&EPA
United States
Environmental Protection
Agency
Office of Water
(4303) i
EPA821-R-97-007
November 1997
Technical Development Document
for Proposed Pretreatment
Standards for Existing and New
Sources for the Industrial
Laundries Point Source Category
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TECHNICAL DEVELOPMENT DOCUMENT FOR
PROPOSED PRETREATMENT STANDARDS
FOR EXISTING AND NEW SOURCES
FOR THE
INDUSTRIAL LAUNDRIES POINT SOURCE CATEGORY
Carol M. Browner
Administrator '.
Robert Perciasepe
Administrator, Office of Water
Sheila Frace
Acting 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
November 7, 1997 ;
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ACKNOWLEDGEMENT AND DISCLAIMER
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. (Contract No. 68-C5-0032), under the direction and
review of the Office of Science and Technology. Neither, the United States Government nor
any of its employees, contractors, subcontractors, or their employees make any warrant,
expressed or implied, or assume any legal liability or responsibility for any third party's use
of or the results of such use of any information, apparatus, product, or process discussed in
this report, or represents that its use by such party would not infringe on privately owned
rights.
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FOREWORD
This document delineates the development of the proposed pretreatment
standards for the Industrial Laundries Point Source Category. 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 16 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
BACKGROUND 1-1
1.1 Introduction ; 1-1
1.2 Legal Authority 1-1
1.3 Background ' 1-1
1.3.1 Clean Water Act . 1-1
1.3.2 Pollution Prevention Act (PPA) 1-4
1.3.3 Regulatory Flexibility Act (RFA) as
Amended by the Small Business
Regulatory Enforcement Fairness
Act of 1996 (SBREFA) 1-4
1.3.4 Prior Regulation of the Industrial
Laundries Point Source Category 1-5
SUMMARY \ 2-1
2.1 Introduction ; 2-1
2.2 Overview of the Industrial Laundries
Industry .; 2-1
2.3 Scope of the Proposed Regulation 2-2
2.4 Exclusion 2-3
2.5 Pretreatment Standards for Existing Sources
(PSES) 2-3
2.6 Pretreatment Standards for New Sources
(PSNS) '. 2-3
2.7 Effluent Limitations Guidelines for Direct
Dischargers 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
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TABLE OF CONTENTS (Continued)
CHAPTER 4
Page
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 Since 1992 3-6
3.3.1 Screener Questionnaires 3-6
3.3.2 1994 Industrial Laundries Industry—
Questionnaire (Detailed
Questionnaire) 3-9
3.3.3 Detailed Monitoring Questionnaire 3-12
3.4 Summary of EPA's Site Visit Program
(1993-1997) 3-13
3.4.1 Criteria for Site Visit Selection 3-13
3.4.2 Types of Information Collected 3-14
3.5 Summary of EPA's Sampling Program
(1993-1996) 3-14
3.5.1 Criteria for Sampling Site Selection 3-14
3.5.2 Information Collected 3-15
3.5.3 Sample Collection and Analysis 3-15
3.6 Other Industry-Supplied Data 3-16
3.7 POTW Data 3-17
3.8 Summary of Literature Searches 3-18
3.9 Summary of Other Data Sources 3-20
3.9.1 Risk Reduction Engineering
Laboratory Treatability Database 3-20
3.9.2 Fate of Priority Pollutants in
Publicly Owned Treatment Works
Database 3-20
3.9.3 The Domestic Sewage Study 3-21
3.9.4 Canadian Studies 3-21
3.9.5 Industrial Pollution Prevention
Project 3-22
3.10 References 3-22
INDUSTRY PROFILE 4-1
4.1 Introduction 4_1
n
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TABLE OF CONTENTS (Continued)
CHAPTER 5
: Page
4.2 Overview of the Industry . .; 4-1
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 4-8
4.2.5 Customers 4-8
4.3 Laundering Processes 4-15
4.3.1 Water-Using/Wastewater-
Generating Processes 4-15
4.3.2 Non-Water-Using/Non-Wastewater-
Generating Processes 4-17
4.3.3 Chemicals Used in Industrial
Laundries 4-19
4.4 Facilities and Equipment . 4-22
4.4.1 Washers, Extractors, and Washer-
Extractors 4-22
4.4.2 Tunnel Washers 4-24
4.4.3 Dry-Cleaning Units .: 4-24
4.4.4 Equipment Use and Age 4-24
4.5 Pollution Prevention Activities 4-24
4.6 Trends in the Industry 4-29
4.6.1 Trend Away from Dry Cleaning 4-29
4.6.2 Trend of Small Facilities Being Purchased by
Larger Firms .....; 4-29
4.6.3 Trends in Equipment and Technologies 4-30
4.7 Treatment Technologies hi Use 4-30
4.8 References 4-30
WATER USE AND WASTEWATER CHARACTERIZATION 5-1
5.1 Introduction 5-1
5.2 Sources of Service Water anid Water Use 5-1
5.2.1 Sources of Service Water at
Industrial Laundries 5-1
5.2.2 Use of Service Water at Industrial
Laundries 5-2
5.3 Wastewater Volume by Type of Discharge 5-6
5.4 Water Conservation Measures 5-11
in
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TABLE OF CONTENTS (Continued)
CHAPTER 6
CHAPTER 7
Page
5.5 Characterization of Raw Wastewater by
Item Laundered 3_H
5.6 Characterization of Total, Heavy, and Light
Raw Wastewater Streams 5-11
INDUSTRY SCOPE AND SUBCATEGORIZATION 6-1
6.1 Introduction 6-1
6.2 Regulatory Background 6-1
6.3 Industry Scope 6-2
6.4 Subcategorization Analysis 6-7
6.4.1 Disproportionate Economic Impacts 6-7
6.4.2 Laundry Processes and Water Use
Practices 6-8
6.4.3 Plant Age 6-8
6.4.4 Plant Location 6-8
6.4.5 Plant Size 6-9
6.4.6 Raw Materials 6-10
6.4.7 Non-water Quality Environmental
Impacts 6-10
6.4.8 Type of Item Laundered and
Wastewater Characteristics 6-10
6.5 References 6-11
POLLUTANTS SELECTED FOR REGULATION 7-1
7.1 Introduction 7_1
7.2 Pollutants Considered for Regulation 7-1
7.3 Identification of Pollutants of Concern 7-4
7.4 Pollutants Selected for Regulation 7-10
7.4.1 Elimination of Parameters that
Comprise TPH 7-16
7.4.2 Elimination of Treatment
Chemicals 7_16
7.4.3 Elimination of Pollutants Not
Treated or Below Treatable
Concentrations 7-16
7.4.4 Elimination of Pollutants that Do
Not Pass Through or Otherwise
Interfere with POTWs 7-18
IV
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TABLE OF CONTENTS (Continued)
CHAPTER 8
\ Page
7.4.5 Selection of Regulated Pollutants 7-30
7.5 References i 7-36
POLLUTION PREVENTION, RECYCLING, TREATMENT,
AND DISPOSAL TECHNOLOGIES EMPLOYED BY THE
INDUSTRIAL LAUNDRIES INDUSTRY 8-1
8.1 Introduction l 8-1
8.2 The Environmental Management Hierarchy 8-1
8.3 Pollution Prevention/Source Reduction in
the Industrial Laundries Industry 8-3
8.3.1 Preprocess Pollution Prevention
Activities 8-4
8.3.2 In-Process Pollution Prevention
Activities 8-7
8.4 Pollution Recycling/Resource Conservation
and the Industrial Laundries Regulatory
Development Process 8-11
8.4.1 Wastewater Conservation in the
Industrial Laundries Industry 8-12
8.4.2 Energy Conservation in the
Industrial Laundries Industry 8-12
8.5 Wastewater Treatment Technologies in the
Industrial Laundries Industry; • • • 8-12
8.5.1 Gravity Settling 8-13
8.5.2 Stream Splitting 8-15
8.5.3 Screening ; 8-16
8.5.4 Equalization 8-18
8.5.5 Chemical Emulsion Breaking 8-19
8.5.6 Chemical Precipitation • 8-23
8.5.7 Dissolved Air Flotation (DAF) 8-25
8.5.8 Sludge Dewatering 8-29
8.5.9 pH Adjustment ...... 8-33
8.5.10 Ultrafiltration/Microfiltration 8-34
8.5.11 Centrifugation 8-34
8.5.12 Volatile Organic Compound (VOC)
Removal Technologies 8-35
8.5.13 Oil/Water Separation 8-38
8.5.14 Media Filtration 8-39
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TABLE OF CONTENTS (Continued)
CHAPTER 9
Page
8.6 Pollution Disposal Practices in the
Industrial Laundries Industry 3.39
8.7 References g_40
TREATMENT PERFORMANCE DATA USED FOR THE
DEVELOPMENT OF LONG-TERM AVERAGES,
VARIABILITY FACTORS, AND STANDARDS 9-1
9.1 Introduction 9_1
9.2 Sources of Treatment Technology
Performance Data From Well-Designed and
Well-Operated Treatment Systems 9.2
9.2.1 Industrial Laundry Sampling
Program Data 9_2
9.2.2 Detailed Monitoring Questionnaire
(DMQ) Data 9.4
9.3 Evaluation of Treatment Performance Data 9.5
9.3.1 Assessment of Treatment System
Performance and Identification of
Process Upsets 9.5
9.3.2 Identification of Pollutants Not
Treated by the Treatment
Technology 9.5
9.3.3 Identification of Pollutants Not
Present in Influent Samples at
Sufficient Concentrations to
Evaluate Treatment Effectiveness 9.7
9.3.4 Identification of Treatment
Performance Data With Inconsistent
Detection Limits 9.7
9.3.5 Identification of Data Considered a
Lower Limit of the Actual Value 9.7
9.4 Long-Term Average Concentrations for the
Pollutants of Concern 9.7
9.5 Long-Term Average Concentrations,
Variability Factors, and Standards for the
Pollutants Proposed for Regulation 9.3
9.6 Identification of Data Used to Calculate the
Long-Term Average Concentrations for the
Prelaundering Technology Group 9.25
VI
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TABLE OF CONTENTS (Continued)
Page
9.7 Mass-Based Standards : . . . 9-26
9.8 References ; 9-26
CHAPTER 10 DEVELOPMENT OF REGULATORY OPTIONS 10-1
10.1 Introduction ; 10-1
10.2 Pretreatment Standards for Existing Sources
(PSES) 10-1
10.2.1 Initial Technology Options
Considered 10-1
10.2.2 Inclusion of Pollution Prevention in
the Technology Options 10-12
10.2.3 Exclusion of Wastewater Recycling
Activities from the Technology
Options 10-12
10.2.4 Initial Technology Options Not
Further Considered . 10-13
10.2.5 Additional Technology Options
Considered ; 10-13
10.2.6 Technology Options Eliminated
from Further Consideration 10-16
10.2.7 Regulatory Options Further
Considered for PSES 10-17
10.3 Pretreatment Standards for New Sources
(PSNS) 10-17
10.4 References 10-18
CHAPTER 11 POLLUTANT LOADING AND REMOVAL ESTIMATES . . 11-1
11.1 Introduction ; 11-1
11.2 Data Sources 11-2
11.3 Methodology Used to Estimate Pollutant
Loadings and Removals 11-3
11.3.1 Methodology Used to Estimate
Untreated Pollutant Loadings 11-4
11.3.2 Methodology Used to Estimate
Baseline and Postcompliance
Wastewater Loadings 11-7
11.3.3 Methodology Used to Estimate
Pollutant Removals 11-12
vn
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TABLE OF CONTENTS (Continued)
Page
11.4 Pollutant Loadings and Removals 11-17
CHAPTER 12 COSTS OF TECHNOLOGY BASES FOR REGULATIONS . 12-1
12.1 Introduction 12-1
12.2 Costing Methodology 12-2
12.2.1 Cost Model Development and
Structure 12-4
12.2.2 Components of the Cost of
Compliance 12-5
12.2.3 Treatment-in-Place Credit
Methodology 12-11
12.3 Cost Modeling 12-14
12.3.1 Cost Model Driver 12-14
12.3.2 Stream Splitting 12-15
12.3.3 Pumps 12-16
12.3.4 Screening 12-18
12.3.5 Equalization 12-19
12.3.6 Dissolved Air Flotation 12-20
12.3.7 Chemical Precipitation 12-22
12.3.8 Sludge Dewatermg 12-24
12.3.9 pH Adjustment 12-26
12.3.10 Treatment System Building 12-27
12.3.11 Contact Haul In Lieu of
Treatment 12-28
12.3.12 Compliance Monitoring 12-29
12.4 Engineering Costs by Regulatory Option 12-30
12.5 References 12-30
CHAPTER 13 REGULATORY OPTIONS SELECTION 13-1
13.1 Introduction 13-1
13.2 Regulatory Options Considered 13-1
13.2.1 Pretreatment Standards for Existing
Sources (PSES) 13-1
13.2.2 Pretreatment Standards for New
Sources (PSNS) 13-2
13.3 Final Regulatory Options Selection 13-3
13.3.1 Pretreatment Standards for Existing
Sources (PSES) 13-3
Vlll
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TABLE OF CONTENTS (Continued)
Page
13.3.2 Pretreatment Standards for New
Sources (PSNS) , 13-4
13.3.3 Direct Dischargers 13-4
CHAPTER 14 NON-WATER QUALITY ENVIRONMENTAL IMPACTS . . 14-1
14.1 Introduction 14-1
14.2 Non-Water Quality Environmental Impacts
of the CP-IL and DAF-IL Regulatory
Options Considered as the Basis for PSES 14-1
14.2.1 Energy Consumption Impacts 14-2
14.2.2 Air Emissions Impacts, 14-2
14.2.3 Solid Waste Impacts , 14-9
14.3 Non-Water Quality Environmental Impacts
of the Regulatory Options Considered for
PSNS ' 14-11
14.4 References ; 14-11
CHAPTER 15 PRETREATMENT STANDARDS FOR EXISTING SOURCES
(PSES) AND PRETREATMENT STANDARDS FOR NEW
SOURCES (PSNS) 15-1
15.1 Introduction 15-1
15.2 Summary of the Proposed PSES and PSNS 15-2
15.2.1 Regulated Facilities .' 15-2
15.2.2 POTW Pass-Through Analysis 15-2
15.2.3 Regulated Pollutants 15-3
15.2.4 PSES and PSNS 15-3
15.3 Implementation of the PSES and PSNS 15-6
15.3.1 Point of Application 15-6
15.3.2 Permit Limitations 15-6
15.3.3 Monitoring and Compliance 15-11
15.4 References 15-11
CHAPTER 16 GLOSSARY OF TERMS 16-1
Appendix A - Tables Referenced in Chapter 3
Appendix B - Tables Referenced in Chapter 5 ;
Appendix C - Tables Referenced in Chapter 6 :
Appendix D - Tables Referenced in Chapter 7
IX
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LIST OF TABLES
Page
Table 2-1 Proposed PSES and PSNS for the Industrial Laundries Industry 2-4
Table 4-1 Geographic Distribution of Industrial Laundries by State and
Region 4.4
Table 4-2 Industrial Laundry Size Distribution 4-7
Table 4-3 Types of Items Laundered 4.9
Table 4-4 Typical Customers for Each Type of Item Laundered 4-11
Table 4-5 Laundering Processes Reported in the Detailed Questionnaire 4-16
Table 4-6 Industrial Laundering Wash Formula Chemicals Reported in the Detailed
Questionnaire 4_20
Table 4-7 Amounts of Detergent Added Per Pound of Laundry for Items
Most Often Laundered 4_21
Table 4-8 Age of Facilities and Start of Laundry/Dry-Cleaning Operations (Estimated
Percentage of Total Facilities in Each Time Period) 4-23
Table 4-9 Types of Laundry Processing Equipment Reported in the Detailed
Questionnaire 4_25
Table 4-10 Age of Laundry Processing Equipment Reported in the Detailed
Questionnaire (Percentage of Equipment Type Installed in Each Time
Period) 4_26
Table 4-11 Pre-Process Pollution Prevention Activities 4-27
Table 4-12 In-Process Pollution Prevention Activities 4-28
Table 5-1 Service Water Sources 5.3
Table 5-2 Service Water Use 5.4
Table 5-3 Item-Specific Water Use 5.7
Table 5-4 Discharge Practices of Industrial Laundries 5-9
Table 5-5 Water Conservation Practices and Water Use Reduction 5-12
Table 5-6 Wastewater Characterization for Item Specific Wastewater
at Industrial Laundries 5-13
Table 5-7 Wastewater Characterization Data for Heavy Wastewater Streams
at Industrial Laundries 5-20
Table 5-8 Wastewater Characterization Data for Light Wastewater Streams
at Industrial Laundries 5-23
Table 5-9 Wastewater Characterization Data for Total Raw Wastewater
Streams at Industrial Laundries 5-26
Table 6-1 Comparison of Linen Facility and Industrial Laundry Facility Mean
Pollutant Log Concentrations 6-4
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LIST OF TABLES (Continued)
Page
Table 6-2 Comparison of Linen Facility and Denim Prewash Facility Mean Pollutant
Log Concentrations 6-5
Table 7-1 Pollutants Not Detected in Any Samples Analyzed during the
1993-1996 Industrial Laundries Sampling Program 7-5
Table 7-2 Pollutants Detected in Less Than 10 Percent of Samples
Analyzed During the 1993-1996 Industrial Laundries Sampling
Program 7-8
Table 7-3 Semiquantitative Metal and Elemental Pollutants Excluded from
the Pollutants of Concern for the Industrial Laundries Industry 7-9
Table 7-4 Average Influent Concentrations, Effluent Concentrations, and Removals
for Phosphorous and Surfactants ; 7-11
.Table 7-5 Pollutants of Concern for the Industrial Laundries Industry 7-12
Table 7-6 Pollutants Selected for Proposed Regulation in the Industrial
Laundries Industry ; 7-17
Table 7-7 Pollutants Eliminated from Consideration for Regulation for the Industrial
Laundries Industry for Chemical Precipitation Options 7-19
Table 7-8 Pollutants Eliminated from Consideration for Regulation for the Industrial
Laundries Industry for Dissolved Air Flotation Options 7-21
Table 7-9 Comparison of the Chemical Precipitation Treatment Technology
and POTW Percent Removals for the Industrial Laundries
Pass-Through Analysis 7-23
Table 7-10 Comparison of the DAF Treatment Technology and POTW
Percent Removals for the Industrial Laundries Pass-Through
Analysis , 7-25
Table 7-11 Generic Removal for n-Alkanes ; 7-31
Table 7-12 Pollutants Considered for Regulation for Chemical Precipitation
and DAF after the Pass-Through Analysis 7-32
Table 8-1 Number of Industrial Laundries, by Production Category, Reporting
Preprocess Pollution Prevention Activities in the Detailed Questionnaire . 8-5
Table 8-2 Types of Preprocess Pollution Prevention Activities Reported in
the Detailed Questionnaire 8-6
Table 8-3 Number of Industrial Laundries, by Production Category, Reporting
In-Process Pollution Prevention Activities in the Detailed
Questionnaire ; 8-8
Table 8-4 Types of In-Process Pollution Prevention Activities Reported in
the Detailed Questionnaire 8-9
Table 8-5 Number of Facilities Responding to Detailed Questionnaire Using
Wastewater Treatment Technologies 8-14
XI
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LIST OF TABLES (Continued)
Page
Table 9-1 Overall Long-Term Average (LTA) Concentrations for the Five
Postlaundering Treatment Technology Groups for the Pollutants
of Concern 9-9
Table 9-2 Episode Long-Term Average (LTA) Concentrations and
Variability Factors (VF) for Chemical Emulsion Breaking
Treatment of Heavy Wastewater for the Pollutants Proposed for
Regulation 9-13
Table 9-3 Summary of Long-Term Averages (LTA), Variability Factors (VF),
and Standards for Chemical Emulsion Breaking Treatment of Heavy
Wastewater 9-14
Table 9-4 Episode Long-Term Average (LTA) Concentrations and Variability
Factors (VF) for DAF Treatment of Heavy Wastewater for Pollutants
Proposed for Regulation 9-15
Table 9-5 Summary of Long-Term Averages (LTA), Variability Factors (VF),
and Standards for DAF Treatment of Heavy Wastewater 9-16
Table 9-6 Episode Long-Term Average (LTA) Concentrations and Variability
Factors (VF) for Chemical Precipitation Treatment of Heavy
Wastewater for the Pollutants Proposed for Regulation 9-17
Table 9-7 Summary of Long-Term Averages (LTA), Variability Factors (VF), and
Standards for Chemical Precipitation Treatment of Heavy Wastewater . . 9-18
Table 9-8 Episode Long-Term Average (LTA) Concentrations and Variability
Factors (VF) for DAF Treatment of All Facility Process Wastewater
for the Pollutants Proposed for Regulation 9-19
Table 9-9 Summary of Long-Term Averages (LTV), Variability Factors (VF), and
Standards for DAF Treatment of All Facility Process Wastewater 9-21
Table 9-10 Episode Long-Term Average (LTA) Concentrations and Variability
Factors (VF) for Chemical Precipitation Treatment of All Facility
Process Wastewater for the Pollutants Proposed for Regulation 9-22
Table 9-11 Summary of Long-Term Averages (LTA), Variability Factors (VF), and
Standards for Chemical Precipitation Treatment of All Facility Process
Wastewater 9-24
Table 9-12 Target Effluent Concentrations for Steam Tumbling of Heavy Items
Before Water Washing for the Pollutants of Concern 9-27
Table 10-1 Technology Options Initially Considered for the Industrial Laundries
Proposed Rule 10-2
Table 10-2 Definitions of Additional Technology Options Considered for PSES . . . 10-14
Table 11-1 Pollutant Loadings per Pound of Item Processed (mg Pollutant/lb Laundry)! 1-5
Table 11-2 Analytical Data Transfers 11-6
XII
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LIST OF TABLES (Continued)
Page
Table 11-3 Methodology Used to Estimate Baseline Loadings for the Industrial
Laundries Industry 11-8
Table 11-4 Target Average Concentrations for DAF-IL and CP-IL for the Pollutants
of Concern 11-9
Table 11-5 Methodology Used to Estimate Postcompliance Loadings for DAF-IL
for the Industrial Laundries Industry 11-13
Table 11-6 Methodology Used to Estimate Postcompliance Loadings for CP-IL
for the Industrial Laundries Industry . . . . i 11-14
Table 11-7 Methodology Used to Estimate Postcompliance Loadings for Combo-IL
for the Industrial Laundries Industry . . . .; 11-15
Table 11-8 Methodology Used to Estimate Postcompliance Loadings for
Combo-IL-2LIM for the Industrial Laundries Industry 11-16
Table 11-9 Summary of Pollutant Loadings and Removals for the Entire Industrial
Laundries Industry for OC-Only 11-18
Table 11-10 Summary of Pollutant Loadings and Removals for the Entire Industrial
Laundries Industry for DAF-IL ; 11-23
Table 11-11 Summary of Pollutant Loadings and Removals for the Entire Industrial
Laundries Industry for CP-IL i 11-28
Table 11-12 Summary of Pollutant Loadings and Removals for the Entire Industrial
Laundries Industry for Combo-IL i 11-33
Table 11-13 Summary of Pollutant Loadings and Removals for the Excluded
Industrial Laundries (141 Facilities) for OC-Only 11-38
Table 11-14 Summary of Pollutant Loadings and Removals for the Excluded
Industrial Laundries (141 Facilities) for DAF-IL 11-43
Table 11-15 Summary of Pollutant Loadings and Removals for the Excluded
Industrial Laundries (141 Facilities) for CP-IL 11-48
Table 11-16 Summary of Pollutant Loadings and Removals for the Excluded
Industrial Laundries (141 Facilities) for Combo-IL 11-53
Table 12-1 Operation and Maintenance Unit Costs Used by the Cost Model 12-7
Table 12-2 Capital Unit Costs Used by the Cost Model 12-9
Table 12-3 Components of Total Capital Investment 12-12
Table 12-4 Summary of PSES Engineering Costs 12-31
Table 12-5 Summary of PSES Annualized Engineering Costs for Industrial
Laundries Included in the Proposed Regulation 12-32
Table 14-1 Incremental Energy Increases Associated With Implementation of the
CP-IL and DAF-IL Regulatory Options 14-3
Table 14-2 Fugitive Air Emissions of Organic Pollutants From Industrial Laundry
Wastewater - Analysis of a Worst-Case Scenario 14-6
xm
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LIST OF TABLES (Continued)
Page
Table 14-3 Incremental Sludge Generation Increases Associated With Implementation
of the CP-IL and DAF-IL Regulatory Options 14-10
Table 15-1 Pollutants Proposed to be Regulated Under PSES and PSNS 15-4
Table 15-2 Proposed PSES and PSNS for the Industrial Laundries Industry 15-5
Table 15-3 Alternative Concentration-Based Limits for Example Facilities 15-9
Table 15-4 EPA-Approved Analytical Methods for Analyzing the Regulated
Pollutants 15-12
xiv
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LIST OF FIGURES
Page
Figure 4-1
Figure 5-1
Figure 5-2
Figure 8-1
Figure 8-2
Figure 8-3
Figure 8-4
Figure 8-5
Figure 8-6
Figure 8-7
Figure 8-8
Figure 8-9
Figure 8-10
Figure 10-1
Figure 10-2
Figure 10-3
Geographic Distribution of Industrial Laundry Facilities
Distribution of Facilities by Production Normalized Laundry Process
Water Use <
Distribution of Facilities by Production Normalized Laundry Process
Water Discharge <
Environmental Management Options Hierarchy
Shaker Screen
Batch Chemical Emulsion Breaking Unit . j
Continuous CEB Unit with Coalescing Plates
Batch Chemical Precipitation System . . . .!
Continuous Chemical Precipitation System '
Dissolved Air Flotation Unit
Rotary Vacuum Filter
Filter Press
Fixed Bed Activated Carbon Adsorption Column
CEB-Heavy Option: Chemical Emulsion Breaking of Heavy Industrial
Laundry Wastewater
DAF-Heavy, DAF-IL, and DAF-TWL Options: Dissolved Air Flotation
of a Portion of a Facility's Process Wastewater
CP-Heavy, CP-IL, and CP-TWL Options: Chemical Precipitation of a
Portion of a Facility's Process Wastewater
4-3
, 5-5
5-10
8-2
8-17
8-21
8-22
8-24
8-26
8-28
8-31
8-32
8-37
10-6
10-7
10-8
XV
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LIST OF FIGURES (Continued)
Page
Figure 10-4 DAF-A11 Option: Dissolved Air Flotation of Total Facility Process
Wastewater 10-9
Figure 10-5 CP-A11 Option: Chemical Precipitation of Total Facility Process
Wastewater 10-10
Figure 10-6 OC-Only Option: In-Process Organics Control 10-11
xvi
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Chapter 1 - Background
CHAPTER 1
BACKGROUND
1.1
Introduction
This chapter presents background information supporting the development of
effluent limitations guidelines and standards for the Industrial Laundries Point Source
Category. Section 1.2 presents the legal authority to regulate the industrial laundries industry.
Section 1.3 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.
1.2
Legal Authority
This regulation for the Industrial Laundries Point Source Category is being
proposed 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 segu, as
amended by the Clean Water Act of 1977, Pub. L. 95-217, and the Water Quality Act of
1987, Pub. L. 100-4), also referred to as "the CWA" or "the Act."
1.3
1.3.1
Background
Clean Water Act
The Federal Water Pollution Control Act Amendments of 1972 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
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3.
Chapter 1 - Background
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 uniformly inadequate, BPT may be transferred from a
different subcategory or category.
Best Available Technology Economically Achievable (BATl (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.
Best Conventional Pollutant Control Technology (BCT) (section
304(a)(4) of the Act).
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, f American Paper Institute
v- EPA, 660 F.2d 954 (4th Cir. 1981)]. EPA's current methodology for
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Chapter 1 - Background
the general development of BCT limitations was issued in 1986 (51 FR
24974; July 9, 1986).
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, 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.
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 Xct 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 and thus a need for categorical standards 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.
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).
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1.3.2
Chapter 1 - Background
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.
Pollution Prevention Act (PPA)
In the Pollution Prevention Act of 1990 (42 U.S.C. 13101 et seq.. 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; pollution that cannot be prevented should be recycled or reused in an
environmentally safe manner wherever feasible; pollution 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)). This proposed regulation for the Industrial Laundries Point Source
Category was reviewed for its incorporation of pollution prevention as part of EPA's effort.
Chapter 8 of this document describes the results of this effort.
1.3.3
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 SBREFA, EPA generally is required to conduct an initial regulatory flexibility analysis
(IFRA) describing the impact of the proposed rule on small entities. Under section 605(b) of
the RFA, if the Administrator certifies that the rule will not have a significant impact on a
substantial number of small entities, EPA is not required to prepare the IFRA.
Although this proposed rule minimizes impacts on small businesses through an
exclusion, EPA conducted an IFRA pursuant to section 603(b) of the RFA addressing:
• The need for, objectives of, and legal basis for the rule.
• A description of, and where feasible, an estimate of the number of small
entities to which the rule would apply.
• The projected reporting, recordkeeping, and other compliance
requirements of the rule, including an estimate of the classes of small
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Chapter 1 - Background
entities that would be subject to the 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 the proposed rule.
• A description of any significant regulatory alternatives to the proposed
rule which accomplish the stated objectives of applicable statutes and
which minimize any significant economic impact of the proposed rule
on small entities. Consistent with the stated objectives of the CWA, the
analysis discusses 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 the rule, or any part thereof, for
such small entities. Based on, the IRFA and other factors, this
proposed rule incorporates an exclusion to eliminate
disproportionate impacts on small businesses and also reduces the
number of small businesses affected by the proposed rule.
Pursuant to the RFA as amended by SBREFA, EPA convened a Small Business
Advocacy Review Panel. The Panel is comprised of 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 RFA, and
collected the advice and recommendations of small entity representatives. For this proposed
rule, the small entity representatives included owners of small industrial laundries and trade
association representatives. The Panel prepared a report (available in the administrative
record for this rulemaking) that summarizes their outreach to small entities and the comments
submitted by the small entity representatives. The Panel's1 report also presents their findings
on issues related to the elements of an IRFA. ;
1.3.4
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
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Chapter 1 - Background
1976 settlement agreement and subsequently 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.
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 (screening and verification study). However, in 1982,
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,
the Agency 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 fNRDC et al. v. Reillv. 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
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1 Chapter 1 - Background
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 most
recent Effluent Guidelines Plan update was published on February 26, 1997 (62 FR 8726).
This plan requires, 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.
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Chapter 2 - Summary
CHAPTER 2
SUMMARY
2.1
Introduction
The proposed regulations for the industrial laundries industry include
pretreatment standards for the control of wastewater pollutants. This chapter presents a
summary of the proposed rule. Section 2.2 presents a brief overview of the industry, Section
2.3 discusses the scope of the proposed rule, Section 2.4 describes the proposed exclusion to
the rule, and Sections 2.5 through 2.7 summarize the proposed pretreatment standards and
effluent limitations guidelines.
2.2
Overview of the Industrial Laundries Industry
The industrial laundries industry includes facilities that launder or dry clean
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
facilities covered by the proposed rule also wash other items not classified as industrial
laundry items, such as linen supply garments, linen flatwork, health-care items, and
miscellaneous other items.
Industrial laundry facilities are located hi 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 IV. Most of the laundering facilities are
situated in large urban areas. EPA estimates that there are 1,747 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 corresponding
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 launder most items using water washing. Water washing involves
washing items in water. Some facilities launder items using dry cleaning, 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.
When water washing and dry cleaning are performed hi 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
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Chapter 2 - Summary
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.
Facilities water-wash nearly 97 percent of their items using a standard process.
Approximately one percent of laundered items are dry-cleaned, including some 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).
Based on data collected by EPA for this rulemaking, 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. Chemicals
frequently used in industrial laundry operations include alkaline solutions, detergents, bleach,
antichlor, sours, softeners, and starch. A variety of other items that are added to some wash
formulas include enzymes, builders, oil treatment chemicals, water conditioners, dyes, stain
treatment chemicals, and bactericides. The primary pollutants discharged by industrial
laundries are all of the conventional pollutants except fecal coliform (oil and grease,
biochemical oxygen demand (BOD5), and total suspended solids (TSS)), 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. All of the industrial laundries identified by EPA discharge their process wastewater
to publicly owned treatment works (POTWs).
2.3
Scope of the Proposed Regulation
The proposed pretreatment standards apply to process wastewater discharges
from new and existing industrial laundries. EPA is proposing 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 laundered textile items. This definition
includes textile rental companies that perform laundering operations. Laundering means
washing with water, including water washing following dry cleaning. This rule would not
apply to laundering exclusively through dry cleaning. Industrial textile items include, but are
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, filters, and clean room items. If any of these items are used for hotels, hospitals, or
restaurants, they are not industrial items.
The proposed rule would not apply to discharges from on-site laundering at
industrial facilities, laundering of industrial textile items originating from the same business
entity, and facilities that exclusively launder linen items, denim prewash items, new items
(i.e., items directly from the textile manufacturer, not yet used for their intended purpose),
any other laundering of hotel, hospital, or restaurant items, or any combination of these items.
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Chapter 2 - Summary
This proposed rule would apply to hotel, hospital, or restaurant laundering of industrial textile
items. In addition, this rule would not apply to discharges from the oil-only treatment of
mops. Linen items include sheets, pillowcases, 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 (this list is meant to be all-inclusive).
For facilities covered under the industrial laundry definition, wastewater from
all water-washing operations would be covered, including the washing of linen items, as long
as these items do not constitute 100 percent of the items washed.
2.4
Exclusion
Under Pretreatment Standards for Existing Sources (PSES), EPA is proposing
to exclude existing facilities that launder less than one million pounds of incoming laundry
per calendar year and less than 255,000 pounds of shop and/or printer towels/rags per
calendar year. EPA proposes this exclusion to eliminate the unacceptable economic impacts
on these smaller facilities. The excluded facilities would be disproportionately adversely
impacted relative to all facilities covered by this rule. Most of the excluded facilities are
small entities under the Small Business Administration (SBA) definition of small entity. The
excluded facilities account for less than three percent of the pollutant removals from U.S.
waters than would occur if the rule were implemented without the exclusion.
Under Pretreatment Standards for New Sources (PSNS), EPA is proposing no
exclusions for new sources since the economic projections indicate that there would be no
barrier to entry as a result of the proposed new source standards.
2.5
Pretreatment Standards for Existing Sources (PSES)
EPA is proposing PSES numerical limitations based on chemical precipitation
technology treatment of industrial laundry wastewater for 1.1 priority and nonconventional
pollutants. The pretreatment standards are applicable to all process wastewater discharged by
facilities that are within the scope of the rule. Industrial laundries laundering less than one
million pounds per year of industrial laundry and less than 255,000 pounds per year of shop
and/or printer towels/rags are excluded from regulation under PSES. PSES are presented in
Table 2-1. ;
2.6
Pretreatment Standards for New Sources fPSNS)
EPA is proposing PSNS based on chemical precipitation of industrial laundry
wastewater for 11 priority and nonconventional pollutants. ; The new source standards are
applicable to all process wastewater discharged by industrial laundries that meet the definition
of a new source. PSNS are presented in Table 2-1.
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Chapter 2 - Summary
Table 2-1
Proposed PSES and PSNS for the Industrial Laundries Industry
Pollutant or Poltatent Property
Copper
Lead
Zinc
Bis(2-ethylhexyl) Phthalate
Ethylbenzene
Naphthalene
Tetrachloroethene
Toluene
m-Xylene2
o-&p-Xylene2
TPH (as SGT-HEM)3
Proposed PSES and PSNS for fcnd-of-Pipe Monitoring Points
Maximum for any 1 day
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Chapter 2 - Summary
2.7
Effluent Limitations Guidelines for Direct Dischargers
EPA has not identified any direct dischargers in the industrial laundries
industry or any candidate indirect dischargers, or transfer of performance data from facilities
in other industries or from pilot-scale test results for determining the appropriate level of
performance to set limitations for direct discharging new sources; therefore, EPA has not
developed effluent limitations guidelines for direct wastewater discharges to surface waters.
As a result, the Agency is reserving effluent limitations guidelines and standards for the
following levels of control for the Industrial Laundries Point Source Category: Best
Practicable Control Technology Currently Available (BPT), Best Conventional Pollutant
Control Technology (BCT), Best Available Technology Economically Achievable (BAT), and
New Source Performance Standards (NSPS).
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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 industry. EPA collected information necessary for the development of this rule
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 and applicability of the
regulation. Throughout this chapter, the term "laundry" is; used to indicate that information
was collected from industrial laundries as well as other laundry facilities. The scope and
applicability of the proposed regulation are discussed in detail in Chapter 6.
This chapter summarizes the information collection activities undertaken and
the information sources used for this proposed rulemakingj as follows:
• Section 3.2 summarizes data collection efforts prior to 1992;
• Section 3.3 discusses the questionnaire activities conducted since 1992;
• Section 3.4 summarizes EPA's site visit program conducted from 1993
through 1997;
• Section 3.5 discusses EPA's sampling program conducted from 1993
through 1996;
• Section 3.6 presents other industry-collected data efforts;
• Section 3.7 discusses data collected from publicly owned treatment
works (POTWs); !
• Section 3.8 summarizes literature searches performed on the industrial
laundries industry;
• Section 3.9 summarizes other sources of data on the industrial laundries
industry; and
• Section 3.10 presents the references used in this section.
