generated   Production (Ibs of process/item at  facility)  Facility untreated concentration
      per pound of laundry (mg/lb)     Flow  (L, for process/item at facility)        (mg/L= for process/item)
                                             9-4

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                                                                                                         Chapter 9 - Pollutant Loading and Removal Estimates
                                                                   Table 9-1
                                           Pollutant Loadings per Pound of Item Processed
                                                         (mg Pollutant/lb Laundry)
Pollutant
BOD5
O&G (measured as HEM)
TPH (measured as SGT-HEM)1
TSS
COD
TOC
TXM
TXO
NCM
NCO
Industrial
Garments
2,578
932
326
2,160
12,281
2,627
21
11
114
35
Shop
Towels
20,293
23,160
12,845
36,709
111,985
16,110
235
350
602
1,341
Printer
Towels/Rags
51,581
94,464
30,828
14,735
222,981
33,168
326
1,045
298
2,707
Steam Tumbled
Printer
Towels/Rags
12,998
15,535
4,226
11,915
81,240
15,977
75
89
93
1,041
Mats
544
314
145
2,050
1,515
340
14
12
107
11
Mops
13,646
3,378
1,316
13,152
64,242
6,192
73
53
348
247
Linen Items
7,237
1,295
147
2,241
9,376
4,817
15
25
83
54
Items Dry
Cleaned Prior to
Water Washing
1,605
NA
NA
1,165
9,011
NA
26
14
107
14
VO
      'SGT-HEM is measured by Method 1664 (promulgated at 64 FR 26315; May 14, 1999). In this method, EPA defines SGT-HEM as non-polar matenal (NPM).
      Throughout this document and the Industrial Laundries Administrative Record, EPA refers to SGT-HEM as TPH.

      BOD5 - Biochemical oxygen demand.
      O&G - Oil and grease.
      HEM - Hexane extractable material.
      NA - Not available.
      TPH  - Total petroleum hydrocarbon.
      SGT-HEM - Silica gel treated-hexane extractable material.
      TSS - Total suspended solids.
      COD - Chemical oxygen demand.
      TOC - Total organic carbon.
      TXM - Total priority metals and elements.
      TXO - Total priority organics.
      NCM - Nonconventional metals.
      NCO - Nonconventional organics.

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                                                                  Chapter 9 - Pollutant Loading and Removal Estimates
                                             Table 9-2
                                  Analytical Data Transfers
Analytical Data Transfers for Water-Washed Items1
Item
Health-Care Items (BOS)
Family Laundry (B15)
Executive Wear (B 18)
Continuous Roll Towels (BIO)
Miscellaneous Not Our Goods
(NOG) (B 19)
New Items (B 17)
Clean Room Garments (B 1 1 )
Laundry Bags (B14)
Fender Covers (B09)
Filters (B23)
Other (unspecified) (B13)
Buffing Pads (B24)
Item-Specific Data to be
Transferred
Linen (B06, B07)
Linen (B06, B07)
Linen (B06, B07)
Linen (B06, B07)
Linen (B06, B07)
Linen (B06, B07)
Linen (B06, B07)
Industrial Garments (B01)
Shop Towels (B02)
Shop Towels (B02)
Floor Mats (B04)
Floor Mats (B04)
Basis of Data Transfer
Customer and Use
Customer and Use
Customer and Use
Customer
Customer
Pollutant Loading
Pollutant Loading
Customer and Chemical Use
Customer and Use
Customer and Use
Chemical Use
Customer and Use
Analytical Data Transfers for Processes
Process
Denim Prewash
Dual-Phase Processing
Process Data to be Transferred
Water Washing of Linen Items
Dry Cleaning Followed by Water
Washing2
Basis of Data Transfer
Pollutant Loading
Chemical Use and Pollutant Loading
'Codes in parenthesis refer to codes used in the detailed questionnaire.
2If data were not available for a specific pollutant, data were transferred from water washing of mats.
                                                  9-6

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                                                            Chapter 9 - Pollutant Loading and Removal Estimates

From the facility-specific concentration, the annual pollutant loading for each facility process/item
was calculated using the following equation:

      Facility untreated concentration    Facility annual flow       1 Ib      Facility untreated annual loading
        (mg/L, for process/item)     (L/yr, for process/item)   453 600 mg      (Ibs/yr, for process/item)

To estimate the total untreated wastewater pollutant loading for a facility, EPA summed the
loadings calculated from each process/item combination for each pollutant.

9.3.2         Methodology Used to Estimate Industry Baseline Wastewater Loadings

              Industry baseline loadings represent the industry pollutant loadings after
accounting for removal of pollutants from untreated wastewater by treatment technologies in
place at industrial laundries. Chapter 11 of this document discusses the assessment of treatment
in place for industrial laundries. Based on information provided in the detailed questionnaire for
the 1993 operating year, the treatment technologies in use at industrial laundries included
chemical emulsion breaking, dissolved  air flotation, chemical precipitation, microfiltration, and
ultrafiltration. Some facilities use these technologies to treat their entire process wastewater
stream, while other facilities treat only part of their process wastewater.

              Table 9-3 presents the various treatment-in-place scenarios for the  190 in-scope
facilities.  EPA calculated baseline pollutant loadings based  on the reported capacity of each
facility's treatment system (i.e., the amount of treated wastewater discharged) and the appropriate
set of target average concentrations chosen for each facility. The set of target average
concentrations was chosen based  on an approximation of the type of treated  wastewater that is
generated from the facility's treatment system.

              The baseline pollutant loadings for facilities with no treatment in place are
equivalent to the facilities' untreated pollutant loadings, as discussed in Section 9.3.1 of this
document. The baseline pollutant loadings for facilities that have treatment in place were
estimated by applying the appropriate set of target average concentrations to  the annual facility
treated wastewater discharge flow as shown in the following equation:

       Target average concentration x Facility annual treated x     1 Ib      Facility baseline annual loading
       for treatment in place (mg/L)  discharge flow (L/yr)   453 gQQ mg    for treated wastewater (Ibs/yr)
               The baseline pollutant loadings for a facility treating a portion of their wastewater
are the sum of the facility baseline annual loading for the treated portion of the wastewater (as
calculated above) and the annual pollutant loading for the untreated portion of wastewater
(calculated as described in Section 9.3.1 of this document).
                                             9-7

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                                                                                                                      Chapter 9 - Pollutant Loading and Removal Estimates
                                                                           Table 9-3
                                               Treatment-In-Place Scenarios for Model Facilities
Treatment In Place
None
CEB-Heavy

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                                                           Chapter 9 - Pollutant Loading and Removal Estimates

              EPA calculated target average concentrations used in estimating the baseline
pollutant loadings from the analytical data described in Section 7.2 of this document. Prior to
calculating the target average concentrations, the data were edited using procedures described in
Chapter 7 of this document for calculating long-term averages, variability factors, and candidate
pretreatment standards with one exception. As described in Section 7.3.3 of this document, if the
average concentration of a pollutant in the influent samples collected from a facility was less than
ten times the method detection level for that pollutant, EPA did not use the data for that pollutant
at that facility to calculate long-term averages, variability factors, and candidate pretreatment
standards, but did use the data to calculate the target average concentrations used to estimate
pollutant loadings.  Table 9-4  summarizes the target average concentrations that were used to
estimate the baseline loadings  for facilities with treatment in place.

              As stated previously, baseline pollutant loadings for facilities with treatment in
place were calculated based on the reported treatment system, type, hydraulic capacity, and the
set of target average concentrations chosen for each facility's treated wastewater type.  Each
facility was given a treatment-in-place designation for their equipment type and hydraulic capacity
with respect to the seven technology control options and corresponding target average
concentrations shown in Table 9-4. By applying the appropriate set of target average
concentrations to each facility's treated discharge flow, EPA estimated  the baseline pollutant
loadings from these facilities' treatment systems.

              For most of the facilities that reported treating their wastewater, the target average
concentrations chosen were based on  pollutant concentration data from treatment systems
equivalent to what each facility has in place. For example, the facilities that reported treating all
of their process wastewater with DAF or chemical precipitation received  a treatment-in-place
designation of DAF-All and CP-A11, respectively, based on their equipment type and hydraulic
capacity.  In addition, the set of target average concentrations chosen for  these facilities are based
on pollutant concentration data collected from DAF and CP systems treating total facility process
wastewater streams, respectively (DAF-All and CP-A11, as shown in Table 9-4). Similarly,
facilities that reported DAF  or chemical precipitation system hydraulic  capacities that were
sufficient to treat the wastewater generated from the laundering of their industrial textile items
were  given a treatment-in-place designation of DAF-IL and CP-IL, respectively.  The target
average concentrations were also chosen from the  sets for DAF-IL and CP-IL, as shown in Table
9-4.

              There were six facilities that reported treatment system capacities that were larger
than required for one technology control  option, but insufficient for another technology control
option treating the next larger portion of wastewater with the same technology. For example, one
facility shown in Table 9-3 reported having a chemical precipitation system that treats an amount
of wastewater that is greater than that generated by laundering its heavy industrial textile items,
but less than that its total industrial laundry wastewater.  Since the facility has a treatment system
larger than the CP-Heavy technology  control  option, but smaller than the CP-IL technology
control option, it was given  a treatment-in-place designation of "less than" (<) CP-IL. Further,
since this facility reported treating wastewater generated from the laundering of items other than
just its heavy industrial textile items, it was assumed that the treatment  system effluent pollutant
concentrations would be represented by the CP-IL set of target average concentrations

                                            9-9

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                                              Chapter 9 - Pollutant Loading and Removal Estimates
                               Table 9-4

Overall Target Average Concentrations for the Seven Technology Control
Options for the Pollutants of Concern Used as the Bases for Calculation of
                      Baseline Pollutant Loadings
Pollutant of Concern
Median Target Average Concentration (mg/L)1
CEB-Heavy2
Towel Only3
CP-Heavy4
DAF-IL/
DAF-A115
CP-IL/
CP-A11'
Conventionals
Biochemical Oxygen Demand 5-Day (BOD5)
Oil and Grease (measured as HEM)
Total Suspended Solids (TSS)
1,040
268
259
1,310
230
487
1,390
38.2
56.3
497
37.8
85.5
399
28.5
117
Priority Organics
1, 1, 1-Trichloroethane
1,2-Diphenylhydrazine
4-Chloro-3-methylphenol
Bis(2-ethylhexyl) Phthalate
Butyl Benzyl Phthalate
Chlorobenzene
Chloroform
Di-ซ-butyl Phthalate
Di-ซ-octyl Phthalate
Ethylbenzene
Isophorone
Methylene Chloride
Naphthalene
Phenol
Tetrachloroethene
Toluene
trans- 1,2-Dichloroethene
Trichloroethene
—
—
0.205
0.462
—
—
—
0.0100
0.0307
0.305
—
0.0360
0.104
—
0.286
0.543
—
—
—
—
—
0.600
—
—
—
0.170
—
1.37
—
—
0.800
—
—
6.35
—
—
—
45.2
—
0.0469
0.0100
—
0.0527
0.0100
—
0.0931
—
—
0.114
—
0.127
0.818
—
0.0529
0.0100
—
0.151
0.144
0.216
0.0280
0.185
0.125
0.0280
0.0605
—
0.546
0.0764
0.211
0.250
0.711
—
—
0.390
—
0.0416
0.0691
0.0100
0.0336
0.0373
0.0100
0.0342
0.154
0.300
0.126
0.0583
—
0.421
0.973
—
0.0363
Nonconventional Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pentanone
ฐ<-Terpineol
Benzoic Acid
Benzyl Alcohol
Hexanoic Acid
m-Xylene
ซ-Decane
ซ-Docosane
0.113
0.0458
1.21
0.0722
0.0100
—
—
0.128
0.366
0.279
0.0347
4.68
0.129
7.42
9.55
0.471
—
—
—
—
1.26
0.110
0.421
0.0100
—
0.256
—
—
—
—
0.104
0.0240
0.0120
17.4
0.116
13.6
0.595
0.472
1.58
—
—
0.327
0.469
0.0232
1.68
0.0114
1.54
1.96
0.0464
—
0.342
0.203
0.241
0.0873
0.0113
                                  9-10

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                          Chapter 9 - Pollutant Loading and Removal Estimates
Table 9-4 (Continued)
Pollutant of Concern
Median Target Average Concentration (mg/L)1
CEB-Heavy2
Towel Only3
CP-Heavy4
DAF-IL/
DAF-A115
CP-IL/
CP-A11'
Nonconventional Organics (Continued)
ซ-Dodecane
ซ-Eicosane
ซ-Hexacosane
ซ-Hexadecane
ซ-Octacosane
ซ-Octadecane
ซ-Tetracosane
ซ-Tetradecane
ซ-Triacontane
o-&p-Xylene
p-Cresol
p-Cymene
Pentamethylbenzene
0.574
0.0779
0.0100
0.0417
0.0100
0.0560
—
0.116
—
0.359
—
—
—
—
0.150
—
0.490
—
0.422
—
0.979
—
—
—
0.610
—
0.0100
0.0382
0.0122
0.0315
0.0100
0.0100
0.0329
0.612
0.0341
0.0940
—
0.0208
0.0100
0.195
0.0477
0.0195
0.0842
0.0100
0.0694
0.0219
0.0754
0.0100
0.271
0.117
0.0700
—
1.46
0.0150
0.0131
0.0413
0.0168
0.0308
0.0121
0.0394
0.0119
0.197
—
0.0100
—
Priority Metals and Elements
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
0.195
—
0.00208
0.132
0.153
0.437
0.914
0.000200
0.255
—
—
—
6.78
0.0438
0.00866
—
0.00650
0.0715
1.45
0.237
—
0.0225
—
0.0846
—
0.903
0.0246
0.00820
0.00100
0.00500
0.0147
0.534
0.0473
0.000206
0.0307
0.0157
0.00400
—
0.0637
0.0593
0.0259
—
0.0145
0.0695
0.478
0.175
0.000242
0.0406
0.0524
0.0188
0.00294
0.837
0.0343
0.0121
0.000650
0.00774
0.0463
0.270
0.0993
0.000329
0.0396
0.00313
0.00769
—
0.303
Nonconventional Metals and Elements
Aluminum
Barium
Boron
Cobalt
Iron
Manganese
Molybdenum
Tin
Titanium
Vanadium
Yttrium
6.33
0.339
1.64
—
47.3
0.596
0.205
0.0642
0.0818
0.0114
—
1.34
0.702
—
0.0885
19.0
0.884
—
0.0336
0.0927
0.0162
0.00410
0.0804
0.145
11.4
0.0149
0.366
0.00768
0.774
0.0300
0.00453
0.0100
0.00300
1.31
0.0584
0.522
0.0381
2.79
0.0340
0.119
0.0631
0.0112
0.00700
0.00208
1.33
0.155
0.383
0.0195
1.78
0.0318
0.275
0.0299
0.0461
0.00757
0.00344
           9-11

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                                                                           Chapter 9 - Pollutant Loading and Removal Estimates
                                           Table 9-4 (Continued)
Pollutant of Concern
Median Target Average Concentration (mg/L)1
CEB-Heavy2
Towel Only3
CP-Heavy4
DAF-IL/
DAF-A115
CP-IL/
CP-A11'
Bulk Nonconventionals
Chemical Oxygen Demand (COD)
Total Organic Carbon (TOC)
Total Petroleum Hydrocarbon (measured as SGT-HEM)7
2,460
626
200
3,320
1,610
42.1
2,510
910
7.20
998
326
13.7
1,270
310
10.2
'LTAs for these pollutants of concern were not calculated for all options for one or more of the following reasons:  the pollutant was
not treated by the technology; the pollutant was not detected in the influent wastewater; there was a process upset at the time samples
were collected; the treatment performance data had inconsistent detection limits; or data considered a lower limit of the actual value.
See Section 7.3 of this chapter for more details related to the data editing criteria.
2CEB-Heavy represents data from facilities using chemical emulsion breaking treatment of heavy wastewater.
3Towel Only represents data from facilities using DAF treatment of heavy wastewater.
4CP-Heavy represents data from facilities using chemical precipitation treatment of heavy wastewater.
5DAF-IL and DAF-All  represent data from facilities using DAF treatment of all facility process wastewater.
6CP-IL and CP-A11 represent data from facilities using chemical precipitation treatment of all facility process wastewater.
'SGT-HEM is measured by Method 1664 (promulgated at 64 FR 26315; May 14, 1999). In this method, EPA defines SGT-HEM as
non-polar material (NPM).  Throughout this document and the Industrial Laundries Administrative Record, EPA refers to SGT-HEM
as total petroleum hydrocarbon (TPH).

HEM-Hexane extractable material.
SGT-HEM - Silica gel treated-hexane extractable material.
                                                        9-12

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                                                           Chapter 9 - Pollutant Loading and Removal Estimates

in estimating this facility's baseline pollutant loading.  A similar assessment was performed for the
remaining four facilities that reported chemical precipitation treatment of wastewater generated
from fewer items than their heavy industrial textile items (
-------
                                                                                      Chapter 9 - Pollutant Loading and Removal Estimates
                                                       Table 9-5
                Methodology Used to Estimate Baseline Loadings for the Industrial Laundries Industry
Treatment In Place
None
CEB-Heavy

-------
                                                                                                                        Chapter 9 - Pollutant Loading and Removal Estimates
                                                                    Table 9-5 (Continued)
Treatment In Place
CP-A11
Source of Target Average
Concentrations for
Treated Baseline Loadings
CP-A11
Number of Model Facilities with
Treatment In Place
175
Basis for Baseline Pollutant Loadings
Total process stream loading estimated from target average
concentrations for CP-A116
VO
'Three of these facilities process the majority of their industrial laundry items with a dry-cleaning followed by water-washing process. EPA assumed these facilities
would meet the limitations for the DAF-IL and CP-IL regulatory options without installing these treatment technologies. For the purposes of modeling, EPA estimated
their baseline pollutant loadings from the target average concentrations calculated for the CP-IL regulatory option.
2Three facilities reported CEB treatment of the total wastewater stream. EPA does not have data representing CEB treatment of the total wastewater stream; the
baseline pollutant loadings for these facilities were estimated assuming they are only treating heavy industrial laundry wastewater.
3The DAF-A11 target average concentrations are equivalent to the DAF-IL target average concentrations and are applied to the facilities' entire process wastewater
annual flows.
4This facility operates a microfiltration unit. Since microfiltration can achieve lower final effluent pollutant concentrations than chemical precipitation when operated
properly  (2), this facility is considered to have better treatment in place than the  CP-Heavy option.
5One of these facilities operates an ultrafiltration unit.  Since ultrafiltration can achieve lower final effluent pollutant concentrations than chemical precipitation when
operated properly (2), this facility is considered to have better treatment in place than the CP-A11 option.
6The CP-A11 target average concentrations are equivalent to the CP-IL target average concentrations and are applied to the facilities' entire process wastewater annual
flows.
       CEB - Chemical emulsion breaking.
       CP - Chemical precipitation.
       DAF - Dissolved air flotation.
       IL - Industrial laundry.
       NA - Not applicable.

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                                                                                                                    Chapter 9 - Pollutant Loading and Removal Estimates
                                                                        Table 9-6
       Methodology Used to Estimate Postcompliance Loadings  for the DAF-IL Regulatory Option for the
                                                         Industrial Laundries Industry
Treatment In
Place
None
CEB-Heavy

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                                                                                                                           Chapter 9 - Pollutant Loading and Removal Estimates
                                                                               Table 9-7
        Methodology Used  to Estimate Postcompliance Loadings for the CP-IL Regulatory Option for the Industrial
                                                                       Laundries Industry
Treatment In
Place
None
CEB-Heavy

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                                                           Chapter 9 - Pollutant Loading and Removal Estimates

 9.3.4          Methodology Used to Estimate POTW Baseline and Postcompliance
               Wastewater Loadings

               POTW baseline pollutant loadings represent the loadings from industrial laundries
 discharged through POTWs to surface water in 1993, based on POTW  removal efficiencies for
 the pollutants of concern. The POTW baseline loadings account for the removal of pollutants
 from untreated industrial laundry wastewater by treatment technologies in place at industrial
 laundries, as previously discussed in Section 9.3.2.  The POTW baseline pollutant loadings were
 calculated for each of the 190 in-scope facilities, as shown in the following equation:
 Facility baseline annual loading    ,,   T>rvr\T.r   n *  *      i ซ- •    \  POTW baseline annual loading
          (Ibs/yr)         5 x (1 - POTW pollutant removal efficiency) =          (lbs/yr)

               POTW postcompliance pollutant loadings for each of the regulatory options take
 into account loadings from industrial laundries discharged through POTWs to surface water after
 implementation of a rule. POTW postcompliance pollutant loadings account for the removal of
 pollutants from industrial laundry wastewater after implementation of the regulatory options, as
 previously discussed in Section 9.3.3. The POTW postcompliance pollutant loadings were
 calculated for each of the 190 in-scope facilities, as shown in the following equation:

Facility postcompliance annual loading   ,,   r^-m?   n *  *     i  ซ- •   -,  POTW postcompliance annual loading
    3 ^     ,-n. ,  ->          5 x (1 - POTW pollutant removal  efficiency) =            ,n. i \
           (lbs/yr)              \          r                   n              (lbs/yr)

               The POTW pollutant removal efficiencies that were used to calculate POTW
 baseline and postcompliance loadings are shown for each pollutant of concern in Table 9-8.
 Chapter 7 of this document describes the methods used to estimate the  POTW removal
 efficiencies.

 9.3.5          Methodology Used to Estimate Industry and POTW Pollutant Removals

               Industry pollutant removals represent the difference between industry baseline
 loadings and postcompliance loadings for each regulatory option.  Because all the identified
 industrial laundries are indirect dischargers, the removals presented  here represent removals of
 pollutants being discharged to POTWs.  EPA calculated the pollutant removals for each facility
 using the following equation:

      Facility  baseline annual loading   Facility postcompliance annual loading   Facility pollutant removals
                (lbs/yr)                          (lbs/yr)              ~        (lbs/yr)
               EPA used the following methodology to estimate pollutant removals:

               1)      If the facility postcompliance annual loading of a pollutant was higher than
                      the facility baseline annual loading, the facility pollutant removal was set to
                      zero:
                                            9-18

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                                              Chapter 9 - Pollutant Loading and Removal Estimates
                              Table 9-8
POTW Pollutant Removal Efficiencies for the Pollutants of Concern
Pollutant of Concern
POTW Pollutant Removal Efficiency
Conventionals
Biochemical Oxygen Demand 5-Day (BOD5)
Oil and Grease (measured as HEM)
Total Suspended Solids (TSS)
91%
87%
91%
Priority Organics
1,1,1 -Trichloroethane
1 ,2-Diphenylhydrazine
4-Chloro-3-methylphenol
Bis(2-ethylhexyl) Phthalate
Butyl Benzyl Phthalate
Chlorobenzene
Chloroform
Di-w-butyl Phthalate
Di-w-octyl Phthalate
Ethylbenzene
Isophorone
Methylene Chloride
Naphthalene
Phenol
Tetrachloroethene
Toluene
trans- 1 ,2-Dichloroethene
Trichloroethene
24%
62%
63%
60%
86%
24%
24%
75%
33%
33%
62%
18%
18%
95%
33%
33%
33%
33%
Nonconventional Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pentanone
ซ-Terpineol
Benzoic Acid
Benzyl Alcohol
Hexanoic Acid
18%
28%
85%
18%
18%
81%
33%
33%
                                 9-19

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                          Chapter 9 - Pollutant Loading and Removal Estimates
Table 9-8 (Continued)
Pollutant of Concern
POTW Pollutant Removal Efficiency
Nonconventional Organics (Continued)
w-Xylene
w-Decane
w-Docosane
w-Dodecane
w-Eicosane
w-Hexacosane
w-Hexadecane
w-Octacosane
w-Octadecane
w-Tetracosane
w-Tetradecane
w-Triacontane
o-&/>-Xylene
p-Creso\
p-Cymene
Pentamethy Ibenzene
33%
33%
94%
33%
33%
94%
33%
94%
33%
94%
33%
94%
33%
72%
99%
91%
Priority Metals and Elements
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
72%
40%
61%
91%
91%
84%
92%
33%
52%
34%
80%
28%
77%
Nonconventional Metals and Elements
Aluminum
Barium
88%
35%
           9-20

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                                                                Chapter 9 - Pollutant Loading and Removal Estimates
                                    Table 9-8 (Continued)
Pollutant of Concern
POTW Pollutant Removal Efficiency
Nonconventional Metals and Elements (Continued)
Boron
Cobalt
Iron
Manganese
Molybdenum
Tin
Titanium
Vanadium
Yttrium
14%
4%
83%
41%
52%
65%
69%
42%
58%
Bulk Nonconventionals
Chemical Oxygen Demand (COD)
Total Organic Carbon (TOC)
Total Petroleum Hydrocarbon (measured as SGT-HEM)1
82%
71%
74%
1 Silica gel treated-hexane extractable material (SGT-HEM) is measured by Method 1664 (promulgated at 64 FR
26315; May 14, 1999). In this method, EPA defines SGT-HEM as non-polar matenal (NPM).  Throughout this
document and the Industrial Laundries Administrative Record, EPA refers to SGT-HEM as total petroleum hydrocarbon
(TPH).
                                                9-21

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                                                         Chapter 9 - Pollutant Loading and Removal Estimates

              2)     If the pollutant was not present at baseline, the removal was set to zero;
                     and

              3)     If a target average concentration was not calculated for a pollutant for a
                     regulatory option (i.e., the postcompliance loading for the pollutant could
                     not be calculated), the removal was set to zero.

              Each of the facility pollutant removals were extrapolated using the facility survey
weights to calculate the total industry pollutant removals for each of the regulatory options.

              Similarly, POTW pollutant removals represent the difference between POTW
baseline annual loadings and postcompliance annual loadings for each regulatory option. The
POTW pollutant removals represent the annual amount of pollutants that would be removed from
surface water after implementation of a rule.  EPA calculated the POTW pollutant removals for
each facility using the following equation:


      POTW baseline annual loading   POTW postcompliance annual loading   POTW pollutant removals
               (Ibs/yr)                        (Ibs/yr)              ~         (Ibs/yr)
              Each of the POTW pollutant removals were extrapolated to calculate the total
POTW pollutant removal for the industrial laundries industry for each of the regulatory options.

9.4           Pollutant Loadings and Removals

              EPA estimated annual industry untreated, baseline, and postcompliance loadings
for each of the regulatory options using the methodology described in Section 9.3 of this
document. EPA extrapolated the facility-specific loadings and removals from the 190 in-scope
facilities (and subsets of the 190 facilities) to represent the entire industry of 1,742 facilities (and
subsets of the industry).  In addition, EPA estimated the POTW  annual baseline and
postcompliance loadings from industrial laundries discharged by POTWs to surface water for each
of the regulatory options using the methodology described in Section 9.3.4 of this document.
EPA extrapolated the POTW loadings and removals, as described previously. Tables
summarizing the loadings and pollutant removals from industrial laundry and POTW effluents for
each pollutant of concern are included in Appendix E of this document.

              The following tables (presented at the end of this chapter) summarize the industry
and POTW baseline and postcompliance pollutant loadings, the  POTW pollutant removals, and
the POTW toxic-weighted pollutant removals (in total pounds and in pound equivalents) for total
priority and nonconventional pollutant groupings:

              •       Tables 9-9 and 9-10 - present industry and POTW baseline and
                     postcompliance loadings, the POTW pollutant removals, and the POTW
                     toxic-weighted pollutant removals for all  1,742 facilities for CP-IL and
                     DAF-IL, respectively;
                                           9-22

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                                                        Chapter 9 - Pollutant Loading and Removal Estimates

              •      Tables 9-11 and 9-12 — present industry and POTW baseline and
                    postcompliance loadings, the POTW pollutant removals, and the POTW
                    toxic-weighted pollutant removals for 1,606 facilities included in the
                    CP-IL and DAF-IL regulatory options under the "1  Million/255 K"
                    exclusion, respectively;

              •      Tables 9-13 and 9-14 — present industry and POTW baseline and
                    postcompliance loadings, the POTW pollutant removals, and the POTW
                    toxic-weighted pollutant removals for 1,224 facilities included in the
                    CP-IL and DAF-IL regulatory options under the "3  Million/120 K"
                    exclusion, respectively; and

              •      Tables 9-15 and 9-16 — present industry and POTW baseline and
                    postcompliance loadings, the POTW pollutant removals, and the POTW
                    toxic-weighted pollutant removals for 789 facilities  included in the
                    CP-IL and DAF-IL regulatory options under the "5  Million/255 K"
                    exclusion, respectively.

              EPA estimates toxic-weighted pollutant removals by multiplying pounds of a
pollutant removed by an assigned toxic weighting factor to obtain the "pound equivalent"
pollutant removals. The assigned toxic weighting factor for each pollutant is based on the
pollutant's relative toxicity to copper.  The toxic weighting factors assigned to each pollutant of
concern can be found in the Industrial Laundries Administrative Record and the Cost-
Effectiveness Analysis document (3).

9.5           Pollutant Loadings and Removals Estimated from 1998 Facility Treatment-
              In-Place Data

              The industrial laundries trade associations (the Uniform  and Textile Service
Association (UTSA) and the Textile Rental Services Association (TRSA)) performed a survey of
all industrial laundries that were sent a detailed questionnaire.  More information on the types of
data collected by the UTSA/TRSA survey is provided in Section 3.7.2  of this document.. The
purpose of the survey was to provide EPA with 1998 data on treatment technologies in place at
industrial laundries.  Of the 190 in-scope facilities, 162 responded to the UTSA/TRSA survey.
Section 6.5.16 of this document summarizes the types of equipment that were reported in the
survey.

              At proposal (62 FR 66181; December 17,  1997), EPA estimated the industry and
POTW pollutant removals based on treatment-in-pi ace information reported in the detailed
questionnaire for the 1993 operating year. For the Notice of Data Availability (NODA) (63 FR
71054; December 23, 1998); EPA compared the pollutant removals estimated at proposal to the
industry and POTW pollutant removals estimated using the treatment-in-place information
reported in  the UTSA/TRSA survey for the 1998 operating year for the DAF-IL and CP-IL
regulatory options with the 1 Million/255 K exclusion.  EPA's methodology and the results of the
comparison are discussed below.
                                          9-23

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                                                         Chapter 9 - Pollutant Loading and Removal Estimates

              EPA compared the treatment system description contained in the UTSA/TRSA
survey to the treatment system components reported in the detailed questionnaire for each facility.
Most facilities did not report the treatment system design parameters of the treatment units
reported in the UTSA/TRSA survey.  To calculate the changes in the industry and POTW
baseline pollutant loadings, EPA made the following assumptions when reviewing the
UTSA/TRSA survey data:

              •       EPA continued to use the flow and production data that was reported in
                     the detailed questionnaire for all facilities.

              •       For facilities that reported that they treat a portion of their wastewater and
                     did not indicate the percentage of wastewater treated, EPA assumed that
                     they are treating only a small portion of their total wastewater.

              •       For facilities that reported DAF, chemical precipitation, or chemical
                     emulsion breaking treatment, EPA assumed that the facility is operating
                     these systems in a manner equivalent to the technology control options
                     costed by EPA.

              •       For facilities that provided treatment system descriptions that were not
                     detailed enough for EPA to make judgement regarding the treatment
                     system, EPA assumed that they are still operating the treatment system
                     reported in the  detailed questionnaire.

              •       For a facility that reported possible biological treatment, EPA assumed that
                     it does not have treatment in place equivalent to any of the technology
                     control options.

              •       For a denim prewash facility that operated a partial treatment system, EPA
                     assumed that it treats wastewater from all items except for the denim
                     prewash, which is not included in the scope of the rule.

              •       EPA did not reduce costs to reflect ancillary treatment technologies (e.g.,
                     screens, filter presses, equalization tanks) added since those reported in the
                     detailed questionnaire.

              •       EPA did not make any changes in the compliance costs for ten facilities
                     that reported closing or rebuilding since 1993.

              •       For facilities that reported that they planned to install treatment systems in
                     the future, EPA assumed that they are still operating the treatment system
                     reported in the  detailed questionnaire.

              •       EPA assumed facilities that did not respond to the UTSA/TRSA survey (28
                     out of the 190 in-scope facilities) were still operating the treatment system
                     reported in the  detailed questionnaire.

                                          9-24

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                                                        Chapter 9 - Pollutant Loading and Removal Estimates

              Table 9-17 presents a comparison of the POTW pollutant removals estimated for
the proposal and the POTW pollutant removals estimated using the UTSA/TRSA survey data for
the CP-IL and DAF-IL regulatory options with the 1 Million/255 K exclusion. Table 9-18
presents this comparison for the industry pollutant removals. The pollutant loadings and removals
were calculated using the assumptions and methodologies described previously in this chapter. By
incorporating the treatment-in-place information reported in the UTSA/TRSA survey, the baseline
pollutant loadings were changed for those facilities that reported adding or changing the treatment
technologies reported in the detailed questionnaire.  Because the industry and POTW pollutant
removals are a function of the baseline pollutant loadings, the pollutant removals also changed.
The total POTW pollutant removals were estimated to decrease by 8.9 million pounds and 9.5
million pounds (32 percent and 33 percent) from 1993 to 1998 in the
CP-IL and DAF-IL options, respectively. The total industry pollutant removals were estimated to
decrease by 50 million pounds and 53 million pounds (32 percent for each) from 1993 to 1998 in
the CP-IL and DAF-IL options, respectively.  Based on this comparison, EPA estimates that the
actual pollutant loadings and removals for the industrial laundries industry to comply with the
regulatory options (regardless of the specific exclusion) would be less than the pollutant loadings
and removals for the final action, based on the 1993 operating year.

9.6           References

1.             U.S. Environmental Protection Agency. Technical Development Document for
              Proposed Pretreatment Standards for Existing and New Sources  for the Industrial
              Laundries Point Source Category. EPA-821-R-97-007, Washington, DC,
              November 1997.

2.             Bartram, Gary H., Crossflow Microfiltration. A Cost Effective Approach to Treat
              Metals. Oil and Grease in the Industrial Laundries and Metal Finishing Industries.
              EPOC Filtration and Separation Systems, Fresno, CA, February  1993.

3.             U.S. Environmental Protection Agency. Cost-Effectiveness Analysis for the Final
              Action Regarding Pretreatment Standards for the Industrial Laundries Point
              Source Category TRevised February 20001  EPA-821-R-00-005, Washington, DC,
              February 2000.
                                          9-25

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                                                     Chapter 9 - Pollutant Loading and Removal Estimates
                                     Table 9-9
      Summary of Baseline Pollutant Loadings, Postcompliance Pollutant
     Loadings, and POTW Pollutant Removals from Industrial Laundries
                             Wastewater for CP-IL1
                                 Entire Industry2
Pollutant Group
Total Priority Organics
Total Nonconventional Organics
Total Priority Metals and Elements
Total Nonconventional Metals and Elements
Total Pollutants

Total Priority Organics
Total Nonconventional Organics
Total Priority Metals and Elements
Total Nonconventional Metals and Elements
Total Pollutants

Total Priority Organics
Total Nonconventional Organics
Total Priority Metals and Elements
Total Nonconventional Metals and Elements
Total Pollutants
Industry Baseline
Wastewater Pollutant
Loading (Ibs/yr)
683,114
1,805,347
487,665
2,180,096
5,156,222
Industry
Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
429,496
893,523
226,084
1,148,083
2,697,186
Total Pollutant
Removal from POTW
Effluents (Ibs/yr)
132,595
528,732
49,597
183,693
894,617
POTW Baseline
Wastewater Pollutant
Loading (Ibs/yr)
392,545
1,030,225
99,114
414,749
1,936,633
POTW Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
259,950
501,493
49,517
231,056
1,042,016
Total Toxic Weighted Pollutant
Removal from POTW
Effluents (Ib-equivalents/yr)
4,712
2,321
32,200
3,685
42,918
'Numbers in this table were calculated using more significant figures than shown.
2The entire industrial laundries industry is estimated to consist of 1,742 facilities.
                                        9-26

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                                                     Chapter 9 - Pollutant Loading and Removal Estimates
                                    Table 9-10
      Summary of Baseline Pollutant Loadings, Postcompliance Pollutant
     Loadings, and POTW Pollutant Removals from Industrial Laundries
                            Wastewater for DAF-IL1
                                 Entire Industry2
Pollutant Group
Total Priority Organics
Total Nonconventional Organics
Total Priority Metals and Elements
Total Nonconventional Metals and Elements
Total Pollutants

Total Priority Organics
Total Nonconventional Organics
Total Priority Metals and Elements
Total Nonconventional Metals and Elements
Total Pollutants

Total Priority Organics
Total Nonconventional Organics
Total Priority Metals and Elements
Total Nonconventional Metals and Elements
Total Pollutants
Industry Baseline
Wastewater Pollutant
Loading (Ibs/yr)
683,114
1,805,347
487,665
2,180,096
5,156,222
Industry Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
461,552
951,992
299,142
1,223,799
2,936,485
Total Pollutant
Removal from POTW
Effluents (Ibs/yr)
130,515
519,692
35,086
172,582
857,875
POTW Baseline
Wastewater Pollutant
Loading (Ibs/yr)
392,545
1,030,225
99,114
414,749
1,936,633
POTW Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
262,030
510,533
64,029
242,167
1,078,759
Total Toxic Weighted Pollutant
Removal from POTW
Effluents (Ib-equivalents/yr)
4,812
2,248
25,006
3,179
35,245
'Numbers in this table were calculated using more significant figures than shown.
2The entire industrial laundries industry is estimated to consist of 1,742 facilities.
                                        9-27

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                                                     Chapter 9 - Pollutant Loading and Removal Estimates
                                    Table 9-11
      Summary of Baseline Pollutant Loadings, Postcompliance Pollutant
     Loadings, and POTW Pollutant Removals from Industrial Laundries
                             Wastewater for CP-IL1
 Excluding Facilities with Less than 1 Million Pounds per Year Total Production and Less
           than 255,000 Pounds per Year Shop and Printer Towel Production2
Pollutant Group
Total Priority Organics
Total Nonconventional Organics
Total Priority Metals and Elements
Total Nonconventional Metals and Elements
Total Pollutants

Total Priority Organics
Total Nonconventional Organics
Total Priority Metals and Elements
Total Nonconventional Metals and Elements
Total Pollutants

Total Priority Organics
Total Nonconventional Organics
Total Priority Metals and Elements
Total Nonconventional Metals and Elements
Total Pollutants
Industry Baseline
Wastewater Pollutant
Loading (Ibs/yr)
673,848
1,775,897
481,921
2,161,142
5,092,808
Industry Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
426,467
886,592
224,544
1,140,153
2,677,756
Total Pollutant
Removal from POTW
Effluents (Ibs/yr)
128,929
515,223
48,852
181,470
874,474
POTW Baseline
Wastewater Pollutant
Loading (Ibs/yr)
387,038
1,012,832
98,031
410,917
1,908,818
POTW Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
258,109
497,609
49,178
229,447
1,034,343
Total Toxic Weighted Pollutant
Removal from POTW
Effluents (Ib-equivalents/yr)
4,603
2,262
31,663
3,627
42,155
'Numbers in this table were calculated using more significant figures than shown.
2136 of the 1,742 total industrial laundries are excluded from compliance under this criterion.
                                        9-28

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                                                     Chapter 9 - Pollutant Loading and Removal Estimates
                                    Table 9-12
      Summary of Baseline Pollutant Loadings, Postcompliance Pollutant
     Loadings, and POTW Pollutant Removals from Industrial Laundries
                            Wastewater for DAF-IL1
 Excluding Facilities with Less than 1 Million Pounds per Year Total Production and Less
           than 255,000 Pounds per Year Shop and Printer Towel Production2
Pollutant Group
Total Priority Organics
Total Nonconventional Organics
Total Priority Metals and Elements
Total Nonconventional Metals and Elements
Total Pollutants

Total Priority Organics
Total Nonconventional Organics
Total Priority Metals and Elements
Total Nonconventional Metals and Elements
Total Pollutants

Total Priority Organics
Total Nonconventional Organics
Total Priority Metals and Elements
Total Nonconventional Metals and Elements
Total Pollutants
Industry Baseline
Wastewater Pollutant
Loading (Ibs/yr)
673,848
1,775,897
481,921
2,161,142
5,092,808
Industry Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
457,889
943,083
297,093
1,215,322
2,913,387
Total Pollutant
Removal from POTW
Effluents (Ibs/yr)
127,021
506,768
34,442
170,447
838,678
POTW Baseline
Wastewater Pollutant
Loading (Ibs/yr)
387,038
1,012,832
98,031
410,917
1,908,818
POTW Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
260,017
506,064
63,589
240,470
1,070,140
Total Toxic Weighted Pollutant
Removal from POTW
Effluents (Ib-equivalents/yr)
4,702
2,192
24,522
3,126
34,542
'Numbers in this table were calculated using more significant figures than shown.
2136 of the 1,742 total industrial laundries are excluded from compliance under this criterion.
                                        9-29

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                                                       Chapter 9 - Pollutant Loading and Removal Estimates
                                     Table 9-13
      Summary of Baseline Pollutant Loadings, Postcompliance Pollutant
     Loadings, and POTW Pollutant Removals from Industrial Laundries
                              Wastewater for CP-IL1
 Excluding Facilities with Less than 3 Million Pounds per Year Total Production and Less
           than 120,000 Pounds per Year Shop and Printer Towel Production2
Pollutant Group
Total Priority Organics
Total Nonconventional Organics
Total Priority Metals and Elements
Total Nonconventional Metals and Elements
Total Pollutants

Total Priority Organics
Total Nonconventional Organics
Total Priority Metals and Elements
Total Nonconventional Metals and Elements
Total Pollutants

Total Priority Organics
Total Nonconventional Organics
Total Priority Metals and Elements
Total Nonconventional Metals and Elements
Total Pollutants
Industry Baseline
Wastewater Pollutant
Loading (Ibs/yr)
631,744
1,647,212
441,515
1,971,667
4,692,138
Industry Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
398,718
830,949
210,022
1,071,075
2,510,764
Total Pollutant
Removal from POTW
Effluents (Ibs/yr)
122,069
470,717
43,760
160,819
797,365
POTW Baseline
Wastewater Pollutant
Loading (Ibs/yr)
363,259
937,119
89,899
375,981
1,766,258
POTW Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
241,190
466,402
46,139
215,162
968,893
Total Toxic Weighted
Pollutant
Removal from POTW
Effluents (Ib-equivalents/yr)
4,245
2,063
28,913
3,262
38,483
'Numbers in this table were calculated using more significant figures than shown.
2518 of the 1,742 total industrial laundries are excluded from compliance under this criterion. This exclusion includes
the 136 facilities under the 1 Million/255K exclusion shown in Table 9-11.
                                         9-30

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                                                       Chapter 9 - Pollutant Loading and Removal Estimates
                                     Table 9-14
      Summary of Baseline Pollutant Loadings, Postcompliance Pollutant
     Loadings, and POTW Pollutant Removals from Industrial Laundries
                             Wastewater for DAF-IL1
 Excluding Facilities with Less than 3 Million Pounds per Year Total Production and Less
           than 120,000 Pounds per Year Shop and Printer Towel Production2
Pollutant Group
Total Priority Organics
Total Nonconventional Organics
Total Priority Metals and Elements
Total Nonconventional Metals and Elements
Total Pollutants

Total Priority Organics
Total Nonconventional Organics
Total Priority Metals and Elements
Total Nonconventional Metals and Elements
Total Pollutants

Total Priority Organics
Total Nonconventional Organics
Total Priority Metals and Elements
Total Nonconventional Metals and Elements
Total Pollutants
Industry Baseline
Wastewater Pollutant
Loading (Ibs/yr)
631,744
1,647,212
441,515
1,971,667
4,692,138
Industry Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
429,619
891,855
272,614
1,136,150
2,730,238
Total Pollutant
Removal from POTW
Effluents (Ibs/yr)
118,833
458,757
31,323
151,033
759,946
POTW Baseline
Wastewater Pollutant
Loading (Ibs/yr)
363,259
937,119
89,899
375,981
1,766,258
POTW Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
244,426
478,361
58,576
224,949
1,006,312
Total Toxic Weighted
Pollutant
Removal from POTW
Effluents (Ib-equivalents/yr)
4,335
1,987
22,458
2,798
31,578
'Numbers in this table were calculated using more significant figures than shown.
2518 of the 1,742 total industrial laundries are excluded from compliance under this criterion. This exclusion includes
the 136 facilities under the 1 Million/255K exclusion shown in Table 9-12.
                                         9-31

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                                                     Chapter 9 - Pollutant Loading and Removal Estimates
                                    Table 9-15
      Summary of Baseline Pollutant Loadings, Postcompliance Pollutant
     Loadings, and POTW Pollutant Removals from Industrial Laundries
                             Wastewater for CP-IL1
 Excluding Facilities with Less than 5 Million Pounds per Year Total Production and Less
           than 255,000 Pounds per Year Shop and Printer Towel Production2
Pollutant Group
Total Priority Organics
Total Nonconventional Organics
Total Priority Metals and Elements
Total Nonconventional Metals and Elements
Total Pollutants

Total Priority Organics
Total Nonconventional Organics
Total Priority Metals and Elements
Total Nonconventional Metals and Elements
Total Pollutants

Total Priority Organics
Total Nonconventional Organics
Total Priority Metals and Elements
Total Nonconventional Metals and Elements
Total Pollutants
Industry Baseline
Wastewater Pollutant
Loading (Ibs/yr)
524,074
1,344,436
353,460
1,563,066
3,785,036
Industry Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
352,002
685,436
170,841
879,286
2,060,565
Total Pollutant
Removal from POTW
Effluents (Ibs/yr)
105,310
376,388
34,364
123,380
639,442
POTW Baseline
Wastewater Pollutant
Loading (Ibs/yr)
301,652
761,153
72,129
299,886
1,434,820
POTW Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
196,341
384,765
37,765
176,506
795,377
Total Toxic Weighted
Pollutant
Removal from POTW
Effluents (Ib-equivalents/yr)
3,443
1,646
23,713
2,601
31,403
'Numbers in this table were calculated using more significant figures than shown.
2953 of the 1,742 total industrial laundries are excluded from compliance under this criterion.
                                        9-32

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                                                     Chapter 9 - Pollutant Loading and Removal Estimates
                                    Table 9-16
      Summary of Baseline Pollutant Loadings, Postcompliance Pollutant
     Loadings, and POTW Pollutant Removals from Industrial Laundries
                            Wastewater for DAF-IL1
 Excluding Facilities with Less than 5 Million Pounds per Year Total Production and Less
           than 255,000 Pounds per Year Shop and Printer Towel Production2
Pollutant Group
Total Priority Organics
Total Nonconventional Organics
Total Priority Metals and Elements
Total Nonconventional Metals and Elements
Total Pollutants

Total Priority Organics
Total Nonconventional Organics
Total Priority Metals and Elements
Total Nonconventional Metals and Elements
Total Pollutants

Total Priority Organics
Total Nonconventional Organics
Total Priority Metals and Elements
Total Nonconventional Metals and Elements
Total Pollutants
Industry Baseline
Wastewater Pollutant
Loading (Ibs/yr)
524,074
1,344,436
353,460
1,563,066
3,785,036
Industry Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
355,948
748,338
214,235
924,266
2,242,787
Total Pollutant
Removal from POTW
Effluents (Ibs/yr)
98,937
360,245
25,734
116,032
600,948
POTW Baseline
Wastewater Pollutant
Loading (Ibs/yr)
301,652
761,153
72,129
299,886
1,434,820
POTW Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
202,715
400,907
46,395
183,854
833,871
Total Toxic Weighted Pollutant
Removal from POTW
Effluents (Ib-equivalents/yr)
3,525
1,563
18,488
2,199
25,775
'Numbers in this table were calculated using more significant figures than shown.
2953 of the 1,742 total industrial laundries are excluded from compliance under this criterion.
                                        9-33

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                                                                                 Chapter 9 - Pollutant Loading and Removal Estimates
                                                   Table 9-17
         POTW Pollutant Removal Comparison Between the Removals Estimated at Proposal and Removals
              Incorporating UTSA/TRSA Survey Data for the CP-IL and DAF-IL Regulatory Options1
     Excluding Facilities with Less than 1 Million Pounds per Year Total Production and Less than 255,000 Pounds per Year Shop
                                          and Printer Towel/Rag Production2
Pollutant Grouping
POTW Pollutant Removal
Estimated for Proposal3
(1993 Ibs/yr)
POTW Pollutant Removal
Estimated Based on
UTSA/TRSA Survey4
(1998 Ibs/yr)
Percent Decrease in POTW
Pollutant Removal
CP-IL
Total Bulk Conventionals
Total Bulk Nonconventionals
Total Bulk Parameters
Total Priority Organics
Total Nonconventional Organics
Total Organics
Total Priority Metals and Elements
Total Nonconventional Metals and Elements
Total Metals and Elements
Total Pollutants
6,020,955
20,226,788
26,247,743
157,067
725,659
882,726
52,263
125,516
177,779
27,308,248
4,471,490
13,226,655
17,698,145
101,571
504,789
606,360
39,828
114,068
153,896
18,458,401
26%
35%
33%
35%
30%
31%
24%
9%
13%
32%
DAF-IL
Total Bulk Conventionals
Total Bulk Nonconventionals
Total Bulk Parameters
Total Priority Organics
Total Nonconventional Organics
Total Organics
6,149,908
21,268,017
27,417,925
180,908
783,871
964,779
4,559,753
13,732,557
18,292,310
110,677
549,338
660,015
26%
35%
33%
39%
30%
32%
VO

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                                                                                                                 Chapter 9 - Pollutant Loading and Removal Estimates
                                                               Table 9-17 (Continued)
Pollutant Grouping
Total Priority Metals and Elements
Total Nonconventional Metals and Elements
Total Metals and Elements
Total Pollutants
POTW Pollutant Removal
Estimated for Proposal3
(1993 Ibs/yr)
34,535
135,543
170,078
28,552,782
POTW Pollutant Removal
Estimated Based on
UTSA/TRSA Survey4
(1998 Ibs/yr)
25,063
119,054
144,117
19,096,442
Percent Decrease in POTW
Pollutant Removal
27%
12%
15%
33%
VO
       'Numbers in this table were calculated using more significant figures than shown.
       2136 of the 1,742 total industrial laundries are excluded from compliance under this criterion.
       3The removals estimated for proposal (62 FR 66181; December 17,1997) are based on treatment-in-place information from the detailed questionnaire for the 1993
       operating year.
       4The removals were estimated based on treatment-in-place information in the UTSA/TRSA survey for the 1998 operating year (presented in the Notice of Data
       Availability, 63 FR 71054; December 23, 1998).

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                                                                                 Chapter 9 - Pollutant Loading and Removal Estimates
                                                   Table 9-18
VO
        Industry Pollutant Removal Comparison Between the Removals Estimated at Proposal and Removals
              Incorporating UTSA/TRSA Survey Data for the CP-IL and DAF-IL Regulatory Options1
     Excluding Facilities with Less than 1 Million Pounds per Year Total Production and Less than 255,000 Pounds per Year Shop
                                          and Printer Towel/Rag Production2
Pollutant Grouping
Industry Pollutant Removal
Estimated for Proposal3
(1993 Ibs/yr)
Industry Pollutant
Removal Estimated Based
on UTSA/TRSA Survey4
(1998 Ibs/yr)
Percent Decrease in
Industry Pollutant
Removal
CP-IL
Total Bulk Conventionals
Total Bulk Nonconventionals
Total Bulk Parameters
Total Priority Organics
Total Nonconventional Organics
Total Organics
Total Priority Metals and Elements
Total Nonconventional Metals and Elements
Total Metals and Elements
Total Pollutants
57,702,653
98,227,707
155,930,360
210,212
754,444
964,656
272,883
703,067
975,950
157,870,966
42,466,234
64,012,182
106,478,416
172,624
534,573
707,197
217,645
712,265
929,910
108,115,523
26%
35%
32%
18%
29%
27%
20%
(1%)
5%
32%
DAF-IL
Total Bulk Conventionals
Total Bulk Nonconventionals
Total Bulk Parameters
Total Priority Organics
Total Nonconventional Organics
Total Organics
59,446,266
103,854,831
163,301,097
221,062
845,004
1,066,066
43,743,855
66,935,920
110,679,775
139,853
604,197
744,050
26%
36%
32%
37%
28%
30%

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                                                                                                                 Chapter 9 - Pollutant Loading and Removal Estimates
                                                               Table 9-18 (Continued)
Pollutant Grouping
Total Priority Metals and Elements
Total Nonconventional Metals and Elements
Total Metals and Elements
Total Pollutants
Industry Pollutant Removal
Estimated for Proposal3
(1993 Ibs/yr)
183,359
732,951
916,310
165,283,473
Industry Pollutant
Removal Estimated Based
on UTSA/TRSA Survey4
(1998 Ibs/yr)
134,461
726,346
860,807
112,284,632
Percent Decrease in
Industry Pollutant
Removal
27%
1%
6%
32%
          'Numbers in this table were calculated using more significant figures than shown.
          2136 of the 1,742 total industrial laundries are excluded from compliance under this criterion.
          3The removals estimated for proposal i
          1993 operating year.
'. FR 66181; December 17,1997) are based on treatment-in-place information from the detailed questionnaire for the
VO
          4The removals were estimated based on treatment-in-place information in the UTSA/TRSA survey for the 1998 operating year (presented in the Notice of Data
          Availability, 63 FR 71054; December 23, 1998).

