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PRELIMINARY DATA SUMMARY
FOR THE
INDUSTRIAL LAUNDRIES
INDUSTRY
Office of Water Regulations and Standards
Office of Water
United States Environmental Protection Agency
Washington, D.C.
September 1989
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PREFACE
This is one of a series of Preliminary Data Summaries
prepared by the Office of Water Regulations and Standards of the
U.S. Environmental Protection Agency. The Summaries contain
engineering, economic and environmental data that pertain to
whether the industrial facilities in various industries discharge
pollutants in their wastewaters and whether the EPA should pursue
regulations to control such discharges. The summaries were
prepared in order to allow EPA to respond to the mandate of
section 304(m) of the Clean Water Act, which requires the Agency
to develop plans to regulate industrial categories that
contribute to pollution of the Nation's surface waters.
The Summaries vary in terms of the amount and nature of the
data presented. This variation reflects several factors,
including the overall size of the category (number of
dischargers), the amount of sampling and analytical work
performed by EPA in developing the Summary, the amount of
relevant secondary data that exists for the various categories,
whether the industry had been the subject of previous studies (by
EPA or other parties), and whether or not the Agency was already
committed to a regulation for the industry. With respect to the
last factor, the pattern is for categories that are already the
subject of regulatory activity (e.g., Pesticides, Pulp and Paper)
to have relatively short Summaries. This is because the
Summaries are intended primarily to assist EPA management in
designating industry categories for rulemaking. Summaries for
categories already subject to rulemaking were developed for
comparison purposes and contain only the minimal amount of data
needed to provide some perspective on the relative magnitude of
the pollution problems created across the categories.
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ACKNOWLEDGEMENTS
Preparation of this Preliminary Data Summary was directed by Mr.
Rex Gile, Project Officer, of the Industrial Technology Division,
Preparation of the economic analysis sections was directed by Mr.
Rob Esworthy of the Analysis and Evaluation Division. Ms.
Allison Greene of the Assessment and Watershed Protection
Division was responsible for preparation of the environmental
assessment analysis. Support was provided under EPA Contract
Nos. 68-03-6302, 68-03-3545 and 68-03-3339.
Additional copies of this document may be obtained by writing to
the following address:
Industrial Technology Division (WH-552)
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Telephone (202) 382-7131
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TABLE OF CONTENTS
SECTION TITLE PAGE NO.
SUMMARY i
1.0 INTRODUCTION 1
1.1 Purpose and Authority. 1
1.2 Regulatory Background 3
TECHNICAL SUPPORT
2.0 INTRODUCTION TO TECHNICAL SUPPORT STUDY 5
2.1 Introduction 5
2.2 Study Methodologies 5
3.0 DESCRIPTION OF THE INDUSTRY 8
3.1 Industry Profile 8
3.2 Industry Processes 10
4.0 SUBCATEGORIZATION 15
4.1 Laundering Shop Towels 15
4.2 Dry Cleaning 16
5.0 WATER USE AND WASTE CHARACTERIZATION 19
5.1 Water Use Characterization 19
5.2 Wastewater Characteristics . . .20
5.2.1 Pollutants Searched For 20
5.2.2 Pollutant Sources 24
5.2.3 Wastewater Analytical Data 24
5.3 Wastewater Sampling and Analysis 27
5.4 Waste Solids Sampling and Analysis 31
5.5 Sampling and Analytical Results 31
5.6 Analytical Data from Other Sources 31
6.0 POLLUTANT PARAMETERS. 55
6.1 Conventional Pollutants . .55
6.2 Priority Pollutants 55
6.2.1 ITD/RCRA Sampling and Analysis
Program - Wastewater Samples .... .57
6.2.2 ITD/RCRA Sampling and Analysis Program -
Solids and Sludge Samples. 59
6.3 Nonconventional Pollutants 66
6.3.1 ITD/RCRA Sampling and Analysis Program -
Wastewater Samples 66
6.3.2 ITD/RCRA Sampling and Analysis Program -
Solids and Sludge Samples 68
6.4 Industry Mass Loadings . .73
6.4.1 Annual Raw Waste Mass Loading - ITD/RCRA
Program 74
6.4.2 Annual Raw Waste Mass Loadings - 1978
Screening Program 75
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TABLE OF CONTENTS (continued)
SECTION TITLE PAGE NO.
6.4.3 Comparison of Annual Average Raw Waste
Mass Loadings 86
6.4.4 Annual Final Effluent Pollutant Mass
Loadings 86
7.0 CONTROL AND TREATMENT TECHNOLOGY 90
7.1 Conventional Technology 91
7.1.1 Solids Removal 91
7.1.2 Free Oil Removal 91
7.1.3 Temperature Control 92
7.1.4 Capabilities of Conventional Technology.92
7.2 Incompatible Pollutant Removal - Presently Applied
Technologies 92
7.2.1 Dissolved Air Flotation (DAF) Treatment
Technology 92
7.2.2 Membrane Filtration 104
7.2.3 Ultrafiltration Treatment Technology . 108
ECONOMIC IMPACT ANALYSIS
8.0 INTRODUCTION TO THE ECONOMIC IMPACT STUDY 117
8.1 Introduction 117
8.2 Nature of Laundry Services and Processes . . . 117
8.2.1 Services Provided 118
8.2.2 Processes Employed 119
9.0 INDUSTRY CHARACTERISTICS AND TRENDS 124
9.1 Number of Firms and Establishments 124
9.1.1 Trends 124
9.2 Industry Revenues 132
9.2.1 Trends 132
9.3 Revenues by Market Segment 138
9.3.1 Trends 138
9.4 Employment and Wages 138
9.4.1 Trends 140
9.5 Revenues Per Employee 140
9.5.1 Trends 140
10.0 ECONOMIC INFLUENCES ON THE INDUSTRIAL LAUNDRY INDUSTRY145
10.1 Competition 145
10.2 Availability of Substitute Goods and Services. 145
10.3 Environmental Regulation 146
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TABLE OF CONTENTS (continued)
SECTION TITLE PAGE NO.
11.0 FINANCIAL CHARACTERISTICS OF INDUSTRIAL LAUNDRIES AND
ECONOMIC IMPACTS OF PRETREATMENT SYSTEM INSTALLATION
AND OPERATION 147
11.1 Financial Characteristics of the Industrial
Laundries Industry 147
11.1.1 Quick Ratio, Current Ratio 150
11.1.2 Current Liabilities to Net Worth, Total
Liabilities to Net Worth 150
11.1.3 Return on Sales 150
11.1.4 Return on Assets 150
11.2 Economic Impact of Installation of Ultrafiltration
Pretreatment System 151
11.2.1 Selection of Model Plants and
Profit Categories 151
11.2.2 Capital and Operating Costs of
Ultrafiltration Pretreatment Systems . 153
11.2.3 Economic Impacts of Ultrafiltration
Pretreatment Systems 162
11.3 Summary of Economic Impacts 163
ENVIRONMENTAL IMPACT ANALYSIS
12.0 ENVIRONMENTAL IMPACT ANALYSIS 167
12.1 Summary of Environmental Impact Study .... 167
12.2 Methodology 168
12.3 Environmental Analysis Results and Conclusions.171
12.3.1 Impacts on Human Health 171
12.3.2 Impacts on Aquatic Life 171
12.3.3 POTW Impacts 174
12.3.4 Receiving Stream Profiles 174
12.3.5 Pollutant Fate 174
13.0 REFERENCES 177
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TABLE OF CONTENTS (continued)
SECTION TITLE PAGE NO.
APPENDICES - Appendices have not been attached to this document.
However, copies of them may be obtained from the
contact person for this document who is identified
in the acknowledgments section.
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LIST OF TABLES
NUMBER TITLE PAGE NO.
SUMMARY
SUMMARY OF THE ESTIMATED ANNUAL RAW WASTE MASS LOADINGS OF
THE INDUSTRIAL LAUNDRY INDUSTRY ii
SECTION 3
3-1 TYPICAL FORMULA FOR HEAVY SOIL (WORK UNIFORMS) . . .11
SECTION 4
4-1 RAW WASTEWATER POLLUTANT LOADING: COMPARISON BETWEEN
LAUNDERING SHOP TOWELS AND LAUNDERING UNIFORMS . . .17
SECTION 5
5-1 LIST OF PRIORITY POLLUTANTS ANALYZED IN THE WASTEWATER OF
LAUNDRIES A, B, C, AND D 22
5-2 LIST OF NON-PRIORITY POLLUTANTS ANALYZED 23
5-3 CONVENTIONAL AND NONCONVENTIONAL POLLUTANT CONCENTRATIONS IN
INDUSTRIAL LAUNDRY WASTEWATERS 28
5-4 PRIORITY POLLUTANT CONCENTRATIONS IN INDUSTRIAL LAUNDRY
RAW WASTEWATERS 29
5-5 CONVENTIONAL AND NONCONVENTIONAL POLLUTANT CONCENTRATIONS IN
DOMESTIC SEWAGE 30
5-6 SUMMARY OF REPORTED ANALYTICAL RESULTS-LAUNDRY A . .33
5-7 SUMMARY OF REPORTED ANALYTICAL RESULTS-LAUNDRY B . .35
5-8 SUMMARY OF REPORTED ANALYTICAL RESULTS-LAUNDRY C . .38
5-9 SUMMARY OF REPORTED ANALYTICAL RESULTS-WATER AND WASTEWATER
SAMPLES-LAUNDRY D 40
5-10 SUMMARY OF REPORTED ANALYTICAL RESULTS-SOLIDS AND OILS
SAMPLES-LAUNDRY D 44
5-11 SUMMARY OF AVERAGE RAW WASTE CONCENTRATIONS FOR COMBINED
UNIFORM WASHERS AND TOWEL WASHERS WASTEWATER STREAMS AT
LAUNDRY D 48
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LIST OF TABLES (continued)
NUMBER TITLE PAGE NO.
5-12 ITD/RCRA SAMPLING PROGRAM SUMMARY OF REPORTED ANALYTICAL
RESULTS-PLANT E 50
5-13 SUMMARY OF POLLUTANT CONCENTRATIONS IN INDUSTRIAL
LAUNDRY WASTEWATERS OBTAINED FROM THE MASSACHUSETTS WATER
RESOURCE AUTHORITY 51
5-14 SUMMARY OF REPORTED ANALYTICAL RESULTS FROM THREE LAUNDRIES
DISCHARGING TO A NEW YORK STATE POTW 52
5-15 SUMMARY OF POLLUTANT CONCENTRATIONS FOUND IN INDUSTRIAL AND
COMMERCIAL LAUNDRY WASTEWATERS OBTAINED FROM STATE AND LOCAL
SOURCES .53
SECTION 6
6-1 SUMMARY OF CONVENTIONAL POLLUTANT CONCENTRATIONS IN
INDUSTRIAL LAUNDRY WASTEWATERS - ITD/RCRA SAMPLING
PROGRAM 56
6-2 SUMMARY OF PRIORITY POLLUTANT DATA FROM INDUSTRIAL LAUNDRIES
RAW WASTEWATER - ITD/RCRA SAMPLING PROGRAM 58
6-3 SUMMARY OF PRIORITY POLLUTANTS FOUND IN SLUDGE SAMPLES -
ITD/RCRA SAMPLING PROGRAM 61
6-4 SUMMARY OF NONCONVENTIONAL POLLUTANT DATA FROM INDUSTRIAL
LAUNDRIES WASTEWATER - ITD/RCRA SAMPLING PROGRAM . .67
6-5 SUMMARY OF NONCONVENTIONAL POLLUTANTS, AND SOLID WASTE
CHARACTERISTICS FOUND IN SLUDGE SAMPLES - ITD/RCRA SAMPLING
PROGRAM 69
6-6 INDUSTRIAL LAUNDRIES INDUSTRY MASS LOADING ESTIMATE.77
6-7 ESTIMATED ANNUAL RAW WASTE LOADINGS FOR ITD-LISTED ANALYTES
FOR THE INDUSTRIAL LAUNDRIES INDUSTRY-ITD/RCRA SAMPLING
PROGRAM 82
6-8 INDUSTRIAL LAUNDRIES INDUSTRY MASS LOADING ESTIMATE.83
6-9 ESTIMATED ANNUAL RAW WASTE LOADINGS FOR PRIORITY POLLUTANTS
AND SELECTED CONVENTIONAL AND NONCONVENTIONAL POLLUTANTS -
FOR THE INDUSTRIAL LAUNDRIES INDUSTRY 1978
SCREENING PROGRAM 85
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LIST OF TABLES (continued)
NUMBER TITLE PAGE NO.