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Chapter 3 - Data Collection Methodology and Information Sources
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 studying 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 collected sampling data
for conventional and nonconventional pollutants and some metals at a small number of
facilities.
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 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
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Chapter 3 - Data Collection Methodology and Information Sources
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 i
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 Consent Decree (see Section 1.3.4 for discussion of the Consent Decree), in wastewaters
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Chapter 3 - Data Collection Methodology and Information Sources
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 influent and effluent. EPA also sampled an industrial laundry using a dissolved air
flotation (DAF) treatment system over a one-month period to obtain data on the variability of
this type of treatment system.
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.
In 1981, EPA chose not to establish effluent limitations for the Auto and Other
Laundry Point Source Category, of which industrial laundries was 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
Chapter 3 - Data Collection Methodology and Information Sources
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
3.9.3). :
At the industrial laundry sampled in 1985, EPA collected composite samples of
the final effluent after a settling basin over the course of one operating day. EPA collected
wastewater samples from untreated wastewater streams and final effluent wastewater streams
at the four other industrial laundry facilities. EPA sampled these four facilities for two
consecutive days and composited the wastewater over thei course of each operating day. EPA
collected final effluent samples from two dissolved air flotation systems, one ultrafiltration
system, and a settling basin. ,
EPA analyzed the samples for conventional pollutants, priority and
nonconventional organic pollutants, priority and nonconventional metal pollutants, and other
nonconventional pollutants, which later comprised the "ITD List of Analytes".
Other sources of 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 this time period was used to prepare the Preliminary Data
Summary for the Industrial Laundries Industry (1) and formed the basis for EPA's decision to
develop effluent limitations guidelines and standards for the Industrial Laundries Point Source
Category. ;
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3.3
Chapter 3 - Data Collection Methodology and Information Sources
Summary of Industrial Laundries Questionnaire Activity Since 1992
EPA's first step in developing the current proposed 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 sent four screener questionnaires to different segments of
the laundry industry between 1993 and 1995 to collect information to be used in identifying
the population of the laundry industry, developing the scope of the 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 sent a detailed questionnaire to a subset of identified laundry facilities. Based
on the responses to the detailed questionnaire, EPA sent a monitoring questionnaire to a
subset of the facilities that had received a detailed questionnaire. These data-gathering efforts
are described in more detail below. Additional details on the data-gathering efforts are found
in the Statistical Support Document for Proposed Pretreatment Standards for Existing and
New Sources for the Industrial Laundries Point Source Category (2). Copies of
nonconfidential questionnaires are contained in the administrative record for this rulemaking.
3.3.1
Screener Questionnaires
EPA conducted four separate mailings of slightly different screener
questionnaires to develop the scope of the regulation, 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 that 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 8 of this document. The four different screener questionnaires and their
mailings are discussed in the following sections.
The 1993 Industrial Laundries Industry Screener Questionnaire
In 1993, EPA developed and mailed out the two-page 1993 Industrial
Laundries Industry Screener Questionnaire to a large number of industrial laundries to solicit
updated information on the industry. The purpose of this screener questionnaire was to
characterize the industry and to determine which facilities may be in-scope for the proposed
rule. 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 administrative record for this rulemaking.
EPA sent the screener questionnaire to a total of 1,751 facilities. EPA selected
1,745 of these facilities from the UTS A 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
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Chapter 3 - D'ata Collection Methodology and Information Sources
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 mailout of the screener
questionnaires is shown in the following table. '.
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 then-
parent company.
*This 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.
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.
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Chapter 3 - Data Collection Methodology and Information Sources
Status of 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.
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 was used to determine the industrial laundry industry population.
1995 Industrial Laundries Industry Screener 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
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 UTSA;
• Responses to Question 25 (Q25) in Part B of the Industrial Laundries
Detailed 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
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Chapter 3 - D.ata Collection Methodology and Information Sources
accepted from off site and its annual production, 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 proposed regulations. Of
the 100 screener questionnaires mailed, EPA received 86 responses.
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 laundry facilities selected from the
1993 Industrial Laundries Industry Screener Questionnaire database (screener questionnaire
database) and from the Dun & Bradstreet database. EPA used the information reported by the
respondents in the detailed questionnaire to develop an industry profile, characterize industry
production and water use, develop pollutant loadings and reduction estimates, and develop
compliance cost estimates, as discussed throughout this document. A blank copy of the
detailed questionnaire, along with copies of the nonconfidential portions of the completed
detailed questionnaires, are contained in the administrative record for this rulemaking.
Detailed Questionnaire Recipient Selection and Mailing
EPA mailed the detailed questionnaire in June and July 1994 to 250 selected
laundry facilities. 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 develop the proposed rule.
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. :
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Chapter 3 - Data Collection Methodology and Information Sources
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 1994. EPA received eight pretest questionnaire
responses.
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 tirade associations (TRSA and UTSA), EPA's Office of Pollution Prevention and
Toxics, and EPA's Office of Solid Waste to collect information necessary to develop effluent
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.
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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 disposal, and space availability at the facility. EPA used this information to evaluate
current treatment in place at industrial laundries facilities 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 of Proposed Pretreatment Standards for Existing and New Sources for
the Industrial Laundries Point Source Category (4). ]
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. The
engineering review also included coding responses to questions 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.
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Compilation of Respondent Data
EPA compiled information reported in the detailed questionnaire and
summaries of this information are located in Chapters 4, 5, and 8 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 received the detailed questionnaire. 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 sampled;
• Facilities with paired monitoring data (i.e., facilities that monitor both
influent and effluent pollutant concentrations);
• At least one facility with each technology being considered for inclusion
in the regulatory options; and
• Facilities that had no treatment (or that have gravity settling and screens
only) to characterize industrial laundry raw wastewater.
The DMQ requested that facilities submit analytical data identified 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.
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 DMO 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
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Chapter 3 - Data Collection Methodology and Information Sources
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.
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 the standards for the industrial laundries industry, as
presented in Chapter 9 of this document and the Statistical Support Document (2).
3.4
Summary of EPA's Site Visit Program (1993-1997)
EPA conducted 32 site visits to industrial laundry facilities between 1993 and
1997 to collect information about industrial laundries 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). In general, EPA visited sites to encompass a range of industrial laundry facilities
and other facilities, such as linen facilities, hospital cooperative laundries, and denim prewash
facilities, to determine the scope of the regulation.
3.4.1
Criteria for Site Visit Selection
EPA based site selection on information hi responses to the screener and
detailed questionnaires. 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 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.
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Chapter 3 - Data Collection Methodology and Information Sources
3.4.2
Types of Information Collected
EPA documented information for each site visit in a site visit report. 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 (1993-1996)
EPA conducted sampling episodes at eight facilities between 1993 and 1996 to
obtain data on the characteristics of industrial laundry wastewaters and to assess the following:
the loading of pollutants to POTWs from industrial laundries; the effectiveness of technologies
designed to reduce and remove pollutants from industrial laundries 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 technology option development.
After selecting a site for sampling, EPA prepared a detailed sampling and
analysis plan, based on the information contained in the site visit report and follow-up
correspondence with the site contact. 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;
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Chapter 3 - Data Collection Methodology and Information Sources
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 for each sampled site; the sampling episode reports are contained hi the
administrative record for this rulemaking. The sampling episode reports also contain
preliminary technical analyses of treatment system performance.
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) and the Industrial Laundries Quality Assurance Project
Plan (QAPP). These documents are contained in the administrative record for this
rulemaking. :
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
five-day consecutive 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
QAPP, such as blanks and duplicate samples, to verify the precision and accuracy of sample
analyses.
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Chapter 3 - Data Collection Methodology and Information Sources
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 list the metal and organic pollutants, respectively, analyzed using these methods.
The laboratories analyzed oil and grease and total petroleum hydrocarbons (TPH) using the
proposed Method 1664 (11). Method 1664 measures oil and grease as hexane extractable
material (HEM) and measures TPH as silica gel treated-hexane extractable material (SGT-
HEM). Method 1664 measures a different fraction of oil and grease and TPH than is
measured by the currently approved methods, which use freon. Table A-3 in Appendix A
lists other parameters analyzed during the sampling program and the methods by which they
were analyzed (12, 13).
Quality control 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 an 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.
3.6
Other Industry-Supplied Data
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 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
maximal pollutant loadings. These are maximal 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 maximal 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
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Chapter 3 - data Collection Methodology and Information Sources
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 maximal 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 maximal
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. Unfortunately, several of the facilities sampled experienced difficulties with
then: treatment system during the sampling days. Also, the production normalized pollutant
loading levels were based on average production levels instead of actual production levels,
which were used in the first part of the study.
3.7
POTW Data
The Association of Metropolitan Sewerage Agencies (AMSA), in an effort to
assist EPA in collecting data for the development of effluent 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 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.);
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Chapter 3 - Data Collection Methodology and Information Sources
• 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);
• 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 can be found in
the administrative record for this rulemaking.
3.8
Summary of Literature Searches
EPA has conducted several searches of the open literature throughout the
development of this proposed regulation to provide information on the industrial laundries
industry. The sources searched have 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);
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Chapter 3 - Data Collection Methodology and Information Sources
• Lists of industrial laundries from various on-line searching methods
(1986); and
• POTW and State Water Quality Agency lists (1986).
EPA conducted other literature searches in 1993 to gather publicly available
information on the industrial laundries industry. EPA conducted one literature search to
obtain information about industrial laundries 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 search focused on the following topics: waste streams, waste
treatment technologies, operations, and costs of operation. The following databases were
searched:
Database
Water Resources Abstracts
Waternet
NTIS
COMPENDEX
ENVIRONLINE
Pollution Abstracts
Books in Print
LCMark
Textile Technology Digest
World Textiles
Description
Water resources topics
Index 'of the American Water Works
Association Publications
Government-sponsored research,
development, and engineering reports
and analysis
Engineering and technology applications
Environmental Sciences
Pollution control and research
Books in print, forthcoming books, and
books going out of print in the U.S.
Library of Congress catalogued
publications
Worldwide coverage of textiles and
related subjects
Textiles in areas of technology and
management
As part of the literature search, EPA identified three trade journals important hi
the industrial laundries industry: Textile Rental. Industrial Launderer. and Laundry News.
These journals provide up-to-date information on the industrial laundries industry. EPA has
conducted regular reviews of these journals during the development of this regulation.
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Chapter 3 - Data Collection Methodology and Information Sources
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).
3.9
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 industrial laundries rulemaking
are discussed below.
3.9.1
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,
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
percent removals of various pollutants.
3.9.2
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 (14), 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:
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Chapter 3 - Data Collection Methodology and Information Sources
* 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 percent removals of various pollutants.
3.9.3
The Domestic Sewage Study
In February 1986, EPA issued the Report to Congress on the Discharge of
Hazardous Wastes to Publicly Owned Treatment Works (15), referred to as the Domestic
Sewage Study (DSS). This report, which was based in part on the 50 POTW Study, revealed
a significant number of sites discharging pollutants to POTWs that are a threat to the
treatment capability of these POTWs and were not regulated by national categorical
pretreatment regulations. Among the unregulated sources were industrial laundries, which
tend 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 Point Source Category
3.9.4
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 laundries associations conducted a survey of Canadian industrial
laundries to assess the amount of oil and grease and other pollutants that were being
discharged into the sewer systems. The survey was conducted to obtain an overview of the
industrial laundries industry, the sources of contamination, and the treatment used to reduce
the pollutant loads to the 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
3-21
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Chapter 3 - Data Collection Methodology and Information Sources
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 comprises the following entities: Ontario
Ministry of Environment and Energy, Metro Toronto, 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.
3.9.5
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 included as part of the engineering studies in the
development of the proposed rule.
The Agency-wide efforts, called the Industrial Pollution Prevention Project
(IPS), 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 (16), 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 (17), and Pollution
Prevention at Industrial Laundries: A Collaborative Approach in Southern California (18).
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 the
proposed rule, a number of potential pollution prevention practices and technology
applications were identified. Section VI of the preamble to the proposed rule and Chapters 8
and 10 of this document discuss the pollution prevention technologies and practices and their
uses with respect to this proposed rule.
3.10
1.
References
U.S. Environmental Protection Agency. Preliminary Data Summary for the
Industrial Laundries Industry. EPA 440/1-89/103, September 1989.
3-22
-------
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
Chapter 3 - Data Collection Methodology and Information Sources
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.
U.S. Environmental Protection Agency. Information Collection Request.
Environmental Protection Agency 1994 Industrial Laundries Industry
Questionnaire. March 3, 1994.
U.S.
U.S. Environmental Protection Agency. Economic Assessment of Proposed
Pretreatment Standards for Existing and New Sources for the Industrial
Laundries Point Source Category. EPA-821-R-97-008, Washington, D.C.,
November 1997.
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, B.C.,
November 1997.
Eastern Research Group, Inc. Data Element Dictionary for the DMO Database.
Prepared for the U.S. Environmental Protection Agency, Office of Water,
Washington, D.C., November 1997.
U.S. Environmental Protection Agency. Sampling and Analysis Procedures for
Screening of Industrial Effluents for Priority Pollutants. April 1977.
U.S. Environmental Protection Agency. Method 1620 Draft - Metals by
Inductively Coupled Plasma Atomic Emission Spectroscopv and Atomic
Absorption Spectroscopv. September 1989.
U.S. Environmental Protection Agency. Method 1624 Revision C - Volatile
Organic Compounds by Isotope Dilution GCMS. 40 CFR 136, Appendix A,
June 1989.
U.S. Environmental Protection Agency. Method 1625 Revision C -
Semivolatile Organic Compounds by Isotope Dilution GCMS. 40 CFR 136,
Appendix A, June 1989. :
U.S. Environmental Protection Agency. Method 1664: N-Hexane Extractable
Material (HEM) and Silica Gel Treated N-Hexane Extractable Material (SGT-
HEM) by Extraction and Gravimetry (Oil and Grease and Total Petroleum
Hydrocarbons). EPA-821-B-94-004b, April 1995.
3-23
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12.
13.
14.
15.
16.
17.
18.
Chapter 3 - Data Collection Methodology and Information Sources
U.S. Environmental Protection Agency. Methods for Chemical Analysis of
Water and Wastes. EPA-800-4-79-020, Revised March 1983.
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.
U.S. Environmental Protection Agency. Fate of Priority Pollutants in Publicly
Owned Treatment Works. EPA 440/1-82/303, September 1982.
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.
U.S. Environmental Protection Agency. Industrial Pollution Prevention Project
(IP3VSummarv Report. EPA-820-R-95-007, July 1995.
U.S. Environmental Protection Agency. Pollution Prevention at Industrial
Laundries: Assessment Observations and Waste Reduction Options. EPA-820-
R-95-010, July 1995.
U.S. Environmental Protection Agency. Pollution Prevention at Industrial
Laundries: A Collaborative Approach in Southern California. EPA-820-R-95-
012, July 1995.
3-24
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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. Most
of the data presented in this chapter are from facility responses to the 1994 Industrial
Laundries Industry Detailed 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. EPA defined
193 of these facilities as being in scope (industry scope is discussed in detail in Chapter 6).
The percentages and number of facilities performing various processes discussed in this
section were estimated based on the responses from the 193 in-scope facilities, and then
extrapolated to represent the industry population of 1,747 facilities, using appropriate survey
weights. 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; and
• Section 4.8 presents the references used in this section.
4.2 Overview of the Industry
This section provides an overview of the industrial laundries industry. This
overview comprises general information pertaining to the industry, including geographic
location, SIC codes, facility size, types of items laundered, and customers.
4-1
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Chapter 4 - Industry Profile
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 were identified by trade association mailing lists. Only industrial laundries that
reported generating laundry process wastewater and discharged that 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 a smaller 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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4-3
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Chapter 4 - Industry Profile
Table 4-1
Geographic Distribution of Industrial
Laundries by State and Region
Region/State
Region I
Connecticut
Maine
Massachusetts
New Hampshire
Rhode Island
Vermont
Region H
New Jersey
New York
Puerto Rico
Region DDE
Delaware
District of Columbia
Maryland
Pennsylvania
Virginia
West Virginia
Region IV
Alabama
Florida
Georgia
Kentucky
Mississippi
Number of Facilities inJRegion/State*
55
11
4
29
6
4
1
72
19
51
2
1 10J !
I-
i 4
} 3
17
49
21
^
181
fSs «wv ,-
14
42
28
27
6
4-4
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Table 4-1 (Continued)
Chapter 4 - Industry Profile
Region/State
North Carolina
South Carolina
Tennessee
Region V
Illinois
Indiana
Michigan
Minnesota
Ohio
Wisconsin
Region VI
Arkansas
Louisiana
New Mexico
Oklahoma
Texas
Region VH
Iowa
Kansas
Missouri
Nebraska
Region VHI
Colorado
Montana
North Dakota
South Dakota
Utah
Number of Facilities in Region/State1
; 35
; 13
; 16
', 203
42
i 33
36
i 17
56
i 19
131
18
16
! 10
1 15
I 72
57
14
: 8
'. 24
11
i 36
; 16
i 3
: i
; 4
', 6
4-5
-------
Table 4-1 (Continued)
Chapter 4 - Industry Profile
Region/State
Wyoming
Region IX
Arizona
California
Guam
Hawaii
Nevada
Region X
Alaska
Idaho
Oregon
Washington
Number of Fa«iJitfe$ itt Region/State1
6
" * " ' 136 " ';
14
102
3
8
9
3^
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 discharged that v/astewater to a POTW.
4-6
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Chapter 4 - Industry Profile
Table 4-2
Industrial Laundry
Size Distribution
Production Category
Clbs/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
Percent age of Total
Number of Facilities
Reporting
Production Data
10
27
36
11 ;
8 ;
8 !
100
Total Estimated
Production for
this Category
ps/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
Estimates
Percentage of
Total
Production
<1
10
29
15
17
28
100
'Number of facilities is estimated based on the 193 in-scope facilities, extrapolated to represent the entire
industry.
Source: 1994 Industrial Laundries Industry Detailed Questionnaire
4-7
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Chapter 4 - Industry Profile
4.2.4
Items Laundered
As reported by the in-scope facilities, industrial laundries wash a variety of
items. The three primary categories 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.
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.
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.
4-8
-------
Table 4-3
Types of Items Laundered
Chapter 4 - Industry Profile
Item Type1
Industrial Garments (B01)
Shop Towels, Industrial Wipers, etc. (B02)
Printer 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 (Bl 1)
Clean Wipes (B12)
Other Items (B13)4
Laundry Bags (B 14)
Family Laundry (B15)
Absorbents (B16)
New Items (B17)
Executive Wear (B18)
Miscellaneous Not Our Goods (NOG) (B19)
Rewash Items (B20)
Airline Carpet and Seat Covers (B22)
Estimated
Number of
Facilities
Laundering Item
1,441 ;
1,332
480
1,644 i
1,400 ;
942 :
1,364 ;
648 ;
687 '
927
28 1
.
31 ,
28 ;
84 1
-
74
43
14 i
38 i
;
Estimated
Percentage
ofT*tal
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
-
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
-
4-9
-------
Chapter 4 - Industry Profile
Table 4-3 (Continued)
Item type1
Filters (B23)
Buffing Pads (B24)
Total
Estimated
Number at
Facilities
Laundering Item
7
6
-
Estimated
Percentage
of Total
Facilities
<1
<1
- •
Estimated
Percentage at
Total
Production2
<1
<1
100
The codes in parentheses are from the detailed questionnaire and were used in the questionnaire database.
^otal 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.
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.
Includes items not specified in detailed questionnaire responses.
Source: 1994 Industrial Laundries Industry Detailed Questionnaire
4-10
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Publishing and Printing Industries (C06)
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Industrial Metal, Machinery, and Equipment M:
Publishing and Printing Industries (C06)
Retail/Wholesale Stores (C12)
Miscellaneous Service Industries (CIS)
Agricultural Industry (C16)
Miscellaneous Manufacturing (C19)
......
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4-14
-------
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. (Chapter 6 discusses the scope
of the industry under this proposed regulation.) 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, 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.
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.
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
4-15
-------
Chapter 4 - Industry Profile
Table 4-5
Laundering Processes
Reported in the Detailed Questionnaire
Process
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) (A12)
Dust Control Mop Treatment - Water wash followed
by oil treatment applied outside wash wheel (A10)
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
-------
i Chapter 4 - Industry Profile
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.
Dual-Phase Processing
Some facilities combine the water-washing arid 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. !
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
Non-Water-Using/Non-Wastewater-Generating Processes
Several laundering processes generate little if any wastewater. Processes that
generate small amounts of wastewater include various methods of dry cleaning (charged
system, fresh soap added to each load, and no soap added). 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.
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
4-17
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Chapter 4 - Industoy Profile
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 hi 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
tranferred 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.
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.
4-18
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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;
• Bleach - to brighten the items;
• Antichlor - to remove excess bleach from the items;
• Sour - to reduce the pH of the water to prevent yellowing of the items;
• 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 pound 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.
4-19
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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
Mildcwcidc/Bactericide
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 i
(gal/yr)* !
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
Ob/yrJ*
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.
Quantities listed are additive, not inclusive.
2This category includes chemicals such as pH adjusters, lubricants, fabric coatings, emulsifiers, dispersants, and desizers.
Source: 1994 Industrial Laundries Industry Detailed Questionnaire
4-20
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Chapter 4 - Industry Profile
Table 4-7
Amounts of Detergent Added Per Pound of Laundry
for Items Most Often Laundered
iW
Industrial Garments (B01)
Shop Towels, Industrial Wipers, etc. (B02)
Printer Towels (B03)
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 (Bl 1)
Other (B13)
Laundry Bags (B14)
Family Laundry (B15)
New Items (B17)
Executive Wear (B18)
Miscellaneous NOG (not our goods) (B19)
Rewash Items (B20)
Filters (B23)
Buffing Pads (B24)
Average Gallons of
Detergent Added per Pound
oft^Hindry2 \
0.00166
0.0112
0.0237 !
0.000393 ;
0.00259
0.00223 i
0.00177
0.000575
0.00189
0.00123
0.00299 ;
0.000500
;
0.000667
0.000696
0.00136 :
0.00771 !
!
—
0.0489
Average Pounds of Betergexrt
Added per Pound of
Lamitlrj!'2
0.0235
0.0322
0.0355
0.00537
0.0213
0.0212
0.0228
0.00898
0.0230
0.0142
0.0123
—
0.0202
0.0124
0.00605
0.00865
—
0.0314
0.0486
—
'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. Quantities listed are additive, not inclusive.
Source: 1994 Industrial Laundries Industry Detailed Questionnaire
4-21
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Chapter 4 - Industry Profile
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 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 hi 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 deposited 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. The
equipment 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.
4-22
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Chapter 4 - Industry Profile
Table 4-8
Age of Facilities and Start 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 Starling Laundry
or Dry-cieaniiig
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. !
2Totals may not equal 100% due to rounding.
Source: 1994 Industrial Laundries Industry Detailed Questionnaire
4-23
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Chapter 4 - Industry Profile
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 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 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 Prevention Activities
Based on the detailed questionnaire responses, extrapolated to represent the
entire industry, 503 facilities have a written pollution prevention policy. Seven hundred forty
(740) facilities of the 1,747 extrapolated facilities conduct pollution prevention activities prior
to the laundering process (pre-process 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 pre-process and in-process pollution
prevention activities, respectively, reported in responses to the detailed questionnaire. Chapter
8 discusses these activities in greater detail. Although the detailed questionnaire specifically
requested that wastewater treatment and water reuse/reduction information not be reported in
4-24
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Chapter 4 - Industry Profile
Table 4-9
Types of Laundry Processing Equipment Reported in the Detailed
Questionnaire
Type of Equipment*
Washer-Extractors (D02)
Separate Washers (D01)
Separate Extractors (DOS)
Dry-Cleaning Units (D04)
Tunnel Washers (DOS)
Continuous Roll Towel (CRT) Washers (D07)
Closed-Loop Oil Washers (DOS)
Other (Unspecified) (D06)
Dip Tanks (D10)
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
95.47
42.20
42.36
14.40
2.23
2.00
1.98
<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 190 in-scope facilities that responded to
the question, extrapolated using appropriate survey weights to represent 1,743 facilities.
Source: 1994 Industrial Laundries Industry Detailed Questionnaire
4-25
-------
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4-26
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Chapter 4 - Industry Profile
Table 4-11
Pre-Process Pollution Prevention Activities
Activity
Items with Free Liquids Refused
Certain Items Refused
Miscellaneous Activities
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
60
37
4
1
9
<1
3
4
Percentages are estimated based on a total of 740 extrapolated facilities (responses of in-scope facilities that
reported pre-process pollution prevention activities).
Source: 1994 Industrial Laundries Industry Detailed Questionnaire
4-27
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Chapter 4 - Industry Profile
Table 4-12
In-Process Pollution Prevention Activities
Activity
Change in Laundering/Dry-Cleaning Chemicals
Used1
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 Activities
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 Nwmberaf
Facilities
Reporting In-Process
Activities1
28
23
17
10
31
10
9
5
5
1
1
Percentages are estimated based on the extrapolated responses of 473 extrapolated facilities (responses of in-
scope facilities that reported in-process pollution prevention activities).
Data for these specific in-process pollution prevention activities were specifically requested in the detailed
questionnaire.
Source: 1994 Industrial Laundries Industry Detailed Questionnaire
4-28
-------
Chapter 4 - Industry Profile
response to these 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 8).
Table 4-11 shows that the pre-process 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.
The detailed questionnaire requested data for five specific in-process pollution
prevention activities. Facilities were requested to report any additional in-process pollution
prevention 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. As shown in Table 4-12, the two most common in-
process pollution reduction activities were change in laundering/dry-cleaning chemicals used
and the use of a liquid injection system for wash chemical addition.
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
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. The
largest percentage (45%) of dry-cleaning units was purchased in the 1980s; only 39% 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
4-29
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Chapter 4 - Industry Profile
technologies, and the requirement of more professional management (1). 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 cleanroom 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 recent analysis showed that the largest five firms
control about 55 percent of the market (1).
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 pre-process 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, and the installation of more sophisticated
wastewater treatment systems. Chapter 8 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 8 discusses wastewater treatment
technologies used by the industry in greater detail.
4.8
1.
References
K. Koepper. "Don't Count Out More Public Company Acquisitions.'
Industrial Launderer. August 1997: page 24.
4-30
-------
5.1
Chapter 5 - Water Use and Wastewater Characterization
CHAPTER 5
WATER USE AND WASTEWATER CHARACTERIZATION
Introduction
This chapter discusses water use practices for the industrial laundries industry
and presents a raw wastewater characterization of item-specific and total wastewater streams
at industrial laundries. The water use data presented in this chapter are from the 193 in-scope
facilities responding to the 1994 Industrial Laundries Industry Detailed Questionnaire (in-
scope facilities are those that meet the definition of an industrial laundry as presented in
Chapter 6, regardless of annual production). Where appropriate, these data have been
extrapolated using statistically-derived survey weights to represent the entire industry.
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 the
industrial laundries industry;
• Section 5.5 discusses characterization of raw wastewater by item
laundered; and
• Section 5.6 discusses characterization of total, heavy, and light raw
wastewater streams.
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 iintake source of their service water.
5-1
-------
Chapter 5 - Water Use and Wastewater Characterization
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, 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.
Process water use 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.
5-2
-------
Chapter 5 - Water Use and Wastewater Characterization
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
i ;
174 •
0 :
1,747 ;
Estimated Percentage of
Total facilities By Sow**
90
<1
10
0
100
'Based on responses to the detailed questionnaire from the 193 in-scope facilities, extrapolated to represent the entire industrial laundries
industry.
Source: 1994 Industrial Laundries Industry Detailed Questionnaire ;
5-3
-------
Chapter 5 - Water Use and Wastewater Characterization
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 U«e
92.1
3.1
<1
1.8
<1
1.4
<1
<1
<1
<1
<1
<1
<1
100
'Number of ftcilities reporting water use is based on the responses to the detailed questionnaire from 193 in-scope facilities, 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. 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 Detailed Questionnaire
5-4
-------
-------
Chapter 5 - Water Use and Wastewater Characterization
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 as reported by the 193 in-scope
facilities responding to the detailed questionnaire. These amounts were calculated from
information provided in the wash formulas reported by facilities. 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 closely 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 bv Type of Discharge
All of the in-scope facilities that responded to the detailed questionnaire
discharge laundry wastewater to a POTW. Some facilities also discharge some of their
process wastewater to off-site disposal or land application. 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 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.
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
5-6
-------
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5-7
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5-8
-------
Chapter 5 - Water Use and Wastewater Characterization
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%) i
Estimated Number of Facilities
Discharging Noncontact
Cooling Water
{Percent ot Facilities)
313 (18%)
0 (0%)
0 (0%)
0 (0%)
'Based on responses to the detailed questionnaire from the 193 in-scope facilities, extrapolated to represent the entire industry. Some
facilities reported more than one discharge practice.
Source: 1994 Industrial Laundries Industry Detailed Questionnaire '
5-9
-------
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I
Q
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5-10
-------
Chapter 5 - Water Use and Wastewater Characterization
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 8 provides additional information on wastewater
recycle/reuse.
5.5
Characterization of Raw Wastewater by Item Laundered
As discussed in Chapter 4, 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 most
frequently detected in industrial laundry wastewater. Table 5-6 presents for the 72 pollutants
the mean pollutant concentration by item type. Table B-l in Appendix B 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.
5.6
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. EPA sampling program data and detailed
monitoring questionnaire (DMQ) data from facilities that do not split their wastewater stream
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. 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
5-11
-------
Chapter 5 - Water Use and Wastewater Characterization
Table 5-5
Water Conservation Practices and Water Use Reduction
Water Conservat JOB 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 (gat/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, extrapolated to represent entire industry. Only 1,468 extrapolated facilities responded to
this question. Percentages are based on the entire estimated industry of 1,747.
Source: 1994 Industrial Laundries Industry Detailed Questionnaire
5-12
-------
Chapter 5 - Water Use and Wastewater Characterization
Table 5-6
Wastewater Characterization for Item Specific Wastewater at Industrial
Laundries
Constituent Name
Mew Cwtwntfafiott fm8&>L
Industrial
Garments
Conventional?
Biochemical Oxygen Demand 5-Day (BOD5)
Oil and Grease (measured as HEM)
Total Suspended Solids (TSS)
386
91
348
trfortty Organics
1,1,1 -Trichloroethane
1 ,2-Diphenylhydrazine
4-Chloro-3-methylphenol
Bis(2-ethylhexyl) Phthalate
Butyl Benzyl Phthalate
Chlorobenzene
Chloroform
Di-n-butyl Phthalate
Di-n-octyl Phthalate
Ethylbenzene
Isophorone
Methylene Chloride
Naphthalene
Phenol
Tetrachloroethene
Toluene
trans-l ,2-Dichloroethene
Trichloroethene
Ntmconvenflonat Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pentanone
oc-Terpineol
Benzoic Acid
Benzyl Alcohol
Hexanoic Acid
m-Xylene
n-Decane
n-Docosane
n-Dodecane
0.0550
0.110
0.178
0.224
0.0550
0.0550
0.0550
0.0550
0.0600
0.151
0.0550
0.0558
0.0550
0.0702
0.0550
0.0666
0.0550
0.0550
0.275
0.0550
0.313
0.275
0.0550
0.450
0.0699
0.0885
0.0100
0.0550
0.0632
0.0630
Shop Towels
Printer Towels
-
2,060
2,550
4,590
5.16
1.36
1.03
3.30
0.678
; 0.313
0.370
0.678
0.678
: 6.25
0.678
; 5.28
2.88
0.381
8.03
: 4.81
0.456
: 0.294
1.92
i 0.946
3.98
; 1.88
0.874
3.23
0.678
0.373
1.69
49.5
0.949
18.2
3,940
5,890
1,250
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
3.09
0.836
49.7
2.07
1.07
3.30
0.500
0.433
1.44
90.6
0.668
23.1
Mats
248
84
365
1.60
0.0200
0.0100
2.02
0.0197
0.0100
0.0100
0.0100
0.0494
0.283
0.361
0.442
0.0244
0.0100
0.125
1.29
0.0100
0.0100
0.579
0.0100
2.11
0.458
0.0825
0.231
0.0724
0.0737
0.520
1.98
0.0130
0.121
5-13
-------
Chapter 5 - Water Use and Wastewater Characterization
Table 5-6 (Continued)
Constituent Name
n-Octacosanc
n-Tctracosane
n-Tctradccanc
n-Triacontanc
/>-Cymenc
Pcntamcthylbcnzene
Priority Metata and Elements
Arsenic
Cadmium
Copper
Nickel
Silver
Thallium
Zinc
Nonconvcntioiut MeUls and Elements
Aluminum
Boron
Cobalt
Iron
Molybdenum
Tin
Mean Concentration (mg/L)1
Industrial
Garments
0.0694
0.130
0.0759
0.0956
0.0471
0.0679
0.0634
0.0620
0.0100
0.0550
0.0764
0.0550
0.454
0.0116
0.000758
0.0246
0.0936
0.672
0.214
0.000408
0.103
0.0102
0.00710
0.00360
1.47
5.19
0.254
0.195
0.0171
9.70
0.139
0.0213
0.0922
0.148
0.00700
0.00215
Shop Towels
29.8
1.83
9.85
1.11
11.4
0.831
16.9
0.926
0.563
0.373
2.54
0.678
Printer Towels
1.29
2.01
9.51
0.402
2.43
0.605
7.89
0.626
1.08
0.433
12.4
0.500
- - '
0.211
0.0238
0.00100
0.391
0.478
6.65
7.34
0.00122
0.600
0.0138
0.174
0.00467
13.9
11.3
3.98
1.81
0.336
55.2
1.18
0.351
0.270
0.199
0.0433
0.00810
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
8.22
4.53
0.670
0.614
8.51
0.898
2.10
0.0990
0.184
0.00900
0.00570
Mats
0.0166
0.0197
0.0305
0.0100
0.0152
0.0100
0.0190
0.0306
0.291
0.0100
0.0100
0.0100
0.0203
0.00380
0.00100
0.00950
0.0806
0.220
0.307
0.000430
0.0543
0.00460
0.0171
0.0120
1.06
3.42
0.214
0.0500
0.0135
6.87
0.115
0.0240
0.0439
0.0100
0.00920
0.00500
5-14
-------
Chapter 5 - Water Use and Wastewater Characterization
Table 5-6 (Continued)
Constituent Name
Mean Concentration (mg/L)J
Industrial
Garments
Shop Towels
Printer Towels
Mats
Walk PKmwttventiOttals
Chemical Oxygen Demand (COD)
Total Organic Carbon (TOC)
Total Petroleum Hydrocarbon (measured as SGT-
HEM)
1,740
359
47
14,000
1,950
1,630
16,900
2,740
1,730
80
186
33
5-15
-------
Chapter 5 - Water Use and Wastewater Characterization
Table 5-6 (Continued)
Constituent N*me
Mean Concentration (mg/L)J
Mops
SteanvTumbled
Print** Towels
Itenis Dry
Cleaned Prior to
Vfitef W«!»Jttg
Linen Supply
Item
Conventlon»Is ''•;„„,'''
Biochemical Oxygen Demand 5-Day (BOD5)
Oil and Grease (measured as HEM)
Total Suspended Solids (TSS)
Priority Organic*
1,1,1 -Trichloroethane
1 ,2-Diphenylhydrazine
4-Chloro-3-methyIphenol
Bis(2-ethylhexyl) Phthalate
Butyl Benzyl Phthalate
Chtorobenzene
Chloroform
Di-n-butyl Phthalate
Di-n-octyl Phthalate
Ethylbcnzene
Isophoronc
Mcthylene Chloride
Naphthalene
Phenol
Tetrtchloroethene
Toluene
trans-l ,2-Dichloroethene
Ih'chloroethene
1,150
286
1,100
1,440
1,720
1,320
113
NA
82
881
108
269
' " , ''
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
Nonconventiontl Organic* "'•'" - " '
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pcntanone
cc-Tcrpincol
Bcnzoic Acid
Benzyl Alcohol
Hexanoic Acid
Bi-Xylene
n-Decane
/i-Docosanc
n-Dodccane
n-Ekosane
n-Hexacosane
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
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
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
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
_ --
0.0500
0.0164
0.0607
0.0500
0.0339
0.150
0.202
0.0279
0.0100
i 2.63
0.0392
0.270
0.0862
0.0267
5-16
-------
Chapter 5 - Water Use and Wastewater Characterization
Table 5-6 (Continued)
,-,,...