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                                                      Chapter 10 - Non-Water Quality Environmental Impacts

                                     CHAPTER 10

               NON-WATER QUALITY ENVIRONMENTAL IMPACTS

10.1         Introduction

             As required by Sections 304(b) and 306 of the Clean Water Act, EPA considered
the non-water quality environmental impacts that would be associated with the implementation of
the regulatory options considered as the bases for Pretreatment Standards for Existing Sources
(PSES) and Pretreatment Standards for New Sources (PSNS) for the Industrial Laundries Point
Source Category. Non-water quality environmental impacts are impacts of the regulatory options
on the environment that are not directly associated with wastewater. Specifically, EPA evaluated
the potential effect of the chemical precipitation of industrial laundry wastewater
(CP-IL) and dissolved air flotation of industrial laundry wastewater (DAF-IL) options on energy
consumption, air emissions, and generation of solid wastes (oil and sludge). EPA also considered
the impacts of the CP-IL and DAF-IL options  on water usage and chemical usage. EPA has
determined that changes in water usage and chemical usage from the CP-IL and DAF-IL options
would be acceptable.

             Section 10.2 of this chapter presents the non-water quality environmental impacts
of the CP-IL and DAF-IL regulatory options and the methodology used by EPA to evaluate
impacts on energy consumption, air emissions, and solid waste generation. Section  10.3 presents
the references used.

10.2         Non-Water Quality Environmental Impacts of the CP-IL and DAF-IL
             Options Considered as the Bases for PSES and PSNS

             EPA evaluated the non-water quality environmental impacts that would be
associated with implementation of the CP-IL and DAF-IL options considered as the bases for
PSES and PSNS for the Industrial Laundries Point Source Category. These options are described
in Chapter 8 of this document.  Specifically, the following information is presented in this chapter:

             •      Section 10.2.1 presents  the energy consumption impacts that  would be
                    associated with PSES;

             •      Section 10.2.2 presents  the air emission impacts that would be associated
                    with PSES;

             •      Section 10.2.3 presents  the solid waste impacts that would be associated
                    with PSES; and

             •      Section 10.2.4 presents  the non-water quality environmental impacts that
                    would be associated with PSNS.
                                          10-1

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                                                        Chapter 10 - Non-Water Quality Environmental Impacts

10.2.1        Energy Consumption Impacts

              EPA estimates that implementation of a rule would have resulted in a net increase
in energy consumption for the industrial laundries industry. The incremental increase is based on
electricity used to operate wastewater treatment equipment at facilities that are not currently
operating wastewater treatment equipment comparable to the regulatory options.

              To calculate incremental energy consumption increases for the industrial laundries
industry, EPA examined the wastewater treatment in place at the industrial laundries that would
be covered by a regulation.  EPA used the industrial laundries cost model, described in Chapter 11
of this document, to calculate the energy that would be required to operate wastewater treatment
equipment that would be installed to comply with the regulatory options.  EPA used the
information provided in the 1994 Industrial Laundries Industry Questionnaire (detailed
questionnaire) for the  1993 operating year to determine if a facility would have to install new
equipment. If a facility reported operating a treatment system that was not comparable to the
regulatory options, EPA estimated the facility's energy consumption for the reported system and
subtracted this consumption from the energy requirements of the regulatory options. Facilities
that did not report operating a treatment system comparable to the regulatory options received an
incremental energy consumption amount equivalent to the amount estimated for each regulatory
option.

              EPA extrapolated the energy consumption increases to represent the entire
industrial laundries industry using the survey weights.  Table 10-1 presents the total incremental
energy increase and the average incremental energy increase per facility for the 1,742 existing in-
scope industrial laundries.  Table 10-1 also presents the percentage of total industry energy use
and the percentage of the national  energy requirements represented by the incremental increase
for each regulatory option. Based on a 1996 survey of industrial laundries conducted by the
industry, industrial laundries use approximately 31.2 trillion BTUs per year, or 9.1 billion kilowatt
hours per year. Approximately 2,805 billion kilowatt hours of electric power were generated in
the United States in 1990 (1).

              EPA estimates that the incremental energy consumption increases from the CP-IL
and DAF-IL options would be  a small percentage of the electricity currently used by the industrial
laundries industry to operate all washing, drying, and treatment equipment.  Based on this
analysis, EPA believes that the energy impacts from these regulatory options would have been
acceptable. In addition, industrial laundries can offset the energy impacts of installing additional
wastewater treatment equipment by reusing treated hot or warm water.  This practice results in
energy savings in hot water generation.  The use of heat reclaimers at industrial laundries for
energy conservation is discussed in Chapter 6 of this document.
                                           10-2

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                                                             Chapter 10 - Non-Water Quality Environmental Impacts
                                           Table 10-1
 Incremental Energy Consumption Increases Associated With Implementation
                    of the CP-IL and DAF-IL Regulatory Options
PSES Regulatory
Option1
CP-IL
DAF-IL
Incremental Energy Increases2
Total Industry
Increase (million
kilowatt hours)
69.5
82.8
Average Increase
Per Facility
(kilowatt hours)
39,900
47,500
Percentage of Total
Industry Use3
0.76%
0.91%
Percentage of
National Energy
Requirements4
0.0025%
0.0030%
'Regulatory options are presented in Chapter 8 of this document.
Incremental energy increases are based on 1,742 in-scope industrial laundries. This is a conservative estimate since
fewer facilities would have been covered under regulatory options with exclusions (e.g., 1,224 facilities under the
3 Million/120 K exclusion).  Chapter 8 of this document discusses the exclusions considered for the regulatory options.
3The industrial laundries industry energy use is approximately 9.1 billion kilowatt hours per year, as reported by the
industrial laundries trade associations.
4Approximately 2,805 billion kilowatt hours of electric power were generated in the United States in 1990 (1).
                                               10-2

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                                                       Chapter 10 - Non-Water Quality Environmental Impacts

10.2.2        Air Emissions Impacts

              Industrial laundry facilities generate wastewater that contains organic compounds,
some of which are on the list of Hazardous Air Pollutants (HAPs) in Title 3 of the Clean Air Act
Amendments (CAAA) of 1990.  Atmospheric exposure of the organic-containing wastewater may
result in volatilization of HAPs, including volatile organic compounds (VOCs). HAPs, including
VOCs, are emitted from the wastewater beginning at the point where the wastewater first
contacts ambient air.  Thus, HAPs, including VOCs, may be emitted prior to and during the cycle
and immediately after the washing when the wastewater is discharged from the process unit. Air
pollutants are also emitted from wastewater collection units such as process drains, manholes,
trenches, and sumps, and from wastewater treatment units such as screens, equalization basins,
DAF and chemical precipitation units, and any other units where the wastewater is in contact with
the air.

              EPA believes that emission of air pollutants from industrial laundry wastewater
would have been similar before and after implementation of a rule based on DAF or chemical
precipitation technologies because the wastewater from all industrial laundries currently has
contact with ambient air as it flows to the publicly owned treatment works (POTW). At facilities
that do not currently have treatment on site, the wastewater typically flows from the washers to
an open or partially open catch basin, then to the sewer and on to the POTW, where the
wastewater is typically treated in open aerated basins or lagoons. Emission of air pollutants from
the wastewater occur as the wastewater flows from the facility to the POTW. At a facility with
treatment, the wastewater would have more contact with air while still at the facility, as it is
treated in open units such as equalization basins and DAF or chemical precipitation units prior to
flowing through the sewer to the POTW. Air emissions from the treated wastewater occur at the
treatment units at the facility, as well as while the wastewater flows to the POTW. Thus, EPA
expects that the location of a portion of air emissions from industrial laundry wastewater would
shift from the POTW collection and treatment system to the facility treatment system, but can not
determine whether the overall amount of air emissions from industrial laundry wastewater would
not change. However, EPA believes that the overall amount may decrease slightly with DAF or
chemical precipitation treatment at facilities, since some VOCs and HAPs will partition to the oil
fraction or chemical solids removed from the wastewater prior to discharge.

              EPA examined the total air emissions from one industrial laundry's untreated
wastewater stream assuming all volatile pollutants volatilize from that stream.  As a worst-case
analysis, EPA considered whether this total amount of air emissions would be acceptable
assuming it represented incremental air emissions due to implementation of a rule. (EPA does not
believe that the total amount of air emissions, as calculated below, represent incremental air
emissions since EPA can not determine that there would be any difference before and after
implementation of a rule.) EPA's methodology for estimating fugitive air emissions is described
below.

              EPA collected and analyzed wastewater samples at seven industrial laundries
operating treatment systems that effectively treated industrial laundry wastewater; four of these
treatment systems are the bases of the DAF-IL and CP-IL options.  At all facilities, total raw
wastewater samples were collected. EPA selected the facility with the highest raw wastewater

                                           10-4

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                                                        Chapter 10 - Non-Water Quality Environmental Impacts

loading of organic pollutants to represent a worst-case scenario.  EPA also assumed that all of the
organic pollutants in the raw wastewater would volatilize during treatment.  EPA believes that
this represents a worst-case scenario for the regulatory options because not all of the organic
pollutants present in the wastewater are volatile, and those that are volatile would not volatilize
completely because they are at least somewhat soluble in water.  Based on this methodology, the
fugitive air emissions calculated by EPA are much higher than would actually occur at an
industrial laundry employing wastewater treatment.

              EPA used the following formula to calculate annual fugitive emissions of organic
pollutants:

                                                                     1  Mg
              year
                                                                         9
10mg
where:
              Y = megagrams of organic pollutant volatilized per year (Mg/year)
              X = average concentration of the organic pollutant in the wastewater (mg/L)
              F = average daily wastewater flow rate (gallons/day)
              N = average days of operation per year (days/year).

Fugitive emissions were calculated for all volatile and semivolatile organic pollutants of concern.
If a pollutant was not detected in the raw wastewater sample, EPA used the detection limit
concentration to calculate the fugitive air emissions for that pollutant.  Using the average daily
flow (203,000 gallons per day), average raw wastewater pollutant concentration, and average
days of operation (261 days per year), EPA calculated the fugitive air emission levels presented in
Table 10-2.  Based on summing the fugitive emissions for each individual HAP, the total annual
HAP emissions from this industrial laundry under a worst case analysis would be 14 Mg/year.
The total annual emissions for all organics would be 92 Mg/year.  The total annual emissions
would be 19 Mg/year for volatile organics and 72 Mg/year for semivolatile organics.

              EPA estimated the total pounds of carbon dioxide (CO2)  emissions per year based
on the incremental energy use to range from 28 million pounds of CO2 per year (16,000 pounds
per year per facility) for the CP-IL option and 33 million pounds of CO2 per year (19,100 pounds
per year per facility) for the DAF-IL option (2).  The increased air emissions would be
proportional to the increased energy use. As the increase in energy use reflects only a small
percentage of the industry's total energy use, these increased emissions are only a small
percentage of the emissions from the industry's total energy use. Based  on this analysis, EPA
believes that the incremental air emissions from the CP-IL and DAF-IL options would have been
acceptable.  Although emissions from greenhouse gases other than CO2 result from the burning of
natural gas to produce energy, CO2 is believed to be the most significant in terms of the total
emission quantity. In addition, the burning of natural gas releases other types of pollutants, such
as criteria pollutants and HAPs. Energy produced from the burning of fuels other than natural gas
would produce varying quantities of these types  of emissions.
                                           10-5

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                                             Chapter 10 - Non-Water Quality Environmental Impacts
                              Table 10-2

Fugitive Air Emissions of Organic Pollutants From Industrial Laundry
           Wastewater—Analysis of a Worst-Case Scenario
Organic Air Pollutant
Hazardous Air
Pollutant?
Raw Wastewater
Concentration
(mg/L)
Amount Volatilized
(Mg/year)
Volatile Organics
1 , 1 -Dichloroethane
1,1,1 -Trichloroethane
1,4-Dioxane
2-Butanone
2-Chloroethylvinyl Ether
2-Propanone
4-Methyl-2-pentanone
Chlorobenzene
Ethylbenzene
w-Xylene
Methylene Chloride
o-&p-Xy\ene
Tetrachloroethene
Toluene
trans- 1 ,2-Dichloroethene
Trichloroethene
Trichlorofluoromethane
Y
N
Y
N
N
N
N
Y
Y
Y
Y
Y
N
Y
N
N
N
0.14
0.42
2.59
0.73
1.30
35.79
1.66
0.65
2.40
14.27
1.55
6.36
15.55
13.17
0.04
0.04
0.04
Subtotal for Volatile Organics
0.03
0.08
0.52
0.15
0.26
7.18
0.33
0.13
0.48
2.86
0.31
1.28
3.12
2.64
0.01
0.01
0.01
19.40
Semivolatile Organics
1 ,2-Diphenylhydrazine
2, 3 ,6-Trichlorophenol
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
2,4-Dichlorophenol
2,4-Dimethylphenol
2,4-Dinitrophenol
2-Chlorophenol
2-Methylnapthalene
2-Nitrophenol
4-Chloro-3-methylphenol
Y
N
Y
Y
N
N
Y
N
N
N
N
0.20
0.10
0.10
0.10
0.10
0.10
0.50
0.10
0.10
0.20
0.16
0.04
0.02
0.02
0.02
0.02
0.02
0.10
0.02
0.02
0.04
0.03
                                 10-6

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                         Chapter 10 - Non-Water Quality Environmental Impacts
Table 10-2 (Continued)
Organic Air Pollutant
Hazardous Air
Pollutant?
Raw Wastewater
Concentration
(mg/L)
Amount Volatilized
(Mg/year)
Semivolatile Organics (Continued)
4-Nitrophenol
ซ-Terpineol
Benzoic Acid
Benzyl Alcohol
Bis(2-ethylhexyl) Phthalate
Bromodichloromethane
Butyl Benzyl Phthalate
Diethyl Phthalate
Dimethyl Phthalate
Di-w-butyl Phthalate
Di-w-octyl Phthalate
Hexanoic Acid
Isophorone
Naphthalene
w-Decane
w-Docosane
w-Dodecane
w-Eicosane
w-Hexacosane
w-Hexadecane
w-Nitrosomorpholine
w-Octadecane
w-Tetracosane
w-Tetradecane
/>-Cymene
Pentachlorophenol
Pentamethy Ibenzene
Phenol
Phenol, 2-Methyl-4, 6-Dinitro
Styrene
Y
N
N
N
Y
N
N
N
Y
N
N
N
Y
Y
N
N
N
N
N
N
Y
N
N
N
N
Y
N
Y
N
Y
0.50
0.10
0.66
0.10
19.11
0.04
0.48
0.10
0.10
1.23
0.10
0.10
0.10
6.43
277.97
1.74
11.13
5.13
1.19
13.47
0.10
4.73
4.14
11.88
0.19
0.50
0.84
0.10
0.20
0.17
Subtotal for Semivolatile Organics
Total for Volatile and Semivolatile HAPs
Total for All Volatiles and Semivolatiles
0.10
0.02
0.13
0.02
3.83
0.01
0.10
0.02
0.02
0.25
0.02
0.02
0.02
1.29
55.74
0.35
2.23
1.03
0.24
2.70
0.02
0.95
0.83
2.38
0.04
0.10
0.17
0.02
0.04
0.03
73.07
13.86
92.47
            10-7

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                                                       Chapter 10 - Non-Water Quality Environmental Impacts

10.2.3        Solid Waste Impacts

              EPA considered regulatory options based on DAF and chemical precipitation
technologies followed by dewatering of the sludge generated from these technologies. Based on
information collected in the industrial laundries detailed questionnaire and from data submitted in
comments, most industrial laundry sludge from chemical precipitation or DAF treatment systems
is disposed in nonhazardous landfills. EPA estimated the incremental sludge generation from the
CP-IL and DAF-IL options in a manner similar to estimating the energy consumption incremental
amounts.  EPA estimated that sludge generation would not increase at facilities that reported
currently operating a treatment system comparable to the regulatory options. EPA used the cost
model to estimate the incremental sludge generation rates for facilities not currently operating
wastewater treatment and for facilities operating wastewater treatment not comparable to the
regulatory options.

              EPA calculated the volume of sludge that would be generated by the 1,742 in-
scope industrial laundries after implementation of the CP-IL and DAF-IL options. Table 10-3
presents the incremental increase in sludge generation (in wet sludge and dry solids) from all
existing in-scope industrial laundries. Table 10-3 also presents the average incremental increase
per industrial laundry and the percentage of the national volume of nonhazardous waste sent to
landfills represented by the incremental increase for each regulatory option.  Approximately 430
million tons (dry basis) of industrial nonhazardous waste was sent to landfills in the United States
in 1990 (3). EPA notes that this volume would be offset somewhat by reducing the volume
generated by POTWs. Based on this analysis, EPA believes the solid waste impacts of all of the
regulatory options under consideration would have been acceptable.

10.2.4        Non-Water Quality Environmental Impacts of the Regulatory Options
              Considered for PSNS

              EPA considered the non-water quality environmental impacts associated with the
implementation of the CP-IL and DAF-IL regulatory options, which were considered for PSNS
for the Industrial Laundries Point Source Category.  Over a three-year period (1991, 1992, and
1993), according to the detailed questionnaire, only about 80 new laundry facilities began
operation (and it is not absolutely clear from the data whether these facilities were new
dischargers or were existing dischargers acquired in that year by a different firm). Given the small
level of growth in the industrial laundries industry, EPA believes that new sources are primarily
replacing production from closing facilities that exit the market.  With respect to  any new sources
that start in the future, the non-water quality environmental impacts of compliance with a rule
would not be any greater than those for existing sources. Therefore, EPA has determined that the
non-water quality environmental impacts associated with the implementation of the regulatory
options considered for PSNS would have been negligible.
                                           10-8

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                                                                                                     Chapter 10 - Non-Water Quality Environmental Impacts
                                                              Table 10-3
                  Incremental Sludge Generation Increases Associated With Implementation of the
                                            CP-IL and DAF-IL Regulatory Options
PSES Regulatory
Option Considered for
Proposal1
CP-IL
DAF-IL
Incremental Sludge Generation Increases2
Total Industry
Increase
(Tons of Dewatered
Sludge)
173,000
128,000
Total Industry
Increase
(Tons of Dry Solids)3
60,600
70,600
Average Facility
Increase
(Tons of Dewatered
Sludge)
99.5
73.7
Average Facility
Increase
(Tons of Dry Solids)3
34.8
40.6
Percentage of National
Volume of Waste
Disposed to
Nonhazardous
Industrial Landfills4
0.014%
0.016%
'Regulatory options are presented in Chapter 8 of this document.
Incremental sludge generation increases are based on 1,742 industrial laundries in-scope industrial laundries.  This is a conservative estimate since fewer facilities
would have been covered under regulatory options with exclusions (e.g., 1,224 facilities under the 1 Million/255 K exclusion).  Chapter 8 of this document discusses
the exclusions considered for the regulatory options.
Industrial laundries responding to the detailed questionnaire that currently treat their wastewater through DAF or chemical precipitation reported an average solids
content of their dewatered sludge of 55% and 35%, respectively.
4Approximately 430 million tons (dry basis) of industrial nonhazardous waste was sent to landfills in the United States in 1990 (3).

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                                                        Chapter 10 - Non-Water Quality Environmental Impacts
10.3          References

1.             Steam. Its Generation and Uses. 4th Edition, Bab cock & Wilcox, Ed Stutz &
              Kitto, Barberton, Ohio. 1992.

2.             U.S. Environmental Protection Agency. AP-42, Fifth Edition, Volume 1, 1998.

3.             U.S. Environmental Protection Agency. Subtitle D Study Phase I. EPA 530-SW-
              86-054. Washington, DC, 1986.
                                          10-10

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                                                   Chapter 11 - Costs of Technology Bases for Regulatory Options

                                      CHAPTER 11

          COSTS OF TECHNOLOGY BASES FOR REGULATORY OPTIONS

11.1          Introduction

              This chapter describes the methodology used to estimate the costs to implement
each of the regulatory options considered for the final action for the Industrial Laundries Point
Source Category.  Chapters 6 and 8 of this document describe in detail the technologies used as
the bases for the regulatory options considered. The cost estimates provide a basis for
determining the economic impact of implementing the options on the industry.  The results from
assessing the economic impact of the regulatory options are found in the Economic Assessment
(EA) for the industrial laundries final action (1).  The cost estimates, together with the pollutant
reduction estimates described in Chapter 9 of this document, also provide a basis for evaluating
the cost-effectiveness of the options.

              EPA used the following approach in estimating compliance costs for the industrial
laundries industry:

              •      EPA mailed the 1994 Industrial Laundries Industry Questionnaire (detailed
                    questionnaire) to a statistically selected sample of industrial laundries
                    (discussed in Chapter 3 of this document).  The information provided for
                    the 1993 operating year from the 190 in-scope facilities that responded was
                    used to determine baseline wastewater treatment system design and
                    operating status.  The in-scope facilities are those that launder industrial
                    textile items from off site as a business activity, as discussed in Chapter 4
                    of this document.

              •      EPA identified candidate end-of-pipe wastewater treatment technologies
                    and grouped appropriate technologies into technology control options
                    (discussed in Chapters 6 and 8 of this document).

              •      EPA analyzed data collected from industry to determine untreated
                    wastewater pollutant concentrations and pollutant removal performance of
                    the technology control options (discussed in Chapter 9 of this document).

              •      EPA developed cost equations for capital and operating and maintenance
                    (O&M) costs for each of the technologies included in the technology
                    control options based on information gathered from industrial laundry
                    facilities,  wastewater treatment system vendors, and engineering judgement
                    (discussed in this chapter).

              •      EPA developed and used a computerized design and cost model, the
                    Industrial Laundries Design and Cost Model (cost model), to calculate
                                           11-1

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                                                    Chapter 11 - Costs of Technology Bases for Regulatory Options

                     capital and annual compliance costs (presented in this chapter) and
                     pollutant loadings (presented in Chapter 9 of this document) for each
                     technology control option for each facility.

              •      EPA used output from the cost model to calculate total annualized costs in
                     1993 dollars for each facility for each regulatory  option (presented in the
                     EA).

              •      EPA compared each facility's annualized cost for each regulatory option to
                     the annualized cost for the facility to contract for off-site wastewater
                     treatment (presented in this chapter).  If the cost for off-site treatment was
                     less than the cost to install and operate an on-site treatment system, the off-
                     site treatment cost was used as the facility's cost for compliance.

              •      EPA used the annualized costs and the pollutant loadings calculated by the
                     cost model to calculate cost-effectiveness and the economic impact of each
                     regulatory option on the industry (presented in the EA).

              EPA estimated compliance costs for all technology control options presented in
Chapter 8 of this document.  These cost estimates may be found in the Industrial Laundries
Administrative Record.  This chapter presents the methodology, assumptions, and cost estimates
for the two regulatory options, DAF-IL and CP-IL. EPA estimated industry-wide costs by
estimating compliance costs for the 190 in-scope facilities to purchase, install, and operate each of
the options.  Using statistically calculated facility weighting factors, EPA then extrapolated the
results to the entire industrial  laundries industry (1,742 industrial laundries). EPA also estimated
industry-wide  costs for three exclusions (discussed in Chapter 8 of this document) for each of the
two regulatory options.

              The following information is discussed in this section:

              •      Section 11.2 discusses the costing methodology;

              •      Section 11.3 discusses cost modeling and summarizes cost estimating
                     assumptions and design bases for the technologies that comprise the
                     regulatory options;

              •      Section 11.4 presents the cost estimates for each regulatory option;

              •      Section 11.5 presents the cost estimates for each regulatory option
                     estimated from updated wastewater treatment information provided in a
                     1998 survey conducted by the industrial laundries trade associations; and

              •      Section 11.6 presents the references used in this chapter.
                                            11-2

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                                                    Chapter 11 - Costs of Technology Bases for Regulatory Options

11.2          Costing Methodology

              To determine the impact of pretreatment standards on the industrial laundries
industry, EPA estimated costs associated with regulatory compliance.  A computerized cost
model was developed to estimate compliance costs for each of the regulatory options. EPA used
the cost model to estimate costs for the treatment technologies used as the bases for the
calculated limitations of each regulatory option.  Although the estimated compliance costs were
developed based on implementation of these treatment technologies, EPA emphasizes that a
regulation would not require that a facility operate these technologies, but only that the
appropriate facility effluent standards be met.

              EPA selected a facility-by-facility model approach to develop the compliance costs
as opposed to a more general modeling approach, because of the variability of processes and
resultant wastewaters among industrial laundries. EPA used facility information available from
responses to the detailed questionnaire to  characterize the wastewater and assess existing
treatment technologies at each facility. EPA did not include information from facilities that did
not provide sufficient technical and/or economic data to be adequately characterized as to their
current operations and/or economic status, respectively.  For the purposes  of the cost model, a
facility was excluded if EPA did not have information on its flow, production, and/or wastewater
treatment activities.

              In other cases when more specific information was not available, EPA made
engineering assumptions regarding facility operations, or used industry average data and various
wastewater treatment equipment vendor and consultant information. Thus, for any given facility,
the costs estimated may deviate from those that the facility would actually incur. However,
because EPA based these assumptions on  industry-wide data, the resulting estimates are
considered accurate when evaluated on an industry-wide, aggregate basis.

              As discussed in Chapter 8 of this document, EPA identified the following
regulatory options:

              •      DAF-IL Option - Dissolved air flotation (DAF) treatment of wastewater
                     generated from the  washing of industrial textile items only; the cost model
                     uses target average concentrations calculated from data obtained from the
                     industry for DAF treatment of a facility's total process wastewater stream
                     to calculate pollutant removals for the DAF-IL option.

              •      CP-IL Option - Chemical precipitation treatment of wastewater generated
                     from the washing of industrial textile items only; the cost model uses target
                     average concentrations calculated from data obtained from the industry  for
                     chemical precipitation treatment of a facility's total process wastewater
                     stream to calculate  pollutant removals for the CP-IL option.

              Also as discussed in Chapter 8 of this document, EPA identified three exclusions
for each of the technology options:

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                                                   Chapter 11 - Costs of Technology Bases for Regulatory Options

              •       1 Million/255 K—Facilities processing less than 1,000,000 pounds of
                     incoming laundry and less than 255,000 pounds of industrial towels
                     annually are excluded;

              •       3 Million/120 K—Facilities processing less than 3,000,000 pounds of
                     incoming laundry and less than 120,000 pounds of industrial towels
                     annually are excluded (this exclusion also excludes all facilities excluded
                     under the 1 Million/255 K exclusion, above); and

              •       5 Million/255 K—Facilities processing less than 5,000,000 pounds of
                     incoming laundry and less than 255,000 pounds of industrial towels
                     annually are excluded.

11.2.1        Cost Model Development and Structure

              EPA evaluated the following three existing cost models from other EPA effluent
guidelines development efforts to be used as the basis for the industrial laundries cost model:

              •       Metal Products and Machinery (MP&M) Phase I Industries Design and
                     Cost Model;

              •       Pharmaceuticals Industry Cost Model; and

              •       Pesticides Formulating, Packaging, and Repackaging Industry (PFPR) Cost
                     Model.

              The MP&M and pharmaceuticals cost models were programmed in FoxProฎ.
These cost models have treatment technology "modules" designed to calculate the cost of each
individual treatment technology. The individual modules are tied together with the cost model
"driver," the main program that accesses input data, runs the modules in the appropriate order for
each regulatory option, and tracks intermediate and output data. The PFPR cost model was
programmed in a spreadsheet, but also designed with individual modules. Because FoxProฎ
provided a more flexible platform than a spreadsheet on which to build the cost model and
because the data for the industrial laundries project were already stored in FoxProฎ files, EPA
decided to use FoxProฎ for the industrial laundries cost model.

              The industrial laundries cost model driver was based on the MP&M cost model
driver. The major advantage of the MP&M cost model driver over the pharmaceuticals cost
model driver is its ability to calculate the baseline pollutant loads and the postcompliance pollutant
loads along with the costs for regulatory options. The pharmaceuticals cost model driver was not
programmed to calculate pollutant loads.

              EPA adapted the MP&M cost model driver for the industrial laundries cost
estimation effort with one major modification: any value calculated by the cost model is stored in
an output file.  This allows the user of the cost model to examine the significance of each
calculated value in the cost calculated for each technology module.

                                          11-4

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                                                    Chapter 1 1 - Costs of Technology Bases for Regulatory Options

              The inputs to the industrial laundries cost model include untreated wastewater
pollutant concentrations, flow rates, operating schedules, and treatment technologies currently in
place for each facility costed. EPA obtained facility information on the flow rates, operating
schedules, and treatment technologies in place for the 1993 operating year from the detailed
questionnaire response for each facility.  As described previously, facilities that did not report
flow, production, and/or treatment technology information were not included in the cost
estimation effort. If facilities did not report operating days per year or hours per day, facility
average data were used. EPA calculated the untreated wastewater pollutant concentrations for
each facility costed using wastewater characterization data obtained from the industry and each
facility's production data provided in the detailed questionnaire, as described in  Chapter 9 of this
document.  The input information for the cost model was maintained in database files.  Section
11.3 of this document discusses the cost model and its operation in more detail.

11.2.2         Components of the Cost of Compliance

              EPA adjusted all costs calculated by the cost model to 1993 dollars because all
facility-specific information in the detailed questionnaire database is from the 1993 operating year.
This adjustment allows direct comparison between financial data reported in the detailed
questionnaire and calculated compliance costs for each facility.  Costs were adjusted using the
Chemical Engineering (CE) Plant Cost 1993 annual index value of 359.2 (2) and the index value
for the year in which the costs were originally reported in the following formula:


                                   AC =
                                                 oci;

where:

              AC    =      Adjusted cost, 1993 dollars
              OC    =      Original cost, dollars
              OCI   =      Original cost year index.

              EPA used the cost model to calculate capital and annual operating and
maintenance (O&M) costs for each technology included in the regulatory option and to sum the
capital and annual O&M costs for all technologies in the option at each facility.

              Capital costs comprise direct and indirect costs associated with the purchase and
installation of wastewater treatment equipment. Primary sources of the capital costs were vendor
information and literature references. Table 11-1 presents the unit capital costs used by the cost
model and includes references for the origin of each cost.  Typically, direct capital costs include
the following:

              •      Purchase of treatment equipment and any accessories;

              •      Purchase of treatment equipment instrumentation (e.g., controllers);

              •      Installation costs (e.g., labor and rental fees  for equipment such as cranes);

                                            11-5

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                             Chapter 11 - Costs of Technology Bases for Regulatory Options
                 Table 11-1
Capital Unit Costs Used by the Cost Model
Capital Costs (includes crane rental)
Item
Air-operated sludge pump
(4 to 60 gpm)
Batch chemical precipitation
treatment units
(100 to 2,500 gallons)
Building
C-Clamp-mounted agitators
(0.25 to 2 hp)
Centrifugal wastewater
transfer pumps
(> 27 gpm)
Chemical feed system (0.01
to 3,200 Ib/hr)
Continuous chemical
precipitation treatment units
(2 to 150 gpm)
Continuous DAF treatment
units
(25 to 1,000 gpm)1
Covered and flanged
fiberglass tanks (1 10 to
50,000 gallons)
Covered and flanged
fiberglass tanks (1 10 to
50,000 gallons)
Equipment and labor required
for washer modification for
split stream capability
Filter press
(5 to 125 ft3)
Flange -mounted agitators
(0.25 to 5 hp)
Installation labor rate
Cost (1993 $s)
Cost = 571.91 + 37.161 x C - 0.18842 x C2 per
pump
(C = Capacity in gpm)
Cost = 23,773 + 19.963 x V - (2.8223 x 10'3)
x V2 per unit
(V = batch size in gallons)
$40.32 per square foot
Cost = 3,168.998 + 2965.1 15 x log(P)
per agitator
(P = power requirement in hp)
Cost = 2,758.989 x loglo (C) - 2,185.941
per pump
(C = capacity in gpm)
Cost = 12,421 + 38. 142 x C - (3.8125 x 10'3) x
C2 per unit
(C = Capacity in Ibs/gal)
Cost = 47,192 + 1,129.6 x C - (1.3255 x C2)
per unit
(C = capacity in gpm)
Cost =111, 370 xloglo(C)- 139,260
per unit
(C = capacity in gpm)
Cost = 2,839.2 + 0.9004 xV
per tank
(V = volume in gallons)
Cost = 2,927.1 + 0.9182 xV
per tank
(V = volume in gallons)
$4,096.61 to $7,599.37 per washer
Cost = 33,331 xln(C)- 36,195
per press
(C = capacity in ft3)
Cost = 4,247.414 + 2,616.527 x loglo (P)
per agitator
(P = power requirement in hp)
$25. 27 per hour
Module(s)
Pump
Chemical
Precipitation
Building
pH Adjustment
Pump
DAF,
pH Adjustment
Chemical
Precipitation
DAF
Contract Haul
Equalization
Stream Splitting
Sludge Dewatering
Equalization, pH
Adjustment
All
Reference
(8)
(16)
(20)
(19)
(8)
(14, 19)
(16)
(14)
(22)
(11)
(7)
(17)
(11,19)
(3)
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                                                            Chapter 11 - Costs of Technology Bases for Regulatory Options

                                     Table 11-1 (Continued)
Capital Costs (includes crane rental)
Item
Open polyethylene tank
(55 to 6,400 gallons)
pH controller
Positive displacement
wastewater transfer pumps
(<3 to 27 gpm)
PVC piping for stream
segregation retrofit2
Shaker screen unit
(48-inch and 60-inch units)
Cost (1993 $s)
Cost = 362.48 + 1.5907 x V - (1.0583 x 10'4)
x V2 per tank
(V = Volume in gallons)
$1,554.77 per controller
$839.38 to $2,130.04 per pump
$27. 08 per foot
$8, 13 1.76 to $9,542.93 per unit
Module(s)
Screen,
pH Adjustment
pH Adjustment
Pump
Stream Splitting
Screen
Reference
(9, 19)
(19)
(8)
(7)
(9)
Optimization Cost Allowance
Item/Activity
Increased equalization
capacity
Training and consulting
Cost (1993 $s)
$3,693 to $23,558
$4,800
Module(s)
—
—
Reference
(6)
(6)
'The same DAF unit (750 gpm) will be costed for capacities ranging within 750 to 1,000 gpm, as this size unit is
capable of treating up to 1,000 gpm of wastewater flow.
2An additional $500 per facility was allowed to account for any necessary elbow joints or other connections.

DAF - Dissolved air flotation.
                                                  11-7

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                                                     Chapter 11 - Costs of Technology Bases for Regulatory Options
              •      Construction of buildings or other structures to house major treatment
                     units (e.g., foundation slab, enclosure, containment, lighting, and electricity
                     hook-ups); and

              •      Purchase of necessary pumps (e.g., for wastewater transfer, chemical
                     addition, sludge handling).

              EPA obtained the wage rate for all required labor to properly install the systems
associated with the technology bases from The Richardson Rapid System Process Plant
Construction Estimating Standards (3) as the average hourly rate for one installation worker. The
average rate in 1994 was $25.90 per hour.  This rate was scaled back to a 1993 rate of $25.27 per
hour using the CE Plant Cost indices.

              Indirect capital costs typically include the following:

              •      Purchase and installation of necessary piping to interconnect treatment
                     system units (e.g., pipe, pipe hangers, fittings, valves, insulation, similar
                     equipment);

              •      Purchase and installation of electrical equipment (e.g., switches, wire,
                     fittings, grounding, instrument and control wiring, lighting panels);

              •      Engineering costs (e.g., administrative, legal, process design and general
                     engineering, communications, consultant fees, travel, supervision, and
                     inspection  of treatment  equipment);

              •      Site maintenance (e.g., roads, walkways, fences, parking areas,
                     landscaping, site clearing);

              •      Contingency (e.g., compensation for unpredictable events such as foul
                     weather, price changes, small design changes, and errors in estimates); and

              •      Contractors' fees.

              For each technology, EPA accounted for each required indirect capital cost by
using a factor related to purchased and installed capital costs. The total capital investment is
obtained by multiplying the direct capital cost by the indirect capital cost factor.  Table 11-2
presents the components of the total capital investment, including the indirect capital cost factor
used by the cost model.
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                                                   Chapter 11 - Costs of Technology Bases for Regulatory Options
                                      Table 11-2
                     Components of Total Capital Investment
Number
1
2
3
4
5
6
7
8
9
Component
Equipment capital costs, including required
accessories, installation, delivery,
instrumentation, building, containment,
pumping
Piping
Electrical
Engineering/administrative/legal services
Total Plant Cost
Site Work
Contingency
Contractor's Fee
Total Capital Investment
Cost
Direct Capital Cost
10% of the Direct Capital Cost
2% of the Direct Capital Cost
10% of the Direct Capital Cost
1.22 x Direct Capital Cost
(Sum of Components 1 through 4)
1.5% of the Total Plant Cost
13% of the Total Plant Cost
5% of the Total Plant Cost
1.46 x Direct Capital Cost
(Sum of Components 5 through 8)
Source: Industrial Laundries Design and Cost Model.
                                          11-9

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                                                    Chapter 11 - Costs of Technology Bases for Regulatory Options

              Annual O&M costs comprise all costs related to operating and maintaining the
treatment system for a period of one year, including the estimated costs for compliance
monitoring of the effluent.  Table 11-3 presents the annual O&M unit costs used by the cost
model and includes references for the origin of each cost. Annual O&M costs include the
following:

              •      Chemical usage;

              •      O&M labor and materials;

              •      Removal, transportation, and disposal of any waste solids, sludges, oils, or
                     other waste products generated by the treatment system; and

              •      Utilities,  such as electricity, required to run the treatment system.

              Sources of annual O&M costs primarily included literature references and vendor
information.  Information from other EPA effluent guidelines development efforts and engineering
judgement were used in some instances when estimating O&M labor.

              At proposal, assumptions on the number of hours required of a worker to operate
a treatment system were made for each piece of equipment included in the treatment system for
each regulatory option.  EPA also assumed that an industrial laundry treatment system operator
received an equivalent rate of pay as an installation worker. However, based on comments
received and  industry-supplied data, EPA simplified how it estimated the  annual O&M labor costs
for each option.  Annual O&M labor costs were estimated to be equivalent to one full-time
operator paid at a rate of $13.77 per hour for each facility that did not report having treatment
(4).

              EPA obtained the cost for electricity used by various treatment technologies from
the Department of Energy's Monthly Energy Review (5).  The average cost of electricity for
industrial facilities for the year 1993 was $0.049 per kilowatt-hour.

11.2.3        Treatment-in-Place Credit Methodology

              EPA evaluated facility responses to the detailed questionnaire to determine which
treatment technologies were in place and in operation at each facility in the 1993 operating year.
Facilities were given credit for having operational treatment in place; these treatment credits were
used to develop  cost estimates for system upgrades instead of new systems where appropriate.
No compliance costs beyond necessary additional monitoring and an optimization cost allowance
(discussed in Section 11.2.4 of this document) were estimated for facilities that were determined
to have treatment equivalent to an option currently in use. EPA's methodology for crediting
facilities for existing treatment on site is discussed below.
                                           11-10

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                                      Chapter 11 - Costs of Technology Bases for Regulatory Options
                           Table 11-3
Operation and Maintenance Unit Costs Used by the Cost Model
Activities
Activity
Compliance monitoring lab fee
Contract hauling of bulk
wastewater
Monitoring fee for contract
hauled wastewater
Nonhazardous dewatered sludge
disposal
Treatment fee for contract hauled
wastewater
Cost (1993 $s)
$20,200 per year
$537 per full load (5,000 gallons bulk
liquid)
$200 per year
$2.12 per cubic foot
$0.35 per gallon
Module(s)
Compliance
Monitoring
Contract Haul
Contract Haul
Sludge Dewatering
Contract Haul
Reference
(22)
(21)
(21)
(17)
(21)
Chemicals
Chemical
Anionic polymer
Cationic polymer
Ferric chloride
Hydrated lime
Perlite
Quick lime
Sodium hydroxide (50%)
Sulfunc acid (93%)
Cost (1993 $s)
$2.48 per pound
$1.34 per pound
$0.49 per pound
$67. 50 per ton
$0.63 per pound
$45 per ton
$0.1 38 per pound
$75 per ton
Module(s)
DAF, Chemical
Precipitation
DAF, Chemical
Precipitation
DAF
Chemical Precipitation
DAF
Chemical Precipitation
pH Adjustment
DAF, pH Adjustment
Reference
(14, 16)
(14, 16)
(14)
(16)
(14)
(16)
(19)
(14, 19)
Equipment
Equipment
Agitator maintenance and
materials cost
Air-operated sludge pump
maintenance and materials cost
Building maintenance and
materials cost
Chemical feed system materials
maintenance and cost (0.01 to
3,200 Ib/hr)
Cost (1993 $s)
3% of the direct capital cost of agitator
per year
1% of the direct capital cost of pump
per year
3.5% of the direct capital cost of the
building per year
Cost per year = 20 1.99 + 0.1 329 x C-
(3 x 10'5) x C2
(C = Capacity in pounds per hour)
Module(s)
Equalization, pH
Adjustment
Pump
Building
DAF, pH Adjustment
Reference
(11,19)
(8)
(10,20)
(14, 19)
                              11-11

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                                                         Chapter 11 - Costs of Technology Bases for Regulatory Options



                                   Table 11-3 (Continued)
Equipment (Continued)
Equipment
Compliance monitoring materials
cost
Continuous/batch chemical
precipitation treatment unit
maintenance and materials cost
Continuous DAF treatment unit
maintenance and materials cost
Positive displacement or
centrifugal pump maintenance
and materials cost
Reaction tank maintenance and
materials cost
Replacement pH probe
Replacement plates for 48-inch
and 60-inch shaker screen units
Replacement porous collection
bags for shaker screen lint
Replacement screens for 48-inch
and 60-inch shaker screen units
Replacement sliders for 48-inch
and 60-inch shaker screen units
Storage tank maintenance and
materials cost
Wastewater storage tank
maintenance and materials cost
Cost (1993 $s)
$248. 83 per year
3% of the direct capital cost of the
chemical precipitation unit per year
1% of the direct capital cost of the
DAF unit per year
1% of the direct capital cost of pump
per year
3% of direct capital cost of tank per
year
$276.79 per probe
$410.22 to $608.25 per plate replaced
every two years
$200 per year
$174.46 to $257.45 per screen
replaced twice per year
$94.30 to $141.45 per screen
1% of direct capital cost of tank per
year
5% of direct capital cost of tank per
year
Module(s)
Compliance
Monitoring
Chemical Precipitation
DAF
Pump
Equalization,
pH Adjustment
pH Adjustment
Screen
Screen
Screen
Screen
Screen
Contract haul
Reference
(22)
(16)
(13,14)
(8)
(11,19)
(19)
(9)
(9)
(9)
(9)
(9)
(21)
Optimization Cost Allowance
Activity
Increased DAF chemical usage
Increased chemical precipitation
chemical usage
Increased sludge disposal
(Cost (1993 $s)
$406 to $15,5 19 per year
$5 18 to $14,070 per year
$150 to $4,881 per year
Module(s)
—
—
—
Reference
(6)
(6)
(6)
General Costs
Item
O&M labor rate
Electricity usage fee
(Cost (1993 $s)
$13. 77 per hour
$0.049 per kilowatt-hour
Module(s)
All
All
Reference
(4)
(5)
DAF - Dissolved air flotation.
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                               Chapter 11 - Costs of Technology Bases for Regulatory Options

Stream splitting - EPA gave stream-splitting credit to facilities that
indicated that a portion of their wastewater was segregated for treatment,
regardless of the specific method used to segregate the stream.

Mechanical fine screen (i.e.. a shaker or rotary screen) - EPA gave full
screen credit to facilities that had screens in place that treated at least a
portion of the facility's wastewater under the assumption that the screen
was adequate to treat a larger amount of wastewater for the purposes of
the IL options.

Adequate equalization  capacity - EPA gave facilities the following credits:
full credit for mixed tanks having a minimum residence time (two hours);
partial credit for unmixed tanks having at least the minimum residence time
(costs for agitators were added); no credit to facilities having tanks with
less than the minimum  residence time; and full credit for an agitator if
facilities indicated that they had one on site.

Key treatment units (I.e.. DAF. or chemical precipitation) - EPA  gave
facilities full option credit if they indicated that they had the respective key
treatment unit in place. EPA used  certain assumptions and specific criteria
to determine the presence of the key treatment units; Section 11.3 of this
document discusses these assumptions and  criteria further.

DAF  treatment unit (applicable to the CP-IL option) - EPA estimated a
salvage value for DAF  units currently in place at industrial laundries, based
on the reported age of the equipment and estimated capital cost.  EPA also
estimated the annual DAF O&M cost for each facility.  The salvage value
and annual cost for the DAF unit were then credited toward the capital and
annual costs, respectively, that were calculated for the chemical
precipitation unit as part of the costs for compliance under the CP-IL
regulatory option.

A lower indirect capital cost factor was also applied toward the installation
of the chemical precipitation unit at these facilities.  EPA assumed that
facilities that are replacing an existing piece of equipment would  not incur
some of the site preparation and auxiliary equipment (e.g., piping and
electrical hookups)  costs that are included in the indirect cost factor, as
described in Section 11.2.2 of this  document. Section 11.3 further
discusses this treatment-in-place cost estimate.  Table  11-4 presents the
modified components of the total capital investment for facilities  with DAF
treatment.
                      11-13

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                                           Chapter 11 - Costs of Technology Bases for Regulatory Options
                                Table 11-4

Components of Total Capital Investment Estimated for DAF Facilities in the
                         CP-IL Regulatory Option
Number
1
2
3
4
5
6
7
8
9
Component
Chemical precipitation equipment capital costs
including required accessories, installation,
delivery, instrumentation, and pumping
Piping
Electrical
Engineering/administrative/legal services
Total Plant Cost
Site Work
Contingency
Contractor's Fee
Total Capital Investment
Cost
Direct Capital Cost
2% of the Direct Capital Cost; assumed a
chemical precipitation unit will use existing
piping, but some adjustment may be required
Not included; assumed chemical precipitation
unit will use existing connections
10% of the direct capital cost
1 . 12 x Direct Capital Cost (Sum of Components
1 through 4)
Not included, assumed no additional site work
will be required in replacing DAF unit with
chemical precipitation unit
13% of the Total Plant Cost
3.25% of the Total Plant Cost; assumed an
average fee (rather than a maximum fee, as in
Table 1 1-2) since replacement of an existing
treatment unit is less complicated than
installation of a new treatment system
1.30 x Direct Capital Cost (Sum of
Components 5 through 8)
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                                                    Chapter 11 - Costs of Technology Bases for Regulatory Options

              •       Sludge dewatering devices - EPA gave facilities full sludge dewatering
                     credit if they indicated that their sludge dewatering device treated sludge
                     generated by either DAF or chemical precipitation; facilities that indicated
                     that they treat their sludge with a conditioner received full sludge
                     conditioning credit in the DAF-IL regulatory option.

              •       pH adjustment (applicable to the CP-IL regulatory option only) - EPA gave
                     facilities the following credits:  full credit for pH adjustment with no
                     minimum residence time required if they indicated that they have a mixed
                     tank with chemical addition; and partial credit for a tank, an agitator, an
                     acid/base feed system, or some combination of these three components
                     (these facilities were costed only for the missing component(s)).

              •       Space inside of the facility - EPA costed facilities for a building of adequate
                     size to house the regulatory option equipment only if they indicated that
                     they did not currently have space inside; no partial credit was given.

              •       Monitoring costs - EPA gave facilities either full or partial credit based on
                     whether the facilities reported that they monitor their wastewater effluent.

11.2.4        Optimization Cost Allowance

              In the costing performed for the proposed rule, EPA assumed that facilities with
treatment equipment in place equivalent to one of the regulatory options could meet the proposed
pretreatment standards without any additional costs other than compliance monitoring costs.
Based on comments received on the proposed rule, EPA decided to provide an optimization cost
allowance for facilities with full option treatment-in-place credit to allow for the possibility that
those facilities may need to make minor capital improvements to the treatment system in order to
meet the proposed pretreatment standards. Facilities may incur  an increased  annual O&M cost
for optimizing system performance, as well.

                     EPA estimated the cost allowance for these facilities based on assumptions
about the most common types of upgrades that facilities would need to implement to improve the
performance of existing treatment systems. The assumptions are based on EPA's observations
from over 35 site visits and nine sampling episodes at industrial laundries, as well as numerous
conversations with industrial laundry personnel throughout the development of a regulation.
Although EPA used specific cost components to develop the cost  allowance, the cost is intended
to be an allowance for any type of upgrade that an individual facility would identify as necessary
to optimize treatment system performance.

              EPA's capital cost allowance is based on:  1) increasing the equalization capacity;
2) additional operator training; and 3) the cost of an engineering consultant to provide advice on
optimizing treatment system  performance. EPA's estimated annual cost allowance is based on 1)
increased chemical addition and 2) increased sludge disposal costs. The cost allowances were
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based on the average of the costs calculated for chemical precipitation and DAF and applied to all
facilities with either technology in place (6).

11.3          Cost Modeling

11.3.1        Cost Model Driver

              As described earlier, EPA developed a computerized design and cost model to
estimate compliance costs and pollutant loadings for the industrial laundries technology control
options, taking into account each facility's treatment in place. The cost model was programmed
with modules that allowed the user to specify various combinations of technologies and practices
to be costed as required by  each technology control option. In the context of the industrial
laundries cost  estimation effort, "cost model" refers to the overall computer program and
"module" refers to a computer subroutine that generates costs and pollutant loadings for a
specific technology or practice (e.g., chemical precipitation, contract hauling). Some modules
were adapted from cost models used for previous EPA rulemaking efforts, such as MP&M, while
others were developed specifically for this rulemaking.

              EPA developed cost modules for the wastewater treatment technologies and
practices, as well as auxiliary  components of these technologies (e.g., pumps, buildings) included
in the industrial laundries technology control options.  Chapter 8 of this document discusses in
greater detail the specific combinations of these technologies into the technology control options.
As stated previously, this chapter discusses the estimation of compliance costs for the two
regulatory options, DAF-IL and CP-IL.  The technologies, components, and practices that
compose the regulatory options are listed below:

              •      Wastewater and sludge transfer pumps;
              •      Buildings;
              •      Stream splitting;
              •      Mechanical screening;
              •      Equalization;
              •      Dissolved air flotation;
              •      Chemical precipitation;
              •      Sludge dewatering;
              •      pH adjustment; and
              •      Contract hauling of untreated wastewater.

              As discussed in Section 11.2.1, EPA developed a cost model driver to organize the
treatment technology modules and track the costs for the entire  industry.  The cost model driver
performs the following functions, as applicable, for each technology designed for a facility:

              •      Locates and opens all necessary input data files;

              •      Stores input data entered by the user of the cost model;
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              •      Opens and runs each of the technology modules in the appropriate order
                     for each option;

              •      Calculates and tracks the following types of information generated by each
                     technology module:

                     -      Total direct capital costs;
                            Total direct annual costs;
                     -      Electricity used and associated cost;
                            Sludge generation and associated disposal costs;
                     -      Effluent flow rate; and
                            Effluent pollutant concentrations; and

              •      Sends tracked costs by regulatory option to a storage file that may be
                     printed or maintained in electronic form for further manipulation.

              The following sections list the major technologies included as modules within the
cost model and describe the major assumptions and costing methodology used for each.

11.3.2        Stream Splitting

              EPA estimated costs for a facility to install and operate a means of segregating
wastewater streams generated from washing specific items.  Stream splitting was costed in order
for each facility to direct all wastewater generated from the washing of industrial textile items to
the wastewater treatment system, while allowing the facility to discharge wastewater generated
from the washing of nonindustrial textile items (i.e., linen items) to the sewer without treatment.
The costs generally comprised the retrofitting of existing washers to include dual valves for
discharging wastewater to separate conduits and the costs associated with operating and
maintaining these valves. The costs also included a means to divide the facility's existing trench
and sump  system and direct the wastewater flows to separate locations.

              Capital and annual costs for the following equipment were included in the stream-
splitting module:

              •      Retrofitting of existing washers with dual valves and associated control
                     equipment; and

              •      Piping and pumping of wastewater to be treated to the treatment system.

              Direct capital costs were dependent upon the required size for the dual-valve
fitting, which was determined based on the facility-reported size of washer(s) and assumptions
regarding the number of washers to be retrofitted. EPA assumed that no additional annual costs
would be associated with the operation of dual-valves on existing machines.  It was assumed that
all facilities had in place a trench and  sump system, since that is the method used in industrial
laundries to transport process wastewater to the sewer.  If a facility did not report that it
segregates its wastewater, costs were calculated for the required sized valve(s),  200  feet  of PVC

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piping, and other connections necessary to direct the wastewater to be treated to the first unit of
the treatment system (i.e., the equalization tank). If a facility indicated that it segregates its
wastewater, the cost model calculated a zero capital and annual cost for stream splitting for that
facility.

              It was estimated by the equipment vendor that it would take one worker three to
four days to install the valves, pipes, and pumps for the stream-splitting process. It was also
estimated that another 30 minutes would be required for each washer formula to be programmed
(7). Based on site visits, EPA assumed that a typical washer controller contains 15 formulae,
amounting to 7.5 hours of programming time per washer. These estimates are included as part of
the installation labor cost for stream splitting.

              The cost for an air-operated sludge pump to transfer the industrial laundry
wastewater to the equalization tank, including the necessary installation and operating labor, was
also included as part of the stream-splitting module. If a facility indicated that it was transferring
each segregated stream to a treatment unit, it was given credit for having the pump in place.
Refer to Section 11.3.3 below for a more detailed description of the pumps cost module.