6-10 COMPARISON OF ESTIMATED INDUSTRY AVERAGE CONCENTRATIONS OF
INDIVIDUAL POLLUTANTS IN INDUSTRIAL LAUNDRIES RAW
WASTEWATERS - ITD/RCRA PROGRAM VS. 1978
SCREENING PROGRAM 87
6-11 COMPARISON OF ESTIMATED ANNUAL RAW WASTE LOADINGS FOR
PRIORITY POLLUTANTS AND SELECTED CONVENTIONAL AND
NONCONVENTIONAL POLLUTANTS FOR THE INDUSTRIAL LAUNDRIES
INDUSTRY - ITD/RCRA SAMPLING PROGRAM VS. 1978 SCREENING
PROGRAM 89
SECTION 7
7-1 SUMMARY OF REMOVAL EFFICIENCIES OF SELECTED POLLUTANTS BY
CONVENTIONAL TREATMENT AT THREE INDUSTRIAL LAUNDRIES 94
7-2 SUMMARY OF REMOVAL EFFICIENCIES OF SELECTED POLLUTANTS BY
CONVENTIONAL TREATMENT AT TWO INDUSTRIAL LAUNDRIES-ITD/RCRA
SAMPLING PROGRAM 95
7-3 SUMMARY OF REMOVAL EFFICIENCIES FOR COMMONLY MONITORED
POLLUTANTS AT SEVEN INDUSTRIAL LAUNDRIES USING DISSOLVED AIR
FLOTATION. . . 100
7-4 SUMMARY OF REMOVAL EFFICIENCIES BY DISSOLVED AIR FLOTATION
FOR SELECTED ORGANIC PRIORITY POLLUTANTS AT FOUR INDUSTRIAL
LAUNDRIES 101
7-5 SUMMARY OF REMOVAL EFFICIENCIES BY DISSOLVED AIR FLOTATION
FOR SELECTED CONVENTIONAL AND NONCONVENTIONAL POLLUTANTS AT
TWO INDUSTRIAL LAUNDRIES-ITD/RCRA SAMPLING PROGRAM .102
7-6 SUMMARY OF REMOVAL EFFICIENCIES BY DISSOLVED AIR FLOTATION
FOR SELECTED PRIORITY AND NONPRIORITY ORGANIC POLLUTANTS AT
TWO INDUSTRIAL LAUNDRIES-ITD/RCRA SAMPLING PROGRAM .103
7-7 MEMBRANE FILTRATION CHARACTERISTICS
AND OPERATING PARAMETERS 107
7-8 SUMMARY OF REMOVAL EFFICIENCIES FOR SELECTED POLLUTANTS BY
ULTRAFILTRATION APPLIED TO SHOP TOWEL
WASHER WASTEWATER 112
SECTION 8
8-1 DISTRIBUTION OF REVENUE FROM INDUSTRIAL LAUNDRY PRODUCTS
AND SERVICES, 1985 . -120
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LIST OF TABLES (continued)
NUMBER TITLE PAGE NO.
8-2 PERCENT DISTRIBUTION OF RECEIPTS FROM MAJOR
SOURCES IN 1982 121
8-3 INDUSTRIAL LAUNDRY MARKET SEGMENT REVENUE GROWTH RATES,
1978 TO 1984 122
8-4 INDUSTRIAL LAUNDRY MARKET SEGMENT REVENUES AND GROWTH,
1978 TO 1985 123
SECTION 11
11-1 CONSOLIDATED BALANCE SHEET AND INCOME STATEMENT FOR 88
INDUSTRIAL LAUNDRY FIRMS 148
11-2 SELECTED FINANCIAL RATIOS FOR 88 INDUSTRIAL LAUNDRY
FIRMS 149
11-3 DISTRIBUTION OF INDUSTRIAL LAUNDRY ESTABLISHMENTS BY
ANNUAL REVENUES, AND COMPARISON
WITH MODEL PLANT SIZES 152
11-4 STATE AND FEDERAL INCOME TAXES APPLIED TO INDUSTRIAL
LAUNDRIES OF THREE SIZE AND PROFIT CLASSES 158
11-5 ANNUAL EFFLUENT PRODUCTION AND PRETREATMENT SYSTEM
COSTS FOR THREE MODEL INDUSTRIAL LAUNDRY PLANTS. . .159
11-6 ANNUALIZED COST OF PRETREATMENT SYSTEM, EXPRESSED AS
PERCENT OF REVENUES FOR THREE INDUSTRIAL LAUNDRY MODEL
PLANTS 165
SECTION 12
12-1 SUMMARY OF WATER QUALITY CRITERIA EXCEEDANCES-ITD/RCRA
SAMPLING DATA 168
12-2 SUMMARY OF WATER QUALITY CRITERIA EXCEEDANCES-1978
SAMPLING DATA 169
12-3 PROFILE OF INDUSTRIAL LAUNDRIES INDUSTRY USED IN THE
ENVIRONMENTAL IMPACT ANALYSIS 172
12-4 ENVIRONMENTAL FATE OF POLLUTANTS OF CONCERN 174
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LIST OF FIGURES
NUMBER TJ^Tjjg PAGE
SECTION 5
5-1 SUMMARY OF TREATMENT SYSTEMS AND SAMPLING POINTS - ITD/RCRA
SAMPLING PROGRAM 32
SECTION 7
7-1 DISSOLVED AIR FLOTATION TREATMENT SYSTEM FOR LAUNDRY
WASTEWATER 93
7-2 CROSSFLOW MEMBRANE FILTER 106
7-3 ULTRAFILTER TREATMENT SYSTEM FOR LAUNDRY WASTEWATER.110
SECTION 9
9-1 NUMBER OF INDUSTRIAL LAUNDRY FIRMS BY FIRM EMPLOYMENT,
1982 . . 126
9-2 NUMBER OF INDUSTRIAL LAUNDRY FIRMS BY FIRM REVENUES,
1982 127
9-3 NUMBER OF INDUSTRIAL LAUNDRY ESTABLISHMENTS BY
ESTABLISHMENT EMPLOYMENT, 1982 128
9-4 NUMBER OF INDUSTRIAL LAUNDRY ESTABLISHMENTS BY
ESTABLISHMENT REVENUES, 1982 129
9-5 NUMBER OF INDUSTRIAL LAUNDRY ESTABLISHMENTS BY STATE,
1985 130
9-6 NUMBER OF INDUSTRIAL LAUNDRY ESTABLISHMENTS, 1967 TO
1982 131
9-7 NUMBER OF INDUSTRIAL LAUNDRY ESTABLISHMENTS BY
ESTABLISHMENT EMPLOYMENT, 1978 TO 1985 133
9-8 TOTAL INDUSTRIAL LAUNDRY RECEIPTS BY FIRM REVENUES,
1982 134
9-9 TOTAL INDUSTRIAL LAUNDRY RECEIPTS BY ESTABLISHMENT
REVENUES, 1982 135
9-10 INDUSTRIAL LAUNDRY REVENUES (CONSTANT DOLLARS),
1967 TO 1982 136
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LIST OF FIGURES (continued)
NUMBER TITLE PAGE NO.
9-11 INDUSTRIAL LAUNDRY REVENUES PER ESTABLISHMENT (CONSTANT
DOLLARS) , 1967 TO 1982 137
9-12 TOTAL INDUSTRIAL LAUNDRY EMPLOYMENT BY STATE, 1985 139
9-13 INDUSTRIAL LAUNDRY EMPLOYMENT, 1967 TO 1982 . . . .141
9-14 INDUSTRIAL LAUNDRY REVENUES PER EMPLOYEE, BY
ESTABLISHMENT SIZE (REVENUES), 1982 142
9-15 INDUSTRIAL LAUNDRY REVENUES PER EMPLOYEE, BY ESTABLISHMENT
SIZE (N OF EMPLOYEES), 1982 143
9-16 INDUSTRIAL LAUNDRY REVENUES PER EMPLOYEE (CONSTANT
DOLLARS) , 1967 TO 1982 144
SECTION 11
11-1 ANALYSIS OF PRETREATMENT SYSTEM FINANCIAL IMPACT: MODEL
PLANT A (REVENUES = $300,000/YEAR) 155
11-2 ANALYSIS OF PRETREATMENT SYSTEM FINANCIAL IMPACT: MODEL
PLANT B (REVENUES = $1,000,000/YEAR) 156
11-3 ANALYSIS OF PRETREATMENT SYSTEM FINANCIAL IMPACT: MODEL
PLANT C (REVENUES = $2,500,000/YEAR) 157
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SUMMARY
The U.S. Environmental Protection Agency has conducted a study of
the industrial laundries industry in response to a recommendation
made in the Domestic Sewage Study and because of concern for the
potential discharge of toxic and hazardous pollutants. The purpose
of the study was to prepare a document to assist the Agency in
deciding whether to develop national effluent limitations
guidelines and standards for the industry. The document comprises
three studies, undertaken independently, listed as follows:
o a technical support study
o an economic impact study
o an environmental impact study
The technical support study consisted of two parts: the collection
and analysis of industrial laundry wastewater and waste solids
samples, and the collection of sufficient information about the
industry to develop a preliminary updated industry technical
profile. The economic impact study consisted of a review and
update of the economic profile of the industrial laundries industry
and an analysis of the projected economic impact of wastewater
regulation on the industry. The environmental impact study is an
evaluation of the impacts of industrial laundry wastewater
discharges on publicly operated treatment works and their receiving
streams.
Industrial laundries (SIC 7218) are primarily engaged in supplying
laundered or, to a limited extent, dry-cleaned work uniforms,
wiping towels, safety equipment (gloves, flame-resistant clothing,
etc.), dust covers and cloths, and similar items to industrial or
commercial users. These items may belong to the industrial
launderers and be supplied to users on a rental basis, or they may
be the customer's own goods. Most industrial launderers offer
their customers a variety of textile maintenance services, but
approximately 88 percent of their receipts in 1974 were derived
from the activities defined above. The estimated 28,400 plants
that are primarily engaged in dry cleaning or dyeing apparel and
household fabrics for the general public belong to SIC 7216 and are
not included in this study.
Samples of raw wastewater, and treated final effluent at laundries
with wastewater treatment facilities, and waste solids were
collected and analyzed for a wide variety of hazardous and
nonhazardous pollutants. The results of the analyses showed that
any of a large number of hazardous organic or metallic pollutants
may be found in industrial laundry wastes at concentrations that
vary widely with location and time. Some hazardous pollutants were
found at levels above 10 mg/1. BOD5, TSS, and oil and grease
levels average approximately 1000 mg/1.