Constituent Name
R-Hexadecane
n-Octacosane
n-Octadecane
n-Tetracosane
n-Tetradecane
n-Triacontane
o-&p-Xylene
p-Cresol
p-Cymene
Pentamethylbenzene
^Priority Bfetals and Elements
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Vlercury
Nickel
Selenium
Silver
Thallium
Zinc
TConconventional Metals and Elements
Aluminum
Barium
Boron
Cobalt
Iron
Manganese
Molybdenum
Tin
Titanium
Vanadium
Yttrium
Mean Concentration (mg/L)J
Mops
1.07
0.221
0.875
0.100
1.47
0.163
0.100
0.100
0.100
0.100
0.0556
0.0178
0.00100
0.0373
0.184
3.52
1.76
0.00840
0.195
0.00460
0.0160
0.00240
5.32
17.3
0.953
0.327
0.0620
31.9
0.638
0.0940
0.128
0.307
0.0320
0.00500
Steam-Tnmbted
Printer Towels
91.6
0.0633
1.48
0.0724
12.8
, 0.0587
0.0146
0.0400
j 0.0400
0.0400
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
2.80
1.63
0.0500
: 0.202
i 2.62
0.277
, 2.64
! 0.0761
0.0178
0.0221
! 0.00500
Items Dry
Cleaned Prior to
Water WasHIng
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
0.00500
NA
0.0825
0.0933
0.668
0.519
0.000150
0.0200
NA
0.00500
NA
0.450
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Ltnen Supply
Items
0.160
0.0212
0.0720
0.0630
0.140
0.0551
0.0100
0.0100
0.108
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
0.381
3.08
0.301
0.0970
0.00990
3.26
0.0812
0.0263
0.0290
0.0654
0.00990
0.00470
5-17
-------
Chapter 5 - Water Use and Wastewater Characterization
Table 5-6 (Continued)
Constituent N*me
Bulk Noneonvtntionilj
Chemical Oxygen Demand (COD)
Total Organic Carbon (TOC)
HEM)
ftfean Concentration (mg/L)1
Mop*
5,410
518
111
Steam*Tumbled
Pfiwter Towels
9,000
1,770
468
Items Dry
Cleaned Prior to
water wasftltig
„,
638
NA
NA
Linen Supply
Items ;
^ ,.,„ , ••'
844
401
12
'The detection limit concentration was used in calculations for data points reported as non-detects.
NA - Not Available. No data were available for this constituent.
5-18
-------
Chapter 5 - Water Use and Wastewater Characterization
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.
Tables 5-7 through 5-9 present for 72 pollutants the mean concentrations for
heavy, light, and total raw wastewater streams. Table B-2 in Appendix B of this document
presents for the 72 pollutants 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 af e 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.
5-19
-------
Chapter 5 - Water Use and Wastewater Characterization
Table 5-7
Wastewater Characterization Data for Heavy Wastewater
Streams at Industrial Laundries
% ,. 33,
Pollutant s . . „,,""« .
Mean Concentration1
(mg/l,)
'M j
Conventionals - ' ' "' >',-•„•
Biochemical Oxygen Demand 5-Day (BOD^)
Oil and Grease (measured as HEM)
Total Suspended Solids (TSS)
4,160
2,950
2,320
Priority Organics „,, "~L\ , „
1,1,1 -Trichloroethane
1 ,2-Diphenylhydrazine
4-Chloro-3-methylplienol
Bis(2-ethylhexyl) Phthalate
Butyl Benzyl Phthalate
Chlorobenzene
Chlorofonn
Di-7Z-butyl Phthalate
Di-«-octyl Phthalate
Ethylbenzene
Isophorone
Methylene Chloride
Naphthalene
Phenol
Tetrachloroethene
Toluene
/ra/is-l,2-Dichloroethene
Trichloroethene
1.16
2.60
0.260
11.6
8.96
0.271
0.296
1.45
0.599
3.65
0.207
0.854
5.07
0.303
1.79
9.69
0.271
1.27
Nonconventional Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pentanone
25.5
0.892
8.49
5.82
5-20
-------
Chapter 5 - Water Use and Wastewater Characterization
Table 5-7 (Continued)
Pollutant
oc-Terpineol
!
Benzole Acid '
Benzyl Alcohol '
Hexanoic Acid
m-Xylene
n-Decane
H-Docosane
n-Dodecane
n-Eicosane
w-Hexacosane
w-Hexadecane
n-Octacosane
n-Octadecane
w-Tetracosane
n-Tetradecane
n-Triacontane
o-&p-Xylene
p-Cresol
p-Cymene
Pentamethylbenzene
Mean Consentrstitt*1
(mg/L)
0.379
3.36
1.56
0.210
4.47
86.5
0.504
29.5
4.41
0.354
9.49
0.370
4.00
0.316
7.23
0.366
3.59
0.204
3.55
0.412
Priority Metals and Elements
Antimony
Arsenic '
Beryllium
Cadmium
Chromium :
Copper
Lead
Mercury i
Nickel
Selenium !
0.788
0.0125
0.00142
0.121
0.296
5.37
1.60
0.000816
0.266
0.0174
5-21
-------
Chapter 5 - Water Use and Wastewater Characterization
Table 5-7 (Continued)
Pollutant
Silver
Thallium
Zinc
Hem Cottueotiratioti1
(mg/L)
0.199
0.00989
7.79
Nonconveqtional 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 non-detects.
5-22
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Chapter 5 - Water Use and Wastewater Characterization
Table 5-8
Wastewater Characterization Data for Light Wastewater
Streams at Industrial Laundries
Pollutant of Concern
Mean Concentration*
CmgfL)
Conventionals
Biochemical Oxygen Demand 5-Day (BODS)
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-n-butyl Phthalate
Di-n-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
Nonconventlonal Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pentanone
0.147
0.0566
0.518
0.240
5-23
-------
Chapter 5 - Water Use and Wastewater Characterization
Table 5-8 (Continued)
Pollutant of Concern
oc-Terpineol
Benzoic Acid
Benzyl Alcohol
Hexanoic Acid
wj-Xylene
n-Decane
w-Docosane
n-Dodecane
n-Eicosane
w-Hexacosane
n-Hexadecane
n-Octacosane
n-Octadecane
«-Tetracosane
n-Tetradecane
n-Triacontane
o-&p-Xylene
p-Cresol
p-Cymene
Pentamethylbenzene
M^a» CoiMjentwttion1
(mg/L)
0.123
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
1.32
0.00653
0.000938
0.0211
0.113
0.858
0.348
0.000715
0.101
0.0133
5-24
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Chapter 5 - Water Use and Wastewater Characterization
Table 5-8 (Continued)
Pollutant of Concern
Silver :
Thallium
Zinc
Mean Coasenti-atiott1
(mg/L)
0.00432
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 Nonconventfonais !
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 non-detects.
5-25
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Chapter 5 - Water Use and Wastewater Characterization
Table 5-9
Wastewater Characterization Data for Total Raw Wastewater
Streams at Industrial Laundries
Pollutant
Mean Concentration*
(mgflL)
Conventionals
Biochemical Oxygen Demand 5-Day (BOD<;)
Oil and Grease (measured as HEM)
Total Suspended Solids (TSS)
879
1,450
849
Priority Organfcs
1,1,1 -Trichloroethane
1 ,2-Diphenylhydrazine
4-Chloro-3-methylphenol
Bis(2-ethylhexyl) Phthalate
Butyl Benzyl Phthalate
Chlorobenzene
Chloroform
Di-n-butyl Phthalate
Di-n-octyl Phthalate
Ethylbenzene
Isophorone
Methylene Chloride
Naphthalene
Phenol
Tetrachloroethene
Toluene
trans- 1 , 2-Dichloroethene
Trichloroethene
0.334
0.0984
0.070
5.42
0.139
0.155
0.0344
0.273
0.103
0.681
0.0790
0.390
1.72
0.0861
3.69
2.49
0.0230
0.0211
Nonconventional Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pentanone
2.98
0.157
12.8
1.89
5-26
-------
Chapter 5 - Water Use and Wastewater Characterization
Table 5-9 (Continued)
Pollutant
oc-Terpineol
Benzole Acid
Benzyl Alcohol
Hexanoic Acid
m-Xylene
n-Decane
«-Docosane
w-Dodecane
n-Eicosane
n-Hexacosane
H-Hexadecane
w-Octacosane
n-Octadecane
n-Tetracosane
n-Tetradecane
n-Triacontane
o-&p-Xylene
p-Cresol
p-Cymene
Pentamethylbenzene
Mean Concentratiott1
(mg/L)
0.326
0.779
0.0753
0.0854
5.56
97.0
0.680
6.75
2.12
0.529
5.57
0.103
1.82
1.63
5.08
0.160
3.02
0.0713
0.143
0.313
Priority Metals and Elements
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
0.0945
0.0185
0.00752
0.0574
0.263
1.36
0.809
0.00110
0.165
0.0648
5-27
-------
Chapter 5 - Water Use and Wastewater Characterization
Table 5-9 (Continued)
Pollutant
Silver
Thallium
Zinc
Nonconventional Metals and Elements
Aluminum
Barium
Boron
Cobalt
Iron
Manganese
Molybdenum
Tin
Titanium
Vanadium
Yttrium
Mean Concentration1
(mg/L)
0.0278
0.0248
2.16
"'
5.86
1.18
0.701
0.184
30.9
0.504
0.386
0.176
0.166
0.0710
0.0127
Bulk Nonconventionals - *
Chemical Oxygen Demand (COD)
Total Organic Carbon (TOC)
Total Petroleum Hydrocarbon (measured as SGT-HEM)
5,290
1,440
530
The detection limit concentration was used in calculations for data points reported as non-detects.
5-28
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6.1
Chapter 6 - Industry Scope and Subcategorization
CHAPTER 6
INDUSTRY SCOPE AND SUBCATEGORIZATION
Introduction
This chapter discusses the scope and applicability of the proposed rule and the
Subcategorization analysis for the Industrial Laundries Point Source Category. The purpose of
the scope and applicability is to define the type of facilities that will be covered by the
proposed rule. The purpose of subcategorization is to group together, if appropriate, facilities
of similar characteristics so that pretreatment standards representative of each group can be
developed. This provides each subcategory with a uniform set of pretreatment standards that
consider technological achievability and economic impacts unique to that subcategory.
After examining data collected on the industry, EPA has determined that
subcategorization of the Industrial Laundries Point Source Category is not appropriate, as
discussed in this chapter.
The following sections discuss the following topics:
• Section 6.2 discusses the regulatory background of the industrial
laundries industry;
• Section 6.3 discusses the scope of the industry;
• Section 6.4 presents the subcategorization analysis; and
• Section 6.5 presents the references used.
6.2
Regulatory Background
As discussed in Chapter 2, the Auto and Other Laundries Category, of which
industrial laundries was a subcategory, was mandated for study and possible effluent
limitations guidelines and standards development by the 1976 Settlement Agreement.
However, in 1982, the 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 publicly owned treatment works (POTWs) and that did not
pass through, interfere with, or otherwise prove incompatible with the operation of POTWs.
After gathering additional information about the industrial laundries industry,
EPA published its 1986 Domestic Sewage Study (DSS), which identified industrial laundries
as potential contributors of large amounts of hazardous pollutants to POTWs. In its 1990
Effluent Guidelines Plan (55 FR 80), EPA listed the industrial laundries industry as a new
6-1
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Chapter 6 - Industry Scope and Subcategorization
category to be studied for possible effluent limitations guidelines and standards development.
The Natural Resources Defense Council (NRDC) and Public Citizen, Inc. filed suit against
EPA, charging that EPA's plan did not meet the requirements of 304(m) of the Clean Water
Act. A Consent Decree was entered by the Court in January 31, 1992 (57 FR 19748); as
modified in 1994, the Consent Decree requires that EPA promulgate effluent limitations
guidelines and standards for the Industrial Laundries Point Source Category in 1998 (59 FR
25859). In 1997, EPA negotiated new proposal and promulgation deadlines with the NRDC;
as a result, EPA must now promulgate the rule for the industrial laundries industry by June
1999 (62 FR 8726).
6.3
Industry Scope
One of the steps in developing pretreatment standards for the industrial
laundries industry was determining 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 and
applicability of the regulation.
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 rule. Based on the data collected by EPA,
97 percent of all laundering performed by industrial laundries is water washing. As discussed
in Chapters 4 and 5, industrial laundry treated by oil-only dust control mop treatment
generates no wastewater. Therefore, oil-only dust control mop treatment is proposed to be
excluded from regulation under the proposed rule. Industrial laundry treated by dry cleaning
generates little wastewater, which typically contains very low concentrations of pollutants.
Because this process generates an insignificant amount of wastewater, it is proposed to be
excluded from regulation under the proposed rule. Only water-washing laundering processes
are included in the scope of the rule. In addition, one facility reported dyeing of new items.
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.
EPA then looked at the types of items that were water-washed to determine if
any specific items should be excluded from regulation. 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(l).
6-2
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Chapter 6 - Industry Scope and Subcategorization
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 6-1. Table
6-1 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 higher 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 6-2. Table 6-2 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 proposed rule.
EPA is also proposing to exclude on-site laundries from the applicability of the
rule. The focus of this rule is 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 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 C of this document. These regulations generally apply to wastewater
generated from these industries, including on-site laundering. For example, the OCPSF
effluent guidelines control discharges from garment laundering at OCPSF facilities. For
6-3
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Chapter 6 - Industry Scope and Subcategorization
Table 6-1
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
tacility
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
F-value
0.0001
0.0012
0.0001
0.0001
O.OOOl
O.0001
O.OOOl
O.OOOl
Significant
at 3=0.01?
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
6-4
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Chapter 6 - Industry Scope and Subcategorization
Table 6-2
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
Meaa
Concentration
(mgflL)
; 95
! 19
• 161
'•• 470
0.013
0.003
' 0.04
0.01
: 0.21
0.06
2.71
i 0.50
; 0.32
0.06
p-vafue
0.018
0.021
0.0001
0.0014
0.001
0.027
0.114
Significant
ata-Q.01?
No
No
Yes
Yes
Yes
No
No
6-5
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Chapter 6 - Industry Scope and Subcategorization
industries not yet covered by effluent limitations guidelines and standards, it makes sense to
examine these industries and the wastewater treatment processes at these industrial facilities 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
subcategory as a whole. This is consistent with EPA's efforts to make common-sense
regulatory decisions.
EPA has also considered concerns expressed by industrial launderers that by
excluding on-site laundering of industrial items, EPA has created an incentive for businesses
to switch from using industrial launderers covered by the rule to on-site laundering. EPA
does not believe this will happen because the average increased price per pound of laundering
as a result of the proposed rule ($0.003 per pound) is so small that the cost of buying the
equipment and operating the equipment on site would not be justified. Furthermore, an
increase in pollutant loads at the facility may necessitate additional changes in the facility's
NPDES permit if it is a direct discharger or its pretreatment permit issued by the local POTW
if it is an indirect discharger. Section 8 of the Economic Assessment (2) supporting this
proposed rule and the Analysis of Hotels, Hospitals, and Prisons (HHPs) Database
memorandum (3) contain additional information on this issue.
Based on these analyses, EPA determined the facilities within the scope of the
proposed rule. Industrial laundries that would be in scope include 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 laundered textile items; this includes
textile rental companies that perform laundering operations. Laundering in this definition
means washing with water, including water washing following dry cleaning. This rule would
not apply to laundering exclusively through dry cleaning. Industrial textile items include, but
are 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, filters, and clean room items. If any of these items are used by hotels, hospitals, or
restaurants, they are not industrial items. For a facility that meets this definition, wastewater
from all water-washing operations would be covered by the proposed rule, including
wastewater from the washing of linen items, as long as these items do not constitute 100
percent of the items washed.
The proposed rule would not apply to discharges from on-site laundering at
industrial facilities, laundering of industrial textile items within the same business entity, and
facilities that exclusively launder linen items, denim prewash items, new items (i.e., items
directly from the textile manufacturer, not yet used for their intended purpose), any other
laundering of hospital, hotel, or restaurant items or any combination of these items. This
proposed rule does apply to hotel, hospital, or restaurant laundering of industrial textile items.
6-6
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Chapter 6 - Industry Scope and Subcategorization
In addition, this proposed rule would not apply to the discharges from oil-only treatment of
mops. 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.
6.4
Subcategorization Analysis
EPA assessed several factors to determine whether segmenting or
subcategorizing the Industrial Laundries Point Source Category is appropriate. These factors
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 has determined that the Industrial Laundries
Point Source Category warrants no Subcategorization. However, the proposed PSES contain
an exclusion for small facilities due to disproportionate economic impacts. The remainder of
this section discusses EPA's analysis of each of these factors.
6.4.1
Disproportionate Economic Impacts
EPA looked at production as a means of defining applicability of the rule, since
EPA commonly uses production as a good indicator of size 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 following
6-7
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Chapter 6 - Industry Scope and Subcategorization
implementation of this rule. EPA did a breakpoint analysis and determined that
disproportionate impacts occur at facilities with production of less than one million pounds
per year and less than 255,000 pounds per year of shop and printer towels/rags. Appendix E
of the Economic Assessment presents EPA's rationale for this exclusion.
Under Pretreatment Standards for Existing Sources (PSES), EPA is proposing
to exclude existing facilities processing less than one million pounds of incoming laundry per
calendar year and less than 255,000 pounds of shop towels and/or printer towels/rags per
calendar year. EPA proposes this exclusion to eliminate the unacceptable economic impacts
on these smaller facilities that would occur without the exclusion. Appendix E of the
Economic Assessment contains a more detailed discussion of this exclusion. As a result of
this exclusion, there would be a decrease of less than three percent in the pollutant removals
achieved under the proposed rule.
Under Pretreatment Standards for New Sources (PSNS), EPA is proposing no
exclusions since the economic projections indicate that there would be no barrier to entry as a
result of the proposed new source standards.
6.4.2
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 6.3, 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.
6.4.3
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 hi
Chapter 4. EPA is therefore not considering plant age as a basis for subcategorization.
6.4.4
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. EPA did not
subcategorize based on geographical location because location does not affect the ability of
industrial laundries to comply with the proposed rulemaking.
6-8
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Chapter 6 - Industry Scope and Subcategorization
6.4.5
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.
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.
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.
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.
In addition, as discussed in Section 6.4.1, EPA looked at production in
determining the applicability of the proposed rule to the industry. As a result, EPA is
proposing to exclude from regulation existing facilities that process less than one million
pounds of incoming laundry per calendar year and less than 255,000 pounds of shop
towels/rags. ;
6-9
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Chapter 6 - Industry Scope and Subcategorization
6.4.6
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 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.
6.4.7
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 14, EPA estimates that minimal non-water quality
impacts would result from implementation of this proposed regulation. Therefore, EPA
determined that these non-water quality environmental impacts are not an adequate basis for
subcategorizing the industrial laundries industry.
6.4.8
Type of Item Laundered and Wastewater Characteristics
As discussed in Section 6.3 of this document, the types of items laundered by
facilities covered under the scope of this rulemaking include, but are not limited to, the
following industrial textile items: shop towels, printer towels/rags, furniture towels, rags,
mops, mats, rugs, tool covers, fender covers, dust-control items, gloves, buffing pads,
absorbents, uniforms, and clean room garments. Laundering of linen items is also covered
when industrial items are laundered at the same facility.
EPA examined type of item laundered as a possible basis of Subcategorization,
as different items cleaned usually generate different wastewater characteristics. As presented
in Chapter 5, printer towels/rags, shop towels, and mops generally have concentrations of
pollutants that are greater than the concentrations for floor mats and industrial garments.
Laundering of printer towels/rags and shop towels generates 67 percent of the toxic-weighted
wastewater pollutant load from the industry, although these items represent only 5 percent of
the total industry production and 10 percent of the total industrial laundry production.
EPA considered requiring different wastewater limitations 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
6-10
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1 Chapter 6 - Industry Scope and Subcategorization
industry by type of item laundered with different limitations for different types of items
would require segregation and separate treatment of wastestreams. To be effective, separate
limitations for wastewater for specific laundry items would require the use of in-plant
limitations. Requiring industrial laundries to segregate wastewater and treat the segregated
streams separately adds complexity to the regulation that is unnecessary. In addition, most
facilities that reported having treatment in the detailed questionnaire treat all of their
wastewater from laundering of all items. Also, most industrial laundries currently sample
only their total facility effluent at the point of discharge to the POTW. Implementation of in-
plant limits would place an additional recordkeeping burden on both the industry and permit
writers and would increase the costs for the industry to comply with the proposed rule.
6.5
3.
References
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.
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-97-008, Washington, DC,
November 1997.
Memorandum: Analysis of Hotels, Hospitals, and Prisons (HHPs) Database,
February 21, 1997.
6-11
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Chapter 7 - Pollutants Selected for Regulation
CHAPTER 7
POLLUTANTS SELECTED FOR REGULATION
7.1
Introduction
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 D-l in Appendix D 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.
This chapter presents the methodology used1 to select pollutants for regulation
under the proposed industrial laundries rule. Section 7.2 discusses the pollutants considered
for regulation. Section 7.3 discusses the criteria used to identify pollutants of concern from
the list of pollutants considered for regulation. Section 7.4 discusses the criteria used to select
pollutants for regulation, including the pass-through analysis, from the pollutants of concern
list, and Section 7.5 presents the references used.
7.2
Pollutants Considered for Regulation
EPA considered four conventional, 98 priority, and 213 nonconventional
organic, metal, and elemental pollutant parameters for potential regulation for the industrial
laundries industry. Three hundred and twelve (312) of these pollutants are listed hi The
Industrial 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 1993-1996 industrial laundries
sampling program, which is discussed in Chapter 3. Table D-2 in Appendix D lists the 315
pollutants analyzed by EPA in industrial laundry wastewater during this sampling program.
EPA used data collected from seven industrial laundries for selecting pollutants of concern
and regulated pollutants. :
For the industrial laundries industry, EPA used the newly proposed EPA
Method 1664 to analyze for oil and grease and total petroleum hydrocarbons (TPH) because
the currently approved method for analyzing these parameters uses freon, which is being
phased out of use. Method 1664 has been proposed to measure oil and grease as hexane
7-1
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Chapter 7 - Pollutants Selected for Regulation
/
extractable material (HEM) and to measure TPH as silica gel treated-hexane extractable
material (SGT-HEM).
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 Detailed Questionnaire.
The 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 D-l in Appendix D); 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.
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 facilities have limits for dioxins and furans.
7-2
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1 Chapter 7 - Pollutants Selected for Regulation
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 facilities has limits for PCBs.
EPA did not consider pesticides for regulation because most priority 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. Pesticides were analyzed for at four
facilities during the 1985-1987 sampling program, and ten 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 facilities
has 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 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.
7-3
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Chapter 7 - Pollutants Selected for Regulation
7.3
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 7-1 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 7-2 lists the 50 pollutants meeting this
criterion.
• Pollutants identified during screening, but not quantified due to a lack
of an acceptable analytical method. Eight metal and elemental
pollutants that were detected in industrial laundry samples greater than
10 percent of the tune 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 metals were used for screening purposes only and
were excluded from the pollutants of concern because they are not
quantified. Table 7-3 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 present in source water at
concentrations similar to quantities present on industrial laundry items
and generated from industrial laundry processes, based on comparing the
concentrations of these pollutants in source water from seven sampling
episodes to the concentrations in industrial laundry wastewater.
• 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.
7-4
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Chapter 7 - Pollutants Selected for Regulation
Table 7-1
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
7-5
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Chapter 7 - Pollutants Selected for Regulation
Table 7-1 (Continued)
Pollutant
Ethane, Pentachloro-
Ethyl Cyanide
Ethyl Methacrylate
Ethyl Methanesulfonate
Ethylcnethiourea
Hexachloropropene
lodomethane
Isosafrole
Longifolene
Malachite Green
Mestranol
Methapyrilene
Methyl Methanesulfonate
N-Nitrosodi-N-butylamine
N-Nitrosodiethylamine
N-Nitrosomethylethylamine
N-Nitrosomethylphenylamine
N-Nitrosopiperidine
N.N-Dirnethylformamide
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
l-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-Trichloropropane
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
7-6
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Chapter 7 - Pollutants Selected for Regulation
Table 7-1 (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-Nitroaniline
3,3 '-Dimethoxybenzidine
3,6-Dimethylphenanthrene
4-Aminobiphenyl
4-Chloro-2-nitroaniline
4,4'-Methylenebis(2-chloroaniline)
4,5-Methylene Phenanthrene
5-Nitro-o-toluidine
7, 12-Dimethylbenz(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 i
Hafnium
Holmium
Indium
Lanthanum
Lutetiuin
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.
7-7
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Chapter 7 - Pollutants Selected for Regulation
Table 7-2
Pollutants Detected in Less Than 10 Percent of Samples Analyzed During
the 1993-1996 Industrial Laundries Sampling Program
Priority Organic*
jNoneonventional Organics
Acrylonitrile
Acetophenone
Benzene
Aniline
Bis(2-chloroethoxy)methane
Biphenyl
Bis (2-chloroethyl)ether
Dibenzofuran
Bromodichloromethane
2,3-Dichloroaniline
2-Chloroethylvinyl ether
Dimethyl sulfone
2-Chlorophenol
1,4-Dioxane
Dibromochloromethane
Diphenylamine
1.1-Dichloroethane
Diphenyl ether
1,2-Dichloroethane
2-Hexanone
1,1-Dichloroethene
Isobutyl alcohol
2,4-Dichlorophenol
1-Methylfluorene
Diethyl phthalate
1 -Methylphenanthrene
2,4-Dimethylphenol
Methyl methacrylate
Dimethyl phthalate
N-Nitrosomorpholine
2,4-Dinitrophenol
o-Cresol
2,6-Dinitrotoluene
Safrole
2-Nitrophenol
Styrene
4-Nitrophenol
Trichlorofluoromethane
N-Nitrosodiphenylamine
2,3,6-Trichlorophenol
Pentachlorophenol
2,4,5-Trichlorophenol
Phenanthrene
Tripropyleneglycol methyl ether
Phenol,2-Methyl-4,6-Dinitro-
2-Propenal
1,1,2,2-Tetrachloroethane
Tetrachloromethane
Trans-1,3-Dichloropropene
2,4,6-Trichlorophenol
7-8
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Chapter 7 - Pollutants Selected for Regulation
Table 7-3
Semiquantitative Metal and Elemental Pollutants Excluded from the
Pollutants of Concern for the Industrial Laundries Industry
Nonconventioaal Metals
and Elements
Iodine
Iridium
Lithium
Phosphorus
Potassium
Silicon
Strontium
Sulfur
7-9
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Chapter 7 - Pollutants Selected for Regulation
— Total orthophosphate, total phosphorous, and total hydrolyzable
phosphate: Table 7-4 presents the average influent,
concentrations, effluent concentrations, and percent removals for
these pollutants by both the dissolved air flotation and
chemical precipitation treatment technologies. These pollutants
are typically regulated by water quality standards on a case-by-
case basis. These pollutants are not considered for national
regulation for the industrial laundries industry.
— Surfactants (nonionic (CTAS) and anionic (MBAS)): Table 7-4
presents the average influent concentrations, effluent
concentrations, and percent removals for these pollutants by both
the dissolved air flotation and chemical precipitation treatment
technologies. 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.
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.
Total suspended solids and total solids were both detected in industrial laundry wastewater.
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 suspended solids portion, not the dissolved solids portion, 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 7-5 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.
7.4
Pollutants Selected for Regulation
This section presents the pollutant parameters selected for regulation for the
proposed rule for the Industrial Laundries Point Source Category. These parameters were
chosen from the list of 72 pollutant parameters of concern discussed above. Although all 72
pollutant parameters of concern were used to estimate compliance costs, pollutant loadings,
and pollutant reductions, only certain parameters were selected for regulation. Because the
list of pollutants of concern is rather large, EPA has chosen to propose a subset of these
7-10
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Chapter 7 - Pollutants Selected for Regulation
Table 7-4
Average Influent Concentrations, Effluent Concentrations,
and Removals for Phosphorous and Surfactants
Pollutant
Average Influent
{m^lL)
Average Effluent
(ittgfc)
Chemical Precipitation
Total Hydrolyzable
Phosphorous
Total Orthophosphate
Total Phosphorous
'Surfactants (anionic)
Surfactants (nonionic)
Total Hydrolyzable
Phosphorous
Total Orthophosphate
Total Phosphorous
Surfactants (anionic)
Surfactants (nonionic)
67.6
No Data
42.0
12.0
109
0:363
No Data
0.992
6.23
43.4
Average Percent
Removal
>99
No Data
98
48
60
Dissolved Air Flotation
10.8
6.88
21.4
7.64
446
5.15
2.95
8.94
0.818
202
52
57
58
89
55
7-11
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7-15
-------
Chapter 7 - Pollutants Selected for Regulation
pollutants for regulation to streamline the control and compliance process. Moreover,
monitoring for all 72 pollutants of concern is not necessary to ensure that industrial laundry
wastewater pollutants are adequately controlled, since many of the pollutants originate from
similar sources and have similar properties. EPA selected the pollutants for regulation to
represent the entire population of the pollutants of concern; they include metals, volatile
organics, and semivolatile organics. Table 7-6 presents the pollutants selected for proposed
regulation. The rationale for selecting these pollutants is discussed below.
7.4.1
Elimination of Parameters that Comprise TPH
EPA is not specifically controlling the following eleven straight chain alkane
(»-alkanes) pollutants in the proposed rule because EPA believes these pollutants comprise a
portion of TPH, measured as SGT-HEM, and thus would be controlled by EPA's regulation
of TPH:
K-Decane;
w-Docosane;
H-Dodecane;
w-Eicosane;
n-Hexacosane;
H-Hexadecane;
K-Octacosane;
H-Octadecane;
n-Tetracosane;
n-Tetradecane; and
K-Triacontane.
7.4.2
Elimination of Treatment Chemicals
EPA eliminated aluminum and iron from the proposed regulation because
aluminum and iron are commonly added to wastewater as treatment chemicals in the industrial
laundries industry. Regulation of aluminum and iron could interfere with their beneficial use
as wastewater treatment additives.
7.4.3
Elimination of Pollutants Not Treated or Below Treatable Concentrations
EPA eliminated pollutants from the proposed regulation when the pollutants
were not removed by the treatment technologies under consideration as the bases for the
regulation. EPA also eliminated pollutants when the pollutants were present below treatable
concentrations in wastewater influent to the treatment systems sampled, and therefore would
not be substantially removed by the treatment technologies under consideration. For the
purposes of this proposed rule, EPA only used 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.
7-16
-------
Chapter 7 - Pollutants Selected for Regulation
Pollutants Selected for Proposed Regulation in
Pollutant
Priority Organics
Bis(2-ethylhexyl) Phthalate
Ethylbenzene
Naphthalene
Tetrachloroethene
Toluene
Nonconventional Organics
w-Xylene
o-&p-Xylene
Priority Metals
Copper
Lead
Zinc
Bulk Nonconventionals
Total Petroleum Hydrocarbon (measured as SOT-HEM)"1
EPA is proposing the use of EPA Methods 1624 and 624 for the analysis of xylenes, even though xylenes are
not specifically listed as an analyte in either of these methods (promulgated at 40 CFR Part 136). EPA used data
obtained from the analysis of xylenes by these two methods in the development of the proposed industrial
laundry standards.
Total Petroleum Hydrocarbons (measured as SGT-HEM) is total petroleum hydrocarbons measured by the silica
gel treated-hexane extractable material (SGT-HEM) analytical method proposed January 23, 1996 (Method 1664).
7-17
-------
Chapter 7 - Pollutants Selected for Regulation
EPA considered two main technologies as the bases for the regulatory options
(see Chapter 10 for a description of the regulatory options). The two technologies
arechemical precipitation and dissolved air flotation (DAF). For each of these technologies,
EPA eliminated a different set of pollutants from further consideration for regulation based on
treatability. For chemical precipitation, EPA eliminated 31 pollutants from further
consideration for regulation. Table 7-7 lists these pollutants and the reasons the pollutants
were eliminated. For DAF, EPA eliminated 19 pollutants from further consideration for
regulation; Table 7-8 lists these pollutants and the reasons the pollutants were eliminated.
7.4.4
Elimination of Pollutants that Do Not Pass Through or Otherwise Interfere
with POTWs
Section 307(b) of the Clean Water Act requires EPA to promulgate
pretreatment standards for indirect dischargers to ensure removal of pollutants which pass
through, interfere with, or are incompatible with the operation of POTWs. Pollutants shown
to pass through a POTW may be regulated by 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.
7.4.4.1
Background
Before proposing pretreatment standards, EPA examines whether the pollutants
discharged by the industry pass through a POTW to waters of the U.S. or interfere with the
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 facilities meeting BAT effluent limitations. For the industrial laundries industry, where
only pretreatment standards are being considered, EPA compared the POTW removals with
removals achieved by indirect dischargers using the candidate technology that satisfies the
BAT factors.
For specific pollutants, such as volatile organic compounds or highly
biodegradable compounds, EPA may use other means to determine pass through. For volatile
compounds, a volatile override test based on the Henry's Law Constant is used to determine
pass through. For this proposed rule, EPA has determined that a pollutant that has a Henry's
Law Constant greater than 2.4 x 10-5 atm-m3/mole will be sufficiently volatile such that a
significant portion of the compound would not be treated by the POTW and therefore is
determined to pass through. For highly biodegradable compounds, the pass-through
determination may be conducted using engineering modeling.
For this proposed rule, the percent removal comparison between indirect
dischargers using the candidate PSES technology and POTWs and the volatile override test
were used to determine pass through. Since EPA has not identified any direct dischargers,
7-18
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Chapter 7 - Pollutants Selected for Regulation
Table 7-7
Pollutants Eliminated from Consideration for Regulation for the Industrial
Laundries Industry for Chemical Precipitation Options
Pollutant
Reason Excluded
Priority Organics
1 ,2-Diphenylhydrazine
4-Chloro-3-methylphenol
Chlorobenzene
Chloroform
Di-n-butyl-phthalate
Methylene Chloride
Phenol
trans-l ,2-Dichloroethene
Trichloroethene
Pollutant not detected.
Pollutant detected below treatable concentrations.
Pollutant detected below treatable concentrations.
Pollutant detected below treatable concentrations.
Pollutant detected below treatable concentrations.
Pollutant detected below treatable concentrations.
Pollutant not treated by technology.
Pollutant not detected. ;
Pollutant not detected.
Nonconventional Organics
2-Propanone
oc-Terpineol
Benzoic Acid
Benzyl Alcohol
Hexanoic Acid
/j-Cresol
p-Cymene
Pentamethylbenzene
Pollutant not treated by technology. ;
Pollutant not treated by technology.
Pollutant detected below treatable concentrations.
Pollutant not treated by technology. '
Pollutant not treated by technology.
Pollutant not detected.
Pollutant not detected.
Pollutant not detected.
Priority Metals and Elements
Antimony
Arsenic
Beryllium
Mercury
Nickel
Selenium
Silver
Thallium
Pollutant detected below treatable concentrations.
Pollutant detected below treatable concentrations.
Pollutant detected below treatable concentrations.
Pollutant detected below treatable concentrations.
Pollutant detected below treatable concentrations.
Pollutant detected below treatable concentrations.
Pollutant detected below treatable concentrations.
Pollutant not detected.
7-19
-------
Chapter 7 - Pollutants Selected for Regulation
Table 7-7 (Continued)
Pollutant
Reason Excluded ' ' ,"
Nonconventlonal Metals and Elements
Barium
Boron
Cobalt
Tin
Vanadium
Yttrium
Pollutant detected below treatable concentrations.
Pollutant detected below treatable concentrations.
Pollutant detected below treatable concentrations.
Pollutant detected below treatable concentrations.
Pollutant detected below treatable concentrations.
Pollutant detected below treatable concentrations.
7-20
-------
Chapter 7 - Pollutants Selected for Regulation
Table 7-8
Pollutants Eliminated from Consideration for Regulation for the Industrial
Laundries Industry for Dissolved Air Flotation Options
Pollutant
Reason Excluded
Priority Organics
1 ,2-Diphenylhydrazine
Butyl Benzyl Phthalate
Isophorone
trans-l ,2-Dichloroethene
Trichloroethene
Pollutant not detected.
Pollutant detected below treatable concentrations.
Pollutant not detected.
Pollutant detected below treatable concentrations.
Pollutant detected below treatable concentrations.
Nonconventional Organics
Benzyl Alcohol
Hexanoic Acid
p-Cresol
Pentamethylbenzene
Pollutant detected below treatable concentrations.
Pollutant not detected.
Pollutant detected below treatable concentrations.
Pollutant not detected.
Priority Metals and Elements
Arsenic
Beryllium
Mercury
Silver
Thallium
Pollutant detected below treatable concentrations.
Pollutant not detected.
Pollutant detected below treatable concentrations.
Pollutant detected below treatable concentrations.
Pollutant detected below treatable concentrations.
Nonconventional Metals and Elements
Barium
Boron
Cobalt
Vanadium
Yttrium
Pollutant detected below treatable concentrations.
Pollutant detected below treatable concentrations.
Pollutant detected below treatable concentrations.
Pollutant detected below treatable concentrations.
Pollutant detected below treatable concentrations.
7-21
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Chapter 7 - Pollutants Selected for Regulation
EPA used PSES percent removals for evaluating pass through. EPA finds that a pollutant
passes through when the average percent removed nationwide by well-operated POTWs(those
meeting secondary treatment requirements) is less than the average percent removed by
facilities meeting the candidate PSES for that pollutant.
EPA eliminated three conventional pollutants, biochemical oxygen demand
(BOD), total suspended solids (TSS), and oil and grease (measured as HEM), from further
consideration for regulation 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. For this analysis, EPA evaluated 25 pollutants from
the list of 72 pollutants of concern for chemical precipitation and 37 pollutants were evaluated
for dissolved air flotation. The POTW removals used in the pass-through analysis are
presented in Tables 7-9 and 7-10. The following sections present the methodology and results
from the pass-through analysis performed for both the chemical precipitation and DAF.
7.4.4.2 Methodology for Determining Treatment Technology Percent Removals
Treatment performance data for chemical precipitation and dissolved air
flotation were obtained during the industrial laundries sampling program. Influent and
effluent data for chemical precipitation were obtained from one facility and comparable data
for DAF were obtained from two facilities. These data were used to determine whether a
pollutant passes through a POTW. For conducting the pass-through analysis, the data were
edited as described in Chapter 9 for calculating the long-term average concentrations. This
editing included removing data that were associated with treatment or process upsets,
removing data for pollutants that were never detected in influents to treatment systems,
removing data for pollutants not treated by the treatment technology, and removing data with
influent concentrations less than ten times the method detection level and the corresponding
effluent data. These editing criteria were used to allow for the possibility that low percent
removals reflected low influent concentrations, not treatment technology performance.