11.3.3        Pumps

              EPA estimated costs for a facility to install and operate pumps, as necessary, to
transfer wastewater and sludge from one treatment unit to another within the regulatory control
options. A cost for an air-operated  positive displacement pump was calculated  in situations
where the wastewater was  presumed to contain a high amount of solids (e.g., wastewater
discharged directly from washers and sludge streams). Where wastewater was to be transferred
from one treatment unit to  another,  a cost for a positive displacement pump was calculated for
flows up to 27 gpm and a centrifugal pump was costed for flows greater than 27 gpm.

              Direct capital and annual costs were calculated based on the required size of each
type of transfer pump.  Both  types of pumps were sized based on the required flow rate calculated
by the cost model using mass balances around each treatment unit.  EPA developed the
convention that costs calculated for each treatment unit module would include the capital and
annual costs for an effluent pump.  Exceptions to this convention occur in the cost for the shaker
screen that included both an influent and effluent pump.  Also, a cost was not calculated for an
effluent pump in situations where the treatment unit is the last in the option's treatment train (e.g.,
the DAF or the pH adjustment modules), because it was assumed that the wastewater can flow by
gravity into the sewer.

              Annual costs included O&M material costs and energy costs.  No energy costs
were associated with the air-operated positive displacement pumps because EPA assumed that all
industrial laundries currently have an air compressor and supply line available to operate the
positive displacement pump without incurring any additional costs.

              The pump module includes an estimate of installation labor costs, based on the size
and type of pump being costed.  All labor estimates are based on information obtained from past
effluent guidelines  costing  efforts, as well as engineering judgement. Installation is

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estimated to take one worker from 1.5 to 42 hours for various types of positive displacement and
centrifugal pumps, up to a 750-gpm capacity (8).

              EPA assumed that facilities that reported having two sequential treatment units in
place also have the necessary transfer pump in between, and therefore calculated zero capital and
annual costs for the transfer pump.  All other facilities that did not report having a treatment unit
located downstream from the unit costed in the module received capital and annual costs for an
effluent transfer pump. For example, a facility that reported having an equalization tank followed
by an oil-water separation tank in place received no costs for an effluent pump in the equalization
module.  However, a facility that reported an equalization tank followed by discharge to the sewer
received both capital and annual costs for an equalization tank effluent pump, sized sufficiently to
transfer wastewater to the next required treatment unit in the option.

11.3.4         Screening

              Mechanical screens are commonly used at industrial laundries to remove lint and
other solid constituents from wastewater.  Therefore, EPA estimated costs for mechanical
screening of a facility's untreated wastewater from the washing  of nonindustrial textile items prior
to recombination with treated wastewater from the washing of industrial textile items.  The
module calculates the costs necessary to pump the wastewater to be screened  from the sump to
the screen; mechanically remove lint suspended in the wastewater; discharge the lint into a
collection vessel (e.g., a drum or bag); discharge the screened wastewater into a collection tank;
and pump the  screened wastewater from the collection tank to the next unit in the  option's
treatment train.

              Capital and annual costs for the following equipment were included in the
screening module:
                     An influent positive displacement pump;
                     A shaker screen;
                     A screen effluent holding tank; and
                     A centrifugal effluent pump.
              Annual costs included O&M material costs, energy costs, and lint disposal costs.
The disposal costs were based on the average nonhazardous disposal costs reported by facilities
for disposing of collected lint from screens.  Both the direct capital and annual costs for screens
were based on the required size of the screen, which was determined based on the input flow
rate(s) used by the cost model. Based on sampling data, EPA assumed that the flow rate and
pollutant loads are unaffected by the screening operation.  Therefore, the screen module
calculated the flow rate and pollutant loads in the effluent from the screen to be equal to those in
the influent.

              The screen module includes an estimate of installation labor costs for the screen
unit and effluent holding tank.  All labor estimates are based on information obtained from
equipment vendors, as well as engineering judgement.  Installation of the shaker screen unit and
holding tank is estimated to take one worker four hours and seven hours, respectively (9).

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              The annual O&M materials cost associated with the holding tank was not
calculated as a separate item, but was included as part of the estimating factor for the total annual
cost, based on estimates used in past effluent guidelines (9). The annual O&M materials cost was
assumed to be half of the total annual cost for the holding tank (i.e., one percent of the direct
capital cost), based on engineering judgement (10).

              A cost was calculated for a screen if a facility  did not report that it had a
mechanical screen in place. Facilities reporting any type of mechanical screening (e.g., shaker
screen, rotary screen) in place received zero capital and annual costs for the screen.  EPA
assumed that a facility reporting that it screens any portion of its wastewater would also be able to
screen the wastewater generated from washing its industrial textile items and, therefore, EPA
calculated zero capital and annual costs for the screen.

              Costs for a maximum of two wastewater pumps to transfer the wastewater to the
screen and from  the holding tank to the next treatment unit, including the necessary installation
labor, were also included as part of the shaker screen module. If a facility indicated that it was
screening at least a portion of its wastewater, it was given credit for having the influent pump. If
it also indicated that it was transferring the screened water to another treatment unit, it was also
given credit for the effluent pump. Refer to Section 11.3.3 of this document for a more detailed
description of the pumps  cost module.

11.3.5        Equalization

              EPA estimated costs for the equalization of a facility's industrial laundry
wastewater. The equalization module calculates the costs necessary to equalize the wastewater
prior to treatment in a mixed tank sized to absorb fluctuations in flow, pollutant load, and pH and
to pump the equalized wastewater to the next unit in the option's treatment train.

              Capital and annual costs for the following equipment were included in the
equalization module:

              •      A closed tank;
              •      A mixer(s); and
              •      A centrifugal  effluent pump.

              Annual costs included O&M material costs and energy costs.  Both the direct
capital and annual costs for the equalization tanks were based on the required size of the tank.
The tanks were designed  to have a four-hour residence time, based on the median reported
residence time for equalization tanks in the detailed questionnaire.  The required size of the tanks
was therefore calculated from this design parameter and the influent flow rate for each facility.
The required mixer size, as well as the number of mixers, was calculated based on the size of the
tank using the design parameter of 0.5 mixer hp per 1,000 gallons of tank capacity (11).  EPA
assumed that the pollutant loads are unaffected by equalization and, therefore, the module
calculated the pollutant loads in the effluent from the equalization tank to be equivalent to those in
the influent.
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              The equalization module includes an estimate of installation labor costs for the
equalization tank and mixer. All labor estimates are based on information obtained from
equipment vendors, as well as past effluent guidelines costing efforts and engineering judgement.
Installation for the equalization tank and mixer is estimated to take five workers eight hours and
one worker 2.4 hours, respectively (11).

              The annual O&M materials cost for the equalization tank and mixer is not
calculated as a separate item, but is included as part of the estimating factor for the annual cost,
based on estimates used in past effluent guidelines efforts (11). The annual O&M materials costs
associated with the equalization tank and mixer were assumed to be more than half of the total
annual cost for each (i.e., three percent of the direct capital costs), based on engineering
judgement (10).

              A cost was calculated for an equalization tank if a facility did not report that it had
a large enough tank in place. Facilities that had tanks with a minimum residence time of two
hours were given full credit for the equalization tank, and the module calculated zero capital and
annual costs for the tank. Likewise, facilities that reported having a mixer on site were given full
credit for the mixer.

              The costs for the effluent wastewater pump to transfer the wastewater to the next
treatment unit, including the necessary installation and operating labor, were also included as part
of the equalization module.  If a facility indicated that it was transferring the stream to another
treatment unit, it was given credit for having the effluent pump in place. Refer to Section 11.3.3
of this document for a more detailed description of the pumps cost module.

11.3.6        Dissolved Air Flotation

              EPA estimated costs for DAF treatment of wastewater generated from the
washing of industrial textile items in the DAF-IL regulatory option. The DAF module calculates
the costs necessary to treat the wastewater with sulfuric acid, ferric chloride, and cationic and
anionic polymers to form an agglomerated floe containing pollutants; float the floe to the surface
of the unit; remove the floating floe from the wastewater; pump the collected floe to a sludge
conditioning tank and treat it with perlite; pump the conditioned sludge to sludge dewatering; and
discharge the DAF-treated wastewater to the sewer.

              Capital and annual costs for the following equipment were included in the DAF
module:

              •      An acid-feed system;

              •      A DAF unit, including three chemical addition units, pH controller,
                     chemical premix tanks, and positive displacement sludge transfer pump;
                     and

              •      An open sludge conditioning tank with a mixer.
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              Annual costs included O&M material costs, energy costs, and raw material (e.g.,
sulfuric acid, ferric chloride, cationic polymer, anionic polymer, and perlite) costs. Both the direct
capital and annual costs for the DAF unit were based on the required capacity of the unit to treat
a continuous flow of wastewater. The required capacity of the unit was calculated based on the
influent flow rate(s) in gallons per minute of flow.  The chemical addition rates were determined
based on average reported amounts of chemical per gallon of wastewater treated. The following
chemical addition rates were used by the DAF cost module:
Chemical
Sulfuric acid
Ferric chloride
Cationic polymer
Anionic polymer
Perlite
Gallons of Chemical per 10,000 Gallons
Laundry Wastewater Flow
of Industrial
0.8
0.9
2
0.07
0.25 pounds per pound of sludge collected
unit on a dry-solids basis
from the DAF
              The recommended amount of perlite added per pound of DAF sludge was
provided by a chemical vendor.  The DAF module calculated pollutant loads in the treated
wastewater effluent using target average concentrations calculated from DAF system sampling
and DMQ data. The module calculated a sludge flow rate based on a median sludge generation
rate (0.031 pounds of sludge per gallon of wastewater) calculated from data provided by facilities
using DAF (12). The module also included the effluent flow rate based on a mass balance around
the unit using the influent flow rates of wastewater and chemicals, as well as the amount of sludge
removed from the wastewater though DAF treatment.

              The DAF module includes an estimate of installation labor costs for the DAF unit.
All labor estimates are based on information obtained from equipment vendors, as well as past
effluent guidelines costing efforts and engineering judgement. Installation labor for the DAF
system is estimated by a vendor to be included in an installation cost factor of six percent of the
purchased cost (13).

              The annual O&M materials cost for the DAF unit was estimated to be included as
part of the total maintenance cost factor of the DAF system capital cost (13). The O&M
materials cost associated with the DAF unit was assumed to be half of the total maintenance cost
(i.e., one percent of the direct capital cost), based on engineering judgement (10).

              The DAF module also includes installation labor costs for the chemical feed
system. The installation labor for the chemical feed system was calculated with the total capital
cost from the cost curves obtained from past effluent guidelines costing efforts. The labor hours
were not broken out as separate items (14).

              A cost was calculated for a DAF unit if a facility did not report that it treated its
wastewater with DAF.  Facilities that had DAF units of sufficient capacity were given full option
credit.  For example, a facility that reported treating its total wastewater flow with DAF was
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given full credit for the DAF-IL option and received only monitoring costs and an optimization
cost allowance to comply with a rule under this option. Facilities that reported operating an
induced air flotation (IAF) unit of sufficient capacity were also given full option  credit. However,
a facility that reported treating a portion of its wastewater was evaluated as to whether it had
sufficient DAF capacity to treat the industrial laundry wastewater.  For example, a facility
reported that it treats 35 percent of its wastewater with DAF; 50 percent of its wastewater is
industrial laundry wastewater. Under the DAF-IL option, it needs to treat 15 percent more of its
wastewater to  comply with the option requirements. The facility received capital and annual costs
for a DAF unit sized to treat 15 percent of its wastewater flow.  This additional unit together with
the unit in place can treat the 50 percent industrial laundry wastewater flow.

              Based on final long-term average concentrations for chemical precipitation and
DAF gathered from sampling and DMQ data, chemical precipitation achieves lower pollutant
concentrations in the treated wastewater than DAF.  Likewise, when operated properly,
ultrafiltration and microfiltration are considered to provide greater pollutant removals than
DAF (15).  Therefore, facilities with chemical precipitation, ultrafilters, or microfilters with
sufficient capacity to treat the wastewater generated from washing industrial textile  items received
treatment-in-place credit for having a complete DAF system in the DAF-IL option.  However,
facilities with these technologies that do not have sufficient capacity received capital and annual
costs for a DAF unit sized to treat their industrial laundry wastewater.

11.3.7        Chemical Precipitation

              EPA estimated costs for chemical precipitation treatment of wastewater generated
from washing  industrial textile items in the CP-IL regulatory option. The chemical precipitation
module calculates the costs necessary to treat the wastewater with lime and cationic and anionic
polymers to precipitate and agglomerate pollutants from the wastewater; settle the precipitate to
the bottom of the treatment tank in batch systems  or continuously remove the  precipitate with
inclined plates in continuous systems; and  pump the chemical precipitation-treated wastewater
from the chemical precipitation unit to the next unit in the option's treatment train.

              Capital and annual costs for the following equipment were included in the batch
chemical precipitation system module:

              •      A mixed batch treatment tank;
              •      Three chemical addition units with pH controller;
              •      A positive displacement sludge transfer pump;
              •      A sludge holding tank; and
              •      A centrifugal effluent pump.

              Capital and annual costs for the following equipment were included in the
continuous chemical precipitation system module:

              •      A continuous chemical precipitation unit (including three chemical addition
                     units, pH controller,  chemical premix tanks and inclined plate settlers);
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              •      A positive displacement sludge transfer pump;

              •      A sludge holding tank; and

              •      A centrifugal effluent pump.

              Annual costs included O&M material costs, energy costs, and raw material (e.g.,
lime, cationic polymer, and anionic polymer) costs.  Both the direct capital and annual costs were
based on the required capacity of the unit to treat either a batch of wastewater or a continuous
flow of wastewater, which was calculated based on the influent flow rate(s).  Costs were
calculated for batch units for facilities with less than 2,500 gallons per day of flow and continuous
units for facilities with flows greater than 2,500 gallons per day. The chemical addition rates used
by the module were determined based on average amounts of chemical per gallon of wastewater
treated that were reported in responses to the detailed questionnaire and by sampled facilities.
The following chemical addition rates were used by the chemical precipitation cost module:
Chemical
Lime
Cationic Polymer
Anionic Polymer
Amount of Chemical Added per 10,000 Gallons
Industrial Laundry Wastewater Flow
of
1 00 pounds
2 gallons
0.07 gallon
              The module calculated pollutant loads in the treated wastewater effluent using
target average concentrations calculated from chemical precipitation system sampling and DMQ
data.  The module calculated a sludge flow rate based on a median sludge generation rate (0.039
pounds of sludge per gallon of wastewater) calculated from data provided by facilities using
chemical precipitation (12).  The module also calculated the effluent flow rate based on a mass
balance around the unit using the influent flow rates of wastewater and chemicals, as well as the
amount of solids removed from the wastewater though chemical precipitation treatment.

              The chemical precipitation module includes an estimate of installation labor costs
for the batch and continuous units.  All labor estimates are based on information obtained from  an
equipment vendor, as well as past effluent guidelines costing efforts and engineering judgement.
Installation for the chemical  precipitation systems is estimated by  the vendor to take one worker
40 hours for the smallest system and two workers 80 hours for the largest system (16).

              The annual O&M materials cost for the chemical precipitation unit was estimated
to be included as part of the  estimating factor for the total annual cost, based on past effluent
guidelines costing efforts (16). The annual O&M materials cost was assumed to be more than
half of the total annual cost for the chemical precipitation unit (i.e., three percent of the chemical
precipitation system capital cost), based on engineering judgement (10).
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              A cost was calculated for a chemical precipitation unit if a facility did not report
that it treated its wastewater with chemical precipitation. Facilities that had chemical precipitation
units of sufficient capacity were given full option credit. For example, a facility that reported
treating its total wastewater flow with chemical precipitation was given full credit for the DAF-IL
and CP-IL regulatory options and received only monitoring costs and a nominal cost allowance to
comply with a rule under these options. However, a facility that reported treating a portion of its
wastewater with continuous chemical precipitation was evaluated as to whether it had sufficient
chemical precipitation capacity to treat the wastewater according to each option, similar to the
example presented in Section 11.3.6 for the DAF technology. Most facilities that have a batch
chemical precipitation unit in place have a significant amount of untreated wastewater that would
require treatment under the IL options, such that a continuous chemical precipitation unit would
be required in addition to the batch unit in place. EPA assumed that these facilities would not
continue to operate both a batch and continuous chemical precipitation unit simultaneously.
Instead, these facilities received no credit toward the CP-IL option and received capital and
annual costs to install and operate a new chemical precipitation system appropriately sized to treat
the facility's industrial laundry wastewater.

              The costs for the effluent wastewater pump to transfer the wastewater to the  next
treatment unit, including the necessary installation and operating labor, were also included as part
of the chemical precipitation module.  If a facility indicated that it was currently transferring the
stream to another treatment unit, it was given credit for having the effluent pump in place. Refer
to Section 11.3.3 of this document for a more detailed description of the pumps cost module.

              When operated properly, ultrafiltration and microfiltration are considered to
provide greater pollutant removals than  chemical precipitation (15). Therefore, facilities with
ultrafilters or microfilters of sufficient capacity to treat the wastewater generated from washing
industrial textile items received treatment-in-place credit for having a complete chemical
precipitation system  in the CP-IL option.

              Capital and  annual costs  for a complete chemical precipitation unit were calculated
for facilities with DAF systems in the CP-IL option.  These facilities received a salvage value
credit toward the CP-IL capital costs for replacement of their existing DAF unit. The  salvage
value was estimated  based  on the reported age of the unit and the estimated capital cost.  It was
also assumed that facilities replacing an  existing unit would not incur as many indirect capital
costs as facilities installing a new treatment system.  Therefore, a lower indirect capital cost factor
was applied to the estimated capital cost for the chemical precipitation unit.  Table 11-4 presents
the lower indirect capital cost factors applied in the CP-IL option for the facilities with DAF  units
in place. An annual  cost credit was also applied to the CP-IL annual cost for these facilities. The
capital and annual  O&M costs for the DAF unit were estimated using the methodology described
in Section 11.3.6 of this document for the reported amount of flow treated by the existing DAF
unit.
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11.3.8        Sludge Dewatering

              EPA estimated costs for facilities to dewater the sludge generated by either a DAF
or chemical precipitation unit. The sludge dewatering module calculates the costs necessary to
pump the sludge through a filter press; remove and dispose of the dewatered cake from the filter;
and return the filtrate to the treatment system sump.

              Capital and annual costs for the following equipment were included in the sludge
dewatering system module:

              •       A plate and frame filter press system with accessories such as a plate
                     shifter, platform, and cake disposal dumpsters; and

              •       A positive displacement influent sludge pump.

              Annual costs included O&M material costs, energy costs, and dewatered cake
disposal cost. The capital and annual costs associated with the filter press were based on the
required size of the press, which was calculated based on the influent sludge flow rate, solids
concentration, and the dewatered cake solids concentration.  EPA based solids concentrations for
both the sludge and  dewatered cake generated by each technology on filter press vendor test data
and facility responses to the detailed questionnaire.  The filter press was sized based on the
volume of dewatered cake that is generated from the sludge stream.  The number of batches per
day of dewatering was optimized by the module to minimize the size of the filter press, where
possible. The volume of cake and the filtrate flow rate were calculated by the sludge dewatering
module from a mass balance using the sludge flow rate and the sludge and cake solids
concentrations.  The additional costs for the filter press system accessories were dependent upon
the required size of the filter press.  The dewatered cake disposal costs were based on the average
reported nonhazardous dewatered cake disposal costs per volume of cake  and the module-
calculated volume of dewatered cake per year for each facility.  The capital and annual costs for
the influent sludge pump were calculated based on the required capacity of the pump, which was
based on the sludge  influent flow rate.

              The module is designed to return the filtrate to the facility's trench and sump
system, based on typical operating procedures reported by industrial laundries.  EPA assumed that
the filtrate would flow by gravity from the filter press to the trench and/or sump and therefore
would not require any additional collection tanks or transfer pumps. EPA assumed that the
returning filtrate would not affect the raw pollutant concentrations in the untreated wastewater
because the filtrate volume represents only a small percentage of the volume of the sump.  The
cost model adjusts the influent flow rate by a factor to account for this slight increase in influent
flow rate.

              The sludge dewatering module includes an estimate of installation labor costs for
the filter press unit.  All labor estimates are based on information obtained from an equipment
vendor and engineering judgement. Installation labor for the filter press is estimated by the vendor
to be included in an  installation cost factor of 75 percent of the purchased cost (17).
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              A facility received full sludge dewatering credit if it reported having a sludge
dewatering device in place to dewater sludge from a system similar to DAF or chemical
precipitation. For example, facilities that reported operating a sludge dewatering device to
dewater sludge generated by gravity settling were not given credit for the system.  EPA assumed
that such a system would not have sufficient capacity to treat the amount of sludge generated by
DAF or chemical precipitation units.

              The costs for the influent sludge pump to transfer the sludge into and through the
filter press, including the necessary installation labor, were also included as part of the sludge
dewatering module. If a facility indicated that they were dewatering an appropriate  amount of
sludge, they were given credit for having the influent pump in place. Refer to Section 11.3.3 of
this document for a more detailed description of the pumps cost module.

11.3.9        pH Adjustment

              EPA estimated costs for facilities to adjust the pH of the effluent wastewater
generated by the CP-IL regulatory option. The pH adjustment module calculates the costs
necessary to combine untreated linen supply wastewater and treated industrial laundry
wastewater; monitor the pH of the effluent stream; and add necessary chemicals to a mixed tank
to adjust the pH of the final effluent stream to within a specified range.

              Capital and annual costs for the following equipment were included in the pH
adjustment module:

              •       An open, mixed tank;
              •       A pH controller; and
              •       A chemical  addition system.

              Annual costs included O&M material costs, energy cost, and raw material (e.g.,
sulfuric acid or sodium hydroxide) costs. The capital and annual costs associated with the
chemical addition system were based on the required size of the system, which was calculated
based on the total influent flow rate and an estimation of the amount of acid or caustic that was
required to adjust the final effluent pH to within a specific range.  EPA assumed chemical
precipitation-treated wastewater to have a pH of 12, based on the average pH observed during
sampling episodes. EPA also assumed that untreated light industrial laundry wastewater had a pH
of 10, based on sampling data.  Based on existing industrial laundry limitations on pH at the point
of discharge, EPA assumes that the final effluent pH must be between 5 and 10  upon discharge.
Therefore, according to these assumptions, the wastewater generated by the CP-IL regulatory
option requires pH adjustment prior to discharge in order for facilities to continue to meet their
existing pH limits.  EPA assumed DAF-treated wastewater to have a pH of 9, based on sampling
data.  Since the wastewater generated by the DAF-IL regulatory option is already within the
assumed pH limits, pH adjustment costs are not calculated for this option.

              The capital and annual costs associated with the pH adjustment tank were based
on the required size of the tank, which was calculated, based on the influent flow rate, to have a
three-minute residence time for the wastewater. This is the required residence time to achieve a

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                                                    Chapter 11 - Costs of Technology Bases for Regulatory Options

target pH in a mixed tank with liquid chemical addition (18).  The mixer was also costed based on
its required size, which was determined based on the size of the pH adjustment tank.

              The pH adjustment module calculates the resulting pollutant loads from the
combination of the treated and untreated streams. EPA assumed that pH adjustment would not
affect the pollutant concentrations in the final effluent.  The pH adjustment module calculated the
final pollutant loads to be equivalent to those in the pH adjustment influent.

              The pH adjustment module includes an estimate of installation labor costs for the
pH adjustment tank and mixer. All labor estimates are based on information obtained from
equipment vendors, as well as past effluent guidelines costing efforts and engineering judgement.
Installation for the pH adjustment tank and mixer is estimated to take one worker seven hours and
2.4 hours, respectively (19).

              The annual O&M materials cost for the pH adjustment tank and mixer was not
calculated as a separate item, but included as part of the estimating factor for the annual cost,
based on estimates used in past effluent guidelines efforts (19).  The  annual O&M materials costs
associated with the pH adjustment tank and mixer were  assumed to be more than half of the total
annual cost for each (i.e., three percent of the direct capital costs), based on engineering
judgement (10).

              The pH adjustment module also includes installation labor costs for the chemical
feed system.  The installation labor for the chemical feed system was included in the total capital
cost used from past effluent guidelines costing efforts.  The labor hours were not broken out as
separate items (19).

              A facility received full pH adjustment credit if it reported using some type of pH
adjustment.  Costs were estimated for facilities that reported having  some of the components of
the pH adjustment system to add the necessary parts to complete the system.  Facilities did not
have to meet a minimum residence time requirement and received treatment-in-place credit for
any tank that was available to use for pH adjustment.

11.3.10       Treatment System Building

              EPA estimated costs for facilities to construct and maintain a building to house the
option treatment system using the building module.  Capital and annual  costs for the following
equipment were included in the treatment system building:

              •       A concrete floor slab;
              •       A concrete curb around the building perimeter;
              •       A rectangular-shaped, pre-engineered steel frame building; and
              •       Utilities (plumbing, HVAC, and electricity).

              Annual costs include costs for labor and materials for the yearly maintenance and
repair of the building. These costs were estimated to be 3.5 percent of the direct capital cost (10).
The capital cost associated with constructing the building was based on the required size of the

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                                                    Chapter 11 - Costs of Technology Bases for Regulatory Options

building. The square footage requirement of the building was determined for each regulatory
option based on the equipment space requirements for a low, medium, and large flow of
wastewater. Dimensions of various size equipment pieces were gathered from equipment
specifications supplied by vendors. The building square footage was calculated by summing each
of the option equipment space requirements, allowing for a five- to ten-foot clearance between
equipment pieces and the building walls. The building space design, as well as the capital cost per
square foot, were increased since proposal based on comments and industry supplied data (20).

              EPA observed during site visits and sampling episodes that facilities were able to
install wastewater treatment equipment in existing space either inside the facility or on their
existing property. Based on this information, EPA assumed that a facility would not need to
purchase additional land to install wastewater treatment equipment required by the technology
control options.

              A facility received full credit for a building in place if they reported having
sufficient space available in their existing building.   These facilities received zero capital and
annual costs for a building. Facilities that reported having less than the option's required space  or
that did not report available space in the detailed questionnaire had costs estimated to construct
and maintain a building.

11.3.11        Contract Haul In Lieu of Treatment On Site

              EPA estimated the cost of contract hauling wastewater for off-site treatment at a
treatment, storage,  and disposal facility (TSDF) or a Centralized Waste Treater (CWT) facility.
These estimated costs included the cost to transport the wastewater to the off-site treatment
facility,  and were compared to the cost of on-site treatment.  For some industrial laundries with
low flow rates, it was less expensive for a facility to contract for off-site treatment and disposal
rather than treat the wastewater on site. EPA compared the annualized cost of transportation and
off-site treatment with the annualized cost to treat that wastewater on site for each regulatory
option.

              Capital and annual costs for the following equipment were included in the
contract-haul-in-lieu-of-treatment module:

              •       Stream splitting costs;
              •       An influent pump; and
              •       A wastewater storage tank.

              Annual costs included O&M labor and material costs, energy cost, tank sampling
costs, and transportation fees.  The capital and annual costs for the influent pump and wastewater
storage tank are dependent upon the required sizes for each. The tank and pump sizes were
calculated by the contract haul module based on the flow rate of the wastewater to be collected
and hauled. The tank was sized to hold up to one week of wastewater flow. The tank was also
50 percent overdesigned to accommodate fluctuations in facility production. The costs for
transportation of the wastewater to the off-site industrial treatment facility were calculated based
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                                                    Chapter 11 - Costs of Technology Bases for Regulatory Options

on the number of trips per year required to haul the wastewater (assuming wastewater is hauled in
one 5,000-gallon tank truck for each trip) and a cost per trip fee provided by a vendor. The cost
per gallon to treat the wastewater, as well as the annual tank sampling fee, were also obtained
from vendor information.

              The contract haul module includes an estimate of installation and O&M labor costs
for the wastewater storage tank and installation of stream-splitting components. All labor
estimates are based on information obtained from equipment vendors, as well as past effluent
guidelines costing efforts and engineering judgement.  Installation labor for the storage tank is
estimated by the vendor to take five workers eight hours.  The annual O&M labor cost for the
tank is not calculated as a separate item, but included as part  of the estimating factor for the
annual cost (i.e., five percent of the direct capital cost of the tank), based on estimates used by
past effluent guidelines efforts. In addition, it was estimated that  it would take one facility worker
two hours to assist in pumping a 5,000-gallon load of wastewater into the tank truck (21).  The
installation labor required for the stream-splitting components is described in Section 11.3.2 of
this document.

              A facility received full tank and/or pump credits if it indicated that a sufficiently
sized tank or pump was available on site to transfer and store the  wastewater to be hauled.  These
facilities received zero capital and annual costs for the pump and tank. All facilities with or
without equipment credits were costed for the annual sampling, transportation, and treatment
costs.

              The costs for the influent pump to transfer the wastewater into the storage tank,
including the necessary installation and operating labor, were also included as part of the contract-
haul-in-lieu-of-treatment module. Refer to Section 11.3.3 of this  document for a more detailed
description of the pumps cost module.

11.3.12        Compliance Monitoring

              EPA calculated annual compliance monitoring costs for all industrial laundry
facilities that discharge wastewater. These costs  included laboratory costs to analyze one sample
each of volatile and  semivolatile organics and quantitative metals  monthly, and to analyze TPH
(measured as SGT-HEM)1 four times per month. The costs for each type of analysis per sample
were obtained from  a laboratory contracted by EPA on past wastewater sampling efforts. Also
included was the cost for glassware and containers needed to package the samples.  These costs
were obtained from  data acquired during the EPA wastewater sampling efforts.

              Facilities that reported in the detailed questionnaire that they monitored their
wastewater were only costed for the analyses.  Otherwise, facilities were  costed for the analysis
and materials required for the wastewater monitoring (22).
'Silica gel treated-hexane extractable material (SGT-HEM) is measured by Method 1664 promulgated at 64 FR 26315;
May 14, 1999. In this method, EPA defines SGT-HEM as non-polar material (NPM).  Throughout this document and
the Industrial Laundries Administrative Record, EPA refers to SGT-HEM as total petroleum hydrocarbon (TPH).

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                                                   Chapter 11 - Costs of Technology Bases for Regulatory Options

11.4          Engineering Costs for the Regulatory Options

              Table 11-5 summarizes estimated engineering costs for the regulatory options.
Costs shown include capital and annual O&M (including energy usage) costs totaled for the 190
in-scope facilities extrapolated to represent the entire industrial laundries industry of 1,742
facilities. In addition, the capital and O&M costs are shown for the three exclusions incorporated
into each of the regulatory options, as discussed in Chapter 8 of this document. Table 11-6
presents estimated engineering costs on an amortized yearly basis for the regulatory options.  The
methodology used to calculate the amortized annual costs from the capital and annual option
costs calculated by the cost model is presented in the EA for the industrial laundries rulemaking
(1).

              EPA estimates that chemical precipitation's lower O&M costs make it less
expensive to operate on an annualized basis than DAF. Because EPA's performance data show
that chemical precipitation achieves better treatment than DAF, facilities operating a DAF unit
were assumed to replace that unit with a chemical precipitation unit in order to comply with the
CP-IL option pretreatment standards, as described in Section 11.2.3 of this document. In EPA's
estimates, facilities that currently operate a DAF would realize an O&M cost savings for
operating a chemical precipitation unit compared to operating the DAF unit.  Therefore, EPA's
estimated costs for the CP-IL option include the O&M cost credit for facilities that currently
operate a DAF to replace the DAF unit with a chemical precipitation unit.

11.5          Compliance Costs Estimated from 1998 Facility Treatment-In-Place Data

              In 1998, the industrial laundries trade associations (the Uniform and Textile
Service Association (UTSA) and the Textile Rental Services Association (TRSA)) surveyed the
industrial laundries to which EPA sent a detailed questionnaire in  1994. More information on the
types of data collected by the UTSA/TRSA survey is provided in  Section 3.7.2 of this document..
The purpose of the  survey was to provide EPA with updated information on treatment
technologies in place at industrial laundries. Of the 190 in-scope facilities, 162 responded to the
UTSA/TRSA survey.  Section 6.5.16 of this document summarizes the types of equipment that
were reported in the survey.

              At proposal (62 FR 66181; December 17, 1997), EPA estimated capital and
annual O&M compliance costs based on treatment-in-place information reported in the detailed
questionnaire for the 1993 operating year.  For the Notice of Data Availability (NODA) (63 FR
71054; December 23, 1998); EPA compared the compliance costs estimated at proposal to the
compliance costs estimated using the treatment-in-place information reported in the UTSA/TRSA
survey for the 1998  operating year for the DAF-IL and CP-IL regulatory options with the 1
Million/255 K  exclusion. EPA's methodology and the results of the comparison are discussed
below.

              EPA compared the treatment system description  contained in the UTSA/TRSA
survey to the treatment system components reported in the detailed questionnaire for each
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                                                            Chapter 11 - Costs of Technology Bases for Regulatory Options
                                             Table 11-5
              Summary of Engineering Costs for the Regulatory Options
Option
Capital Cost
(Million 1993 $s)
O&M Cost
(Million 1993 $s per Year)
Capital and Annual Costs for All Industrial Laundries1
CP-IL
DAF-IL
544
451
124
150
Capital and Annual Costs with the 1 Million/255 K Exclusion2
CP-IL
DAF-IL
515
425
117
142
Capital and Annual Costs with the 3 Million/120 K Exclusion3
CP-IL
DAF-IL
395
320
89.1
122
Capital and Annual Costs with the 5 Million/255 K Exclusion4
CP-IL
DAF-IL
242
188
52.9
69.5
'The entire industrial laundries industry is estimated to consist of 1,742 facilities.
2There are 136 facilities processing less than 1,000,000 pounds of incoming laundry and less than 255,000 pounds of
industrial towels annually that are excluded, leaving a total of 1,606 facilities.
3There are 518 facilities processing less than 3,000,000 pounds of incoming laundry and less than 120,000 pounds of
industrial towels annually that are excluded (this exclusion also excludes all facilities excluded under the 1 Million/255
K exclusion, above), leaving a total of 1,224 facilities.
4There are 953 facilities processing less than 5,000,000 pounds of incoming laundry and less than 255,000 pounds of
industrial towels annually that are excluded, leaving a total of 789 facilities.

Source:  Output from the Industrial Laundries Design and Cost Model, February 15, 1999.
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                                                            Chapter 11 - Costs of Technology Bases for Regulatory Options
                                             Table 11-6

                        Summary of Annualized Engineering Costs
                                  for the Regulatory Options
Option
Annualized Cost
(Million 1993 $s per Year)
Annualized Post-Tax Cost for All Industrial Laundries1
CP-IL
DAF-IL
128
137
Annualized Post-Tax Cost with the 1 Million/255 K Exclusion2
CP-IL
DAF-IL
121
129
Annualized Post-Tax with the 3 Million/120 K Exclusion3
CP-IL
DAF-IL
90.8
98.8
Annualized Post-Tax Cost with the 5 Million/255 K Exclusion4
CP-IL
DAF-IL
53.9
60.0
'The entire industrial laundries industry is estimated to consist of 1,742 facilities.
2There are 136 facilities processing less than 1,000,000 pounds of incoming laundry and less than 255,000 pounds of
industrial towels annually that are excluded, leaving a total of 1,606 facilities.
3There are 518 facilities processing less than 3,000,000 pounds of incoming laundry and less than 120,000 pounds of
industrial towels annually that are excluded (this exclusion also excludes all facilities excluded under the 1 Million/255
K exclusion, above), leaving a total of 1,224 facilities.
4There are 953 facilities processing less than 5,000,000 pounds of incoming laundry and less than 255,000 pounds of
industrial towels annually that are excluded, leaving a total of 789 facilities.

Source:  Economic Assessment for the Final Action Regarding Pretreatment Standards for the Industrial Laundries Point
Source Category.
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                                                    Chapter 11 - Costs of Technology Bases for Regulatory Options

facility. In the UTSA/TRSA survey, most facilities did not report the treatment system design
parameters.  To calculate the changes in the capital and annual O&M compliance costs, EPA
made the following assumptions when reviewing the UTSA/TRSA survey data:

              •       EPA continued to use the flow and production data reported in the detailed
                     questionnaire for all facilities.

              •       For facilities treating a portion of their wastewater that did not indicate the
                     percentage of wastewater treated, EPA assumed that they are treating only
                     a small portion of their total wastewater.

              •       For facilities using DAF, chemical precipitation, or chemical emulsion
                     breaking treatment, EPA assumed that the facility is operating these
                     systems in a manner equivalent to the technology control options costed by
                     EPA.

              •       For facilities providing treatment system descriptions that were not detailed
                     enough for EPA to determine what treatment system was operated, EPA
                     assumed that they are still operating the treatment system reported in the
                     detailed questionnaire.

              •       For a facility reporting use of biological treatment, EPA assumed that it
                     does not have treatment in place equivalent to any of the technology
                     control options.

              •       For a denim prewash facility that operated a partial treatment system, EPA
                     assumed that it treats wastewater from all items except for the denim
                     prewash, which is not included in the  scope of the rule.

              •       EPA did not reduce costs to reflect ancillary treatment technologies (e.g.,
                     screens, filter presses, equalization tanks) added since those reported in the
                     detailed questionnaire.

              •       EPA did not make any changes in the  compliance costs for ten facilities
                     that reported closing or rebuilding since 1993.

              •       For facilities that reported that they planned to install treatment systems in
                     the future, EPA assumed that they are still operating the treatment system
                     reported in the detailed questionnaire.

              •       EPA assumed facilities that did not respond to the UTSA/TRSA survey (28
                     out of the 190 in-scope facilities) were still operating the treatment system
                     reported in the detailed questionnaire.

              Table 11-7 presents a comparison of the compliance capital and annual O&M costs
estimated for the proposal and the compliance capital and annual O&M costs estimated

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                                                  Chapter 11 - Costs of Technology Bases for Regulatory Options

                                      Table 11-7

  Capital and Annual O&M Compliance Cost Comparison Between the Costs
 Estimated at Proposal and Costs Incorporating UTSA/TRSA Survey Data for
                   the DAF-IL and CP-IL Regulatory Options1
 Excluding Facilities with Less than 1 Million Pounds per Year Total Production and Less
         than 255,000 Pounds per Year Shop and Printer Towel/Rag Production2
Option
Compliance Cost
Estimated for Proposal3
(Million 1993 $s)
Compliance Cost
Estimated Based on
UTSA/TRSA Survey4
(Million 1993 $s)
Percent Decrease in
Compliance Costs
Capital Cost
CP-IL
DAF-IL
$515
$425
$408
$299
21%
30%
Annual O&M Cost
CP-IL
DAF-IL
$117 per year
$142 per year
$71.7 per year
$114 per year
39%
20%
'Numbers in this table were calculated using more significant figures than shown.
2136 of the 1,742 total industrial laundries are excluded from compliance under this criterion.
3The costs estimated for proposal (62 FR 66181; December 17, 1997) are based on treatment-in-place information from
the detailed questionnaire for the 1993 operating year.
4The costs were estimated based on the treatment-in-place information in the UTSA/TRSA survey for the 1998
operating year (presented in the Notice of Data Availability, 63 FR71054; December 23, 1998).
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                                                  Chapter 11 - Costs of Technology Bases for Regulatory Options

using the UTSA/TRSA survey data for the CP-IL and DAF-IL regulatory options with the 1
Million/255 K exclusion.  The costs were calculated in 1993 dollars using the assumptions and
methodologies described previously in this chapter.  The capital costs decreased by 107 million
dollars and 126 million dollars (21 percent and 30 percent) from 1993 to 1998 in the CP-IL and
DAF-IL options, respectively. The annual O&M costs decreased by 45 million dollars and 28
million dollars (39 percent and 20 percent) from 1993 to 1998 in the CP-IL and DAF-IL options,
respectively.  Based on this comparison, EPA estimates that the actual costs for the industrial
laundries industry to comply with the regulatory options (regardless of the specific exclusion)
would be less in both capital and annual  O&M costs than the costs calculated for the final  action,
based on the 1993 operating year.

11.6         References

1.            U.S. Environmental Protection Agency. Economic Assessment for the Final Action
             Regarding Pretreatment Standards for the Industrial Laundries Point Source
             Category ^Revised February 20001 EPA-821-R-00-004,  Washington, D.C.,
             February 2000.

2.            "Economic Indicators."  Chemical Engineering. March 1994, page 182.

3.            The Richardson Rapid System Process Plant Construction Estimating Standards.
             Volume 4: Process Equipment, 1994.

4.            Memorandum: Revised Labor Costs for the Industrial Laundries Cost Model,
             March 19, 1999.

5.            U.S. Department of Energy. Monthly Energy Review. DOE/EIA-0035(94/03),
             March 1994.

6.            Eastern Research Group, Inc. DAF and CP Cost Optimization Allowance
             Documentation.  Prepared for the U.S.  Environmental Protection Agency, Office
             of Water, Washington, D.C., June 1999.

7.            Eastern Research Group, Inc. Stream Splitting Cost Module Documentation for
             the Industrial Laundries Cost Model. Prepared for the U.S. Environmental
             Protection Agency, Office of Water, Washington, D.C., November 1997.

8.            Eastern Research Group, Inc. Pump Cost Module Documentation for the
             Industrial Laundries Cost Model. Prepared for the U.S. Environmental Protection
             Agency, Office of Water, Washington, D.C., November 1997.

9.            Eastern Research Group, Inc. Shaker Screen Cost Module Documentation for the
             Industrial Laundries Cost Model. Prepared for the U.S. Environmental Protection
             Agency, Office of Water, Washington, D.C., November 1997.
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                                                  Chapter 11 - Costs of Technology Bases for Regulatory Options

10.          Peters, Max S. et al. Plant Design and Economics for Chemical Engineers. Fourth
             Edition. McGraw-Hill, Inc., 1991.

11.          Eastern Research Group, Inc. Equalization Cost Module Documentation for the
             Industrial Laundries Cost Model. Prepared for the U.S. Environmental Protection
             Agency, Office of Water, Washington, D.C., November 1997.

12.          Memorandum: Comparison of Dissolved Air Flotation (DAF) and Chemical
             Precipitation Dewatered Sludge Generation Rates and Disposal Costs as Reported
             by Industry and as Calculated by the Industrial Laundries Cost Model, June 30,
             1999.

13.          U.S. Environmental Protection Agency.  Guidance Document for Effluent
             Discharges from the Auto and Other Laundries Point Source Category. Office of
             Water and Waste Management, February 1982.

14.          Eastern Research Group, Inc. Dissolved Air Flotation Cost Module
             Documentation for the Industrial Laundries Cost Model. Prepared for the U.S.
             Environmental Protection Agency, Office of Water, Washington, D.C., November
             1997.

15.          Bartman, Gary H. Crossflow Microfiltration. A Cost Effective Approach to Treat
             Metals.  Oil and Grease in the Industrial Laundries and Metal Finishing Industries.
             EPOC Filtration and Separation Systems, Fresno, CA, February 1993.

16.          Eastern Research Group, Inc. Chemical  Precipitation Cost Module Documentation
             for the Industrial Laundries Cost Model. Prepared for the U.S.  Environmental
             Protection Agency, Office of Water, Washington, D.C., November 1997.

17.          Eastern Research Group, Inc. Filter Press Cost Module Documentation for the
             Industrial Laundries Cost Model. Prepared for the U.S. Environmental Protection
             Agency, Office of Water, Washington, D.C., November 1997.

18.          Trimble, D. "Neutralizing Alkaline Wastewaters."  Textile Rental. November
             1994, pages 80-82.

19.          Eastern Research Group, Inc. pH Adjustment Cost Module Documentation for the
             Industrial Laundries Cost Model. Prepared for the U.S. Environmental Protection
             Agency, Office of Water, Washington, D.C., November 1997.

20.          Eastern Research Group, Inc. Building Cost Module Documentation for the
             Industrial Laundries Cost Model. Prepared for the U.S. Environmental Protection
             Agency, Office of Water, Washington, D.C., June 1999.
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                                                    Chapter 11 - Costs of Technology Bases for Regulatory Options

21.           Eastern Research Group, Inc. Contract Haul Cost Module Documentation for the
              Industrial Laundries Cost Model. Prepared for the U.S. Environmental Protection
              Agency, Office of Water, Washington, D.C., November 1997.

22.           Eastern Research Group, Inc. Monitoring Cost Estimate. Prepared for the U.S.
              Environmental Protection Agency, Office of Water, Washington, D.C., May 1997.
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                                                                      Chapter 12 - Glossary of Terms

                                     CHAPTER 12

                                GLOSSARY OF TERMS

2LIM: A term used by EPA to designate "Combo" technology control options on which the
standards are based on either DAF or chemical precipitation treatment technologies, as
appropriate.  The specific set of standards that are applied is based on which technology was
determined to be less expensive to install and operate at a facility or was reported to be in place at
the facility.

Absorbents: Substance used to absorb leaks, spills, and sprays around machinery and
workstations.

Administrator:  The Administrator of the U.S. Environmental Protection Agency.

All: A term used by EPA to designate technology control options that treat the total facility
process wastewater stream.

Annually: For purposes of the exclusion,  annually would mean per calendar year.

Agency:  The U.S. Environmental Protection Agency.

BAT:  The best available technology economically  achievable, as described in section 304(b)(2)
of the Clean Water Act.
       The best conventional pollutant control technology, as described in section 304(b)(4) of
the Clean Water Act.

Bench-scale operation: Laboratory testing of materials, methods, or processes on a small scale,
such as on a laboratory worktable.

BMP or BMPs: Best management practice(s), as described in section 304(e) of the Clean Water
Act or as authorized by section 402 of the CWA.

BOD5: Five-day biochemical oxygen demand. A measure of biochemical decomposition of
organic matter in a water sample. It is determined by measuring the dissolved oxygen consumed
by microorganisms to oxidize the organic contaminants in a water sample under standard
laboratory conditions of five days and 20 ฐC. BOD5 is not related to the oxygen requirements in
chemical combustion.

BPT:  The best practicable control technology currently available, as described in section
304(b)(l) of the Clean Water Act.

Buffing pads: Items used to polish floors.
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                                                                     Chapter 12 - Glossary of Terms

CAA:  Clean Air Act. The Air Pollution Prevention and Control Act (42 U.S.C. 7401 et. seq.).
as amended, inter alia, by the Clean Air Act Amendments of 1990 (Public Law 101-549, 104 Stat.
2399).

CEB:  Chemical emulsion breaking.  A term used by EPA to designate a technology control
option  on which the standards are based on chemical emulsion breaking treatment of the
wastewater generated from laundering of heavy industrial textile items (e.g., shop towels, printer
towels/rags, mops, fender covers, and filters).

CFR:  Code of Federal Regulations, published by the U.S. Government Printing Office.  A
codification of the general and permanent rules published in the Federal Register by the Executive
departments and agencies of the federal government.

Clean  room garments:  Used in particle- and static-free environments by computer
manufacturing, pharmaceutical, biotechnology, aerospace, and other customers to control
contamination  in production areas.

CN: Abbreviation for total cyanide.

COD:  Chemical oxygen demand - A nonconventional bulk parameter that measures the total
oxygen-consuming capacity of wastewater.  This parameter is a  measure of materials in water or
wastewater that are biodegradable and materials that are resistant (refractory) to biodegradation.
Refractory compounds slowly exert demand on downstream receiving water resources. Certain
of the compounds measured by this parameter have been found to have carcinogenic, mutagenic,
and similar adverse effects, either singly or in combination. It is expressed as the amount of
oxygen consumed by  a chemical oxidant in a specific test.

Combo: A term used by EPA to designate technology control options on which the standards are
based on a combination of DAF and chemical  precipitation treatment technologies. The set of
standards are compiled by taking the higher concentration from either DAF  or chemical
precipitation treatment of each pollutant.

Contract hauling: The removal of any waste stream from the plant or facility by a company
authorized to transport and dispose of the waste, excluding discharges to sewers or surface
waters.

Control authority:  (1) The POTW if the POTW's submission for its pretreatment program
(ง403.3(t)(l)) has been approved in accordance with the requirements of ง403.11; or (2) the
approval authority if the  submission has not been approved.

Conventional  pollutants:  Constituents of wastewater as determined in section 304(a)(4) of the
Clean Water Act and  the regulations thereunder (i.e., biochemical oxygen demand (BOD5), total
suspended solids (TSS), oil and grease, fecal coliform, and pH).
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                                                                      Chapter 12 - Glossary of Terms

Cooperative:  An enterprise or organization owned by and operated for the benefit of those using
its services.  For purposes of this rule, a laundry serving like facilities owned by and/or operated
for the benefit of those facilities.

CP:  Chemical precipitation. A term used by EPA to designate technology control options on
which the standards are based on chemical precipitation treatment of all or part of the wastewater.

CWA: Clean Water Act. The Federal Water Pollution Control Act Amendments of 1972 (33
U.S.C. 1251 et sea.).

DAF:  Dissolved air flotation. A term used by EPA to designate technology control options on
which the standards are based on DAF treatment of all or part of the wastewater.

Daily discharge: The discharge of a pollutant measured during any calendar day or any 24-hour
period.

Denim prewash:  Washing of denim material or manufactured denim items prior to sale to soften
the fabric and/or alter its appearance.  This is achieved through use of chemicals and processes
such as stone,  acid, and ice washing.

Detailed questionnaire:  1994 Industrial Laundries Questionnaire. A questionnaire sent by EPA
to collect detailed technical and economic information from industrial laundry and linen facilities
for the 1993 operating year, under authority of section 308 of the Clean Water Act. The
questionnaire was sent to those facilities likely to be affected by promulgation of effluent
limitations guidelines, pretreatment standards, and new source performance standards for their
industry.

DMQ: 1995 Detailed Monitoring Questionnaire.  A questionnaire sent by EPA to 37 industrial
laundries based on responses to the detailed questionnaire that requested available monitoring
data for 1993.

Direct discharger:  The discharge of a pollutant or pollutants directly to a water of the United
States with or without treatment by the discharger.

Dry cleaning: The  cleaning of fabrics using an organic-based solvent rather than water-based
detergent solution.

Dual-phase washing: The dry cleaning and water washing of laundry items in series without
drying the items between the solvent and water phases.

Effluent:  Wastewater discharges.

EPA:  The U.S. Environmental Protection Agency.
                                           12-2

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                                                                      Chapter 12 - Glossary of Terms

Facility: All contiguous property owned, operated, leased or under control of the same person,
or corporate or business entity. The contiguous property may be divided by public or private
right-of-way.

Fender covers: Items used in the automobile repair and services industry to protect the fenders of
automobiles from oil, grease, dirt, and other damage.

FR:  Federal Register, published by the U.S. Government Printing Office, Washington, D.C.  A
publication making available to the public regulations and legal notices issued by federal agencies.

HAPS: Hazardous air pollutants.

Hazardous waste: Any material that meets the Resource Conservation and Recovery Act
definition of "hazardous waste" contained in 40 CFR Part 261.

Health care items:  Items such as hospital gowns, linen, and towels used in hospitals, doctors'
offices, and dentists' offices.

Heavy: A term used by EPA to designate treatment control options that treat facility wastewater
generated from the laundering of heavy industrial textile items (e.g., shop towels, printer
towels/rags, mops, fender covers, and filters) and are based on standards developed from
wastewater generated from the laundering of heavy industrial textile items.

HEM: Hexane extractable material.  A method-defined parameter that measures the presence of
relatively nonvolatile hydrocarbons, vegetable oils, animal fats, waxes, soaps, greases,  and related
material that are extractable in the solvent n-hexane.  This parameter does not include materials
that volatilize at temperatures below 85ฐC (see Method 1664, promulgated at 64 FR 26315; May
14, 1999). EPA uses the term "HEM" synonymously with the conventional pollutant oil and
grease (O&G).

Household laundry: Items that are "noncommercially" owned or are domestic in nature. These
items may range from clothing to small rugs.

Indirect discharge:  The discharge of a pollutant or pollutants to a publicly owned treatment
works (POTW) with  or without pretreatment by the discharger.

Industrial laundry:  Any facility that launders industrial textile items from off site as a business
activity (i.e., launders industrial textile items for other business entities for a fee or through a
cooperative agreement). Either the industrial facility or the off-site customer may own the
industrial laundered textile items; this includes textile rental companies that perform laundering
operations.
                                           12-4

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                                                                      Chapter 12 - Glossary of Terms

IL: A term used by EPA to designate treatment control options that treat the facility wastewater
generated from the laundering of industrial textile items and are based on standards developed
from wastewater generated from the laundering of all items.

Industrial  textile items: Items such as, but not limited to, industrial: shop towels, printer
towels/rags, furniture towels, rags, mops,  mats, rugs, tool covers, fender covers, dust-control
items, gloves, buffing pads, absorbents, uniforms, and filters.

Industrial  towels: Items such as, but not limited to: shop towels, printer towels/rags, and
furniture towels.

Inorganic wastewater treatment chemicals: Inorganic chemicals that are commonly used in
wastewater treatment systems to aid in the removal of pollutants through physical/chemical
technologies such as chemical precipitation, flocculation, neutralization, chemical oxidation,
hydrolysis, and/or adsorption.

Laundering: Washing items with water, including water washing following dry cleaning.

Linen:  Items such as sheets, pillow cases, blankets, bath towels and washcloths, hospital gowns
and robes, tablecloths, napkins, tableskirts, kitchen textile items, continuous roll towels,
laboratory coats, family laundry, executive wear, mattress pads, incontinence pads, and diapers.
This list is intended to be all-inclusive.