Wastewater analytical data were used to estimate the industry's
annual raw waste pollutant mass loadings for several classes of
organic, metallic and other types of pollutants. These estimated
raw waste loads are presented in the Summary Table.
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SUMMARY TABLE
SUMMARY OF THE ESTIMATED ANNUAL RAW WASTE
MASS LOADINGS OF THE INDUSTRIAL LAUNDRY INDUSTRY
Mass Loading
Pollutants
(1000 Ibs/yr)
(1000 Ibs/yr)
Conventional Pollutants
BOD.
TSS3
Oil and grease
Subtotal
NonconventionalPollutants
Volatile organics
Semivolatile organics
Pesticides and Herbicides
Metals and elements
COD
Subtotal
Priority Pollutants
Volatile organics
Semivolatile organics
Pesticides and herbicides
Cyanide
Metals
Subtotal
Total
165,000
154,000
148.000
24,000
3,100
200
1,500
688.000
467,000
717,000
5.400
1.189.000
Note: Mass loadings are based on an estimated population of 1,000 industrial
laundries and a total industrial wastewater flow of 68 million gallons
per day.
ii
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The 1978 screening and verification sampling program involving
industrial laundries suggested that shop towels and cloths were a
significant source of the priority pollutants (volatiles,
semivolatiles, and metals) found in industrial laundry wastewater.
However in 1982, the Agency excluded the Industrial Laundries
subcategory from national regulations because 95 percent of all
industrial laundries discharged pollutants that were susceptible
to treatment by publicly-owned treatment works (POTW) , and did not
interfere with or pass through POTWs and were not otherwise
incompatible with POTWs.
Since then there have been a number of developments that suggest
a reconsideration of this exclusion may be necessary. First, the,
results of the ITD/RCRA sampling program suggest that shop towels!
are a continuing source not only of priority pollutants but many
nonconventional hazardous pollutants as well. Secondly, the Agency
has acquired a limited amount of data which suggests that a new
technology, ultrafiltration, can be used to reduce significantly
the pollutant concentrations generated by the laundering of shop
towels. The Agency now has more information on the POTW
volatilization of the many volatile pollutants generated by
industrial laundries. Thus, the Agency may have adequate
information to determine whether these pollutants pass through
POTWs .
Sampling data and comments by industry personnel and treatment
system operators have identified wastewater from laundering shop
towels as the industry's major source of hazardous pollutants.
Control and reduction of pollutants generated by washing shop
towels may well reduce the total pollutant load discharged by the
industry to a point where it is no longer a concern.
Economic data characterizing the industrial laundries industry were
obtained from the U.S Census Bureau, the Institute of Industrial
Launderers and earlier U.S. EPA Effluent Guidelines studies. The
number and size of industrial laundries and the number of employees
and the revenues generated per facility were determined. These
data were compared with earlier data (from approximately 1980) to
characterize the industry and identify trends in the industry.
The study showed that the industry comprises many rather small
facilities and a few large ones which economically dominate the
industry. There has been some growth in the industry in some
regions of the country but overall there has been little growth
either in number of employees or revenue in the last twenty years.
The data suggest that the industry is slow to modernize and that
productivity, although increasing, is offset by cost competition.
Three major influences on the industry are shown to be competition
within an industry experiencing no significant growth, the
availability of substitute goods and services, and environmental
regulation. The industry personnel -Fe>*tL that disposable products^
towels) poseia threat_to__jthe
^ ___
indtrs-efyT In addition, increased costs due 'Co environmenEa
might cause customers to move toward in-house laundries
or increased use of disposables.
iii
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The economic data gathered are used to describe the financial
characteristics of industrial laundry firms and to estimate the
impact on industry profits of a requirement for ultrafiltration as
a wastewater pretreatment system. The data indicate that many
firms in the industry operate on very slim margins of income over
liabilities, have high liabilities compared to net worth and have
very small operating margins. In other words, many facilities
would have trouble absorbing the costs of installing and operating
wastewater pretreatment systems.
Three model plant sizes were defined, based on plant revenues, on
which the economic impact analyses were performed. The model
plants, represented approximately the 25th, the 50th, and the 80th
percentiles, respectively, of all industrial laundry
establishments. The capital and operating costs were calculated
for ultrafiltration pretreatment systems sized appropriately for
each model plant. Finally, the impact on pretax profits of
installing the ultrafiltration systems were calculated for the
model mills.
Assuming that costs cannot be passed on to the customers, the
analysis indicates that a requirement for ultrafiltration
pretreatment may result in severe economic impacts for a large
proportion of plants in the industry. The annualized cost of
pretreatment is predicted to be greater than the pretax profit
earned by over one-fourth of the firms in the industry. The impact
is much greater on smaller firms.
The environmental impact study evaluated the impacts of fourteen
indirect discharging industrial laundries on publicly owned
treatment works (POTWs) and ultimately on the POTW receiving
streams. Impacts on the POTWs were evaluated in terms of
inhibition of POTW operations and contamination of the
POTW sludges. Receiving stream impacts were evaluated by comparing
estimated instream pollutant concentrations with aquatic life toxic
effects levels and EPA water quality criteria.
Two data sets were used for the environmental impact analysis, one
from a 1986-1987 EPA industrial laundries wastewater effluent
monitoring program and one from a similar 1978 EPA program.
Analysis of the ____.
Onty^beli^idine and arsenic exceed 'humarT health criteria
md cyanide exceeds ~
Analysis of the 1978 data set projects water quality impacts. Six
pollutants exceed human health criteria or chronic aquatic life
criteria or both and two pollutants, (zinc and lead) exceed POTW
inhibition levels.
iv
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SECTION 1
1.0 INTRODUCTION
This document provides the most current information available about
the industrial laundries subcategory of the auto and other
laundries point source category. The document comprises three
studies of the subcategory; a technical support study including
processes employed, waste characteristics, and wastewater treatment
technologies employed (Sections 2 through 7), an economic impact
study projecting the likely economic results of regulating
industrial laundries wastewater discharge (Sections 8 through 11)
and an environmental impact study evaluating the impacts of the
industry's wastewater on the environment (Section 12).
This study of the industrial laundries industry (hereinafter called
the industry study) was undertaken in response to the
recommendations of the Domestic Sewage Study that EPA review
pretreatment standards, collect additional data, and amend the
categorical pretreatment standards as necessary, for the industrial
laundries industry (among several other industries). A history of
the Domestic Sewage Study and its role in focusing regulatory
attention under the Clean Water Act is set out below.
1.1 Purpose and Authority
The Federal Water Pollution Control Act (Clean Water Act or CWA)
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
was to issue effluent limitation guidelines, pretreatment
standards, and new source performance standards for industry dis-
chargers .
The Act included a timetable for issuing these guidelines.
Pursuant to the Act and a settlement agreement reached in
litigation, 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. See
Natural Resources Defense Council, Inc. v. Train. 8 ERC 2120
(D.D.C. 1976), modified. 12 ERC 1833 (D.D.C. 1979). Moreover, EPA
is required by section 301(d) of the Federal Water Pollution
Control Act Amendments of 1972 and 1977 (the "Act"), to review and
revise, if necessary, effluent limitations promulgated pursuant to
sections 301, 304, 306, 307, 308, and 501 of the Act.
In 1984, Congress enacted the Hazardous and Solid Waste Amendments
(HSWA) to the Resource Conservation and Recovery Act (RCRA).
Section 3018(a) of RCRA, as amended, directed EPA to submit a
report to Congress concerning wastes exempted from RCRA regulation
as a result of the Domestic Sewage Exclusion of RCRA and discharged
through sewer systems to publicly owned treatment works (POTWs).
The report mandated by Section 3018(a) examined the nature and
sources of hazardous wastes discharged to POTWs, measured the
effectiveness of Agency programs in dealing with such discharges,
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and recommended ways to improve the programs to achieve better
control of hazardous wastes entering POTWs. The report (the
Domestic Sewage Study, hereinafter referred to as the DSS) (1) was
prepared by EPA's office of Water and submitted to Congress on
February 7, 1986.
Section 3018(b) then required the Administrator to revise existing
regulations and to promulgate such additional regulations as are
necessary to ensure that hazardous wastes discharged to POTWs are
adequately controlled to protect human health and the environment.
These regulations are to be promulgated pursuant to RCRA,
Section 307 of the CWA, or any other appropriate authority
possessed by EPA.
The Domestic Sewage Exclusion (DSE) established by Congress in
section 1004(27) of RCRA, provides that solid or dissolved material
in domestic sewage is not solid waste as defined in RCRA and such
materials cannot be considered a hazardous waste for purposes of
RCRA. The DSE applies to domestic sewage and industrial wastes
discharged to POTW sewers which contain domestic sewage, even if
the industrial wastes would otherwise be considered hazardous
wastes.
Under the DSE industrial facilities which discharge such wastes to
sewers containing domestic sewage are not subject to RCRA generator
and transporter requirements, such as manifesting and reporting.
In addition, POTWs receiving such wastes mixed with domestic sewage
are not deemed to have received hazardous wastes and therefore need
not comply with certain RCRA hazardous waste treatment, storage,
and disposal requirements with respect to these wastes. However,
the DSE does not apply to sludge produced by a POTW as a result of
wastewater treatment if such sludge is found to be a RCRA
characteristic waste under 40 CFR 261 subpart c.
The DSE stems from the assumption that the pretreatment program of
the CWA can ensure adequate control of industrial discharges to
sewers. This program, mandated by section 307(b) of the CWA and
implemented in 40 CFR Part 403, requires the establishment of
pretreatment standards for pollutants discharged to POTWs by
industrial facilities, to prevent such pollutants from interfering
with, passing through, or otherwise being incompatible with the
operation of POTWs. The DSE avoids the potential regulatory
redundancy of subjecting hazardous wastes mixed with domestic
sewage to RCRA management requirements if these wastes are already
subject to appropriate pretreatment requirements under the CWA.
The study concluded that the DSE should be retained at the present
time and recommended ways to improve various EPA programs under the
CWA to obtain better control of hazardous wastes entering POTWs.
In addition, the Study recommended research efforts to fill
information gaps, and indicated that other statutes (such as RCRA
and the Clean Air Act) should be considered with the CWA to control
either hazardous waste dischargers or receiving POTWs or both, if
the recommended research indicates the presence of problems not
adequately addressed by the CWA.
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One of the main recommendations of the Study was that EPA review
and amend categorical pretreatment standards to achieve better
control of the constituents of hazardous wastes. The DSS
recommends that the Agency modify existing standards to improve
control of organic priority pollutants and non-priority pollutants,
and that EPA promulgate categorical standards for industrial
categories not included in the Natural Resources Defense Council
consent decree (NRDC v. Train, 8 ERG 2120. D.C.C. 1976).
The Study found that some industrial sources discharging
potentially hazardous wastes to POTWs may not be sufficiently
regulated by categorical standards. Among these unregulated
sources are industrial laundries which tend to discharge
significant quantities of toxic and hazardous pollutants on a
facility-specific basis.
1.2 Regulatory Background
The Auto and Other Laundries Category which includes industrial
laundries as one of its subcategories was one of the industry
categories mandated for study and possible effluent guidelines
development by the 1977 Clean Water Act and a Settlement
Agreement between the Agency and environmental groups. In 1980,
the Agency did propose PSES, PSNS, and NSPS for the industrial
and linen supply laundry subcategories of the industry. This
proposal was later withdrawn and the industry, including the
industrial laundries subcategory, was excluded from regulation by
paragraph 8 of the Natural Resources Defense Council v. Costle
consent decree. The basis for the exclusion of the industrial
laundry subcategory was the fact that 95 percent of the
subcategory dischargers discharged pollutants that were amenable
to treatment by POTWs and which did not pass through, interfere
with, or prove otherwise incompatible with the operation of
POTWs. As stated in the previous section, the Agency may
reconsider this exclusion because of recent developments.