After the data were edited, 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:
Percent Removal =
Lnfluerrt - Effluent
2X5
Influent.
'avg
7-22
-------
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-------
7.4.4.3
Chapter 7 - Pollutants Selected for Regulation
3) EPA calculated the median percent removal for each pollutant for each
technology from the facility-specific percent removals.
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 (50 POTW Studv> (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. Additional information on these
sources is presented below. The following priority of data sources was used to determine the
percent removal of pollutants by POTWs nationwide:
• 50 POTW Study;
• RREL Treatability Database; and
7.4.4.4
• Generic pollutant group removal.
50 POTW Study
The primary source of the POTW percent removals data was the 50 POTW
Study. The POTW data were edited to eliminate influent and the corresponding effluent data
where the average influent concentration at a POTW was less than ten times the method
detection level edit, 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 were
eliminated where the influent concentrations were less than 20 |j,g/L or less than the method
detection level for pollutants where the method detection level is greater than 20 jxg/L. The
effluent data corresponding to these influent data were also eliminated. EPA selected 20 jj,g/L
because, for pollutants with low influent concentrations (i.e., less than 20 [o.g/L or the method
detection limit), the effluent concentrations were consistently below the method detection level
and could not be precisely quantified.
After the POTW data were edited, the following methodology was used 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
7-28
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2)
3)
Chapter 7 - Pollutants Selected for Regulation
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.
Percent removals were calculated from the average influent and average
effluent concentrations for each pollutant for the POTW using the
equation in Section 7.4.4.2 of this document.
The median percent removal was calculated for each pollutant from the
POTW-specific percent removals.
7.4.4.5
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 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 were 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.
7-29
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Chapter 7 - Pollutants Selected fqr Regulation
After applying these editing criteria, EPA calculated percent removals for each
data source for each pollutant, using the equation in Section 7.4.4.2 of this document. EPA
then took the average of the percent removals for each pollutant to obtain an average POTW
percent removal from the REEL Treatability Database.
7.4.4.6
Generic Removal
After the editing of the 50 POTW Study and REEL Treatability Database, data
for TPH, measured as SGT-HEM, were still not available. In order to determine an
appropriate POTW percent removal for this pollutant, the available data for the 72 pollutants
of concern were reviewed. EPA determined that the best source of POTW removal data for
TPH would be the generic group removal of the «-alkanes. EPA determined that because the
H-alkanes comprise a portion of TPH, the percent removal from these compounds represents
the best available percent removal for TPH. Table 7-11 presents the n-alkanes removal data
used to calculate the percent removal for TPH.
7.4.4.7
Results of the POTW Pass-Through Analysis
Tables 7-9 and 7-10 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 2.4 x 10"5 atm-m3/rnol was determined to pass through regardless of its percent
removal. For chemical precipitation, 23 of the 25 pollutants analyzed passed through. For
DAF, 26 of the 37 pollutants analyzed passed through.
7.4.5
Selection of Regulated Pollutants
Based on the results of the pass-through analysis, EPA considered the pollutants
shown in Table 7-12 as pollutants for regulation under the proposed rule for the chemical
precipitation and DAF technologies. To further streamline the list of pollutants for proposed
regulation, EPA considered using "indicator" pollutants to reflect control of 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 11 pollutants for regulation.
EPA considered three bulk parameters, TPH (measured as SGT-HEM), TOC,
and COD, for regulation. 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
7-30
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Chapter 7 - Pollutants Selected for Regulation
Table 7-11
Generic Removal for «-Alkanes
Pollutant
n-Decane
n-Dodecane
n-Eicosane
Average Group Removal
POTW Removal <%)
9
95
92
65
Source of Data
KREL Treatability Database -
Domestic and Industrial Wastewater
Edit
RREL Treatability Database -
Domestic and Industrial Wastewater
Edit
RREL Treatability Database -
Domestic and Industrial Wastewater
Edit
—
7-31
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Chapter 7 - Pollutants Selected for Regulation
Table 7-12
Pollutants Considered for Regulation for Chemical Precipitation and BAF
after the Pass-Through Analysis
Chemical Precipitation
Bulk Nonconventionals
Chemical Oxygen Demand (COD)
Total Organic Carbon (TOC)
Total Petroleum Hydrocarbons (measured as SGT-HEM)
Priority Volatile Organics
1,1,1 -Trichloroethane
Ethylbenzene
Tctrachloroethene
Toluene
Priority Semivolatile Organics
Bis(2-ethylhexyl) Phthalate
Butyl Benzyl Phthalate
Di-n-octyl Phthalate
Naphthalene
Nonconvcntional Volatile Organics
2-Butanone
2-Methyl-2-pentanone
m-Xylene
o-&p-Xylene
Nonconventional Volatile Organics
2-Methyhiaphthalene
Priority Metals and Elements
Cadmium
Chromium
Copper
Lead
Zinc
7-32
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Chapter 7 - Pollutants Selected for Regulation
Table 7-12 (Continued)
Chemical Precipitation
Nonconventional Metals and Elements
Manganese
Titanium
DAF
Bulk Nonconventionals
Total Petroleum Hydrocarbons (measured as SGT-HEM)
Priority Volatile Organics
1,1,1-Trichloroethane
Chlorobenzene
Chloroform
Ethylbenzene
Methylene Chloride
Tetrachloroethene
Toluene
Priority Semivolatile Organics
Bis(2-ethylhexyl) Phthalate
Di-n-butyl Phthalate
Di-H-octyl Phthalate
Naphthalene
Nonconventional Volatile Organics
2-Butanone
4-Methyl-2-pentanone
wz-Xylene
o-&p-Xylene
Nonconventional Semivolatile Organics
2-Methylnaphthalene
oc -Terpineol
7-33
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Chapter 7 - Pollutants Selected for Regulation
Table 7-12 (Continued)
DAJ?
Priority Metals and Elements
Antimony
Chromium
Copper
Nickel
Zinc
Nonconventional Metals and Elements
Manganese
Tin
Titanium
SOT-HEM - Silica gel treated-hexane extractable material.
7-34
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Chapter 7 - Pollutants Selected for Regulation
compounds and mineral oils are treated less effectively by POTWs than many other carbon-
containing compounds; therefore, EPA has selected TPH for proposed regulation. Because
TPH measures a variety of organic compounds, it can also serve as an indicator pollutant for
other organic pollutants shown on Table 7-12.
EPA believes that controlling the following volatile organic pollutants will
control the remaining volatile organic pollutants shown on Table 7-12:
Ethylbenzene;
Tetrachloroethene;
Toluene;
/H-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 7-12. As shown in Table
7-5, these pollutants are detected frequently and at relatively high concentrations.
EPA believes that controlling the following semivolatile organic pollutants will
control the remaining semivolatile organic and phthalate pollutants shown on Table 7-12:
• Bis(2-ethylhexyl) phthalate; and
• Naphthalene.
EPA selected these pollutants because they are detected frequently, at relatively high
concentrations, and are relatively toxic.
EPA believes that controlling the following metal pollutants will control the
remaining metal and elemental pollutants on Table 7-12:
• Copper;
• Lead (Note: lead does not pass through for DAF); and
• Zinc.
These metals were selected because the minimum solubilities of their associated metal
hydroxides span a pH range of approximately 7 through 12. Controlling the pollutants within
this pH range will also control other metal pollutants of concern. Most metals will be treated
by chemical precipitation or dissolved air flotation within this range. These metals were also
selected because they were detected most frequently (in nearly 100% of untreated wastewater
samples) and in the highest concentrations.
7-35
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Chapter 7 - Pollutants Selected for Regulation
7.5
1.
2.
3.
References
U.S. Environmental Protection Agency. List of Lists: A Catalog of Analvtes
and Methods. 121W-4005. Washington, D.C., August 1991.
U.S. Environmental Protection Agency. Fate of Priority Pollutants in Publicly
Owned Treatment Works. EPA-440/1-82/303. Washington, DC, September
1982.
U.S. Environmental Protection Agency. The Risk Reduction Engineering
Laboratory (RREL) Treatabilitv Database. Version 5.O., Cincinnati, OH.
7-36
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•Chapter 8 - Pollution Control Technologies
CHAPTER 8
POLLUTION PREVENTION, RECYCLING, TREATMENT, AND DISPOSAL
TECHNOLOGIES EMPLOYED BY THE INDUSTRIAL LAUNDRIES INDUSTRY
8.1
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
information:
• Section 8.2 discusses the environmental management hierarchy
established by the United States Congress and EPA;
• Section 8.3 discusses the pollution prevention measures used in the
industrial laundries industry;
• Section 8.4 discusses the pollution recycling measures used in the
industrial laundries industry;
• Section 8.5 discusses the major wastewater treatment technologies used
by the industry;
• Section 8.6 discusses the pollution disposal measures used by the
industrial laundries industry; and
8.2
• Section 8.7 presents the references used.
The Environmental Management Hierarchy
As it applies to industry, the environmental management hierarchy (outlined in
Figure 8-1) stipulates that:
• Facilities should reduce pollution at the source whenever feasible;
• Facilities should recycle pollution 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
8-1
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Chapter 8 - Pollution Control Technologies
I.
Source Reduction
A. Product Changes
1. Design for Less Environmental Impact
2. Increased Product Life
B. Process Changes
1.
2.
3.
Input Material Changes
• Material Purification
• Substitution of Less Toxic Materials
Technology Changes
Layout Changes
Increased Automation
Improved Operating Conditions
Improved Equipment
New Technology
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
HI. Treatment
IV. Disposal
Reference: United State EPA, Office of Research and Development. Facility Pollution
Prevention Guide, EPA/600/R-92/088, May 1992.
Figure 8-1. Environmental Management Options Hierarchy
8-2
-------
Chapter 8 - Pollution Control Technologies
• 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 will be presented in Sections 8.3 and 8.4 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
8.3 through 8.6 of this document.
8.3
Pollution Prevention/Source Reduction in the Industrial Laundries
Industry
Pollution prevention, established as the most desirable option of pollution
control 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 policy, declaring that the
generation of pollutants should be prevented or reduced during the production cycle whenever
feasible.
In the 1994 Industrial Laundries Industry Detailed Questionnaire, EPA asked
industrial laundries to provide information on the types of pollution prevention activities
performed at their facilities. Of the 193 in-scope industrial laundries responding to the
detailed questionnaire (in-scope facilities are those that meet the definition of an industrial
laundry as presented in Chapter 6, regardless of annual production), 47 industrial laundries
reported having a pollution prevention policy (45 of these facilities attached copies of the
plans to the questionnaire), and 54 industrial laundries stated that they plan to implement
additional pollution prevention activities in the near future.
8-3
-------
Chapter 8 - Pollution Control Technologies
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 8.3.1 and
8.3.2 of this document.
8.3.1
Preprocess Pollution Prevention Activities
Seventy-nine (79) in-scope industrial laundries responding to the detailed
questionnaire reported conducting preprocess pollution prevention activities. Table 8-1
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 8-1, the performance of preprocess pollution prevention activities does not
appear to be related to facility size.
Table 8-2 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. Thirteen 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/ah- stripping of volatiles
from items. During the IPS, 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.
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
Industrial earments
Percentage of Facilities Refusing Items
Facilities Refusing Item* with Free Liquids
' 48%
28%
15%
Facilities Refusing Certain Items
27%
32%
12%
8-4
-------
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8-5
-------
Chapter 8 - Pollution Control Technologies
Table 8-2
Types of Preprocess Pollution Prevention Activities Reported
in the Detailed Questionnaire
Activity ,
Refusal of Items with Free Liquids
Refusal of Certain Items
Centrifugation of Items to Remove Liquids
Steam/Air Stripping of Volatile Organics
from Items
Items Presorted to Remove Objects
Items Dry-Cleaned Before Water Washing
Number of
Faculties
Performing
Activity
54
41
6
22
3
53
Percentage of Total
Number of Facilities
Reporting Pre-Process
Activities*
68%
52%
8%
3%
4%
6%
'Percentages are based on 79 industrial laundries that reported preprocess activities.
One of these facilities 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.
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.
8-6
-------
Chapter 8 - Pollution Control Technologies
Of the six facilities (in Table 8-2) that reported centrifugation to remove
liquids, four performed this activity on shop or printer towels. Likewise, both of the facilities
that reported steam/air stripping of volatile organics from items also performed this activity on
shop or printer towels. 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.
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 waterwashing and steam stripping (steam tumbling), during site visit and
sampling activities. Section 8.3.12 discusses these technologies and their application in the
industry in more detail.
8.3.2
In-Process Pollution Prevention Activities
Fifty (50) industrial laundries reported conducting in-process pollution
prevention activities. Table 8-3 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 8-3, the performance of in-process pollution prevention activities does not
appear to be related to facility size.
Table 8-4 lists all in-process pollution prevention activities reported by
industrial laundries. The most common types of in-process pollution prevention activities
reported by the industrial laundries were:
8-7
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8-8
-------
Chapter 8 - Pollution Control Technologies
Table 8-4
Types of In-Process Pollution Prevention Activities Reported
in the Detailed Questionnaire
Activity
Improved Training of Employees
Change in Laundering/Dry Cleaning Chemicals Used
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
N*»a>1>e* Ktt
Facilities
Performing
Activity
19
20
18
i10
6
3
1
1
1
Percentage ol Total
Number of Facilities
Reporting In-Process
Activities1
38%
40%
36%
20%
12%
6%
2%
2%
2%
'Percentages are based on 50 industrial laundries that reported in-process pollution prevention activities.
8-9
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Chapter 8 - Pollution Control Technologies
A change in the use of laundering/dry-cleaning chemicals (40 percent);
Improved training of employees (i.e., chemical safety, proper handling
of equipment) (38 percent); and
• Installation of a liquid injection system to add wash chemicals (36
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 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 non-hazardous and hazardous waste streams;
• Improve standard operating procedures;
• Establish an inventory control system;
• Perform routine and preventative maintenance on facility equipment;
• Incorporate a paper recycling program;
• 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;
8-10
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Chapter 8 - Pollution Control Technologies
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 less refractory
emulsions.
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 for 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 (e.g., 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.
8.4
Pollution Recycling/Resource Conservation and the Industrial Laundries
Regulatory Development Process
As established in the environmental management hierarchy, pollution that
cannot be prevented or reduced in an environmentally safe manner should be recycled
whenever feasible. Pollution recycling conducted in an environmentally safe manner shares
many of the advantages of pollution prevention/source reduction. Pollution 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 are taking
advantage of opportunities to conserve energy through heat exchange. 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 8.4.1 and 8.4.2 of this document.
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8.4.1
Chapter 8 - Pollution Control Technologies
Wastewater 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-six of the 193 in-scope industrial laundries responding to the detailed
questionnaire (24 percent) reported recycling a portion of the water used by the facility as
process makeup water. Twenty-seven of these facilities (59 percent) reported reusing
noncontact cooling water as process makeup water. Twenty facilities (43 percent) reported
recycling/reusing laundry wastewater back into the water-washing process before the
wastewater had been treated. One of these facilities 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 (19 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.
8.4.2
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. 663 of the 1500 facilities responding to the
screener questionnaire (44 percent) reported operating a heat reclaimer at their facility.
8.5 Wastewater Treatment Technologies in the Industrial Laundries Industry
As established hi the environmental management hierarchy, pollution that
cannot be prevented or recycled in an environmentally safe manner should be treated
whenever feasible. This section describes major wastewater treatment technologies used in the
industrial laundries industry, based on responses to the detailed questionnaire. Sections 8.5.1
through 8.5.14 describe the wastewater treatment technologies used in the industry. These
treatment technologies include:
Gravity settling (Section 8.5.1);
Stream splitting (Section 8.5.2);
Screening (Section 8.5.3);
Equalization (Section 8.5.4);
Chemical emulsion breaking (Section 8.5.5);
Chemical precipitation (Section 8.5.6);
Dissolved air flotation (DAF) (Section 8.5.7);
Sludge dewatering (Section 8.5.8)j
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Chapter 8 - Pollution Control Technologies
pH adjustment (Section 8.5.9);
Ultrafiltration (Section 8.5.10);
Centrifugation (Section 8.5.11);
VOC removal technologies (Section 8.5.12);
Oil/water separation (Section 8.5.13); and
Media filtration (Section 8.5.14).
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 8-5 presents the total number of facilities
(out of 193 in-scope facilities responding to the detailed questionnaire) that reported using
each of these technologies.
8.5.1
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) (2).
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
Although only fifty-one percent of in-scope industrial laundries responding to
the detailed questionnaire (98 of 193) reported treating their wastewater through gravity
settling, every facility visited by EPA has a settling basin in place at their facility. Therefore,
EPA believes all industrial laundries have settling basins in place at their facilities and can
incorporate gravity settling and solids removal as part of their treatment train without
modification of their wastewater treatment equipment. All 98 facilities reporting the use of
gravity settling also report removing sludge from the gravity settling unit. The gravity
settling units used at these 98 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 6 facilities) and polymer (added by 2 facilities).
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Chapter 8 - Pollution Control Technologies
Table 8-5
Number of Facilities Responding to Detailed Questionnaire Using
Wastewater Treatment Technologies
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
98
20
146
147
11
19
36
59
42
2
4
12
28
10
Percentage of Total Ntstnfoer of
Industrial Laundries Responding to
the Detailed Questionnaire1
51%
10%
76%
76%
6%
10%
19%
31%
22%
1%
2%
6%
15%
5%
Percentages are based on the 193 in-scope industrial laundries that responded to the detailed questionnaire.
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Chapter 8 - Pollution Control Technologies
8.5.2
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 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 recycle or reuse the less
concentrated streams.
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 (3).
In addition to the facility's process wastewater trench and sump system being
split, 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 and used
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
to enable them to divert the wastewater. 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.
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Chapter 8 - Pollution Control Technologies
Industry Application
Ten percent of in-scope industrial laundries responding to the detailed
questionnaire (20 of 193) 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.
8.5.3
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.
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 (4). 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 (5).
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 (4). Hydrosieve 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 (6). Figure 8-2 presents a diagram of a shaker screen.
A rotary screen consists of a circular 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
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Chapter 8 - Pollution Control Technologies
the chamber toward the exterior, with solids collection on the interior surface of the
screen (2).
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 8.5.1, 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 (76 percent) perform at least one
screening operation before discharging their wastewater (146 out of 193 in-scope facilities
responding to the detailed questionnaire reported having a screen(s)). Twenty-six facilities
perform coarse screening only, using a bar screen.
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 (67 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; six facilities use both static and mechanical
fine screening; and two facilities use all three types of screens: coarse, static fine, and
mechanical fine screening.
8.5.4
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,
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Chapter 8 - Pollution Control Technologies
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 from 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 (7). Section 8.5.9 (pH
Adjustment) discusses equalization units that use pH-adjusting chemicals.
Industry Application
Seventy-six percent of the in-scope industrial laundries responding to the
detailed questionnaire (147 of 193) reported treating their wastewater through equalization.
None of these facilities reported adding chemicals to their equalization units. None of the
facilities treating their wastewater through equalization reported collecting solids from the
equalization unit. The majority (66 percent) of the facilities treating their wastewater through
equalization 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.
8.5.5
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
demulsificatibn by causing molecular collisions that help agglomerate 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.
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Chapter 8 - Pollution Control Technologies
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 8-3 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 layer of oil that flows or is pumped from the unit. Figure 8-4 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 (8).
Industry Application
Eleven of the 193 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 are used most frequently (at 5 of
the facilities) to collect the demulsified oil from the surface of wastewater. Eight facilities
demulsify the oil in a batch process with a median residence time of six 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). Eight 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
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Chapter 8 - Pollution Control Technologies
skimmer
sludge
pan
decanter
Figure 8-3. Batch Chemical Emulsion Breaking Unit
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09
I
5
191)
13
5
w>
1
.2
en
I
1
s
09
I
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u
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Chapter 8 - Pollution Control Technologies
often used as a pretreatment to other technologies; six of the eleven facilities reported using
chemical emulsion breaking as a pretreatment to either dissolved air flotation (three facilities)
or chemical precipitation (three facilities). Ten of the eleven facilities that use chemical
emulsion breaking reported disposing of the demulsified oil at an oil reclaimer.
8.5.6
Chemical Precipitation
General Description
Chemical precipitation is one of the most commonly used processes in water
treatment (9). 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 (8).
In chemical precipitation units, coagulation and fiocculation 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 (FeClg), and
aluminum sulfate or alum (A12(SO4)3*18 H2O). Flocculent aids, typically anionic polymers,
are added to further enhance the agglomeration of the particles (7).
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 resulting sludge is
removed for further dewatering and subsequent disposal. Figure 8-5 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
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Chapter 8 - Pollution Control Technologies
chemical
addition
raw
wastewater
Figure 8-5. Batch Chemical Precipitation System
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Chapter 8 - Pollution Control Technologies
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 then: single unit design and relatively short required retention
tune, continuous chemical precipitation units are space efficient. However, the performance
of continuous systems can be disrupted if wastewater conditions are varied. Figure 8-6
presents a diagram of a continuous chemical precipitation system.
Industry Application
Ten percent of the in-scope industrial laundry facilities responding to the
detailed questionnaire (19 of 193) 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 (14 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. 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 (21%)
1 (5%)
Number Of Facilities
Treating Entire; Waste
Stream
4 (21%)
10 (53%)
All 19 facilities using chemical precipitation reported operating a continuous
treatment unit. No facilities reported batch chemical precipitation operation.
8.5.7
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 i 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
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&
I
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1
1
ofc
2
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Chapter 8 - Pollution Control Technologies
(4). 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 (4).
DAF has been applied extensively in the water treatment industry. Specifically,
DAF is used 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 typically operated on a continuous
basis and incorporate the chemical mix tanks, flotation vessels, and sludge collection into a
single unit. Figure 8-7 presents a diagram of a DAF unit.
Industry Application
Nineteen percent of the in-scope industrial laundry facilities responding to the
detailed questionnaire (36 of 193) reported treating their wastewater using DAF. All of these
facilities add chemicals to the DAF and collect the DAF float sludge. (Four additional
facilities that reported using DAF were excluded because they do not add chemicals or 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 (metal salt)
Polymer
Polymer, flocculent
Polymer, flocculent, metal salts
Number of Facilities Treating Waste Stream
14 (39%)
i 14 (39%)
. , 5 (14%)
3 (8%)
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DAFunit.
8.5.8
Chapter 8 - Pollution Control Technologies
Thirteen facilities also add sulfuric acid to the wastewater before it enters the
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;
• 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 (2).
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 (2). 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
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Chapter 8 - Pollution Control Technologies
earth or perlite) are usually required to precoat the filter (2). Figure 8-8 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) mat 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 8-9 presents a diagram of a filter press.
Industry Application
Thirty-one percent of the in-scope industrial laundry facilities responding to the
detailed questionnaire (59 of 193) reported dewatering their sludge before disposal. The types
of dewatering devices reported include:
Plate and frame filters
Rotary vacuum filters
Sludge dryers
Bag filters
Other
34 facilities (58%)
16 facilities (27%)
4 facilities (7%)
2 facilities (5%)
2 facilities (5%)
In the industrial laundries industry, most of the sludge that is dewatered comes
from DAF or chemical precipitation units. Nearly half of the dewatering devices (28 of 59
facilities) process sludge from a DAF unit. Fifteen 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 16 percent for the
underwatered sludge. Facilities that dewater a sludge reported an average solids content of 62
percent for the dewatered sludge.
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I
1
1
I
!
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: • Chapter 8 - Pollution Control Technologies
Twenty-nine 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
13 (45%)
10 (34%)
5 (17%)
5 (17%)
4 (14%)
Note that facilities that add more than one chemical are represented twice in the above table.
8.5.9
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
Twenty-two percent of in-scope facilities responding to the detailed
questionnaire (42 of 193) 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 47 pH adjustment units.
Acid (usually sulfuric) is added to the pH adjustment unit most frequently (42 of 47).
However, sodium hydroxide (4 of 47), and lime (2 of 47) are also added to the pH adjustment
units. Sixty-eight percent of the pH adjustment units discussed in the detailed questionnaire
(32 of 47) have one or more mixers. The average residence time of all 47 units at the 42
facilities is 2.1 hours.
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Chapter 8 - Pollution Control Technologies
8.5.10 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 (8). Ultrafiltration
and microfiltration have the benefit of removing entrained solids and oils from wastewater
with lower capital costs than chemical treatment (10). 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.
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 recently changed out after 4.5
years of operation. 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.
8.5.11
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
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: Chapter 8 - Pollution Control Technologies
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
(2).
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 by the centrifugal forces.
Industry Application
Two percent of in-scope industrial laundries responding to the detailed
questionnaire (4 of 193) reported treating their wastewater with centrifugation. While only
three of the four facilities reported removing sludge generated during centrifugation, EPA
believes that all facilities treating their wastewater with centrifugation remove the sludge
generated.
8.5.12 Volatile Organic Compound (VOC) Removal Technologies
General Description
In-Process Volatile Organic Compound (VOC) Removal
Two in-process VOC removal technologies were investigated for the industrial
laundries industry: dry cleaning and steam tumbling. Both dry cleaning and steam tumbling
effectively remove 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). These pollutants are recovered from the solvent through
distillation and are then disposed. The distilled solvent may be then reused in subsequent dry-
cleaning processes. In steam tumbling, soiled items are agitated within a modified washer/
extractor while steam is injected into the chamber. The tumbling items contact the steam,
which removes the VOCs. The steam is condensed, and the pollutants are recovered through
a phase separation and disposed.
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Chapter 8 - Pollution Control Technologies
End-Of-Pipe VOC Removal
Two methods of removing VOCs from process wastewater that have been
demonstrated in the industrial laundries industry are carbon adsorption and air stripping.
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
contact with the activated carbon, the dissolved VOCs adsorb onto the surface of the activated
carbon. Figure 8-10 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.
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
In-Process Volatile Organic Compound (VOO Removal
Two of the 193 in-scope industrial laundries responding to the detailed
questionnaire (one percent) reported steam tumbling items before water-washing and five of
the 193 facilities (three percent) reported dry cleaning items before water-washing.
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Chapter 8 - Pollution Control Technolojies
influent
dispersion
mechanism
bed
support
screen
influent
effluent
Figure 8-10. Fixed Bed Activated Carbon Adsorption Column
8-37
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Chapter 8 - Pollution Control Technologies
End-Of-Pipe VOC Removal
Three of the 193 in-scope industrial laundries responding to the detailed
questionnaire (2 percent) reported operating air strippers to remove VOCs from their process
wastewater. However, EPA is aware that one of these facilities does not operate their air
stripper. Two of the 193 industrial laundries (one percent) reported operating activated
carbon adsorption columns to remove VOCs from their process wastewater.
8.5.13 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
chemical 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 slamming 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 8-3 is similar to the type of
skimming device used in oil/water separators.
Industry Application
Fifteen percent of industrial laundries responding to the detailed questionnaire
(28 of 193) report treating their wastewater through oil/water separation. These facilities
employ various devices to remove the oil that has risen to the surface of the wastewater.
These include:
• Oil skimmer (64 percent);
• Oil mop (14 percent);
• Coalescer (11 percent);
• Gravity (7 percent); and
• Decanter (4 percent).
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is 9.5 hours.
8.5.14
Chapter 8 - Pollution Control Technologies
The average residence time of the wastewater in the oil/water separation units
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 that
the 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 193 in-scope industrial laundries responding to the detailed
questionnaire (19 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). Five media filtration
units used sand alone (42 percent); two media filtration units operated with sand, anthracite,
and garnet as the filter media (17 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 3 times per day.
8.6
Pollution Disposal Practices in the Industrial Laundries Industry
As established in the environmental management hierarchy, pollution disposal
or release into the environment should be employed only as a last resort and should be
conducted in an environmentally safe manner. All 193 in-scope industrial laundries
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Chapter 8 - Pollution Control Technologies
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 193) also reported discharging a portion of their
wastewater to land application.
Thirteen percent of these industrial laundries (25 of 193) reported having a
portion of their process wastewater contract-hauled off-site for disposal. Facilities contract-
hauling a portion of their wastewater off-site store the wastewater to be contract-hauled in
above ground storage tanks so that the water can be hauled off-site in bulk. Wastewater is
typically hauled off-site in 5,000 gallon increments, which is the capacity of most vacuum
tankers used to haul the wastewater. The frequency of bulk wastewater pickups depends on
the amount of time required to generate 5,000 gallons of wastewater. The wastewater,
handled as non-hazardous waste, may be hauled off-site for treatment to a Treatment Storage
Disposal Facility (TSDF) or to a Centralized Waste Treater (CWT) (11). Facilities having
only a portion of their wastewater hauled off-site also have stream splitting capability as
discussed in Section 8.5.2 of this document.
8.7
1.
2.
3.
4.
5.
6.
References
U.S. Environmental Protection Agency. Pollution Prevention at Industrial
Laundries: Assessment Observations and Waste Reduction Options.
Washington, DC, July 1995. EPA 820-R-95-010.
Metcalf and Eddy, Inc. Wastewater Engineering: Treatment Disposal, and
Reuse. Third Edition. McGraw-Hill Inc., 1991.
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.
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.
The Dober Group. Presenting the Concepts of Wastewater Pretreatment
Equipment for the Denim and Industrial Laundry Industries. Frank Prendergast,
Process Engineer, December 12, 1993.
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..
8-40
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7.
8.
9.
10.
11.
Chapter 8 - Pollution Control Technologies
Eckenfelder, W. Wesley, Jr. Industrial Water Pollution Control. Second Edition.
McGraw-Hill Co., 1989.
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.
American Water Works Association. Water Quality and Treatment: A
Handbook of Community Water Supplies. Frederick W. Pontius. McGraw-
Hill, Inc., 1990.
Abcor, Inc. Ultrafiltration for Dewatering of Waste Emulsified Oils.
Steven D. Pinto, June 7, 1978.
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.
8-41
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Chapter 9 - Treatment Performance Data
CHAPTER 9
TREATMENT PERFORMANCE DATA USED FOR THE DEVELOPMENT OF
LONG-TERM AVERAGES, VARIABILITY FACTORS, AND STANDARDS
9.1 Introduction
This chapter discusses the treatment performance .data collected by and
available to EPA for use in calculating long-term average concentrations for the pollutants of
concern and long-term averages, variability factors, and standards for the constituents and
pollutant parameters proposed for regulation. The pollutants of concern and the pollutants
proposed for regulation are presented in Chapter 7. The following information is presented in
this chapter:
• Section 9.2 describes and classifies the sources of the treatment
performance data used by EPA in the calculation of the long-term
averages, variability factors, and standards into six treatment technology
groups;
• Section 9.3 describes the data-editing procedures used to identify data
points considered appropriate for calculating long-term averages,
variability factors, and standards for the five postlaundering treatment
technology groups;
• Section 9.4 presents the long-term averages for the five postlaundering
treatment technology groups for the pollutants of concern;
• Section 9.5 presents the long-term average concentrations, variability
factors, and concentration-based standards calculated for the five
postlaundering treatment technology groups for the pollutants proposed
for regulation;
• Section 9.6 presents the methodology used to calculate target effluent
concentrations for steam tumbling, the prelaundering treatment
technology group;
• Section 9.7 presents EPA's analysis on the development of mass-based
standards; and '.
• Section 9.8 presents the references used.
9-1
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9.2
Chapter 9 - Treatment Performance Data
Sources of Treatment Technology Performance Data From Well-Designed
and Well-Operated Treatment Systems
EPA used two sources of treatment performance data to calculate the long-term
average concentrations, variability factors, and standards for industrial laundries wastewater
treatment systems: EPA industrial laundry sampling data and Detailed Monitoring
Questionnaire (DMQ) data. Chapter 3 describes these sources. EPA first considered
sampling data from industrial laundries with well-designed and well-operated treatment
systems representing the various treatment technologies to calculate long-term average
concentrations, variability factors, and standards. Chapter 8 describes the treatment
technologies used as the basis for the proposed standards. EPA also used DMQ data from
facilities using treatment technologies equivalent to the treatment technologies sampled by
EPA. Sections 9.2.1 and 9.2.2, respectively, discuss the EPA industrial laundry sampling data
and the DMQ data used for standards development.
9.2.1
Industrial Laundry Sampling Program Data
EPA considered industrial laundry wastewater data from the following Agency
sampling programs for use in calculating long-term average concentrations, variability factors,
and standards: the 1985-1987 Industrial Technology Division (ITD)/Resource Conservation
and Recovery Act (RCRA) Sampling Program and the 1993-1996 sampling program. No data
from the 1985-1987 ITD/RCRA Sampling Program were used to calculate long-term averages,
variability factors, and standards. However, data from the 1993-1996 sampling program were
used in these calculations. The identification of sampling data representative of well-designed
and well-operated treatment systems from these sampling programs is presented below.
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 data from facilities with well-designed and well-operated
treatment systems representative of wastewater treatment technologies used as the basis for the
proposed standards. EPA determined that none of the ITD/RCRA Sampling Program data
could be used to calculate long-term average concentrations, variability factors, or 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 was not representative of the wastewater from the facility. A third facility used
ultrafiltration as its main treatment technology. EPA does not consider ultrafiltration to be an
effective treatment 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 have
tried using ultrafiltration but have subsequently replaced the ultrafilter with a different
9-2
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Chapter 9 - Treatment Performance Data
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 for standards development.
1993-1996 EPA Sampling Program
EPA collected wastewater samples from eight industrial laundries between 1993
and 1996 as part of the data-gathering effort for development of the proposed industrial
laundries rule. Facilities were selected based on site visits and responses to the 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 data for all of the
pollutants of concern. The eight sampled industrial laundries used one of the following major
wastewater treatment technologies as part of their overall treatment system (one sampled
facility used two major wastewater treatment technologies, chemical precipitation and organics
control):
Chemical emulsion breaking;
Dissolved air flotation (DAF); :
Chemical precipitation;
Ultrafiltration;
Vacuum degassing; and
Organics control (steam tumbling). ;
In addition to classifying the eight sampled :facilities into groups depending on
the treatment technology used by the facility, EPA also classified the eight facilities into
groups depending on the type of wastewater treated by the treatment technology. Some of the
sampled facilities treated all of their process wastewater while others treated only the 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).
i
One facility sampled by EPA steam-tumbled its shop and printer towels/rags
prior to water washing. The quantity and type of data available for steam tumbling were
different from the data available for the other treatment technologies. EPA developed target
effluent concentrations for this prelaundering treatment technology group instead of long-term
averages, variability factors, and standards. Section 9.6 of this document presents the
methodology used to calculate the target effluent concentrations for steam tumbling.
The data obtained by EPA during sampling episodes at industrial laundries
using ultrafiltration and vacuum degassing do not demonstrate effective treatment of industrial
laundry wastewater. EPA's ultrafiltration data represent one day of treatment of wastewater
from laundering of only printer towels. In addition, as discussed earlier in this section,
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Chapter 9 - Treatment Performance Data
ultrafilters are easily clogged from oil and grease in industrial laundry wastewater. Vacuum
degassing, which was sampled at one facility, is used to remove volatile organics from
wastewater. The sampling data for vacuum degassing did not demonstrate effective removal
of volatile organics. Because ultrafiltration and vacuum degassing were not found to be
effective in treating industrial laundry wastewater, EPA did not calculate long-term average
concentrations, variability factors, or standards for these treatment technologies.
The remaining sampling data represented the following five treatment groups
based on 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 six facilities representing these five postlaundering
treatment technology groups were used to calculate long-term average concentrations,
variability factors, and standards. The number of sampled facilities representing each
postlaundering treatment technology group is presented in the following table.
Number of Sampled Facilities Representing Each Treatment Technology Group
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 Alt
Facility Process
Wastewater
1
9.2.2
Detailed Monitoring Questionnaire (DMQ) Data
In 1995, EPA developed and mailed the DMQ to 37 facilities throughout the
United States (as described in Chapter 3). In response to this questionnaire, the 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
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Chapter 9 - Treatment Performance Data
could be used to represent any of the five wastewater treatment technology groups sampled by
EPA.
The wastewater treatment technology groups sampled by EPA include treatment
through chemical emulsion breaking, DAF, and chemical precipitation. EPA used the
following design and operating criteria to determine whether the DMQ data were
representative of one of these three major wastewater treatment technologies sampled:
• Chemical Emulsion Breaking~pH of wastewater is adjusted with acid
and an oil removal mechanism is in place.
• DAF--fiocculation and coagulation chemicals are added, an air injection
mechanism is in place, and a removal system for float sludge is in
place.
• Chemical Precipitation—flocculation and coagulation chemicals are
added and a settling mechanism is in place.
EPA determined that 17 of the 37 DMQ facilities did not provide data
representative of these treatment technologies sampled by EPA. Facility diagrams for the
remaining 20 facilities, which were using one of these three treatment technologies, were then
examined to determine if the sampling points for which data were reported represent final
effluent from the treatment technology. EPA determined that 9 of the 20 facilities did not
meet this criterion. (EPA did not receive paired data for any of the 20 DMQ facilities using
one of these three wastewater treatment technologies sampled by EPA. Therefore, the
criterion requiring data to be representative of the influent to one of these three treatment
technologies could not be used.) The remaining eleven 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). These data were used in conjunction with EPA's sampling data to calculate long-
term average concentrations, variability factors, and standards.