Linen flatwork/full dry: Items such as napkins, tablecloths, and sheets.

LTA: Long-term average.  For purposes of the pretreatment standards, average pollutant levels
achieved over a period of time by a facility, subcategory, or technology  option.  LTAs were used
in developing the standards in the industrial laundries proposed rule.

Minimum  level:  The level at which an analytical system gives recognizable signals and an
acceptable calibration point.

Miscellaneous not our goods (NOG):  Items that are commercially owned by an outside
company. Industrial laundries do not always know the breakdown of these items.

New source: As defined in 40 CFR 122.2, 122.29, and 403.3 (k), a new source is any building,
structure, facility, or installation from which there is or may be a discharge of pollutants, the
construction of which commenced (1) for  purposes of compliance with New Source Performance
Standards, after the promulgation of such  standards under CWA section 306; or (2) for the
purposes of compliance with Pretreatment Standards for New Sources, after the publication of
proposed standards under CWA section 307(c), if such standards are thereafter promulgated in
accordance with that section.

Noncontact cooling water: Water used for cooling which does not come into direct contact with
any raw material, intermediate product, by-product, waste product, or finished product.  This
term is not intended to relate to air conditioning systems.

                                           12-5

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                                                                      Chapter 12 - Glossary of Terms

Non-water quality environmental impact: An environmental impact of a control or treatment
technology, other than to surface waters.

Noncontinuous or intermittent discharge: Discharge of wastewaters stored for periods of at
least 24 hours and released on a batch basis.

Nonconventional pollutants:  Pollutants that are neither conventional pollutants nor toxic
pollutants listed at 40 CFR Section 401.

Nondetect value: A concentration-based measurement reported below the minimum level that
can reliably be measured by the analytical method for the pollutant.

NPDES: The National Pollutant Discharge Elimination System, a federal program requiring
industry dischargers, including municipalities, to obtain permits to discharge pollutants to the
nation's water, under section 402 of the CWA.

NPM: Non-polar material.  A method-defined parameter that measures the substances that
remain after n-hexane extractable material is exposed to silica gel. NPM contains straight and
branched chain hydrocarbons and other chemical substances in which there are either no mixture
of atoms of different types or these mixtures are "balanced" in the molecule (see Method 1664,
promulgated at 64 FR 26315; May 14, 1999).  EPA uses the term "NPM" synonymously with
silica gel treated-hexane  extractable material (SGT-HEM).

NRDC: Natural Resources Defense Council.

NSPS: New source performance standards. This term refers to standards for new sources under
section 306 of the CWA.

PC-Only:  Prelaundering organics control.  A term used by EPA to designate a technology
control option that processes industrial towels (e.g., shop towels, printer towels/rags) in an
air/steam tumbler to remove volatile organic compounds prior to water washing.

Off site: "Off site" means outside the boundaries of the facility.

On site:  "On site" means within the boundaries of the facility.

Oil and grease (O&G): A method-defined parameter that measures the presence of relatively
nonvolatile hydrocarbons, vegetable oils, animal fats, waxes, soaps, greases, and related materials
that are extractable in Freon 113 (l,l,2-trichloro-l,2,2-trifluoroethane).  This parameter does not
include materials that volatilize at temperatures below 75ฐC (see Method 413.1).  O&G is a
conventional pollutant as defined in section 304(a)(4) of the Clean Water Act and in 40 CFR Part
401.16. O&G is also measured by the hexane extractable material (HEM) method (see Method
1664, promulgated at 64 FR 26315; May 14, 1999).

P2: Pollution prevention.
                                          12-6

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                                                                      Chapter 12 - Glossary of Terms

Pilot-scale:  The trial operation of processing equipment which is the intermediate stage between
laboratory experimentation and full-scale operation in the development of a new process or
product.

PM:  Paniculate matter.

Point source category:  A category of sources of water pollutants that are included within the
definition of "point source" in section 502(14) of the CWA.

Pollutant (to water):  Dredged spoil, solid waste, incinerator residue, filter backwash, sewage,
garbage, sewage sludge, munitions, chemical wastes, biological materials, certain radioactive
materials, heat, wrecked or discarded equipment, rock, sand, cellar dirt, and industrial, municipal,
and agricultural waste discharged into water.  See CWA Section 502(6); 40 CFR 122.2.

POTW or POTWs:  Publicly owned treatment works.  A treatment works as defined by Section
212 of the CWA, which is owned by a state or municipality (as defined by Section 502(4) of the
Act).  This definition includes any devices and systems used in the storage, treatment, recycling
and reclamation of municipal sewage or industrial wastes of a liquid nature.  It also includes
sewers,  pipes, and other conveyances only if they convey wastewater to a POTW Treatment
Plant. The term also means the municipality as defined in Section 502(4) of the CWA, which has
jurisdiction over the indirect discharges to and the discharges from such a treatment works.

PPA  Pollution Prevention Act of 1990 (42 U.S.C. 13101 et seg., Pub.L. 101-508, November 5,
1990).

PDS: Preliminary Data Summary for the Industrial Laundries Industry. A document that was
prepared by  EPA summarizing sampling data from five industrial laundries collected between
1985  and 1987.

Pretreatment standard: A regulation specifying industrial wastewater effluent quality required
for discharge to a POTW.

Printer towels/rags:  Towels used to clean solvents, inks, or soils from various objects or to wipe
up spilled solvents and other liquids until they are saturated. They are commonly used in
publishing and printing shops.

Priority pollutants:  The toxic pollutants listed in 40 CFR Part 423,  Appendix A.

Process wastewater collection system: A piece of equipment, structure, or transport mechanism
used in conveying or storing a process wastewater stream. Examples of process wastewater
collection system equipment include individual drain systems, wastewater tanks, surface
impoundments, and containers.

PSES: Pretreatment standards for existing sources of indirect discharges, under section 307(b) of
the CWA.
                                           12-7

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                                                                      Chapter 12 - Glossary of Terms

PSNS: Pretreatment standards for new sources of indirect discharges, under section 307(b) and
(c) of the CWA.

RCRA: Resource Conservation and Recovery Act of 1976, as amended (42 U.S.C. 6901, et
sea.).

RREL: Risk Reduction Engineering Laboratory.

Reuse: The use in laundry operations of all or part of a waste stream produced by an operation
which would otherwise be disposed of, whether or not the stream is treated prior to reuse, and
whether the reused waste stream is fed to the same operation or to another operation.

RFA  The Regulatory Flexibility Act as amended by SBREFA (5 U.S.C. 60 et seq.Y

Rewash items: Items that require a second washing to be in an acceptable state for return to the
customer.

Screener questionnaire:  Four different two-page questionnaires mailed by EPA to facilities in
the laundries industry to develop the scope of the industrial laundries regulation, identify the
population of the industrial laundries industry, and select facilities to receive the more detailed
questionnaire.

SB A:  Small Business Administration.

SBREFA:  Small Business Regulatory Enforcement Fairness Act of 1996 (P.L. 104-121, March
29,  1996).

Septic system: A system which collects and treats wastewater, particularly sanitary sewage. The
system is usually composed of a septic tank which settles and anaerobically degrades solid waste,
and a drainfield which relies on soil to adsorb or filter biological contaminants.  Solid wastes are
periodically pumped out of the septic tank and hauled to off-site disposal.

SGT-HEM:  Silica gel treated-hexane extractable material.  A method-defined parameter that
measures the presence of mineral  oils that are extractable in the solvent n-hexane and not
adsorbed by silica gel.  This parameter does not include materials that volatilize at temperatures
below 85ฐC (see Method  1664, promulgated at 64 FR 26315; May 14, 1999). EPA defines SGT-
HEM as non-polar material (NPM). Throughout this document and the Industrial Laundries
Administrative Record, EPA refers to SGT-HEM as total  petroleum hydrocarbon (TPH).

Shop towels:  Towels used to clean oil and grease or soils from various objects or to wipe up oil
and grease and other liquids until they are saturated. They are commonly used in machine shops,
automotive repair shops, and gas stations.

SIC: Standard Industrial Classification. A numerical categorization system used by the U.S.
Department of Commerce to  denote segments of industry. An SIC code refers to the principal
product, or group of products, produced or distributed, or to services rendered by an operating

                                          12-8

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                                                                      Chapter 12 - Glossary of Terms

establishment. SIC codes are used to group establishments by the primary activity in which they
are engaged.

Small business:  Businesses with annual revenues less than $10.5 million. This is the higher of
the two Small Business Administration definitions of small businesses for SIC codes 7218 and
7213.

Source reduction: The reduction or elimination of waste generation at the source, usually within
a process. Any practice that:  1) reduces the amount of any hazardous substance, pollutant, or
contaminant entering any waste stream or otherwise released into the environment (including
fugitive emissions) prior to recycling, treatment, or  disposal; and 2) reduces the hazards to public
health and the environment associated with the release of such substances, pollutants, or
contaminants.

Toxic pollutants: The pollutants designated by EPA as toxic in 40 CFR Part 401.15. Also
known as priority pollutants.

TOC: Total organic carbon.  A nonconventional bulk parameter that measures the total organic
content of wastewater. Unlike five-day biochemical oxygen demand (BOD5) or chemical oxygen
demand (COD), TOC is independent of the oxidation state of the organic matter and does not
measure other organically bound elements, such as nitrogen and hydrogen, and inorganics that can
contribute to the oxygen demand measured by BOD5 and COD.  TOC methods utilize heat and
oxygen, ultraviolet irradiation, chemical oxidants, or combinations of these oxidants to convert
organic carbon to carbon dioxide (CO2). The CO2 is then measured by various methods.

TPH:  Total petroleum hydrocarbon. A method-defined parameter that measures the presence of
mineral oils that are extractable in Freon 113 (l,l,2-trichloro-l,2,2-trifluoroethane) and not
absorbed by silica gel. This parameter does not include materials that volatilize at temperatures
below 70 ฐC (see Method 418.1).  Throughout this document and the Industrial Laundries
Administrative Record, EPA refers to silica gel treated-hexane extractable material (SGT-HEM)
as TPH.

TRSA: Textile Rental Services Association of America.

TSCA Toxic Substances Control Act (15 U.S.C. 2601 et seg.)

TSS:  Total suspended solids.

Towel Only: A term used by EPA to designate a technology control option that treats facility
wastewater generated from the laundering of industrial towels (e.g.,  shop towels and printer
towels/rags) with dissolved air flotation (DAF) and  is based on standards developed from
wastewater generated from the laundering of industrial towels and treated by DAF technology.

TWL: A term used by EPA to designate treatment  control options that treat facility wastewater
generated from the laundering of heavy industrial textile items (e.g., shop towels, printer
                                          12-9

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                                                                       Chapter 12 - Glossary of Terms

towels/rags, mops, fender covers, and filters) and are based on standards developed from
wastewater generated from the laundering of all items.

UTS A: Uniform and Textile Service Association.

Variability factor: The daily variability factor is the ratio of the estimated 99th percentile of the
distribution of daily values divided by the expected value, median or mean, of the distribution of
the daily data. The monthly  variability factor is the estimated 95th percentile of the distribution of
the monthly averages of the data divided by the expected value of the monthly averages.

VOCs: Volatile organic compounds.

Water washing:  The process of washing laundry items in which water is the solvent used.

Waters of the United States:  The same meaning set forth in 40 CFR 122.2.

Wet air pollution or odor pollution control system scrubbers:  Any equipment using water or
water mixtures to control emissions of dusts, odors, volatiles, sprays, or other air pollutants.

Zero discharge: No discharge of process wastewater pollutants to waters of the United States or
to a POTW.
                                           12-10

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                                   Appendix A - Tables Referenced in Chapter 3
          Appendix A




Tables Referenced in Chapter 3

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                                                          Appendix A - Tables Referenced in Chapter 3
                                     Table A-l
             Metal and Elemental Constituents Measured Under the
                     Industrial Laundries Sampling Program
                                 (EPA Method 1620)
Metal and Elemental Constituents
Aluminum
Antimony
Arsenic
Barium
Beryllium
Boron
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Molybdenum
Nickel
Selenium
Silver
Sodium
Thallium
Tin
Titanium
Vanadium
Yttrium
Zinc
Additional Metal and Elemental Constituents1 Not Subject to Rigorous QA/QC
Procedures Per Method 1620:
Bismuth
Cerium
Dysprosium
Erbium
Europium
Gadolinium
Gallium
Germanium
Gold
Hafnium
Holmium
Indium
Iodine
Iridium
Lanthanum
Lithium
Lutetium
Neodymium
Niobium
Osmium
Palladium
Phosphorus
Platinum
Potassium
Praseodymium
Rhenium
Rhodium
Ruthenium
Samarium
Scandium
Silicon
Strontium
Sulfur
Tantalum
Tellurium
Terbium
Thorium
Thulium
Tungsten
Uranium
Ytterbium
Zirconium
'Analyses for these metals and elements were used for screening purposes, and the metals were not selected for
regulation in this rulemaking.
                                        A-l

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                                                                   Appendix A - Tables Referenced in Chapter 3
                                         Table A-2
                       Organic Constituents Measured Under
                    the Industrial Laundries Sampling Program
                               (EPA Methods 1624 and 1625)
                         Volatile Organic Constituents (EPA Method 1624)
Acrylonitrile
Benzene
Bromodichloromethane
Bromomethane
Carbon Bisulfide
Chloroacetonitrile
Chlorobenzene
Chloroethane
Chloroform
Chloromethane
Cis-1,3-dichloropropene
Crotonaldehyde
Dibromochloromethane
Dibromomethane
Diethyl Ether
Ethyl Cyanide
Ethyl Methacrylate
Ethylbenzene
lodomethane
Isobutyl Alcohol
m-Xylene
Methyl Methacrylate
Methylene Chloride
o+p-Xylene
Tetrachloroethene
Tetrachloromethane
Toluene
trans-1,2-Dichloroethene
trans-1,3-Dichloropropene
trans-1,4-Dichloro-2-butene
Tribromomethane
Trichloroethene
Trichlorofluoromethane
Vinyl Acetate
Vinyl Chloride
1,1 -Dichloroethane
1,1 -Dichloroethene
1,1,1 -Trichloroethane
1,1,1,2-Tetrachloroethane
1,1,2-Trichloroethane
1,1,2,2-Tetrachloroethane
1,2-Dibromoethane
1,2-Dichloroethane
1,2-Dichloropropane
1,2,3-Trichloropropane
1,3-Butadiene, 2-Chloro
1,3 -Dichloropropane
1,4-Dioxane
2-Butanone
2-Chloroethyl Vinyl Ether
2-Hexanone
2-Propanone
2-Propen-l-ol
2-Propenal
2-Propenenitrile, 2-Methyl-
3 - Chloropropene
4-Methyl-2-pentanone
                                              A-2

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                                                                       Appendix A - Tables Referenced in Chapter 3
                                   Table A-2 (Continued)
                         Semivolatile Organic Constituents (EPA Method 1625)
Acenaphthene
Acenaphthylene
Acetophenone
alpha-Terpineol
Aniline
Aniline, 2,4,5-Trimethyl-
Anthracene
Aramite
Benzanthrone
Benzenethiol
Benzidine
Benzo (a) anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(ghi)perylene
Benzo(k)fluoranthene
Benzoic Acid
Benzonitrile, 3,5-Dibromo-4-hydroxy-
Benzyl Alcohol
beta-Naphthylamine
Biphenyl
Biphenyl, 4-Nitro
Bis(2-Chloroethoxy)methane
Bis(2-Chloroethyl) ether
Bis(2-Chloroisopropyl) ether
Bis(2-ethylhexyl) phthalate
Butyl benzyl phthalate
Carbazole
Chrysene
Ciodrin
Crotoxyphos
Di-n-butyl phthalate
Di-n-octyl phthalate
Di-n-Propylnitrosamine
Dibenzo(a,h)anthracene
Dibenzofuran
Dibenzothiophene
Diethyl Phthalate
Dimethyl Phthalate
Dimethyl Sulfone
Diphenyl Ether
Diphenylamine
Diphenyldisulfide
Ethane, Pentachloro-
Ethyl Methanesulfonate
Ethylenethiourea	
Fluoranthene
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclopentadiene
Hexachloroethane
Hexachloropropene
Hexanoic Acid
Indeno(l ,2,3-Cd)pyrene
Isophorone
Isosafrole
Longifolene
Malachite Green
Mestranol
Methapyrilene
Methyl Methanesulfonate
n-Decane
n-Docosane
n-Dodecane
n-Eicosane
n-Hexacosane
n-Hexadecane
N-Nitrosodi-n-butylamine
N-Nitrosodiethylamine
N-Nitrosodimethylamine
N-Nitrosodiphenylamine
N-Nitrosomethylethylamine
N-Nitrosomethylphenylamine
N-Nitro somorpholine
N-Nitrosopiperidine
n-Octacosane
n-Octadecane
n-Tetracosane
n-Tetradecane
n-Triacontane
N,N-Dimethylform amide
Naphthalene
Nitrobenzene
o-Anisidine
o-Cresol
o-Toluidine
o-Toluidine, 5-Chloro-
p-Chloroaniline
p-Cresol
p-Cymene
p-Dimethylaminoazobenzene
p-Nitroaniline	
                                                A-3

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                                                                       Appendix A - Tables Referenced in Chapter 3
                                   Table A-2  (Continued)
                   Semivolatile Organic Constituents (EPA Method 1625) (Continued)
Pentachlorobenzene
Pentachlorophenol
Pentamethy Ibenzene
Perylene
Phenacetin
Phenanthrene
Phenol
Phenol, 2-Methyl-4,6-Dinitro-
Phenothiazine
Pronamide
Pyrene
Pyridine
Resorcinol
Safrole
Squalene
Styrene
Thianaphthene
Thioacetamide
Thioxanthe-9-one
Toluene, 2,4-Diamino-
Triphenylene
Tripropyleneglycol Methyl Ether
1 -Bromo-2-chlorobenzene
1 -Bromo-3-chlorobenzene
1 -Chloro-3-nitrobenzene
1 -Methylfluorene
1 -Methylphenanthrene
1 -Naphthylamine
1 -Phenylnaphthalene
1,2-Dibromo-3 -chloropropane
1,2-Dichlorobenzene
1,2-Diphenylhydrazine
1,2,3 -Trichlorobenzene
1,2,3-Trimethoxybenzene
1,2,4-Trichlorobenzene
1,2,4,5-Tetrachlorobenzene
1,2:3,4-Diepoxy butane
1,3-Dichloro-2-propanol
1,3 -Dichlorobenzene
1,3,5-Trithiane
1,4-Dichlorobenzene
1,4-Dinitrobenzene
1,4-Naphthoquinone
1,5-Naphthalenediamine
2-(Methylthio)benzothiazole
2-Chloronaphthalene
2-Chlorophenol
2-Isopropylnaphthalene
2-Methylbenzothioazole
2-Methylnaphthalene
2-Nitroaniline
2-Nitrophenol
2-Phenylnaphthalene
2-Picoline
2,3-Benzofluorene
2,3 -Dichloroaniline
2,3 -Dichloronitrobenzene
2,3,4,6-Tetrachlorophenol
2,3,6-Trichlorophenol
2,4-Dichlorophenol
2,4-Dimethylphenol
2,4-Dinitrophenol
2,4-Dinitrotoluene
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
2,6-Di-tert-butyl-p-benzoquinone
2,6-Dichloro-4-nitroaniline
2,6-Dichlorophenol
2,6-Dinitrotoluene
3-Methylcholanthrene
3-Nitro aniline
3,3' -Dichlorobenzidine
3,3' -Dimethoxy benzidine
3,6-Dimethy Iphenanthrene
4-Aminobiphenyl
4-Bromophenyl Phenyl Ether
4-Chloro-2-nitroaniline
4-Chloro-3-methylphenol
4-Chlorophenyl Phenyl Ether
4-Nitrophenol
4,4'-Methylenebis(2-chloroaniline)
4,5-Methylene Phenanthrene
5-Nitro-o-toluidine
7,12-Dimethy lbenz(a)anthracene
                                                 A-4

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                                                                   Appendix A - Tables Referenced in Chapter 3
                                          Table A-3
                            Additional Parameters Measured
                    in the  Industrial Laundries Sampling Program
Parameter
Biochemical Oxygen Demand (BOD5)
Chemical Oxygen Demand (COD)
Hexane Extractable Material (oil and grease)
PH
Phosphorus, Total
Silica Gel Treated-Hexane Extractable Material (total
petroleum hydrocarbons)
Surfacants
Total Solids
Total Hydrolyzable Phosphorus
Total Organic Carbon
Total Orthophosphate
Total Suspended Solids (TSS)
EPA Method
405. 11
410.11
410.21
1664 (proposed)2
150.11
365.21
1664 (proposed)2
5540C, 5540D3
160.31
365.21
415. 11
365.21
160.21
'U.S. Environmental Protection Agency. Methods for Chemical Analysis of Water and Wastes.  EPA-800-4-79-020,
Revised March 1983.

2U.S. Environmental Protection Agency. Method 1664: N-Hexane Extractable Material (HEM) and Silica Gel Treated
N-Hexane Extractable Material (SOT-HEM) by Extraction and Gravimetry (Oil and Grease and Total Petroleum
Hydrocarbons'). EPA-821-B-94-004b, April 1995.

3Standard Methods for the Examination of Water and Wastewater. A.D. Eaton, L.S.  Clesceri and A.E. Greenberg, eds.
19th Edition. American Public Health Association, Washington, D.C., 1995.
                                              A-5

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                                   Appendix B - Table Referenced in Chapter 4
          Appendix B




Table Referenced In Chapter 4

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                                         Appendix B - Table Referenced in Chapter 4
                     Table B-l

Industries for Which EPA Has Established Effluent
       Limitations Guidelines and Standards
CWA Part
405
406
407
408
409
410
411
412
413
414
415
417
418
419
420
421
422
423
424
425
426
427
428
429
430
431
432
433
434
435
436
Industry
Diary Products Processing
Grain Mills
Canned and Preserved Fruits and Vegetables Processing
Canned and Preserved Seafood Processing
Sugar Processing
Textile Mills
Cement Manufacturing
Feedlots
Electroplating
Organic Chemicals, Plastics and Synthetic Fibers
Inorganic Chemical Manufacturing
Soap and Detergent Manufacturing
Fertilizer Manufacturing
Petroleum Refining
Iron and Steel Manufacturing
Nonferrous Metals Manufacturing
Phosphate Manufacturing
Steam Electric Power Generating
Ferroalloy Manufacturing
Leather Tanning and Finishing
Glass Manufacturing
Asbestos Manufacturing
Rubber Manufacturing
Timber Products Processing
Pulp, Paper and Paperboard
The Builders' Paper and Boardmills
Meat Products
Metal Finishing
Coal Mining
Oil and Gas Extraction
Mineral and Mining Processing
                        B-l

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                               Appendix B - Table Referenced in Chapter 4
Table B-l (Continued)
CWA Part
439
440
443
446
447
454
455
457
458
459
460
461
463
464
465
466
467
468
469
471
Industry
Pharmaceutical Manufacturing
Ore Mining and Dressing
Paving and Roofing Materials (Tars and Asphalt)
Paint Formulating
Ink Formulating
Gum and Wood Chemicals Manufacturing
Pesticide Chemicals
Explosives Manufacturing
Carbon Black Manufacturing
Photographic Processing
Hospital
Battery Manufacturing
Plastics Molding and Forming
Metal Molding and Casting
Coil Coating
Porcelain Enameling
Aluminum Forming
Copper Forming
Electrical and Electronic Components
Nonferrous Metals Forming and Metal Powder
           B-2

-------
                                   Appendix C - Tables Referenced in Chapter 5
          Appendix C




Tables Referenced in Chapter 5

-------
                                                                                           Appendix C - Tables Referenced in Chapter 5
                                                         Table  C-l
                                              Priority Pollutant List1
   1 Acenaphthene
   2 Acrolein (2-Propenal)
   3 Acrylonitrile
   4 Benzene
   5 Benzidine
   6 Carbon Tetrachloride (Tetrachloromethane)
   7 Chlorobenzene
   8 1,2,4-Trichlorobenzene
   9 Hexachlorobenzene
   10  1,2-Dichloroethane
   11  1,1,1-Trichloroethane
   12  Hexachloroethane
   13  1,1-Dichloroethane
   14  1,1,2-Trichloroethane
   15  1,1,2,2-Tetrachloroethane
   16  Chloroethane
   17  Removed
   18  Bis(2-chloroethyl) Ether
   19  2-Chloroethyl Vinyl Ether (mixed)
   20  2-Chloronaphthalene
   21  2,4,6-Trichlorophenol
   22  Parachloro-m-cresol (4-Chloro-3-Methylphenol)
   23  Chloroform (Trichloromethane)
   24  2-Chlorophenol
   25  1,2-Dichlorobenzene
   26  1,3-Dichlorobenzene
   27  1,4-Dichlorobenzene
   28  3,3'-Dichlorobenzidine
   29  1,1-Dichloroethene
   30  1,2-Trans-Dichloroethene
   31  2,4-Dichlorophenol
   32  1,2-Dichloropropane
   33  1,3-Dichloropropylene (1,3-Dichloropropene)
   34  2,4-Dimethylphenol
   35  2,4-Dinitrotoluene
   36  2,6-Dinitrotoluene
   37  1,2-Diphenylhydrazine
   38  Ethylbenzene
   39  Fluoranthene
   40  4-Chlorophenyl Phenyl Ether
   41  4-Bromophenyl Phenyl Ether
   42  Bis(2-Chloroisopropyl) Ether
   43  Bis(2-Chloroethoxy) Methane
   44  Methylene Chloride (Dichloromethane)
   45  Methyl Chloride (Chloromethane)
   46  Methyl Bromide (Bromomethane)
   47  Bromoform (Tribromomethane)
   48  Dichlorobromomethane (Bromodichloromethane)
   49  Removed
   50  Removed
   51  Chlorodibromomethane (Dibromochloromethane)
   52  Hexachlorobutadiene
   53  Hexachlorocyclopentadiene
   54  Isophorone
   55  Naphthalene
   56  Nitrobenzene
   57  2-Nitrophenol
   58  4-Nitrophenol
   59  2,4-Dinitrophenol
   60  4,6-Dinitro-o-Cresol (Phenol, 2-methyl-4,6-dinitro)
   61  N-Nitrosodimethylamine
   62  N-Nitrosodiphenylamine
   63  N-Nitrosodi-n-propylamine (Di-n-propylnitrosamine)
   64  Pentachlorophenol
   65  Phenol
66  Bis(2-Ethylhexyl) Phthalate
67  Butyl Benzyl Phthalate
68  Di-n-butyl Phthalate
69  Di-n-octyl Phthalate
70  Diethyl Phthalate
71  Dimethyl Phthalate
72  Benzo(a)anthracene (1,2-Benzanthracene)
73  Benzo(a)pyrene (3,4-Benzopyrene)
74  Benzo(b)fluoranthene (3,4-Benzo fluoranthene)
75  Benzo(k)fluoranthene
76  Chrysene
77  Acenaphthylene
78  Anthracene
79  Benzo(ghi)perylene (1,12-Benzoperylene)
80  Fluorene
81  Phenanthrene
82  Dibenzo(a,h)anthracene (1,2,5,6-Dibenzanthracene)
83  Indeno(l,2,3-cd)pyrene (2,3-o-Phenylenepyrene)
84  Pyrene
85  Tetrachloroethylene (Tetrachloroethene)
86  Toluene
87  Trichloroethylene (Trichloroethene)
88  Vinyl Chloride (Chloroethylene)
89  Aldrin
90  Dieldrin
91  Chlordane (Technical Mixture & Metabolites)
92  4,4'-DDT (p,p'-DDT)
93  4,4'-DDE (p,p'-DDX)
94  4,4'-DDD (p,p'-TDE)
95  Alpha-endosulfan
96  Beta-endosulfan
97  Endosulfan Sulfate
98  Endrin
99  Endrin Aldehyde
100 Heptachlor
101 Heptachlor Epoxide
102 Alpha-BHC
103 Beta-BHC
104 Gamma-BHC (Lindane)
105 Delta-BHC
106 PCB-1242(Arochlor  1242)
107 PCB-1254 (Arochlor  1254)
108 PCB-1221 (Arochlor  1221)
109 PCB-1232 (Arochlor  1232)
110 PCB-1248 (Arochlor  1248)
111 PCB-1260 (Arochlor  1260)
112 PCB-1016 (Arochlor  1016)
113 Toxaphene
114 Antimony (total)
115 Arsenic (total)
116 Asbestos (fibrous)
117 Beryllium (total)
118 Cadmium (total)
119 Chromium (total)
120 Copper (total)
121 Cyanide (total)
122 Lead (total)
123 Mercury (total)
124 Nickel (total)
125 Selenium (total)
126 Silver (total)
127 Thallium (total)
128 Zinc (total)
129 2,3,7,8-Tetrachlorodibenzo-p-Dioxin
'Priority pollutants are numbered 1 through 129 but include 126 pollutants since EPA removed three pollutants from the list (Numbers 17, 49, and
50).
Source:  40 CFR Part 423, Appendix A.
                                                               C-l

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                                     Appendix C - Tables Referenced in Chapter 5
               Table C-2
Pollutants Considered for Regulation
POLLUTANT
1,1,1 ,2-TETRACHLOROETHANE
1 , 1 , 1 -TRICHLOROETHANE
1 , 1 ,2,2-TETRACHLOROETHANE
1 , 1 ,2-TRICHLOROETHANE
1 , 1 -DICHLOROETHANE
1 , 1 -DICHLOROETHENE
1 ,2,3-TRICHLOROBENZENE
1,2,3-TRICHLOROPROPANE
1 ,2,3 -TRIMETHOXYBENZENE
1 ,2,4,5-TETRACHLOROBENZENE
1 ,2,4-TRICHLOROBENZENE
l,2-DIBROMO-3-CHLOROPROPANE
1 ,2-DIBROMOETHANE
1 ,2-DICHLOROBENZENE
1 ,2-DICHLOROETHANE
1 ,2-DICHLOROPROPANE
1 ,2-DIPHENYLH YDRAZINE
1 ,2 : 3 ,4-DIEPOXYBUTANE
1,3,5-TRITHIANE
1,3-BUTADIENE, 2-CHLORO
l,3-DICHLORO-2-PROPANOL
1,3-DICHLOROBENZENE
1 ,3-DICHLOROPROPANE
1 ,4-DICHLOROBENZENE
1 ,4-DINITROBENZENE
1,4-DIOXANE
1 ,4-NAPHTHOQUINONE
1 ,5-NAPHTHALENEDIAMINE
1 -BROMO-2-CHLOROBENZENE
1 -BROMO-3-CHLOROBENZENE
1 -CHLORO-3-NITROBENZENE
1 -METH YLFLUORENE
ANALYTICAL METHOD
1624
1624
1624
1624
1624
1624
1625
1624
1625
1625
1625
1625
1624
1625
1624
1624
1625
1625
1625
1624
1625
1625
1624
1625
1625
1624
1625
1625
1625
1625
1625
1625
                  C-2

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                              Appendix C - Tables Referenced in Chapter 5
Table C-2 (Continued)
POLLUTANT
1 -METHYLPHENANTHRENE
1-NAPHTHYLAMINE
1 -PHENYLNAPHTHALENE
2,3,4,6-TETRACHLOROPHENOL
2,3,6-TRICHLOROPHENOL
2,3-BENZOFLUORENE
2,3-DICHLOROANILINE
2,3-DICHLORONITROBENZENE
2,4,5-TRICHLOROPHENOL
2,4,6-TRICHLOROPHENOL
2,4-DICHLOROPHENOL
2,4-DIMETHYLPHENOL
2,4-DINITROPHENOL
2,4-DINITROTOLUENE
2,6-DI-TERT-BUTYL-P-BENZOQUINONE
2,6-DICHLORO-4-NITROANILINE
2,6-DICHLOROPHENOL
2,6-DINITROTOLUENE
2-(METHYLTHIO)BENZOTHIAZOLE
2-BUTANONE
2-CHLOROETHYL VINYL ETHER
2-CHLORONAPHTHALENE
2-CHLOROPHENOL
2-HEXANONE
2-ISOPROPYLNAPHTHALENE
2-METHYLBENZOTHIOAZOLE
2-METHYLNAPHTHALENE
2-NITROANILINE
2-NITROPHENOL
2-PHENYLNAPHTHALENE
2-PICOLINE
2-PROPANONE
2-PROPEN-l-OL
2-PROPENAL
ANALYTICAL METHOD
1625
1625
1625
1625
1625
1625
1625
1625
1625
1625
1625
1625
1625
1625
1625
1625
1625
1625
1625
1624
1624
1625
1625
1624
1625
1625
1625
1625
1625
1625
1625
1624
1624
1624
           C-3

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                              Appendix C - Tables Referenced in Chapter 5
Table C-2 (Continued)
POLLUTANT
2-PROPENENITRILE, 2-METHYL-
3,3'-DICHLOROBENZIDINE
3,3'-DIMETHOXYBENZIDINE
3,6-DIMETHYLPHENANTHRENE
3-CHLOROPROPENE
3-METHYLCHOLANTHRENE
3-NITROANILINE
4,4'-METHYLENEBIS(2-CHLOROANILINE)
4,5-METHYLENE PHENANTHRENE
4-AMINOBIPHENYL
4-BROMOPHENYL PHENYL ETHER
4-CHLORO-2-NITROANILINE
4-CHLORO-3-METHYLPHENOL
4-CHLOROPHENYL PHENYL ETHER
4-METHYL-2-PENTANONE
4-NITROPHENOL
5-NITRO-O-TOLUIDINE
7, 1 2-DIMETHYLBENZ(A)ANTHRACENE
ACENAPHTHENE
ACENAPHTHYLENE
ACETOPHENONE
ACRYLONITRILE
ALPHA-TERPINEOL
ALUMINUM
ANILINE
ANILINE, 2,4,5-TRIMETHYL-
ANTHRACENE
ANTIMONY
ARAMITE
ARSENIC
BARIUM
BENZANTHRONE
BENZENE
BENZENETHIOL
ANALYTICAL METHOD
1624
1625
1625
1625
1624
1625
1625
1625
1625
1625
1625
1625
1625
1625
1624
1625
1625
1625
1625
1625
1625
1624
1625
1620
1625
1625
1625
1620
1625
1620
1620
1625
1624
1625
           C-4

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                              Appendix C - Tables Referenced in Chapter 5
Table C-2 (Continued)
POLLUTANT
BENZIDINE
BENZO(A)ANTHRACENE
BENZO(A)PYRENE
BENZO(B)FLUORANTHENE
BENZO(GHI)PERYLENE
BENZO(K)FLUORANTHENE
BENZOIC ACID
BENZONITRILE, 3,5-DIBROMO-4-HYDROXY-
BENZYL ALCOHOL
BERYLLIUM
BETA-NAPHTHYLAMINE
BIPHENYL
BIPHENYL, 4-NITRO
BIS(2-CHLOROETHOXY)METHANE
BIS(2-CHLOROETHYL) ETHER
BIS(2-CHLOROISOPROPYL) ETHER
BIS(2-ETHYLHEXYL) PHTHALATE
BISMUTH
BOD 5-DAY (CARBONACEOUS)
BORON
BROMODICHLOROMETHANE
BROMOMETHANE
BUTYL BENZYL PHTHALATE
CADMIUM
CALCIUM
CARBAZOLE
CARBON DISULFIDE
CERIUM
CHEMICAL OXYGEN DEMAND (COD)
CHLOROACETONITRILE
CHLOROBENZENE
CHLOROETHANE
CHLOROFORM
CHLOROMETHANE
ANALYTICAL METHOD
1625
1625
1625
1625
1625
1625
1625
1625
1625
1620
1625
1625
1625
1625
1625
1625
1625
1620
405.1
1620
1624
1624
1625
1620
1620
1625
1624
1620
410.4
1624
1624
1624
1624
1624
           C-5

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                              Appendix C - Tables Referenced in Chapter 5
Table C-2 (Continued)
POLLUTANT
CHROMIUM
CHRYSENE
CIS-1 ,3-DICHLOROPROPENE
COBALT
COPPER
CROTONALDEHYDE
CROTOXYPHOS
DI-N-BUTYL PHTHALATE
DI-N-OCTYL PHTHALATE
DI-N-PROPYLNITROSAMINE
DIBENZO(A,H) ANTHRACENE
DIBENZOFURAN
DIBENZOTHIOPHENE
DIBROMOCHLOROMETHANE
DIBROMOMETHANE
DIETHYL ETHER
DIETHYL PHTHALATE
DIMETHYL PHTHALATE
DIMETHYL SULFONE
DIPHENYL ETHER
DIPHENYLAMINE
DIPHENYLDISULFIDE
DYSPROSIUM
ERBIUM
ETHANE, PENTACHLORO-
ETHYL CYANIDE
ETHYL METHACRYLATE
ETHYL METHANESULFONATE
ETHYLBENZENE
ETHYLENETHIOUREA
EUROPIUM
FLUORANTHENE
FLUORENE
GADOLINIUM
ANALYTICAL METHOD
1620
1625
1624
1620
1620
1624
1625
1625
1625
1625
1625
1625
1625
1624
1624
1624
1625
1625
1625
1625
1625
1625
1620
1620
1625
1624
1624
1625
1624
1625
1620
1625
1625
1620
           C-6

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                              Appendix C - Tables Referenced in Chapter 5
Table C-2 (Continued)
POLLUTANT
GALLIUM
GERMANIUM
GOLD
HAFNIUM
HEXACHLOROBENZENE
HEXACHLOROBUTADIENE
HEXACHLOROCYCLOPENTADIENE
HEXACHLOROETHANE
HEXACHLOROPROPENE
HEXANOIC ACID
HOLMIUM
INDENO(1,2,3-CD)PYRENE
INDIUM
IODINE
IODOMETHANE
IRIDIUM
IRON
ISOBUTYL ALCOHOL
ISOPHORONE
ISOSAFROLE
LANTHANUM
LEAD
LITHIUM
LONGIFOLENE
LUTETIUM
M-XYLENE
MAGNESIUM
MALACHITE GREEN
MANGANESE
MERCURY
MESTRANOL
METHAPYRILENE
METHYL METHACRYLATE
METHYL METHANESULFONATE
ANALYTICAL METHOD
1620
1620
1620
1620
1625
1625
1625
1625
1625
1625
1620
1625
1620
1620
1624
1620
1620
1624
1625
1625
1620
1620
1620
1625
1620
1624
1620
1625
1620
1620
1625
1625
1624
1625
           C-7

-------
                              Appendix C - Tables Referenced in Chapter 5
Table C-2 (Continued)
POLLUTANT
METHYLENE CHLORIDE
MOLYBDENUM
N,N-DIMETHYLFORMAMIDE
N-DECANE
N-DOCOSANE
N-DODECANE
N-EICOSANE
N-HEXACOSANE
N-HEXADECANE
N-NITROSODI-N-BUTYLAMINE
N-NITROSODIETHYLAMINE
N-NITROSODIMETHYLAMINE
N-NITROSODIPHENYLAMINE
N-NITROSOMETHYLETHYLAMINE
N-NITROSOMETHYLPHENYLAMINE
N-NITROSOMORPHOLINE
N-NITROSOPIPERIDINE
N-OCTACOSANE
N-OCTADECANE
N-TETRACOSANE
N-TETRADECANE
N-TRIACONTANE
NAPHTHALENE
NEODYMIUM
NICKEL
NIOBIUM
NITROBENZENE
0+P XYLENE
0-ANISIDINE
0-CRESOL
0-TOLUIDINE
0-TOLUIDINE, 5-CHLORO-
OIL AND GREASE (measured as HEM)
OSMIUM
ANALYTICAL METHOD
1624
1620
1625
1625
1625
1625
1625
1625
1625
1625
1625
1625
1625
1625
1625
1625
1625
1625
1625
1625
1625
1625
1625
1620
1620
1620
1625
1624
1625
1625
1625
1625
1664
1620

-------
                              Appendix C - Tables Referenced in Chapter 5
Table C-2 (Continued)
POLLUTANT
P-CHLOROANILINE
P-CRESOL
P-CYMENE
P-DIMETHYLAMINOAZOBENZENE
P-NITROANILINE
PALLADIUM
PENTACHLOROBENZENE
PENTACHLOROPHENOL
PENTAMETHYLBENZENE
PERYLENE
PH
PHENACETIN
PHENANTHRENE
PHENOL
PHENOL, 2-METHYL-4,6-DINITRO-
PHENOTHIAZINE
PHOSPHORUS
PLATINUM
POTASSIUM
PRASEODYMIUM
PRONAMIDE
PYRENE
PYRIDINE
RESORCINOL
RHENIUM
RHODIUM
RUTHENIUM
SAFROLE
SAMARIUM
SCANDIUM
SELENIUM
SILICON
SILVER
SODIUM
ANALYTICAL METHOD
1625
1625
1625
1625
1625
1620
1625
1625
1625
1625
150.1
1625
1625
1625
1625
1625
1620
1620
1620
1620
1625
1625
1625
1625
1620
1620
1620
1625
1620
1620
1620
1620
1620
1620
           C-9

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                              Appendix C - Tables Referenced in Chapter 5
Table C-2 (Continued)
POLLUTANT
SQUALENE
STRONTIUM
STYRENE
SULFUR
SURFACTANTS (CTAS)
SURFACTANTS (MBAS)
TANTALUM
TELLURIUM
TERBIUM
TETRACHLOROETHENE
TETRACHLOROMETHANE
THALLIUM
THIANAPHTHENE
THIOACETAMIDE
THIOXANTHE-9-ONE
THORIUM
THULIUM
TIN
TITANIUM
TOLUENE
TOLUENE, 2,4-DIAMINO-
TOTAL HYDROLYZABLE PHOSPHORUS
TOTAL ORGANIC CARBON (TOC)
TOTAL ORTHOPHOSPHATE
TOTAL PETROLEUM HYDROCARBON (measured as SGT-
HEM)
TOTAL PHOSPHORUS
TOTAL SOLIDS
TOTAL SUSPENDED SOLIDS
TRANS- 1 ,2-DICHLOROETHENE
TRANS- 1 ,3 -DICHLOROPROPENE
TRANS- 1 ,4-DICHLORO-2-BUTENE
TRIBROMOMETHANE
TRICHLOROETHENE
ANALYTICAL METHOD
1625
1620
1625
1620
5540D
5540C
1620
1620
1620
1624
1624
1620
1625
1625
1625
1620
1620
1620
1620
1624
1625
365.2
415.1
365.2
1664
365.2
160.3
160.2
1624
1624
1624
1624
1624
          C-10

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                              Appendix C - Tables Referenced in Chapter 5
Table C-2 (Continued)
POLLUTANT
TRICHLOROFLUOROMETHANE
TRIPHENYLENE
TRIPROPYLENEGLYCOL METHYL ETHER
TUNGSTEN
URANIUM
VANADIUM
VINYL ACETATE
VINYL CHLORIDE
YTTERBIUM
YTTRIUM
ZINC
ZIRCONIUM
ANALYTICAL METHOD
1624
1625
1625
1620
1620
1620
1624
1624
1620
1620
1620
1620
          C-ll

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                                                                                         Appendix C - Tables Referenced in Chapter 5
                                                      Table C-3

                  Wastewater Characterization for Item-Specific Wastewater at Industrial Laundries
Industrial Garments
Constituent Name
Concentration (mg/L)1
Minimum
Maximum
Mean
Number of
Times
Analyzed for
Number of
Times
Detected
Percentage
Detected
Conventionals
Biochemical Oxygen Demand 5-Day (BOD5)
Oil and Grease (measured as HEM)
Total Suspended Solids (TSS)
218
18.8
129
600
358
524
350
149
304
6
6
6
6
6
6
100
100
100
Priority Organics
1, 1, 1-Trichloroethane
1,2-Diphenylhydrazine
4-Chloro-3-methylphenol
Bis(2-ethylhexyl) Phthalate
Butyl Benzyl Phthalate
Chlorobenzene
Chloroform
Di-ซ-butyl Phthalate
Di-w-octyl Phthalate
Ethylbenzene
Isophorone
Methylene Chloride
Naphthalene
Phenol
Tetrachloroethene
Toluene
trans- 1,2-Dichloroethene
Trichloroethene
0.0100
0.0200
0.0100
0.100
0.0100
0.0100
0.0100
0.0100
0.0100
0.0100
0.0100
0.0100
0.0100
0.0200
0.0100
0.0100
0.0100
0.0100
0.100
0.200
0.504
3.97
0.431
0.100
0.100
0.211
0.100
0.482
0.933
0.100
0.415
0.127
0.100
0.128
0.100
0.100
0.0400
0.110
0.130
0.838
0.111
0.0400
0.0400
0.0736
0.0583
0.104
0.194
0.0406
0.107
0.0544
0.0400
0.0486
0.0400
0.0400
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
0
0
2
5
2
0
0
1
2
1
1
1
1
5
0
3
0
0
0
0
33
83
33
0
0
17
33
17
17
17
17
83
0
50
0
0
Nonconventional Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pentanone
0.0500
0.0100
0.0500
0.0500
0.500
0.383
0.5000
0.500
0.200
0.102
0.226
0.200
6
6
6
6
0
1
1
0
0
17
17
0
p
to

-------
                                                                                                       Appendix C - Tables Referenced in Chapter 5
                                                       Table C-3 (Continued)
Industrial Garments
Constituent Name
Concentration (mg/L)1
Minimum
Maximum
Mean
Number of
Times
Analyzed for
Number of
Times
Detected
Percentage
Detected
Nonconventional Organics (Continued)
ฐ<-Terpineol
Benzoic Acid
Benzyl Alcohol
Hexanoic Acid
m-Xylene
ซ-Decane
ซ-Docosane
ซ-Dodecane
ซ-Eicosane
ซ-Hexacosane
ซ-Hexadecane
ซ-Octacosane
ซ-Octadecane
ซ-Tetracosane
ซ-Tetradecane
ซ-Triacontane
o-&p-Xylene
p-Cresol
p-Cymene
Pentamethylbenzene
0.0100
0.100
0.0291
0.0471
0.0100
0.0100
0.0118
0.0100
0.0140
0.0190
0.0100
0.0100
0.0100
0.0188
0.0100
0.0115
0.0100
0.0100
0.0100
0.0100
0.100
0.500
0.484
0.176
0.0100
4.61
1.35
7.32
2.52
0.226
3.30
0.220
2.46
1.37
3.41
0.479
0.0100
0.100
0.208
0.100
0.0550
0.353
0.132
0.0962
0.0100
0.807
0.271
1.26
0.471
0.117
0.602
0.0821
0.445
0.281
0.612
0.123
0.0100
0.0417
0.0873
0.0550
6
6
6
6
4
6
6
6
6
6
6
6
6
6
6
6
4
6
6
6
0
3
4
4
0
1
5
2
4
6
3
4
5
4
2
4
0
0
2
0
0
50
67
67
0
17
83
33
67
100
50
67
83
67
33
67
0
0
33
0
Priority Metals and Elements
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
0.0151
0.00110
0.000300
0.00500
0.0159
0.148
0.0460
0.000200
0.0180
1.57
0.0232
0.00100
0.0459
0.161
1.31
0.407
0.000760
0.164
0.312
0.00907
0.000605
0.0269
0.0959
0.688
0.238
0.000395
0.0999
6
6
6
6
6
6
6
6
6
6
2
2
5
6
6
5
3
5
100
33
33
83
100
100
83
50
83
o

-------
                                                Appendix C - Tables Referenced in Chapter 5
Table C-3 (Continued)
Industrial Garments
Constituent Name
Concentration (mg/L)1
Minimum
Maximum
Mean
Number of
Times
Analyzed for
Number of
Times
Detected
Percentage
Detected
Priority Metals and Elements (Continued)
Selenium
Silver
Thallium
Zinc
0.000500
0.00230
0.00100
0.264
0.0200
0.0431
0.0100
3.07
0.00767
0.0146
0.00293
1.50
6
6
6
6
2
3
0
6
33
50
0
100
Nonconventional Metals and Elements
Aluminum
Barium
Boron
Cobalt
Iron
Manganese
Molybdenum
Tin
Titanium
Vanadium
Yttrium
3.20
0.0404
0.0306
0.00230
1.42
0.0732
0.00450
0.0246
0.0842
0.00200
0.000300
8.73
0.560
0.369
0.0461
17.4
0.209
0.0539
0.267
0.223
0.0120
0.00400
4.85
0.273
0.187
0.0134
10.9
0.148
0.0213
0.0722
0.150
0.00707
0.00178
6
6
6
6
6
6
6
6
6
6
6
6
6
6
2
6
6
4
5
6
1
1
100
100
100
33
100
100
67
83
100
17
17
Bulk Nonconventionals
Chemical Oxygen Demand (COD)
Total Organic Carbon (TOC)
Total Petroleum Hydrocarbon (measured as SGT-HEM)
1,070
163
5.00
2,760
540
74.5
1,710
367
47.4
6
6
6
6
6
5
100
100
83


-------
                                                                                                       Appendix C - Tables Referenced in Chapter 5
                                                       Table C-3 (Continued)
Shop Towels
Constituent Name
Concentration (mg/L)1
Minimum
Maximum
Mean
Number of
Times
Analyzed for
Number of
Times
Detected
Percentage
Detected
Conventionals
Biochemical Oxygen Demand 5-Day (BOD5)
Oil and Grease (measured as HEM)
Total Suspended Solids (TSS)
1,130
2,090
2,540
5,640
5,360
6,730
2,780
3,250
4,450
6
4
4
6
4
4
100
100
100
Priority Organics
1, 1, 1-Trichloroethane
1,2-Diphenylhydrazine
4-Chloro-3-methylphenol
Bis(2-ethylhexyl) Phthalate
Butyl Benzyl Phthalate
Chlorobenzene
Chloroform
Di-ซ-butyl Phthalate
Di-w-octyl Phthalate
Ethylbenzene
Isophorone
Methylene Chloride
Naphthalene
Phenol
Tetrachloroethene
Toluene
trans- 1,2-Dichloroethene
Trichloroethene
0.0100
0.0700
0.0200
0.633
0.0350
0.0100
0.0100
0.0350
0.0350
0.556
0.0350
0.0100
0.329
0.0350
0.170
1.11
0.0100
0.0100
38.3
2.00
2.06
9.44
3.79
1.00
1.00
1.00
1.00
36.0
36.3
39.9
5.16
1.00
55.5
11.6
1.00
1.00
4.13
1.07
0.795
3.63
1.46
0.252
0.292
0.558
0.538
5.27
9.58
4.22
2.91
0.310
8.92
5.33
0.367
0.247
6
4
4
5
4
5
4
4
4
6
4
6
5
4
6
5
5
5
3
0
1
4
1
1
1
1
1
6
1
3
4
1
5
5
1
2
50
0
25
80
25
20
25
25
25
100
25
50
80
25
83
100
20
40
Nonconventional Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pentanone
ฐ<-Terpineol
Benzoic Acid
Benzyl Alcohol
0.0898
0.465
1.00
0.132
0.0350
0.301
0.0350
15.8
1.21
5.95
5.00
1.59
5.00
35.0
5.40
0.826
3.98
1.88
0.956
2.55
9.26
4
4
4
4
4
4
4
3
3
3
2
2
2
1
75
75
75
50
50
50
25
o

-------
                                                Appendix C - Tables Referenced in Chapter 5
Table C-3 (Continued)
Shop Towels
Constituent Name
Concentration (mg/L)1
Minimum
Maximum
Mean
Number of
Times
Analyzed for
Number of
Times
Detected
Percentage
Detected
Nonconventional Organics (Continued)
Hexanoic Acid
m-Xylene
ซ-Decane
ซ-Docosane
ซ-Dodecane
ซ-Eicosane
ซ-Hexacosane
ซ-Hexadecane
ซ-Octacosane
ซ-Octadecane
ซ-Tetracosane
ซ-Tetradecane
ซ-Triacontane
o-&p-Xylene
p-Cresol
p-Cymene
Pentamethylbenzene
0.0200
0.884
4.70
0.313
13.3
1.44
0.100
2.85
0.100
1.06
0.328
6.51
0.0689
0.482
0.0200
0.0350
0.0350
1.00
2.99
154
1.55
23.7
84.6
4.01
17.4
2.21
22.1
5.30
36.8
1.71
3.27
1.00
8.11
1.00
0.305
2.12
42.2
1.10
19.1
25.1
1.40
10.0
0.858
11.2
1.95
15.0
0.719
1.47
0.305
2.05
0.534
4
3
5
4
4
4
4
5
4
5
4
4
4
3
4
5
4
0
3
5
3
4
4
2
5
2
5
3
4
2
3
0
2
0
0
100
100
75
100
100
50
100
50
100
75
100
50
100
0
40
0
Priority Metals and Elements
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
0.0973
0.00800
0.000560
0.105
0.119
2.44
2.04
0.000200
0.175
0.0100
0.00270
0.00100
0.369
0.0511
0.00100
0.856
1.17
9.79
20.5
0.00425
1.61
0.0200
0.877
0.0120
0.198
0.0224
0.000890
0.358
0.490
6.48
6.52
0.00183
0.599
0.0145
0.139
0.00390
6
5
4
6
6
6
6
5
6
4
6
4
6
4
1
6
6
6
6
3
6
2
3
0
100
80
25
100
100
100
100
60
100
50
50
0