The Agency has undertaken several studies of this industry. The
first resulted in draft proposed effluent guidelines and
standards and a draft proposal development document in 1974.
More recent studies, occurring in 1977 through 1980 documented
the decision to exclude the industry from regulation under
paragraph 8 and resulted in
Guidance Document for Effluent Discharges from
the Auto and other Laundries Point Source Category. February
1982.
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TECHNICAL SUPPORT
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SECTION 2
2.0 INTRODUCTION TO TECHNICAL SUPPORT STUDY
Sections 2 through 7 of this document provide a technical study
of the industrial laundries industry focused primarily on waste
generation and characterization and wastewater treatment. The
study reviews previous EPA wastewater studies of the industrial
laundries industry and updates the EPA data base.
2.1 Introduction
The technical study provides an updated profile of the industrial
laundries industry, and chemical analyses of wastewater and waste
solids obtained from recent sampling episodes and recent
wastewater monitoring data obtained through other authorities.,
The document provides a technical basis which can be used to
determine whether regulations should be developed for this
industry. The document will also serve as a summary of
information which can be used by permit writers and POTWs in
controlling hazardous wastes until final rules are published.
The industrial laundry subcategory is defined and described in
Section 3 and subcategorization is reviewed in section 4.
Section 5 characterizes industrial laundries wastewaters in terms
of flow, concentrations and loads. Pollutants of concern are
identified in Section 6, and control and treatment technologies
are discussed in Section 7.
2.2 Study Methodologies
At the start of this industry study, data gathering efforts and
information assessments were subdivided into the following tasks.
Review and Assessment - Previous data were reviewed, data gaps
and requirements were assessed and industry opinions and
assistance were obtained via a meeting with representatives of
the Institute of Industrial Launderers, the Textile Rental
Services Association of America, and the Alliance of Textile Care
Associations.
Supplemental Data Gathering - Background information necessary to
prepare a list of candidate facilities to be sampled, or
necessary to update existing information on this industry was
obtained from documents reporting previous Agency (Effluent
Guidelines Division) studies of the auto and other laundries
industry, the most recent of which are:
° Guidance Document for Effluent Discharges from the Auto and
Other Laundries Point Source Category. February 1982 ,*
o Development Document for Effluent Guidelines and Standards f
or the Auto and Other Laundries Point Source Category.
October 1980;
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o Technical Support Document for Auto and Other Laundries Indu
stry. October 1979.
These documents and the technical record which supports them
summarize the information gathered during the earlier studies.
Data gathering efforts have included two data collection
portfolios (1977 and 1979) and wastewater sampling and analytical
programs.
Recent information used to select the facilities at which
sampling episodes occurred or used elsewhere in this industry
study were obtained from the following.
o telephone interviews with, and visits to, personnel at EPA
Regional and State offices, industry trade associations, and
representative industrial laundry facilities; and
o the literature, including research reports, journals and
magazines, and computer-based abstract data bases.
Information was obtained to reliably characterize the industry's
processes, subcategorization, and pollutants of concern and to
determine pollutant treatability and identify possible treatment
technologies.
Supplemental Data Collection Portfolio (DCP) - A DCP to
supplement the 1977 DCP has been prepared and, after Agency
approval, will be distributed to the industry. The DCP will
furnish necessary information about current industry practices.
Sampling and Analytical Programs - A program was undertaken to
obtain wastewater and waste solid samples at four industrial
laundries located in different sections of the country.
Information obtained during the supplemental data gathering
program in conjunction with the advice and assistance from the
Institute of Industrial Laundries was used to select seven
laundry facilities for site visits four of which were later
selected for sampling episodes.
Raw wastewater, treated effluent, and waste solids samples were
obtained at each facility. The samples were analyzed for
conventional and nonconventional pollutants and the pollutants on
the "ITD List of Analytes" (priority pollutants plus
approximately 200 additional organic compounds). Sludge
leachates from solids samples were also analyzed for the
compounds on the ITD list.
Industrial Profile and Subcateggrj.zation -The detailed
information collected in previous data gathering efforts was the
basis for the industry profile presented in documents referenced
above. Information collected during the present study has been
compared to earlier information to update, and revise as neces-
sary, the industry profile and subcategorization scheme.
Additional information will be obtained from the DCP after it is
distributed and returned.
Water Use. Solids Generation, and Waste Characterization - The
data base established previously by EPA and the new data was
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reviewed to update the water use and waste characterization for
the industry. The available literature about industrial
laundries was reviewed and data collected during the sampling
program and from state and municipal authorities were evaluated.
Selection of Pollutant Parameters - The analytical data base was
updated to include data obtained both during previous industry
studies and during this industry study. The data base was
reviewed with respect to levels, frequency of occurrence, and
relative toxicity of pollutants found in the wastewaters and
waste solids generated by the industrial laundries industry to
identify pollutants of concern.
Assessment of Control and Treatment Technologies - Previous and
new waste treatment information and data on full scale, pilot
scale, and laboratory scale in-plant controls and treatment
systems were evaluated. Literature on in-plant controls avnd
treatment systems were collected and reviewed. As part of the
control and treatment technology assessment, pollutant reduction
and treatability were evaluated to determine the effluent levels
attainable by the various technologies.
Information for technologies used in other industries to remove
any of the significant pollutants identified in this industry
category was obtained and reviewed to determine if the
technologies can be applied to the industrial laundries.
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SECTION 3
3.0 DESCRIPTION OF THE INDUSTRY
This section consists of a general profile of the industrial
laundries industry including size, products, and trends since
previous EPA studies of the industry, and a description of the
laundering processes used by the industry.
3.1 Industry Profile
Industrial launderers, Standard Industrial Classification (SIC
7218), operate establishments which primarily supply laundered or
dry-cleaned work uniforms, wiping towels, safety equipment
(gloves, flame resistant clothing, etc.)/ dust covers and cloths,
and similar items to industrial or commercial users. These items
may belong to the industrial launderers and be supplied to users
on a rental basis or they may belong to the customer.
There are 1288 operating industrial laundries (SIC 7218)
according to the 1982 Census of Service Industries. Of these,
approximately 1000 operate their own laundry or dry-cleaning
facilities and the remainder are mostly sales establishments or
administrative or distribution centers. This study is concerned
only with those that operate laundering or dry-cleaning
processes.
Industrial laundries, because of the nature of their business,
are mostly located in metropolitan areas, normally close to their
customers. They are located throughout the United States but
about half are found in the seven most densely populated
industrial states. Because of their metropolitan locations,
almost all industrial laundries discharge to publicly owned
treatment works.
The laundries industry, as characterized by its labor force and
equipment usage, has been slow to modernize. The industry is
extremely labor intensive, with about one-third of the labor
force earning minimum wages. The industry is also conservative
in equipment usage as equipment has not changed greatly in design
in recent years. Basic laundry equipment is durable and there is
a strong tendency in the industry to purchase used or rebuilt
machinery when replacing equipment. However, economic forces are
causing some changes. For example, the shortage in unskilled
labor is forcing the industry to begin to convert to more modern,
partly or fully-automatic labor-saving equipment.
Most industrial launderers offer their customers a variety of
textile maintenance services but more than 80% of the total
weight of material cleaned by industrial laundries consists of
industrial garments (such as uniforms, coveralls, work shirts,
and pants), industrial flatwork items (particularly shop towels)
and dust control items (such as floor mats, mops, and tool
covers). The remaining items cleaned include linen service items
(white uniforms, restaurant and hotel linens, etc.) and a variety
of commercial laundry and dry-cleaning products. The major
8
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customers of industrial laundries are chemical and manufacturing
plants, automotive repair shops and service stations, machine
shops, printing establishments, and janitorial services.
Because the nature of this service industry, receipts for the
industry are closely tied to the gross national product. The
1982 Census of Service Industries indicates that total receipts
of the industrial laundering industry were 1.9 billion dollars in
1982. Linen suppliers (SIC 7213) generated an additional 0.23
billion dollars in receipts for products defined as industrial
laundering.
Industrial laundries and linen suppliers use the same basic
equipment to provide similar services. Although there is some
overlap in the work done by industrial launderers and linen
suppliers, industrial launderers rent personalized garments
fitted and labeled for the individual while linen suppliers
provide rental garments by size. Some industrial laundering is
also done, to a lesser extent, by power (commercial) laundries
(Sic 7211) and dry cleaners (SIC 7216).
Changes in the industry since the previous EPA studies (1974 and
1979) have not yet been fully documented but some trends are
apparent. Factors having relatively great effect on the industry
are the cost of energy, and federal, state and local
environmental regulations. Increasing energy costs have caused
the industry to use lower washwater temperatures whenever
possible (7). However, to attain the same degree of cleansing at
lower temperatures, the launderer must use greater quantities of
surfactants and other chemicals thereby increasing the pollutant
loading of the waste effluent.
In many communities, local water pollution control standards have
become more strict in recent years causing launderers in these
areas to seek methods to reduce their water use and pollutant
loadings. Among the solutions occurring in the industry are
addition of wastewater pretreatment systems and use of more
efficient laundering equipment. Some launderers have dropped
customers with particularly dirty garments or shop towels (these
customers may send their articles to communities with less
stringent regulations). In addition, there appears to be a shift
from heavily soiled blue collar work uniforms towards cleaner,
white collar work clothes such as the slacks and sports jackets
worn by airlines personnel.
More numerous and more stringent water and air standards and
concomitant problems of pollutant control are causing the
industrial laundries industry to give up dry-cleaning processes
in favor of waterwashing processes which result in fewer water
pollution and no air pollution problems. In 1977, an estimated
420 facilities out of a total of approximately 1,000 industrial
laundries did some dry cleaning. In 1987, there are still
approximately 1,000 industrial laundries, but only an estimated
150-160 facilities still use dry-cleaning processes. Further
increases in the cost of petrochemicals may further reduce the
use of dry-cleaning processes.
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3. 2 Industry Processes
The three basic processes used at industrial laundries are water
wash (laundering), dry cleaning, and dual-phase processing. The
process and types of equipment used in each laundry depend to a
large degree on the types of services offered.
In the laundering process, soiled materials are first sorted so
that processing can be done on the basis of fabric type, color,
soil type, ownership, or type of garment. Items requiring
prespotting and destaining are identified. Stains which may set
as a result of washing must be removed before washing. Destain-
ing procedures include soaking in cold water and use of acids,
bleaches, or multiple organic solvents or a combination thereof.
Each laundry load is then put in a washing machine and undergoes
a series of cycles in which various processing operations are
carried out, depending on the types of items, composition of the
fabrics, and the soil classification. The first cycle is
generally a flush (defined as any rinsing operation before
bleaching) in which water removes loosely attached solids and a
portion of the water soluble soils. The flush may be followed by
the break (defined as the first supply operation) during which
the garments are treated with an alkali solution to swell
cellulosic fibers so that soil is more easily removed.
Detergents may also be added at the break. The actual wash
cycles (sudsing) are multiple procedures in which articles are
agitated in repeated changes of detergent solutions until they
are clean.
The sudsing cycles are frequently followed by a bleach cycle
where the detergent solution is replaced by a bleach solution.