9.3
Evaluation of Treatment Performance Data
After identifying available treatment performance data, EPA identified specific
data points that were not considered representative of well-designed, well-operated treatment
systems. These data points were not used to calculate long-term averages, variability factors,
and standards for each of the five wastewater treatment technology groups incorporating
chemical emulsion breaking, DAF, or chemical precipitation as the primary treatment unit.
The following criteria were used to identify these data points:
• Assessment of performance of the treatment system at the sampled
facilities and DMQ facilities identified above including identification of
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document.
9.3.1
Chapter 9 - Treatment Performance Data
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 9.3.1 through 9.3.4 of this
Assessment of Treatment System Performance and Identification of
Process Upsets
The available data were reviewed to determine if the treatment systems for
which effluent data were available were well operated during the time when samples were
collected. The criteria used to determine good system operation are dependent on the
treatment technology being evaluated; the following parameters are indicative 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 removal of oil and grease; and
• Chemical Precipitation: removal of TSS and removal of 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 the sampling episode.
DMQ data could not be evaluated using this criterion because no facilities representing one of
the three major wastewater treatment technologies sampled provided paired influent and
effluent data. Data that did not meet the evaluation criterion were flagged as unusable.
9.3.2
Identification of Pollutants Not Treated by the Treatment Technology
The data for each EPA sampling episode were reviewed 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
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Chapter 9 - Treatment Performance Data
concentration of the pollutant in the influent samples, the data were flagged as unusable.
DMQ data could not be evaluated using this criterion because no paired influent and effluent
data were provided.
9.3.3
Identification of Pollutants Not Present in Influent Samples at Sufficient
Concentrations to Evaluate Treatment Effectiveness
The data for each EPA sampling episode were reviewed to determine if a
pollutant of concern 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 ten 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
standards. DMQ data could not be evaluated using this criterion because no paired influent
and effluent data were provided.
9.3.4
Identification of Treatment Performance Data With Inconsistent Detection
Limits
The data for each pollutant at each sampling episode were reviewed 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. These data were not used in calculating long-term averages,
variability factors, and standards, although other data were available to use in calculating
values for these pollutants.
9.3.5
Identification of Data Considered a Lower Limit of the Actual Value
The sampling data were reviewed 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, variability factors, and standards.
9.4
Long-Term Average Concentrations for the Pollutants of Concern
The data meeting the review requirements presented in Section 9.3 of this
document were used to calculate long-term average concentrations for the 72 pollutants of
concern for each of the five postlaundering treatment technology groups. 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
9-7
-------
Chapter 9 - Treatment Performance Data
calculations for data points reported as non-detects. The methodology used to calculate long-
term averages, variability factors, and standards is presented in the Statistical Support
Document for Proposed Pretreatment Standards for Existing and New Sources for the
Industrial Laundries Point Source Category (1). EPA calculated the overall long-term average
concentrations for each pollutant of concern by finding the median of the episode long-term
average concentrations. When both sampling and DMQ data met the data review criteria for
a specific pollutant for a treatment technology group, EPA used data from both sampled and
DMQ facilities to calculate long-term average concentrations. When only EPA sampling data
met the data review criteria, EPA only used data from EPA sampled facilities to calculate
long-term average concentrations. When only DMQ 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 9-1 presents the long-term average concentrations for each pollutant of
concern for each of the five postlaundering treatment technology groups. The treatment
technology groups listed in Table 9-1 are defined as follows:
• CEB-Heavy represents data from facilities using chemical emulsion
breaking of heavy wastewater;
• DAF-Heavy represents data from facilities using DAF of heavy
wastewater;
• CP-Heavy represents data from facilities using chemical precipitation of
heavy wastewater;
• DAF-A11 represents data from facilities using DAF of all facility process
wastewater; and
• CP-A11 represents data from facilities using chemical precipitation of all
facility process wastewater.
9.5
Long-Term Average Concentrations. Variability Factors, and Standards
for the Pollutants Proposed for Regulation
For the 11 pollutants proposed for regulation, EPA calculated long-term
averages, variability factors, and standards for the five postlaundering treatment technology
groups. As presented in Section 9.4 of this document, long-term averages were calculated
using equations derived from an adapted delta-lognormal model that accounts for effluent
samples with a pollutant concentration at the detection limit. Variability factors were also
calculated using equations from the adapted delta-lognormal model. Standards were
calculated as the product of the long-term average and the variability factor. Section 9.4
9-8
-------
Chapter 9 - Treatment Performance Data
Table 9-1
Overall Long-Term Average (LTA) Concentrations for the Five
Postlaundering Treatment Technology Groups for the Pollutants of Concern
Pollutant of concern
, Median LTA {fflg/D
CEB-HWVy*
PAF-HfcSVy2
CP-Heavy3
PAF-AH4
Conventionals
Biochemical Oxygen Demand 5-Day (BOD5)
Oil and Grease (measured as HEM)
Total Suspended Solids (TSS)
. 1040
268
259
1310
230
487
1390
38.2
56.3
497
37.8
85.5
CP-AN*
499
28.5
119
Priority Organics
1 ,1 ,1 -Trichloroethane
1 ,2-Diphenylhydrazine
4-Chloro-3 -methylphenol
Bis(2-ethylhexyl) Phthalate
Butyl Benzyl Phthalate
Chlorobenzene
Chloroform
Di-n-butyl Phthalate
Di-n-octyl Phthalate
Ethylbenzene
Isophorone
Methylene Chloride
Naphthalene
Phenol
Tetrachloroethene
Toluene
trans-\ ,2-Dichloroethene
Trichloroethene
—
—
0.205
0.462
._
—
—
0.0100
0.0307
0.305
—
—
0.104
—
0.286
0.543
_
—
...
—
~
0.852
0.182
T-
-_-
0.647
---
1.56
:..
—
'...
...
u._
2.50
,—
; —
_.
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
...
--
0.109
0.0342
._
—
-_
0.0342
0.269
0.297
...
0.0583
„.
0.259
1.05
—
—
Nonconvcntional Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
—
0.0458
1.21
4.68
0.129
7.42
—
0.0100
"-
17.4
0.116
13.6
3.23
0.0125
—
9-9
-------
Chapter 9 - Treatment Performance Data
Table 9-1 (Continued)
Pollutant of Concern
Median LTA (mg/L)
CEB-Heavy1
BAF-Heavy2
OP-Heavy3
BAF-AII4
Nonconventlona! Organtcs (Continued)
4-Methyl-2-pentanone
cc-Tcrpineol
Benzoic Acid
Benzyl Alcohol
Hexanoic Acid
m-Xylene
n-Dccane
/i-Docosane
n-Dodccane
n-Eicosane
n-Hcxacosanc
n-Hexadecane
n-Octacosane
n-Octadecane
rt-Tctracosanc
n-Tctradccane
«-Triacontane
o-&/>-Xylenc
;»"Cresol
p-Cymene
Pen tame thylbcnzene
Priority Metals and Elements
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
0.0722
0.0100
...
._
0.128
0.366
0.279
0.0347
0.574
0.0779
0.0100
0.0417
0.0100
0.0560
_
0.116
_
0.359
„
_.
—
0.195
_
—
0.132
0.153
0.437
0.914
_.
0.255
9.55
0.471
._
—
_
—
—
0.110
—
0.373
—
1.05
—
0.422
0.125
0.979
—
—
—
0.531
—
_
—
._
—
0.0715
1.45
0.361
—
_.
—
...
—
—
_.
0.104
0.0240
0.0120
0.0100
0.0382
0.0122
0.0315
0.0100
0.0100
0.0329
0.612
0.0341
0.0940
—
0.0208
0.0100
—
—
—
0.00500
0.0147
0.534
0.0473
—
—
0.595
0.472
1.58
—
—
0.595
0.469
0.0232
0.195
0.0477
0.0195
0.0842
...
0.0694
0.0219
0.0754
0.0100
0.271
...
0.0700
~.
0.0800
—
—
0.0161
0.0695
0.478
0.175
—
0.0544
CP-AII5
3.13
—
...
._
0.347
0.104
0.0110
2.83
0.0167
0.0144
0.0682
0.0168
0.0309
0.0107
0.0601
0.0138
0.231
...
~.
0.00691
0.0426
0.139
0.100
-,„
-_
9-10
-------
Chapter 9 - Treatment Performance Data
Table 9-1 (Continued)
Pollutant of Concern
Priority Metals and Elements (Continued)
Selenium
Silver
Thallium
Zinc
Median LTA (mg/L)
CEB-Heavy*
DAF-Heavy4
...
._
—
6.78
... :
0.0846
...
0.903
Nonconventional Metals and Elements
Aluminum
Barium
Boron
Cobalt
Iron
Manganese
Molybdenum
Tin
Titanium
Vanadium
Yttrium
6.33
...
1.64
—
47.3
0.596
0.205
...
0.0818
...
—
Bulk Nonconventionals
Chemical Oxygen Demand (COD)
Total Organic Carbon (TOC)
Total Petroleum Hydrocarbon (measured as SGT-HEM)
2460
626
200
1.34,
0.702
...
— :
19.0
0.884
—
__
0.0927
—
._
3320
1610
42.1
CP-Heavy3 f BAF-AII*
. _-
_
...
0.0637
0.0804
0.145
11.4
_
0.366
0.00768
0.774
...
0.00453
—
.„
0.0524
—
—
0.837
1.31
._
—
-_
2.79
0.0340
0.119
0.0972
0.0192
_
...
2510
910
7.20
998
326
13.7
CP-AB5
...
_
_
0.200
0.468
...
._
._
4.12
0.00877
0.457
—
0.0179
._
._
1080
342
10.8
'CEB-Heavy represents data from facilities using chemical emulsion breaking treatment of heavy wastewater.
2DAF-Heavy represents data from facilities using DAF treatment of heavy wastewater.
3CP-Heavy represents data from facilities using chemical precipitation treatment of heavy wastewater.
4DAF-A11 represents data from facilities using DAF treatment of all facility process wastewater.
5CP-A11 represents data from facilities using chemical precipitation treatment of all facility process wastewater.
HEM-Hexane Extractable Material.
SGT-HEM - Silica Gel Treated-Hexane Extractable Material. •
9-11
-------
Chapter 9 - Treatment Performance Data
discusses which data were used to calculate the long-term averages and subsequently the
variability factors and standards.
The following tables present the overall and episode long-term averages,
variability factors, and standards for the five postlaundering treatment technology groups for
the 11 pollutants proposed for regulation:
• Table 9-2 presents the long-term averages and variability factors for
chemical emulsion breaking treatment of heavy wastewater for each
pollutant proposed for regulation by episode;
• Table 9-3 presents the median of the episode long-term averages,
variability factors, and standards for chemical emulsion breaking
treatment of heavy wastewater for each pollutant proposed for regulation;
• Table 9-4 presents the long-term averages and variability factors for
DAP treatment of heavy wastewater for each pollutant proposed for
regulation by episode;
• Table 9-5 presents the median of the episode long-term averages,
variability factors, and standards for DAF treatment of heavy wastewater
for each pollutant proposed for regulation;
• Table 9-6 presents the long-term averages and variability factors for
chemical precipitation treatment of heavy wastewater for each pollutant
proposed for regulation by episode;
• Table 9-7 presents the median of the episode long-term averages,
variability factors, and standards for chemical precipitation treatment of
heavy wastewater for each pollutant proposed for regulation;
• Table 9-8 presents the long-term averages and variability factors for
DAF treatment of all facility process wastewater for each pollutant
proposed for regulation by episode;
• Table 9-9 presents the median of the episode long-term averages,
variability factors, and standards for DAF treatment of all facility process
wastewater for each pollutant proposed for regulation;
• Table 9-10 presents the long-term averages and variability factors for
chemical precipitation treatment of all facility process wastewater for
each pollutant proposed for regulation by episode; and
• Table 9-11 presents the median of the episode long-term averages,
variability factors, and standards for chemical precipitation treatment of
all facility process wastewater for each pollutant proposed for regulation.
9-12
-------
Chapter 9 - Treatment Performance Data
Table 9-2
Episode Long-Term Average (LTA) Concentrations and Variability Factors (VF)
for Chemical Emulsion Breaking Treatment of Heavy Wastewater for the
Pollutants Proposed for Regulation
Regulated Pollutant
Site
Number*
ItfA
(rag/L)
1-BayW2 I
-------
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iff
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9
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2
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|
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s
CO
s
o
JJ
d
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«
| Bis(2-ethylhexyi;
2
$
•3
s
f
s
0
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2
2
2
0
3
—
s
o
I
i
2
2
en
oo
0
s
3
«
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o
f
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»
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2
2
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1
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00
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es
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53
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§
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1
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1
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^ 1 s
w 8 £
si ^
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t|> aS
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s c no
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| a a w
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^. u u g
'*3 iS 3 w
u •§ 2 i
*-a ^1
a s §=3?
-day VF is defined
-day variability fao
:troleum hydrocartx
lot analyzed. EPA
EM - Silica Gel Ti
- t 8.* SB
u u ^ ' ti
' £ iS s < 5
r^r s §S
-------
Chapter 9 - Treatment Performance Data
Table 9-4
Episode Long-Term Average (LTA) Concentrations and Variability
Factors (VF) for DAF Treatment of Heavy Wastewater for Pollutants
Proposed for Regulation1
Pollutant
Site
Number^
LTA
(mg/L)
M&tyW3
(mg/L)
4-BayW4
(mg/L)
Priority Organics
Bis(2-ethylhexyl) Phthalate
Ethylbenzene
Toluene
S2
S2
S2
; 0.852
1.56
! 2.50
NC
2.86
1.96
NA
NA
NA
Priority Metals and Elements ;
Copper
Lead
Zinc
S2
S2
S2
1.45
0.361
0.903
1.90
6.18
2.68
NA
NA
NA
Bulk Nonconventionals ;
Total Petroleum Hydrocarbon (measured as SGT-HEM)
S2
42.1
2.31
1.37
Insufficient data were available to calculate long-term average pollutant concentrations for all of the pollutants proposed
for regulation at each site. This table only includes pollutants proposed for regulation at sites for which a long-term
average could be calculated.
Facilities with a site number beginning with "S" were sampled by EPA. Facilities with a site number beginning with
"Q" provided data in their detailed monitoring questionnaire.
3The 1-day VF is defined as the daily variability of pollutant concentrations; EPA used the 1-day VF to calculate daily
maximum standards for all pollutants proposed for regulation.
4The 4-day variability factor is defined as the monthly variability of pollutant concentrations based on 4 days of sampling
per month. EPA used the 4-day VF to calculate a monthly average standard for total petroleum hydrocarbon.
NA - Not analyzed. EPA did not use the 4-day VF to calculate standards for these pollutants.
NC - Not calculated. Insufficient data were available to calculate this variability factor. Four values, at least two of
which must be detected, are necessary to calculate a variability factor.
SGT-HEM - Silica Gel Treated-Hexane Extractable Material.
9-15
-------
VO
r*
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l>
u
§
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t
s
ri
s?
00
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1.
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i
1
9-16
-------
Chapter 9 - Treatment Performance Data
Table 9-6
Episode Long-Term Average (LTA) Concentrations and Variability
Factors (VF) for Chemical Precipitation Treatment of Heavy Wastewater
for the Pollutants Proposed for Regulation
Pollutant
Site
Number1
1TA
(mgflL)
t«»ay W2
(ragflL)
4-BayvF3
(mgflL)
Priority Organics
Bis(2-ethylhexyl) Phthalate
Ethylbenzene
Naphthalene
Tetrachloroethene
Toluene
S3
S3
S3
S3
S3
0.0469
0.0931
0.114
0.127
0.818
NC
4.37
3.14
4.48
6.79
NA
NA
NA
NA
NA
Nonconventional Organics
m-Xylene
o-&p-Xylene
S3
S3
0.104
0.0940
2.66
3.63
NA
NA
Priority Metals and Elements
Copper
Lead
Zinc
S3
S3
S3
0.534
0.0473
0.0637
4.06
NC
6.19
NA
NA
NA
Bulk Nonconventionals
Total Petroleum Hydrocarbon (measured as SGT-HEM)
S3
7.20
NC
NC
'Facilities with a site number beginning with "S" were sampled by EPA. Facilities with a site number beginning with
"Q" provided data in their detailed monitoring questionnaire. :
2The 1-day VF is defined as the daily variability of pollutant concentrations. EPA used the 1-day VF to calculate daily
maximum standards for all pollutants proposed for regulation.
3The 4-day variability factor is defined as the monthly variability of pollutant concentrations based on 4 days of sampling
per month. EPA used the 4-day VF to calculate a monthly average standard for total petroleum hydrocarbon.
NA - Not analyzed. EPA did not use the 4-day VF to calculate standards for these pollutants.
NC - Not calculated. Insufficient data were available to calculate this variability factor. Four values, at least two of
which must be detected, are necessary to calculate a variability factor.
SGT-HEM - Silica Gel Treated-Hexane Extractable Material.
9-17
-------
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1-day VF is defined as
4-day variability factor
petroleum hydrocarbon
• Not analyzed. EPA di
• Not calculated. Insuffl
-HEM - Silica Gel Trea
W W «M ' C_i
t-j t-j HI •*« r ^ ^
_S^ ! g g g
9-18
-------
Chapter 9 - Treatment Performance Data
Table 9-8
Episode Long-Term Average (LTA) Concentrations and Variability
Factors (VF) for DAF Treatment of All Facility Process Wastewater
for the Pollutants Proposed for Regulation1
Pollutant
at*
Number2
LTA
(mg/L)
l»3>ay VF3
(mgflL)
4-3*ay VF*
(Hlg/L)
Priority Organics
Bis(2-ethylhexyl) Phthalate
Ethylbenzene
Naphthalene
Tetrachloroethene
Toluene
Ql
S4
S5
Q2
S5
Q2
S4
S5
Q2
Ql
S4
S5
Q2
S4
S5
0.421
0.0334
0.144
0.00438
0.374
0.00304
0.0764
0.180
0.0239
25.1
0.0656
0.434
0.0473
0.711
4.20
3.43
2.73
3.06
3.54
4.16
NC
4.73
1.57
4.97
15.4
3.08
5.87
13.5
7.93
2.80
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Nonconventional Organics :
m-Xylene
o-&p-Xylene
S5
S4
S5
0.595
0.117
0.424
3.55
3.15
4.07
NA
NA
NA
Priority Metals and Elements
Copper
Lead
Q4
Q3
Q2
Ql
S5
S4
Q4
Ql
Q2
Q3
S5
S4
0.387
0.569
0.593
0.668
0.173
0.360
0.100
0.215
0.233
0.320
0.0553
0.135
3.15
6.95
4.52
6.40
1.59
3.07
NC
5.05
2.99
1.55
1.39
3.72
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
9-19
-------
Chapter 9 - Treatment Performance Data
Table 9-8 (Continued)
Pollutant
Site
Number
LTA
(mg/L)
t-0ay VF3
(mg£L)
4-Day W4
(rngflL)
Priority Metals and Elements (Continued)
Zinc
Q4
Ql
Q3
Q2
S5
S4
0.778
0.897
0.911
1.22
0.268
0.513
2.96
7.34
6.27
5.11
1.58
3.17
NA
NA
NA
NA
NA
NA
Bulk Nonconventionals
Total Petroleum Hydrocarbon (measured as SGT-HEM)
S4
S5
11.4
16.0
3.64
2.62
1.68
1.44
'insufficient data were available to calculate long-term average pollutant concentrations for all of the pollutants proposed
for regulation at each site. This table only includes pollutants proposed for regulation at sites for which a long-term
average could be calculated.
^Facilities with a site number beginning with "S" were sampled by EPA. Facilities with a site number beginning with
"Q" provided data in their detailed monitoring questionnaire.
3The 1-day VF is defined as the daily variability of pollutant concentrations. EPA used the 1-day VF to calculate daily
maximum standards for all pollutants proposed for regulation.
''The 4-day variability factor is defined as the monthly variability of pollutant concentrations based on 4 days of sampling
per month. EPA used the 4-day VF to calculate a monthly average standard for total petroleum hydrocarbon.
NA - Not analyzed. EPA did not use the 4-day VF to calculate standards for these pollutants.
NC - Not calculated. Insufficient data were available to calculate this variability factor. Four values, at least two of
which must be detected, are necessary to calculate a variability factor.
SGT-HEM - Silica Gel Treated-Hexane Extractable Material.
9-20
-------
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9-21
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Chapter 9 - Treatment Performance Data
Table 9-10
Episode Long-Term Average (LTA) Concentrations and Variability
Factors (VF) for Chemical Precipitation Treatment of All Facility
Process Wastewater for the Pollutants Proposed for Regulation
Pollutant
Site
Number
LTA
(mg/L)
J«Day VFS
(mg/L}
4-UayW4
(mg/L}
Priority Organics
Bis(2-ethylhexyl) Phthalate
Ethylbenzene
Naphthalene
Tetrachloroethene
Toluene
Q7
S6
Q7
Q9
S6
Q6
Q7
86
Q9
S6
Q7
Q9
S6
0.148
0.0691
0.0360
0.343
0.269
0.0582
0.0583
0.0768
0.0795
0.438
0.0370
1.05
1.58
NC
1.21
NC
9.68
2.47
NC
NC
3.90
7.56
5.65
NC
2.86
2.39
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Nonconventional Organics
m-Xylene
o-&p-Xylene
S6
S6
0.347
0.231
3.84
4.12
NA
NA
Priority Metals and Elements
Copper
Lead
Zinc
Q5
Q6
S6
Q7
Q5
Q8
Q6
S6
Q5
Q8
Q6
S6
0.139
0.400
0.0563
0.0264
0.100
0.195
0.279
0.0619
0.0968
0.303
1.72
0.0547
1.71
1.56
3.57
3.89
1.29
2.66
1.52
5.29
3.96
6.94
2.14
1.79
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
9-22
-------
Chapter 9 - Treatment Performance Data
Table 9-10 (Continued)
Pollutant
Site
Number2
X.1A
(mg/L)
1-Day W*
4-iteyW* ,
(mg/L)
Bulk Nonconventionals
Total Petroleum Hydrocarbon (measured as SGT-HEM)
S6
10.8
2.54 | 1.42
'insufficient data were available to calculate long-term average pollutant concentrations for all of the pollutants proposed
for regulation at each site. This table only includes pollutants proposed for regulatio'n at sites for which a long-term
average could be calculated.
facilities with a site number beginning with "S" were sampled by EPA. Facilities with a site number beginning with
"Q" provided data in their detailed monitoring questionnaire.
3The 1-day VF is defined as the daily variability of pollutant concentrations. EPA used the 1-day VF to calculate daily
maximum standards for all pollutants proposed for regulation.
4The 4-day variability factor is defined as the monthly variability of pollutant concentrations based on 4 days of sampling
per month. EPA used the 4-day VF to calculate a monthly average standard for total petroleum hydrocarbon.
NA - Not analyzed. EPA did not use the 4-day VF to calculate standards for these pollutants.
NC - Not calculated. Insufficient data were available to calculate this variability factor. Four values, at least two of
which must be detected, are necessary to calculate a variability factor.
SGT-HEM - Silica Gel Treated-Hexane Extractable Material.
9-23
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^I3S§
-------
Chapter 9 - Treatment Performance Data
9.6
Identification of Data Used to Calculate the Long-Term Average
Concentrations for the Prelaundering Technology Group
One of the sampled facilities steam-tumbled printer towels/rags before water-
washing them. Steam tumbling is designed to remove organic pollutants from laundry items.
Therefore, this treatment technology is not expected to demonstrate pollutant removals for all
72 pollutants of concern. This section presents EPA's methodology used to identify pollutants
effectively removed by steam tumbling and to calculate target effluent concentrations for these
pollutants.
EPA collected samples of wastewater discharge after processing a load of
printer towels/rags that was steam-tumbled before water washing and from a load of printer
towels/rags that was not steam-tumbled before water washing. Because both loads contained
the same item and because both loads did not contain any free-standing liquids (this facility
does not accept printer towels/rags containing free-standing liquids), EPA considered the
untreated pollutant loadings from both loads to be equivalent. The raw wastewater samples
from the load that was not steam-tumbled were used to represent the untreated influent to the
steam-tumbling unit, and the effluent wastewater samples from the steam-tumbled load were
used to demonstrate the changes in the untreated wastewater characteristics from steam
tumbling. EPA used these data to identify pollutants effectively removed by steam tumbling
and to calculate target effluent concentrations for the pollutants removed by steam tumbling.
EPA used these samples to identify pollutants removed by steam tumbling by
comparing the untreated influent and the effluent wastewater samples used to demonstrate
changes in the untreated wastewater characteristics from steam tumbling. All volatile organic
pollutants for which a removal could be calculated (pollutant removals for 7 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 8 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.
Based on this analysis, EPA considered 24 organic pollutants from the list of
72 pollutants of concern to be removed by steam tumbling. Based on EPA analysis and
vendor data, EPA determined that shop towels, printer towels/rags, mops, filters, and fender
covers would be steam-tumbled in this option. These untreated items typically contain the
highest concentrations of pollutants of all items laundered at industrial laundries. EPA
determined that steam tumbling items other than shop towels, printer towels/rags, mops,
filters, and fender covers does not result in significant pollutant removals because these items
do not typically contain high concentrations of organic pollutants.
9-25
-------
Chapter 9 - Treatment Performance Data
EPA then identified target effluent concentrations for steam tumbling of shop
towels, printer towels/rags, mops, filters, and fender covers for the 24 pollutants effectively
removed by steam tumbling. For some of the 24 pollutants, the pollutant concentration on
items not treated by steam tumbling (garments, mats, and linen items) was higher than the
pollutant concentration for steam tumbling of printer towels/rags. In these cases, EPA
selected the highest pollutant concentration from garments, mats, and linen items as the target
effluent concentration for that pollutant. Table 9-12 presents the target effluent concentrations
for steam tumbling for the 24 organic pollutants effectively removed.
9.7
Mass-Based Standards
EPA considered proposing mass-based standards for the industrial laundry
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. EPA determined that basing the mass-based
standards on total wastewater flow and total production data is more appropriate than basing
the standards on individual item data. 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.
9.8
1.
References
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.
9-26
-------
Chapter 9 - Treatment Performance Data
Table 9-12
Target Effluent Concentrations for Steam Tumbling of Heavy Items Before
Water Washing for the Pollutants of Concern
Pollutant of Concern
Median LTA (mgflL) ;
Priority Organics
1,1,1 -Trichloroethane
Butyl Benzyl Phthalate
Chlorobenzene
Chloroform
Ethylbenzene
Methylene Chloride
Naphthalene
Tetrachloroethene
Toluene
trans- 1 ,2-Dichloroethene
Trichloroethene
1.60
0.366
0.0550
0.889
0.283
0.442
0.226
0.125
1.29
0.0550
i 0.0550
Nonconventional Organics
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Methyl-2-pentanone
oc-terpineol
»i-Xylene
w-Decane
n-Dodecane
n-Hexacosane
n-Octacosane
w-Triacontane
o-&/?-Xylene
/j-Cymene
0.579
0.0550
; 2.11
; 0.500
: 0.0830
0.520
2.63
: 2.65
0.130
0.0960
0.0620
0.291
0.108
9-27
-------
-------
Chapter 10 - Development of Regulatory Options
CHAPTER 10
DEVELOPMENT OF REGULATORY OPTIONS
10.1
Introduction
This chapter presents the regulatory options considered by EPA as the basis for
the proposed 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 10.2 presents the regulatory options considered as the basis for
the proposed PSES;
• Section 10.3 presents the regulatory options considered as the basis for
the proposed PSNS; and
10.2
• Section 10.4 presents the references used.
Pretreatment Standards for Existing Sources (PSES)
Pretreatment standards for existing sources establish quantitative limits on the
indirect discharge of priority and noncoriventional pollutants to waters of the United States
(i.e., PSES limit industrial discharges to publicly owned treatment works (POTWs)). PSES
are designed to prevent the discharge of pollutants that pass through* interfere with, or are
otherwise incompatible with the operation of POTWs. The Clean Water Act (CWA) requires
pretreatment for pollutants that pass through POTWs in amounts that would exceed direct
discharge effluent standards or limit POTW sludge management alternatives, including the
beneficial use of sludges on agricultural lands. These limits are based upon the performance
of specific technologies, but they do not require the use of any specific technology. PSES are
applied to individual facilities and are administered by local permitting authorities (i.e., the
government entity controlling the POTW to which the industrial wastewater is discharged).
The facility then chooses its own approach to complying with its permit standards.
EPA considered 17 technology options as potential bases for PSES. These
options are presented in Sections 10.2.1 and 10.2.2 below.
10.2.1
Initial Technology Options Considered
As described in Chapter 9, EPA had data available for five major
postlaundering wastewater treatment technologies and one prelaundering treatment technology
used by industrial laundries. These formed the basis for EPA's six initial technology options.
The following sections further discuss each of these initial technology options. Table 10-1
10-1
-------
Chapter 10 - Development of Regulatory Options
Table 10-1
Technology Options Initially Considered for the Industrial
Laundries Proposed Rule
Regulatory
Option
CEB-Heavy
DAF-Heavy
CP-Heavy
DAF-A11
CP-A11
OC-Only
De$cription
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 laundry items.
Basis of
Standards
CEB-Heavy
DAF-Heavy
CP-Heavy
DAF-A11
CP-A11
OC-Only
Number of Facilities
with Equivalent
or Better Treatment
In f toce*
5
1
72
33
173
O4
'Dtt» obtained from 193 in-scope facilities that responded to the detailed questionnaire. In-scope facilities are those that meet the definition
of in industrial laundry as presented in Chapter 6, regardless of annual production.
2Onc of these facilities operates a microfiltration unit to treat a portion of its process wastewater. Since microfiltration 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.
3One of these facilities operates an ultrafiltration unit to treat all of its process wastewater. Since ultrafiltration 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.
*D»ta from one facility were used to develop target average concentrations for OC-Only, but this facility steam tumbles printer towels only,
not *11 heavy industrial items.
10-2
-------
1 Chapter 10 - Development of Regulatory Options
summarizes the six initial technology options and the number of detailed questionnaire
facilities that have equivalent or better treatment currently in place.
Postlaundering Wastewater Treatment Technology Options
The five initial postlaundering wastewater treatment technology 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-Heaw ~ 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 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 detailed questionnaire and EPA site visits to industrial laundries, it
was 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 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, it was determined that these units facilitate
the operation of subsequent treatment units. 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, it is expected that the pH of the treated wastewater streams
from these 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. For technology options in which a portion of the facility's
wastewater is treated with chemical emulsion breaking or chemical precipitation, combination
of the treated and untreated streams prior to final pH adjustment and discharge is also
included. The effluent from DAF is expected to be within facilities' locally permitted
10-3
-------
Chapter 10 - Development of Regulatory Options
discharge range for pH, based on detailed questionnaire and sampling data. Therefore, the
DAF treatment options do not include pH adjustment. For technology options in which a
portion of the facility's wastewater is treated with DAF, combination of the treated and
untreated streams prior to discharge is included.
The five initial wastewater treatment technology 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 of these options 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
• Linen.
The heavy industrial stream includes wastewater generated from water washing
the following items:
• Shop towels;
• Printer towels;
• Mops;
• Fender covers; and
• Filters.
The light industrial stream includes wastewater generated from water washing
the following items:
• Industrial Garments;
• Floor Mats;
• Clean Room Garments;
• 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;
Mats;
Mops;
Fender covers;
Clean Room Garments;
10-4
-------
: Chapter 10 - Development of Regulatory Options
• Laundry Bags;
• Filters; and
• Buffing Pads.
The linen 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 linen items):
• Linen Supply Garments;
• Linen Flatwork/Full Dry;
• Health-Care Items;
• Continuous Roll Towels;
• Family Laundry;
• New Items;
• Executive Wear; and
• Miscellaneous Not Our Goods.
The wastewater generated from the washing of heavy industrial items ("heavy" wastewater)
contains higher concentrations of most pollutants than the wastewater generated from the
washing of light industrial and linen items ("light" wastewater). Figures 10-1, 10-2, and 10-3
illustrate the CEB-Heavy, DAF-Heavy, and CP-Heavy technology options, respectively. The
All options treat the total facility process wastewater. Figures 10-4 and 10-5 illustrate the
DAF-A11 and CP-A11 technology options, respectively.
EPA obtained specific performance data on the treatment of heavy industrial
laundry wastewater through wastewater sampling at industrial laundries, as discussed in
Chapter 9. The standards for the Heavy options would be based on pollutant concentrations
obtained from the treated heavy wastewater, prior to combining with the light wastewater
stream, as shown in Figures 10-1, 10-2, and 10-3. The standards for the All options would be
based on pollutant concentrations obtained at the point of discharge from treatment of the
entire wastewater stream as shown in Figures 10-4 and 10-5.
Prelaundering Organics Control (DC-Only) Technology Option
The OC-Only option, shown in Figure 10-6, consists of steam tumbling
treatment of facilities' heavy industrial laundry items to remove organics prior to water
washing of the items. EPA obtained specific performance data from one facility on the steam
tumbling of printer towels, as discussed in Chapter 9. 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, as shown in Figure 10-6.
10-5
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10-11
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10.2.2
Chapter 10 - Development of Regulatory Options
Inclusion of Pollution Prevention in the Technology Options
Most of the preprocess pollution prevention activities reported in the detailed
questionnaire involve good operating practices that any industrial laundry can 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 facilities 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 can perform this activity.
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 less refractory
emulsions.
Most of the facilities from which EPA has gathered data used for the
development of DAP and chemical precipitation pretreatment standards practice refusal of
items containing free liquids. 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. No other pollution prevention activities were
consistently practiced by facilities from which data were obtained to develop pretreatment
standards.
10.2.3 Exclusion of Wastewater Recycling Activities from the Technology Options
Some industrial laundries reported that they have incorporated wastewater
recycling activities into their processes, as described previously in Section 8.4.1. EPA has
found that the implementation of wastewater recycling is a facility-specific issue that is
largely dependent 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 being used overall (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.
10-12
-------
10.2.4
Chapter 10 - Development of Regulatory Options
Initial Technology Options Not Further Considered
EPA eliminated the Heavy options from further consideration because it was
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 iii-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. \
•10.2.5
Additional Technology Options Considered
EPA considered additional alternative technology options, which were
variations on the initial DAF and chemical precipitation technology options presented above,
to find the most cost-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. The standards for these
additional technology options are based on performance data obtained from either DAF or
chemical precipitation treatment of the total facility process wastewater stream. In other
words, the standards for the additional technology options are the same as those for the DAF-
All and CP-A11 initial technology options described previously. These additional regulatory
options are described in the sections below.
Table 10-2 summarizes the 10 additional technology options and the number of
facilities that have equivalent or better treatment currently in place.
Industrial Laundry Wastewater (IL) Technology Options
The IL wastewater technology options, DAF-IL and CP-IL, are similar to the
DAF-Heavy and CP-Heavy technology options shown in Figures 10-2 and 10-3, 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 items is treated. The treated stream is
combined with the untreated linen wastewater stream prior to monitoring and discharge.
Thus, in Figures 10-2 and 10-3 the heavy and light industrial wastewater streams are
represented by the "heavy" stream in the diagram and the linen 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).
10-13
-------
Chapter 10 - Development of Regulatory Options
Table 10-2
Definitions of Additional Technology Options Considered for PSES
Regulatory
Option
DAF-IL
CP-IL
Combo-IL
Combo-IL-2LIM
DAF-TWL
CP-TWL
Combo-TWL
Combo-TWL-
2LIM
Combo-All
Combo-AH-2LIM
' i ' t ;/>, '
* j/ t
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.
Basis of
Standards
DAF-A11
CP-A11
The higher LTA
between
DAF-A11 and
CP-AH
DAF-A11 or CP-
AH, based on
technology
costed
DAF-A11
CP-All
The higher LTA
between
DAF-A11 and
CP-All
DAF-A11 or CP-
All, based on
technology
costed
The higher LTA
between
DAF-A11 and
CP-All
DAF-A11 or CP-
All, based on
technology
costed
Number of
Facilities witt*
Equivalent or
Better Treatment
In Place1
1
1
2
2
1
72
82
82
503
503
Data obtained from 193 in-scope facilities that responded to the detailed questionnaire. In-scope facilities were those that meet the
definition of an industrial laundry as presented in Chapter 6, regardless of annual production.
One of these facilities operates a microfiltration unit to treat a portion of its process wastewater. Since microfiltration can achieve lower
finil effluent pollutant concentrations than chemical precipitation (1), this facility is considered to have better treatment in place for the CP-
Hc»vy option.
3One of these facilities operates an ultrafiltration unit to treat all of its process wastewater. Since ultrafiltration can achieve lower final
effluent concentrations than chemical precipitation (1), this facility is considered to have better treatment in place for the CP-All option.
LTA - Long-term average
10-14
-------
• Chapter 10 - Development of Regulatory Options
EPA has determined that the wastewater generated from laundering of linen
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 linen wastewater does not need treatment
to meet those standards. EPA developed the IL wastewater technology options to import
lower-cost treatment systems to treat a portion of the facility's process wastewater.
Towel (TWL) Technology Options
The TWL wastewater technology options are nearly identical to the DAF-
Heavy and CP-Heavy technology options shown in Figures 10-2 and 10-3, respectively,
including treatment of wastewater generated from washing heavy industrial laundry items, as
defined in Section 10.2.1. Light industrial and linen wastewater is discharged without
treatment. Thus, in Figures 10-2 and 10-3 the heavy industrial wastewater stream is
represented by the "heavy" stream in the diagram and the light industrial and linen 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 to
discharge and that are based on treatment performance data for the DAF-All and CP-A11
technology options.