-------
                                                Appendix C - Tables Referenced in Chapter 5
Table C-3 (Continued)
Shop Towels
Constituent Name
Concentration (mg/L)1
Minimum
Maximum
Mean
Number of
Times
Analyzed for
Number of
Times
Detected
Percentage
Detected
Priority Metals and Elements (Continued)
Zinc
6.82
29.4
13.5
6
6
100
Nonconventional Metals and Elements
Aluminum
Barium
Boron
Cobalt
Iron
Manganese
Molybdenum
Tin
Titanium
Vanadium
Yttrium
5.57
0.730
0.0500
0.0720
24.6
0.510
0.153
0.0290
0.0177
0.0106
0.00320
20.1
10.3
3.81
0.795
114
1.95
1.27
0.808
0.574
0.113
0.0171
13.1
4.08
1.99
0.288
55.8
1.09
0.382
0.370
0.232
0.0420
0.00794
6
6
6
6
6
6
6
6
6
6
4
6
6
5
6
6
6
6
5
6
6
4
100
100
83
100
100
100
100
83
100
100
100
Bulk Nonconventionals
Chemical Oxygen Demand (COD)
Total Organic Carbon (TOC)
Total Petroleum Hydrocarbon (measured as SGT-HEM)
7,700
750
520
26,300
2,950
3,410
13,300
2,030
1,760
6
6
4
6
6
4
100
100
100


-------
                                                                                                       Appendix C - Tables Referenced in Chapter 5
                                                       Table C-3 (Continued)
Printer Towels
Constituent Name
Concentration (mg/L)1
Minimum
Maximum
Mean
Number of
Times
Analyzed for
Number of
Times
Detected
Percentage
Detected
Conventionals
Biochemical Oxygen Demand 5-Day (BOD5)
Oil and Grease (measured as HEM)
Total Suspended Solids (TSS)
3,360
936
810
4,250
11,800
1,600
3,940
5,890
1,250
3
3
3
3
3
3
100
100
100
Priority Organics
1, 1, 1-Trichloroethane
1,2-Diphenylhydrazine
4-Chloro-3-methylphenol
Bis(2-ethylhexyl) Phthalate
Butyl Benzyl Phthalate
Chlorobenzene
Chloroform
Di-ซ-butyl Phthalate
Di-w-octyl Phthalate
Ethylbenzene
Isophorone
Methylene Chloride
Naphthalene
Phenol
Tetrachloroethene
Toluene
trans- 1,2-Dichloroethene
Trichloroethene
1.00
0.200
0.100
3.83
1.00
0.100
0.0100
0.844
0.100
0.521
0.100
0.140
3.73
0.100
2.40
14.1
0.0118
0.100
8.26
2.00
1.00
36.4
9.34
1.00
1.00
7.75
2.61
29.2
1.00
1.54
12.7
1.00
6.16
33.2
1.00
1.00
4.50
1.00
0.433
19.0
5.55
0.467
0.370
3.20
1.24
13.2
0.500
0.614
9.64
0.500
3.92
20.5
0.371
0.476
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
2
0
0
3
2
1
0
2
1
3
0
3
3
0
3
3
1
1
67
0
0
100
67
33
0
67
33
100
0
100
100
0
100
100
33
33
Nonconventional Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pentanone
ฐ<-Terpineol
Benzoic Acid
Benzyl Alcohol
2.05
0.100
23.4
0.500
0.100
1.50
0.100
5.00
1.71
96.6
5.00
1.58
5.00
1.00
3.09
0.836
49.7
2.07
1.07
3.30
0.500
3
3
3
3
3
3
3
2
2
3
1
2
2
0
67
67
100
33
67
67
0
p
oo

-------
                                                                                                       Appendix C - Tables Referenced in Chapter 5
                                                       Table C-3 (Continued)
Printer Towels
Constituent Name
Concentration (mg/L)1
Minimum
Maximum
Mean
Number of
Times
Analyzed for
Number of
Times
Detected
Percentage
Detected
Nonconventional Organics (Continued)
Hexanoic Acid
m-Xylene
ซ-Decane
ซ-Docosane
ซ-Dodecane
ซ-Eicosane
ซ-Hexacosane
ซ-Hexadecane
ซ-Octacosane
ซ-Octadecane
ซ-Tetracosane
ซ-Tetradecane
ซ-Triacontane
o-&p-Xylene
p-Cresol
p-Cymene
Pentamethylbenzene
0.100
0.100
10.1
0.100
12.9
1.22
1.00
4.34
0.100
1.73
0.100
3.08
0.100
0.100
0.100
8.10
0.100
1.00
2.79
158
1.00
41.8
1.38
3.73
15.4
1.01
3.62
1.00
15.8
1.00
2.05
1.00
19.8
1.00
0.433
1.44
90.6
0.668
23.1
1.29
2.01
9.51
0.402
2.43
0.605
7.89
0.626
1.08
0.433
12.4
0.500
3
2
3
3
3
3
3
3
3
3
3
3
3
2
3
3
3
0
1
3
1
3
3
2
3
1
3
1
3
1
1
0
3
0
0
50
100
33
100
100
67
100
33
100
33
100
33
50
0
100
0
Priority Metals and Elements
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
0.0200
0.00100
0.00100
0.0129
0.278
8.20
1.12
0.000200
0.0962
0.0100
0.00900
0.00100
0.104
0.00530
0.00100
0.0444
7.31
14.9
23.8
0.000290
0.108
0.0230
0.555
0.0120
0.0556
0.00313
0.00100
0.0253
2.65
11.0
8.91
0.000230
0.101
0.0177
0.207
0.00767
3
3
3
3
3
3
3
3
3
3
3
3
2
2
0
3
3
3
3
1
3
0
3
0
67
67
0
100
100
100
100
33
100
0
100
0
p
VO

-------
                                                                                                       Appendix C - Tables Referenced in Chapter 5
                                                       Table C-3 (Continued)
Printer Towels
Constituent Name
Concentration (mg/L)1
Minimum
Maximum
Mean
Number of
Times
Analyzed for
Number of
Times
Detected
Percentage
Detected
Priority Metals and Elements (Continued)
Zinc
2.84
4.21
3.62
3
3
100
Nonconventional Metals and Elements
Aluminum
Barium
Boron
Cobalt
Iron
Manganese
Molybdenum
Tin
Titanium
Vanadium
Yttrium
3.30
3.14
0.614
0.222
5.58
0.305
0.328
0.0431
0.0797
0.00700
0.00400
17.4
6.97
0.777
0.942
10.0
1.29
5.17
0.138
0.313
0.0120
0.00810
8.22
4.53
0.670
0.614
8.51
0.898
2.10
0.0990
0.184
0.00900
0.00570
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
0
1
100
100
100
100
100
100
100
100
100
0
33
Bulk Nonconventionals
Chemical Oxygen Demand (COD)
Total Organic Carbon (TOC)
Total Petroleum Hydrocarbon (measured as SGT-HEM)
15,800
2,220
133
19,100
3,520
4,540
16,900
2,740
1,730
3
3
3
3
3
3
100
100
100
p

to
o

-------
                                                                                                       Appendix C - Tables Referenced in Chapter 5
                                                       Table C-3 (Continued)
Mats
Constituent Name
Concentration (mg/L)1
Minimum
Maximum
Mean
Number of
Times
Analyzed for
Number of
Times
Detected
Percentage
Detected
Conventionals
Biochemical Oxygen Demand 5-Day (BOD5)
Oil and Grease (measured as HEM)
Total Suspended Solids (TSS)
98.0
84.3
365
248
153
1,020
179
105
690
3
3
3
3
3
3
100
100
100
Priority Organics
1, 1, 1-Trichloroethane
1,2-Diphenylhydrazine
4-Chloro-3-methylphenol
Bis(2-ethylhexyl) Phthalate
Butyl Benzyl Phthalate
Chlorobenzene
Chloroform
Di-w-butyl Phthalate
Di-w-octyl Phthalate
Ethylbenzene
Isophorone
Methylene Chloride
Naphthalene
Phenol
Tetrachloroethene
Toluene
trans- 1,2-Dichloroethene
Trichloroethene
0.0100
0.0200
0.0100
1.18
0.0100
0.0100
0.0100
0.0100
0.0192
0.0100
0.0100
0.0100
0.0100
0.0100
0.0100
0.0100
0.0100
0.0100
1.60
0.0200
0.0100
2.02
0.0907
0.0100
0.0100
0.315
0.0494
0.283
0.361
0.442
0.0244
0.0238
0.125
1.29
0.0100
0.0100
0.806
0.0200
0.0100
1.70
0.0350
0.0100
0.0100
0.114
0.0369
0.147
0.186
0.226
0.0172
0.0134
0.0676
0.654
0.0100
0.0100
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
1
0
0
3
2
0
0
2
3
1
2
1
1
1
1
2
0
0
33
0
0
100
67
0
0
67
100
33
67
33
33
33
33
67
0
0
Nonconventional Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pentanone
ฐ<-Terpineol
Benzoic Acid
Benzyl Alcohol
0.0500
0.0100
0.0500
0.0500
0.0100
0.0500
0.0185
0.579
0.0100
2.11
0.458
0.0825
0.231
0.0724
0.314
0.0100
1.10
0.254
0.0463
0.156
0.0520
3
3
3
3
3
3
3
1
0
2
1
1
2
3
33
0
67
33
33
67
100
o
to

-------
                                                                                                        Appendix C - Tables Referenced in Chapter 5
                                                        Table C-3 (Continued)
Mats
Constituent Name
Concentration (mg/L)1
Minimum
Maximum
Mean
Number of
Times
Analyzed for
Number of
Times
Detected
Percentage
Detected
Nonconventional Organics (Continued)
Hexanoic Acid
m-Xylene
ซ-Decane
ซ-Docosane
ซ-Dodecane
ซ-Eicosane
ซ-Hexacosane
ซ-Hexadecane
ซ-Octacosane
ซ-Octadecane
ซ-Tetracosane
ซ-Tetradecane
ซ-Triacontane
o-&p-Xylene
p-Cresol
p-Cymene
Pentamethylbenzene
0.0152
0.0100
0.0100
0.0130
0.0100
0.0166
0.0184
0.0100
0.0100
0.0112
0.0100
0.0100
0.0274
0.0100
0.0100
0.0100
0.0100
0.0817
0.520
1.98
0.0272
0.121
0.0318
0.0265
0.0305
0.0168
0.0222
0.0934
0.0190
0.0306
0.291
0.0100
0.0100
0.0100
0.0611
0.265
0.995
0.0175
0.0654
0.0206
0.0211
0.0206
0.0134
0.0160
0.0394
0.0145
0.0292
0.151
0.0100
0.0100
0.0100
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
1
1
3
1
3
3
2
2
3
2
1
3
1
0
0
0
100
33
33
100
33
100
100
67
67
100
67
33
100
33
0
0
0
Priority Metals and Elements
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
0.0200
0.00380
0.000540
0.00950
0.0806
0.220
0.307
0.000430
0.0543
0.00150
0.0155
0.00160
0.0209
0.0143
0.00100
0.0267
0.303
3.97
1.64
0.00392
0.297
0.00460
0.0176
0.0120
0.0204
0.00905
0.000775
0.0147
0.167
1.31
0.711
0.00142
0.152
0.00305
0.0168
0.00680
3
3
3
3
3
3
3
3
3
3
3
3
3
2
2
3
3
3
3
3
3
0
3
0
100
67
67
100
100
100
100
100
100
0
100
0
p

to
to

-------
                                                                                                       Appendix C - Tables Referenced in Chapter 5
                                                       Table C-3 (Continued)
Mats
Constituent Name
Concentration (mg/L)1
Minimum
Maximum
Mean
Number of
Times
Analyzed for
Number of
Times
Detected
Percentage
Detected
Priority Metals and Elements (Continued)
Zinc
1.06
4.31
2.42
3
3
100
Nonconventional Metals and Elements
Aluminum
Barium
Boron
Cobalt
Iron
Manganese
Molybdenum
Tin
Titanium
Vanadium
Yttrium
3.42
0.214
0.0500
0.0135
6.87
0.115
0.0240
0.0439
0.0100
0.00920
0.00500
17.4
0.551
0.123
0.0256
47.7
0.553
0.0417
0.205
0.828
0.0465
0.00874
10.3
0.376
0.0818
0.0184
24.7
0.318
0.0321
0.0938
0.364
0.0273
0.00675
3
3
3
3
3
3
3
3
3
3
3
3
3
2
3
3
3
3
3
2
3
2
100
100
67
100
100
100
100
100
67
100
67
Bulk Nonconventionals
Chemical Oxygen Demand (COD)
Total Organic Carbon (TOC)
Total Petroleum Hydrocarbon (measured as SGT-HEM)
80.0
33.0
33.2
968
186
72.5
515
111
48.5
3
3
3
3
3
2
100
100
67
p
to

-------
                                                                                                       Appendix C - Tables Referenced in Chapter 5
                                                       Table C-3 (Continued)
Mops
Constituent Name
Concentration (mg/L)1
Minimum
Maximum
Mean
Number of
Times
Analyzed for
Number of
Times
Detected
Percentage
Detected
Conventionals
Biochemical Oxygen Demand 5-Day (BOD5)
Oil and Grease (measured as HEM)
Total Suspended Solids (TSS)
140
9
332
2,160
564
1,860
1,150
286
1,100
2
2
2
2
2
2
100
100
100
Priority Organics
1, 1, 1-Trichloroethane
1,2-Diphenylhydrazine
4-Chloro-3-methylphenol
Bis(2-ethylhexyl) Phthalate
Butyl Benzyl Phthalate
Chlorobenzene
Chloroform
Di-ซ-butyl Phthalate
Di-w-octyl Phthalate
Ethylbenzene
Isophorone
Methylene Chloride
Naphthalene
Phenol
Tetrachloroethene
Toluene
trans- 1,2-Dichloroethene
Trichloroethene
0.0100
0.200
0.100
1.08
0.166
0.0100
0.0130
0.100
0.100
0.0100
0.100
0.0100
0.443
0.100
0.0100
0.0194
0.0100
0.0100
2.08
0.200
0.100
1.13
1.62
0.100
0.100
0.768
0.116
0.100
0.100
0.143
0.500
0.100
0.100
0.100
0.100
0.100
1.04
0.200
0.100
1.10
0.895
0.0550
0.0565
0.434
0.108
0.0550
0.100
0.0767
0.471
0.100
0.0550
0.0597
0.0550
0.0550
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
1
0
0
2
2
0
1
1
1
0
0
1
2
0
0
1
0
0
50
0
0
100
100
0
50
50
50
0
0
50
100
0
0
50
0
0
Nonconventional Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pentanone
ฐ<-Terpineol
Benzoic Acid
Benzyl Alcohol
0.0500
0.100
0.0500
0.0500
0.100
1.91
0.100
2.21
0.763
4.40
0.500
0.100
2.78
1.12
1.13
0.432
2.22
0.275
0.100
2.35
0.610
2
2
2
2
2
2
2
1
1
1
0
0
2
1
50
50
50
0
0
100
50
p
to

-------
                                                                                                       Appendix C - Tables Referenced in Chapter 5
                                                       Table C-3 (Continued)
Mops
Constituent Name
Concentration (mg/L)1
Minimum
Maximum
Mean
Number of
Times
Analyzed for
Number of
Times
Detected
Percentage
Detected
Nonconventional Organics (Continued)
Hexanoic Acid
m-Xylene
ซ-Decane
ซ-Docosane
ซ-Dodecane
ซ-Eicosane
ซ-Hexacosane
ซ-Hexadecane
ซ-Octacosane
ซ-Octadecane
ซ-Tetracosane
ซ-Tetradecane
ซ-Triacontane
o-&p-Xylene
p-Cresol
p-Cymene
Pentamethylbenzene
0.185
0.100
0.271
0.137
0.100
0.246
0.207
0.286
0.168
0.392
0.100
1.13
0.0941
0.100
0.100
0.100
0.100
0.246
0.100
1.66
0.178
16.0
0.336
0.213
1.86
0.275
1.36
0.100
1.80
0.232
0.100
0.100
0.100
0.100
0.216
0.100
0.965
0.157
8.07
0.291
0.210
1.07
0.221
0.875
0.100
1.47
0.163
0.100
0.100
0.100
0.100
2
1
2
2
2
2
2
2
2
2
2
2
2
1
2
2
2
2
0
2
2
1
2
2
2
2
2
0
2
2
0
0
0
0
100
0
100
100
50
100
100
100
100
100
0
100
100
0
0
0
0
Priority Metals and Elements
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
0.003100
0.00260
0.00100
0.00500
0.0178
0.427
0.0460
0.000910
0.0180
0.00460
0.00620
0.00240
0.0556
0.0178
0.00100
0.0373
0.184
3.52
1.76
0.00840
0.195
0.0200
0.0160
0.0100
0.0294
0.0102
0.00100
0.0212
0.101
1.97
0.903
0.00466
0.106
0.0123
0.0111
0.00620
2
2
2
2
2
2
2
2
2
2
2
2
2
2
0
1
2
2
1
2
1
0
2
0
100
100
0
50
100
100
50
100
50
0
100
0
p
to

-------
                                                                                                       Appendix C - Tables Referenced in Chapter 5
                                                       Table C-3 (Continued)
Mops
Constituent Name
Concentration (mg/L)1
Minimum
Maximum
Mean
Number of
Times
Analyzed for
Number of
Times
Detected
Percentage
Detected
Priority Metals and Elements (Continued)
Zinc
0.686
5.32
3.00
2
2
100
Nonconventional Metals and Elements
Aluminum
Barium
Boron
Cobalt
Iron
Manganese
Molybdenum
Tin
Titanium
Vanadium
Yttrium
2.25
0.189
0.0533
0.0100
3.90
0.0783
0.0284
0.0290
0.0602
0.0120
0.00400
17.3
0.953
0.327
0.0620
31.9
0.638
0.0940
0.128
0.307
0.0320
0.00500
9.78
0.571
0.190
0.0360
17.9
0.358
0.0612
0.0785
0.184
0.0220
0.004500
2
2
2
2
2
2
2
2
2
2
2
2
2
2
1
2
2
2
1
2
1
0
100
100
100
50
100
100
100
50
100
50
0
Bulk Nonconventionals
Chemical Oxygen Demand (COD)
Total Organic Carbon (TOC)
Total Petroleum Hydrocarbon (measured as SGT-HEM)
720
133
5
10,100
902
218
5,410
518
111
2
2
2
2
2
1
100
100
50
p
to

-------
                                                                                                       Appendix C - Tables Referenced in Chapter 5
                                                       Table C-3 (Continued)
Steam-Tumbled Printer Towels
Constituent Name
Concentration (mg/L)1
Minimum
Maximum
Mean
Number of
Times
Analyzed for
Number of
Times
Detected
Percentage
Detected
Conventionals
Biochemical Oxygen Demand 5-Day (BOD5)
Oil and Grease (measured as HEM)
Total Suspended Solids (TSS)
1,440
1,720
1,320
1,440
1,720
1,320
1,440
1,720
1,320
1
1
1
1
1
1
100
100
100
Priority Organics
1, 1, 1-Trichloroethane
1,2-Diphenylhydrazine
4-Chloro-3-methylphenol
Bis(2-ethylhexyl) Phthalate
Butyl Benzyl Phthalate
Chlorobenzene
Chloroform
Di-ซ-butyl Phthalate
Di-w-octyl Phthalate
Ethylbenzene
Isophorone
Methylene Chloride
Naphthalene
Phenol
Tetrachloroethene
Toluene
trans- 1,2-Dichloroethene
Trichloroethene
0.0118
0.0800
0.0400
8.77
0.366
0.0100
0.0100
0.117
0.325
0.0100
0.0400
0.0100
0.226
0.0432
0.0100
0.0436
0.0100
0.0100
0.0118
0.0800
0.0400
8.77
0.366
0.0100
0.0100
0.117
0.325
0.0100
0.0400
0.0100
0.226
0.0432
0.0100
0.0436
0.0100
0.0100
0.0118
0.0800
0.0400
8.77
0.366
0.0100
0.0100
0.117
0.325
0.0100
0.0400
0.0100
0.226
0.0432
0.0100
0.0436
0.0100
0.0100
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
0
0
1
1
0
0
1
1
0
0
0
1
1
0
1
0
0
100
0
0
100
100
0
0
100
100
0
0
0
100
100
0
100
0
0
Nonconventional Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pentanone
ฐ<-Terpineol
Benzoic Acid
Benzyl Alcohol
0.0500
0.0400
0.681
0.0500
0.0400
0.977
0.819
0.0500
0.0400
0.681
0.0500
0.0400
0.977
0.819
0.0500
0.0400
0.681
0.0500
0.0400
0.977
0.819
1
1
1
1
1
1
1
0
0
1
0
0
1
1
0
0
100
0
0
100
100
p
to

-------
                                                                                                        Appendix C - Tables Referenced in Chapter 5
                                                        Table C-3 (Continued)
Steam-Tumbled Printer Towels
Constituent Name
Concentration (mg/L)1
Minimum
Maximum
Mean
Number of
Times
Analyzed for
Number of
Times
Detected
Percentage
Detected
Nonconventional Organics (Continued)
Hexanoic Acid
m-Xylene
ซ-Decane
ซ-Docosane
ซ-Dodecane
ซ-Eicosane
ซ-Hexacosane
ซ-Hexadecane
ซ-Octacosane
ซ-Octadecane
ซ-Tetracosane
ซ-Tetradecane
ซ-Triacontane
o-&p-Xylene
p-Cresol
p-Cymene
Pentamethylbenzene
0.384
0.0151
0.499
0.131
2.65
3.05
0.0904
91.6
0.0633
1.48
0.0724
12.8
0.0587
0.0146
0.0400
0.0400
0.0400
0.384
0.0151
0.499
0.131
2.65
3.05
0.0904
91.6
0.0633
1.48
0.0724
12.8
0.0587
0.0146
0.0400
0.0400
0.0400
0.384
0.0151
0.499
0.131
2.65
3.05
0.0904
91.6
0.0633
1.48
0.0724
12.8
0.0587
0.0146
0.0400
0.0400
0.0400
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
0
0
0
100
100
100
100
100
100
100
100
100
100
100
100
100
100
0
0
0
Priority Metals and Elements
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
0.0261
0.00380
0.00100
0.0358
0.275
4.86
0.957
0.000200
0.0372
0.0230
0.0653
0.0120
0.0261
0.00380
0.00100
0.0358
0.275
4.86
0.957
0.000200
0.0372
0.0230
0.0653
0.0120
0.0261
0.00380
0.00100
0.0358
0.275
4.86
0.957
0.000200
0.0372
0.0230
0.0653
0.0120
1
1
1
1
1
1
1
1
1
1
1
1
1
0
0
1
1
1
1
0
1
0
1
0
100
0
0
100
100
100
100
0
100
0
100
0
p

to
oo

-------
                                                                                                        Appendix C - Tables Referenced in Chapter 5
                                                       Table C-3 (Continued)
Steam-Tumbled Printer Towels
Constituent Name
Concentration (mg/L)1
Minimum
Maximum
Mean
Number of
Times
Analyzed for
Number of
Times
Detected
Percentage
Detected
Priority Metals and Elements (Continued)
Zinc
2.10
2.10
2.10
1
1
100
Nonconventional Metals and Elements
Aluminum
Barium
Boron
Cobalt
Iron
Manganese
Molybdenum
Tin
Titanium
Vanadium
Yttrium
2.80
1.63
0.0500
0.202
2.62
0.277
2.64
0.0761
0.0178
0.0221
0.00500
2.80
1.63
0.0500
0.202
2.62
0.277
2.64
0.0761
0.0178
0.0221
0.00500
2.80
1.63
0.0500
0.202
2.62
0.277
2.64
0.0761
0.0178
0.0221
0.00500
1
1
1
1
1
1
1
1
1
1
1
1
1
0
1
1
1
1
1
1
1
0
100
100
0
100
100
100
100
100
100
100
0
Bulk Nonconventionals
Chemical Oxygen Demand (COD)
Total Organic Carbon (TOC)
Total Petroleum Hydrocarbon (measured as SGT-HEM)
9,000
1,770
468
9,000
1,770
468
9,000
1,770
468
1
1
1
1
1
1
100
100
100
p

to
VO

-------
                                                                                                       Appendix C - Tables Referenced in Chapter 5
                                                       Table C-3 (Continued)
Items Dry Cleaned Prior to Water Washing
Constituent Name
Concentration (mg/L)1
Minimum
Maximum
Mean
Number of
Times
Analyzed for
Number of
Times
Detected
Percentage
Detected
Conventionals
Biochemical Oxygen Demand 5-Day (BOD5)
Total Suspended Solids (TSS)
110
70
120
93
113
82
3
3
3
3
100
100
Priority Organics
Ethylbenzene
Toluene
0.00200
0.00200
0.232
1.23
0.0458
0.225
11
11
8
8
73
73
Priority Metals and Elements
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Silver
Zinc
0.00500
0.0100
0.0200
0.0600
0.00500
0.000100
0.0200
0.00500
0.350
0.00500
0.150
0.1700
0.940
1.50
0.000200
0.0200
0.00500
0.640
0.00500
0.0825
0.0933
0.668
0.519
0.000150
0.0200
0.00500
0.450
3
4
3
4
3
4
3
5
3
0
3
3
4
2
0
0
0
3
0
75
100
100
67
0
0
0
100
Bulk Nonconventionals
Chemical Oxygen Demand (COD)
528
804
638
3
3
100
p
OJ
o

-------
                                                Appendix C - Tables Referenced in Chapter 5
Table C-3 (Continued)
Linen Supply Items
Constituent Name
Concentration (mg/L)1
Minimum
Maximum
Mean
Number of
Times
Analyzed for
Number of
Times
Detected
Percentage
Detected
Conventionals
Biochemical Oxygen Demand 5-Day (BOD5)
Oil and Grease (measured as HEM)
Total Suspended Solids (TSS)
50
72
35
2,520
142
1,060
881
108
269
9
3
9
9
3
9
100
100
100
Priority Organics
1, 1, 1-Trichloroethane
1,2-Diphenylhydrazine
4-Chloro-3-methylphenol
Bis(2-ethylhexyl) Phthalate
Butyl Benzyl Phthalate
Chlorobenzene
Chloroform
Di-ซ-butyl Phthalate
Di-w-octyl Phthalate
Ethylbenzene
Isophorone
Methylene Chloride
Naphthalene
Phenol
Tetrachloroethene
Toluene
trans- 1,2-Dichloroethene
Trichloroethene
0.00500
0.0200
0.0100
0.0410
0.0100
0.00500
0.0100
0.0100
0.0100
0.00500
0.0100
0.0100
0.0100
0.0467
0.00500
0.00500
0.00500
0.00500
0.0100
0.0200
0.0100
1.49
0.263
0.0100
2.58
0.0717
0.130
0.0100
0.0100
0.0130
0.304
0.104
0.0100
0.152
0.0100
0.0100
0.00833
0.0200
0.0100
0.574
0.0944
0.00833
0.889
0.0306
0.0572
0.00833
0.0100
0.0112
0.108
0.0674
0.00833
0.0241
0.00833
0.00833
5
3
3
3
3
5
5
3
3
5
3
5
3
3
5
5
5
5
0
0
0
3
1
0
5
1
2
0
0
2
1
3
0
1
0
0
0
0
0
100
33
0
100
33
67
0
0
40
33
100
0
20
0
0
Nonconventional Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pentanone
ฐ<-Terpineol
Benzoic Acid
Benzyl Alcohol
0.0500
0.01000
0.0500
0.0500
0.0100
0.116
0.0100
0.0500
0.0291
0.0804
0.0500
0.0817
0.216
0.575
0.0500
0.0164
0.0607
0.0500
0.0339
0.150
0.202
3
3
3
3
3
3
3
0
1
2
0
1
3
2
0
33
67
0
33
100
67


-------
                                                                                                        Appendix C - Tables Referenced in Chapter 5
                                                        Table C-3 (Continued)
Linen Supply Items
Constituent Name
Concentration (mg/L)1
Minimum
Maximum
Mean
Number of
Times
Analyzed for
Number of
Times
Detected
Percentage
Detected
Nonconventional Organics (Continued)
Hexanoic Acid
m-Xylene
ซ-Decane
ซ-Docosane
ซ-Dodecane
ซ-Eicosane
ซ-Hexacosane
ซ-Hexadecane
ซ-Octacosane
ซ-Octadecane
ซ-Tetracosane
ซ-Tetradecane
ซ-Triacontane
o-&p-Xylene
p-Cresol
p-Cymene
Pentamethylbenzene
0.0100
0.0100
0.0100
0.0100
0.0100
0.0100
0.0100
0.0100
0.0100
0.0100
0.0100
0.0100
0.0100
0.0100
0.0100
0.0100
0.0100
0.0418
0.0100
7.87
0.0732
0.513
0.209
0.0598
0.458
0.0436
0.169
0.128
0.400
0.126
0.0100
0.0100
0.305
0.0100
0.0279
0.0100
2.63
0.0392
0.270
0.0862
0.0267
0.160
0.0212
0.0720
0.0630
0.140
0.0551
0.0100
0.0100
0.108
0.0100
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
2
0
1
2
2
2
2
2
1
2
2
1
2
0
0
1
0
67
0
33
67
67
67
67
67
33
67
67
33
67
0
0
33
0
Priority Metals and Elements
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
0.00810
0.00880
0.00100
0.00500
0.0100
0.0500
0.0400
0.000200
0.0150
0.00200
0.00500
0.00100
0.3130
0.300
0.00100
0.0500
0.140
2.50
0.500
0.00300
0.280
0.300
0.0700
0.0100
0.114
0.156
0.00100
0.0219
0.0492
0.527
0.151
0.00165
0.0771
0.151
0.0291
0.00700
3
4
3
15
15
15
15
4
15
4
14
3
2
3
0
2
7
14
8
2
6
0
6
0
67
75
0
13
47
93
53
50
40
0
43
0
p
OJ
to

-------
                                                                                                                                Appendix C - Tables Referenced in Chapter 5
                                                                    Table C-3 (Continued)
Linen Supply Items
Constituent Name
Concentration (mg/L)1
Minimum
Maximum
Mean
Number of
Times
Analyzed for
Number of
Times
Detected
Percentage
Detected
Priority Metals and Elements (Continued)
Zinc
0.120
1.10
0.381
17
17
100
Nonconventional Metals and Elements
Aluminum
Barium
Boron
Cobalt
Iron
Manganese
Molybdenum
Tin
Titanium
Vanadium
Yttrium
1.35
0.0804
0.0310
0.00900
1.09
0.0285
0.0100
0.0290
0.0267
0.00800
0.00300
4.70
0.646
0.229
0.0117
8.93
0.147
0.0588
0.0290
0.105
0.0133
0.00810
3.08
0.301
0.0970
0.00990
3.26
0.0812
0.0263
0.0290
0.0654
0.00990
0.00470
3
3
3
3
5
3
3
3
3
3
3
3
3
1
1
5
3
1
0
3
2
1
100
100
33
33
100
100
33
0
100
67
33
Bulk Nonconventionals
Chemical Oxygen Demand (COD)
Total Organic Carbon (TOC)
Total Petroleum Hydrocarbon (measured as SGT-HEM)
197
310
9
1,520
494
19
844
401
12
7
3
3
7
3
3
100
100
100
o
       'The detection limit concentration was used in calculations for data points reported as nondetects.

-------
                                                                                         Appendix C - Tables Referenced in Chapter 5
                                                      Table C-4
                 Wastewater Characterization Data for Wastewater Streams at Industrial Laundries
Wastewater Characterization Data for Heavy Wastewater
Pollutant of Concern
Concentration (mg/L)1
Minimum
Maximum
Mean
Number of
Times
Analyzed
Number of
Times
Detected
Percentage
Detected
(%)
Conventionals
Biochemical Oxygen Demand 5-Day (BOD5)
Oil and Grease (measured as HEM)
Total Suspended Solids (TSS)
1,600
612
213
9,810
6,410
7,000
4,160
2,950
2,320
18
18
18
18
18
18
100
100
100
Priority Organics
1, 1, 1-Trichloroethane
1,2-Diphenylhydrazine
4-Chloro-3-methylphenol
Bis(2-ethylhexyl) Phthalate
Butyl Benzyl Phthalate
Chlorobenzene
Chloroform
Di-ซ-butyl Phthalate
Di-w-octyl Phthalate
Ethylbenzene
Isophorone
Methylene Chloride
Naphthalene
Phenol
Tetrachloroethene
Toluene
trans- 1,2-Dichloroethene
Trichloroethene
0.0100
0.0200
0.0100
0.0353
0.0100
0.00992
0.0100
0.0100
0.100
0.100
0.0100
0.0100
0.388
0.0100
0.0100
0.321
0.00992
0.00992
10.3
41.3
1.00
42.0
74.4
1.00
1.00
9.98
1.69
18.7
1.00
6.62
18.8
1.00
7.88
41.8
1.00
20.0
1.16
2.60
0.260
11.3
8.89
0.271
0.296
1.30
0.599
3.65
0.207
0.854
4.76
0.303
1.79
9.69
0.271
1.27
18
18
18
18
18
18
18
18
18
18
18
18
18
18
18
18
18
18
5
3
2
16
5
0
5
12
6
17
0
7
18
3
11
18
0
1
28
17
11
89
28
0
28
67
33
94
0
39
100
17
61
100
0
6
Nonconventional Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pentanone
0.0500
0.100
0.552
0.0500
272
2.24
52.7
69.9
25.5
0.892
8.49
5.82
18
18
18
18
11
12
16
11
61
67
89
61
o

-------
                                                                                                       Appendix C - Tables Referenced in Chapter 5
                                                       Table C-4 (Continued)
Wastewater Characterization Data for Heavy Wastewater
Pollutant of Concern
Concentration (mg/L)1
Minimum
Maximum
Mean
Number of
Times
Analyzed
Number of
Times
Detected
Percentage
Detected
(%)
Nonconventional Organics (Continued)
ฐ<-Terpineol
Benzoic Acid
Benzyl Alcohol
Hexanoic Acid
m-Xylene
ซ-Decane
ซ-Docosane
ซ-Dodecane
ซ-Eicosane
ซ-Hexacosane
ซ-Hexadecane
ซ-Octacosane
ซ-Octadecane
ซ-Tetracosane
ซ-Tetradecane
ซ-Triacontane
o-&p-Xylene
p-Cresol
p-Cymene
Pentamethylbenzene
0.100
0.0500
0.0100
0.0100
0.0751
0.100
0.100
0.0459
0.100
0.100
0.269
0.100
0.100
0.0100
0.100
0.0100
0.0438
0.0100
0.0100
0.0100
2.26
12.2
10.7
1.00
25.0
419
2.50
106
26.5
1.28
38.4
1.44
13.6
1.00
41.6
1.00
17.8
1.00
12.2
1.97
0.379
3.36
1.56
0.210
4.47
86.5
0.504
29.5
4.28
0.354
9.11
0.370
4.00
0.289
7.23
0.366
3.59
0.204
3.16
0.412
18
18
18
18
13
18
18
18
18
18
18
18
18
18
18
18
13
18
18
18
6
9
4
1
13
17
7
17
17
5
18
4
17
3
15
4
13
0
11
6
33
50
22
6
100
94
39
94
94
28
100
22
94
17
83
22
100
0
61
33
Priority Metals and Elements
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
0.0200
0.00100
0.000970
0.0236
0.0990
2.08
0.3500
0.000200
0.0541
8.24
0.0396
0.00341
0.331
0.726
11.6
3.78
0.00665
0.861
0.788
0.0125
0.00142
0.121
0.296
5.37
1.60
0.000816
0.266
18
18
18
18
18
18
18
18
18
14
9
7
18
18
18
18
9
18
78
50
39
100
100
100
100
50
100
o

-------
                                                                                                       Appendix C - Tables Referenced in Chapter 5
                                                       Table C-4 (Continued)
Wastewater Characterization Data for Heavy Wastewater
Pollutant of Concern
Concentration (mg/L)1
Minimum
Maximum
Mean
Number of
Times
Analyzed
Number of
Times
Detected
Percentage
Detected
(%)
Priority Metals and Elements (Continued)
Selenium
Silver
Thallium
Zinc
0.000500
0.00230
0.000900
2.54
0.0451
1.25
0.0526
15.7
0.0174
0.199
0.00989
7.79
18
18
18
18
7
13
4
18
39
72
22
100
Nonconventional Metals and Elements
Aluminum
Barium
Boron
Cobalt
Iron
Manganese
Molybdenum
Tin
Titanium
Vanadium
Yttrium
4.10
1.25
0.0310
0.0620
6.89
0.381
0.145
0.0290
0.0843
0.00800
0.000300
21.0
7.22
37.2
3.10
96.6
6.31
2.29
0.589
1.32
0.0892
0.0417
9.97
3.63
4.93
0.449
42.1
1.51
0.668
0.130
0.344
0.0381
0.0101
18
18
18
18
18
18
18
18
18
18
18
18
18
17
18
18
18
18
15
18
16
11
100
100
94
100
100
100
100
83
100
89
61
Bulk Nonconventionals
Chemical Oxygen Demand (COD)
Total Organic Carbon (TOC)
Total Petroleum Hydrocarbon (measured as SGT-HEM)
1,620
106
101
29,300
6,240
4,120
13,700
2,790
1,440
18
18
18
18
18
18
100
100
100
o

-------
                                                Appendix C - Tables Referenced in Chapter 5
Table C-4 (Continued)
Wastewater Characterization Data for Light Wastewater
Pollutant of Concern
Concentration (mg/L)1
Minimum
Maximum
Mean
Number of
Times Analyzed
Number of
Times Detected
Percentage
Detected
(%)
Conventionals
Biochemical Oxygen Demand 5-Day (BOD5)
Oil and Grease (measured as HEM)
Total Suspended Solids (TSS)
120
14.3
124
1,280
430
804
568
154
344
14
14
14
14
14
14
100
100
100
Priority Organics
1, 1, 1-Trichloroethane
1,2-Diphenylhydrazine
4-Chloro-3-methylphenol
Bis(2-ethylhexyl) Phthalate
Butyl Benzyl Phthalate
Chlorobenzene
Chloroform
Di-ซ-butyl Phthalate
Di-w-octyl Phthalate
Ethylbenzene
Isophorone
Methylene Chloride
Naphthalene
Phenol
Tetrachloroethene
Toluene
trans- 1,2-Dichloroethene
Trichloroethene
0.0100
0.0200
0.0100
0.116
0.0100
0.0100
0.0100
0.0100
0.0100
0.0100
0.0100
0.0100
0.0195
0.0100
0.0100
0.0225
0.0100
0.0100
0.100
1.62
0.100
6.02
0.353
0.100
0.100
1.04
0.177
0.282
0.100
0.100
1.04
0.580
0.797
0.110
0.100
0.100
0.0160
0.220
0.0411
1.10
0.0690
0.0160
0.0455
0.104
0.0667
0.0620
0.0400
0.0213
0.358
0.105
0.0977
0.0553
0.0160
0.0160
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
0
2
2
14
7
0
12
4
7
12
0
2
11
7
9
13
0
0
0
14
14
100
50
0
86
29
50
86
0
14
79
50
64
93
0
0
Nonconventional Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pentanone
ฐ<-Terpineol
Benzoic Acid
Benzyl Alcohol
0.0500
0.0100
0.0759
0.0500
0.0100
0.0500
0.0100
0.862
0.198
2.52
2.29
0.449
0.772
0.283
0.147
0.0566
0.518
0.240
0.123
0.306
0.102
14
14
14
14
14
14
14
4
8
13
3
9
5
8
29
57
93
21
64
36
57


-------
                                                                                                       Appendix C - Tables Referenced in Chapter 5
                                                       Table C-4 (Continued)
Wastewater Characterization Data for Light Wastewater
Pollutant of Concern
Concentration (mg/L)1
Minimum
Maximum
Mean
Number of
Times Analyzed
Number of
Times Detected
Percentage
Detected
(%)
Nonconventional Organics (Continued)
Hexanoic Acid
m-Xylene
ซ-Decane
ซ-Docosane
ซ-Dodecane
ซ-Eicosane
ซ-Hexacosane
ซ-Hexadecane
ซ-Octacosane
ซ-Octadecane
ซ-Tetracosane
ซ-Tetradecane
ซ-Triacontane
o-&p-Xylene
p-Cresol
p-Cymene
Pentamethylbenzene
0.0100
0.0173
0.0447
0.0100
0.0100
0.0123
0.0100
0.0107
0.0100
0.0100
0.0100
0.0100
0.0100
0.0108
0.0100
0.0100
0.0100
0.103
0.143
1.62
0.293
10.8
0.756
0.102
1.13
0.100
0.253
0.456
0.771
0.109
0.241
0.100
0.100
0.264
0.0557
0.0555
0.354
0.0591
0.973
0.124
0.0465
0.330
0.0432
0.0850
0.0680
0.103
0.0492
0.0765
0.0400
0.0473
0.0787
14
9
14
14
14
14
14
14
14
14
14
14
14
9
14
14
14
4
9
13
8
9
10
5
11
6
11
5
8
6
9
0
2
4
29
100
93
57
64
71
36
79
43
79
36
57
43
100
0
14
29
Priority Metals and Elements
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
0.0201
0.00100
0.000470
0.00120
0.0165
0.200
0.0460
0.000200
0.0180
0.000500
0.00230
0.000900
13.8
0.0200
0.00148
0.0434
0.317
1.95
0.810
0.00141
0.339
0.0308
0.00820
0.0100
1.32
0.00653
0.000938
0.0211
0.113
0.858
0.348
0.000715
0.101
0.0133
0.00432
0.00313
14
14
14
14
14
14
14
14
14
14
14
14
10
4
5
9
14
14
13
9
11
2
4
0
71
29
36
64
100
100
93
64
79
14
29
0
o

OJ
oo

-------
                                                                                                       Appendix C - Tables Referenced in Chapter 5
                                                       Table C-4 (Continued)
Wastewater Characterization Data for Light Wastewater
Pollutant of Concern
Concentration (mg/L)1
Minimum
Maximum
Mean
Number of
Times Analyzed
Number of
Times Detected
Percentage
Detected
(%)
Priority Metals and Elements (Continued)
Zinc
0.624
2.79
1.47
14
14
100
Nonconventional Metals and Elements
Aluminum
Barium
Boron
Cobalt
Iron
Manganese
Molybdenum
Tin
Titanium
Vanadium
Yttrium
1.87
0.108
0.0360
0.00230
2.26
0.0628
0.0100
0.0290
0.0404
0.00200
0.00030
7.43
0.752
3.07
0.137
27.5
0.353
0.0868
0.211
0.724
0.0393
0.0114
4.65
0.421
0.391
0.0264
10.3
0.184
0.0357
0.0625
0.206
0.0138
0.00313
14
14
14
14
14
14
14
14
14
14
14
14
14
11
6
14
14
11
10
14
4
1
100
100
79
43
100
100
79
71
100
29
7
Bulk Nonconventionals
Chemical Oxygen Demand (COD)
Total Organic Carbon (TOC)
Total Petroleum Hydrocarbon (measured as SGT-HEM)
500
117
5
2,360
540
282
1,410
338
85
14
14
14
14
14
12
100
100
86
p
OJ
VO

-------
                                                                                                       Appendix C - Tables Referenced in Chapter 5
                                                       Table C-4 (Continued)
Wastewater Characterization Data for Total Stream Wastewater
Pollutant of Concern
Concentration (mg/L)1
Minimum
Maximum
Mean
Number of
Times
Analyzed
Number of
Times Detected
Percentage
Detected
(%)
Conventionals
Biochemical Oxygen Demand 5-Day (BOD5)
Oil and Grease (measured as HEM)
Total Suspended Solids (TSS)
82.0
558
60.0
3,470
2,460
4,860
933
1,670
1,200
56
13
56
56
13
56
100
100
100
Priority Organics
1, 1, 1-Trichloroethane
1,2-Diphenylhydrazine
4-Chloro-3-methylphenol
Bis(2-ethylhexyl) Phthalate
Butyl Benzyl Phthalate
Chlorobenzene
Chloroform
Di-ซ-butyl Phthalate
Di-w-octyl Phthalate
Ethylbenzene
Isophorone
Methylene Chloride
Naphthalene
Phenol
Tetrachloroethene
Toluene
trans- 1,2-Dichloroethene
Trichloroethene
0.00100
0.000025
0.000005
0.000420
0.000005
0.000100
0.00200
0.000005
0.000005
0.00200
0.000005
0.00500
0.000014
0.000005
0.00100
0.000500
0.00500
0.000020
5.56
0.200
0.315
38.9
1.23
1.41
0.100
3.49
0.493
3.95
1.77
4.13
13.6
0.464
46.2
20.9
0.100
0.262
0.283
0.0918
0.0684
4.99
0.140
0.131
0.0359
0.245
0.0910
0.634
0.154
0.336
1.47
0.0777
3.91
2.64
0.0204
0.0346
23
20
21
21
21
23
23
21
21
43
21
32
21
24
23
52
19
23
16
0
6
21
8
7
17
7
5
37
7
16
18
9
20
46
0
9
70
0
29
100
38
30
74
33
24
86
33
50
86
38
87
88
0
39
Nonconventional Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pentanone
ฐ<-Terpineol
Benzoic Acid
Benzyl Alcohol
0.00500
0.0150
0.00500
0.00500
0.0100
0.0200
0.0100
47.5
0.405
61.8
16.7
2.27
3.13
1.29
2.51
0.166
10.9
1.67
0.258
0.648
0.143
25
17
25
19
16
17
17
17
13
23
14
7
9
7
68
76
92
74
50
53
41
p

-k
o

-------
                                                Appendix C - Tables Referenced in Chapter 5
Table C-4 (Continued)
Wastewater Characterization Data for Total Stream Wastewater
Pollutant of Concern
Concentration (mg/L)1
Minimum
Maximum
Mean
Number of
Times
Analyzed
Number of
Times Detected
Percentage
Detected
(%)
Nonconventional Organics (Continued)
Hexanoic Acid
m-Xylene
ซ-Decane
ซ-Docosane
ซ-Dodecane
ซ-Eicosane
ซ-Hexacosane
ซ-Hexadecane
ซ-Octacosane
ซ-Octadecane
ซ-Tetracosane
ซ-Tetradecane
ซ-Triacontane
o-&p-Xylene
p-Cresol
p-Cymene
Pentamethylbenzene
0.0100
0.0393
1.31
0.0200
1.13
0.0200
0.0200
0.0200
0.0100
0.0382
0.0200
0.236
0.0296
0.125
0.0100
0.0100
0.0100
0.327
25.3
712
3.04
17.5
6.41
3.28
22.5
0.250
8.97
8.34
19.9
0.531
9.45
0.100
0.360
2.33
0.125
4.35
73.6
0.659
6.16
1.97
0.413
4.76
0.0853
1.78
1.51
4.44
0.144
2.48
0.0585
0.138
0.242
16
18
16
16
16
16
16
16
16
16
16
16
16
18
16
16
16
6
18
16
13
16
15
14
15
6
16
14
16
11
18
0
10
1
38
100
100
81
100
94
88
94
38
100
88
100
69
100
0
62
6
Priority Metals and Elements
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
0.0463
0.00100
0.000880
0.00300
0.00360
0.0357
0.00500
0.000100
0.0100
0.00100
0.000500
0.00100
0.144
0.180
0.0200
0.290
3.59
7.86
3.26
0.00800
3.07
0.258
0.500
0.130
0.0913
0.0183
0.00598
0.0641
0.315
1.74
0.955
0.00128
0.305
0.0550
0.0316
0.0190
17
36
17
47
50
49
50
36
46
30
53
17
13
22
9
44
40
49
49
25
40
18
36
2
76
61
53
94
80
100
98
69
87
60
68
12


-------
                                                                                                                                Appendix C - Tables Referenced in Chapter 5
                                                                    Table C-4 (Continued)
Wastewater Characterization Data for Total Stream Wastewater
Pollutant of Concern
Concentration (mg/L)1
Minimum
Maximum
Mean
Number of
Times
Analyzed
Number of
Times Detected
Percentage
Detected
(%)
Priority Metals and Elements (Continued)
Zinc
0.139
12.5
2.85
50
50
100
Nonconventional Metals and Elements
Aluminum
Barium
Boron
Cobalt
Iron
Manganese
Molybdenum
Tin
Titanium
Vanadium
Yttrium
0.441
0.240
0.0500
0.0619
13.6
0.190
0.110
0.0290
0.0190
0.00820
0.00200
25.3
2.93
1.89
0.289
111
2.19
0.793
1.12
0.747
0.190
0.0575
8.24
1.31
0.689
0.169
39.5
0.627
0.363
0.278
0.251
0.0678
0.0199
24
23
17
17
17
20
17
17
17
17
17
24
23
15
13
17
20
17
12
17
14
8
100
100
88
76
100
100
100
70
100
82
47
Bulk Nonconventionals
Chemical Oxygen Demand (COD)
Total Organic Carbon (TOC)
Total Petroleum Hydrocarbon (measured as SGT-HEM)
528
229
139
10,600
2,700
1,170
6,090
1,160
682
27
17
13
27
17
13
100
100
100
p

-k
to
       'The detection limit concentration was used in calculations for data points reported as nondetects.

-------
                                                         Appendix D - References Used for Chapter 7
                                  Appendix D

                         References Used in Chapter 7
Calculations of Long-Term Averages and Variability Factors and Facility Level and
                   Performance Data for Pollutants of Concern

-------
                                                              Appendix D - References Used for Chapter 7

                                     Reference D-l
                            Description Of Data Conventions

This section discusses the types of data in the IL analytical database and the hierarchy and
procedures for aggregating multiple sampling observations within a sampling day.

1.1           Data Review

The EPA wastewater sampling data in the analytical database were thoroughly reviewed and
validated by the EPA's Sample Control Center (further discussions of this data are at times
referred to as the "SCC" data for this reason). During this review, the integrity of each sample
was assessed to ensure that all specifications of the sampling protocol were met.  The reviewers
determined that some samples should be excluded from the analyses.  Samples with flags of
"EXCLUDE" or "DETECTED," which indicate a value was detected but the concentration value
was not recorded, were excluded from the analyses.

Also during the data review, several samples were qualified with a greater than (>) sign, indicating
the reported concentration value is considered a lower limit of the actual value.  This is because
the reported concentration was outside  the range of the analytical method.  When possible, these
samples are diluted and reanalyzed.  Otherwise these samples were handled as right-censored
samples and excluded from all calculations.

An engineering review of the database was also conducted and a few additional data values were
excluded from the analyses for the reasons summarized in Chapter 9 of the Technical
Development Document for Proposed Pretreatment Standards for Existing and New Sources for
the Industrial Laundries Point Source Category (EPA Report No. EPA-821 -R-97-007). One
reason for such an exclusion would be if a pollutant was not detected in sufficient concentrations
to evaluate treatment effectiveness.

1.2           Data Types

The IL analytical database (from the SCC and DMQ data) contains the following three different
types of samples delineated by certain qualifiers in the database:

•   Noncensored (NC):  a measured value, i.e., a sample measured above the level at which the
    detection decision was made.

•   Nondetect (ND):  samples for which analytical measurement did not yield a  concentration
    above the sample-specific detection limit.

•   Right-censored (RC):  samples qualified with a greater than (>) sign, signifying that the
    reported value is considered a lower limit of the actual concentration.  All RC values were
    excluded from the analyses because these values could not be quantified with certainty.
                                          D-l

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                                                              Appendix D - References Used for Chapter 7
                               Reference D-l (Continued)
1.3
   Data Aggregation
Data aggregation for the IL analytical data was performed at two levels. This section discusses
the different levels and approaches for data aggregation, including multiple grab samples (one or
more samples collected for a particular sampling point over time, assigned different sample
numbers, and not physically composited) and field duplicates (one or more samples collected for
a particular sampling point at approximately the same time, assigned different sample numbers,
and flagged as duplicates for a single episode number).
1.3.1
   Data Aggregation Across Multiple Grab Samples
The first type of data aggregation performed was for multiple grab samples. Within the SCC
database, SGT-HEM was reported as concentrations of multiple grab samples taken during one-
day sampling periods. Since long-term averages (LTAs) and limitations were based on daily
concentrations, multiple observations on a single day at the same sample point were averaged.
When all of the samples in a set were NC, i.e., detected samples, the arithmetic average of the
samples was straightforward.  However, when one or more of the samples were censored, or ND,
multiple grab samples were aggregated within each sampling day/sample point combination using
the methods identified in Table 1-1.

                                        Table 1-1
                      Method for Averaging Multiple Grab Samples

If observations are:
A11NC
A11ND
NC and ND
I.Max. NO
Max. Detection Limit
2. Max. NC <
Max. Detection Limit
Label of
"average"
NC
ND

NC


ND

Value of "average" is:
SNC,/n
Maximum Detection Limit

(SNQ +SND1)/n


Max. Detection Limit
1.3.2
n=number of grab samples per day.
NC = noncensored values
ND = nondetected values

   Aggregation of Field Duplicates
Another type of data aggregation for the IL SCC data was performed due to the identification of
field duplicates in the database. The field duplicates are defined as one or more samples collected
for a particular sampling point at approximately the same time, assigned different sample numbers,
and flagged as duplicates for a single episode number/sampling point.  Duplicates were collected
for purposes of quality assurance/quality control.  Table 1-2 presents the methods used to
aggregate duplicates. Note that within the DMQ data no field duplicates
                                           D-2

-------
                                                               Appendix D - References Used for Chapter 7
                                Reference D-l (Continued)
were labeled, but for a few sample days, two concentrations were reported.   Since there were
only two concentrations reported within sample day, the aggregation method would be the same
regardless of whether they were treated as grab samples or duplicate samples. Thus, these
concentrations were classified as duplicate samples and were aggregated according to the
methods outlined in Table 1-2.
                                        Table 1-2
                     Method for Averaging Field Duplicate Samples
If observations are:
Both NC
BothND
NC and ND
1 . NC > Detection Limit
2. NC < Detection Limit
Label of
"average"
NC
ND
NC
ND
Value of "average" is:
SNC/2
Maximum Detection Limit
(NC + ND)/2
Detection Limit
 NC = noncensored values
 ND = nondetected values
If a sample had both multiple grabs and field duplicates, the multiple grabs were aggregated first.
                                           D-3

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                                                              Appendix D - References Used for Chapter 7

                                     Reference D-2
               Statistical Methodology - Modified Delta-Lognormal Model

2.1           Basic Overview of Delta-lognormal Distribution

The lognormal distribution is often appropriate for modeling effluent data. However, the
presence of ND and very low concentration measurements in the IL effluent data led to the
consideration of a modification to the lognormal distribution in modeling such data for several
reasons. First, the lognormal model assumes that all concentration values are positively valued.
Second, the actual values of NDs are not known, though each ND has a concentration somewhere
between zero and the reported detection limit. In this sense, ND measurements represent, in
statistical terms, what are known as censored samples.