Sudsing is then followed by a series of rinsing cycles to reduce
the alkali and soap content of the fabrics. Next a blueing or
brightening cycle may be included. The final operation (the
finish) usually involves souring or acidifying to reduce the pH
of the final bath to about 5 to prevent yellowing of fabrics by
sodium bicarbonate during pressing.
A typical wash formula for heavily soiled work uniforms is
presented in Table 3-1. The number of sudsing operations and
rinses and the types of special treatments will vary with the
types of materials laundered and with the particular laundry
establishment doing the work.
After being laundered, typical fabrics retain water equal in
weight to about 2.5 times their dry weight. Most of this water
is removed in a 5 to 15-minute cycle in an extractor, which may
be either a centrifugelike device or a hydraulic press. When
removed from an extractor, fabrics generally retain moisture
equivalent to only 50% of their dry weight and are ready for
pressing or other finishing operations.
Finishing is the last step before readying the laundry items for
customer delivery. Finishing generally refers to drying,
pressing, and folding of the laundered goods, but may also
10
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TABLE 3-1
TYPICAL FORMULA FOR HEAVY SOIL (WORK UNIFORMS)1
Operation
Flush
Break, Sudsing
Sudsing
Flush
Bleach
Rinse
Rinse
Rinse
Finish
Washer
Water
Level
High
Low
Low
High
Low
High
High
High
Low
Temp
t-F)
140-160
180
165-180
1VO- 160
140-160
120-140
105-115
105-115
105-115
Time
(Minutes)
1-3
10-12
5-8
1-2
8-10
1-2
1-2
1-2
4-6
Supply
Type pH
Alkali; 11.5-12.5
detergent
Detergent
Bleach 10.2-10.8
Sour; mildistat; 5.5-6.5
Softener
1 From Textile Laundering Technology (8)
11
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involve destaining and minor repairs. In the past it was the
most labor intensiveprocess associated with laundering as each
piece was pressed individually. Now, however, much work is being
done automatically by steam tunnels. In this process, items on
hangers are conveyed through the two chambers of a steam tunnel.
Garments are exposed to live steam at about 40 psi. Saturation
of each piece with steam heats and relaxes synthetic and natural
fibers and the garments return to their original shape. From the
steaming section they pass into the drying/air finishing chamber.
Here hot dry air is forced over the garments at high velocity so
that the wrinkles are removed as the garments are dried. Items
that don't require pressing, such as towels, mats, etc., are
dried in hot air tumblers.
Conventional washers used in professional laundries can handle
loads from 20 to 1,000 pounds and are equipped with thermometers
for temperature control, gauges for control of water levels,
timing devices, and devices to reverse the direction of rotation
every four or five revolutions. The equipment, often fully
automatic through the entire wash cycle, usually consists of a
perforated horizontal cylinder rotating in a shell. The
cylinders are equipped with ribs that lift the fabrics as the
cylinder rotates and drops them back into the washing solution.
The cylinders range from 24 in. to 60 in. in diameter, and from
18 in. to 126 in. in length. Some washers may automatically
deposit the wash load into trucks or an adjacent extractor, but
many must be emptied manually at the completion of the washing
cycles.
Other washer designs available are the tunnel washer and the
modular washer. Tunnel washers provide continuous operation and
can process up to 1,870 Ib. of laundry per hour in a fully
automatic process. Water, steam, and laundry chemicals are
mechanically injected into the system, and following washing, the
load is moved by conveyer to extractors and dryers. Tunnel
washers use a counterflow process: water at tap temperature
enters the system at the discharge end for the final rinse and
flows through the rinse and suds bath before discharge to a
drain. Live steam may be introduced at several points along the
tunnel to heat the water to the desired temperature for rinsing,
bleaching, and sudsing, or high temperature zones can be located
within the tunnel to heat the water. Tunnel washers use less
water than conventional washers (0.7 - 1.5 gal/lb of laundry
processed versus 1.5-5 gal/lb).
Modular units can be used alone or in combination with other
units to provide flexibility in machine capacity. These washers
have a shell-less design, with agitation provided by a portion of
the wash solution surging in and out of the machine. Modular
units are loaded from the top by hopper, sling, or conveyor and
are unloaded through a front door. The units, when accompanied
by conveyors, hydraulic extractors, and tumbler dryers, may
constitute a fully automatic system.
Dry-cleaning processes are similar to waterwashing. In the dry-
cleaning process, fabrics are cleaned in an organic solvent
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instead of an aqueous detergent solution. Certain hydrophilic
fibers, washed in water, swell and undergo dimensional change
that causes wrinkles and shrinkage which can be avoided by use of
dry-cleaning solvents. These solvents dissolve soils at low
temperatures and under generally mild conditions, unlike
laundering processes which involve complex colloidal mechanisms
occurring at high temperatures and the use of relatively harsh
chemicals such as alkalis and bleaches. Thus, dry-cleaning
causes considerably less wear on a fabric than laundering and
uses much less water.
The general processing steps for dry cleaning are similar to
those for laundering. Three methods are used: charged system,
fresh soap adde4__tp-xfiach load, and no soap added. In the charged
system, a (detergent \nd a small quantity of water (usually 0.5%
to 4%) are added tcr1 the dry-cleaning solvent. The water and
detergent concentration in the solvents is maintained throughout
the washing process by using conductivity meters to automatically
control the addition of water and detergent. In the second
method, the solvent is charged with a given amount of soap or
detergent at the beginning of each load and does not receive any
additional charge during the cleaning cycle. Because the process
is not monitored as closely as the charged system, maximum
efficiency is not achieved with this system. The no-soap method
uses only dry-cleaning solvent.
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 pfocess wastewater3\
The wastewater contains varying quantities of the solvent.
Industrial launderers frequently supply customers with dust mops
treated with oil the purpose of which is to retain the collected
dust. To avoid water pollution problems when the mops are
returned for cleaning, some companies clean and treat the mops
directly in the treatment oil. Mops are loaded into a
washer/extractor and cleaned with the heated treatment 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 which uses no process
water.
Dual-phase or dual-stage processing is a cleaning method that
employs a water/ detergent wash and a separate solvent wash to
clean items that contain large amounts of both water-soluble
soils and oil and grease. The order of"processing is determined
by the solvent used, type of soil, and drying energy require-
ments .
All of the 74 industrial laundries for which data were collected
in the 1977 data collection portfolio used water-wash for some
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portion of their workload, 52 dry-cleaned some portion, and 17
used the dual-phase process for some portion. More than 80
percent of the total poundage washed by the surveyed laundries
was water-washed, about 13 percent was dry-cleaned, and only
about 5 percent was dual-phase processed. Dry cleaning processes
are apparently used to a considerably lesser extent at present
than in 1977. Relatively high quantities of dry cleaning solvent
may enter the wastewater stream as a result of dual-phase
cleaning. However, based on discussions with plant personnel and
industry association representatives, dual-phase cleaning is
being phased out as a laundry process.
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SECTION 4
4.0 SUBCATEGORIZATION
The industrial laundries industry is a subcategory of the Auto
and Other Laundries point source category. The subcategorization
scheme for this category is developed in detail in previous
documents (4, 5, 6) and is summarized below.
The primary bases for subcategorization of this category were
type of items cleaned, nature and quantity of soils and
contaminants present on the items, and cleaning processes used.
The subcategorization scheme consists of nine separate
subcategories of which only the industrial laundries subcategory
is currently being studied in this report. This study does not
propose any major modifications to the subcategorization scheme,
but there are two significantly different processes used in the
industrial laundries subcategory that were not fully considered
in earlier studies: laundering shop towels and dry cleaning.
4.1 Laundering Shop Towels
The subdivision of the industrial laundries subcategory into two
product sectors, shop towels and all other water washed items,
was not suggested at the time of the subcategorization develop-
ment. However, the data suggest that pollutant loading for shop
towel wastewaters is so much higher than the combined wastewaters
from other water washed products that significant reductions in
pollutant loads can be realized by treating only wastewater from
shop towel washing processes.
According to the 1977 data collection survey, most industrial
laundries wash some shop towels, but very few wash only shop
towels. A substantial portion, about 20 percent, of the
industry's total production is shop towels. It is therefore
probably not practical to create a new subcategory for towel
washing, but it should be considered a significant product sector
of the industry.
There is general recognition within the industry that the
greatest single source of pollutants of concern is from
laundering shop towels which are also referred to as wipers or
rags. This has been supported in conversations with laundry
personnel, permitting authorities, and treatment system
operators. EPA has on record several letters from treatment
system operators stating that wastewater from industrial
laundries and specifically wastewater from laundering shop
towels, are among their major problems. A number of laundries
have reduced their pollutant loads by refusing to service some
customers' shop towels or by segregating the wastewater from
their towel washing processes and treating this wastewater apart
from the rest.
Shop towels are used to clean solvents or soils from various
objects or to wipe up spilled solvents and other liquids until
they are saturated. They are designed to absorb as much liquid
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as possible. Shop towels are commonly used in print shops,
machine shops, and automotive repair shops. They frequently
contain large quantities of toxic volatile organic solvents such
as toluene, ethyl benzene, or tetrachloroethene; semivolatile
organics such as isophorone and naphthalene; and toxic metals
such as lead and chromium. They may also contain nonconventional
volatile pollutants such as acetone and methyl ethyl ketone as
well as nonvolatile long-chain alkane compounds. Since shop
towels contain heavy soils loads, they require more water and
laundry chemicals per pound washed than do other laundered items.
Thus, the pollutant loads from towel washing processes are
further increased.
There, have been very little analytical data available for
estimating pollutant loads resulting from laundering shop towels
versus laundering other articles. During the current study, one
laundry was sampled that segregates towel washing wastewater from
other process wastewaters. The pollutant concentrations for the
segregated towel washing wastewater stream, and for the remaining
wastewater from washing uniforms and all other products are
presented in Table 5-12 in the next section.
To obtain a comparison of pollutant loads between washing shop
towels and washing uniforms and all other products, the data
shown in Table 5-12 have been converted to average pounds of
pollutant per 1000 pounds of product laundered. These average
pollutant loads have been summed over each of the following
groups: volatile organic compounds, semi-volatile organic
compounds, priority pollutant metals, common metals (Ca, Fe, Mg,
Na) , and other metals (Al, Ba, B, Co, Mn, Mb, Sn, Ti, V, Y) .
These total loads and the loads for BODJ5, COD, TSS, and oil and
grease are presented in Table 4-1.
Although the data are based on only two days sampling of
wastewater streams which contain highly variable quantities of
pollutants, the difference in the average pollutant loads per
1000 pounds product between shop towels and uniforms is
pronounced. The pollutant loads resulting from washing towels
contain four to nine times as much priority pollutant metals,
common metals, and other metals, BOD5_, TSS, and COD as the
pollutant loads resulting from washing uniforms. Laundering
towels generates approximately 35 times as much semi-volatile
organics, 32 times as much oil and grease, and 100 times as much
volatile organics. Although the amount of data is limited, the
data do indicate that the difference between pollutant loads
generated by laundering towels and laundering other products is
significant.