Combination (Combo) Technology Options
EPA also considered technology options in which standards would be based on
a combination of the DAF-IL and CP-IL standards in order to allow for increased flexibility
in the technologies used by the industry to treat their industrial laundry wastewater, allowing
for a more cost-effective technology option. These combination (Combo) options, Combo-IL
and Combo-IL-2LIM, are described below.
The Combo-IL technology option combines both the DAF-IL and CP-IL
standards into one set of standards for the industrial laundry industry. These standards would
be established based on the less stringent of the standards for the two technology options for
each pollutant. EPA's data show that, overall, chemical precipitation performs somewhat
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 under 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 option (based on a comparison of DAF-IL and
CP-IL annualized costs) to treat their industrial laundry wastewater.
10-15
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Chapter 10 - Development of Regulatory Options
The Combo-IL-2LIM technology option is similar to the Combo-IL option
described above. In this option, the standards for the DAF-IL option would apply to facilities
using DAF to treat then: 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 under 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 CP-IL technology 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 similar manner
to the Combo-IL and Combo-IL-2LIM options described above, but resulted in higher
compliance posts.
As in the IL options, EPA also considered additional TWL technology options
(Combo-TWL and Combo-TWL-2LIM) in which standards are based on a combination of the
DAF-TWL and CP-TWL standards in order 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.
10.2.6 Technology Options Eliminated from Further Consideration
Based on technical and economic analyses, EPA eliminated the following
technology options from further consideration:
• 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 the
pollutant concentrations in the untreated light industrial and linen wastewater streams are
10-16
-------
Chapter 10 - Development of Regulatory Options
higher than the standards for these technology options. The standards for the TWL options
would be based on the treatment of total facility process wastewater and EPA determined that
these standards could not be met with the treatment schemes of the TWL options.
EPA eliminated the All options from further consideration because although the
IL and the All options can achieve the same effluent pollutant concentrations, the costs to
treat the total facility process wastewater in the All options are higher than the costs for the
IL options.
No Regulation Option
EPA also considered a no regulation option, which entails having no national
standards. Facilities would only need to comply with applicable local standards. EPA
rejected the No Regulation option because it provides no control of pollutants passing through
or interfering with POTW operations. Further, the No Regulation option would not represent
best available technology economically achievable or best available demonstrated control
technology as those terms are applied for the purpose of setting pretreatment standards.
10.2.7
Regulatory Options Further Considered for PSES
The remaining five technology options further considered for the industrial
laundries rule are:
• DAF-IL;
• CP-IL;
• Combo-IL;
• Combo-IL-2LIM; and
• OC-Only.
These options became regulatory options considered as the basis for the
proposed PSES. EPA performed detailed analyses of costSj, pollutant removals, and economic
impacts for these options as described in Chapter 12 of this document and the Economic
Assessment (EA) (3).
10.3
Pretreatment Standards for New Sources (PSNS)
Pretreatment standards for new sources establish quantitative standards on the
indirect discharge of priority and nonconventional pollutants to waters of the United States.
Industry has the opportunity to design and install the best and most efficient processes and
wastewater treatment systems at new facilities. Accordingly, Congress directed EPA to
consider the best demonstrated alternative processes, process changes, in-plant control
measures, and end-of-pipe wastewater treatment technologies that reduce pollution to the
maximum extent feasible. In response to that directive, EPA considered effluent reductions
attainable by the most advanced and demonstrated process and treatment technologies at
10-17
-------
Chapter 10 - Development of Regulatory Options
industrial laundries. EPA considered the five regulatory options evaluated as the basis for'the
proposed PSES as the basis for the proposed PSNS.
10.4
References
1.
2.
3.
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.
Memorandum: Preliminary Data for Calculating Mass-Based Limitations for
the Industrial Laundries Industry, August 15, 1997 (DCN L04319).
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.
10-18
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Chapter 11 - Pollutant Loading and Removal Estimates
CHAPTER 11
11.1
POLLUTANT LOADING AND REMOVAL ESTIMATES
Introduction
This chapter presents annual pollutant loading and removal estimates for the
industrial laundries industry for each of the regulatory options. 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. Untreated, baseline,
and postcompliance pollutant loadings and pollutant removals for the industry were estimated
for 72 pollutants of concern using data collected from the industry throughout development of
the proposed rule. 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
currently in place at industrial laundries.
• Baseline loadings — pollutant loadings in industrial laundry wastewater
currently being discharged to POTWs. These loadings do account for
wastewater treatment currently in place at industrial laundries.
• Postcompliance loadings — pollutant loadings in industrial laundry
wastewater after implementation of the rule. These loadings are
calculated assuming that all industrial laundries would operate
wastewater treatment technologies equivalent to the technology option.
The following information is presented in this chapter:
• Section 11.2 presents the data sources that were used to estimate
pollutant loadings and removals;
• Section 11.3 discusses the methodology used to estimate pollutant
loadings and pollutant removals; and
• Section 11.4 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.
11-1
-------
Chapter 11 - Pollutant Loading and Removal Estimates
11.2
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), and the Preliminary Data Summary (PDS). These data sources are discussed in detail
in Chapter 3.
To estimate untreated pollutant loadings for the industrial laundries industry,
EPA estimated pollutant concentrations and loadings for 72 pollutants at 193 in-scope
industrial laundries that submitted sufficient information in response to the 1993 detailed
questionnaire (in-scope facilities meet the definition of an industrial laundry as presented in
Chapter 6, regardless of their annual production). EPA then extrapolated the loadings to the
entire industry based on the survey weights developed for each facility. The 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 two loads of pants
and two loads of shirts collected during two sampling episodes;
• Water washing of shop towels — data from three loads of shop towels
collected during three sampling episodes and two days of PDS data
from a shop-towel-only stream at a facility sampled for the PDS.;
• 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 one load of mats collected during a
sampling episode;
• 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 bv water washing of printer towels/rags ~ data
from one load collected during a sampling episode;
11-2
-------
Chapter 11 - Pollutant Loading and Removal Estimates
• 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.
Data submitted by one facility for clean room items and denim prewashing data
obtained by EPA during a site visit were not used to estimate pollutant loadings and removals
because the data were not available at the time the analysis was completed.
Data used for estimating postcompliance loadings for each regulatory option are
presented in Chapters 9 and 10 and are summarized as follows:
• Organics Control (Steam Tumbling) of Heavy Industrial Laundry Items
(PC-Only) — data from one load of steam-tumbled printer towels/rags;
• Dissolved Air Flotation of Industrial Laundry Wastewater (DAF-ID —
data from two sampled facilities and four DMQ facilities;
• Chemical Precipitation of Industrial Laundry Wastewater (CP-IU) — data
from one sampled facility and five DMQ facilities; and
• Dissolved Air Flotation or Chemical Precipitation of Industrial Laundry
Wastewater (Combo-IL and Combo-IL-2LIM) ~ for dissolved air
flotation, data from two sampled facilities and four DMQ facilities; for
chemical precipitation, data from one sampled facility and five DMQ
facilities.
Baseline loadings for individual facilities were estimated from untreated or
postcompliance loadings, based on the wastewater treatment in place reported by the facility
in the detailed questionnaire. Section 11.3 below present details on the methodology used to
estimate the pollutant loadings and removals.
11.3
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.
11-3
-------
11.3.1
Chapter 11 - Pollutant Loading and Removal Estimates
Methodology Used to Estimate Untreated Pollutant Loadings
EPA estimated untreated pollutant loadings for each of the 193 in-scope
facilities using the process/item-specific data discussed in Section 11.2 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 currently in place at industrial laundries.
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
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)
The pollutant loading per pound of item was calculated 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 11-1 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 11.2 of this
document.
Data were not obtained for all the process/item combinations reported by the
193 in-scope facilities in the detailed questionnaires. To estimate the pollutant loadings for all
facilities, EPA transferred data from the process/item combinations with data available to
other process/item-specific combinations for which data were not available. Table 11-2
presents these data transfers.
For each facility, 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
following equation was used to calculate the pollutant concentrations for each facility:
Amount of pollutant generated Production (Ibs of process/item at facility) _ Concentration
per pound of laundry (mg/lb) Flow (L, for process/item at facility) ~ (mg/L for process/item at facility)
11-4
-------
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11-5
-------
Chapter 11 - Pollutant Loading and Removal Estimates
Table 11-2
Analytical Data Transfers
Analytical Bata Transfers for Water-Washed Items*
Item
Health-Care Items (BOS)
Family Laundry (B15)
Executive Wear (B18)
Continuous Roll Towels (BIO)
Miscellaneous Not Our Goods
(NOG) (B19)
New Items (B17)
Clean Room Garments (Bl 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)
Industrial Garments (B01)
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
Customer
Customer and Chemical Use
Use and Customer
Use and Customer
Chemical Use
Customer and Use
Analytical Data Transfers for Processes
Process
Denim Prewash
Dual-Phase Processing
Process Bata 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
1 Codes in parenthesis refer to codes used in the detailed questionnaire.
If data were not available for a specific pollutant, data were transferred from water washing of mats.
11-6
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Chapter 11 - Pollutant Loading and Removal Estimates
From the facility-specific concentration, the pollutant loading was calculated using the
following equation: ;
Facility untreated concentration Facility annual flow 1 Ib
(mg/L, for process/item) (L/yr, for process/item) 453,600 mg
Facility untreated annual loading
(Ib/yr)
To estimate the total untreated wastewater pollutant loading for a facility, the loadings
calculated from each process/item combination were summed together for each pollutant.
11.3.2 Methodology Used to Estimate Baseline and Postcompliance 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 12 discusses the assessment of treatment in place for
industrial laundries. The treatment technologies in use at industrial laundries, based on the
detailed questionnaire, included chemical emulsion breaking, dissolved air flotation, chemical
precipitation, and ulrrafiltration. Some facilities use these technologies to treat their entire
process wastewater stream, while other facilities treat only part of their process wastewater.
Table 11-3 shows the methodology used to estimate baseline loadings for each facility. EPA
estimated the baseline loadings for facilities with ultrafiltration or microfiltration treatment
systems using the data for chemical precipitation treatment systems.
Postcompliance pollutant loadings for each regulatory option represent the total
industry wastewater pollutant loadings after implementation of the proposed rule.
Postcompliance pollutant loadings were estimated from the target average concentrations and
the annual facility wastewater discharge flow for each of the 193 in-scope facilities as shown
in the following equation:
Postcompliance target average concentration
(mg/L)
Facility annual discharge flow
1 Ib _ Facility postcompliance annual loading
453,600 mg ~ Qbsfyr)
Target average concentrations were calculated from the analytical data
described in Section 11.2 of this document. The target average concentrations for OC-Only
are presented in Chapter 9. Prior to calculating target average concentrations for DAF-IL and
CP-IL, the data were edited using procedures described in Chapter 9 for calculating long-term
averages, with the exception that the average concentration of a pollutant in the influent
samples collected from a facility did not need to be greater than ten times the method
detection level for that pollutant. Table 11-4 presents the target average concentrations for
DAF-IL and CP-IL. The target effluent concentrations for Combo-IL and Combo-IL-2LIM
are derived from DAF-IL and CP-IL, depending on the technology chosen.
11-7
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Chapter 11 - Pollutant Loading and Removal Estimates
Table 11-3
Methodology Used to Estimate Baseline Loadings for the Industrial
Laundries Industry
Facility Treatment in Place
No Treatment
CEB - partial stream1 ^
DAF - partial stream1
CP - partial stream1
DAF - total stream
CP - total stream
Source for Baseline leadings
Estimated from untreated wastewater concentrations
Treated stream loading estimated from target average concentrations for
CEB-Heavy and untreated stream loading estimated from untreated
wastewater concentrations
Treated stream loading estimated from target average concentrations for
DAF-IL and untreated stream loading estimated from untreated wastewater
concentrations
Treated stream loading estimated from target average concentrations for CF-
IL and untreated stream loading estimated from untreated wastewater
concentrations
Treated stream loading estimated from target average concentrations for
DAF-A11
Treated stream loading estimated from target average concentrations for CP-
All
!For the purposes of estimating baseline loads, EPA assumed that the stream reported as treated by the facility is
equivalent to the industrial laundry stream estimated for the EL-Options described in Chapter 10.
2Three facilities reported CEB treatment of the total wastewater stream. EPA does not have data representing
CEB treatment of the total wastewater stream; the loadings for these facilities were estimated assuming they are
only treating heavy wastewater.
CEB - Chemical emulsion breaking
DAF - Dissolved air flotation
CP - Chemical precipitation
CEB-Heavy - Chemical emulsion breaking of heavy industrial laundry wastewater
DAF-IL - Dissolved air flotation of industrial laundry wastewater
CP-IL - Chemical precipitation of industrial laundry wastewater
DAF-A11 - Dissolved air flotation of all process wastewater
CP-A11 - Chemical precipitation of all process wastewater
11-8
-------
Chapter 11 - Pollutant Loading and Removal Estimates
Table 11-4
Target Average Concentrations for DAF-IL and CP-IL
for the Pollutants of Concern1
Pollutant of Concern
Target Average Concentration
(mg/L)
DAF-IL
CP-IL
Conventionals
Biochemical Oxygen Demand 5-Day
(BOD5)
Oil and Grease ("measured as HEM)
Total Suspended Solids CTSS")
497
37.8
85.5 i
499
28.5
119
Priority Oreanics
1,1,1 -Trichloroethane
1 ,2-Dit>henvlhvdrazine
4-Chloro-3 -methvfohenol
Bis(2-ethvlhexvD Phthalate
Butvl Benzyl Phthalate
Chlorobenzene
Chloroform
Di-M-butvl Phthalate
Di-n-octvl Phthalate
Ethvlbenzene
Isoohorone
Methvlene Chloride
Naphthalene
Phenol
Tetrachloroethene
Toluene
trans- 1 ,2-Dichloroethene
Trichloroethene
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
...
_
0.471
__-
0.042
0.109
0.0342
0.0336
0.0513
0.0342
0.0342
0.269
0.297
0.126
0.0583
-__
0.259
1.05
...
Nonconventional Oreanics
2-Butanone
2-Methvlnaohthalene
2-Prooanone
4-Methvl-2-t>entanone
oc-Terpineol
17.4
0.116
13.6
0.595
0.472
3.23
0.0125
...
3.13
—
11-9
-------
Chapter 11 - Pollutant Loading and Removal Estimates
Table 11-4 (Continued)
Pollutant of Concern
Target Average Concentration
(
-------
Chapter 11 - Pollutant Loading and Removal Estimates
Table 11-4 (Continued)
Pollutant of Concern
Target Average Concentration . \
Ottg/L)
DA1-IL
CP-JOL
Priority Metals and Elements (Continued)
Thallium
Zinc
0.00294
0.837 ;
0.200
Nonconventional Metals and Elements
Aluminum
Barium
Boron
Cobalt
Iron
Manganese
Molybdenum
Tin
Titanium
Vanadium
Yttrium
1.31
0.0584
0.522
0.0381
2.79
0.0340
0.119
0.0631
0.0112;
0.00700
0.00208
0.468
0.261
0.238
0.0316
4.12
0.00877
0.457
0.0103
0.0179
0.0100
0.00500
Bulk Nonconventionals
Chemical Oxygen Demand (COD)
Total Organic Carbon (TOO
Total Petroleum Hydrocarbon (measured as
SGT-HEM)
998
326
13.7
1080
342
10.8
'Target average concentrations for OC-Only are presented in Chapter 9. Target average concentrations for Combo-IL and Combo-IL-2LIM
are dervived from the target average concentrations for DAF-IL and CP-IL.
HEM - Hexane extractable material. :
SGT-HEM - Silica gel treated-hexane extractable material.
11-11
-------
Chapter 11 - Pollutant Loading and Removal Estimates
To estimate postcompliance loading for facilities with treatment in place, EPA
ranked the treatment technologies in use by their performance. Based on data and information
collected during the development of this proposed rule, EPA determined that ultrafiltration,
microfiltration, and chemical precipitation generally achieve lower pollutant concentrations in
treated wastewater than dissolved air flotation, and that dissolved air flotation achieves lower
pollutant concentrations in treated wastewater than chemical emulsion breaking. Tables 11-5
through 11-8 present the methodologies used to estimate the postcompliance loadings for the
DAF-EL, CP-IL, COMBO-IL, and COMBO-IL-2LIM regulatory options, based on the
facility's treatment in place.
Postcompliance loadings for OC-Only were estimated using the target average
concentrations for 24 pollutants of concern considered to be controlled by this technology and
the target average concentrations for the applicable treatment system (or untreated
concentrations for facilities with no treatment) for the remaining 49 pollutants of concern not
controlled by this technology. No facilities have treatment in place equivalent to this
regulatory option.
11.3.3
Methodology Used to Estimate Pollutant Removals
Pollutant removals represent the difference between 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:
Baseline Loadings - Postcompliance Loadings = Pollutant Removals
EPA used the following methodology to estimate pollutant removals:
1) If the postcompliance loading of a pollutant was higher than the baseline
loading, the removal was set to zero;
2) If the pollutant was not present at baseline, the removal was set to zero;
and
3) If a long-term average was not calculated for a pollutant for a
technology option (i.e., the postcompliance loading for the pollutant
could not be calculated), the removal was set to zero.
11-12
-------
Chapter 11 - Pollutant Loading and Removal Estimates
Table 11-5
Methodology Used to Estimate Postcompliance Loadings for DAF-IL for the
Industrial Laundries Industry
Facility Treatment in Place
No Treatment
CEB - partial stream
DAF - partial stream
CP - partial stream
DAF - total stream
CP - total stream
Source for Postcompliance Loadings
Industrial laundry stream loading estimated from the target average
concentrations for DAF-IL; linen stream loading estimated from untreated
wastewater concentrations
Industrial laundry stream loading estimated from the target average
concentrations for DAF-IL; linen stream loading estimated from untreated
wastewater concentrations
Industrial laundry stream loading estimated from the target average
concentrations for DAF-IL; linen stream loading estimated from untreated
wastewater concentrations
Industrial laundry stream loading estimated from the target average
concentrations for CP-IL; linen stream loading estimated from untreated
wastewater concentrations
Total stream loading estimated from the target average concentrations for
DAF-A11
Total stream loading estimated from the target average concentrations for CP-
All
CEB - Chemical Emulsion Breaking
DAF - Dissolved Air Flotation
CP - Chemical Precipitation
DAF-IL - Dissolved Air Flotation of Industrial Laundry Wastewater
CP-IL - Chemical Precipitation of Industrial Laundry Wastewater
DAF-A11 - Dissolved Air Flotation of All Process Wastewater
CP-A11 - Chemical Precipitation of All Process Wastewater
11-13
-------
Chapter 11 - Pollutant Loading and Removal Estimates
Table 11-6
Methodology Used to Estimate Postcompliance Loadings for CP-IL for the
Industrial Laundries Industry
Facility Treatment in Place
No Treatment
CEB - partial stream
DAF - partial stream
CP - partial stream
DAF - total stream
CP - total stream
Source for Postcompliance Loadings
Industrial laundry stream loading estimated from the target average
concentrations for CP-IL; linen stream loading estimated from untreated
wastewater concentrations
Industrial laundry stream loading estimated from the target average
concentrations for CP-IL; linen stream loading estimated from untreated
wastewater concentrations
Industrial laundry stream loading estimated from the target average
concentrations for CP-IL; linen stream loading estimated from untreated
wastewater concentrations
Industrial laundry stream loading estimated from the target average
concentrations for CP-IL; linen stream loading estimated from untreated
wastewater concentrations
Total stream loading estimated from the target average concentrations for CP-
IL; linen stream loading estimated from untreated wastewater concentrations
Total stream loading estimated from the target average concentrations for CP-
All
CEB - Chemical Emulsion Breaking
DAF - Dissolved Air Flotation
CP - Chemical Precipitation
CP-EL - Chemical Precipitation of Industrial Laundry Wastewater
CP-A11 - Chemical Precipitation of All Process Wastewater
11-14
-------
Chapter 11 - Pollutant Loading and Removal Estimates
Table 11-7
Methodology Used to Estimate Postcompliance Loadings for Combo-IL for
the Industrial Laundries Industry
fa*llj# Treatment in Place
No Treatment
CEB - partial stream
DAF - partial stream
CP - partial stream
DAF - total stream
CP - total stream
Source for Postcompliance Loadings i
Industrial laundry stream loading estimated from the higher target average
concentrations between DAF-IL and CP-IL; linen stream loading estimated
from untreated wastewater concentrations
Industrial laundry stream loading estimated from the higher target average
concentrations between DAF-IL and CP-IL; linen stream loading estimated
from untreated wastewater concentrations
Industrial laundry stream loading estimated from the target average
concentrations for DAF-IL; linen stream loading estimated from untreated
wastewater concentrations
Industrial laundry stream loading estimated from the target average
concentrations for CP-IL; linen stream loading estimated from untreated
wastewater concentrations
Total stream loading estimated from the target average concentrations for
DAF-ALL
Total stream loading estimated from the target average concentrations for CP-
ALL
CEB - Chemical Emulsion Breaking
DAF - Dissolved Air Flotation
CP - Chemical Precipitation
DAF-IL - Dissolved Air Flotation of Industrial Laundry Wastewater
CP-IL - Chemical Precipitation of Industrial Laundry Wastewater
DAF-A11 - Dissolved Air Flotation of AH Process Wastewater
CP-A11 - Chemical Precipitation of All Process Wastewater
11-15
-------
Chapter 11 - Pollutant Loading and Removal Estimates
Table 11-8
Methodology Used to Estimate Postcompliance Loadings for
Combo-IL-2LIM for the Industrial Laundries Industry
Facility Treatment in Place
No Treatment
CEB - partial stream
DAF - partial stream
CP - partial stream
DAF - total stream
CP - total stream
Source for Postcompliance Loadings
Industrial laundry stream loading estimated from the target average
concentrations for CP-IL; linen stream loading estimated from untreated
wastewater concentrations
Industrial laundry stream loading estimated from the target average
concentrations for CP-IL; linen stream loading estimated from untreated
wastewater concentrations
Industrial laundry stream loading estimated from the target average
concentrations for DAF-IL; linen stream loading estimated from untreated
wastewater concentrations
Industrial laundry stream loading estimated from the target average
concentrations for CP-IL; linen stream loading estimated from untreated
wastewater concentrations
Total stream loading estimated from the target average concentrations for
DAF-A11
Total stream loading estimated from the target average concentrations for CP-
All
CEB - Chemical Emulsion Breaking
DAF - Dissolved Air Flotation
CP - Chemical Precipitation
DAF-IL - Dissolved Air Flotation of Industrial Laundry Wastewater
CP-EL - Chemical Precipitation of Industrial Laundry Wastewater
DAF-AH - Dissolved Air Flotation of All Process Wastewater
CP-A11 - Chemical Precipitation of All Process Wastewater
11-16
-------
Chapter 11 - Pollutant Loading and Removal Estimates
11.4
Pollutant Loadings and Removals
Annual untreated, baseline, and postcompliance loadings were estimated for
each of the regulatory options using the methodology described in Section 11.3 of this
document. The facility-specific loadings and removals were extrapolated from the 193 in-
scope facilities to represent the entire industry of 1,747 facilities. Tables 11-9 through 11-12
present the total untreated, baseline, and postcompliance loadings and the pollutant removals
for all 1,747 facilities for DAF-IL, CP-IL, Combo-IL, and OC-Only. Tables 11-13 through
11-16 present the total untreated, baseline, and postcompliance loadings and pollutant removal
for the 141 facilities that are excluded from the regulation as discussed in Chapter 6 for DAF-
IL, CP-IL, Combo-IL, and OC-Only. Pollutant loadings and removals for Combo-IL-2LIM,
which are not presented in this chapter, are similar to Combo-IL and are within the range of
the DAF-IL and CP-IL pollutant loadings and removals.
11-17
-------
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11-30
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11-40
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11-43
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12.1
Chapter 12 - Costs of Technology Bases for Regulations
CHAPTER 12
COSTS OF TECHNOLOGY BASES FOR REGULATIONS
Introduction
This chapter describes the methodology used to estimate the costs to implement
each of the regulatory options under consideration for the Industrial Laundries Point Source
Category. Chapters 8 and 10 describe in detail the regulatory options as well as the
technologies used as the bases for the options. The cost estimates, together with the pollutant
reduction estimates described in Chapter 11, provide a basis for evaluating the options. The
cost estimates also provide a basis for determining the economic impact of the proposed
regulation on the industry at different pollutant discharge levels. The results from assessing
the economic impact of the regulation are found in the Economic Assessment (EA) for the
industrial laundries proposed rulemaking (1).
EPA used the following approach in estimating compliance costs for the
industrial laundries industry:
• EPA mailed detailed questionnaires to a statistically selected sample of
industrial laundries (discussed in Chapter 3). The information from the
193 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 6.
• EPA analyzed field sampling data to determine the pollutant
concentrations of untreated wastewater in the industry (discussed in
Chapter 11).
• EPA identified candidate end-of-pipe wastewater treatment technologies
and grouped appropriate technologies into regulatory options (discussed
in Chapters 8, 9, and 10). The regulatory options serve as the bases for
compliance cost and pollutant loading calculations.
• EPA analyzed field sampling data and detailed monitoring questionnaire
(DMQ) data to determine pollutant removal performance of the
technology options (discussed in Chapter 11).
• EPA developed cost equations for capital and operating and maintenance
(O&M) costs for each of the technologies included in the regulatory
options based on information gathered from industrial laundry facilities,
wastewater treatment system vendors, and engineering judgement
(discussed in this chapter).
12-1 ;
-------
Chapter 12 - Costs of Technology Bases for Regulations
0 EPA developed and used a computerized design and cost model, the
Industrial Laundries Design and Cost Model (cost model), to calculate
compliance costs (presented in this chapter) and pollutant loadings
(presented in Chapter 11) for each option.
• 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 performed an analysis comparing each facility's annualized cost for each
regulatory option to the annualized cost for the facility to have their wastewater
contract hauled to an off-site treatment facility (presented in this chapter). If
the cost for contract hauling was less than the cost to install and operate an on-
site treatment system, the contract-hauling 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 industry-wide costs for the five regulatory options by estimating
compliance costs for the 193 in-scope facilities to purchase, install, and operate each of the
technology options. Using statistically calculated facility weighting factors, EPA then
extrapolated the results to the entire industrial laundries industry (1,747 industrial laundries).
The following information is discussed in this section:
• Section 12.2 discusses the costing methodology;
• Section 12.3 discusses cost modeling and summarizes cost estimating
assumptions and design bases for the technologies that comprise the
regulatory options;
• Section 12.4 presents the cost estimates by regulatory option; and
• Section 12.5 presents the references used in this section.
12.2 Costing Methodology
To accurately determine the impact of the proposed pretreatment standards on
the industrial laundries industry, EPA estimated costs associated with regulatory compliance.
The 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 basis for the calculated limitations of each regulatory option. Although the
12-2
-------
Chapter 12 - Costs of Technology Bases for Regulations
estimated compliance costs were developed based on implementation of these treatment
technologies, EPA emphasizes that the proposed regulations do not require that a facility
install or possess 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. In some cases, facilities were excluded from being
costed if they 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.
fc»
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 hi Chapter 10, EPA identified the following regulatory options:
• DAF-IL Option - Dissolved air flotation (DAF) treatment of wastewater
generated from the washing of industrial laundry items only; the cost
model uses long-term averages calculated from sampling data 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 laundry items only; the cost
model uses long-term averages calculated from sampling data for
chemical precipitation treatment of a facility.'s total process wastewater
stream to calculate pollutant removals for the CP-IL option.
• Combo-IL Option - Either DAF or chemical precipitation treatment of
wastewater generated from the washing of industrial laundry items only;
the cost model uses a single set of combined long-term averages, based
on the higher long-term average calculated for each pollutant from
sampling data for either DAF or chemical precipitation treatment of a
facility's total process wastewater stream to calculate pollutant removals
for the Combo-IL option.
12-3
-------
12.2.1
Chapter 12 - Costs of Technology Bases for Regulations
0 Combo-IL-2LIM Option - Either DAF or chemical precipitation
treatment of wastewater generated from the washing of industrial
laundry items only; the cost model uses two sets of long-term averages,
based on sampling data for either DAF or chemical precipitation
treatment of a facility's total process wastewater stream to calculate
pollutant removals for the Combo-IL-2LIM option. For facilities
currently operating DAF, the DAF limits are applied; for all other
facilities, the chemical precipitation limits are applied.
• QC-Onlv Option - Steam-tumbling treatment of facilities' heavy
industrial laundry items prior to water washing; the cost model uses
target concentrations calculated from steam tumbling sampling data to
calculate pollutant removals for 24 organic pollutants for the OC-Only
option.
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 FoxPro®.
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
FoxPro® 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
FoxPro® files, EPA decided to use FoxPro® 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. In addition, the MP&M cost model
12-4
-------
Chapter 12 - Costs of Technology Bases for Regulations
driver was designed to handle flow reduction technologies and practices as part of the
regulatory options. This allowed pollutant concentrations and flow rates from certain streams
to be adjusted as the streams were sent to flow reduction modules. Although flow reduction
technologies are currently not part of the proposed regulatory options for industrial laundries,
the MP&M cost model driver allows the flexibility to add them to the cost model.
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 importance of
each calculated value in the cost calculated for each technology module.
The inputs to the industrial laundries cost model include raw wastewater '
pollutant concentrations, flow rates, operating schedules, and treatment technologies currently
in place for each facility costed. EPA obtained the flow rates, operating schedules, and
treatment technologies currently in place 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 raw wastewater pollutant concentrations for each facility costed using sampling
and DMQ data based on each facility's production data, as described in Chapter 11. The
input information for the cost model was maintained in database files. Section 12.3 of this
document discusses the cost model and its operation in more detail.
12.2.2
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 1993. 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 6f 359.2 (2) and the index
value for the year in which the costs were originally reported in the following formula:
(359 o 1\
fir)
where:
AC = Adjusted cost, 1993 dollars
OC = Original cost, dollars
OCI = Original cost year index.
EPA used the cost model to calculate annual operating and maintenance
(O&M) and capital costs for each technology and to sum the capital and O&M costs for all
technologies at each facility. Annual O&M costs comprise all costs related to operating and
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Chapter 12 - Costs of Technology Bases for Regulations
maintaining the treatment system for a period of one year, including the estimated costs for
compliance monitoring of the effluent. 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 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. EPA
obtained the wage rate for all required labor to properly install, operate, and maintain 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. It was assumed that an industrial
laundry treatment system operator would receive an equivalent rate of pay as an installation
worker. Assumptions on the number of hours required of a worker to operate a treatment
system were made for each piece of equipment that was included in the treatment system for
each regulatory option. Section 12.3 of this document discusses these assumptions in detail.
EPA obtained the cost for electricity used by various treatment technologies
from the Department of Energy's Monthly Energy Review (4). The average cost of electricity
for industrial facilities for the year 1993 was $0.049 per kilowatt-hour.
Table 12-1 presents the O&M unit costs used by the cost model and includes
references for the origin of each cost.
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 12-2 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);
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Chapter 12 - Costs of Technology Bases for Regulations
Table 12-1
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
Cost93$$)
2.48 per pound
1.34 per pound
0.49 per pound
67.50 per ton
0.63 per pound
45 per ton
0.138 per pound
75 per ton
Module($)
DAF, Chemical
Precipitation
DAF, Chemical
Precipitation
DAF
Chemical
Precipitation
DAF
Chemical
Precipitation
pH Adjustment
DAF, pH Adjustment
Reference
(10, 12)
(10, 12)
(10)
(12)
(10)
(12)
(15)
(10, 15)
Equipment
Co$t (1993 $«)
5% 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 = 2,868.6 + 4.0721 x
C + (1.7502 x 10'5) x C2
(C = Capacity in pounds per hour)
Module(s)
Equalization, pH
Adjustment
Pump
Building
DAF, pH Adjustment
Reference i
(8, 15)
(6)
(16, 17)
(10, 15)
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Chapter 12 - Costs of Technology Bases for Regulations
Table 12-1 (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
Cost (1993 $s)
248.83 per year
5% of the direct capital cost of the
chemical precipitation unit per year
2% of the direct capital cost of the
DAF unit per year
1% of the direct capital cost of
pump per year
5% of direct capital cost of tank per
year
276.79 per probe
435.49 to 633.52335.14 per plate
replaced every two years
200 per year
180.78 to 263.76 per screen
replaced twice per year
106.94 to 154.09 per screen
2% of direct capital cost of tank per
year
Module(s)
Compliance
Monitoring
Chemical
Precipitation
DAF
Pump
Equalization,
pH Adjustment,
Contract Haul
pH Adjustment
Screen
Screen
Screen
Screen
Screen
Reference ;
(19)
(12)
(9, 10)
(6)
(8, 15,
19)
(15)
(7)
(7)
(7)
(7)
(7)
<5eneral Costs '.
Item
Electricity usage fee
O&M labor rate
(Cost (1993 $s)
0.049 per kilowatt-hour
25.27 per hour
Module(s)
All
All
Reference ;
(4)
(3)
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Chapter 12 - Costs of Technology Bases for Regulations
Table 12-2
Capital Unit Costs Used by the Cost Model
Capital Costs (includes 27 gpm)
Chemical feed system (0.01
to 3,200 Ib/hr)
Concrete slab
Concrete curb
Continuous chemical
precipitation treatment units
(2 to 150 gpm)
Continuous DAF treatment
units
(25 to 1,000 gpm)1
Covered and flanged
fiberglass tanks (110 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
Oast Q.993 Ss)
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* 10'3
x V2 per unit
(V = batch size in gallons)
19.38 per square foot
Cost = 3,168.998 + 2965.115 x log(P)
per agitator
(P = power requirement in hp)
Cost = 2,758.989 x long (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)
8.39 per square foot
6.51 per foot
Cost = 47,192 + 1,129.6 x C - 1.3255 x C2
per unit
(C = capacity in gpm)
Cost = 1 1 1,370 x log (C) - 139,260
per unit
(C = capacity in gpm)
Cost = 2,839.2 + 0.9004 x V
per tank
(V = volume in gallons)
Cost = 2,927.1 + 0.9182 x V
per tank
(V = volume in gallons)
4,096.61 to 7,599.38 per washer ,
M«dule(s)
Pump
Chemical
Precipitation
Building
pH Adjustment
Pump
DAF,
pH Adjustment
Building
Building
Chemical
Precipitation
DAF
Contract Haul
Equalization
Stream Splitting
Reference
(6)
(12)
(17)
(15)
(6)
(10, 15)
(17)
(17)
(12)
(10)
(19)
(8)
(5)
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Chapter 12 - Costs of Technology Bases for Regulations
Table 12-2 (Continued)
Capital Costs (includes crane rental)
Item
Filter press
(5 to 125 ft3)
Flange-mounted agitators
(0.25 to 5 hp)
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)
Utility installation and hook
up
Cost (l$93 $s)
Cost = 33,331 x ln(C) - 36,195
per press
(C = capacity in ft3)
Cost = 4,247.414 + 2,616.527 x log (P)
per agitator
(P = power requirement in hp)
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 2130.04 per pump
27.08 per foot
8,131.76 to 9,542.93 per unit
1.14 per square foot
Module(s)
Sludge
Dewatering
Equalization
Screen,
pH Adjustment
pH Adjustment
Pump
Stream Splitting
Screen
Building
Reference
(13)
(8)
(7, 15)
(15)
(6)
(5)
(7)
(17)
'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 S500 per facility was allowed to account for any necessary elbow joints or other connections.
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Chapter 12 - Costs of Technology Bases for Regulations
« 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).
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 12-3
presents the components of the total capital investment, including the indirect capital cost
factor used by the cost model.
12.2.3
Treatment-in-PIace Credit Methodology
EPA evaluated facility responses to the detailed questionnaire to determine
which treatment technologies are currently in place and in operation at each facility. 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 were estimated for facilities that
were determined to have treatment equivalent to an option currently in use. EPA's
methodology for giving credit to facilities for existing treatment on site is discussed below.
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Chapter 12 - Costs of Technology Bases for Regulations
Table 12-3
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 i
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
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Chapter 12 - Costs of Technology Bases for Regulations
Stream splitting - EPA gave stream-splitting credit to facilities that
indicated that a portion of their wastewater was currently being
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 stream under the assumption that the screen was
adequate to treat a larger amount of wastewater stream 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., DAP, 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
12.3 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 12.2.2 of
this document. Section 12.3 further discusses this treatment-in-place
cost estimate.
Sludge dewatering devices - EPA gave facilities full sludge dewatering
credit if they indicated that their sludge dewatering device treated sludge
being generated by either DAF or chemical precipitation; facilities that
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Chapter 12 - Costs of Technology Bases for Regulations
indicated that they treat their sludge with a conditioner received full
sludge conditioning credit in the DAF-IL regulatory option.
• pH adjustment (applicable to options utilizing chemical precipitation
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; 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)); and full credit in the total stream treatment options only
if they indicated that they use in-line pH adjustment.
• Space inside of the facility - EPA costed facilities for a building of
adequate size to house the treatment 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 currently monitor their wastewater effluent.