In general, censored samples are measurements for which the exact value is not known but are
bounded either by an upper or lower numerical limit. Nondetects qualify in this framework as
left-censored samples, which have an upper bound at the detection limit and a lower bound at
zero.  To model NDs as left-censored samples under a strictly lognormal density model, it is
necessary to assume that the exact (but unknown) values of these measurements follow the same
lognormal distributional pattern as the rest of the detected measurements and that they are
positively valued (i.e., greater than zero).

Therefore, two reasonably simple modifications to  the lognormal density model have been used by
the EPA for several years.  The first modification is known as the classical delta-lognormal model
(Figure 2-1), first used in economic  analysis to model income and revenue patterns (see Atchison
and Brown, 1955).  In this adaptation of the simple lognormal density, the model is expanded to
include zero amounts.  To do this, all positive (dollar) amounts are grouped together and fit to a
lognormal density.  Then all zero amounts are segregated into another group of measurements
representing a discrete distributional "spike" at zero. The resulting mixed distribution, combining
a continuous density portion with a discrete-valued spike, is known as the delta-lognormal
distribution. The delta in the name refers to the percentage of the overall distribution contained in
the spike at zero, that is, the percentage of zero amounts.

                                       Figure 2-1
                                Delta-Lognormal Model
          Non-Detects   /           ^	^	  De(ects
                                          D-4

-------
                                                              Appendix D - References Used for Chapter 7
                               Reference D-2 (Continued)
Researchers at the EPA (see Kahn and Rubin, 1989) further adapted the classical delta-lognormal
model ("adapted model") to account for ND measurements in the same fashion that zero
measurements were handled in the original delta-lognormal. Instead of zero amounts and non-
zero (positive) amounts, the data consisted of NDs and detects. Rather than assuming that NDs
represented a spike of zero concentrations, these samples were allowed to have a single positive
value, usually equal to the minimum level of the analytical method (Figure 2-2).  Since each ND
was assigned the same positive value,  the distributional spike in this adapted model was located
not at zero, but at the minimum level.  This adaptation is appropriate since it is known that the
NDs are some value greater than zero.  This adapted model was used in developing limitations for
the Organic Chemicals, Plastics, and Synthetic Fibers (OCPSF) and pesticides manufacturing
rulemaking.

                                       Figure 2-2
                            Adapted Delta-Lognormal Model
                                                Detects
                 0 51015 20
In the adapted delta-lognormal model, the delta again referred to those measurements contained
in the discrete spike, this time representing the proportion of ND values observed within the data
set. By using this approach, computation of estimates for the population mean and variance could
be done easily by hand, and NDs were not assumed to follow the same distributional pattern as
the detected measurements. The adapted delta-lognormal model can be expressed mathematically
as follows:
           Pr (U  =
(1-6) 
 fl
[aogfr)
if
if
if
0< u <
u = D
u >  D
                                                                     D
(2.1)
where 5 represents the true proportion of NDs (or the probability that any randomly drawn
measurement will be a ND), D equals the minimum level value of the discrete spike assigned to all
NDs, <&(•) represents the standard normal cumulative distribution function, and |i and  a are the
parameters of the lognormal density portion of the model. This model assumes that all
nondetected values have a single detection limit D.

It is also possible to represent the adapted delta-lognormal model in another mathematical form,
one in which it is particularly easy to derive formulas for the expected value (i.e., LTA) and
                                          D-5

-------
                                                              Appendix D - References Used for Chapter 7
                               Reference D-2 (Continued)

variance of the model. In this case, a random variable distributed according to the adapted delta-
lognormal distribution can be represented as the stochastic combination of three other
independent random variables.  The first of these variables is an indicator variable, Iu, equal to one
when the measurement u is a ND and equal to zero when u is a detected value. The second
variable, XD, represents the value of a ND measurement (discrete). In the adapted delta-
lognormal, this variable is always a constant equal to the concentration value assigned to each ND
(i.e., equal to D in the adapted delta-lognormal model). In general, however, XD need not be a
constant, as will be seen below in the modified delta-lognormal model. The final random variable,
Xc, represents the value of a detected measurement, and is distributed according to a lognormal
distribution (continuous) with parameters |i and a.

Using this formulation, a random variable from the adapted delta-lognormal model can be written
as:
                              U = IUXD  +(!-ซ;                                  (2.2)


and the expected value of U is then derived by substituting the expected value of each quantity in
the right-hand side of the equation.  Because the variables Iu, XD, and Xc are mutually
independent, this leads to the expression:
               E(U)  = bE(XD)+(\-b)E(Xc)  = dD + (l-5)exp(n  +  0.5 a2)                   (2.3)


where again 5 is the probability that any random measurement will be ND and the exponentiated
expression is the familiar mean of a lognormal distribution. In a similar fashion, the variance of
the adapted delta-lognormal model can be established by squaring the expression for U above,
taking expectations, and subtracting the square of E(U) to get:
  Var(U) = E(U2)  -  [E(U)}2  = bVar(XD) + (\-8)Var&c) + b(l-b)[E(XD)-E(Xc)}2.           (2 4)


Since, in the adapted  delta-lognormal formulation, XD is a constant, this expression can be
reduced to the following:
    Var(U) = (l-6)exp(2n+o2)[exp(a2)-(l-6)] + 6(l-6)JD[JD-2exp((i+0.5a2)].              (2.5)


In order to estimate the adapted delta-lognormal mean and variance from a set of observed sample
measurements, it is necessary to derive sample estimates for the parameters 5, |i, and a.  5 is
typically estimated by the observed proportion of NDs in the data set.  |i and a are estimated
using the log values of the detected samples where |i is estimated using the arithmetic mean of the
log detected measurements and a is estimated using the standard deviation of these same log
values; NDs are not included in the calculations.  Once the parameter estimates are obtained, they
are used in the formulas above to derive the estimated adapted delta-lognormal mean and
variance.
                                           D-6

-------
                                                               Appendix D - References Used for Chapter 7
                                Reference D-2 (Continued)

To calculate effluent limitations and/or standards, it is also necessary to estimate upper percentiles
from the underlying data model. Using the delta-lognormal formulation above in equation (2.1),
letting Ua represent the 100*ath percentile of random variable U, and adopting the standard
notation of zs for the sth percentile of the standard normal distribution, an arbitrary delta-
lognormal percentile can be expressed as the following:
                          D         if  6+(l-6)O((log(Z))-(i)/a) >a                    (2.6)
The daily maximum limitations are established on the basis of an estimated upper 99th percentile
from the underlying data model, so that 0.99 would be substituted for a in the above expression.
To derive the daily VF for the 99th percentile based on the adapted delta-lognormal model, divide
U99 in the expression above by the previous formula for the LTA, namely U99/E(U).

2.2           Motivations for Modifications to the Adapted Delta-Lognormal Model

While the adapted delta-lognormal model has been used successfully for years by the EPA in a
variety of settings, the model makes two key assumptions about the observed data that are not
fully satisfied within the IL analytical database. First, the discrete spike portion of the adapted
delta-lognormal model is a fixed,  single-valued probability mass associated (typically) with all ND
measurements.  If all ND samples in the IL database had roughly the same reported detection
limit,  this assumption would be adequately satisfied.  However, the detection limits reported are
sample specific and, therefore, varied as a result of factors such as dilution. Because of this
variation in detection limits, a single-valued discrete spike could not adequately represent the set
of ND measurements observed in the IL database and a modification to the model was
considered.

In addition, the adapted delta-lognormal model sets all NC values below the detection to the
minimum level of the analytical method. For example, if the minimum level for Toluene was .10
mg/1,  then any NC samples reported below .10 mg/1 were set to . 10 mg/1.  There were a few
instances in the IL analytical studies where a NC value was reported below the minimum level of
the analytical method.

2.2.1          Modification of the Discrete Spike

To appropriately modify the adapted delta-lognormal model for the observed IL database, a
modification was made to the discrete, single-valued spike representing ND measurements.
Because ND samples have varying detection limits, the spike of the delta-lognormal model has
been replaced by a discrete distribution made up of multiple spikes. Each spike in this
modification is associated with a distinct detection limit observed in the IL database.  Thus,
instead of assigning all NDs to a single, fixed value, as in the adapted model, NDs can be
associated with multiple values depending on how the detection limits vary (Figure 2-3).
                                           D-7

-------
                                                               Appendix D - References Used for Chapter 7
                                Reference D-2 (Continued)
                                        Figure 2-3
                        Modified Adapted Delta-Lognormal Model
            Non-Detects
                 \
                 \
                                                 Detects
                 0 5101520
In particular, because the detection limit associated with a ND sample is considered to be an
upper bound on the true value, which could range conceivably from zero up to the detection limit,
the modified delta-lognormal model used here assigns each ND sample to its reported detection
limit.

Once each ND has been associated with its reported detection limit, the discrete "delta" portion of
the modified model is estimated in a way similar to the adapted delta-lognormal distribution,
where multiple spikes are constructed and linked to the distinct detection limits observed in the
data set.  In the adapted model, the parameter 5 is estimated by computing the proportion of
NDs. In the modified model, 5 again represents the proportion of NDs, but is divided into the
sum of smaller fractions, 5;, each representing the proportion of NDs associated with a particular
and distinct detection limit. This can be written as:
                                                                                     (2.7)
If D; equals the value of the ith smallest distinct detection limit in the data set, and the random
variable X represents a randomly chosen ND sample, then the discrete distribution portion of the
modified delta-lognormal model can be mathematically expressed as:
                                Pr(XD
-------
                                                                  Appendix D - References Used for Chapter 7
                                 Reference D-2 (Continued)

It is important to recognize that, while replacing the single discrete spike in the adapted delta-
lognormal distribution with a more general discrete distribution of multiple spikes increases the
complexity of the model, the discrete portion with multiple spikes plays a role in limitations and
standards development identically parallel to the single spike case and offers flexibility for
handling multiple observed detection limits.
                                             D-9

-------
                                                              Appendix D - References Used for Chapter 7

                                     Reference D-3
                 Estimation Under The Modified Delta-Lognormal Model

Once the modifications to the adapted delta-lognormal distribution are made, it is possible to fit a
wide variety of observed effluent data sets to the modified model. Multiple detection limits for
NDs can be handled.  The same basic framework can be used even if there are no NT) values or
censored data.
Combining the discrete portion of the model with the continuous portion, the cumulative
probability distribution of the modified delta-lognormal model can be expressed as follows, where
Dn denotes the largest distinct detection limit observed among the NDs, and the first summation is
taken over all those values, D;, that are less than u:
             Pr(UD
                                                               (3.1)
Again combining the discrete and continuous portions of the modified model, the expected value
of the random variable U can be derived as a weighted sum of the expected values of the discrete
and continuous lognormal portions of the distribution. This follows because the modified delta-
lognormal random variable U can be expressed again as a combination of three other independent
variables, that is:
                                =  IUXD
                     (1 -
(3.2)
where this time XD represents a random NT) from the discrete portion of the model, Xc represents
a random detected measurement from the continuous lognormal portion, and Iu is an indicator
variable signaling whether any particular random measurement is detected or not. Then the
expected value and variance of U have forms somewhat similar to the standard delta-lognormal
model, namely:
E(U) =
                                       (l-6)expOi+0.5a2)
(3.3)
           Var(U)  =
                         5(1-5)
                         - 6)exp(2|i + o2)(exp(o2) -
                   •-exp(|i+0.5a2)
                                                                                   (3.4)
where the     D;
              Dj
              6,
  detection limit for the ith NT) value
  detection limit for the jthND value, where i < j
  proportion of NDs with detection limit = D;
                                          D-10

-------
                                                               Appendix D - References Used for Chapter 7
                                Reference D-3 (Continued)
              5j      = proportion of NDs with detection limit = Dj
              5      = proportion of all NDs
              |i      = mean log concentrations of noncensored (NC) values
              a      = standard deviation of log NC values.

For example, consider a facility that has 10 samples with the following concentrations:
Sample number
1
2
3
4
5
6
7
8
9
10
Measurement Type
ND
ND
ND
ND
NC
NC
NC
NC
NC
NC
Concentration (mg/L)
10
15
15
20
25
25
30
35
35
40
Then the mean and variance of the log NC values are calculated as follows:
                                               n
                        (2*ln(25) + ln(30) + 2*ln(35)  + ln(40))
                                                                =  3.44
       1 (2*(ln(25)-3.44)2)  + (ln(30)-3.44)2 + 2*(ln(35)-3.44)2) +(ln(40)-3.44)2) =  .0376
                                           D-ll

-------
                                                                   Appendix D - References Used for Chapter 7
                                    Reference D-3 (Continued)
     The ND components of the variance equation are:

     D! = 10,5! = 1/10
     D2=15, 52=l/5
     D3 = 20, 53= 1/10.
     As such, the variance for this example is:
Var(x) =
_L*!(10-15)2 + -L*-L(10-20)2 + I*_L(15-20)2 ,
10 5 10 10 5 10 ^(^
2(l 2\
A >)
2 (~
5
( 10 1 ( 5 I 1 10 I ,- ,,
exp^j. i i
5
- lpxnr?*3 444. n^7^^Vr,rn^57^ n
+0.5*.0376)
2
QS 8

     3.1
     3.1.1
Facility-Specific Estimates
Estimation of Facility-Specific LTAs
     For the purposes of estimating facility-specific LTAs (equal to the expected value in the equation
     (3.3)), the EPA chose to divide the IL data sets into two groups based on their size (number of
     samples) and the type of samples in the subset because the computations differ for each group.
     The groups were defined as follows:
                   Group 1:
             Less than 2 NC samples or less than 4 total samples.
                   Group 2:     Two or more NC samples or 4 or more total samples.

     For Group 1, the LTAs were calculated as the arithmetic average of the samples, since the sample
     sizes for either the discrete portion or the continuous lognormal portion of the data were too
     small to allow distributional assumptions to be made. Specifically, Group 1 contained all data
     subsets with all NDs or only one detect.  Sample-specific detection limits were substituted as the
     values associated with nondetectable samples.

     For Group 2, the LTAs were calculated using the procedures outlined in the preceding section
     using equation (3.3) and the Maximum Likelihood Estimates (MLEs) for |i and a.
                                               D-12

-------
                                                              Appendix D - References Used for Chapter 7
                               Reference D-3 (Continued)

3.1.2          Estimation of Facility-Specific VFs

After determining estimated LTA values for each pollutant, facility, and option combination, the
EPA developed 1-day variability factors (VF1) and/or 4-day variability factors (VF4) depending
on the proposed frequency of monitoring, as  outlined in Table 3-1.

                                       Table 3-1
                         EPA Proposed Monitoring Frequencies
Pollutant Category
Metals, Organics
Classicals
Frequency of Monitoring
Monthly (Wl)
Weekly (Wl, VF4)
Similar to the calculations for the LTAs, the data were divided into the same two computation
groups based on the number and type of samples in each data subset for purposes of estimating
variability factor.  These computation groups are defined as follows:

              Group 1:     Less than 2 NC samples or less than 4 total samples. Upper
                           percentiles and VFs could not be computed using the modified
                           delta-lognormal methodology.

              Group 2:     Two or more NC samples and 4 or more total samples.  The
                           estimates of the parameters for the modified delta-lognormal
                           distribution of the data were calculated using maximum likelihood
                           estimation in the log-domain. Upper percentiles and VFs were
                           calculated using these estimated parameters.

Several data subsets belong in Group 1, and therefore have missing 99th percentiles and VFs.

3.1.2.1        Estimation of Facility-Specific VF1

The VF1 are a function of the LTA, E(U), and the 99th percentile.  An iterative approach was
used in finding the 99th percentile of each data subset using the modified delta-lognormal
methodology by first defining D0=0, 50=0, and Dk+1 = ฐฐ as boundary conditions, where D; equals
the ith smallest detection limit, and 5; is the associated proportion of NDs at the ith detection limit.
A cumulative distribution function, p, for each data subset was computed as a step function
ranging from 0 to 1. The general form, for a given value c, is

                                1ฐง1C) ~ ^    n   ^  ^  <- n     ™-n i   L             (3 o
   ES   i-t   S\
   6; + (l-6)
!=0
                                   0
                                          D-13

-------
                                                              Appendix D - References Used for Chapter 7
                               Reference D-3 (Continued)
where <& is the standard normal cumulative distribution function. The following steps were
completed to compute the estimated 99th percentile of each data subset:

              1.      k values of p at c=Dm, m=l,...k were computed and labeled pm.

              2.      The smallest value of m, such that pm > 0.99, was determined and labeled
                     as PJ.  If no such m existed, steps 3 and 4 were skipped and step 5 was
                     computed instead.

              3.      Computed p* = PJ - 5j.

              4.      If p*< 0.99, then P99 = Dj,
                     else if p*> 0.99, then
A+*->
'( '-1 V
0.99 -ฃ 6 1
I ป-=o )
(1-5)
a
           P99 = exp
        5.     If no such m exists, such that pm > 0.99 (m=l,...k), then

         P99 = expfA+^f0-"-81
                                                                                   (3.6)
The daily
                          . 0-S).  .

dly variability factor, VF1, was then calculated as
                         PQQ
                                                                                   (3.7)
                        VF1 =
                         P99
                         E(U)'
                                                                                  (3.8)
3.1.2.2
        Estimation of Facility-Specific VF4
Since the EPA is assuming for costing purposes that the Classical Pollutant, SGT-HEM, will be
monitored weekly (approximately 4 times a month), the EPA calculated a VF for monthly
averages based on the distribution of 4-day averages.  In order to calculate the VF4, the
assumption was made that the approximating distribution of U4, the sample mean for a random
sample of 4 independent concentration values, is also derived from this modified delta-lognormal
distribution, with the same mean as the distribution of the concentration values. The mean of this
distribution of 4-day averages is
                 E(U4)  =
                                                                                   (3.9)
                                          D-14

-------
                                                               Appendix D - References Used for Chapter 7
                               Reference D-3 (Continued)
where (X4)D denotes the mean of the discrete portion of the distribution of the average of four
independent concentration values (i.e., when all observations are not detected), and (X4)c denotes
the mean of the continuous lognormal portion of the distribution.

First, it is assumed that the probability of detection (5) on each of the four days is independent of
that on the other days, since these samples are not taken on consecutive days and are therefore
not correlated such that 64 = 54. Also, since

                                            =  E(XD]
then
                                        (l-54)exp(n4
                                                                                   (3.10)
and since E(U4) = E(U), then
                        4 =  loง
                                     (1-54)
                                                 -0.5o24.
                                                                                   (3.11)
The expression for o24 was derived from the following relationship

    Far(f/4)  = 54Far((JQ)I)) + (1-54)Far((JQ)c)  + 64(l-(

Since

                          Var(Xn)
              Var((X4)D) =	1-21    E(XJD=E(XD\   and
                                                                                   (3.12)
                                                                                   (3.13)
then
     Var(U,}  =
                                                 54(1 -S4)[E(XD) -E(X4)C]2.
(3.14)
                                          D-15

-------
                                                           Appendix D - References Used for Chapter 7
                              Reference D-3 (Continued)
This further simplifies to
Var(U4) =
        -54(l-54)
                         462

                        k  6D
                                        (l-64)exp(2n4+o24)[exp(a24)-l]
                               - exp(n4+0.5a24)
and furthermore,
exp(o24)-l  =
Then, from (3.10) above,
                                     (E(U) -
                                              ; = 1
                      (1-54)
                                     (1-54)
                                                                         (3.15)
k k
ฐ2 E E 8A<
Vnr(TT \ ' ^ KJ J ^
> ซrw4;

D,~Df
fi2n fi4"i

" 2
E S;D . - 5 exp(|i4 + 0.5o24)
                                     (l-54)exp(2n4 + o24)
                                                     -,   since E(U4)=E(U)
                                                                               (3.16)
and letting
                                  then,  exp(n4+0.5o24) =

Furthermore,
         1 +

                                            -52(l-54)
                                                ^
                                                                  A
                                                                  6r|
                                            42
                                        (1-54)
                                                                         (3.18)
                                                                               (3.19)
                                        D-16

-------
                                                              Appendix D - References Used for Chapter 7
                               Reference D-3 (Continued)

Since Var(U4) = Var(U)/4, then, by rearranging terms,
 o24  = log
                                 o-64)62E ฃa,
                                          ; = 1
                                          ฃ a^l-ft4)-a*!
                    4r|2
                    4r|2
                                                                                   (3.20)
Thus, estimates of |i4 and o4 were derived by using estimates of 6l3...6k (sample proportion of
NDs at observed detection limits D^.^D^, ji (MLE of logged values), and a2 (MLE logvariance
with sample bias adjustment) in the equations above.

In finding the estimated 95th percentile of the average of four observations (four NDs, not all at
the same detection limit), an average can be generated that is not necessarily equal to Dl3 D2,..., or
Dk. Consequently, more than k discrete points exist in the distribution of the 4-day averages.  For
example, the average of four NDs at k=2 detection limits are at the following discrete points with
the associated probabilities:

                             /       D*                5*
1
2
3
4
5
D, V
(3D, +D2)/4 451352
(2Z)1+2Z)2)/4 65 j2522
(Z)1+3Z)2)/4 45^^
-*-^o "o
In general, when all four observations are not detected, and when k detection limits exist, the
multinomial distribution can be used to determine associated probabilities, that is,
                      Pr
f/,=-
                                              4!
-na"
                                                         (3.21)
                                                  ','; = !
The number of possible discrete points, k*, for k=l,2,3,4, and 5 are given below:
                                         k
                                         1
                                         2
                                         O

                                         4
                                         5
                      k!
                      1
                      5
                      15
                      35
                      70
                                          D-17

-------
                                                                Appendix D - References Used for Chapter 7
                                Reference D-3 (Continued)

To find the estimated 95th percentile of the distribution of the average of four observations, the
same basic steps (described in Section 3. 1.2. 1) as used for the 99th percentile of the distribution of
daily observations were followed with the following changes:

              1.      Change P99 to P95, and 0.99 to 0.95.
              2.      Change Dm to Dm*, the weighted averages of the detection limits.
              3.      Change 5; to 5;*.
              4.      Change k to k*, the number of possible discrete points based on k detection
                     limits.
              5.      Change the estimates of 5, |i, and a to estimates of 64,  |i4, and o4,
                     respectively.

Then, the estimate of the 95th percentile 4-day mean VF is:
                    VF4 = -- ,     since   E(UJ  = E(U).                        (3 22)
                           E(U)
                                           D-18

-------
                                                        Appendix D - References Used for Chapter 7
               Reference D-4
Long-Term Averages and Variability Factors
    Chemical Emulsion Breaking (CEB)
Analyte
2-METHYLNAPHTHALENE
2-PROPANONE
4-CHLORO-3-METHYLPHENOL
4-METHYL-2-PENTANONE
ALPHA-TERPINEOL
ALUMINUM
ANTIMONY
BIS (2-ETHYLHEXYL) PHTHALATE
BOD 5-DAY (CARBONACEOUS)
BORON
CADMIUM
CHEMICAL OXYGEN DEMAND (COD)
CHROMIUM
COPPER
DI-N-BUTYL PHTHALATE
DI-N-OCTYL PHTHALATE
ETHYLBENZENE
HEXANOIC ACID
IRON
LEAD
M-XYLENE
MANGANESE
Episode
SI
SI
SI
SI
SI
SI
SI
SI
SI
SI
SI
SI
SI
SI
SI
SI
SI
SI
SI
SI
SI
SI
Inf
# Obs
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
Inf
# ND
0
0
4
0
4
0
0
0
0
0
o
0
0
0
2
2
0
4
0
0
0
0
Inf
Est. LTA Eff
(mg/L) # Obs
1.
^
0 .
2.
0 .
16.
0 .
312.
2400.
1.
0 .
11900.
0 .
4 .
4 .
0.
0 .
0.
68.
2.
2.
0.
.59 4
. 90 4
.18 4
.75 4
.10 4
. 90 4
.26 4
.00 4
. 00 4
. 93 4
.20 4
.00 4
.59 4
.40 4
.78 4
.49 4
. 88 4
.12 4
.70 4
.49 4
.52 4
.79 4
Eff
# ND
0
0
1
2
4
0
0
0
0
0
0
0
0
0
4
0
0
1
0
0
0
0
Eff
Est. LTA
(mg/L)
0 .
1.
0 .
0.
0 .
6.
0 .
0.
1040.
1.
0 .
2460.
0 .
0.
0 .
0.
0 .
0.
47 .
0.
0 .
0.
. 05
. 21
.21
.07
. 01
33
.20
. 46
. 00
. 64
.13
.00
.15
. 44
. 01
.03
.31
.13
.30
. 91
.37
.60
Eff
1-Day
VF
3.57
1.81
3. 80
1.33

1.85
1.20
3.67
1. 65
1. 90
1.24
1.21
1. 41
1.76

3.70
4.74
1. 94
1. 45
1.32
1. 61
1.37
Eff
4-day
VF
1. 65
1.24
1. 81
1.25

1.25
1. 07
1.68
1.20
1.26
1. 08
1.07
1.13
1.23

1.68
1. 91
1.52
1.14
1.10
1.19
1.12

-------
                                                            Reference D-4 (Continued)
                                                                                                                 Appendix D - References Used for Chapter 7
to
o
Analyte
MOLYBDENUM
N-DECANE
N-DOCOSANE
N-DODECANE
N-EICOSANE
N-HEXACOSANE
N-HEXADECANE
N-OCTACOSANE
N-OCTADECANE
N-TETRADECANE
NAPHTHALENE
NICKEL
O+P XYLENE
OIL AND GREASE (AS HEM)
TETRACHLOROETHENE
TITANIUM
TOLUENE
TOTAL ORGANIC CARBON (TOC)
TOTAL PETROLEUM HYDROCARBON (AS SGT-HEM)
TOTAL SUSPENDED SOLIDS
ZINC
Episode
SI
SI
SI
SI
SI
SI
SI
SI
SI
SI
SI
SI
SI
SI
SI
SI
SI
SI
SI
SI
SI
Inf
# Obs
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
Inf
# ND
0
0
2
0
0
4
0
4
0
0
0
0
0
0
1
0
0
0
0
0
0
Inf
Est. LTA Eff
(mg/L) # Obs
1.
41.
0.
3220.
13.
0 .
12 .
0 .
4 .
2.
5 .
0 .
2.
5140.
2
0 .
2.
1260.
3090.
4320.
8.
.12 4
.30 4
.84 4
. 00 4
. 80 4
.34 4
.00 4
.37 4
.17 4
. 87 4
.38 4
. 60 4
.59 4
. 00 4
.30 4
.52 4
.06 4
. 00 4
.00 4
. 00 4
.71 4
Eff
# ND
0
0
0
3
0
4
0
4
2
0
0
0
0
0
0
0
0
0
0
0
0
Eff
Est. LTA
(mg/L)
0.
0 .
0.
0 .
0.
0 .
0.
0 .
0.
0 .
0.
0 .
0.
268.
0.
0 .
0.
626.
200.
259.
6.
. 21
.28
.03
. 57
.08
. 01
.04
. 01
.06
.12
.10
.26
.36
. 00
.29
. 08
.54
. 00
.00
. 00
.78
Eff
1-Day
VF
1.80
4 .24
3. 67

3.28

3. 42

10. 90
2. 87
1.82
1. 67
1.72
3.54
2. 91
1.28
1.79
1. 41
3.51
2.51
1.33
Eff
4-day
VF
1.
1.
1.

1.

1.

3 .
1.
1.
1.
1.
1.
1.
1.
1.
1.
1.
1.
1.
. 2 4
. 80
.68

. 59

. 62

.18
. 50
.25
.21
.22
. 65
.51
. 09
. 2 4
.13
. 64
. 42
.11

-------
                                                                                             Appendix D - References Used for Chapter 7
                                                  Reference D-5
                                   Long-Term Averages and Variability Factors
                                   Dissolved Air Flotation - Heavy (DAF-Heavy)
Analyte
2-BUTANONE
2-METHYLNAPHTHALENE
2-PROPANONE
4-METHYL-2-PENTANONE
Episode
S2
S2
S2
S2
Inf
# Obs
5
5
5
5
Inf
# ND
4
^
2
4
Inf
Est. LTA
(mg/L)
5.65
0.64
8 . 07
18.00
Eff
# Obs
4
4
4
4
Eff
# ND
2
2
0
2
Eff
Est. LTA
(mg/L)
4 . 68
0.13
7 . 42
9 . 55
Eff
1-Day
VF
4 . 41
3.85
2. 69
3. 94
Eff
4-day
VF
1. 82
1.71
1.46
1.73
ALPHA-TERPINEOL

ALUMINUM

BARIUM

BIS(2-ETHYLHEXYL)  PHTHALATE



BOD 5-DAY  (CARBONACEOUS)

CHEMICAL OXYGEN DEMAND  (COD)

CHROMIUM

COPPER

DI-N-BUTYL PHTHALATE

ETHYLBENZENE



IRON

LEAD



MANGANESE

N-DECANE

N-DOCOSANE
Q10
S2
Median

-------
                                                                                                                    Appendix D - References Used for Chapter 7
to
to
                                                             Reference D-5 (Continued)


Analyte Episode

Inf
# Obs

Inf
# ND
Inf
Est. LTA
(mg/L)

Eff
# Obs

Eff
# ND
Eff
Est. LTA
(mg/L)
Eff
1-Day
VF
Eff
4-day
VF
N-EICOSANE



N-HEXADECANE



N-OCTADECANE



N-TETRADECANE



NAPHTHALENE



OIL AND GREASE  (AS  HEM)



P-CYMENE



SILVER



TETRACHLOROETHENE



TITANIUM



TOLUENE







TOTAL ORGANIC CARBON  (TOC)



TOTAL PETROLEUM  HYDROCARBON (AS SGT-HEM)



TOTAL PETROLEUM  HYDROCARBONS



TOTAL RECOVERABLE OIL  AND GREASE



TOTAL SUSPENDED  SOLIDS



ZINC

-------
                                                                                                    Appendix D - References Used for Chapter 7
o
to
                                                           Reference D-6
                                            Long-Term Averages and Variability Factors
                                             Chemical Precipitation - Heavy (CP-Heavy)
Analyte
1, 2-DIPHENYLHYDRAZINE
2-METHYLNAPHTHALENE
ALUMINUM
BARIUM
BIS (2-ETHYLHEXYL) PHTHALATE
BOD 5-DAY (CARBONACEOUS)
BORON
BUTYL BENZYL PHTHALATE
CADMIUM
CHEMICAL OXYGEN DEMAND (COD)
CHROMIUM
COPPER
DI-N-BUTYL PHTHALATE
ETHYLBENZENE
IRON
LEAD
M-XYLENE
MANGANESE
MOLYBDENUM
N-DECANE
N-DOCOSANE
N-DODECANE
Episode
S3
S3
S3
S3
S3
S3
S3
S3
S3
S3
S3
S3
S3
S3
S3
S3
S3
S3
S3
S3
S3
S3
Inf
# Obs
4
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
4
5
5
Inf
# ND
3
2
0
0
2
0
o
3
0
0
0
0
1
1
0
0
0
0
0
1
4
1
Inf
Est. LTA
(mg/L)
10.
0.
11.
2.
1.
7850.
16.
0.
0 .
15300.
0 .
3 .
0 .
0.
40.
1.
1.
1.
0 .
3 .
0 .
8.
. 50
.20
.20
. 43
. 94
.00
.30
. 2 4
.16
.00
.26
. 4 2
. 41
. 96
.30
. 55
.36
. 02
. 82
.25
.12
7 7
Eff
# Obs
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
Eff
# ND
3
5
3
0
4
0
0
5
5
0
3
0
5
1
2
4
1
3
0
4
4
5
Eff Eff
Est. LTA 1-Day
(mg/L) VF
45.
0.
0 .
0.
0 .
1390.
11.
0.
0 .
2510.
0 .
0.
0 .
0.
0 .
0.
0 .
0.
0 .
0.
0 .
0.
.20 6. 82
.01
.08 8.13
.15 3.47
. 05
.00 1.83
.40 5.88
.01
. 01
.00 1.86
.01 2. 64
.53 4.06
. 01
.09 4.37
.37 10.80
.05
.10 2.66
.01 10.30
.77 7.49
. 02
. 01
.01
Eff
4-day
VF
1. 03

2. 60
1.63

1.25
2.16


1.25
1.44
1.76

1.80
3.15

1. 42
3.02
2.53




-------
                                                            Reference D-6 (Continued)
                                                                                                                 Appendix D - References Used for Chapter 7
o
to
Analyte
N-EICOSANE
N-HEXACOSANE
N-HEXADECANE
N-OCTACOSANE
N-OCTADECANE
N-TETRACOSANE
N-TETRADECANE
N-TRIACONTANE
NAPHTHALENE
O+P XYLENE
OIL AND GREASE (AS HEM)
P-CYMENE
PENTAMETHYLBENZENE
TETRACHLOROETHENE
TITANIUM
TOLUENE
TOTAL ORGANIC CARBON (TOC)
TOTAL PETROLEUM HYDROCARBON (AS SGT-HEM)
TOTAL SUSPENDED SOLIDS
TRICHLOROETHENE
ZINC
Episode
S3
S3
S3
S3
S3
S3
S3
S3
S3
S3
S3
S3
S3
S3
S3
S3
S3
S3
S3
S3
S3
Inf
# Obs
5
5
5
5
5
5
5
5
5
5
5
5
5
4
5
5
5
5
5
4
5
Inf
# ND
1
3
0
3
1
4
2
4
0
0
0
2.
2
0
0
o
0
0
0
4
0
Inf
Est. LTA
(mg/L)
1.
0 .
3
0 .
1.
0 .
1.
0 .
2.
1.
4550.
1.
0.
2.
0.
2.
2680.
2330.
2840.
0 .
9
. 02
.54
. 2 6
. 50
.15
.17
. 67
.25
.16
.24
.00
.73
.71
. 06
.56
. 86
.00
. 00
.00
. 06
.03
Eff
# Obs
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
Eff
# ND
3
4
4
5
5
4
4
3
0
0
0
4
5
2
3
0
0
4
0
2
0
Eff Eff
Est. LTA 1-Day
(mg/L) VF
0.
0 .
0.
0 .
0.
0 .
0.
0 .
0.
0 .
38.
0 .
0.
0 .
0.
0 .
910.
7 .
56.
0 .
0.
.04 10.10
. 01
.03
. 01
.01
. 03
.61
.03 10.10
.11 3.14
.09 3. 63
.20 2.11
. 02
.01
.13 4.48
.00 4.92
.82 6.79
.00 2.71
.20
.30 10.70
.05 0.43
.06 6.19
Eff
4-day
VF
3.01






3. 01
1.56
1. 67
1.32


1. 90
1.88
2.37
1.46

3.29
1. 60
2.23

-------
                                                                                              Appendix D - References Used for Chapter 7
ANTIMONY

ARSENIC

BARIUM

BENZOIC ACID


BENZOIC ACID

BENZYL ALCOHOL

BIS(2-ETHYLHEXYL) PHTHALATE
                                                   Reference D-7
                                   Long-Term Averages and Variability Factors
                                       Dissolved Air Flotation - All (DAF-A11)
Inf
Analyte Episode # Obs
1,1,1-TRICHLOROETHANE Q2
S5 5
Median
1,2-DIPHENYLHYDRAZINE Ql
2-BUTANONE S4 5
S5 5
Median
2-METHYLNAPHTHALENE Ql
S4 5
Median
2-PROPANONE S5 5
4-CHLORO-3-METHYLPHENOL Ql
Q2
S5 4
Median
4-METHYL-2-PENTANONE S4 5
S5 5
Median
ALPHA-TERPINEOL S4 5
ALUMINUM S4 5
S5 5
Median
Inf
Inf Est. LTA
# ND (mg/L)

1 0.
0.

0 58.
0 1.
30.

0 0.
0 .
0 20.


1 0.
0.
1 1.
3 5 .
3
3 0.
0 47.
0 2.
25.

.31
.31

.60
.88
.20

.31
.31
. 90


33
. 33
. 04
. 23
.14
. 64
.70
. 7 7
.20
Eff
# Obs
13
5

5
5
5

5
5

5
5
12
5

5
5

5
5
5

Eff
# ND
12
1

5
0
0

5
3

0
4
11
1

1
5

0
0
o

Eff
Est. LTA
(mg/L)
0 .
0 .
0.
0 .
33 .
0.
17 .
0.
0.
0 .
13.
0 .
0 .
0.
0.
1.
0.
0.
0 .
2.
0 .
1.
. 00
. 05
.03
.22
.80
9 9
. 40
.22
.01
.12
.60
. 45
. 00
. 22
2 2
. 05
.14
.60
. 47
.41
.20
.31
Eff
1-Day
VF

4 .
4 .

14.
3
8.

1.
1.
3 .


4 .
4 .
12.

12 .
14 .
2.
2.
2.

.310
.310

. 900
.010
. 960

.060
. 060
.580


.560
.560
. 500

.500
. 400
.150
. 620
.380
Eff
4-day
VF

1. 94
1. 94

3.48
1.53
2.50

1.02
1. 02
1.66


1.86
1.86
3.59

3.59
3. 86
1.33
1.44
1.38
                                        14

                                        14
Median

Ql

Ql
                                                                           1.11

                                                                           1.11

-------
BUTYL BENZYL PHTHALATE

CADMIUM
o
to
CHLOROBENZENE
                                                                                                     Appendix D - References Used for Chapter 7
                                               Reference D-7 (Continued)


Analyte Episode
S4
S5
Median

Inf
# Obs
5
4


Inf
# ND
1
0

Inf
Est. LTA
(mg/L)
2.36
38.10
20.20

Eff
# Obs
5
5


Eff
# ND
0
1

Eff
Est. LTA
(mg/L)
0.03
0.14
0.14
Eff
1-


3.
3.
Day
F
730
060
060
Eff
4-day
VF
1.47
1.52
1.52
                                            Ql
                                            Ql
                                            as
                                            Median
                                                                                       15
                                                                                        4
                                                                                       12
                                                                                                           14
                                                                                                            2
                                                                                                                             1.71
                                                                                                                             1.35
                                                                                                                             1.23
                                                                                                                             1.21
                                                                                                                             1.29

-------
                                                                                                                 Appendix D - References Used for Chapter 7
                                                            Reference D-7 (Continued)
Inf
Analyte Episode # Obs
COPPER Ql
Q2
Inf
Inf Est. LTA
# ND (mg/L)

Eff
# Obs
15
13
Eff
# ND
0
1
Eff
Est. LTA
(mg/L)
0.67
0.59
Eff
1-Day
VF
6.400
4 .520
Eff
4-day
VF
2.28
1. 87
o
to
            DI-N-BUTYL PHTHALATE
            DI-N-OCTYL PHTHALATE
            ETHYLBENZENE
            IRON
            ISOPHORONE

            LEAD
Median

Ql
S5
Median

Ql
S5
Median

Q2
S5
Median

S4
S5
Median

Ql
                                                                                                   15
                                                                                                   14
                                                                                                    4
                                                                                                           10
                                                                                                                                         1.45
                                                                                                                                         1.35
                                                                                                                                         1.40
            M-XYLENE

            MANGANESE
            MERCURY
            METHYLENE CHLORIDE
                                                         S4
                                                         S5
                                                         Median
                                                                                                   14
                                                                                                   13
                                                                                                           14
                                                                                                            2
                                                                                                           13

-------
                                                            Reference D-7 (Continued)
                                                                                                                 Appendix D - References Used for Chapter 7
                                                                     Inf
                                                                    ? Obs
                     Inf
                     ? ND
   Inf
Est.  LT?
 (mg/L)
Eff
# ND
   Eff
Est. LTA
 (mg/L)
 Eff
1-Day
 VF
 Eff
4-day
  VF
            N-DECANE
                                                         S5
                                                         Median

                                                         S4
                                                         S5
                                                         Median
                                                                                 1.49
                                                                                 1.14
                                                                                 1.31

                                                                                 1.84
                                                                                 1.54
                                                                                 1. 69
to
oo
            N-DODECANE
            N-EICOSANE
            N-HEXACOSANE
                                                         S4
                                                         S5
                                                         Median
S4
S5
Median
            N-HEXADECANE
            N-OCTADECANE
                                                         S4
                                                         S5
                                                         Median
            N-TETRACOSANE
            N-TETRADECANE
                                                         S4
                                                         S5
                                                         Median
            N-TRIACONTANE

            NAPHTHALENE
                                                         S4
                                                                                                   13
                                                                                                           13
                                                                                                            2

-------
                                                                                                                  Appendix D - References Used for Chapter 7
to
VO
NICKEL






O+P XYLENE



OIL AND GREASE  (AS HEM)



P-CRESOL

P-CYMENE



PHENOL





SELENIUM



SILVER



TETRACHLOROETHENE
            TIN

            TITANIUM

            TOLUENE
                                                            Reference D-7 (Continued)
Analyte Episode
S5
Median
Inf
# Obs
4
Inf
# ND
0
Inf
Est. LTA
(mg/L)
7.07
3. 86
Eff
# Obs
5
Eff
# ND
1
Eff
Est. LTA
(mg/L)
0.18
0. 08
Eff
1-Day
VF
1.570
3.150
Eff
4-day
VF
1.24
1. 62
Ql

S4
S5
Median

Ql
Q2
S4
Median

Ql
S4
Median

Ql
Q3
Median
                                                                                                    15
                                                                                                    14
                                                                                                    15
                                                                                                     4
                                                                                                             4
                                                                                                            11
                                                                                                            11
                                                                                                             3
                                                                                                    13

-------
                                                                                                     Appendix D - References Used for Chapter 7
                                                Reference D-7 (Continued)


Analyte Episode
S4
S5
Median
TOTAL ORGANIC CARBON (TOC) S4
S5
Median
TOTAL PETROLEUM HYDROCARBON (AS SGT-HEM) S4
S5
Median

Inf
# Obs
5
5

5
5

5
5


Inf
# ND
0
0

0
0

0
o

Inf
Est. LTA
(mg/L)
0.81
37 . 80
19.30
881.00
1100. 00
989.00
318.00
683. 00
500 . 00

Eff
# Obs
5
5

4
5

5
5


Eff
# ND
0
0

0
0

1
0

Eff
Est. LTA
(mg/L)
0.71
4 .20
0.71
456.00
195. 00
326. 00
11.40
16. 00
13.70

1

•-J
2
7
1
1
1
3
2
3
Eff
-Day
VF
. 930
. 800
. 930
.780
. 750
. 770
.640
. 620
.130
Eff
4-day


1.
2.
1.
1.
1.
1.
1.
1.
fF
. 63
. 48
. 63
.23
.23
.23
. 68
. 44
. 56
TOTAL SUSPENDED SOLIDS
o
I
O
TOTAL XYLENES

TRANS-1,2-DICHLOROETHENE



TRICHLOROETHENE
                                                                                                    13
                                                                                       13
                                                                                                             4
                                                                                                            13
                                                                                               11
                                                                                                                              1.78

-------
                                                          Appendix D - References Used for Chapter 7
               Reference D-8
Long-Term Averages and Variability Factors
    Chemical Precipitation - All (CP-A11)
Analyte Episode
1,1,1-TRICHLOROETHANE Q5
Q7
Q9
S6
Median
1,2-DIPHENYLHYDRAZINE Q7
2-BUTANONE S6
2-METHYLNAPHTHALENE S6
S7
Median
2-PROPANONE S7
4-CHLORO-3-METHYLPHENOL Q7
4-METHYL-2-PENTANONE S6
S7
Median
ALUMINUM S6
S7
Median
BENZYL ALCOHOL S7
BIS (2-ETHYLHEXYL) PHTHALATE Q7
S6
S7
Median
BOD 5-DAY (CARBONACEOUS) Q8
S6
S7
Median
BUTYL BENZYL PHTHALATE Q7
BUTYL BENZYL PHTHALATE S6
S7
Inf
# Obs


5


5
5
4

5

5
5

5
5

4

5
4


5
2


5
4
Inf
# ND


1


1
0
0

0

2
0

0
0

0

0
0


0
0


2
1
Inf
Est. LTA
(mg/L)


1.
1.

3.
0.
0.
0 .
1.

2.
1.
1.
11.
17.
14 .
0.

2.
2 .
2

2200 .
1380.
1790.

0 .
0 .


. 53
.53

.21
. 33
. 22
.27
.81

.51
.14
. 82
.30
. 90
. 60
. 46

. 97
. 96
97

.00
.00
. 00

.13
.16
Eff
# Obs
4
3
4
4

3
4
4
5

4
3
4
5

4
5

5
3
4
5

3
4
5

3
4
5
Eff
# ND
4
3
0
0

3
0
0
4

0
3
0
0

0
0

0
2
0
0

0
0
0

3
4
5
Eff
Est. LTA
(mg/L)
0 .
0 .
0.
1.
0 .
0.
3.
0.
0.
0 .
1.
0 .
3 .
0.
1.
0.
2 .
1.
0.
0 .
0 .
0.
0.
623.
376.
399 .
399 .
0.
0 .
0 .
.39
. 04
. 55
.19
. 47
.13
.23
.01
.01
. 01
.54
. 06
.13
.78
. 96
.47
.19
.33
.34
.15
. 07
.04
.07
. 00
.00
.00
. 00
.06
. 01
. 01
Eff
1-Day
VF

9
9 .
9 .

1.
1.

1.
2.

12 .
T
9 .
4 .
2 .
3.
6.

1.
2 .
2

1.
1.
1.




.460
.670
. 560

. 830
. 680

. 680
.240

.400
.080
.730
.240
.580
. 410
.380

.210
. 960
.080

.240
.660
. 450



Eff
4-day
VF

3.00
3.05
3. 02

1.25
1.21

1.21
1.35

3. 64
2. 43
3. 04
1.80
1.43
1. 62
2.27

1. 07
1.52
1.29

1.08
1.20
1.14



      Median
                                    0.14
                                                              0.01
                                                    14
                                                                                i.:

-------
                                                                                                                  Appendix D - References Used for Chapter 7
            CHLOROBENZENE
o
I
K>
            COPPER
            DI-N-BUTYL  PHTHALATE

            DI-N-OCTYL  PHTHALATE
            ETHYLBENZENE
            HEXANOIC ACID

            IRON
                                                            Reference D-8 (Continued)


Analyte Episode

Inf
# Obs

Inf
# ND
Inf
Est. LTA
(mg/L)

Eff
# Obs

Eff
# ND
Eff
Est. LTA
(mg/L)
Eff
1-Day
VF
Eff
4-day
VF

-------
                                                Reference D-8 (Continued)
                                                                                                      Appendix D - References Used for Chapter 7
                                                         Inf
                                                        ? Obs
 Inf
? ND
   Inf
Est.  LT?
 (mg/L)
Eff
# ND
   Eff
Est. LTA
 (mg/L)
 Eff
1-Day
 VF
 Eff
4-day
  VF
LEAD
M-XYLENE
MANGANESE
MERCURY
                                                                                        11
                                                                                         4
                                                                                         4
                                                                                                11
                                                                                                14
MERCURY

METHYLENE CHLORIDE
MOLYBDENUM
N-DECANE
N-DODECANE

-------
                                                Reference D-8 (Continued)
                                                                                                     Appendix D - References Used for Chapter 7
                                                         Inf
                                                        ?  Obs
 Inf
? ND
   Inf
Est.  LT?
 (mg/L)
Eff
# ND
   Eff
Est. LTA
 (mg/L)
 Eff
1-Day
 VF
 Eff
4-day
  VF
                                             S7
                                             Median
N-EICOSANE
                                             S6
                                             S7
                                             Median
N-OCTACOSANE

N-OCTADECANE
                                             S6
                                             S7
                                             Median
                                                            1.14
                                                            1.38
                                                            1.26
N-TETRACOSANE
                                             S6
                                             S7
                                             Median
N-TETRADECANE
                                             S6
                                             S7
                                             Median
N-TRIACONTANE

NAPHTHALENE
                                             S6
NICKEL
O+P XYLENE
OIL AND GREASE  (AS HEM)

-------
                                                                                                      Appendix D - References Used for Chapter 7
                                                Reference D-8 (Continued)


Analyte Episode

Inf
# Obs

Inf
# ND
Inf
Est. LTA
(mg/L)

Eff
# Obs

Eff
# ND
Eff
Est. LTA
(mg/L)
Eff
1-Day
VF
Eff
4-day
VF
P-CYMENE

PHENOL

SILVER

TETRACHLOROETHENE




TIN

TITANIUM



TOLUENE
TOTAL ORGANIC CARBON  (TOC)



TOTAL PETROLEUM HYDROCARBON  (AS  SGT-HEM)



TOTAL SUSPENDED SOLIDS





TOTAL XYLENES

TRANS-1,2-DICHLOROETHENE




TRICHLOROETHENE
1.54
                   1.11

                   1. 42
                   1.23
                   1.32

-------
                                                                                                     Appendix D - References Used for Chapter 7

                                                Reference D-8 (Continued)
                                                                            Inf                          Eff        Eff       Eff
                                                         Inf      Inf    Est.  LTA     Eff     Eff     Est. LTA     1-Day     4-day
Analyte                                      Episode     # Obs     # ND     (mg/L)      # Obs    # ND      (mg/L)       VF        VF



                                             S7            50
                                             Median

                                                                                       16
                                                                                        •-j
                                                                                        4
                                                                                        4

-------
                                   Appendix E - Tables Referenced in Chapter 9
          Appendix E




Tables Referenced In Chapter 9

-------
                                                      Appendix E - Tables Referenced in Chapter 9
                     Table E-l
Summary of POTW Pollutant Loadings and Removals
   from Industrial Laundry Wastewater for CP-IL1
                  Entire Industry2
Pollutant of Concern
POTW Baseline
Wastewater Pollutant
Loading (lbs/yr)3
POTW Postcompliance
Wastewater Pollutant
Loading (lbs/yr)4
Total Pollutant
Removal from POTW
Effluents (lbs/yr)
POTW Pollutant
Removal Efficiency
Conventionals
Biochemical Oxygen Demand 5-Day (BOD5)
Oil and Grease (measured as HEM)
Total Suspended Solids (TSS)
10,004,982
5,007,547
5,627,828
9,230,263
1,990,838
2,893,319
774,718
3,016,709
2,734,509
91%
87%
91%
Priority Organics
1,1,1 -Trichloroethane
1 ,2-Diphenylhydrazine
4-Chloro-3-methylphenol
Bis(2-ethylhexyl) Phthalate
Butyl Benzyl Phthalate
Chlorobenzene
Chloroform
Di-w-butyl Phthalate
Di-w-octyl Phthalate
Ethylbenzene
Isophorone
Methylene Chloride
Naphthalene
Phenol
Tetrachloroethene
33,709
0
3,718
57,572
5,553
1,890
97,422
4,109
9,134
25,491
18,156
23,961
34,140
634
28,342
18,970
0
1,311
31,709
1,844
1,298
97,237
1,197
6,773
8,083
9,207
9,617
15,641
634
18,473
14,739
0
2,407
25,863
3,710
592
186
2,912
2,361
17,408
8,949
14,344
18,499
0
9,869
24%
62%
63%
60%
86%
24%
24%
75%
33%
33%
62%
18%
18%
95%
33%

-------
                                                                                                       Appendix E - Tables Referenced in Chapter 9
                                                       Table E-l (Continued)
Pollutant of Concern
POTW Baseline
Wastewater Pollutant
Loading (lbs/yr)3
POTW Postcompliance
Wastewater Pollutant
Loading (lbs/yr)4
Total Pollutant
Removal from POTW
Effluents (lbs/yr)
POTW Pollutant
Removal Efficiency
Priority Organics (Continued)
Toluene
trans- 1 ,2-Dichloroethene
Trichloroethene
Total Priority Organics
44,474
2,250
1,990
392,545
34,529
2,250
1,177
259,950
9,944
0
813
132,595
33%
33%
33%
—
Nonconventional Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pentanone
ซ-Terpineol
Benzoic Acid
Benzyl Alcohol
Hexanoic Acid
w-Xylene
w-Decane
w-Docosane
w-Dodecane
w-Eicosane
w-Hexacosane
w-Hexadecane
w-Octacosane
w-Octadecane
w-Tetracosane
30,404
8,223
20,956
13,076
9,566
13,079
48,148
5,412
11,867
451,359
999
124,810
98,135
965
59,075
603
47,990
1,376
28,756
2,179
12,894
13,076
6,362
13,079
35,240
5,408
9,820
232,959
352
86,151
8,255
257
16,292
233
7,980
536
1,649
6,044
8,062
0
3,204
0
12,908
4
2,047
218,400
647
38,659
89,881
708
42,784
370
40,010
840
18%
28%
85%
18%
18%
81%
33%
33%
33%
33%
94%
33%
33%
94%
33%
94%
33%
94%
w
to

-------
                                                                                                       Appendix E - Tables Referenced in Chapter 9
                                                       Table E-l (Continued)
Pollutant of Concern
POTW Baseline
Wastewater Pollutant
Loading (lbs/yr)3
POTW Postcompliance
Wastewater Pollutant
Loading (lbs/yr)4
Total Pollutant
Removal from POTW
Effluents (lbs/yr)
POTW Pollutant
Removal Efficiency
Nonconventional Organics (Continued)
w-Tetradecane
w-Triacontane
o-&/>-Xylene
p-Creso\
p-Cymene
Pentamethy Ibenzene
Total Nonconventional Organics
75,308
905
7,444
0
525
0
1,030,225
14,486
447
6,582
0
149
0
501,493
60,821
458
861
0
376
0
528,732
33%
94%
33%
72%
99%
91%
—
Priority Metals and Elements
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
Total Priority Metals and Elements
7,758
7,838
15
481
1,377
21,276
5,874
122
7,338
266
907
0
45,862
99,114
4,932
7,830
14
277
844
11,671
2,183
108
5,129
163
686
0
15,680
49,517
2,826
8
1
204
534
9,604
3,691
15
2,208
103
221
0
30,182
49,597
72%
40%
61%
91%
91%
84%
92%
33%
52%
34%
80%
28%
77%
—
w

-------
                                                                Table E-l (Continued)
                                                                                                                       Appendix E - Tables Referenced in Chapter 9
Pollutant of Concern
POTW Baseline
Wastewater Pollutant
Loading (lbs/yr)3
POTW Postcompliance
Wastewater Pollutant
Loading (lbs/yr)4
Total Pollutant
Removal from POTW
Effluents (lbs/yr)
POTW Pollutant
Removal Efficiency
Nonconventional Metals and Elements
Aluminum
Barium
Boron
Cobalt
Iron
Manganese
Molybdenum
Tin
Titanium
Vanadium
Yttrium
Total Nonconventional Metals and Elements
87,795
46,815
30,043
4,742
216,813
14,908
4,580
2,049
5,492
1,183
329
414,749
58,955
32,596
28,407
2,697
90,380
7,565
4,554
908
3,613
1,057
324
231,056
28,840
14,219
1,636
2,046
126,433
7,343
26
1,140
1,879
126
5
183,693
88%
35%
14%
4%
83%
41%
52%
65%
69%
42%
58%
—
Bulk Nonconventionals
Chemical Oxygen Demand (COD)
Total Organic Carbon (TOC)
Total Petroleum Hydrocarbon (measured as
SGT-HEM)5
46,755,318
22,718,738
3,408,559
35,617,305
20,936,851
618,088
11,138,013
1,781,887
2,790,471
82%
71%
74%
w
       'Numbers in this table were calculated using more significant figures than shown.
       2The entire industrial laundries industry is estimated to consist of 1,742 facilities.
       3POTW baseline wastewater pollutant loading = industry baseline wastewater pollutant loading x (1-POTW pollutant removal efficiency).
       4POTW postcompliance wastewater pollutant loading = industry postcompliance wastewater pollutant loading x (1-POTW pollutant removal efficiency).
       5SGT-HEM is measured by Method 1664 (promulgated at 64 FR 26315; May 14, 1999).  In this method, EPA defines SGT-HEM as non-polar material (NPM).
       Throughout this document and the Industrial Laundries Administrative Record, EPA refers to SGT-HEM as total petroleum hydrocarbon (TPH).