4.2 Dry Cleaning
Dry cleaning is another process used in the industrial laundries
industry that was not proposed for further consideration during
earlier studies. Dry cleaning is recognized as a separate
subcategory that is defined as comprising facilities producing a
product for the general public. Industrial launderers who use
some dry-cleaning processes, or only dry cleaning processes and
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TABLE 4-1
RAW WASTEWATER POLLUTANT LOADING:
COMPARISON BETWEEN LAUNDERING SHOP-TOWELS
AND LAUNDERING UNIFORMS
Pollutant
total volatile organic
compounds2
total semi-volatile organ
Average Raw Waste1
Shop Towels
(Pounds per
1000 pounds towels)
1.49
ic 1.11
Average Raw Waste1
Uniforms
(Pounds per
1000 pound uniforms)
0.014
0.032
Ratio1
of Towels
Raw Waste:
Uniforms
Raw Waste
106
35
compounds2
total pesticides and
herbicides2
total priority pollutant
metals2
0.718
0.154
4.7
total common metals3
total other metals4
BOD5
COD
total suspended solids
oil and grease
flow (gal/lb production)
16.6
0.420
46.3
188
78.6
113
2.1
3.55
0.115
8.29
47.3
9.14
3.58
1.7
4.7
3.7
5.6
4.0
8.6
32
1.2
1 These estimates are based on average concentrations and productions during a
two-day sampling episode and long-term average flow rates.
2 See Table 5-12 for listing of specific pollutants.
3 Ca, Fe, Mg, Na
4 Al, Ba, B, Co, Mn, Mb, Sn, Ti, V, Y
17
-------
no waterwashing processes, are considered to be in the industrial
laundry subcategory.
The most commonly used dry-cleaning solvent, tetrachloroethene,
also known as perchloroethylene or perc, is a chlorinated
hydrocarbon and therefore a pollutant of concern. The dry-
cleaning processes contribute some perc to the wastewater stream,
but there is little data available to quantify a relationship
between the amount of dry-cleaning processed at an industrial
laundry and the pollutant loading resulting therefrom. Dry-
cleaning processes also generate much less wastewater than other
laundering processes. Few industrial laundries employ only dry-
cleaning processes and most industrial laundries that do some dry
cleaning are using the dry-cleaning processes less than in the
past. Therefore, at present, there is little evidence suggesting
a need for subdivision of the industrial laundries subcategory
with respect to dry-cleaning processes.
18
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SECTION 5
5.0 WATER USE AND WASTE CHARACTERIZATION
In this section the quantity of wastewater discharged and the
types and concentrations of pollutants found in the wastewater
and waste solids generated by the industrial laundry industry are
discussed. In the ensuing discussions the pollutants or
pollutant parameters have been divided into four groups which
have the following specific definitions.
o Conventional Pollutants - The conventional pollutants
include biological oxygen demand (BODJi), nonfilterable
residue (TSS), pH, and oil and grease.
o Priority Pollutants - The 126 toxic pollutants listed by
the Agency as a condition of the NRDC Consent Decree.
o Nonconventional Pollutants - This group comprises the
pollutants on EPA's "1987 List of Analytes" which are
not conventional or priority pollutants, or parameters
for characterizing solid waste (solid waste
characteristics). The group consists of the organic
(including pesticides and herbicides), metallic and
elemental pollutants and traditional pollutants mostly
analyzed by wet chemistry methods including filterable
residue, fluoride, ammonia, Kjeldahl nitrogen, nitrate-
nitrite, phosphorus, chemical oxygen demand (COD), total
organic carbon (TOC), and sulfide.
o Solid Waste Characteristics - These pollutant
parameters, used only to characterize solid wastes, are
flash point, pH (soil), total residue, total volatile
residue, total sulfide, reactivity, toxicity, and
corrosivity.
The priority and nonconventional pollutant groups are further
divided into the following subgroups which are based, in part, on
the analytical methods used to detect their presence.
o volatile organic compounds
o semivolatile organic compounds
o pesticides and herbicides
o miscellaneous priority pollutants (cyanide)
o metals and elements
o miscellaneous nonconventional pollutants (COD and common
ions)
5.1 Water Use Characterization
In typical industrial laundries, the principle sources of
wastewater are from waterwashing laundering processes, plant and
equipment cleaning, and sanitary water. Dual-phase laundering
and dry cleaning are minor sources of process wastewater: the
former is rarely used and the latter consumes only small
quantities of process water.
19
-------
The volume of washwater used in industrial laundries ranges from
0.9 to 9.6 gal/lb of material washed and averages 4.8 gal/lb.
The total volume of washwater ranges from 8,600 to 290,000 gpd
and averages 68,000 gpd per facility. In general, only incoming
water is monitored, but it is estimated that 70-85% of the total
water metered into a plant is discharged as process wastewater.
Eight to ten percent of the incoming water is evaporated from
laundered textiles during the drying cycles and approximately 10
percent is used for sanitary or cleaning purposes. A laundry
using dry cleaning processes may discharge noncontact cooling
water.
Both the average quantity of process wastewater discharged and
the instantaneous rate of discharge at each establishment are
highly variable. The quantity of water discharged depends on the
efficiency of the equipment and operations, water conservation
measures applied, types of articles cleaned, types and loadings
of soils on the articles, and the total amount of waterwashing
versus dry cleaning at each laundry. Wastewater discharge rates
and pollutant loadings vary with time. Typical laundries have
four to eight washers operating independently, discharging
quantities of water that are a function of the loads washed.
5.2 Wastewater Characteristics
In this section the raw wastewater effluent from industrial
laundries will be characterized in terms of conventional,
priority, and nonconventional pollutant parameters. Tables in
the next section list the pollutant parameters searched for, a
brief discussion of the sources of pollutants found in the
wastewater and a presentation of the pollutants found during this
and previous studies of the industry.
5.2.1 Pollutants Searched For
In the past, industrial laundries wastewaters have been
characterized by the following conventional, nonconventional, and
priority pollutant parameters.
o pH
o 5-day biochemical oxygen demand (BOD5J
o chemical oxygen demand (COD)
o total organic carbon (TOC)
o non-filterable residue or total suspended solids (TSS)
o oil and grease
o phosphorus
o 126 priority pollutants
This study characterizes industrial laundry wastewater using
these same pollutant parameters as well as approximately 250
additional volatile and semivolatile organic pollutants derived
from the "ITD/RCRA List of Lists" and an extended list of
metallic and elemental and miscellaneous nonconventional
pollutants. The entire list of pollutants analyzed for during
the current ITD/RCRA study constitutes "The 1987 ITD List of
Analytes". Table 5-1 presents a list of priority pollutants, and
20
-------
Table 5-2 presents the remainder of the 1987 ITD List of
Analytes.
21
-------
TABLE 3.1
LIST OF PRIORITY POLLUTANTS ANALYZED IN THE UASTEWATER OF LAUNDRIES A.B.C. and D.
I. METALS
ANTIMONY
ARSENIC
BERYLLIUM
CADMIUM
CHROMIUM
COPPER
LEAD
MERCURY
NICKEL
SELENIUM
SILVER
THALLlfM
7. INC
II. MISCELLANEOUS
ASBESTOS
CYANIDES
III. OISCKZO-P-DIOXKIS
AND DIBEMZOFURANS
2.J.?.3-TCDD
IV. P«.'Rf:EA8I.E
V. EXTRACTABI-E
A. PESTICIDES
t. ORGANOHALIDC
4.i '-ODD
4.4'-ODE
4 . i ' -DDT
ALDRIN
ALPHA-3HC
BETA-3KC
CHLORDANE
DELTA-BHC
DIELORIN
ENDOSULFAN I
ENDOSULFAN II
ENOOSULFAN SULFATE
EttDRIN
ENDRIN ALDEHYDE
GAHHA-8HC
HEPTACHLOR
HEPTACHLOR EPOXIDE
TC3-I016
PCS-1221
PC3-I232
PCB-1254
PCS- 1260
TOXAPIIEME
I.I.I -TR I CHLOROETHANE
1 . 1 . 2 . 2-TETRACIILOROETHANE
1 .1.2 -TR I CHLOROETHANE
I .1-0 [CHLOROETHANE
I. I-DICHLOROETHENE
I .:-D I CHLOROETHANE
I .2-DICHLOROPROPANE
I ,;-;MCIILCmOPROPYlENE
:-CIII.OROFTim. VIMYI. ETHER
AT.ROI.F. IN
ACRYLOMITRM.E
B.
BRi'Mr'-ICIILnROMETHAME
SROMO'IETIIANE
CARBO;.' TETRACHLORIDE
CHLOROBENZENE
CHLOROETHANE
CHLOROFORM
CIILORONETHANE
DISROMOCHLOROMETHANE
ETHYL SEN^ENE
METHYLENE OILORIDE
rr.TPACIII.ORCETIIEHE
TPL'.'EI.'E
r?\NS-l .I-OICIILOROETIIEJIE
TFICIII.OROKTIIEME
SEMt-VOLATILES
. ,\C:DS
2 . i . 6-TR ICHLOROPHENOL
2.i-DICHLOROPHEHOL
2.i-OIMETHYLPHENOL
2. i-3INlTROPHENOL
:-CIII.OROPHEMOL
4-NITROPHENOL
DiniTROCSESOL
rfiTACHLOROCIIENOL
PHENOL
2. BASES
t.2-DIPHENYLHYDRAZINE
2.i-OtNITROTOLUENE
2.4-DIMITROTOLUENE
3,3-OICHLOROBENZIDINE
i-»ROMOPHENYL PHEMYL ETHER
V-CHLORO-3-METHYLPHENOL
i-CHLOROPHENYL PHENYL ETHER
3F.NZIDINE
b i!. i 2 -CHLCROETHYL) ETJIER
(iiji:-CHLOROISOPRCPYL)ETHER
B. SEMI-VOLATILES
2. BASES
DI-N-PROPYLNITROSAMINE
F1UORENE
ISOFHORONE
N-HITROSOOIMETHYLAMINE
N-SITROSODIPHENYLAMtNE
NITROBENZENE
PYRENE
3. NEUTRALS
a, PHTIIALATES
BIS( 2-ETHYLHEXYDPHTHALATE
3UTYL BEMZYL PHTHALATt
DI-M-BUTYL PHTHALATE
01-,1-OCTYL PHTHALATE
DIETHYL PHTHALATE
DIMETHYL PHTHALATE
b. POLYNUCLEAR AROMATIC
2-CHLORONAPHTHALENE
ACENAPHTHEME
ACEHAPHTHYLENE
ANTHRACENE
SENZOIA)ANTHRACENE
SENZO(A)PYRENE
3EMZO( B) FLL'ORANTHENE
BEHZO(CHt1PERYLENE
BENZOIK > FLUORANTHENE
CIIRYSEME
01BENZOf A.H)ANTHRACENE
FLUORANTHENE
INDEMO(t.2.3-CD)PYRENE
NAPHTHALENE
PMENANTHRF'IF.
c. CHLOHINATED HYnROCARBONS
1.2. i-TRICIILOROBENZF.Nf.
1 .2-niCHLOROBENZENE
1.3-OtCHLOROBENZENE
I . i-OlC:il.OROBENZENE
bis(2-CHLOROETHOXY)METHANE
HEXACHLOROBEMZENE
HEXACHLOROBUTADIENE
HEXACIILOROCYCLOPENTAOtENE
HEXACHLOROETIIANE
•JUT VMM.vr.ED FOR
22
-------
TABLE 5.2
LIST Or NON-PRIORITY POLLUTANT PARAMETERS ANALYZED IN WASTEWATES OF LAUNDRIES A.B.C. and 0
I. ELEMENTS
ALUMtWM
SARUIM
BISMUTH
BORON
CALCIUM
CERlrM
O1BAI.T
DYSPROSIUM
ERBIUM
EUROPIUM
GADOLINIUM
CALLIfH
GERMANIUM
COLO
HA FN I I'M
HOLMim
t:;nn:M
icnirJE
I RID (I'M .