12.3 Cost Modeling
12.3.1 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 regulatory
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 regulatory 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 regulatory options. Chapter 10 discusses in greater detail
the specific combinations of these technologies into the regulatory options. These
technologies, components, and practices are listed below:
• Organics control via steam tumbling of heavy industrial laundry items;
• Wastewater and sludge transfer pumps;
• Buildings;
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Chapter 12 - Costs of Technology Bases for Regulations
• Stream splitting;
• Mechanical screening;
• Equalization;
• Dissolved air flotation; ',
• Chemical precipitation;
• Sludge dewatering; ;
• pH adjustment; and
• Contract hauling of untreated wastewater.
As discussed in Section 12.2.1, 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;
• 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;
— 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.
12.3.2
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 for
the IL options in order for each facility to direct all wastewater generated from the washing of
industrial items to the wastewater treatment system, while allowing the facility to discharge
wastewater generated from the washing of nonindustrial items (i.e., linen items) to the sewer
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Chapter 12 - Costs of Technology Bases for Regulations
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 surnp 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 currently segregates its wastewater, costs were calculated for the required sized
valve(s), 200 feet of PVC 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 currently 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 (5). 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 item
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
currently transferring each segregated stream to a treatment unit, it was given credit for
having the pump in place. Refer to Section 12.3.3 below for a more detailed description of
the pumps cost module.
12.3.3
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 technology
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Chapter 12 - Costs of Technology Bases for Regulations
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 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 in the IL options 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 module), because it was assumed that the wastewater
can flow by gravity into the sewer.
Direct annual costs included O&M labor and 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 and O&M 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 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. Typically, the
annual operating labor required for each pump is approximately 15 minutes per week and
maintenance activities require approximately 15 to 30 minutes per week (6).
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.
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Chapter 12 - Costs of Technology Bases for Regulations
12.3.4
Screening
Mechanical screens are commonly used at industrial laundries to remove lint
and other solid constituents from wastewater. Therefore, in each of the IL regulatory options,
EPA estimated costs for mechanical screening of a facility's untreated wastewater from the
washing of nonindustrial laundry items prior to recombination with treated wastewater from
the washing of industrial 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.
e
«
Direct annual costs included O&M labor and 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 and O&M 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. The annual operating labor required for changing out each drum or sack
of collected lint is calculated assuming it takes one worker 10 minutes per sack. The number
of drums or sacks that will be changed per year is calculated based on average lint generation
rates (gallons of lint removed per gallon of wastewater screened) that were reported by
industrial laundry facilities in the detailed questionnaire. Annual maintenance labor for the
shaker screen was estimated by the vendor to be 75 minutes per year to regularly replace
various parts (e.g., the screen, sliders, and perforated plates) and approximately 30 minutes
per week to grease the motor bearings. The annual O&M labor cost for the holding tank is
not calculated as a separate item, but is included as part of the estimating factor for the total
annual cost (i.e., two percent of the direct capital cost of the tank), based on estimates used in
past effluent guidelines efforts (7).
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Chapter 12 - Costs of Technology Bases for Regulations
A cost was calculated for a screen if a facility did not report that it currently
has 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 currently screens any portion of its wastewater
would also be able to screen the wastewater generated from washing its industrial laundry
items and, therefore, EPA calculated zero capital and annual costs for the screen in the IL
options.
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 and operating labor, were also included as part of the shaker screen module. If a
facility indicated that it was currently 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 12.3.3 of this document for a more detailed description of the pumps cost module.
12.3.5
Equalization
EPA estimated costs for the equalization of a facility's industrial laundry
wastewater in the IL options. 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.
Direct annual costs included O&M labor and material costs, as well as 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 (8). 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.
The equalization module includes an estimate of installation and O&M labor
costs for the equalization tank and mixer. All labor estimates are based on information
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Chapter 12 - Costs of Technology Bases for Regulations
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. The annual O&M labor 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 (i.e., five percent of the direct capital cost of the
items), based on estimates used hi past effluent guidelines efforts (8).
A cost was calculated for an equalization tank if a facility did not report that it
has a large enough tank currently 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 currently
transferring the stream to another treatment unit, it was given credit for having the effluent
pump in place. Refer to Section 12.3.3 of this document for a more detailed description of
the pumps cost module.
12.3.6
Dissolved Air Flotation
EPA estimated costs for DAF treatment of wastewater generated from the
washing of industrial laundry items hi the DAF-IL, Combo-IL, and Combo-IL-2LIM options.
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.
module:
Capital and annual costs for the following equipment were included in the DAF
• 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.
Direct annual costs included O&M labor and material costs, energy costs, and
raw material (e.g., sulfuric acid, ferric chloride, cationic polymer, anionic polymer, and
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Chapter 12 - Costs of Technology Bases for Regulations
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 of
Industrial Laundry Wastewater Flow
0.8
0.9
2
0.07
0.25 pounds per pound of sludge collected from the
DAF unit on a dry-solids basis
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 long-term averages calculated from DAF system sampling and
DMQ data. The module also calculated effluent and sludge flow rates 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 DAF treatment.
The DAF module includes an estimate of installation and O&M 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 td be included in an
installation cost factor of six percent of the purchased cost. The vendor estimated that the
annual operating labor required one worker four hours per day, mostly to condition the sludge
prior to dewatering. The maintenance labor for the DAF unit was estimated to be included as
part of the total maintenance cost factor of two percent of the DAF system capital cost (9).
The DAF module also includes installation and O&M labor costs for the
chemical feed system. The installation and annual maintenance labor for the chemical feed
system were calculated with the total capital and annual costs, respectively, from the cost
curves obtained from past effluent guidelines costing efforts. The labor hours were not
broken out as separate items (10).
A cost was calculated for a DAF unit if a facility did not report that it currently
treats 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
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Chapter 12 - Costs of Technology Bases for Regulations
flow with DAF was given full credit for all of the IL options and received only monitoring
costs to comply with the proposed rule under these options. However, a facility that reported
treating a portion of its wastewater was evaluated as to whether it had sufficient DAF capacity
to treat the wastewater according to each option. 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 currently 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, ultrafiltration and
microfiltration are considered to provide greater pollutant removals than DAF (H).
Therefore, facilities with chemical precipitation, ultrafilters, or microfilters received treatment-
in-place credit for having a complete DAF system for treatment of all or a portion of their
process wastewater, as appropriate.
12.3.7
Chemical Precipitation
EPA estimated costs for chemical precipitation treatment of wastewater
generated from washing industrial laundry items in the CP-IL, Combo-IL, and Combo-IL-
2LIM options. 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;
e 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:
i
• A continuous chemical precipitation unit (including three chemical
addition units, pH controller, chemical premix tanks and inclined plate
settlers);
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Chapter 12 - Costs of Technology Bases for Regulations
• A positive displacement sludge transfer pump;
• A sludge holding tank; and
• A centrifugal effluent pump.
Direct annual costs included O&M labor and 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 «| Chemical Addsd per JO,flOO Callous
Industrial Laundry Wastewater Flow
0*
100 pounds
2 gallons
0.07 gallon
The module calculates pollutant loads in the treated wastewater effluent using
long-term averages calculated from chemical precipitation system sampling and DMQ data.
The module also calculates effluent and sludge flow rates 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 and
O&M 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. The O&M labor for the chemical precipitation unit was
estimated to be included as part of the estimating factor for the total annual cost (i.e., five
percent of the chemical precipitation system capital cost), based on past effluent guidelines
costing efforts (12).
A cost was calculated for a chemical precipitation unit if a facility did not
report that it currently treats its wastewater with chemical precipitation. Facilities that had
chemical precipitation units of sufficient capacity were given full option credit. For example,
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Chapter 12 - Costs of Technology Bases for Regulations
a facility that reported treating its total wastewater flow with chemical precipitation was given
full credit for all of the IL options and received only monitoring costs to comply with the
proposed 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 12.3.6 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 unit simultaneously.
Instead, these facilities received no credit toward the IL options and received capital and
annual costs to install and operate a new continuous 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 12.3.3 of this document for a more detailed
description of the pumps cost module.
Ultrafiltration and microfiltration are considered to provide greater pollutant
removals than chemical precipitation (11). Therefore, facilities with ultrafilters or microfilters
received treatment-in-place credit for having a complete chemical precipitation system for
treatment of all or a portion of their process wastewater, as applicable.
12.3.8
Sludge Dewatering
EPA estimated costs for facilities to dewater the sludge generated by either a
DAF or chemical precipitation unit in the DAF, chemical precipitation and Combo options.
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.
Direct annual costs included O&M labor and material costs, energy costs, and
dewatered cake disposal cost. The capital and annual costs associated with the filter press
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Chapter 12 - Costs of Technology Bases for Regulations
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 and O&M
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. The operating labor required for the filter press is estimated by the vendor to
be between 30 and 60 minutes per batch. The vendor also estimated an additional two hours
per year for maintenance on the press (mostly for changing the filter cloths) (13).
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 and operating labor, were also included as
part of the sludge dewatering module. If a facility indicated that they were currently
dewatering an appropriate amount of sludge, they were given credit for having the influent
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Chapter 12 - Costs of Technology Bases for Regulations
pump in place. Refer to Section 12.3.3 of this document for a more detailed description of
the pumps cost module.
12.3.9
pH Adjustment
EPA estimated costs for facilities to adjust the pH of the effluent wastewater
generated by the chemical precipitation options. 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.
Direct annual costs included O&M labor and 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
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 options 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 options is
already within the assumed pH limits, pH adjustment costs are not calculated for these
options.
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 target pH in a mixed tank with liquid chemical addition (14). 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
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Chapter 12 - Costs of Technology Bases for Regulations
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 and O&M 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. The annual O&M labor cost for the
equalization tank and mixer 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 items),
based on estimates used in past effluent guidelines efforts (15).
The pH adjustment module also includes installation and O&M labor costs for
the chemical feed system. The installation labor and the annual maintenance labor for the
chemical feed system were included in the total capital and annual costs, respectively, used
from past effluent guidelines costing efforts. The labor hours were not broken out as separate
items.
A facility received full pH adjustment treatment-in-place credit if it reported
currently 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 tune requirement
and received treatment-in-place credit for any tank that was available to use for pH
adjustment. Facilities that reported using in-line pH adjustment received chemical addition
and pH monitoring credit. EPA assumes that adjusting the pH while combining the treated
and untreated streams close to the discharge point does not allow for sufficient mixing of the
streams and the chemical; thus the target pH would be not be consistently achieved.
12.3.10
Treatment System Building
EPA estimated costs for facilities to construct a building to house the option
treatment system. The building module calculates the costs necessary to construct and
maintain a building designed to house the option treatment system.
Capital and annual costs for the following equipment were included in the
treatment system building:
e
e
e
e
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).
Direct 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
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Chapter 12 - Costs of Technology Bases for Regulations
direct capital cost (16). The capital cost associated with constructing the building was based
on the required size of the building. The square footage requirement of the concrete slab and
building, as well as the perimeter length of curbing, were determined for each 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 three- to six-foot clearance between
equipment pieces and the building walls. The costs per foot of curbing and costs per square
foot of slab and building were both obtained from vendors. All buildings for which costs
were calculated by the module included a 16-foot eave height and one 10-foot by 10-foot
overhead bay door. All of the installation cost estimates provided by the vendor include the
required labor (17).
A facility received full credit for a building in place if they reported having
sufficient space currently 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.
12.3.11
Contact Haul In Lieu of Treatment
EPA assessed 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
compared to the cost of on-site treatment. The equipment included in the industrial laundries
treatment options have minimum sizes and capacities. For industrial laundries with low flow
rates, it was sometimes found to be less expensive for a facility to have wastewater contract
hauled for off-site disposal rather than treat the wastewater on site. To assess contract hauling
in lieu of treatment, EPA compared the annualized cost of contract hauling the wastewater to
be treated 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;
Direct annual costs included operating and maintenance 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 30
days 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-
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Chapter 12 - Costs of Technology Bases for Regulations
site industrial treatment facility were calculated based on the number of trips per year required
to haul the wastewater (assuming each trip involves using one 5,000-gallon tank truck to haul
the wastewater) 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-in-lieu-of-treatment 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 (18). The installation labor
required for the stream-splitting components is described in Section 12.3.2 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 12.3.3 of this document for a
more detailed description of the pumps cost module.
12.3.12
Compliance Monitoring
EPA calculated annual compliance monitoring costs for all industrial laundry
facilities that discharge wastewater. The annual cost calculated by the cost model for
compliance monitoring included laboratory costs to analyze composite samples of volatile and
semivolatile organics and quantitative metals monthly, and to analyze total petroleum
hydrocarbons (measured as silica gel treated-hexane extractable material) once a month
collected as four grab samples. The costs for each type of analysis per sample were obtained
from a laboratory contracted by EPA on past wastewater sampling efforts. EPA assumed that
one worker would be required to spend eight hours per month to collect the samples for
analysis. 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.
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Chapter 12 - Costs of Technology Bases for Regulations
Facilities that reported in the detailed questionnaire that they currently monitor
their wastewater were only costed for the analyses. Otherwise, facilities were costed for the
analysis, labor, and materials required for the wastewater monitoring. EPA assumed it would
take one worker eight hours per month to perform collect the samples (19).
12.4
Engineering Costs by Regulatory Option
Table 12-4 summarizes estimated engineering costs by regulatory option for
Pretreatment Standards for Existing Sources (PSES). Costs shown include capital and annual
O&M (including energy usage) costs totaled for the 193 in-scope facilities extrapolated to
represent the entire industrial laundries industry of 1,747 facilities. In addition, the capital
and O&M costs are shown for 21 in-scope facilities (representing 141 facilities in the
industry) which are excluded from the proposed regulation, as discussed in Chapter 6.
Table 12-5 summarizes estimated PSES engineering costs on an amortized
yearly basis for the 172 in-scope facilities that are included in the proposed regulation, as
discussed in Chapter 6. These costs were extrapolated to represent a total of 1,606 facilities
included in the regulation. 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 is less expensive to operate on an
annualized basis than DAF because of much lower operating and maintenance costs for
chemical precipitation than for DAF. EPA's performance data show that chemical
precipitation achieves better treatment than DAF. In EPA's estimates, facilities that currently
operate a DAF would realize an operating and maintenance cost savings for operating a
chemical precipitation unit compared to operating a DAF unit. Therefore, EPA's estimated
costs for the CP-IL option include operating and maintenance cost credit for facilities that
currently operate a DAF to replace the DAF unit with a chemical precipitation unit. EPA's
costing analysis for the Combo-IL and Combo-IL-2LIM options assumed that all facilities that
already have DAF installed would continue to operate it if given the choice because of
constraints on financing (the limits for these options can be achieved by DAF). Since the cost
estimates for Combo-IL and Combo-IL-2LIM do not involve replacement of DAF units, there
are no operating and maintenance cost credits in these options. For this reason, the Combo-IL
and Combo-IL-2LIM options are estimated to be more expensive on an annualized basis than
the CP-IL option.
12.5
1.
References
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 12 - Costs of Technology Bases for Regulations
Table 12-4
Summary of PSES Engineering Costs
Option
Capital Cost
(Million 1993 $s)
O&M Cost
(Million S/yr (in 1993 Ss))
Capital and Annual Costs for All Industrial Laundries
DAF-IL
CP-IL
Combo-IL
Combo-IL-2LIM
OC-Only
349
449
421
349 - 449
273 :
131
83.4
94.1
83.4 - 131
32.2
Capital and Annual Costs for the Excluded Industrial Laundries
DAF-IL
CP-IL
Combo-IL
Combo-IL-2LIM
OC-Only
. 19.5
24.1 1
22.2
19.5 - 24.1
10.3
5.98
4.98
5.03
4.98 - 5.98
0.606
Source: Output from the Industrial Laundries Design and Cost Model, July 15, 1997.
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Chapter 12 - Costs of Technology Bases for Regulations
Table 12-5
Summary of PSES Annualized Engineering Costs
for Industrial Laundries Included in the Proposed Regulation
Option
DAF-IL
CP-IL
Combo-IL
Combo-IL-2LIM
OC-Only
Annualized Cost
(Million $/yr {in 1993 $s» !
107
85.0
90.0
85.0 - 107
41.6
Source: Economic Assessment for Proposed Pretreatment Standards for Existing and New Sources for the Industrial Laundries Point Source
Category. EPA-821-R-97-005, November 1997.
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2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
Chapter 12 - Costs of Technology Bases for Regulations
"Economic Indicators". Chemical Engineering. March 1994, page 182.
The Richardson Rapid System Process Plant Construction Estimating Standards.
Volume 4: Process Equipment, 1994.
U.S. Department of Energy. Monthly Energy Review. DOE/EIA-0035(94/03),
March 1994.
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, November 1997.
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, DC, November 1997.
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, November 1997.
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, DC, November 1997.
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.
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, DC,
November 1997.
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.
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, DC,
November 1997.
12-33
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13.
14.
15.
16.
17.
18.
19.
Chapter 12 - Costs of Technology Bases for Regulations
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, DC, November 1997.
Trimble, D. "Neutralizing Alkaline Wastewaters". Textile Rental. November
1994, pages 80-82.
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, DC, November 1997.
Peters, Max S. et al. Plant Design and Economics for Chemical Engineers.
Fourth Edition. McGraw-Hill, Inc., 1991.
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, DC, November 1997.
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, November 1997.
Eastern Research Group, Inc. Monitoring Cost Estimate. Prepared for the U.S.
Environmental Protection Agency, Office of Water, Washington, DC, May
1997.
12-34
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Chapter 13 - Regulatory Options Selection
CHAPTER 13
REGULATORY OPTIONS SELECTION
13.1
Introduction
This chapter summarizes the regulatory options for Pretreatment Standards for
Existing Sources (PSES) and Pretreatment Standards for New Sources (PSNS) considered by
EPA as the basis for the proposed rule and discusses the factors considered in determining the
selected options for PSES and PSNS. Chapter 10 presents all technology options evaluated
for the industrial laundries industry and summarizes the factors considered in eliminating from
further consideration some of the technology options for PSES and PSNS. Factors considered
in developing and selecting the options include: effectiveness of treatment technology, costs
to the industry, age of the equipment and facilities involved, the laundering processes used,
process changes required, non-water quality environmental impacts, engineering aspects of the
control technologies, energy requirements, and ease of option implementation.
The regulatory options selected provide the technology bases for the
pretreatment standards for existing and new sources presented in Section 1.3.1 of this
document. Owners or operators of facilities subject to these regulations are not required to
use the specific wastewater treatment technologies selected by EPA to establish the standards.
Rather, a facility can use any combination of process changes, water use changes, and
wastewater treatment to comply with the standards, provided that the standards are not
achieved through prohibited dilution.
Section 13.2 summarizes the regulatory options considered by EPA, and
Section 13.3 presents the rationale for the options selected under PSES and PSNS.
13.2
Regulatory Options Considered
This section discusses the regulatory options considered by EPA as the basis for
the industrial laundries proposed rule. Section 13.2.1 presents the regulatory options
considered for PSES, and Section 13.2.2 presents the regulatory options considered for PSNS.
As discussed in Chapter 10, EPA is not proposing regulations for direct dischargers at this
time.
13.2.1
Pretreatment Standards for Existing Sources (PSES)
Pretreatment standards for existing sources establish quantitative limits on the
indirect discharge of priority and nonconventional pollutants to waters of the United States
(i.e., PSES limit industrial discharges to publicly owned treatment works (POTWs)). PSES
are designed to prevent the discharge of pollutants that pass through, interfere with, or are
otherwise incompatible with the operation of POTWs. The Clean Water Act (CWA) requires
pretreatment for pollutants that pass through POTWs in amounts that would exceed direct
13-1
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Chapter 13 - Regulatory Options Selection
discharge effluent limitations or limit POTW sludge management alternatives, including the
beneficial use of sludges on agricultural lands. These limits are based upon the performance
of specific technologies, but they do not require the use of any specific technology. PSES are
applied to individual facilities and are administered by local permitting authorities (i.e., the
government entity controlling the POTW to which the industrial wastewater is discharged).
The facility then chooses its own approach to complying with its permit limitations.
The regulatory options considered for PSES for the proposed industrial
laundries rule are presented in Chapter 10. These five options are summarized in the
following table:
Definitions of PSES Regulatory Options Considered for the Industrial Laundries Rute
Regulatory Option
DAF-IL
CP-IL
Combo-IL
Combo-IL-2LIM
OC-Only
. -, 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.
Organics control (steam tumbling) of heavy items.
BiisisofLOftg-Terttl
Average (LTA)
Treatment
Performance
DAF-all
CP-all
The higher LTA
between DAF-all and
CP-all
DAF-all or CP-all,
based on technology
costed
OC-only
13.2.2
Pretreatment Standards for New Sources (PSNS)
Pretreatment standards for new sources are designed to prevent the discharge of
pollutants that pass through, interfere with, or are otherwise incompatible with the operation
of POTWs. The CWA requires pretreatment for pollutants that pass through POTWs or limit
POTW sludge management alternatives. The new source has the opportunity to design and
install the best and most efficient industrial laundry processes and wastewater treatment
facilities. Accordingly, Congress directed EPA to consider the best demonstrated alternative
processes, process changes, in-plant control measures, and end-of-pipe wastewater treatment
technologies that reduce pollution to the maximum extent feasible. In response to that
directive, EPA considered effluent reductions attainable by the most advanced and
demonstrated process and treatment technologies at industrial laundries. The factors
considered hi assessing PSNS include:
13-2
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Chapter 13 - Regulatory Options Selection
• The demonstration status of the process and wastewater treatment
technologies;
• The cost of achieving effluent reductions;
• Non-water quality environmental impacts; and
• Energy requirements.
EPA considered the five regulatory options summarized in the previous section
for PSES as the basis for PSNS.
13.3
Final Regulatory Options Selection
This section discusses the regulatory options selected for the industrial laundries
proposed rule for PSES and PSNS. Levels of control for direct dischargers are also
discussed.
13.3.1
Pretreatment Standards for Existing Sources (PSES)
In selecting the regulatory option for PSES, the Agency determined the total
pounds of toxic and nonconventional pollutants (excluding TOC and COD) that would be
removed from wastewater discharges from industrial laundries covered by PSES for each
regulatory option. (Industrial laundries covered by PSES include facilities processing one
million or more pounds of incoming laundry per calendar year and 255,000 or more pounds
of shop towels and/or printer towels/rags per calendar year. Industry scope is discussed in
detail in Chapter 6.) The Agency also estimated the total compliance cost to the industry for
each of the regulatory options. The following table lists the pollutant removals and costs
(determined in Chapters 11 and 12, respectively) for industrial laundries covered by PSES for
the five regulatory options considered.
Estimated Annualized Costs and Toxic and Nonconventional Pollutant Removals from Industrial
Laundry Discharges for Covered Industrial Laundries After Implementing PSES1
Option
DAF-IL
CP-IL
Combo-IL
Combo-IL-2LIM
OC-Only
Estimated Mass of
Pollutants Removed
Annually Including TPH
{thousands of pounds)
12,578
12,768
12,324
12,578 - 12,768
70
Estimated Mass of
TPH Removed
Annually (thousands
of pounds)
10,596
10,828
10,596
10,596 - 10,828
0
Annualized
Cost to
Industry
{millions of
1993 $s)
107.0
85.0
90.0
85.0 - 107.0
41.6
Option
Selected?
/
'Data for 1,606 in-scope industrial laundries for which PSES apply.
13-3
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Chapter 13 - Regulatory Options Selection
EPA selected the CP-IL Option for PSES for industrial laundries covered by
PSES because it achieves the greatest reduction in pollutants discharged. This option, as
discussed in the preamble to the proposed rule, is technically available and represents the best
performance economically achievable. Furthermore, the CP-IL Option has acceptable non-
water quality environmental impacts.
13.3.2
Pretreatment Standards for New Sources (PSNS)
La selecting the regulatory option for PSNS, the Agency determined the total
pounds of pollutants that would be discharged by new industrial laundries for each regulatory
option. (EPA is proposing no exclusions by size for new industrial laundries. Industry scope
is discussed in detail hi Chapter 6.) The Agency also considered the total compliance cost of
the proposed PSNS technologies for new facilities for each of the regulatory options. EPA
selected the CP-IL Option for PSNS for the reasons mentioned in Section 13.3.1 of this
document and discussed in the preamble to the proposed rule.
13.3.3
Direct Dischargers
EPA is reserving effluent limitations guidelines for direct dischargers because
EPA has identified no direct dischargers and has no means of evaluating performance to
determine the appropriate level of control. Proposed limitations based on pretreatment control
technologies would not likely represent best available technology or best available
demonstrated technology for direct dischargers because the treatment technologies at existing
industrial laundries that EPA evaluated were not designed for treatment prior to discharging
directly to surface waters. The type or design (i.e., size) of treatment would not represent
BAT because in all cases facilities rely on additional treatment at POTWs. For the pollutants
evaluated in this proposed rule, the POTWs biological treatment removed from 4 percent to
99 percent depending on the pollutant. Because EPA has not identified any POTWs receiving
a very large proportion of their load (70 to 100 percent) from an industrial laundry, a
determination of direct discharge effluent limitations cannot be performed.
EPA is reserving the following direct discharge levels of control: Best
Practicable Control Technology Currently Available (BPT), Best Conventional Pollutant
Control Technology (BCT), Best Available Technology Economically Achievable (BAT), and
New Source Performance Standards (NSPS). If any direct dischargers arise, they would be
subject to limitations set on a best professional judgement basis.
13-4
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Chapter 14 - Non-Water Quality Environmental Impacts
14.1
CHAPTER 14
NON-WATER QUALITY ENVIRONMENTAL IMPACTS
Introduction
As required by Sections 304(b) and 306 of the Clean Water Act, EPA
considered the non-water quality environmental impacts associated with the implementation of
the regulatory options considered as the basis for the proposed PSES and 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 CP-IL and DAF-IL
regulatory options on energy consumption, air emissions, and solid waste generation of oil and
sludge. EPA also considered the impacts of the CP-IL and DAF-IL regulatory options on
noise pollution, water usage, and chemical usage. EPA has determined that changes in noise
pollution, water usage, and chemical usage from the CP-IL and DAF-IL regulatory options
would be acceptable. Because the Combo-IL and Combo-IL-2LIM options involve
combinations of the CP-IL and DAF-IL options, the non-water quality environmental impacts
for Combo-IL and Combo-IL-2LIM would be within the range of the impacts for CP-IL and
DAF-IL. EPA did not evaluate the non-water quality environmental impacts of the OC-Only
option.
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, solid waste generation, and air emissions. Specifically, the following
information is presented in this chapter:
e Section 14.2 presents the non-water quality environmental impacts
associated with the implementation of the CP-IL and DAF-IL regulatory
options considered as the basis for PSES for the Industrial Laundries
Point Source Category;
• Section 14.3 presents the non-water quality environmental impacts
associated with the implementation of the regulatory options considered
as the basis for PSNS for the Industrial Laundries Point Source
Category; and
Section 14.4 presents the references used.
14.2
Non-Water Quality Environmental Impacts of the CP-IL and DAF-IL
Regulatory Options Considered as the Basis for PSES
EPA evaluated the non-water quality environmental impacts associated with
implementation of the CP-IL and DAF-IL regulatory options considered as the basis for PSES
14-1
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Chapter 14 - Non-Water Quality Environmental Impacts
for the Industrial Laundries Point Source Category. These options are described in Chapter
10 of this document. Specifically, the following information is presented in this section:
• Section 14.3.1 presents the energy consumption impacts;
• Section 14.3.2 presents the air emission impacts; and
14.2.1
• Section 14.3.3 presents the solid waste impacts.
Energy Consumption Impacts
EPA evaluated energy consumption impacts associated with implementation of
the CP-IL and DAF-IL options. Based on this evaluation, EPA estimates that compliance
with either of these options would result in a net increase in energy consumption for the
industrial laundries industry. To calculate incremental energy increases for the industrial
laundries industry, EPA examined the wastewater treatment in place at the industrial laundries
that would be covered by the proposed regulation. For the CP-IL and DAF-IL options, EPA
used the industrial laundries cost model to calculate the energy that would be required to
operate wastewater treatment equipment to be installed at industrial laundries that are not
currently operating treatment systems comparable with these options. The industrial laundries
cost model is described in Chapter 12. EPA extrapolated the energy increases to represent the
entire industrial laundries industry, and estimated the incremental energy increase for the
industrial laundries industry as a result of the CP-IL and DAF-IL options. The incremental
increases in electricity use from all existing in-scope industrial laundries identified by EPA for
the CP-IL and DAF-IL regulatory options are presented in Table 14-1. Table 14-1 also
presents the average incremental increase per facility (based on 1,606 in-scope industrial
laundries identified by EPA) and the percentage of the national energy requirements
represented by the incremental increase for each regulatory option. (Approximately 2,805
billion kilowatt hours of electric power were generated in the United States in 1990(1)).
EPA estimates that the incremental energy 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 has determined that energy impacts from the proposed rule would be
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 for hot water generation. The use of heat reclaimers at
industrial laundries for energy conservation is discussed in Chapter 8.
14.2.2
Air Emissions Impacts
Industrial laundry facilities generate wastewater that contains significant
concentrations of organic pollutants, some of which are on the list of Hazardous Air
Pollutants (HAPs) in Title 3 of the Clean Air Act Amendments (CAAA) of 1990.
14-2
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Chapter 14 - Non-Water Quality Environmental Impacts
Table 14-1
Incremental Energy Increases Associated With Implementation of the
CP-IL and DAF-IL Regulatory Options
PSES Regulatory
Option Considered for
Proposal*
DAF-IL
CP-IL
Incremental Energy increases^
Total Industry Increase
(million kilowatt hours)
79.9
75.6
Average Increase Per
Facility plowtf*
hours)
49,700
47,100
Percentage of
National Energy
Requirements^
0.003%
0.003%
'Regulatory options are presented in Chapter 10 of this document.
Incremental energy increases are based on 1,606 industrial laundries covered by the proposed rule.
Approximately 2,805 billion kilowatt hours of electric power were generated in the United States in 1990(1).
14-3
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Chapter 14 - Non-Water Quality Environmental Impacts
Atmospheric exposure of the organic-containing wastewater may result in volatilization of
HAPs and volatile organic compounds (VOCs) from the wastewater. Emissions from
wastewater treatment systems occur at process drains, manholes, trenches, sumps, screens,
equalization basins, dissolved air flotation units, chemical precipitation units and at any other
locations where the wastewater is in contact with the air.
EPA believes, however, that air emissions from existing industrial laundry
wastewater would be similar before and after implementation of the PSES regulatory options
considered for proposal. 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. Air emissions from the wastewater occur as the wastewater flows from the ,
facility to the POTW and at the POTW. At a facility with treatment, the wastewater has
more contact with air while still at the facility as it is treated in open tanks and other open
treatment 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 and at the POTW. EPA believes that the overall amount of air emissions
from industrial laundries wastewater would not change as a result of the PSES regulatory
options considered for proposal, but that the location of air emissions would shift from the
POTW's treatment system to the facility's treatment system.
EPA evaluated total fugitive air emissions for a representative industrial
laundry based on a worst-case scenario. EPA considered whether this total amount of fugitive
air emissions would be acceptable assuming it represented incremental air emissions due to
each of the PSES regulatory options considered for proposal. However, EPA does not believe
that the total amount of fugitive emissions calculated represents incremental air emissions
because the amount of air emissions would be similar before and after implementation of the
rule. EPA's methodology for estimating fugitive air emissions is described below.
As discussed in Chapter 9, EPA collected and analyzed wastewater samples at
six industrial laundries operating treatment systems that effectively treated industrial laundry
wastewater. These treatment systems are also the basis of the five PSES regulatory options
considered for proposal. At all six facilities, total raw wastewater samples were collected.
EPA selected the facility with the highest raw wastewater 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 all of the PSES regulatory options considered for proposal 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.
14-4
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Chapter 14 - Non-Water Quality Environmental Impacts
EPA used the following formula to calculate annual fugitive emissions of
organic pollutants:
Mg _ fx_rng_
year I liter
I, 78« liters
J. /OJ
gallon
1 Mg
1 x 10y mg
where
Y = megagrams of organic pollutant volatilized per year;
X = average concentration of the organic pollutant in the wastewater;
F = average daily wastewater flow rate; and
N = average days of operation per year.
Fugitive emissions were calculated for all volatile and semivolatile organic pollutants. 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 emissions levels
presented in Table 14-2. Based on summing the fugitive emissions for each individual HAP,
the total annual HAP emissions from this industrial laundry would be 14 Mg/year.
Under the Clean Air Act, major sources of pollution by HAPs are defined as
having either:
(1) A total emission of 25 Mg/year or higher for the total of all HAPs from
all emission points at a facility; or
(2) An emission of 10 Mg/year or higher for a single HAP from all
emission points at a facility.
Based on these criteria, fugitive air emissions from this worst-case industrial laundry would
not be classified as a major source of pollution. Based on the assumptions made to evaluate a
worst-case scenario, the increases in fugitive air emissions from the PSES regulatory options
considered for proposal would be much less than the fugitive air emissions calculated from
the worst-case scenario. Because EPA does not believe there would be an overall increase in
air emissions and because even a shift of location of air emissions would not render a facility
a major source of air pollution, EPA has determined that the incremental fugitive air
emissions impacts from the PSES regulatory options considered for proposal are acceptable.
14-5
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Chapter 14 - Non-Water Quality Environmental Impacts
Table 14-2
Fugitive Air Emissions of Organic Pollutants From Industrial Laundry
Wastewater — Analysis of a Worst-Case Scenario
Organic Air Pollutant
Hazardous Air
Pollutant?
Kaw Wastewater
Concentration
(tttg/k)
Amount Volatilized
(Mg/yfcar)
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
m-Xylene
Methylene Chloride
o-dc/7-Xylene
Tetrachloroethene
Toluene
trans-\ ,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
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
Semivolatile Organics
1 ,2-Diphenylhydrazine
2,3,6-Trichlorophenol
2,4,5-Trichlorophenol
Y
N
Y
0.20
0.10
0.10
0.04
0.02
0.02
14-6
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Chapter 14 - Non-Water Quality Environmental Impacts
Table 14-2 (Continued)
Organic Air Pollutant
2,4, 6-Trichlorophenol
2,4-Dichlorophenol
2,4-Dimethylphenol
2,4-Dinitrophenol
2-Chlorophenol
2-Methylnapthalene
2-Nitrophenol
4-Chloro-3-methylphenol
4-Nitrophenol
oc-Terpineol
Benzole Acid
Benzyl Alcohol
Bis(2-ethylhexyl) Phthalate
Bromodichloromethane
Butyl Benzyl Phthalate
Diethyl Phthalate
Dimethyl Phthalate
Di-n-butyl Phthalate
Di-n-octyl Phthalate
Hexanoic Acid
Isophorone
Naphthalene
n-Decane
n-Docosane
n-Dodecane
Hazardous Air
Pollutant?
Y
N
N
Y
N
N
N
N
Y
N
N
N
Y
N
N
N
Y
N
N
N
Y
Y
N
N
N
Raw Wastewater
Concentration
(mg/L)
0.10
0.10
0.10
0.50
0.10
0.10
0.20
0.16
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
Amount Volatilized
{Mg/year}
0.02
0.02
0.02
0.10
0.02
. 0.02
0.04
0.03
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
14-7
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Chapter 14 - Non-Water Quality Environmental Impacts
Table 14-2 (Continued)
Organic Air Pollutant
n-Eicosane
n-Hexacosane
H-Hexadecane
n-Nitrosomorpholine
w-Octadecane
n-Tetracosane
n-Tetradecane
p-Cymene
Pentachlorophenol
Pentamethylbenzene
Phenol
Phenol, 2-Methyl-4, 6-Dinitro
Serene
Hazardous Air
Pollutant?
N
N
N
Y
N
N
N
N
Y
N
Y
N
Y
Raw Wasfewater
Concentration
(mg/L)
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
Total for HAPs:
Amount Volatilized
{Mg/year)
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
13.86
14-8
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Chapter 14 - Non-Water Quality Environmental Impacts
14.2.3
Solid Waste Impacts
To determine the impact of the proposed regulation on solid waste generation,
EPA used information provided in the industrial laundries detailed questionnaire responses to
estimate the incremental sludge generation from the CP-IL and DAF-IL options. Both of
these options involve treatment of industrial laundry wastewater followed by dewatering of the
sludge generated during treatment. The dewatered sludge is then disposed. Most industrial
laundries responding to the detailed questionnaire reported disposing of their sludge at
nonhazardous industrial landfills. To estimate the incremental sludge generation from CP-IL
and DAF-IL, EPA subtracted the volume of sludge currently generated by industrial laundries
from the estimated volume of sludge that would be generated after implementation of either
option.
The volume of sludge currently generated by industrial laundries (in dry solids,
pounds per year) was calculated using the industrial laundries cost model for all industrial
laundries included in the proposed regulation that currently operate a wastewater treatment
system. EPA did not include sludge generation reported from facilities with minimal
treatment (i.e., settling pits and screens) in the baseline sludge generation amount. Therefore,
the baseline sludge generation is the minimum volume of sludge currently generated and any
calculated incremental increases in sludge generation from the CP-IL or DAF-IL options are
larger than would actually be observed from implementation of these options.