       HEM - Hexane extractable material.
       SGT-HEM - Silica gel treated-hexane extractable material.

-------
                                                                                    Appendix E - Tables Referenced in Chapter 9
                                                   Table E-2
                              Summary of POTW Pollutant Loadings and Removals
                                from Industrial Laundry Wastewater for DAF-IL1
                                                Entire Industry2
Pollutant of Concern
POTW Baseline
Wastewater Pollutant
Loading (lbs/yr)3
POTW Postcompliance
Wastewater Pollutant
Loading (lbs/yr)4
Total Pollutant
Removal from POTW
Effluents (lbs/yr)
POTW Pollutant
Removal Efficiency
Conventionals
Biochemical Oxygen Demand 5-Day (BOD5)
Oil and Grease (measured as HEM)
Total Suspended Solids (TSS)
10,004,982
5,007,547
5,627,828
9,534,919
2,084,632
2,689,166
470,062
2,922,915
2,938,663
91%
87%
91%
Priority Organics
1,1,1 -Trichloroethane
1 ,2-Diphenylhydrazine
4-Chloro-3-methylphenol
Bis(2-ethylhexyl) Phthalate
Butyl Benzyl Phthalate
Chlorobenzene
Chloroform
Di-w-butyl Phthalate
Di-w-octyl Phthalate
Ethylbenzene
Isophorone
Methylene Chloride
Naphthalene
Phenol
Tetrachloroethene
33,709
0
3,718
57,572
5,553
1,890
97,422
4,109
9,134
25,491
18,156
23,961
34,140
634
28,342
1,807
0
3,465
34,075
3,622
1,228
97,418
3,016
6,490
3,846
18,156
22,594
16,766
634
13,743
31,902
0
253
23,497
1,931
662
4
1,092
2,644
21,645
0
1,367
17,374
0
14,599
24%
62%
63%
60%
86%
24%
24%
75%
33%
33%
62%
18%
18%
95%
33%
w

-------
                                                       Table E-2 (Continued)
                                                                                                       Appendix E - Tables Referenced in Chapter 9
Pollutant of Concern
POTW Baseline
Wastewater Pollutant
Loading (lbs/yr)3
POTW Postcompliance
Wastewater Pollutant
Loading (lbs/yr)4
Total Pollutant
Removal from POTW
Effluents (lbs/yr)
POTW Pollutant
Removal Efficiency
Priority Organics (Continued)
Toluene
trans- 1 ,2-Dichloroethene
Trichloroethene
Total Priority Organics
44,474
2,250
1,990
392,545
30,928
2,250
1,990
262,030
13,545
0
0
130,515
33%
33%
33%
—
Nonconventional Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pentanone
ซ-Terpineol
Benzoic Acid
Benzyl Alcohol
Hexanoic Acid
w-Xylene
w-Decane
w-Docosane
w-Dodecane
w-Eicosane
w-Hexacosane
w-Hexadecane
w-Octacosane
w-Octadecane
w-Tetracosane
30,404
8,223
20,956
13,076
9,566
13,079
48,148
5,412
11,867
451,359
999
124,810
98,135
965
59,075
603
47,990
1,376
30,404
7,058
20,892
12,945
9,547
12,923
48,148
5,412
11,063
252,676
409
35,065
10,003
288
18,569
203
10,084
582
0
1,165
64
131
19
156
0
0
804
198,683
590
89,745
88,133
677
40,506
400
37,906
794
18%
28%
85%
18%
18%
81%
33%
33%
33%
33%
94%
33%
33%
94%
33%
94%
33%
94%
w

-------
                                                       Table E-2 (Continued)
                                                                                                       Appendix E - Tables Referenced in Chapter 9
Pollutant of Concern
POTW Baseline
Wastewater Pollutant
Loading (lbs/yr)3
POTW Postcompliance
Wastewater Pollutant
Loading (lbs/yr)4
Total Pollutant
Removal from POTW
Effluents (lbs/yr)
POTW Pollutant
Removal Efficiency
Nonconventional Organics (Continued)
w-Tetradecane
w-Triacontane
o-&/>-Xylene
/>-Cresol
/>-Cymene
Pentamethy Ibenzene
Total Nonconventional Organics
75,308
905
7,444
0
525
0
1,030,225
16,392
439
7,235
0
195
0
510,533
58,916
466
209
0
330
0
519,692
33%
94%
33%
72%
99%
91%
—
Priority Metals and Elements
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
Total Priority Metals and Elements
7,758
7,838
15
481
1,377
21,276
5,874
122
7,338
266
907
0
45,862
99,114
5,471
7,838
15
325
1,007
14,383
2,686
104
5,166
266
813
0
25,955
64,029
2,287
0
0
156
370
6,892
3,188
18
2,172
0
94
0
19,907
35,086
72%
40%
61%
91%
91%
84%
92%
33%
52%
34%
80%
28%
77%
—
w

-------
                                                                Table E-2 (Continued)
                                                                                                                       Appendix E - Tables Referenced in Chapter 9
Pollutant of Concern
POTW Baseline
Wastewater Pollutant
Loading (lbs/yr)3
POTW Postcompliance
Wastewater Pollutant
Loading (lbs/yr)4
Total Pollutant
Removal from POTW
Effluents (lbs/yr)
POTW Pollutant
Removal Efficiency
Nonconventional Metals and Elements
Aluminum
Barium
Boron
Cobalt
Iron
Manganese
Molybdenum
Tin
Titanium
Vanadium
Yttrium
Total Nonconventional Metals and Elements
87,795
46,815
30,043
4,742
216,813
14,908
4,580
2,049
5,492
1,183
329
414,749
58,738
28,005
29,563
3,555
104,510
7,664
4,225
1,727
2,831
1,038
311
242,167
29,058
18,811
479
1,187
112,302
7,245
355
322
2,661
145
18
172,582
88%
35%
14%
4%
83%
41%
52%
65%
69%
42%
58%
—
Bulk Nonconventionals
Chemical Oxygen Demand (COD)
Total Organic Carbon (TOC)
Total Petroleum Hydrocarbon (measured as
SGT-HEM)5
46,755,318
22,718,738
3,408,559
32,559,762
21,128,828
694,530
14,195,556
1,589,911
2,714,029
82%
71%
74%
w
oo
       'Numbers in this table were calculated using more significant figures than shown.
       2The entire industrial laundries industry is estimated to consist of 1,742 facilities.
       3POTW baseline wastewater pollutant loading = industry baseline wastewater pollutant loading x (1-POTW pollutant removal efficiency).
       4POTW postcompliance wastewater pollutant loading = industry postcompliance wastewater pollutant loading x (1-POTW pollutant removal efficiency).
       5SGT-HEM is measured by Method 1664 (promulgated at 64 FR 26315; May 14, 1999).  In this method, EPA defines SGT-HEM as non-polar matenal (NPM).
       Throughout this document and the Industrial Laundries Administrative Record, EPA refers to SGT-HEM as total petroleum hydrocarbon (TPH).
      HEM - Hexane extractable material.
      SGT-HEM - Silica gel treated-hexane extractable material.

-------
                                                                                  Appendix E - Tables Referenced in Chapter 9
                                                 Table E-3
       Summary of POTW Pollutant Loadings and Removals from Industrial Laundry Wastewater for CP-IL1
        Excluding Facilities with Less than 1 Million Pounds per Year Total Production and Less than 255,000
                           Pounds per Year Shop and Printer Towel/Rag Production2
Pollutant of Concern
POTW Baseline
Wastewater Pollutant
Loading (lbs/yr)3
POTW Postcompliance
Wastewater Pollutant
Loading (lbs/yr)4
Total Pollutant
Removal from POTW
Effluents (lbs/yr)
POTW Pollutant
Removal Efficiency
Conventionals
Biochemical Oxygen Demand 5-Day (BOD5)
Oil and Grease (measured as HEM)
Total Suspended Solids (TSS)
9,915,334
4,926,141
5,556,819
9,167,360
1,976,984
2,873,356
747,974
2,949,157
2,683,463
91%
87%
91%
Priority Organics
1,1,1 -Trichloroethane
1 ,2-Diphenylhydrazine
4-Chloro-3-methylphenol
Bis(2-ethylhexyl) Phthalate
Butyl Benzyl Phthalate
Chlorobenzene
Chloroform
Di-w-butyl Phthalate
Di-w-octyl Phthalate
Ethylbenzene
Isophorone
Methylene Chloride
Naphthalene
Phenol
Tetrachloroethene
33,198
0
3,674
56,981
5,491
1,860
96,720
4,048
9,030
24,926
17,888
23,532
33,550
629
27,683
18,841
0
1,304
31,487
1,831
1,288
96,551
1,188
6,726
8,030
9,156
9,554
15,534
629
18,350
14,357
0
2,370
25,494
3,660
572
168
2,860
2,305
16,896
8,732
13,978
18,017
0
9,333
24%
62%
63%
60%
86%
24%
24%
75%
33%
33%
62%
18%
18%
95%
33%
w

-------
                                                       Table E-3 (Continued)
                                                                                                       Appendix E - Tables Referenced in Chapter 9
Pollutant of Concern
POTW Baseline
Wastewater Pollutant
Loading (lbs/yr)3
POTW Postcompliance
Wastewater Pollutant
Loading (lbs/yr)4
Total Pollutant
Removal from POTW
Effluents (lbs/yr)
POTW Pollutant
Removal Efficiency
Priority Organics (Continued)
Toluene
trans- 1 ,2-Dichloroethene
Trichloroethene
Total Priority Organics
43,647
2,216
1,962
387,038
34,255
2,216
1,168
258,109
9,392
0
794
128,929
33%
33%
33%
—
Nonconventional Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pentanone
ซ-Terpineol
Benzoic Acid
Benzyl Alcohol
Hexanoic Acid
w-Xylene
w-Decane
w-Docosane
w-Dodecane
w-Eicosane
w-Hexacosane
w-Hexadecane
w-Octacosane
w-Octadecane
w-Tetracosane
29,922
8,109
20,633
12,863
9,433
12,946
47,557
5,382
11,670
444,334
988
122,629
95,866
949
58,025
594
47,025
1,361
28,330
2,164
12,792
12,863
6,319
12,946
35,019
5,378
9,751
231,316
350
85,552
8,197
255
16,179
231
7,925
532
1,592
5,945
7,841
0
3,114
0
12,537
4
1,919
213,018
638
37,076
87,668
694
41,846
363
39,100
828
18%
28%
85%
18%
18%
81%
33%
33%
33%
33%
94%
33%
33%
94%
33%
94%
33%
94%
w
I


O

-------
Table E-3 (Continued)
                                                Appendix E - Tables Referenced in Chapter 9
Pollutant of Concern
POTW Baseline
Wastewater Pollutant
Loading (lbs/yr)3
POTW Postcompliance
Wastewater Pollutant
Loading (lbs/yr)4
Total Pollutant
Removal from POTW
Effluents (lbs/yr)
POTW Pollutant
Removal Efficiency
Nonconventional Organics (Continued)
w-Tetradecane
w-Triacontane
o-&/>-Xylene
/>-Cresol
/>-Cymene
Pentamethy Ibenzene
Total Nonconventional Organics
73,808
896
7,325
0
519
0
1,012,832
14,386
444
6,530
0
148
0
497,609
59,421
451
795
0
371
0
515,233
33%
94%
33%
72%
99%
91%
—
Priority Metals and Elements
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
Total Priority Metals and Elements
7,711
7,783
15
475
1,362
21,021
5,783
121
7,271
264
899
0
45,325
98,031
4,898
7,775
14
275
838
11,592
2,169
107
5,094
162
681
0
15,573
49,178
2,813
8
1
200
524
9,429
3,615
14
2,177
102
218
0
29,752
48,852
72%
40%
61%
91%
91%
84%
92%
33%
52%
34%
80%
28%
77%
—

-------
                                                               Table E-3 (Continued)
                                                                                                                      Appendix E - Tables Referenced in Chapter 9
Pollutant of Concern
POTW Baseline
Wastewater Pollutant
Loading (lbs/yr)3
POTW Postcompliance
Wastewater Pollutant
Loading (lbs/yr)4
Total Pollutant
Removal from POTW
Effluents (lbs/yr)
POTW Pollutant
Removal Efficiency
Nonconventional Metals and Elements
Aluminum
Barium
Boron
Cobalt
Iron
Manganese
Molybdenum
Tin
Titanium
Vanadium
Yttrium
Total Nonconventional Metals and Elements
87,139
46,263
29,732
4,684
214,833
14,757
4,523
2,030
5,455
1,174
326
410,917
58,547
32,369
28,204
2,679
89,764
7,513
4,509
902
3,588
1,050
322
229,447
28,592
13,894
1,527
2,005
125,069
7,244
15
1,128
1,867
124
5
181,470
88%
35%
14%
4%
83%
41%
52%
65%
69%
42%
58%
—
Bulk Nonconventionals
Chemical Oxygen Demand (COD)
Total Organic Carbon (TOC)
Total Petroleum Hydrocarbon (measured as
SGT-HEM)5
46,198,588
22,515,816
3,341,399
35,378,302
20,794,885
613,888
10,820,286
1,720,931
2,727,511
82%
71%
74%
w
I
to
       'Numbers in this table were calculated using more significant figures than shown.
       2136 of the  1,742 total industrial laundries are excluded from compliance under this criterion.
       3POTW baseline wastewater pollutant loading = industry baseline wastewater pollutant loading x (1-POTW pollutant removal efficiency).
       4POTW postcompliance wastewater pollutant loading = industry postcompliance wastewater pollutant loading x (1-POTW pollutant removal efficiency).
       5SGT-HEM is measured by Method 1664 (promulgated at 64 FR 26315; May 14, 1999).  In this method, EPA defines SGT-HEM as non-polar matenal (NPM).
       Throughout this document and the Industrial Laundries Administrative Record, EPA refers to SGT-HEM as total petroleum hydrocarbon (TPH).
      HEM - Hexane extractable material.
      SGT-HEM - Silica gel treated-hexane extractable material.

-------
                                                                                  Appendix E - Tables Referenced in Chapter 9
                                                 Table E-4
      Summary of POTW Pollutant Loadings and Removals from Industrial Laundry Wastewater for DAF-IL1
        Excluding Facilities with Less than 1 Million Pounds per Year Total Production and Less than 255,000
                           Pounds per Year Shop and Printer Towel/Rag Production2
Pollutant of Concern
POTW Baseline
Wastewater Pollutant
Loading (lbs/yr)3
POTW Postcompliance
Wastewater Pollutant
Loading (lbs/yr)4
Total Pollutant
Removal from POTW
Effluents (lbs/yr)
POTW Pollutant
Removal Efficiency
Conventionals
Biochemical Oxygen Demand 5-Day (BOD5)
Oil and Grease (measured as HEM)
Total Suspended Solids (TSS)
9,915,334
4,926,141
5,556,819
9,468,820
2,070,083
2,670,654
446,514
2,856,057
2,886,164
91%
87%
91%
Priority Organics
1,1,1 -Trichloroethane
1 ,2-Diphenylhydrazine
4-Chloro-3-methylphenol
Bis(2-ethylhexyl) Phthalate
Butyl Benzyl Phthalate
Chlorobenzene
Chloroform
Di-w-butyl Phthalate
Di-w-octyl Phthalate
Ethylbenzene
Isophorone
Methylene Chloride
Naphthalene
Phenol
Tetrachloroethene
33,198
0
3,674
56,981
5,491
1,860
96,720
4,048
9,030
24,926
17,888
23,532
33,550
629
27,683
1,803
0
3,444
33,836
3,596
1,220
96,716
2,994
6,445
3,822
17,888
22,426
16,651
629
13,660
31,396
0
230
23,146
1,895
641
4
1,054
2,585
21,104
0
1,106
16,900
0
14,023
24%
62%
63%
60%
86%
24%
24%
75%
33%
33%
62%
18%
18%
95%
33%
w

-------
                                                                                                       Appendix E - Tables Referenced in Chapter 9
                                                       Table E-4 (Continued)
Pollutant of Concern
POTW Baseline
Wastewater Pollutant
Loading (lbs/yr)3
POTW Postcompliance
Wastewater Pollutant
Loading (lbs/yr)4
Total Pollutant
Removal from POTW
Effluents (lbs/yr)
POTW Pollutant
Removal Efficiency
Priority Organics (Continued)
Toluene
trans- 1 ,2-Dichloroethene
Trichloroethene
Total Priority Organics
43,647
2,216
1,962
387,038
30,709
2,216
1,962
260,017
12,938
0
0
127,021
33%
33%
33%
—
Nonconventional Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pentanone
ซ-Terpineol
Benzoic Acid
Benzyl Alcohol
Hexanoic Acid
w-Xylene
w-Decane
w-Docosane
w-Dodecane
w-Eicosane
w-Hexacosane
w-Hexadecane
w-Octacosane
w-Octadecane
w-Tetracosane
29 922
8,109
20,633
12,863
9,433
12,946
47,557
5,382
11,670
444,334
988
122,629
95,866
949
58,025
594
47,025
1,361
29,922
7,007
20,574
12,770
9,415
12,796
47,557
5,382
10,974
250,890
406
34,847
9,933
286
18,440
202
10,014
578
0
1,102
59
93
19
150
0
0
696
193,444
582
87,782
85,933
664
39,585
393
37,011
783
18%
28%
85%
18%
18%
81%
33%
33%
33%
33%
94%
33%
33%
94%
33%
94%
33%
94%
w

-------
                                                                                                       Appendix E - Tables Referenced in Chapter 9
                                                       Table E-4 (Continued)
Pollutant of Concern
POTW Baseline
Wastewater Pollutant
Loading (lbs/yr)3
POTW Postcompliance
Wastewater Pollutant
Loading (lbs/yr)4
Total Pollutant
Removal from POTW
Effluents (lbs/yr)
POTW Pollutant
Removal Efficiency
Nonconventional Organics (Continued)
w-Tetradecane
w-Triacontane
o-&/>-Xylene
p-Creso\
p-Cymene
Pentamethy Ibenzene
Total Nonconventional Organics
73,808
896
7,325
0
519
0
1,012,832
16,277
436
7,166
0
194
0
506,064
57,530
460
159
0
325
0
506,768
33%
94%
33%
72%
99%
91%
—
Priority Metals and Elements
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
Total Priority Metals and Elements
7,711
7,783
15
475
1,362
21,021
5,783
121
7,271
264
899
0
45,325
98,031
5,434
7,783
15
322
1,001
14,285
2,668
103
5,131
264
807
0
25,776
63,589
2,277
0
0
153
361
6,736
3,115
18
2,140
0
92
0
19,549
34,442
72%
40%
61%
91%
91%
84%
92%
33%
52%
34%
80%
28%
77%
—
w

-------
                                                                                                                      Appendix E - Tables Referenced in Chapter 9
                                                               Table E-4 (Continued)
Pollutant of Concern
POTW Baseline
Wastewater Pollutant
Loading (lbs/yr)3
POTW Postcompliance
Wastewater Pollutant
Loading (lbs/yr)4
Total Pollutant
Removal from POTW
Effluents (lbs/yr)
POTW Pollutant
Removal Efficiency
Nonconventional Metals and Elements
Aluminum
Barium
Boron
Cobalt
Iron
Manganese
Molybdenum
Tin
Titanium
Vanadium
Yttrium
Total Nonconventional Metals and Elements
87,139
46,263
29,732
4,684
214,833
14,757
4,523
2,030
5,455
1,174
326
410,917
58,331
27,811
29,336
3,531
103,792
7,610
4,192
1,716
2,811
1,031
309
240,470
28,809
18,453
396
1,153
111,041
7,147
331
314
2,644
142
18
170,447
88%
35%
14%
4%
83%
41%
52%
65%
69%
42%
58%
—
Bulk Nonconventionals
Chemical Oxygen Demand (COD)
Total Organic Carbon (TOC)
Total Petroleum Hydrocarbon (measured as
SGT-HEM)5
46,198,588
22,515,816
3,341,399
32,339,329
20,984,865
689,782
13,859,259
1,530,952
2,651,618
82%
71%
74%
w
       'Numbers in this table were calculated using more significant figures than shown.
       2136 of the  1,742 total industrial laundries are excluded from compliance under this criterion.
       3POTW baseline wastewater pollutant loading = industry baseline wastewater pollutant loading x (1-POTW pollutant removal efficiency).
       4POTW postcompliance wastewater pollutant loading = industry postcompliance wastewater pollutant loading x (1-POTW pollutant removal efficiency).
       5SGT-HEM is measured by Method 1664 (promulgated at 64 FR 26315; May 14, 1999). In this method, EPA defines SGT-HEM as non-polar material (NPM).
       Throughout this document and the Industrial Laundries Administrative Record, EPA refers to SGT-HEM as total petroleum hydrocarbon (TPH).

       HEM - Hexane extractable material.
       SGT-HEM - Silica gel treated-hexane extractable material.

-------
                                                                                  Appendix E - Tables Referenced in Chapter 9
                                                 Table E-5
     Summary of POTW Pollutant Loadings and Removals from the Industrial Laundry Wastewater for CP-IL1
        Excluding Facilities with Less than 3 Million Pounds per Year Total Production and Less than 120,000
                           Pounds per Year Shop and Printer Towel/Rag Production2
Pollutant of Concern
POTW Baseline
Wastewater Pollutant
Loading (lbs/yr)3
POTW Postcompliance
Wastewater Pollutant
Loading (lbs/yr)4
Total Pollutant
Removal from POTW
Effluents (lbs/yr)
POTW Pollutant
Removal Efficiency
Conventionals
Biochemical Oxygen Demand 5-Day (BOD5)
Oil and Grease (measured as HEM)
Total Suspended Solids (TSS)
9,370,861
4,585,069
5,069,715
8,627,377
1,877,385
2,685,202
743,484
2,707,684
2,384,513
91%
87%
91%
Priority Organics
1,1,1 -Trichloroethane
1 ,2-Diphenylhydrazine
4-Chloro-3-methylphenol
Bis(2-ethylhexyl) Phthalate
Butyl Benzyl Phthalate
Chlorobenzene
Chloroform
Di-w-butyl Phthalate
Di-w-octyl Phthalate
Ethylbenzene
Isophorone
Methylene Chloride
Naphthalene
Phenol
Tetrachloroethene
30,753
0
3,274
53,130
5,223
1,774
93,291
3,776
8,434
22,852
16,533
21,561
31,471
594
25,275
16,546
0
1,141
30,162
1,756
1,202
93,123
1,127
6,305
6,937
7,996
8,392
14,612
594
16,130
14,207
0
2,133
22,968
3,467
572
168
2,649
2,129
15,914
8,536
13,169
16,859
0
9,146
24%
62%
63%
60%
86%
24%
24%
75%
33%
33%
62%
18%
18%
95%
33%
w

-------
                                                       Table E-5 (Continued)
                                                                                                       Appendix E - Tables Referenced in Chapter 9
Pollutant of Concern
POTW Baseline
Wastewater Pollutant
Loading (lbs/yr)3
POTW Postcompliance
Wastewater Pollutant
Loading (lbs/yr)4
Total Pollutant
Removal from POTW
Effluents (lbs/yr)
POTW Pollutant
Removal Efficiency
Priority Organics (Continued)
Toluene
trans- 1 ,2-Dichloroethene
Trichloroethene
Total Priority Organics
41,322
2,108
1,889
363,259
31,963
2,108
1,095
241,190
9,358
0
794
122,069
33%
33%
33%
—
Nonconventional Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pentanone
ซ-Terpineol
Benzoic Acid
Benzyl Alcohol
Hexanoic Acid
w-Xylene
w-Decane
w-Docosane
w-Dodecane
w-Eicosane
w-Hexacosane
w-Hexadecane
w-Octacosane
w-Octadecane
w-Tetracosane
27,866
7,342
19,759
12,014
8,945
12,009
44,649
4,899
10,884
418,536
885
111,108
85,761
862
52,842
533
42,151
1,239
26,274
2,023
11,936
12,014
5,866
12,009
32,259
4,895
8,973
222,769
332
75,061
7,830
240
15,393
215
7,483
508
1,592
5,320
7,824
0
3,079
0
12,390
4
1,911
195,767
553
36,047
77,931
622
37,449
319
34,668
731
18%
28%
85%
18%
18%
81%
33%
33%
33%
33%
94%
33%
33%
94%
33%
94%
33%
94%
w
oo

-------
                                                       Table E-5 (Continued)
                                                                                                       Appendix E - Tables Referenced in Chapter 9
Pollutant of Concern
POTW Baseline
Wastewater Pollutant
Loading (lbs/yr)3
POTW Postcompliance
Wastewater Pollutant
Loading (lbs/yr)4
Total Pollutant
Removal from POTW
Effluents (lbs/yr)
POTW Pollutant
Removal Efficiency
Nonconventional Organics (Continued)
w-Tetradecane
w-Triacontane
o-&/>-Xylene
/>-Cresol
/>-Cymene
Pentamethy Ibenzene
Total Nonconventional Organics
66,629
825
6,881
0
499
0
937,119
13,672
423
6,086
0
142
0
466,402
52,958
402
795
0
357
0
470,717
33%
94%
33%
72%
99%
91%
—
Priority Metals and Elements
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
Total Priority Metals and Elements
7,025
7,482
13
440
1,266
19,404
5,318
114
6,707
232
850
0
41,047
89,899
4,652
7,474
13
260
774
10,834
2,028
101
4,759
142
645
0
14,458
46,139
2,373
8
1
180
492
8,570
3,291
13
1,948
91
205
0
26,589
43,760
72%
40%
61%
91%
91%
84%
92%
33%
52%
34%
80%
28%
77%
—
w

-------
                                                                Table E-5 (Continued)
                                                                                                                       Appendix E - Tables Referenced in Chapter 9
Pollutant of Concern
POTW Baseline
Wastewater Pollutant
Loading (lbs/yr)3
POTW Postcompliance
Wastewater Pollutant
Loading (lbs/yr)4
Total Pollutant
Removal from POTW
Effluents (lbs/yr)
POTW Pollutant
Removal Efficiency
Nonconventional Metals and Elements
Aluminum
Barium
Boron
Cobalt
Iron
Manganese
Molybdenum
Tin
Titanium
Vanadium
Yttrium
Total Nonconventional Metals and Elements
80,313
43,082
27,728
4,411
194,392
13,563
4,310
1,796
4,980
1,096
310
375,981
55,182
30,380
26,201
2,439
84,164
7,096
4,296
783
3,341
977
305
215,162
25,131
12,702
1,527
1,972
110,228
6,467
15
1,013
1,640
119
5
160,819
88%
35%
14%
4%
83%
41%
52%
65%
69%
42%
58%
—
Bulk Nonconventionals
Chemical Oxygen Demand (COD)
Total Organic Carbon (TOC)
Total Petroleum Hydrocarbon (measured as
SGT-HEM)5
42,500,624
21,160,935
3,059,232
32,329,719
19,451,423
570,725
10,170,905
1,709,511
2,488,507
82%
71%
74%
w
to
o
       'Numbers in this table were calculated using more significant figures than shown.
       2518 of the 1,742 total industrial laundries are excluded from compliance under this criterion.  This exclusion includes the 136 facilities excluded under the 1
       Million/255K exclusion shown in Table E-3.
       3POTW baseline wastewater pollutant loading = industry baseline wastewater pollutant loading x (1-POTW pollutant removal efficiency).
       4POTW postcompliance wastewater pollutant loading = industry postcompliance wastewater pollutant loading x (1-POTW pollutant removal efficiency).
       5SGT-HEM is measured by Method 1664 (promulgated at 64 FR 26315; May 14, 1999). In this method, EPA defines SGT-HEM as non-polar material (NPM).
       Throughout this document and the Industrial Laundries Administrative Record, EPA refers to SGT-HEM as total petroleum hydrocarbon (TPH).

       HEM - Hexane extractable material.
       SGT-HEM - Silica gel treated-hexane extractable material.

-------
                                                                                  Appendix E - Tables Referenced in Chapter 9
                                                 Table E-6
      Summary of POTW Pollutant Loadings and Removals from Industrial Laundry Wastewater for DAF-IL1
        Excluding Facilities with Less than 3 Million Pounds per Year Total Production and Less than 120,000
                           Pounds per Year Shop and Printer Towel/Rag Production2
Pollutant of Concern
POTW Baseline
Wastewater Pollutant
Loading (lbs/yr)3
POTW Postcompliance
Wastewater Pollutant
Loading (lbs/yr)4
Total Pollutant
Removal from POTW
Effluents (lbs/yr)
POTW Pollutant
Removal Efficiency
Conventionals
Biochemical Oxygen Demand 5-Day (BOD5)
Oil and Grease (measured as HEM)
Total Suspended Solids (TSS)
9,370,861
4,585,069
5,069,715
8,925,535
1,956,843
2,514,180
445,326
2,628,226
2,555,535
91%
87%
91%
Priority Organics
1,1,1 -Trichloroethane
1 ,2-Diphenylhydrazine
4-Chloro-3-methylphenol
Bis(2-ethylhexyl) Phthalate
Butyl Benzyl Phthalate
Chlorobenzene
Chloroform
Di-w-butyl Phthalate
Di-w-octyl Phthalate
Ethylbenzene
Isophorone
Methylene Chloride
Naphthalene
Phenol
Tetrachloroethene
30,753
0
3,274
53,130
5,223
1,774
93,291
3,776
8,434
22,852
16,533
21,561
31,471
594
25,275
1,714
0
3,045
32,168
3,340
1,135
93,287
2,735
6,069
3,371
16,533
20,454
15,569
593
11,940
29,039
0
230
20,962
1,883
639
4
1,041
2,365
19,481
0
1,106
15,902
0
13,335
24%
62%
63%
60%
86%
24%
24%
75%
33%
33%
62%
18%
18%
95%
33%
w
to

-------
                                                        Table E-6 (Continued)
                                                                                                        Appendix E - Tables Referenced in Chapter 9
Pollutant of Concern
POTW Baseline
Wastewater Pollutant
Loading (lbs/yr)3
POTW Postcompliance
Wastewater Pollutant
Loading (lbs/yr)4
Total Pollutant
Removal from POTW
Effluents (lbs/yr)
POTW Pollutant
Removal Efficiency
Priority Organics (Continued)
Toluene
trans- 1 ,2-Dichloroethene
Trichloroethene
Total Priority Organics
41,322
2,108
1,889
363,259
28,476
2,108
1,889
244,426
12,846
0
0
118,833
33%
33%
33%
—
Nonconventional Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pentanone
ซ-Terpineol
Benzoic Acid
Benzyl Alcohol
Hexanoic Acid
w-Xylene
w-Decane
w-Docosane
w-Dodecane
w-Eicosane
w-Hexacosane
w-Hexadecane
w-Octacosane
w-Octadecane
w-Tetracosane
27,866
7,342
19,759
12,014
8,945
12,009
44,649
4,899
10,884
418,536
885
111,108
85,761
862
52,842
533
42,151
1,239
27,866
6,252
19,700
11,920
8,926
11,859
44,649
4,899
10,188
239,478
381
32,676
9,324
266
17,337
190
9,287
547
0
1,091
59
93
19
150
0
0
696
179,058
504
78,432
76,438
595
35,505
344
32,864
692
18%
28%
85%
18%
18%
81%
33%
33%
33%
33%
94%
33%
33%
94%
33%
94%
33%
94%
w

to
to

-------
                                                       Table E-6 (Continued)
                                                                                                       Appendix E - Tables Referenced in Chapter 9
Pollutant of Concern
POTW Baseline
Wastewater Pollutant
Loading (lbs/yr)3
POTW Postcompliance
Wastewater Pollutant
Loading (lbs/yr)4
Total Pollutant
Removal from POTW
Effluents (lbs/yr)
POTW Pollutant
Removal Efficiency
Nonconventional Organics (Continued)
w-Tetradecane
w-Triacontane
o-&/>-Xylene
/>-Cresol
/>-Cymene
Pentamethy Ibenzene
Total Nonconventional Organics
66,629
825
6,881
0
499
0
937,119
15,298
416
6,722
0
182
0
478,361
51,331
409
159
0
318
0
458,757
33%
94%
33%
72%
99%
91%
—
Priority Metals and Elements
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
Total Priority Metals and Elements
7,025
7,482
13
440
1,266
19,404
5,318
114
6,707
232
850
0
41,047
89,899
5,114
7,482
13
301
915
13,151
2,458
98
4,790
232
759
0
23,263
58,576
1,911
0
0
139
351
6,253
2,860
16
1,917
0
91
0
17,784
31,323
72%
40%
61%
91%
91%
84%
92%
33%
52%
34%
80%
28%
77%
—
w
to

-------
                                                                Table E-6 (Continued)
                                                                                                                       Appendix E - Tables Referenced in Chapter 9
Pollutant of Concern
POTW Baseline
Wastewater Pollutant
Loading (lbs/yr)3
POTW Postcompliance
Wastewater Pollutant
Loading (lbs/yr)4
Total Pollutant
Removal from POTW
Effluents (lbs/yr)
POTW Pollutant
Removal Efficiency
Nonconventional Metals and Elements
Aluminum
Barium
Boron
Cobalt
Iron
Manganese
Molybdenum
Tin
Titanium
Vanadium
Yttrium
Total Nonconventional Metals and Elements
80,313
43,082
27,728
4,411
194,392
13,563
4,310
1,796
4,980
1,096
310
375,981
54,999
26,533
27,332
3,261
96,236
7,179
3,979
1,489
2,686
962
292
224,949
25,314
16,549
396
1,150
98,156
6,384
331
307
2,294
134
17
151,033
88%
35%
14%
4%
83%
41%
52%
65%
69%
42%
58%
—
Bulk Nonconventionals
Chemical Oxygen Demand (COD)
Total Organic Carbon (TOC)
Total Petroleum Hydrocarbon (measured as
SGT-HEM)5
42,500,624
21,160,935
3,059,232
29,779,598
19,637,160
636,199
12,721,025
1,523,775
2,423,033
82%
71%
74%
w
to
       'Numbers in this table were calculated using more significant figures than shown.
       2518 of the 1,742 total industrial laundries are excluded from compliance under this criterion.  This exclusion includes the 136 facilities excluded under the 1
       Million/255K exclusion shown in Table E-4.
       3POTW baseline wastewater pollutant loading = industry baseline wastewater pollutant loading x (1-POTW pollutant removal efficiency).
       4POTW postcompliance wastewater pollutant loading = industry postcompliance wastewater pollutant loading x (1-POTW pollutant removal efficiency).
       5SGT-HEM is measured by Method 1664 (promulgated at 64 FR 26315; May 14, 1999). In this method, EPA defines SGT-HEM as non-polar material (NPM).
       Throughout this document and the Industrial Laundries Administrative Record, EPA refers to SGT-HEM as total petroleum hydrocarbon (TPH).

       HEM - Hexane extractable material.
       SGT-HEM - Silica gel treated-hexane extractable material.

-------
                                                                                  Appendix E - Tables Referenced in Chapter 9
                                                 Table E-7
     Summary of POTW Pollutant Loadings and Removals from the Industrial Laundry Wastewater for CP-IL1
        Excluding Facilities with Less than 5 Million Pounds per Year Total Production and Less than 255,000
                           Pounds per Year Shop and Printer Towel/Rag Production2
Pollutant of Concern
POTW Baseline
Wastewater Pollutant
Loading (lbs/yr)3
POTW Postcompliance
Wastewater Pollutant
Loading (lbs/yr)4
Total Pollutant
Removal from POTW
Effluents (lbs/yr)
POTW Pollutant
Removal Efficiency
Conventionals
Biochemical Oxygen Demand 5-Day (BOD5)
Oil and Grease (measured as HEM)
Total Suspended Solids (TSS)
7,870,550
3,713,278
4,023,754
7,194,216
1,571,679
2,176,761
676,334
2,141,599
1,846,993
91%
87%
91%
Priority Organics
1,1,1 -Trichloroethane
1 ,2-Diphenylhydrazine
4-Chloro-3-methylphenol
Bis(2-ethylhexyl) Phthalate
Butyl Benzyl Phthalate
Chlorobenzene
Chloroform
Di-w-butyl Phthalate
Di-w-octyl Phthalate
Ethylbenzene
Isophorone
Methylene Chloride
Naphthalene
Phenol
Tetrachloroethene
25,408
0
2,549
43,102
4,497
1,560
80,461
3,057
6,912
18,055
13,937
17,752
25,700
499
20,338
12,037
0
785
25,665
1,498
1,003
80,297
941
5,141
4,612
5,688
5,928
12,000
499
11,665
13,371
0
1,764
17,437
2,999
557
165
2,116
1,771
13,443
8,249
11,824
13,699
0
8,673
24%
62%
63%
60%
86%
24%
24%
75%
33%
33%
62%
18%
18%
95%
33%
w
to

-------
                                                       Table E-7 (Continued)
                                                                                                       Appendix E - Tables Referenced in Chapter 9
Pollutant of Concern
POTW Baseline
Wastewater Pollutant
Loading (lbs/yr)3
POTW Postcompliance
Wastewater Pollutant
Loading (lbs/yr)4
Total Pollutant
Removal from POTW
Effluents (lbs/yr)
POTW Pollutant
Removal Efficiency
Priority Organics (Continued)
Toluene
trans- 1 ,2-Dichloroethene
Trichloroethene
Total Priority Organics
34,249
1,871
1,704
301,652
25,789
1,871
921
196,341
8,460
0
783
105,310
33%
33%
33%
—
Nonconventional Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pentanone
ซ-Terpineol
Benzoic Acid
Benzyl Alcohol
Hexanoic Acid
w-Xylene
w-Decane
w-Docosane
w-Dodecane
w-Eicosane
w-Hexacosane
w-Hexadecane
w-Octacosane
w-Octadecane
w-Tetracosane
23,537
5,813
16,989
10,120
7,670
9,960
38,061
3,861
9,110
346,475
676
86,417
66,884
670
41,648
411
32,751
985
21,945
1,639
9,694
10,120
4,715
9,960
25,949
3,857
7,297
191,400
278
54,358
6,629
197
12,927
171
6,193
429
1,592
4,174
7,295
0
2,955
0
12,111
4
1,813
155,075
398
32,059
60,255
473
28,721
239
26,558
556
18%
28%
85%
18%
18%
81%
33%
33%
33%
33%
94%
33%
33%
94%
33%
94%
33%
94%
w
to

-------
                                                       Table E-7 (Continued)
                                                                                                       Appendix E - Tables Referenced in Chapter 9
Pollutant of Concern
POTW Baseline
Wastewater Pollutant
Loading (lbs/yr)3
POTW Postcompliance
Wastewater Pollutant
Loading (lbs/yr)4
Total Pollutant
Removal from POTW
Effluents (lbs/yr)
POTW Pollutant
Removal Efficiency
Nonconventional Organics (Continued)
w-Tetradecane
w-Triacontane
o-&/>-Xylene
/>-Cresol
/>-Cymene
Pentamethy Ibenzene
Total Nonconventional Organics
52,170
668
5,840
0
437
0
761,153
11,458
355
5,072
0
121
0
384,765
40,712
313
768
0
316
0
376,388
33%
94%
33%
72%
99%
91%
—
Priority Metals and Elements
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
Total Priority Metals and Elements
5,514
6,422
10
360
1,026
15,618
4,277
95
5,424
174
718
0
32,490
72,129
3,892
6,415
9
215
616
8,801
1,649
85
3,864
99
537
0
11,583
37,765
1,622
8
1
145
411
6,817
2,628
10
1,560
75
181
0
20,906
34,364
72%
40%
61%
91%
91%
84%
92%
33%
52%
34%
80%
28%
77%
—
w
to

-------
                                                               Table E-7 (Continued)
                                                                                                                      Appendix E - Tables Referenced in Chapter 9
Pollutant of Concern
POTW Baseline
Wastewater Pollutant
Loading (lbs/yr)3
POTW Postcompliance
Wastewater Pollutant
Loading (lbs/yr)4
Total Pollutant
Removal from POTW
Effluents (lbs/yr)
POTW Pollutant
Removal Efficiency
Nonconventional Metals and Elements
Aluminum
Barium
Boron
Cobalt
Iron
Manganese
Molybdenum
Tin
Titanium
Vanadium
Yttrium
Total Nonconventional Metals and Elements
64,518
35,172
23,169
3,750
152,254
10,908
3,668
1,363
3,919
903
261
299,886
45,533
24,803
21,649
1,891
68,808
5,880
3,655
543
2,688
798
257
176,506
18,986
10,369
1,520
1,859
83,446
5,028
14
819
1,230
105
4
123,380
88%
35%
14%
4%
83%
41%
52%
65%
69%
42%
58%
—
Bulk Nonconventionals
Chemical Oxygen Demand (COD)
Total Organic Carbon (TOC)
Total Petroleum Hydrocarbon (measured as
SGT-HEM)5
34,126,011
17,604,176
2,430,965
25,242,072
16,039,154
458,599
8,883,939
1,565,022
1,972,367
82%
71%
74%
w
to
oo
       'Numbers in this table were calculated using more significant figures than shown.
       2953 of the  1,742 total industrial laundries are excluded from compliance under this criterion.
       3POTW baseline wastewater pollutant loading = industry baseline wastewater pollutant loading x (1-POTW pollutant removal efficiency).
       4POTW postcompliance wastewater pollutant loading = industry postcompliance wastewater pollutant loading x (1-POTW pollutant removal efficiency).
       5SGT-HEM is measured by Method 1664 (promulgated at 64 FR 26315; May 14, 1999).  In this method, EPA defines SGT-HEM as non-polar matenal (NPM).
       Throughout this document and the Industrial Laundries Administrative Record, EPA refers to SGT-HEM as total petroleum hydrocarbon (TPH).
      HEM - Hexane extractable material.
      SGT-HEM - Silica gel treated-hexane extractable material.

-------
                                                                                  Appendix E - Tables Referenced in Chapter 9
                                                  Table E-8
      Summary of POTW Pollutant Loadings and Removals from Industrial Laundry Wastewater for DAF-IL1
        Excluding Facilities with Less than 5 Million Pounds per Year Total Production and Less than 255,000
                           Pounds per Year Shop and Printer Towel/Rag Production2
Pollutant of Concern
POTW Baseline
Wastewater Pollutant
Loading (lbs/yr)3
POTW Postcompliance
Wastewater Pollutant
Loading (lbs/yr)4
Total Pollutant
Removal from POTW
Effluents (lbs/yr)
POTW Pollutant
Removal Efficiency
Conventionals
Biochemical Oxygen Demand 5-Day (BOD5)
Oil and Grease (measured as HEM)
Total Suspended Solids (TSS)
7,870,550
3,713,278
4,023,754
7,462,737
1,623,842
2,069,124
407,813
2,089,436
1,954,630
91%
87%
91%
Priority Organics
1,1,1 -Trichloroethane
1 ,2-Diphenylhydrazine
4-Chloro-3-methylphenol
Bis(2-ethylhexyl) Phthalate
Butyl Benzyl Phthalate
Chlorobenzene
Chloroform
Di-w-butyl Phthalate
Di-w-octyl Phthalate
Ethylbenzene
Isophorone
Methylene Chloride
Naphthalene
Phenol
Tetrachloroethene
25,408
0
2,549
43,102
4,497
1,560
80,461
3,057
6,912
18,055
13,937
17,752
25,700
499
20,338
1,307
0
2,327
26,988
2,739
939
80,457
2,163
4,992
2,367
13,937
16,695
12,639
499
8,320
24,101
0
221
16,114
1,758
621
4
893
1,920
15,688
0
1,058
13,061
0
12,018
24%
62%
63%
60%
86%
24%
24%
75%
33%
33%
62%
18%
18%
95%
33%
w
to
VO

-------
                                                                                                       Appendix E - Tables Referenced in Chapter 9
                                                       Table E-8 (Continued)
Pollutant of Concern
POTW Baseline
Wastewater Pollutant
Loading (lbs/yr)3
POTW Postcompliance
Wastewater Pollutant
Loading (lbs/yr)4
Total Pollutant
Removal from POTW
Effluents (lbs/yr)
POTW Pollutant
Removal Efficiency
Priority Organics (Continued)
Toluene
trans- 1 ,2-Dichloroethene
Trichloroethene
Total Priority Organics
34,249
1,871
1,704
301,652
22,770
1,871
1,704
202,715
11,479
0
0
98,937
33%
33%
33%
—
Nonconventional Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pentanone
ซ-Terpineol
Benzoic Acid
Benzyl Alcohol
Hexanoic Acid
w-Xylene
w-Decane
w-Docosane
w-Dodecane
w-Eicosane
w-Hexacosane
w-Hexadecane
w-Octacosane
w-Octadecane
w-Tetracosane
23,537
5,813
16,989
10,120
7,670
9,960
38,061
3,861
9,110
346,475
676
86,417
66,884
670
41,648
411
32,751
985
23,537
4,839
16,930
10,026
7,651
9,810
38,061
3,861
8,440
202,368
310
26,268
7,628
215
14,221
156
7,412
454
0
975
59
93
19
150
0
0
669
144,107
366
60,149
59,256
455
27,427
255
25,339
530
18%
28%
85%
18%
18%
81%
33%
33%
33%
33%
94%
33%
33%
94%
33%
94%
33%
94%
w
I
OJ

o

-------
                                                                                                       Appendix E - Tables Referenced in Chapter 9
                                                       Table E-8 (Continued)
Pollutant of Concern
POTW Baseline
Wastewater Pollutant
Loading (lbs/yr)3
POTW Postcompliance
Wastewater Pollutant
Loading (lbs/yr)4
Total Pollutant
Removal from POTW
Effluents (lbs/yr)
POTW Pollutant
Removal Efficiency
Nonconventional Organics (Continued)
w-Tetradecane
w-Triacontane
o-&/>-Xylene
p-Creso\
p-Cymene
Pentamethy Ibenzene
Total Nonconventional Organics
52,170
668
5,840
0
437
0
761,153
12,540
351
5,681
0
148
0
400,907
39,630
317
158
0
289
0
360,245
33%
94%
33%
72%
99%
91%
—
Priority Metals and Elements
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
Total Priority Metals and Elements
5,514
6,422
10
360
1,026
15,618
4,277
95
5,424
174
718
0
32,490
72,129
4,201
6,422
10
243
717
10,410
1,943
83
3,885
174
631
0
17,676
46,395
1,314
0
0
117
309
5,207
2,334
12
1,539
0
88
0
14,813
25,734
72%
40%
61%
91%
91%
84%
92%
33%
52%
34%
80%
28%
77%
—
w

-------
                                                                                                                      Appendix E - Tables Referenced in Chapter 9
                                                               Table E-8 (Continued)
Pollutant of Concern
POTW Baseline
Wastewater Pollutant
Loading (lbs/yr)3
POTW Postcompliance
Wastewater Pollutant
Loading (lbs/yr)4
Total Pollutant
Removal from POTW
Effluents (lbs/yr)
POTW Pollutant
Removal Efficiency
Nonconventional Metals and Elements
Aluminum
Barium
Boron
Cobalt
Iron
Manganese
Molybdenum
Tin
Titanium
Vanadium
Yttrium
Total Nonconventional Metals and Elements
64,518
35,172
23,169
3,750
152,254
10,908
3,668
1,363
3,919
903
261
299,886
45,418
22,383
22,773
2,642
76,959
5,934
3,362
1,081
2,272
786
245
183,854
19,100
12,789
396
1,109
75,295
4,975
307
282
1,647
117
16
116,032
88%
35%
14%
4%
83%
41%
52%
65%
69%
42%
58%
—
Bulk Nonconventionals
Chemical Oxygen Demand (COD)
Total Organic Carbon (TOC)
Total Petroleum Hydrocarbon (measured as
SGT-HEM)5
34,126,011
17,604,176
2,430,965
23,506,336
16,208,778
503,145
10,619,675
1,395,398
1,927,820
82%
71%
74%
w
I
OJ
to
       'Numbers in this table were calculated using more significant figures than shown.
       2953 of the  1,742 total industrial laundries are excluded from compliance under this criterion.
       3POTW baseline wastewater pollutant loading = industry baseline wastewater pollutant loading x (1-POTW pollutant removal efficiency).
       4POTW postcompliance wastewater pollutant loading = industry postcompliance wastewater pollutant loading x (1-POTW pollutant removal efficiency).
       5SGT-HEM is measured by Method 1664 (promulgated at 64 FR 26315; May 14, 1999).  In this method, EPA defines SGT-HEM as non-polar material (NPM).
       Throughout this document and the Industrial Laundries Administrative Record, EPA refers to SGT-HEM as total petroleum hydrocarbon (TPH).

       HEM - Hexane extractable material.
       SGT-HEM - Silica gel treated-hexane extractable material.