IRON
LANTHAWN
LITHIfM
Lt'TF.TIVM
M-UIMFSIfM
•!A:IC.\!:ESF.
OSMIUM
PALLADIUM
PHOSPHORUS
PLATINUM
POTASSIUM
PRASEODYMIUM
R HEM t I'M
R lion I I'M
RI.'THF.'! HJM
S,\MARII.'!I
SCANDIUM
SILICON
5(10 1 I'M
STPOMTTUM
St'LFVR
TANTALL"!
TELLURIUM
TERRIfM
THORtl'M
TIH'LU'M
TIN
TITANIUM
URANIUM
VA:IADIUM
YTTERBIUM
YTTRIUM
JVPOVIIl'V
II. MISCELLANEOUS
?.ESIDI'E. FILTERABLE
'F.SIPUE, 'ION-FILTERABLE
AS N
. KJELDAHL. TOTAL
TOTAL PHOSPHORUS
II. MISCELLANEOUS
BOD-5
COD
OIL & CREASE. TOTAL RECOVERABLE
TOTAL ORGANIC CARBON
FLASH POINT
PH. SOIL
CORROS1VITY
FLUOR IDF.
NITRATE/NITRITE
SULFTDE
III. DIBENZO-P-DIOXINS
AND DIBEN20FURANS
DIBENZOFURAN
HEPTAC1ILORODIBENZO-P-OIOXINS
H EPTACIILORODIBENZOFURANS
HEXACIII.OROD IBENZO- P-01 OX INS
HEXACIILORODI BENZOFURANS
OCTACirLORODIBENZO-P-DIOXTNS
OCTACHLOROOt BENZOFURANS
PEMTACIII-ORODIBENZO-P-OIOXINS
P EMTACHLORODIBENZOFURANS
TETRACHLORODIBENZO-P-DIOXINS
TETRACIILOROD t BEHZOFURAHS
IV. PURCEABLE
1.I.!.2-TETRACHLOROETHANE
1.2.3-TR1CIILOROPROPANE
1,2-OISROMOETIIANE
U-OiaiLOROPROPANE
t.3-01CHLORO-:-PROPANOL
1 .'-t-OIOXANE
l-SROMO-2-CIILOROBENZEME
I-3ROMO-1-CIILOROBENZENE
2-3UTEMAL
2-HEXANONE
2-P!COL!ME
3-CHLOROPROPENE
4-METIIYL-2-PENTANONE
ACETONE
ALLYL ALCOHOL
CARBON IISULFIDE
CHLOROPRENE
CIS-U-OICHLOROPROPENE
DIBROMOCIILOROPROPANE
DIBROMOMETIIANE
01 aiLOROFLUOROMETHANE
DI ETHYL F.THER
DIMETHYL JiULFONE
ETHYL CYANIDE
ETHYL METHACRYUTE
ISOBUTYL ALCOHOL
METHACRYLONITRILE
METHYL £THYL KETONE
METHYL IODIDE
METHYL METHACRYUTE
N.N-DIMF.THYLFORMAMIDE
TRANS-I ,3-DICIILOROPROPENE
TRANS-I .4-DICIILORO-2-BUTENE
TRICHLOROFLUOROMETHANE
VIMYL ACETATE
V. EXTRACTABLE
A. PESTICIDES
t, ORCANOHALIDE
CAPTAFOL
CAFTAN
CIILORDBENZILATE
ENDRtN XETONE
ISODRIN
KEPONE
METHOXYCIILOR
MIREX
N1TROFEN
PCNB
2. CARBAMATES
ETHYLEMEBISDITH10CARBAMIC
ACID,SALTS. AND ESTFRS
MANEB
•MBAM
THIRAM
ZIME3
ZIRAM
?. ORCMinniOSPHORUS
AZ'.MPHOS-ETHYL
AZINPHOS-METHYL
CARBOPHENOTHION
CHLORFENVINPHOS
CHLORPYRIFOS
COUMAPHOS
CROTOXYPHOS
CYCON
DEMETOH
OtAZINON
DICHLORVOS
DICROTOPHOS
DTOXATH10N
DISULFOTON
EPN
ETUI ON
FAMPHUR
FENSULFOTHION
FENTHION
IIEXAMETHYLPHOSPHORAMIDE
LEPTOPHOS
MALATHION
METHYL PARATHION
MEVtNPHOS
HONOCROTOPHOS
NALED
PARATHION ETHYL
PHORATE
PMOSMET
PHOSPHAMIOON
SULFOTEPP
TEPP
TERBUFOS
TETRACHLORVINPIIOS
TRICIILOROFCN
TRICRESYLPHOSPHATE
TRIMET1IYLPHOSPHATE
23
-------
TABLE 3.2 (continued)
LIST nr TON-PRIORITY POLLUTANT PARAMETERS ANALYZED IN WASTEWATER or LAUNDRIES A.B.C. im» o
4. HERBICIDES
2.4-0
2.4.5-T
2.1.5-TP
DIALLATE
OICIILONF.
B. SEMl-VOLATILES
TRIFIUP.ALIH
». SEMt-VOI.AT!LF.S
I. ACIDS
2.3.4. 6-TETRACHLOROPHENOL
2,3.6-TR!CIII.ORCPHENOL
2.'i.'-TRiciii.nROPiiF:ioi.
KrM7.dC ACID
IIKXANOIC ACID
MALACHITE CREEM
0-CRESOI.
P-CRESOL
P-CYMF.ME
PIIENACETIN
TMI"PIIF:in|.
•ASES
.3-01CIILCRO-2-PROPANOL
.:.5-TRITIIIA:iE
.i-DIMITROBEMZENE
.i-;;ArilTIIOOUlNONE
. 5-;iAPHTHALEMEDIAHlNE
-.~HLOHO-3-;iITROBENZENE
-MF.TMYI.n,UOREMF.
-MrTIIVI.HIE»AHTIIRENE
'lAnmiYLAMtHE
-r!IE?!YL:!APMTHALENE
.5-DICIII.OROAMtLINE
.J-DIC1II.ORONITROBEMZENE
.J-BFMZOFU'ORENE
. '.i-TRIMETHYLANILINE
.i-DI AMINOTCLL'ENE
2-tSCrROrYLNAPHTIIALEtlE
2 - 1 METIW.TII 10 ) BENZOTH I AZOLE
2-METIIYI.ftEMZOTHIOAZOtE
2 -METII YLtIA PHTH ALENE
2-fUPHTHYLAMlNE
2-MITROANILINE
2-PHENYLNAPHTHALENE
1 , 3-D IHETHOXYBENZtOINE
1 .6-OI>1ET!IYLPHE:iANTHRENE
1-METIIYLCIIOLAHTHRrNF.
l-.'lITROAIIII.inr
'• . '. ' -METItYLENEb t »< 2-CIILOROAN I LIN
i.5-MF.THYLE:iE PHEMAMTMRENE
i-AMINOBIPHENVL
i-CHI.ORO-2-NITRCANILlME
i-MITSCniP1IENYL
•-CHLORO-0-TOLUIDIME
5-MITRO.O-TOLUtDINE
?.U-OI«F.THYU3ENZ(a)ANTHRACENE
.\CETOPHENONE
ANILINE
ARAMITE
BENZANTIIRONE
BENZYL ALCOHOL
b I « ( CHI.OROMETHYL ) ETHER
2. BASES
BRCMOXYNIL
CHLOROACETONITRILE
DICHLORAN
DIBENZOTHIOPHENC
DIPHENYL ETHER
DIPHENYLAMINE
ERYTHRITOL ANHYDRIDE
MESTRANOL
METHAPYRILENE
HETHYL HETHANESULFONATE
N.N-OIMETHYLfORMAMlDE
N-NITROSODI-N-BUTYLAHINE
N-N1TROSODIETHYLAHINE
!l-:i ITROSOMETMYLPHENYUH INK
N-MITROSOMETHYLETHYLAMINE
.1-NITROSOHORPHOLINE
N-MITBOSOPtPEHIDINE
0-ANtSIDINE
0-TOL17IOINE
'P-CHLOROANtLtNE
P-DIMETHYUMIMOAZOBENZENE
P-niTROANILINE
PHEMOTIIt.AZINE
PRONAMIDE
PYRIDISE
Til I ANA PHTH EN E
TRITHENYLENE
TRTTROPYLENECLYCOL METHYL ETHER
3. N-ALKANES
N-DF.CANE
N-DCCOSANE
N-DCDF.CAME
N-EICOSANE
N-IIE.tACOSANE
M-HEXAOECANE
N-OCTACOSANE
N-OCTADECAHE
M-TETRACOSANE
S-TETRADECANE
M-TSIACCNTANE
OTHERS
1.2.3-TRTCHLOROBESZENE
1.2.3-TRIMETHOXYBENZENE
I,:.•,5-TETRACHLOROBENZENB
ALPHA-TERPINEOL
BIPIIENYL
DrPIIF.MYL SULFtDE
ETMYLF.NETHIOUREA
ETIIYLNETIIANE SULFONATE
HEXACHLOROPROPENE
ISOSAFROLE
LONCIFOLEME
PENTACHLOROBENZEJIE
PENTACH LOROETHANE
PENTAMETHYLBENZENE
PERYLENE
RESORCINOL
SAFRPLE
SQUALENE
STYRENE
THIOACETAHIOE
THIOXANTHONE
2A
-------
5.2.2 Pollutant Sources
The characteristics of laundry wastewaters are primarily
determined by three factors: the general type of cleaning
process employed (i.e., water versus solvent wash), the types and
quantity of soil present on the textiles being laundered, and the
composition of the various laundering chemicals used.
Cleaning Processes Used - Water-wash effluents contain all of the
soil and lint removed from the textiles, as well as the laundry
chemicals employed in the process. Wastewaters from dry-cleaning
processes tend to contain mostly water-soluble materials and
appreciable quantities of dry cleaning solvent, the latter
normally not present in water-wash effluents. Lint, grit, and
water-insoluble organic and inorganic compounds are largely
removed by the solvent filter or confined to the still bottoms.
Soils Present on Textiles - The soils present in the textiles
brought to each laundry for cleaning vary greatly in composition
and in quantity, reflecting the types of customers serviced by
each laundry. The greatest single source of hazardous pollutants
is probably shop towels and wiping rags which are apparently used
by some customers to dispose of considerable quantities of
organic solvents. The towels and wipers may contain soils
amounting to more than 50 percent of their dry weight. Soils
contained on garments and other articles laundered reflect the
work environments of the industrial manufacturers, chemical
manufacturers, service industries and others that constitute the
clientele of industrial launderers. Mats, dust mops, and other
cleaning articles contribute a great deal of sand—and—gr^t to the
pollutant load but probably no mere hazardous pollutants than are
found in the general environment.
Laundering Chemicals - The process chemicals used in laundering,-
i.e., the laundry formulae, also contribute substantially to the
pollutant load although they may be of lesser importance than the
soil loading. The soaps and detergents contribute to the BOD5.
and oil and grease loadings. Laundry wastewaters generally have
a high pH as most laundering processes occur under alkaline
conditions. A number of priority and other hazardous pollutants
are used for a variety of purposes. Zinc compounds are used in
sours and germicides. Phenolic compounds are used in germicides,
bacteriostats, dust treating compounds, and detergent additives.
Various solvents are used for spot removal and oils may be used
to clean dust mops. Effluents from laundries using chlorine
bleaches probably contain chlorinated hvdrocarbons oroduced
during the bleaching process.