EPA used the industrial laundries cost model to calculate the volume of sludge
that would be generated by the 172 in-scope industrial laundries included in the proposed
regulation after implementation of the CP-IL and DAF-IL options. By subtracting the
baseline sludge generation volume from the volume of sludge generated after implementation
of CP-IL and DAF-IL, EPA determined an incremental sludge generation increase for each of
the 172 in-scope industrial laundries included in the proposed regulation. EPA then
extrapolated the sludge volumes to account for the 1,606 industrial laundries that would be
covered by the proposed rule. Table 14-3 presents the incremental increase in sludge
generation (in wet sludge and dry solids) from all existing in-scope industrial laundries
identified by EPA for CP-IL and for DAF-IL. Table 14-3 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(2)). Based on this analysis, EPA has
determined that the solid waste impacts of the regulatory options consider for proposal are
acceptable.
14-9
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3
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00
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.
o
o
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14-10
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14.3
Chapter 14 - Non-Water Quality Environmental Impacts
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 regulatory options considered for PSNS for the Industrial Laundries
Point Source Category. Over a three-year period (1991, 1992, and 1993), according to the
1994 Industrial Laundries Industry Detailed Questionnaire, laundry operations began at only
about 80 facilities (and it is not absolutely clear from the data whether these facilities were
actually 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.
EPA also believes that new sources will incorporate more pollution prevention practices and
will recycle more of the wastewater generated at their facilities. Therefore, EPA has
determined that the non-water quality environmental impacts associated with the
implementation of the regulatory options considered for PSNS will be negligible.
14.4
1.
2.
References
Steam. Its Generation and Uses. 4th Edition, Babcock & Wilcox, Ed Stutz &
Kitto, Barberton, Ohio. 1992.
U.S. Environmental Protection Agency. Subtitle D Study Phase I.
Washington, DC, 1986, EPA 530-SW-86-054.
14-11
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Chapter 15 - PSES and PSNS
CHAPTER IS
15.1
PRETREATMENT STANDARDS FOR EXISTING SOURCES (PSES) AND
PRETREATMENT STANDARDS FOR NEW SOURCES (PSNS)
Introduction
Pretreatment standards for existing sources establish quantitative limits on the
indirect discharge of priority and nonconventional pollutants to waters of the United States.
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 Clean Water Act (CWA) requires pretreatment for pollutants that pass through POTWs in
amounts that would exceed direct discharge effluent limitations or limit POTW sludge
management alternatives, including the beneficial use of sludges on agricultural lands. EPA
also determines that there is pass-through of a pollutant if the pollutant exhibits significant
volatilization prior to treatment by POTWs. Pretreatment standards are to be technology-
based. The technology selected by the Agency to define the PSES performance for the
removal of priority and nonconventional pollutants may include end-of-pipe treatment, process
changes, and internal controls.
Pretreatment standards for new sources also establish quantitative limits on the
indirect discharge of priority and nonconventional pollutants to waters of the United States.
New indirect discharging facilities have the opportunity to incorporate the best available
demonstrated technologies, including process changes, in-plant control measures, and end-of-
pipe wastewater treatment technologies that reduce pollution to the maximum extent feasible.
The owners or operators of facilities subject to PSES or PSNS are not required
to use the specific wastewater treatment technologies selected by the Agency to establish the
limitations and standards. Rather, a facility can use any combination of process changes,
water use changes, and wastewater treatment to comply with permit limitations and standards,
provided that the limitations and standards are not achieved through prohibited dilution.
EPA has selected the CP-IL Option, a regulatory option based on chemical
precipitation, as the technology basis for the proposed PSES. The CP-IL Option is based on
chemical precipitation treatment of all industrial laundry wastewater for control of wastewater
discharges to POTWs from industrial laundry facilities. The proposed standards would be
applicable to all wastewater discharged from facilities covered under PSES. EPA finds this
option to be the best available treatment performance technology economically achievable
based on data collected during the development of the proposed rule. EPA has also selected
the CP-IL Option as the proposed technology basis for the proposed PSNS. The rationale
behind these selections is discussed in the preamble to the proposed rule and in Chapter 13 of
this document.
15-1
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Chapter 15 - PSES and PSNS
The following information is presented in this section:
15.2
15.2.1
• Section 15.2 reviews the industrial laundries regulated by PSES and
PSNS, provides a brief description of EPA's POTW pass-through
analysis, discusses pollutants proposed to be regulated by PSES and
PSNS, and presents the proposed PSES and PSNS; and
• Section 15.3 discusses PSES and. PSNS implementation with regard to
point of application, permit limitations, and monitoring and compliance
issues.
Summary of the Proposed PSES and PSNS
Regulated Facilities
PSES and PSNS are proposed for the industrial laundries covered by this rale.
As discussed in Section 6.3 of this document, the regulated facilities include facilities that
meet the definition of an industrial laundry.
Under PSES, EPA is proposing to exclude existing facilities laundering less
than one million pounds of incoming laundry per calendar year and less than 255,000 pounds
of shop towels and/or printer towels/rags per calendar year. EPA made this exclusion in order
to eliminate unacceptable disproportionate adverse economic impacts on these smaller
facilities. If any excluded facility launders one million pounds or more of laundry or more
than 255,000 pounds of shop towels and/or printer towels/rags during any calendar year, the
facility would no longer be excluded from PSES. See Chapter 6 for a detailed discussion of
the scope of the proposed rule.
Under PSNS, EPA proposes that no facilities would be excluded, since the
economic projections indicate that there would be no barrier to entry as a result of the new
source standards.
15.2.2
POTW Pass-Through Analysis
Based on currently available data and information, EPA evaluated POTW pass-
through for those pollutants proposed for regulation (listed in Section 7.4 of this document).
In determining whether a pollutant is expected to pass through a POTW, EPA assessed the
following:
• Whether the pollutant would be volatilized from conveyance systems,
equalization or other treatment units, or POTW head works that are
open to the atmosphere;
15-2
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Chapter 15 - PSES and PSNS
• Whether the nation-wide average percentage of a pollutant removed by
well-operated POTWs achieving secondary treatment is less than the
percentage removed by the proposed PSES treatment options; or
• Whether there are any specific instances of POTW interference, upset,
or pass-through known to EPA as being caused by the pollutants
proposed for regulation.
The uncontrolled transfer of a pollutant from water to air through volatilization
does not constitute treatment. Therefore, EPA has determined that for the pollutants proposed
for regulation that undergo significant volatilization from conveyance systems, equalization or
other treatment units, or POTW head works that are open to the atmosphere, will pass through
POTWs and should be regulated by pretreatment standards.
EPA usually determines whether a particular pollutant is passing through a
POTW by comparing the average POTW removal with average removal obtained by direct
dischargers. Direct dischargers have not been identified to date for the industrial laundries
industry. Therefore, EPA determined pass-through for the industrial laundries industry by
comparing the average treatment provided by POTWs nationwide (expressed as a percentage
removal) to the average treatment provided by the proposed PSES options. Chapter 7
provides a detailed description of the pass-through analysis.
15.2.3
Regulated Pollutants
The pollutants proposed to be regulated by EPA include seven organics, three
metals, and one nonconventional bulk parameter, total petroleum hydrocarbons (TPH,
measured as silica gel treated-hexane extractable material (SGT-HEM)). Table 15-1 presents
the proposed list of regulated pollutants. EPA believes that regulating these 11 pollutants will
control the discharge of all pollutants of concern in industrial laundry wastewater. A detailed
description of the pollutants proposed for regulation is in Chapter 7.
15.2.4
PSES and PSNS
Table 15-2 presents the proposed PSES and PSNS for the industrial laundries
industry. The proposed PSES and PSNS for the industry are based on a combination of long-
term average treatment performance concentrations and variability factors that account for
day-to-day variation in measured treated effluent concentrations. Long-term average treatment
performance concentrations, discussed in Chapter 9, are target values that a facility should
achieve on a long-term average basis. The variability factors, also discussed in Chapter 9,
represent the ratio of an elevated value that would be expected to occur only rarely to tjie
long-term average. The purpose of the variability factor is to allow for variations in effluent
concentrations that comprise the long-term average. A facility that designs and operates its
treatment system to achieve a long-term average on a consistent basis should be able to
comply with the daily and monthly limitations in the course of normal operations.
15-3
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Chapter 15 - PSES and PSNS
Table 15-1
Pollutants Proposed to be Regulated Under PSES and PSNS
Metals
Copper
Lead
Zinc
, Organics
Bis(2-ethylhexyl) Phthalate
Ethylbenzene
Naphthalene
Tetrachloroethene
Toluene
ffz-Xylene
0-&p-Xylene
Nonconventional Pollutants
Total Petroleum Hydrocarbons
(measured as SGT-HEM)
SOT-HEM - Silica gel treated-hexane extractable material
15-4
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Chapter IS - PSES and PSNS
Table 15-2
Proposed PSES and PSNS for the Industrial Laundries Industry
Pollutant or Pollutant Property
Copper
Lead
Zinc
Bis(2-ethylhexyl) Phthalate
Ethylbenzene
Naphthalene
Tetrachloroethene
Toluene
ij
m-Xylene
o-&p-Xylene2
TPH (as SGT-HEM)3
proposed PSES and fSNS for Iwd-of-PIpe Rtwiftoridg Points
Maximum for aay 1 day
(mg/L)
0.24
0.27
0.61
0.13
1.64
0.23
1.71
2.76
1.33
0.95
27.5
Monthly Average
(mgflL)
...1
...1
.„!
...'
___!
—1
...1
__1
___!
___!
15.4
*EPA is not proposing monthly average limitations for these pollutants.
2EPA is proposing the use of EPA Methods 1624 and 624 for the analysis of xylenes, even though xylenes are not specifically listed as an
analyte in either of these methods (promulgated at 40 CFR Part 136). EPA used data obtained from the analysis of xylenes by these two
methods in the development of the proposed industrial laundry standards.
3TPH (as SGT-HEM) is total petroleum hydrocarbons measured by the silica gel treated-hexane extractable material analytical method
proposed January 23, 1996 (Method 1664).
15-5
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Chapter 15 - PSES and PSNS
15.3 Implementation of the PSES and PSNS
15.3.1 Point of Application
PSES and PSNS for wastewaters from industrial laundry operations are
applicable at end-of-pipe discharge points, as denoted in Table 15-2, for all pollutants
proposed for regulation. The end-of-pipe monitoring point should be located prior to the
POTW sewer system. If the facility is treating only part of its stream, the end-of-pipe
monitoring point should be located after all process wastewater is commingled.
15.3.2
Permit Limitations
If final PSES and PSNS are promulgated as proposed, EPA expects that permit
limitations for pollutants at end-of-pipe discharge points would be concentration-based.
Proposed concentration-based limitations are listed in Table 15-2, and are the same for PSES
and PSNS. Concentration-based permit limitations offer a direct measure for both the
permitting authority and the permitted facility that PSES or PSNS performance levels are
being achieved.
To establish daily maximum limitations and monthly average limitations, a
permit writer must examine the discharge wastewater streams present at a facility. The permit
writer must define the components of the discharged wastewater stream, as discussed in
Chapter 3 of the Guidance Manual for the Use of Production-Based Pretreatment Standards
and the Combined Wastestream Formula (1).
The proposed concentration-based limitations specified in the categorical
standards apply to the discharge of wastewater from regulated processes (i.e., water washing
of all items) prior to mixing with unregulated and dilute wastewater streams. Because some
facilities may combine regulated and nonregulated streams prior to the discharge location, the
combined wastestream formula (CWF) was developed to allow permit writers to calculate
alternative pollutant limits at industrial facilities where a regulated wastestream is mixed with
other wastestreams, while protecting against inappropriate dilution (see 40 CFR 406(e)). The
formula establishes alternative concentration-based or mass-based limits based on the
proportionate contribution of each wastestream. The formula divides the universe of
wastestreams into three types:
1) Regulated - A wastestream for which a categorical treatment standard
has been promulgated;
2) Unregulated - A wastestream that may contain regulated pollutants but
for which categorical treatment standards have not been promulgated;
and
3) Dilute - A wastestream that contains few or no regulated pollutants.
15-6
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Chapter 15 - PSES and PSNS
The unregulated and the dilute wastestreams are referred to as nonregulated streams.
When a regulated wastestream is combined prior to treatment with other
wastestreams, the CWF must be used to calculate alternate discharge limits that apply to the
combined stream. When a regulated wastestream is combined with other wastestreams after
treatment, the CWF may be applied to calculate alternate discharge limits but it is not
mandatory.
Equation 15-1, the CWF, presents the methodology used to calculate alternative
concentration limits (also see 40 CFR 403.b(e)(l)):
where:
FT - F
D
15-1
CT
•D
Alternative concentration limit for the pollutant in the combined
wastestream
Concentration-based categorical pretreatment standard for the
pollutant in regulated stream i
Average daily flow (at least 30-day average) of regulated stream
i
Average daily flow (at least 30-day average) of dilute
wastestream(s)
FT = Average daily flow (at least 30-day average) of all wastestreams
(including regulated, unregulated, and dilute wastestreams).
If a nonregulated wastestream is combined with a regulated wastestream, after
treatment and monitoring occurs after the streams are combined, the flow-weighted average
formula may be used instead of the CWF. For concentration-based standards, a flow-
proportioning calculation must be performed in order to properly account for the levels of the
regulated pollutant in the nonregulated wastestream(s).
Equation 15-2 presents the flow-weighted average formula:
15-7
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Chapter 15 - PSES and PSNS
15-2
where:
C^ = Adjusted concentration limit for the pollutant in the combined
wastestream
Cj = Concentration-based categorical pretreatment standard for the
pollutant in regulated stream i
Fj = Average daily flow (at least 30-day average) of regulated stream
i
FT = Average daily flow (at least 30-day average) of all wastestreams
(including regulated, unregulated, and dilute wastestreams)
MJ = Actual Mass of pollutant in nonregulated wastestreams combined
with regulated wastestream after treatment.
Using the formula hi this manner will adjust the limitations based on the types (regulated,
unregulated, or dilute) of wastestreams and the point where they are combined. If the
nonregulated wastestream(s) have high pollutant loadings the adjusted concentration limit will
be higher than the categorical standard after implementation of this formula. However, if the
pollutant loading is lower in the nonregulated stream than in the regulated stream, the adjusted
concentration limit will be lower than the categorical standard. When dilute wastestreams are
added, the formula reduces the flow-weighted average in proportion to the flow of the dilute
wastestreams. This adjustment is made to prohibit dilution.
If the effluent guidelines for the Industrial Laundries Point Source Category is
promulgated as proposed, the combined wastestream formula would be applied in the
following manner. The regulated wastestream would consist of process wastewater generated
from the water washing of all items. An example of an unregulated wastestream for the
Industrial Laundries Point Source Category would be the wastewater stream generated from
the dry-cleaning process. A dilute wastestream is defined in 40 CFR Part 403 to include
sanitary wastewater, noncontact cooling water, and boiler blowdown.
Table 15-3 provides discharge streams and discharge flows for three example
facilities. All examples shown here represent use of the CWF, not the flow-weighted average
formula. Example calculations of alternative concentration limits for three proposed regulated
pollutants for the three facilities are presented below.
15.3.2.1 Facility One
Facility One has one regulated wastewater stream. The CWF does not need to
be applied in this instance. The limits for this facility are those presented in Table 15-2.
15-8
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Chapter 15 - PSES and PSNS
Table 15-3
Alternative Concentration-Based Limits for Example Facilities
Facility One
Wastestream1
Process Flow
Total Flow = Process
Flow
Average
Daily Flow
(gal/day)
20,000
20,000
Wastestream*
Process Flow
Noncontact Cooling
Water
Total Flow = Process
Flow + Noncontact
Cooling Water
Average
Daily flow
{gal/day}
20,000
2,000
22,000
Example
Pollutants
TPH
Copper
Naphthalene
TPH
Copper
Naphthalene
Concentration-based
Categorical
Pretreatment Standard
Ctog/L)
: 27.5
0.24
0.23
27.5
0.24
0.23
Alternative
Concentration Limit
(Derived from CWE>
aig/L)
—
Not Applicable
Not Applicable
Not Applicable
Facility Two
Example
Pollutants
TPH
Copper
Naphthalene
None
TPH
Copper
Naphthalene
Concentratiott*based
Categorical
Pretreatment Standard
(mg/L)
27.5
0.24
0.23
— -
27.5
0.24
0.23
Facility f»m
Wastestream
Process Flow from
Water Washing Shop
Towels
Dry-cleaning Flow
Total Flow = Process
Flow from Shop Towels
+ Dry-cleaning Flow
Average
Daily Flow
(gal/day)
20,000
10,000
30,000
Example
Pollutants
TPH
Copper
Naphthalene
TPH
Copper
Naphthalene
TPH
Copper
Naphthalene
Concentration-based
Categorical
Pretreatment Standard
(mgfL)
27.5
0.24
0.23
—
27.5
0.24
0.23
Alternative
Concent ration Limit
(Derived front CWF,
mg/L)
—
—
25.00
0.22
0.21
Alternative
Concentration Limit
(Derived from CWF*
mg/L)
E
—
27.5
0.24
0.23
this facility, streams are combined prior to treatment.
15-9
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Chapter 15 - PSES and PSNS
The permit writer must compare the concentration of the pollutants in the discharge stream to
the limits presented in Table 15-2; if the concentration measured in the discharge is less than
the limit, then the facility is in compliance.
15.3.2.2
Facility Two
Facility Two has two wastewater streams, a regulated stream (process flow) and
a dilution stream (noncontact cooling water). These streams are combined prior to treatment;
therefore, the CWF must be applied. As shown in Table 15-3, the following flow data were
used for the calculation.
Fj (process flow)
FD (noncontact cooling water flow)
FT (total flow)
= 20,000 gal/day
= 2,000 gal/day
= 22,000 gal/day
Equation 15-1 is then applied using the flow data as well as the concentration-
based limits from Table 15-2. An example calculation of the alternative daily maximum
concentration for copper is shown as follows:
= 0.24 mg/L * 20,000 gal/day
20,000 gal/day
22,000 gal/day - 2,000 gal/day
22,000 gal/day
CT = 0.218 mg/L
The alternative maximum daily limits for all other regulated pollutants would
be calculated in a similar manner. After calculating the alternative limits, the permit writer
would compare the measured concentrations in the discharge stream to the alternative limits.
The facility would be in compliance if the measured concentrations in the discharge stream
are lower than the alternative limits.
15.3.2.3
Facility Three
Facility Three has two wastestreams, a regulated stream (process flow from
shop towels) and an unregulated wastestream (flow from dry-cleaning processes). These
streams are combined prior to treatment; therefore, the CWF must be applied. It should be
noted that, when the CWF is applied to a facility combining an unregulated steam with a
regulated stream, the alternative concentration limit of a pollutant will be equal to that of the
concentration-based categorical pretreatment standard for that pollutant. This is due to the
fact that unregulated streams are presumed, for the purposes of the CWF, to contain pollutants
of concern at concentrations equivalent to the regulated stream. Rather than treating the
unregulated flow as dilution, which would result in lowering the allowable concentration of a
pollutant, the CWF allows the pollutant to be discharged in the unregulated wastestream at the
same concentration as the standard for the regulated wastestream that is being discharged.
15-10
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Chapter 15 - PSES and PSNS
Pollutants that are present in the unregulated wastestream are presumed to be treated to the
same level as the regulated wastestream.
As shown in Table 15-3, the following flow data were used for the calculation:
Fj (process flow)
FD (dilution flow)
FT (total flow)
= 20,000 gal/day
= 0 gal/day
= 30,000 gal/day
Equation 15-1 is then applied using the flow data as well as the concentration-
based limits from Table 15-2. An example calculation of the daily maximum concentration
for copper is shown as follows:
0.24 mg/L * 20,000 gal/day 30,000 gal/day - 0 gal/day
20,000 gal/day
30,000 gal/day
CT = 0.24
The maximum daily limits for all other regulated pollutants would be calculated
in a similar manner. After calculating the maximum daily limits, the permit writer would
compare the measured concentration in the discharge stream to the calculated maximum daily
limits. If the measured concentration in the discharge stream is lower than the calculated
maximum daily limits, then the facility is in compliance.
15.3.3
Monitoring and Compliance
The limitations are provided as daily maximums and monthly averages for TPH
(measured as SGT-HEM) and as daily maximums for all other regulated pollutants.
Monitoring was assumed to occur four times per month for TPH and one time per month for
all other regulated pollutants. Compliance with the daily maximum discharge limit is
required, regardless of the number of samples analyzed. EPA-approved analytical methods
for analyzing the regulated pollutants are shown in Table 15-4.
15.4
1.
References
U.S. Environmental Protection Agency. Guidance Manual for the Use of
Production-Based Pretreatment Standards and the Combined Wastestream
Formula. September 1985.
15-11
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Chapter 15 - PSES and PSNS
Table 15-4
EPA-Approved Analytical Methods for Analyzing the Regulated Pollutants1
Pollutant
Copper
Lead
Zinc
Bis(2-ethylhexyl) Phthalate
Ethylbenzene
Naphthalene
Tetrachloroethene
Toluene
m-Xylene
o-&p-Xylene
Total Petroleum Hydrocarbons (measured as SGT-
HEM)
EPA Analytfeal Method
200.7, 220.2, 1620Z
200.7, 239.1, 239.2, 16202
200.7, 289.1, 289.2, 1620Z
606, 625, 1625
602, 624, 1624
610, 625, 1625
601, 624, 1624
602, 624, 1624
624, 1624J
624, 1624J
1664*
'This table shows EPA methods only. Except for total petroleum hydrocarbons measured as silica gel treatcd-hexane extractable material
(SOT-HEM) and xylenes, methods for monitoring these pollutants are specified at 40 CFR Part 136. The CFR also specifies methods
published by voluntary consensus standards bodies, when available.
Although not specifically listed at 40 CFR Part 136, EPA Method 1620 is a consolidation of methods 200.7, 204.2, 206.2, 239.2, 270.2,
2192, 245.5, 245.1, and 245.2. EPA used data obtained from the analysis of metals and elements by Method 1620.
3EPA is proposing the use of EPA Methods 1624 and 624 for the analysis of xylenes. Xylenes are not specifically listed as an analyte in
cither of these methods (promulgated at 40 CFR Part 136). EPA used data obtained from the analysis of xylenes by these two methods in
the development of the proposed industrial laundries standards.
*Totil Petroleum Hydrocarbon (measured as SGT-HEM) is total petroleum hydrocarbons measured by the silica gel treated-hexane
extractable material analytical method proposed January 23, 1996 (Method 1664).
15-12
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Chapter 16 - Glossary of Terms
CHAPTER 16
GLOSSARY OF TERMS
Absorbents: Substance used to absorb leaks, spills, and sprays around machinery and
workstations. Oil, coolants, solvents, and water are common materials absorbed.
Administrator: The Administrator of the U.S. Environmental Protection Agency.
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.
BCT: 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°C. 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: Used to polish floors.
CAA: Clean Air Act. The Air Pollution Prevention and Control Act (42 U.S.C. 7401 et
sea.), as amended, inter alia, by the Clean Air Act Amendments of 1990 (Public Law 101-
549, 104 Stat. 2399).
CEB: Chemical emulsion breaking.
16-1
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Chapter 16 - Glossary of Terms
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.
COP: Chemical oxygen demand (COD) - 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.
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
(§403.3(t)(l)) has been approved in accordance with the requirements of §403.11; 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).
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.
CWA: Clean Water Act. The Federal Water Pollution Control Act Amendments of 1972 ('33
U.S.C. 1251 fit sea.).
PAff: Dissolved air flotation.
Daily discharge: The discharge of a pollutant measured during any calendar day or any 24-
hour period.
16-2
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Chapter 16 - Glossary of Terms
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.
Facility: A facility is 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: 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 26 L
16-3
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Chapter 16 - Glossary of Terms
Health care items: Items such as hospital gowns, linen, and towels used in hospitals,
doctors' offices, and dentists' offices.
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 85°C (see Method 1664). HEM has been
proposed to replace the conventional pollutant oil and grease for EPA survey and monitoring
programs under the Clean Water Act.
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 (ID: 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.
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, filters, and clean room garments.
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, fiocculation, 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 an 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.
16-4
-------
Chapter 16 - Glossary of Terms
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.
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.
NRDC: Natural Resources Defense Council.
NSPS: New source performance standards. This term refers to standards for new sources
under section 306 of the CWA.
OC: Organics control.
Off-site: "Off-site" means outside the boundaries of the facility.
On-site: "On-site" means within the boundaries of the facility.
16-5
-------
Chapter 16 - Glossary of Terms
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 75 C (see Method
413.1). The hexane extractable material (HEM) method has been proposed to replace O&G
for EPA survey and monitoring programs under the Clean Water Act.
1*2: Pollution prevention.
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: Parriculate 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 seq.. Pub.L. 101-508,
November 5, 1990).
Pretreatment standard: A regulation specifying industrial wastewater effluent quality
required for discharge to a POTW.
Printer towel/rag: 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.
16-6
-------
Chapter 16 - Glossary of Terms
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.
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.X
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.
SBA: Small Business Administration.
SBREFA: Small Business Regulatory Enforcement Fairness Act of 1996 (P.L. 104rl21,
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 anaerobipally 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
16-7
-------
Chapter 16 - Glossary of Terms
temperatures below 85 C (see Method 1664). SGT-HEM is proposed to replace the
nonconventional pollutant total petroleum hydrocarbons for EPA survey and monitoring
programs under the Clean Water Act.
Shop towel; Towels used to clean oil and grease or soils from various objects or to wipe up
oil and grease arid 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
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.
TPH: Total petroleum hydrocarbons. A method-defined parameter that measures the
presence of mineral oils mat are extractable in Freon 113 (1,1,2-trichloro-1,2,2-
trifluoroethane) and not absorbed by silica gel. This parameter does not include materials that
volatilize at temperatures below 70°C (see Method 418.1). Silica gel treated-hexane
extractable material (SGT-HEM) has been proposed to replace TPH for EPA survey and
monitoring programs under the Clean Water Act.
TRSA: Textile Rental Services Association of America.
TSCA: Toxic Substances Control Act (15 U.S.C. 2601 et sea.)
TSS: Total suspended solids.
UTSA: Uniform and Textile Service Association.
16-8
-------
Chapter 16 - Glossary of Terms
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.
16-9
-------
-------
Appendix A - Tables Referenced in Chapter 3
Appendix A
Tables Referenced in Chapter 3
-------
-------
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 te Rigorous QA/QC
Procedures Per Method ItfZtJ:
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
-------
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 {EM M*tiM*d i634j
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
Tctrachloromethane
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
-------
Appendix A - Tables Referenced in Chapter 3
Table A-2 (Continued)
Seroivolafile Organic Constituents {EPA Method 1625)
Acenaphthene
Acenaphthylene
Acetophenone
Alpha-terpineol
Aniline
Aniline, 2,4,5-trimethyl-
Antbracene
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( 1,2,3-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-nitrosomorpholine
N-nitrosopiperidine
N-octacosane
N-octadecane
N-tetracosane
N-tetradecane
N-triacontane
N,n-dimethylformamide
Naphthalene
Nitrobenzene
O-anisidine
O-cresol
O-toluidine
O-toluidine, 5-chloro-
P-chloroaniline
P-cresol
P-cymene
P-dimethylaminoazobenzene
P-nitroaniline
A-3
-------
Appendix A - Tables Referenced in Chapter 3
Table A-2 (Continued)
Semivolatile Organic Constituents (EPA Method 1625) (Continued)
Pentachlorobenzene
Pentachlorophenol
Pentamethylbenzene
Perylene
Phenacetin
Phenanthrene
Phenol
Phenol, 2-methyl-4,6-dinitro-
Phenothiazine
Pronamide
Pyrene
Pyridine
Resorcinol
Safrole
Squalenc
Styrene
Thianaphthene
Thioacetamide
Thioxanthe-9-one
Toluene, 2,4-diamino-
Triphenylene
Tripropyleneglycol Methyl Ether
l-bromo-2-chlorobenzene
l-bromo-3-chlorobenzene
l-chloro-3-nitrobenzene
1-methylfluorene
1-methylphenanthrene
1-naphthylamine
1 -phenylnaphthalene
l,2-dibromo-3-ehloropropane
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-diepoxybutane
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-phenyhiaphthalene
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-nitroaniline
3,3 '-dichlorobenzidine
3,3 '-dimethoxybenzidine
3,6-dimethylphenanthrene
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-dimethylbenz(a)anthracene
A-4
-------
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)
Surfactants
Total Solids
Total Hydrolyzable Phosphorus
Total Organic Carbon
Total Orthophosphate
Total Suspended Solids (TSS)
EPA Method
405. I1
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 Gravimetrv (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
-------
-------
Appendix B - Tables Referenced in Chapter 5
Appendix B
Tables Referenced in Chapter 5
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-------
Appendix C - Tables Referenced in Chapter 6
Appendix C
Tables Referenced In Chapter 6
-------
-------
Appendix C - Tables Referenced in Chapter 6
Table C-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
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
-------
Appendix C - Tables Referenced in Chapter 6
Table C-l (Continued)
CWA Part
433
434
435
436
439
440
443
446
447
454
455
457
458
459
460
461
463
464
465
466
467
468
469
471
Industry
Metal Finishing
Coal Mining
Oil and Gas Extraction
Mineral and Mining Processing
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
-------
Appendix D - Tables Referenced in Chapter 7
Appendix D
Tables Referenced in Chapter 7
-------
-------
Appendix D - Tables Referenced in Chapter 7
Table D-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-TrichIorobenzene
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-DimethylphenoI
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-ChloroisopropyI) 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
Source: 40 CFR Part 423, Appendix A
Priority pollutants are numbered 1 through 129 but include 126 pollutants since EPA removed three pollutants from the list (Numbers 17,
49, and 50).
D-l
-------
Appendix D - Tables Referenced in Chapter 7
Table D-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
1 .2-DIBROMO-3-CHLOROPROPANE
1,2-DIBROMOETHANE
1 ,2-DICHLOROBENZENE
1 ,2-DICHLOROETHANE
1 ,2-DICHLOROPROPANE
1 ,2-DIPHENYLHYDRAZINE
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
l-BROMO-2-CHLOROBENZENE
l-BROMO-3-CHLOROBENZENE
l-CHLORO-3-NITROBENZENE
1-METHYLFLUORENE
1-METHYLPHENANTHRENE
1-NAPHTHYLAMINE
1-PHENYLNAPHTHALENE
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
1625
1625
1625
D-2
-------
Appendix D - Tables Referenced in Chapter 7
Table D-2 (Continued)
KHJUITANT
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-CHLOROETHYLVINYL 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
2-PROPENENITRILE, 2-METHYL-
3,3 '-DICHLOROBENZIDINE
3,3'-DIMETHOXYBENZIDINE
3,6-DIMETHYLPHENANTHRENE
3-CHLOROPROPENE
ANALYTICAL METHOD
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
1624
1625
1625
1625
1624
D-3
-------
Appendix D - Tables Referenced in Chapter 7
Table D-2 (Continued)
JPOLtUTANT
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
7,12-DIMETHYLBENZ(A)ANTHRACENE
ACENAPHTHENE
ACENAPHTHYLENE
ACETOPHENONE
ACRYLONTTRILE
ALPHA-TERPINEOL
ALUMINUM
ANILINE
ANILINE, 2,4,5-TRIMETHYL-
ANTHRACENE
ANTIMONY
ARAMITE
ARSENIC
BARIUM
BENZANTHRONE
BENZENE
BENZENETfflOL
BENZIDINE
BENZO(A)ANTHRACENE
BENZO(A)PYRENE
BENZO(B)FLUORANTHENE
BENZO(GHI)PERYLENE
BENZO(K)FLUORANTHENE
BENZOIC ACID
ANALYTICAL METHOB
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
1625
1625
1625
1625
1625
1625
1625
D-4
-------
Appendix D - Tables Referenced in Chapter 7
Table D-2 (Continued)
POLLUTANT
BENZONITRILE, 3,5-DIBROMO-4-HYDROXY-
BENZYL ALCOHOL
BERYLLIUM
BETA-NAPHTHYLAMINE
BffHENYL
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
CHROMIUM
CHRYSENE
CIS-1.3-DICHLOROPROPENE
COBALT
COPPER
CROTONALDEHYDE
CROTOXYPHOS
DI-N-BUTYL PHTHALATE
DI-N-OCTYL PHTHALATE
ANALYTICAL JMETH03>
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
1620
1625
1624
1620
1620
1624
1625
1625
1625
D-5
-------
Appendix D - Tables Referenced in Chapter 7
Table D-2 (Continued)
POLLUTANT
DI-N-PROPYLNITROSAMINE
DroENZO(A,H)ANTHRACENE
DffiENZOFURAN
DIBENZOTHIOPHENE
DffiROMOCHLOROMETHANE
DroROMOMETHANE
DffiTHYL ETHER
DIETHYL PHTHALATE
DIMETHYL PHTHALATE
DIMETHYL SULFONE
DIPHENYL ETHER
DIPHENYLAMINE
DIPHENYLDISULFIDE
DYSPROSIUM
ERBIUM
ETHANE, PENTACHLORO-
ETHYL CYANIDE
ETHYL METHACRYLATE
ETHYL METHANESULFONATE
ETHYLBENZENE
ETHYLENETfflOUREA
EUROPIUM
FLUORANTHENE
FLUORENE
GADOLINIUM
GALLIUM
GERMANIUM
GOLD
HAFNIUM
HEXACHLOROBENZENE
HEXACHLOROBUTADffiNE
HEXACHLOROCYCLOPENTADIENE
HEXACHLOROETHANE
HEXACHLOROPROPENE
HEXANOIC ACID
HOLMIUM
ANALYTICAL METHO0
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
1620
1620
1620
1620
1625
1625
1625
1625
1625
1625
1620
D-6
-------
Appendix D - Tables Referenced in Chapter 1
Table D-2 (Continued)
POLLUTANT
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
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
ANALYTICAL METHOD
1625
1620
1620
1624
1620
1620
1624
1625
1625
1620
1620
1620
1625
1620
1624
1620
1625
1620
1620
1625
1625
1624
1625
1624
1620
1625
1625
1625
1625
1625
1625
• 1625
1625
1625
1625
1625
D-7
-------
Appendix D - Tables Referenced in Chapter 7
Table D-2 (Continued)
pomrFA«T
N-NITROSOMETHYLETHYLAMINE
N-NiraOSOMETHYLPHENYLAMINE
N-NITROSOMORPHOLINE
N-NTTROSOPIPERIDINE
N-OCTACOSANE
N-OCTADECANE
N-TETRACOSANE
N-TETRADECANE
N-TRIACONTANE
NAPHTHALENE
NEODYMIUM
NICKEL
NIOBIUM
NITROBENZENE
O+PXYLENE
O-ANISIDINE
O-CRESOL
O-TOLUIDINE
O-TOLUIDINE, 5-CHLORO-
OIL AND GREASE (measured as HEM)
OSMIUM
P-CHLOROANILINE
P-CRESOL
P-CYMENE
P-DIMETHYLAMINOAZOBENZENE
P-NTTROANILINE
PALLADIUM
PENTACHLOROBENZENE
PENTACHLOROPHENOL
PENTAMETHYLBENZENE
PERYLENE
PH
PHENACETIN
PHENANTHRENE
PHENOL
PHENOL, 2-METHYL-4,6-DINITRO-
ANAmtCAt MEfHOI>
1625
1625
1625
1625
1625
1625
1625
1625
1625
1625
1620
1620
1620
1625
1624
1625
1625
1625
1625
1664
1620
1625
1625
1625
1625
1625
1620
1625
1625
1625
1625
• 150.1
1625
1625
1625
1625
D-8
-------
Appendix D - Tables Referenced in Chapter 7
Table D-2 (Continued)
KJLL0TANT
PHENOTHIAZINE
PHOSPHORUS
PLATINUM
POTASSIUM
PRASEODYMIUM
PRONAMEDE
PYRENE
PYRIDINE
RESORCINOL
RHENIUM
RHODIUM
RUTHENIUM
SAFROLE
SAMARIUM
SCANDIUM
SELENIUM
SILICON
SILVER
SODIUM
SQUALENE
STRONTIUM
STYRENE
SULFUR
SURFACTANTS (CTAS)
SURFACTANTS (MBAS)
TANTALUM
TELLURIUM
TERBIUM
TETRACHLOROETHENE
TETRACHLOROMETHANE
THALLIUM
THIANAPHTHENE
THIOACETAMIDE
THIOXANTHE-9-ONE
THORIUM
THULIUM
ANALYTICAL METHOD
1625
1620
1620
1620
1620
1625
1625
1625
1625
1620
1620
1620
1625
1620
1620
1620
1620
1620
1620
1625
1620
1625
1620
5540D
5540C
' 1620
1620
1620
1624
1624
1620
1625
1625
1625
1620
1620
D-9
-------
Appendix D - Tables Referenced in Chapter 7
Table D-2 (Continued)
POLLUTANT
TIN
TITANIUM
TOLUENE
TOLUENE, 2,4-DIAMINO-
TOTAL HYDROLYZABLE PHOSPHORUS
TOTAL ORGANIC CARBON (TOG)
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-l,4-DICHLORO-2-BUTENE
TRIBROMOMETHANE
TRICHLOROETHENE
TRICHLOROFLUOROMETHANE
TRIPHENYLENE
TRIPROPYLENEGLYCOL METHYL ETHER
TUNGSTEN
URANIUM
VANADIUM
VINYL ACETATE
VINYL CHLORIDE
YTTERBIUM
YTTRIUM
ZINC
ZIRCONIUM
ANALYTICAL METHOD
1620
1620 ,
1624
1625
365.2
415.1
365.2
1664
365.2
160.3
160.2
1624
1624
1624
1624
1624
1624
1625
' 1625
1620
1620
1620
1624
1624
1620
1620
1620
1620
D-10
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