-------
                                                                                     Appendix E - Tables Referenced in Chapter 9
                                                   Table E-9
                                Summary of Pollutant Loadings and Removals from
                                   Industrial Laundry Wastewater for CP-IL1
                                                Entire Industry2
Pollutant of Concern
Industry Raw
Wastewater Pollutant
Loading (Ibs/yr)
Industry Baseline
Wastewater Pollutant
Loading (Ibs/yr)
Industry
Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
Industry Pollutant
Removal from Baseline
(Ibs/yr)
Conventionals
Biochemical Oxygen Demand 5-Day (BOD5)
Oil and Grease (measured as HEM)
Total Suspended Solids (TSS)
123,053,210
64,091,381
80,188,009
111,166,461
38,519,591
62,531,426
102,558,482
15,314,139
32,147,990
8,607,980
23,205,452
30,383,436
Priority Organics
1,1,1 -Trichloroethane
1 ,2-Diphenylhydrazine
4-Chloro-3-methylphenol
Bis(2-ethylhexyl) Phthalate
Butyl Benzyl Phthalate
Chlorobenzene
Chloroform
Di-w-butyl Phthalate
Di-w-octyl Phthalate
Ethylbenzene
Isophorone
Methylene Chloride
Naphthalene
Phenol
Tetrachloroethene
59,729
0
11,265
198,773
49,117
3,052
132,500
27,638
17,710
73,755
48,514
36,366
73,252
12,692
66,769
44,354
0
10,048
143,930
39,666
2,487
128,187
16,435
13,633
38,046
47,778
29,221
41,634
12,686
42,301
24,961
0
3,544
79,273
13,169
1,708
127,943
4,787
10,108
12,064
24,228
11,728
19,075
12,686
27,571
19,393
0
6,504
64,656
26,497
779
244
11,648
3,524
25,982
23,550
17,493
22,560
1
14,730
w

-------
                                                       Table E-9 (Continued)
                                                                                                       Appendix E - Tables Referenced in Chapter 9
Pollutant of Concern
Industry Raw
Wastewater Pollutant
Loading (Ibs/yr)
Industry Baseline
Wastewater Pollutant
Loading (Ibs/yr)
Industry
Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
Industry Pollutant
Removal from Baseline
(Ibs/yr)
Priority Organics (Continued)
Toluene
trans- 1 ,2-Dichloroethene
Trichloroethene
Total Priority Organics
124,476
3,358
3,033
941,999
66,379
3,358
2,971
683,114
51,536
3,358
1,757
429,496
14,842
0
1,214
253,618
Nonconventional Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pentanone
ซ-Terpineol
Benzoic Acid
Benzyl Alcohol
Hexanoic Acid
w-Xylene
w-Decane
w-Docosane
w-Dodecane
w-Eicosane
w-Hexacosane
w-Hexadecane
w-Octacosane
w-Octadecane
w-Tetracosane
42,700
14,664
207,940
20,081
13,811
71,411
73,140
8,081
23,707
1,046,234
21,935
290,183
230,589
26,371
142,838
13,905
109,286
28,108
37,079
11,420
139,704
15,946
11,666
68,837
71,863
8,077
17,712
673,669
16,653
186,284
146,471
16,085
88,172
10,047
71,627
22,929
35,068
3,026
85,958
15,946
7,759
68,837
52,597
8,072
14,657
347,700
5,872
128,584
12,320
4,279
24,316
3,877
11,910
8,936
2,011
8,394
53,746
0
3,907
0
19,265
5
3,056
325,970
10,780
57,700
134,150
11,806
63,856
6,170
59,717
13,993
w

-------
                                                       Table E-9 (Continued)
                                                                                                       Appendix E - Tables Referenced in Chapter 9
Pollutant of Concern
Industry Raw
Wastewater Pollutant
Loading (Ibs/yr)
Industry Baseline
Wastewater Pollutant
Loading (Ibs/yr)
Industry
Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
Industry Pollutant
Removal from Baseline
(Ibs/yr)
Nonconventional Organics (Continued)
w-Tetradecane
w-Triacontane
o-&/>-Xylene
p-Creso\
p-Cymene
Pentamethy Ibenzene
Total Nonconventional Organics
177,656
18,215
14,556
0
71,555
0
2,666,967
112,400
15,088
11,110
0
52,508
0
1,805,347
21,622
7,456
9,824
0
14,907
0
893,523
90,778
7,632
1,286
0
37,601
0
911,824
Priority Metals and Elements
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
Total Priority Metals and Elements
30,491
13,446
39
6,322
21,638
180,093
108,384
196
17,258
408
4,958
0
240,534
623,768
27,706
13,064
39
5,345
15,303
132,972
73,428
182
15,287
403
4,535
0
199,400
487,665
17,615
13,050
37
3,077
9,375
72,944
27 292
161
10,686
247
3,428
0
68,172
226,084
10,091
14
2
2,268
5,928
60,028
46,137
22
4,601
156
1,107
0
131,228
261,581
w

-------
                                                               Table E-9 (Continued)
                                                                                                                     Appendix E - Tables Referenced in Chapter 9
Pollutant of Concern
Industry Raw
Wastewater Pollutant
Loading (Ibs/yr)
Industry Baseline
Wastewater Pollutant
Loading (Ibs/yr)
Industry
Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
Industry Pollutant
Removal from Baseline
(Ibs/yr)
Nonconventional Metals and Elements
Aluminum
Barium
Boron
Cobalt
Iron
Manganese
Molybdenum
Tin
Titanium
Vanadium
Yttrium
Total Nonconventional Metals and Elements
819,659
94,028
36,131
5,856
1,495,967
30,505
13,070
6,712
20,259
2,169
814
2,525,169
731,628
72,023
34,933
4,940
1,275,369
25,269
9,542
5,854
17,716
2,040
783
2,180,096
491,296
50,147
33,031
2,809
531,645
12,823
9,488
2,595
11,656
1,822
771
1,148,083
240,332
21,876
1,902
2,131
743,724
12,446
54
3,259
6,061
218
11
1,032,013
Bulk Nonconventionals
Chemical Oxygen Demand (COD)
Total Organic Carbon (TOC)
Total Petroleum Hydrocarbon (measured as
SGT-HEM)3
333,560,152
87,454,482
22,888,698
259,751,769
78,340,477
13,109,842
197,873,919
72,196,038
2,377,260
61,877,850
6,144,439
10,732,581
w
      'Numbers in this table were calculated using more significant figures than shown.
      2The entire industrial laundries industry is estimated to consist of 1,742 facilities.
      3SGT-HEM is measured by Method 1664 (promulgated at 64 FR 26315; May 14, 1999).  In this method, EPA defines SGT-HEM as non-polar material (NPM).
      Throughout this document and the Industrial Laundries Administrative Record, EPA refers to SGT-HEM as total petroleum hydrocarbon (TPH).

      HEM - Hexane extractable material.
      SGT-HEM - Silica gel treated-hexane extractable material.

-------
                                                                                     Appendix E - Tables Referenced in Chapter 9
                                                   Table E-10
                                Summary of Pollutant Loadings and Removals from
                                   Industrial Laundry Wastewater for DAF-IL1
                                                Entire Industry2
Pollutant of Concern
Industry Raw
Wastewater Pollutant
Loading (Ibs/yr)
Industry Baseline
Wastewater Pollutant
Loading (Ibs/yr)
Industry
Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
Industry Pollutant
Removal from Baseline
(Ibs/yr)
Conventionals
Biochemical Oxygen Demand 5-Day (BOD5)
Oil and Grease (measured as HEM)
Total Suspended Solids (TSS)
123,053,210
64,091,381
80,188,009
111,166,461
38,519,591
62,531,426
105,943,546
16,035,628
29,879,620
5,222,915
22,483,963
32,651,807
Priority Organics
1,1,1 -Trichloroethane
1 ,2-Diphenylhydrazine
4-Chloro-3-methylphenol
Bis(2-ethylhexyl) Phthalate
Butyl Benzyl Phthalate
Chlorobenzene
Chloroform
Di-w-butyl Phthalate
Di-w-octyl Phthalate
Ethylbenzene
Isophorone
Methylene Chloride
Naphthalene
Phenol
Tetrachloroethene
59,729
0
11,265
198,773
49,117
3,052
132,500
27,638
17,710
73,755
48,514
36,366
73,252
12,692
66,769
44,354
0
10,048
143,930
39,666
2,487
128,187
16,435
13,633
38,046
47,778
29,221
41,634
12,686
42,301
2,377
0
9,364
85,188
25,872
1,616
128,182
12,065
9,687
5,741
47,778
27,554
20,447
12,679
20,512
41,976
0
684
58,741
13,795
871
5
4,370
3,946
32,305
0
1,667
21,188
7
21,790
w

-------
                                                                                                      Appendix E - Tables Referenced in Chapter 9
                                                      Table E-10 (Continued)
Pollutant of Concern
Industry Raw
Wastewater Pollutant
Loading (Ibs/yr)
Industry Baseline
Wastewater Pollutant
Loading (Ibs/yr)
Industry
Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
Industry Pollutant
Removal from Baseline
(Ibs/yr)
Priority Organics (Continued)
Toluene
trans- 1 ,2-Dichloroethene
Trichloroethene
Total Priority Organics
124,476
3,358
3,033
950,999
66,379
3,358
2,971
683,114
46,162
3,358
2,971
461,552
20,217
0
0
221,562
Nonconventional Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pentanone
ซ-Terpineol
Benzoic Acid
Benzyl Alcohol
Hexanoic Acid
w-Xylene
w-Decane
w-Docosane
w-Dodecane
w-Eicosane
w-Hexacosane
w-Hexadecane
w-Octacosane
w-Octadecane
w-Tetracosane
42,700
14,664
207,940
20,081
13,811
71,411
73,140
8,081
23,707
1,046,234
21,935
290,183
230,589
26,371
142,838
13,905
109,286
28,108
37,079
11,420
139,704
15,946
11,666
68,837
71,863
8,077
17,712
673,669
16,653
186,284
146,471
16,085
88,172
10,047
71,627
22,929
37,078
9,803
139,280
15,786
11,643
68,014
71,862
8,077
16,512
377,128
6,818
52,336
14,929
4,796
27,715
3,383
15,051
9,701
0
1,618
424
159
23
823
0
0
1,200
296,541
9,834
133,947
131,541
11,289
60,457
6,664
56,576
13,228
w
I
OJ
oo

-------
                                                                                                      Appendix E - Tables Referenced in Chapter 9
                                                      Table E-10 (Continued)
Pollutant of Concern
Industry Raw
Wastewater Pollutant
Loading (Ibs/yr)
Industry Baseline
Wastewater Pollutant
Loading (Ibs/yr)
Industry
Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
Industry Pollutant
Removal from Baseline
(Ibs/yr)
Nonconventional Organics (Continued)
w-Tetradecane
w-Triacontane
o-&/>-Xylene
/>-Cresol
/>-Cymene
Pentamethy Ibenzene
Total Nonconventional Organics
177,656
18,215
14,556
0
71,555
0
2,666,967
112,400
15,088
11,110
0
52,508
0
1,805,347
24,465
7,317
10,799
0
19,495
0
951,992
87,934
7,771
311
0
33,013
0
853,355
Priority Metals and Elements
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
Total Priority Metals and Elements
30,491
13,446
39
6,322
21,638
180,093
108,384
196
17,258
408
4,958
0
240,534
623,768
27,706
13,064
39
5,345
15,303
132,972
73,428
182
15,287
403
4,535
0
199,400
487,665
19,540
13,063
39
3,607
11,193
89,894
33,574
155
10,763
403
4,063
0
112,848
299,142
8,167
0
0
1,737
4,110
43,078
39,854
28
4,524
0
472
0
86,553
188,523
w
I
OJ

vo

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                                                                                                                     Appendix E - Tables Referenced in Chapter 9
                                                              Table E-10 (Continued)
Pollutant of Concern
Industry Raw
Wastewater Pollutant
Loading (Ibs/yr)
Industry Baseline
Wastewater Pollutant
Loading (Ibs/yr)
Industry
Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
Industry Pollutant
Removal from Baseline
(Ibs/yr)
Nonconventional Metals and Elements
Aluminum
Barium
Boron
Cobalt
Iron
Manganese
Molybdenum
Tin
Titanium
Vanadium
Yttrium
Total Nonconventional Metals and Elements
819,659
94,028
36,131
5,856
1,495,967
30,505
13,070
6,712
20,259
2,169
814
2,525,169
731,628
72,023
34,933
4,940
1,275,369
25,269
9,542
5,854
17,716
2,040
783
2,180,096
489,482
43,084
34,376
3,704
614,767
12,989
8,803
4,934
9,132
1,790
740
1,223,799
242,147
28,939
557
1,237
660,602
12,280
740
920
8,584
249
42
956,297
Bulk Nonconventionals
Chemical Oxygen Demand (COD)
Total Organic Carbon (TOC)
Total Petroleum Hydrocarbon (measured as
SGT-HEM)3
333,560,152
87,454,482
22,888,698
259,751,769
78,340,477
13,109,842
180,887,567
72,858,026
2,671,268
78,864,203
5,482,451
10,438,574
w
-U
o
      'Numbers in this table were calculated using more significant figures than shown.
      2The entire industrial laundries industry is estimated to consist of 1,742 facilities.
      3SGT-HEM is measured by Method 1664 (promulgated at 64 FR 26315; May 14, 1999). In this method, EPA defines SGT-HEM as non-polar matenal (NPM).
      Throughout this document and the Industrial Laundries Administrative Record, EPA refers to SGT-HEM as total petroleum hydrocarbon (TPH).

      HEM - Hexane extractable material.
      SGT-HEM - Silica gel treated-hexane extractable material.

-------
                                                                                  Appendix E - Tables Referenced in Chapter 9
                                                 Table E-ll
          Summary of Pollutant Loadings and Removals from Industrial Laundry Wastewater for CP-IL1
  Excluding Facilities with Less than 1 Million Pounds per Year Total Production and Less Than 255,000 Pounds per
                                 Year Shop and Printer Towel/Rag Production2
Pollutant of Concern
Industry Raw
Wastewater Pollutant
Loading (Ibs/yr)
Industry Baseline
Wastewater Pollutant
Loading (Ibs/yr)
Industry
Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
Industry Pollutant
Removal from Baseline
(Ibs/yr)
Conventionals
Biochemical Oxygen Demand 5-Day (BOD5)
Oil and Grease (measured as HEM)
Total Suspended Solids (TSS)
122,032,841
63,393,214
79,368,559
110,170,372
37,893,390
61,742,432
101,859,551
15,207,566
31,926,179
8,310,821
22,685,824
29,816,253
Priority Organics
1,1,1 -Trichloroethane
1 ,2-Diphenylhydrazine
4-Chloro-3-methylphenol
Bis(2-ethylhexyl) Phthalate
Butyl Benzyl Phthalate
Chlorobenzene
Chloroform
Di-w-butyl Phthalate
Di-w-octyl Phthalate
Ethylbenzene
Isophorone
Methylene Chloride
Naphthalene
Phenol
Tetrachloroethene
58,992
0
11,146
197,147
48,625
3,010
131,575
27,364
17,546
72,813
47,811
35,843
72,442
12,594
65,740
43,682
0
9,930
142,454
39,223
2,448
127,263
16,193
13,478
37,203
47,075
28,698
40,915
12,588
41,317
24,791
0
3,523
78,718
13,078
1,695
127,041
4,754
10,038
11,985
24,095
11,651
18,944
12,588
27,387
18,890
0
6,406
63,736
26,146
753
221
11,440
3,440
25,217
22,979
17,047
21,972
1
13,930
w

-------
                                                      Table E-11 (Continued)
                                                                                                       Appendix E - Tables Referenced in Chapter 9
Pollutant of Concern
Industry Raw
Wastewater Pollutant
Loading (Ibs/yr)
Industry Baseline
Wastewater Pollutant
Loading (Ibs/yr)
Industry
Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
Industry Pollutant
Removal from Baseline
(Ibs/yr)
Priority Organics (Continued)
Toluene
trans- 1 ,2-Dichloroethene
Trichloroethene
Total Priority Organics
123,062
3,308
2,991
932,009
65,145
3,308
2,929
673,848
51,127
3,308
1,743
426,467
14,018
0
1,186
247,381
Nonconventional Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pentanone
ซ-Terpineol
Benzoic Acid
Benzyl Alcohol
Hexanoic Acid
w-Xylene
w-Decane
w-Docosane
w-Dodecane
w-Eicosane
w-Hexacosane
w-Hexadecane
w-Octacosane
w-Octadecane
w-Tetracosane
42,112
14,503
205,792
19,822
13,649
70,709
72,258
8,037
23,401
1,034,766
21,738
286,670
227,062
26,081
141,149
13,754
107,779
27,843
36,490
11,262
137,556
15,687
11,504
68,136
70,980
8,033
17,418
663,185
16,466
183,028
143,083
15,821
86,604
9,903
70,187
22,677
34,548
3,006
85,282
15,687
7,707
68,136
52,268
8,027
14,553
345,248
5,832
127,690
12,235
4,250
24,147
3,850
11,828
8,874
1,942
8,257
52,274
0
3,798
0
18,712
5
2,865
317,937
10,635
55,338
130,848
11,572
62,457
6,053
58,359
13,803
w
-U
to

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                                                      Table E-11 (Continued)
                                                                                                      Appendix E - Tables Referenced in Chapter 9
Pollutant of Concern
Industry Raw
Wastewater Pollutant
Loading (Ibs/yr)
Industry Baseline
Wastewater Pollutant
Loading (Ibs/yr)
Industry
Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
Industry Pollutant
Removal from Baseline
(Ibs/yr)
Nonconventional Organics (Continued)
w-Tetradecane
w-Triacontane
o-&/>-Xylene
p-Creso\
p-Cymene
Pentamethy Ibenzene
Total Nonconventional Organics
175,284
18,046
14,372
0
70,799
0
2,635,625
110,160
14,928
10,933
0
51,855
0
1,775,897
21,472
7,403
9,746
0
14,803
0
886,592
88,689
7,524
1,186
0
37,052
0
889,305
Priority Metals and Elements
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
Total Priority Metals and Elements
30,321
13,354
39
6,258
21,450
178,395
107,160
195
17,116
406
4,915
0
238,137
617,745
27,540
12,972
39
5,281
15,133
131,381
72,288
181
15,148
400
4,494
0
197,065
481,921
17,494
12,958
37
3,056
9,312
72,449
27,106
160
10,613
246
3,405
0
67,710
224,544
10,046
14
2
2,226
5,821
58,932
45,182
21
4,535
154
1,089
0
129,355
257,377
w

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                                                              Table E-11 (Continued)
                                                                                                                    Appendix E - Tables Referenced in Chapter 9
Pollutant of Concern
Industry Raw
Wastewater Pollutant
Loading (Ibs/yr)
Industry Baseline
Wastewater Pollutant
Loading (Ibs/yr)
Industry
Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
Industry Pollutant
Removal from Baseline
(Ibs/yr)
Nonconventional Metals and Elements
Aluminum
Barium
Boron
Cobalt
Iron
Manganese
Molybdenum
Tin
Titanium
Vanadium
Yttrium
Total Nonconventional Metals and Elements
814,053
93,127
35,769
5,791
1,483,962
30,237
12,939
6,658
20,135
2,153
808
2,505,633
726,162
71,175
34,572
4,879
1,263,722
25,012
9,423
5,799
17,597
2,024
777
2,161,142
487,891
49,799
32,796
2,791
528,021
12,734
9,393
2,578
11,575
1,810
766
1,140,153
238,270
21,376
1,776
2,089
735,701
12,279
30
3,221
6,022
214
11
1,020,989
Bulk Nonconventionals
Chemical Oxygen Demand (COD)
Total Organic Carbon (TOC)
Total Petroleum Hydrocarbon (measured as
SGT-HEM)3
330,306,526
86,738,604
22,604,163
256,658,823
77,640,746
12,851,536
196,546,125
71,706,500
2,361,108
60,112,698
5,934,246
10,490,428
w
      'Numbers in this table were calculated using more significant figures than shown.
      2136 of the 1,742 total industrial laundries are excluded from compliance under this criterion.
      3SGT-HEM is measured by Method 1664 (promulgated at 64 FR 26315; May 14, 1999). In this method, EPA defines SGT-HEM as non-polar material (NPM).
      Throughout this document and the Industrial Laundries Administrative Record, EPA refers to SGT-HEM as total petroleum hydrocarbon (TPH).

      HEM - Hexane extractable material.
      SGT-HEM - Silica gel treated-hexane extractable material.

-------
                                                                                  Appendix E - Tables Referenced in Chapter 9
                                                 Table E-12
          Summary of Pollutant Loadings and Removals from Industrial Laundry Wastewater for DAF-IL1
  Excluding Facilities with Less than 1 Million Pounds per Year Total Production and Less than 255,000 Pounds per
                                 Year Shop and Printer Towel/Rag Production2
Pollutant of Concern
Industry Raw
Wastewater Pollutant
Loading (Ibs/yr)
Industry Baseline
Wastewater Pollutant
Loading (Ibs/yr)
Industry
Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
Industry Pollutant
Removal from Baseline
(Ibs/yr)
Conventionals
Biochemical Oxygen Demand 5-Day (BOD5)
Oil and Grease (measured as HEM)
Total Suspended Solids (TSS)
122,032,841
63,393,214
79,368,559
110,170,372
37,893,390
61,742,432
105,209,109
15,923,719
29,673,939
4,961,263
21,969,671
32,068,493
Priority Organics
1,1,1 -Trichloroethane
1 ,2-Diphenylhydrazine
4-Chloro-3-methylphenol
Bis(2-ethylhexyl) Phthalate
Butyl Benzyl Phthalate
Chlorobenzene
Chloroform
Di-w-butyl Phthalate
Di-w-octyl Phthalate
Ethylbenzene
Isophorone
Methylene Chloride
Naphthalene
Phenol
Tetrachloroethene
58,992
0
11,146
197,147
48,625
3,010
131,575
27,364
17,546
72,813
47,811
35,843
72,442
12,594
65,740
43,682
0
9,930
142,454
39,223
2,448
127,263
16,193
13,478
37,203
47,075
28,698
40,915
12,588
41,317
2,372
0
9,309
84,589
25,686
1,605
127,257
11,978
9,620
5,705
47,075
27,348
20,306
12,581
20,388
41,310
0
621
57,865
13,537
843
5
4,216
3,858
31,498
0
1,349
20,609
7
20,929
w

-------
                                                                                                      Appendix E - Tables Referenced in Chapter 9
                                                      Table E-12 (Continued)
Pollutant of Concern
Industry Raw
Wastewater Pollutant
Loading (Ibs/yr)
Industry Baseline
Wastewater Pollutant
Loading (Ibs/yr)
Industry
Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
Industry Pollutant
Removal from Baseline
(Ibs/yr)
Priority Organics (Continued)
Toluene
trans- 1 ,2-Dichloroethene
Trichloroethene
Total Priority Organics
123,062
3,308
2,991
932,009
65,145
3,308
2,929
673,848
45,834
3,308
2,929
457,889
19,311
0
0
215,959
Nonconventional Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pentanone
ซ-Terpineol
Benzoic Acid
Benzyl Alcohol
Hexanoic Acid
w-Xylene
w-Decane
w-Docosane
w-Dodecane
w-Eicosane
w-Hexacosane
w-Hexadecane
w-Octacosane
w-Octadecane
w-Tetracosane
42,112
14,503
205,792
19,822
13,649
70,709
72,258
8,037
23,401
1,034,766
21,738
286,670
227,062
26,081
141,149
13,754
107,779
27,843
36,490
11,262
137,556
15,687
11,504
68,136
70,980
8,033
17,418
663,185
16,466
183,028
143,083
15,821
86,604
9,903
70,187
22,677
36,490
9,731
137,160
15,573
11,482
67,346
70,980
8,033
16,380
374,463
6,771
52,010
14,825
4,763
27,522
3,360
14,946
9,633
0
1,531
396
114
23
790
0
0
1,038
288,722
9,696
131,018
128,258
11,058
59,082
6,544
55,240
13,044
w

-------
                                                                                                      Appendix E - Tables Referenced in Chapter 9
                                                      Table E-12 (Continued)
Pollutant of Concern
Industry Raw
Wastewater Pollutant
Loading (Ibs/yr)
Industry Baseline
Wastewater Pollutant
Loading (Ibs/yr)
Industry
Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
Industry Pollutant
Removal from Baseline
(Ibs/yr)
Nonconventional Organics (Continued)
w-Tetradecane
w-Triacontane
o-&/>-Xylene
/>-Cresol
/>-Cymene
Pentamethy Ibenzene
Total Nonconventional Organics
175,284
18,046
14,372
0
70,799
0
2,635,625
110,160
14,928
10,933
0
51,855
0
1,775,897
24,295
7,266
10,696
0
19,359
0
943,083
85,866
7,662
237
0
32,496
0
832,814
Priority Metals and Elements
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
Total Priority Metals and Elements
30,321
13,354
39
6,258
21,450
178,395
107,160
195
17,116
406
4,915
0
238,137
617,745
27,540
12,972
39
5,281
15,133
131,381
72,288
181
15,148
400
4,494
0
197,065
481,921
19,407
12,972
39
3,583
11,119
89,281
33,345
154
10,689
400
4,035
0
112,070
297,093
8,132
0
0
1,699
4,014
42,100
38,943
27
4,459
0
459
0
84,995
184,828
w

-------
                                                                                                                    Appendix E - Tables Referenced in Chapter 9
                                                              Table E-12 (Continued)
Pollutant of Concern
Industry Raw
Wastewater Pollutant
Loading (Ibs/yr)
Industry Baseline
Wastewater Pollutant
Loading (Ibs/yr)
Industry
Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
Industry Pollutant
Removal from Baseline
(Ibs/yr)
Nonconventional Metals and Elements
Aluminum
Barium
Boron
Cobalt
Iron
Manganese
Molybdenum
Tin
Titanium
Vanadium
Yttrium
Total Nonconventional Metals and Elements
814,053
93,127
35,769
5,791
1,483,962
30,237
12,939
6,658
20,135
2,153
808
2,505,633
726,162
71,175
34,572
4,879
1,263,722
25,012
9,423
5,799
17,597
2,024
777
2,161,142
486,090
42,786
34,111
3,678
610,539
12,899
8,734
4,903
9,069
1,778
735
1,215,322
240,072
28,389
460
1,201
653,182
12,114
690
897
8,528
245
42
945,820
Bulk Nonconventionals
Chemical Oxygen Demand (COD)
Total Organic Carbon (TOC)
Total Petroleum Hydrocarbon (measured as
SGT-HEM)3
330,306,526
86,738,604
22,604,163
256,658,823
77,640,746
12,851,536
179,662,938
72,361,602
2,653,006
76,995,885
5,279,144
10,198,530
w
-U
oo
      'Numbers in this table were calculated using more significant figures than shown.
      2136 of the 1,742 total industrial laundries are excluded from compliance under this criterion.
      3SGT-HEM is measured by Method 1664 (promulgated at 64 FR 26315; May 14, 1999). In this method, EPA defines SGT-HEM as non-polar matenal (NPM).
      Throughout this document and the Industrial Laundries Administrative Record, EPA refers to SGT-HEM as total petroleum hydrocarbon (TPH).

      HEM - Hexane extractable material.
      SGT-HEM - Silica gel treated-hexane extractable material.

-------
                                                                                  Appendix E - Tables Referenced in Chapter 9
                                                 Table E-13
      Summary of Pollutant Loadings and Removals from Industrial Laundry Wastewater for CP-IL1 Excluding
  Facilities with Less than 3 Million Pounds per Year Total Production and Less than 120,000 Pounds per Year Shop
                                      and Printer Towel/Rag Production2
Pollutant of Concern
Industry Raw
Wastewater Pollutant
Loading (Ibs/yr)
Industry Baseline
Wastewater Pollutant
Loading (Ibs/yr)
Industry
Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
Industry Pollutant
Removal from Baseline
(Ibs/yr)
Conventionals
Biochemical Oxygen Demand 5-Day (BOD5)
Oil and Grease (measured as HEM)
Total Suspended Solids (TSS)
115,964,420
60,754,967
73,909,767
104,120,680
35,269,760
56,330,170
95,859,747
14,441,421
29,835,581
8,260,933
20,828,339
26,494,589
Priority Organics
1,1,1 -Trichloroethane
1 ,2-Diphenylhydrazine
4-Chloro-3-methylphenol
Bis(2-ethylhexyl) Phthalate
Butyl Benzyl Phthalate
Chlorobenzene
Chloroform
Di-w-butyl Phthalate
Di-w-octyl Phthalate
Ethylbenzene
Isophorone
Methylene Chloride
Naphthalene
Phenol
Tetrachloroethene
55,767
0
10,066
187,452
46,704
2,897
127,024
26,257
16,650
69,708
44,243
33,436
69,883
11,878
62,141
40,464
0
8,850
132,825
37,307
2,334
122,751
15,102
12,588
34,107
43,507
26,294
38,379
11,872
37,725
21,771
0
3,084
75,404
12,546
1,582
122,530
4,507
9,410
10,354
21,043
10,235
17,820
11,871
24,074
18,694
0
5,766
57,420
24,761
753
221
10,595
3,178
23,753
22,464
16,059
20,559
1
13,650
w

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                                                      Table E-13 (Continued)
                                                                                                       Appendix E - Tables Referenced in Chapter 9
Pollutant of Concern
Industry Raw
Wastewater Pollutant
Loading (Ibs/yr)
Industry Baseline
Wastewater Pollutant
Loading (Ibs/yr)
Industry
Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
Industry Pollutant
Removal from Baseline
(Ibs/yr)
Priority Organics (Continued)
Toluene
trans- 1 ,2-Dichloroethene
Trichloroethene
Total Priority Organics
119,592
3,146
2,882
889,726
61,674
3,146
2,820
631,744
47,706
3,146
1,634
398,718
13,968
0
1,186
233,026
Nonconventional Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pentanone
ซ-Terpineol
Benzoic Acid
Benzyl Alcohol
Hexanoic Acid
w-Xylene
w-Decane
w-Docosane
w-Dodecane
w-Eicosane
w-Hexacosane
w-Hexadecane
w-Octacosane
w-Octadecane
w-Tetracosane
39,572
13,425
199,924
18,786
13,053
65,777
67,918
7,312
22,228
995,988
20,009
269,195
211,886
24,606
133,345
12,727
100,441
25,812
33,983
10,198
131,729
14,651
10,908
63,203
66,640
7,312
16,244
624,681
14,748
165,833
128,002
14,359
78,869
8,887
62,912
20,654
32,042
2,809
79,572
14,651
7,153
63,203
48,148
7,306
13,392
332,492
5,537
112,032
11,687
3,996
22,975
3,577
11,169
8,464
1,942
7,389
52,157
0
3,755
0
18,492
5
2,853
292,189
9,212
53,801
116,315
10,363
55,894
5,311
51,743
12,190
w
I

-------
                                                      Table E-13 (Continued)
                                                                                                      Appendix E - Tables Referenced in Chapter 9
Pollutant of Concern
Industry Raw
Wastewater Pollutant
Loading (Ibs/yr)
Industry Baseline
Wastewater Pollutant
Loading (Ibs/yr)
Industry
Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
Industry Pollutant
Removal from Baseline
(Ibs/yr)
Nonconventional Organics (Continued)
w-Tetradecane
w-Triacontane
o-&/>-Xylene
p-Creso\
p-Cymene
Pentamethy Ibenzene
Total Nonconventional Organics
164,472
16,864
13,709
0
68,867
0
2,505,916
99,447
13,750
10,270
0
49,931
0
1,647,212
20,406
7,045
9,084
0
14,211
0
830,949
79,041
6,705
1,186
0
35,720
0
816,263
Priority Metals and Elements
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
Total Priority Metals and Elements
27,861
12,849
34
5,861
20,386
168,218
101,327
184
15,939
357
4,671
0
219,505
577,192
25,088
12,470
34
4,886
14,070
121,275
66,481
170
13,973
352
4,250
0
178,466
441,515
16,613
12,457
32
2,886
8,606
67,715
25,349
151
9,914
215
3,224
0
62,860
210,022
8,475
14
2
2,000
5,464
53,560
41,131
19
4,059
137
1,026
0
115,606
231,493
w

-------
                                                              Table E-13 (Continued)
                                                                                                                     Appendix E - Tables Referenced in Chapter 9
Pollutant of Concern
Industry Raw
Wastewater Pollutant
Loading (Ibs/yr)
Industry Baseline
Wastewater Pollutant
Loading (Ibs/yr)
Industry
Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
Industry Pollutant
Removal from Baseline
(Ibs/yr)
Nonconventional Metals and Elements
Aluminum
Barium
Boron
Cobalt
Iron
Manganese
Molybdenum
Tin
Titanium
Vanadium
Yttrium
Total Nonconventional Metals and Elements
756,848
88,202
33,439
5,506
1,363,427
28,206
12,496
5,990
18,595
2,018
768
2,315,497
669,275
66,280
32,242
4,594
1,143,483
22,988
8,980
5,133
16,066
1,890
737
1,971,667
459,847
46,738
30,466
2,540
495,084
12,027
8,949
2,238
10,776
1,684
726
1,071,075
209,428
19,542
1,776
2,054
648,399
10,961
30
2,895
5,290
205
11
900,592
Bulk Nonconventionals
Chemical Oxygen Demand (COD)
Total Organic Carbon (TOC)
Total Petroleum Hydrocarbon (measured as
SGT-HEM)3
309,627,671
82,060,078
21,514,802
236,114,575
72,968,740
11,766,277
179,609,548
67,073,873
2,195,097
56,505,027
5,894,867
9,571,180
w
I
(^
to
       'Numbers in this table were calculated using more significant figures than shown.
       2518 of the 1,742 total industrial laundries are excluded from compliance under this criterion.  This exclusion includes the 136 facilities excluded under the 1
       Million/255K exclusion shown in Table E-l 1.
       3SGT-HEM is measured by Method 1664 (promulgated at 64 FR 26315; May  14,  1999). In this method, EPA defines SGT-HEM as non-polar matenal (NPM).
       Throughout this document and the Industrial Laundries Administrative Record, EPA refers to SGT-HEM as total petroleum hydrocarbon (TPH).

       HEM - Hexane extractable material.
       SGT-HEM - Silica gel treated-hexane extractable material.

-------
                                                                                  Appendix E - Tables Referenced in Chapter 9
                                                 Table E-14
          Summary of Pollutant Loadings and Removals from Industrial Laundry Wastewater for DAF-IL1
  Excluding Facilities with Less than 3 Million Pounds per Year Total Production and Less than 120,000 Pounds per
                                 Year Shop and Printer Towel/Rag Production2
Pollutant of Concern
Industry Raw
Wastewater Pollutant
Loading (Ibs/yr)
Industry Baseline
Wastewater Pollutant
Loading (Ibs/yr)
Industry
Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
Industry Pollutant
Removal from Baseline
(Ibs/yr)
Conventionals
Biochemical Oxygen Demand 5-Day (BOD5)
Oil and Grease (measured as HEM)
Total Suspended Solids (TSS)
115,964,420
60,754,967
73,909,767
104,120,680
35,269,760
56,330,170
99,172,611
15,052,637
27,935,334
4,948,069
20,217,122
28,394,836
Priority Organics
1,1,1 -Trichloroethane
1 ,2-Diphenylhydrazine
4-Chloro-3-methylphenol
Bis(2-ethylhexyl) Phthalate
Butyl Benzyl Phthalate
Chlorobenzene
Chloroform
Di-w-butyl Phthalate
Di-w-octyl Phthalate
Ethylbenzene
Isophorone
Methylene Chloride
Naphthalene
Phenol
Tetrachloroethene
55,767
0
10,066
187,452
46,704
2,897
127,024
26,257
16,650
69,708
44,243
33,436
69,883
11,878
62,141
40,464
0
8,867
132,825
37,307
2,334
122,751
15,102
12,588
34,107
43,507
26,294
38,379
11,872
37,725
2,255
0
8,229
80,421
23,856
1,493
122,746
10,939
9,058
5,031
43,507
24,944
18,987
11,865
17,821
38,210
0
621
52,404
13,451
841
5
4,163
3,530
29,076
0
1,349
19,392
7
19,904
w

-------
                                                                                                      Appendix E - Tables Referenced in Chapter 9
                                                      Table E-14 (Continued)
Pollutant of Concern
Industry Raw
Wastewater Pollutant
Loading (Ibs/yr)
Industry Baseline
Wastewater Pollutant
Loading (Ibs/yr)
Industry
Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
Industry Pollutant
Removal from Baseline
(Ibs/yr)
Priority Organics (Continued)
Toluene
trans- 1 ,2-Dichloroethene
Trichloroethene
Total Priority Organics
119,592
3,146
2,882
889,726
61,674
3,146
2,820
631,744
42,501
3,146
2,820
429,619
19,173
0
0
202,126
Nonconventional Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pentanone
ซ-Terpineol
Benzoic Acid
Benzyl Alcohol
Hexanoic Acid
w-Xylene
w-Decane
w-Docosane
w-Dodecane
w-Eicosane
w-Hexacosane
w-Hexadecane
w-Octacosane
w-Octadecane
w-Tetracosane
39,572
13,425
199,924
18,786
13,053
65,777
67,918
7,312
22,228
995,988
20,009
269,195
211,886
24,606
133,345
12,727
100,441
25,812
33,983
10,198
131,729
14,651
10,908
63,203
66,640
7,312
16,244
624,681
14,748
165,833
128,002
14,359
78,869
8,887
62,912
20,654
33,983
8,683
131,334
14,537
10,885
62,413
66,640
7,312
15,206
357,429
6,345
48,770
13,916
4,438
25,876
3,162
13,862
9,114
0
1,515
396
114
23
790
0
0
1,038
267,251
8,403
117,063
114,086
9,921
52,992
5,726
49,051
11,540
w

-------
                                                                                                      Appendix E - Tables Referenced in Chapter 9
                                                      Table E-14 (Continued)
Pollutant of Concern
Industry Raw
Wastewater Pollutant
Loading (Ibs/yr)
Industry Baseline
Wastewater Pollutant
Loading (Ibs/yr)
Industry
Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
Industry Pollutant
Removal from Baseline
(Ibs/yr)
Nonconventional Organics (Continued)
w-Tetradecane
w-Triacontane
o-&/>-Xylene
/>-Cresol
/>-Cymene
Pentamethy Ibenzene
Total Nonconventional Organics
164,472
16,864
13,709
0
68,867
0
2,505,916
99,447
13,750
10,270
0
49,931
0
1,647,212
22,833
6,929
10,033
0
18,155
0
891,855
76,614
6,821
237
0
31,776
0
755,357
Priority Metals and Elements
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
Total Priority Metals and Elements
27,861
12,849
34
5,861
20,386
168,218
101,327
184
15,939
357
4,671
0
219,505
577,192
25,088
12,470
34
4,886
14,070
121,275
66,481
170
13,973
352
4,250
0
178,466
441,515
18,264
12,470
34
3,342
10,171
82,192
30,729
146
9,979
352
3,793
0
101,143
272,614
6,824
0
0
1,544
3,898
39,082
35,752
24
3,994
0
457
0
77,323
168,901
w

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                                                                                                                     Appendix E - Tables Referenced in Chapter 9
                                                              Table E-14 (Continued)
Pollutant of Concern
Industry Raw
Wastewater Pollutant
Loading (Ibs/yr)
Industry Baseline
Wastewater Pollutant
Loading (Ibs/yr)
Industry
Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
Industry Pollutant
Removal from Baseline
(Ibs/yr)
Nonconventional Metals and Elements
Aluminum
Barium
Boron
Cobalt
Iron
Manganese
Molybdenum
Tin
Titanium
Vanadium
Yttrium
Total Nonconventional Metals and Elements
756,848
88,202
33,439
5,506
1,363,427
28,206
12,496
5,990
18,595
2,018
768
2,315,497
669,275
66,280
32,242
4,594
1,143,483
22,988
8,980
5,133
16,066
1,890
737
1,971,667
458,327
40,820
31,782
3,397
566,093
12,167
8,290
4,255
8,665
1,659
696
1,136,150
210,948
25,460
460
1,198
577,390
10,821
690
878
7,400
231
41
835,517
Bulk Nonconventionals
Chemical Oxygen Demand (COD)
Total Organic Carbon (TOC)
Total Petroleum Hydrocarbon (measured as
SGT-HEM)3
309,627,671
82,060,078
21,514,802
236,114,575
72,968,740
11,766,277
165,442,212
67,714,343
2,446,918
70,672,363
5,254,397
9,319,359
w
       'Numbers in this table were calculated using more significant figures than shown.
       2518 of the 1,742 total industrial laundries are excluded from compliance under this criterion.  This exclusion includes the 136 facilities excluded under the 1
       Million/255K exclusion shown in Table E-12.
       3SGT-HEM is measured by Method 1664 (promulgated at 64 FR 26315; May 14, 1999).  In this method, EPA defines SGT-HEM as non-polar material (NPM).
       Throughout this document and the Industrial Laundries Administrative Record, EPA refers to SGT-HEM as total petroleum hydrocarbon (TPH).

       HEM - Hexane extractable material.
       SGT-HEM - Silica gel treated-hexane extractable material.

-------
                                                                                  Appendix E - Tables Referenced in Chapter 9
                                                 Table E-15
          Summary of Pollutant Loadings and Removals from Industrial Laundry Wastewater for CP-IL1
   Excluded Facilities with Less than 5 Million Pounds per Year Total Production and Less than 255,000 Pounds per
                                 Year Shop and Printer Towel/Rag Production2
Pollutant of Concern
Industry Raw
Wastewater Pollutant
Loading (Ibs/yr)
Industry Baseline
Wastewater Pollutant
Loading (Ibs/yr)
Industry
Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
Industry Pollutant
Removal from Baseline
(Ibs/yr)
Conventionals
Biochemical Oxygen Demand 5-Day (BOD5)
Oil and Grease (measured as HEM)
Total Suspended Solids (TSS)
99,192,358
53,740,259
61,877,538
87,450,551
28,563,674
44,708,381
79,935,733
12,089,837
24,186,232
7,514,818
16,473,837
20,522,150
Priority Organics
1,1,1 -Trichloroethane
1 ,2-Diphenylhydrazine
4-Chloro-3-methylphenol
Bis(2-ethylhexyl) Phthalate
Butyl Benzyl Phthalate
Chlorobenzene
Chloroform
Di-w-butyl Phthalate
Di-w-octyl Phthalate
Ethylbenzene
Isophorone
Methylene Chloride
Naphthalene
Phenol
Tetrachloroethene
48,625
0
8,056
161,531
41,313
2,615
109,927
23,258
14,324
62,226
37,412
28,625
62,534
9,991
54,652
33,432
0
6,888
107,755
32,124
2,053
105,870
12,228
10,317
26,947
36,677
21,649
31,341
9,985
30,356
15,838
0
2,122
64,163
10,699
1,320
105,654
3,762
7,673
6,884
14,969
7,229
14,635
9,985
17,410
17,593
0
4,766
43,592
21,425
733
216
8,465
2,644
20,064
21,708
14,420
16,706
1
12,945
w

-------
                                                       Table E-15 (Continued)
                                                                                                       Appendix E - Tables Referenced in Chapter 9
Pollutant of Concern
Industry Raw
Wastewater Pollutant
Loading (Ibs/yr)
Industry Baseline
Wastewater Pollutant
Loading (Ibs/yr)
Industry
Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
Industry Pollutant
Removal from Baseline
(Ibs/yr)
Priority Organics (Continued)
Toluene
trans- 1 ,2-Dichloroethene
Trichloroethene
Total Priority Organics
108,899
2,793
2,605
779,386
51,118
2,793
2,543
524,074
38,492
2,793
1,375
325,002
12,626
0
1,168
199,072
Nonconventional Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pentanone
ซ-Terpineol
Benzoic Acid
Benzyl Alcohol
Hexanoic Acid
w-Xylene
w-Decane
w-Docosane
w-Dodecane
w-Eicosane
w-Hexacosane
w-Hexadecane
w-Octacosane
w-Octadecane
w-Tetracosane
34,293
11,207
181,455
16,476
11,481
54,993
57,962
5,762
19,580
883,722
16,395
231,406
181,967
21,259
115,783
10,598
85,626
21,409
28,704
8,074
113,260
12,341
9,354
52,420
56,807
5,762
13,596
517,127
11,271
128,980
99,826
11,166
62,162
6,844
48,883
16,413
26,763
2,277
64,625
12,341
5,750
52,420
38,730
5,757
10,891
285,672
4,633
81,131
9,894
3,280
19,295
2,858
9,244
7,146
1,942
5,798
48,634
0
3,604
0
18,077
5
2,706
231,455
6,638
47,849
89,933
7,885
42,867
3,987
39,639
9,267
w
I

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                                                      Table E-15 (Continued)
                                                                                                      Appendix E - Tables Referenced in Chapter 9
Pollutant of Concern
Industry Raw
Wastewater Pollutant
Loading (Ibs/yr)
Industry Baseline
Wastewater Pollutant
Loading (Ibs/yr)
Industry
Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
Industry Pollutant
Removal from Baseline
(Ibs/yr)
Nonconventional Organics (Continued)
w-Tetradecane
w-Triacontane
o-&/>-Xylene
p-Creso\
p-Cymene
Pentamethy Ibenzene
Total Nonconventional Organics
141,678
14,145
12,155
0
62,378
0
2,191,730
77,866
11,128
8,716
0
43,735
0
1,344,436
17,101
5,916
7,570
0
12,143
0
685,436
60,765
5,212
1,146
0
31,593
0
659,000
Priority Metals and Elements
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
Total Priority Metals and Elements
22,340
11,063
26
4,950
17,660
143,842
87,767
154
13,210
268
4,002
0
180,941
486,220
19,694
10,704
26
4,002
11,402
97,610
53,467
141
11,300
264
3,591
0
141,259
353,460
13,900
10,691
24
2,393
6,840
55,004
20,616
126
8,050
151
2,685
0
50,361
170,841
5,794
13
2
1,608
4,562
42,605
32,851
15
3,251
114
906
0
90,897
182,618
w

-------
                                                              Table E-15 (Continued)
                                                                                                                    Appendix E - Tables Referenced in Chapter 9
Pollutant of Concern
Industry Raw
Wastewater Pollutant
Loading (Ibs/yr)
Industry Baseline
Wastewater Pollutant
Loading (Ibs/yr)
Industry
Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
Industry Pollutant
Removal from Baseline
(Ibs/yr)
Nonconventional Metals and Elements
Aluminum
Barium
Boron
Cobalt
Iron
Manganese
Molybdenum
Tin
Titanium
Vanadium
Yttrium
Total Nonconventional Metals and Elements
622,122
75,689
28,138
4,807
1,107,535
23,557
11,154
4,719
15,094
1,682
651
1,895,150
537,651
54,111
26,941
3,907
895,613
18,489
7,642
3,893
12,641
1,556
621
1,563,066
379,438
38,159
25,173
1,970
404,754
9,966
7,614
1,552
8,672
1,375
612
879,286
158,214
15,952
1,767
1,936
490,858
8,523
28
2,341
3,969
181
10
683,780
Bulk Nonconventionals
Chemical Oxygen Demand (COD)
Total Organic Carbon (TOC)
Total Petroleum Hydrocarbon (measured as
SGT-HEM)3
262,258,089
69,718,257
18,965,925
189,588,950
60,704,055
9,349,866
140,233,731
55,307,428
1,763,841
49,355,219
5,396,627
7,586,025
w
ON
O
      'Numbers in this table were calculated using more significant figures than shown.
      2953 of the 1,742 total industrial laundries are excluded from compliance under this criterion.
      3SGT-HEM is measured by Method 1664 (promulgated at 64 FR 26315; May 14, 1999). In this method, EPA defines SGT-HEM as non-polar material (NPM).
      Throughout this document and the Industrial Laundries Administrative Record, EPA refers to SGT-HEM as total petroleum hydrocarbon (TPH).

      HEM - Hexane extractable material.
      SGT-HEM - Silica gel treated-hexane extractable material.

-------
                                                                                  Appendix E - Tables Referenced in Chapter 9
                                                 Table E-16
          Summary of Pollutant Loadings and Removals from Industrial Laundry Wastewater for DAF-IL1
  Excluding Facilities with Less than 5 Million Pounds per Year Total Production and Less than 255,000 Pounds per
                                 Year Shop and Printer Towel/Rag Production2
Pollutant of Concern
Industry Raw
Wastewater Pollutant
Loading (Ibs/yr)
Industry Baseline
Wastewater Pollutant
Loading (Ibs/yr)
Industry
Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
Industry Pollutant
Removal from Baseline
(Ibs/yr)
Conventionals
Biochemical Oxygen Demand 5-Day (BOD5)
Oil and Grease (measured as HEM)
Total Suspended Solids (TSS)
99,192,358
53,740,259
61,877,538
87,450,551
28,563,674
44,708,381
82,919,296
12,491,092
22,990,267
4,531,255
16,072,582
21,718,114
Priority Organics
1,1,1 -Trichloroethane
1 ,2-Diphenylhydrazine
4-Chloro-3-methylphenol
Bis(2-ethylhexyl) Phthalate
Butyl Benzyl Phthalate
Chlorobenzene
Chloroform
Di-w-butyl Phthalate
Di-w-octyl Phthalate
Ethylbenzene
Isophorone
Methylene Chloride
Naphthalene
Phenol
Tetrachloroethene
48,625
0
8,056
161,531
41,313
2,615
109,927
23,258
14,324
62,226
37,412
28,625
62,534
9,991
54,652
33,432
0
6,888
107,755
32,124
2,053
105,870
12,228
10,317
26,947
36,677
21,649
31,341
9,985
30,356
1,719
0
6,290
67,470
19,564
1,236
105,865
8,654
7,451
3,533
36,677
20,359
15,414
9,978
12,418
31,712
0
598
40,286
12,560
817
5
3,574
2,866
23,414
0
1,290
15,927
7
17,937
w

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                                                      Table E-16 (Continued)
                                                                                                      Appendix E - Tables Referenced in Chapter 9
Pollutant of Concern
Industry Raw
Wastewater Pollutant
Loading (Ibs/yr)
Industry Baseline
Wastewater Pollutant
Loading (Ibs/yr)
Industry
Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
Industry Pollutant
Removal from Baseline
(Ibs/yr)
Priority Organics (Continued)
Toluene
trans- 1 ,2-Dichloroethene
Trichloroethene
Total Priority Organics
108,899
2,793
2,605
779,386
51,118
2,793
2,543
524,074
33,985
2,793
2,543
355,948
17,132
0
0
168,127
Nonconventional Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pentanone
ซ-Terpineol
Benzoic Acid
Benzyl Alcohol
Hexanoic Acid
w-Xylene
w-Decane
w-Docosane
w-Dodecane
w-Eicosane
w-Hexacosane
w-Hexadecane
w-Octacosane
w-Octadecane
w-Tetracosane
34,293
11,207
181,455
16,476
11,481
54,993
57,962
5,762
19,580
883,722
16,395
231,406
181,967
21,259
115,783
10,598
85,626
21,409
28,704
8,074
113,260
12,341
9,354
52,420
56,807
5,762
13,596
517,127
11,271
128,980
99,826
11,166
62,162
6,844
48,883
16,413
28,704
6,721
112,864
12,227
9,331
51,630
56,807
5,762
12,597
302,042
5,173
39,205
11,384
3,576
21,226
2,597
11,063
7,574
0
1,354
395
114
23
790
0
0
999
215,085
6,098
89,775
88,442
7,590
40,936
4,247
37,820
8,839
w

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to

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                                                      Table E-16 (Continued)
                                                                                                      Appendix E - Tables Referenced in Chapter 9
Pollutant of Concern
Industry Raw
Wastewater Pollutant
Loading (Ibs/yr)
Industry Baseline
Wastewater Pollutant
Loading (Ibs/yr)
Industry
Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
Industry Pollutant
Removal from Baseline
(Ibs/yr)
Nonconventional Organics (Continued)
w-Tetradecane
w-Triacontane
o-&/>-Xylene
p-Creso\
p-Cymene
Pentamethy Ibenzene
Total Nonconventional Organics
141,678
14,145
12,155
0
62,378
0
2,191,730
77,866
11,128
8,716
0
43,735
0
1,344,436
18,716
5,843
8,480
0
14,814
0
748,338
59,149
5,284
237
0
28,922
0
596,098
Priority Metals and Elements
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
Total Priority Metals and Elements
22,340
11,063
26
4,950
17,660
143,842
87,767
154
13,210
268
4,002
0
180,941
486,220
19,694
10,704
26
4,002
11,402
97,610
53,467
141
11,300
264
3,591
0
141,259
353,460
15,002
10,704
26
2,699
7,964
65,063
24,289
123
8,094
264
3,153
0
76,854
214,235
4,692
0
0
1,303
3,438
32,547
29,178
18
3,206
0
438
0
64,405
139,225
w

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                                                              Table E-16 (Continued)
                                                                                                                    Appendix E - Tables Referenced in Chapter 9
Pollutant of Concern
Industry Raw
Wastewater Pollutant
Loading (Ibs/yr)
Industry Baseline
Wastewater Pollutant
Loading (Ibs/yr)
Industry
Postcompliance
Wastewater Pollutant
Loading (Ibs/yr)
Industry Pollutant
Removal from Baseline
(Ibs/yr)
Nonconventional Metals and Elements
Aluminum
Barium
Boron
Cobalt
Iron
Manganese
Molybdenum
Tin
Titanium
Vanadium
Yttrium
Total Nonconventional Metals and Elements
622,122
75,689
28,138
4,807
1,107,535
23,557
11,154
4,719
15,094
1,682
651
1,895,150
537,651
54,111
26,941
3,907
895,613
18,489
7,642
3,893
12,641
1,556
621
1,563,066
378,481
34,436
26,481
2,752
452,699
10,057
7,003
3,089
7,330
1,354
584
924,266
159,170
19,675
460
1,155
442,913
8,432
639
805
5,312
202
37
638,800
Bulk Nonconventionals
Chemical Oxygen Demand (COD)
Total Organic Carbon (TOC)
Total Petroleum Hydrocarbon (measured as
SGT-HEM)3
262,258,089
69,718,257
18,965,925
189,588,950
60,704,055
9,349,866
130,590,755
55,892,337
1,935,173
58,998,195
4,811,719
7,414,694
w
      'Numbers in this table were calculated using more significant figures than shown.
      2953 of the 1,742 total industrial laundries are excluded from compliance under this criterion.
      3SGT-HEM is measured by Method 1664 (promulgated at 64 FR 26315; May 14, 1999). In this method, EPA defines SGT-HEM as non-polar material (NPM).
      Throughout this document and the Industrial Laundries Administrative Record, EPA refers to SGT-HEM as total petroleum hydrocarbon (TPH).

      HEM - Hexane extractable material.
      SGT-HEM - Silica gel treated-hexane extractable material.

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