5.2.3 Wastewater Analytical Data
Wastewater analytical data have been obtained from a variety of
sources during earlier EPA studies of the industrial laundries
industry. The first EPA study, initiated in 1971, included a
survey sent to 160 plants. These plants were all members of the
Institute of Industrial Launderers or the Linen Supply
Association of America (LSAA, now the Textile Rental Services
25
-------
Association of America) and included industrial laundries, linen
services and diaper services. In addition to wastewater
analytical data obtained from the survey, EPA obtained extensive
sampling data for conventional and nonconventional pollutants and
some metals at a small number of plants. These studies resulted
in two EPA documents in 1974: a Draft Development Document for
Proposed Effluent Limitations Guidelines (2) , and the Modular
Wastewater Treatment System Demonstration (3).
During studies of the Auto and Other Laundries Category taking
place between 1975 and 1978, EPA gathered conventional,
nonconventional, and priority pollutant analytical data for the
industrial laundries subcategory from several major sources. In
1977 EPA sent surveys to a number of facilities in the category
and received responses from approximately 70 industrial
laundries. The survey provided little wastewater analytical
data, but was the major source of production and process
information used in these studies. The 1977 survey is still the
principal source of water usage information available.
Conventional and nonconventional pollutant data and some priority
pollutant metals data were obtained from municipal sewer district
monitoring reports. These where obtained for industrial
laundries within the jurisdictions of the Metropolitan Sanitary
District of Greater Chicago, County Sanitation District of Los
Angeles County, and the Dade County (Florida) Sanitation
District.
In 1977 and 1978 the LSAA sponsored a survey of 20 member
facilities. Mostly linen supply plants were sampled but some
data were obtained from industrial laundries. The study was
focused primarily on conventional and nonconventional pollutants
and some common priority pollutant metals. The data were
summarized in a 1978 "Report of 20 Member Plants," (39).
Additional wastewater analytical data were obtained from
published and unpublished literature sources (3, 35, 36, 37, 38).
These data also consisted primarily of conventional and
nonconventional and common priority pollutant metals.
In 1978, EPA undertook a screening and verification analysis
program for the Auto and Other Laundries Point Source Category,
to obtain conventional and nonconventional pollutant data, and
data for the entire list of 126 priority pollutants including
metals and organics. Analytical wastewater data were obtained
during this program for approximately 14 industrial laundries.
Most of the laundries sampled had wastewater pretreatment systems
in place and influent and effluent data were obtained from these
plants to characterize the efficiency of the treatment systems.
Most of the sampling episodes were of one day duration, but a
plant with a dissolved air flotation system was sampled for 30
days to obtain variability data.
The screening and verification study was the principle source of
organic priority pollutant data although additional organic
priority pollutant data were obtained from another EPA study.
26
-------
Data from seven laundries were obtained for a 1977 EPA study, the
results of which were published in a document entitled
The Occurrence and Treatabilitv of Priority Pollutants in Industr
ial Laundry Wastewaters (37).
Summaries of the conventional and nonconventional pollutant
concentrations found in laundries wastewaters during the 1975-78
data gathering efforts and sampling programs are presented in
Table 5-3; summaries of priority pollutant concentration data
gathered during the screening and verification program are
presented in Table 5-4. For reference, the concentrations of
some conventional and nonconventional pollutants in domestic
sewage are presented in Table 5-5.
5.3 Wastewater Sampling and Analysis
During the ITD/RCRA industry study, screening sampling episodes
were undertaken at four industrial laundries. Another laundry
was sampled in 1985 as part of the Domestic Sewage Study. This
laundry and the analytical data from it are included in the
discussion which follows. Three of the laundries are located in
two large midwestern cities, one in a moderate sized southeastern
city and one in a moderate sized northeastern city. Laundries A
and B treat their effluent using dissolved air flotation systems,
and Laundries C and E use only settling basins with short
detention time. Laundry D has split wastewater streams: the
effluent from two washers dedicated to shop towels is treated
using an ultrafiltration system and the effluent from all other
laundering processes is discharged through two settling basins
with short detention times.
During the most recent sampling program, wastewater samples were
obtained from raw waste streams and final effluent streams at
four laundries. At the fifth laundry (Laundry E) , samples were
obtained of the final effluent after a settling basin. In
addition, wastewater samples were obtained at several
intermediate points at the laundry with ultrafiltration (Laundry
D) to generate treatment efficiency data across the ultrafilter
and across ancillary lint screens. The wastewater samples were
analyzed for conventional pollutants, priority pollutants, and
nonconventional pollutants, including approximately 250 non-
priority organic compounds from the ITD List of Analytes1 (see
Tables 5-1 and 5-2). The analytical methods used to detect the
pollutants are listed in Appendix A.
Each of the four sampling episodes in which influent and effluent
samples were obtained consisted of two consecutive, separate,
complete wastewater discharge periods (each working day was
approximately ten hours in duration). The fifth sampling episode
1The list of pollutants searched for in the samples from
Laundry E differs slightly from the list presented in Tables 5-1
and 5-2. The analytes searched for at Laundry E can be found in
Appendix B.
27
-------
TABLE 5-3
CONVENTIONAL AND NONCONVENTIONAL POLLUTANT CONCENTRATIONS
IN INDUSTRIAL LAUNDRY WASTEWATERS1
Pollutant
Number Minimum Maximum Median Average
of Concentration Concentration Concentration Concentration
Samples (mg/£) (mg/2) (mg/£) (mg/A)
pH (standard 62
units)
BOD,, 51
COD3 60
TOG 24
TSS 69
oil and grease 66
phosphorus 12
7.5
91
330
130
63
17
1.3
11.9
7,800
7,000
6,800
6,100
7,900
41.6
10.5
920
3,800
1,200
700
730
9.1
10.4
1,300
5,000
1,400
1,000
1,000
12.2
1See Reference (6), p.35. Data were obtained from 73 plants in 1975.
28
-------
TABLE 5-4
PRIORITY POLLUTANT CONCENTRATIONS
IN INDUSTRIAL LAUNDRY RAW WASTEWATERS1
Pollutant
Category and
Pollutant
Number2
Maximum
Concentration
(mg/1)
Median Average
Concentration3 Concentration3
Metals
antimony 7/8
arsenic 6/6
cadmium 7/7
chromium 8/8
copper 8/8
lead 8/8
mercury 4/5
nickel 8/8
selenium 0/4
silver 2/4
zinc 8/8
Volatile Organic Compounds
benzene 2/6
carbon tetrachloride 2/6
1,1,1-trichloroethane 2/6
chloroform 4/6
ethylbenzene 5/6
methylene chloride 3/6
dichlorobromomethane 1/6
tetrachloroethene ' 5/6
toluene 5/6
trichloroethylene 2/6
Semi-volatile Organic Compounds
2-chloronaphthalene 1/6
dichlorobenzenes 1/6
2,4-dimethylphenol 1/6
isophorone 1/6
naphthalene 4/6
N-nitrosodiphenylamine 1/6
phenol 4/6
bis(2-ethylhexyl)
phthalate 4/6
butyl benzyl phthalate 2/6
di-n-butyl phthalate 3/6
di-n-octyl phthalate 2/6
anthracene/phenanthrene 3/6
2.4
0.025
0.11
1.2
4.0
9.4
0.002
0.46
0.0
0.117
4.5
0
0
3
0
17
13
85
3
035
5
0.54
0.003
0.88
2.6
0.80
0.017
1.1
0.46
0.19
4.8
1.8
0.60
3.1
1.5
0.66
0.41
0.47
0.11
0.011
0.060
0.47
1.54
4.6
0.0015
0.12
0.0
0.004
2.99
0.002
0.142
0.001
0.044
0.56
0.217
0.059
0.66
0.046
0.004
1.
5.
0.384
0.013
0.059
0.564
.67
.12
0.0013
0.176
0.0
0.031
3.16
0.022
0.142
0.553
0.008
.13
,109
0.0005
0.219
1.02
0.036
3.
0.
0.003
0.183
0.077
0.032
1.54
0.300
0.136
1.17
0.301
0.175
0.093
0.143
cyanide
4/5
0.28
0.057
0.121
1Data are from 1978 screening program. See 1982 Guidance Document (6),
Section 5 and Appendix A. Data presented here are average influent
concentrations at Plants A,B,C,D,E,K,L, and 2.
2Ratio indicates the number of samples in which the specific pollutant was found
as compared to the total number of samples analyzed.
3Blanks indicate values below analytical detection limits.
29
-------
TABLE 5-5
CONVENTIONAL AND NONCONVENTIONAL POLLUTANT CONCENTRATIONS
LN DOMESTIC SEWAGE1
Typical Concentration
_ Pollutant _ Range, mg/1 _
e 100-300
COD5 250-1,000
TOG 100-300
TSS 100-350
oil and grease 50-150
phosphorus 6-20
aSee Reference (6), p.35
30
-------
consisted of one working day of 24 hours duration. Wastewater
oursamples were composites of samples taken during -the entire
work day.
_5.4 Waste Solids Sampling and Analysis
In addition to wastewater samples, samples of waste solids
generated in the various wastewater treatment technologies in use
were also obtained during the recent sampling episodes at the
four laundries at which both raw waste and final effluent samples
were taken. Samples were obtained of thickened DAF sludge, of
sediments from settling basins, and of solids from two lint
screens at one of the laundries. In addition to solids samples,
an oil sample from an oil skimmer and a final concentrate sample
from an ultrafiltration unit were obtained.
Solids samples (including oil and concentrate samples) were one-
time grab samples taken once during each episode. These samples
were analyzed for the same pollutants as the wastewater samples
except that wet chemistry analyses were not performed on the oil
and concentrate samples. In addition, the solids (but not the
oil or concentrate samples) were analyzed for the following solid
wastes characteristics: flash point; soil pH; total residue;
total volatile residue; and total sulfide.
To estimate the leaching hazards posed by the soils-type of solid
wastes, the toxicity criteria leachate procedure (TCLP) was
applied to these solids. The extracts obtained from the soils by
TCLP were analyzed for all the pollutants on the ITD list (except
TCLP extracts were not analyzed for herbicides and pesticides at
Laundries A and B).
5.5 Sampling and Analytical Results
The results of the analyses of the raw waste and final effluent
streams at the five laundries sampled during the current ITD/RCRA
study are summarized in Tables 5-6 through 5-12. Schematics of
the waste treatment systems employed by each laundry are present-
ed in Figure 5-1 with all of the sample points indicated on the
schematic. Each table contains all the pollutants detected at a
single laundry and the concentration levels at which they were
detected in each wastewater stream and solids sample. Tables 5-
6, 5-7, 5-8, and 5-12 contain the results of analyses- of all
wastewater streams and solids samples obtained at Laundries A, B,
C, and E respectively. Table 5-9 contains the results of
analyses of water and wastewater samples at Laundry D. Table 5-
10 contains the results of analyses of solids and oils samples at
Laundry D. Table 5-11 presents the flow weighted average raw
waste pollutant concentrations for the combined wastewater
streams at Laundry D.
5,6 Analytical Data from Other Sources
Extensive monitoring data for industrial laundries exist, as many
POTWs enforce some discharge standards or at least require some
monitoring. Almost all standards and consequently monitoring,
however, are for some conventional and a few nonconventional
31
-------
LAUNDRY
B
SEWER
SEWER
SOMC ItOUALIM
ItTTLINa (AIIN
SEWER
SEWER
LEGEND
WASTEWATER SAMPLE
SOLIDS SAMPLE
OIL SAMPLE
ULTRAFILTER CONCENTRATE
FIGURE 5-1
SUMMARY OP TREATMENT
SYSTEMS AND SAMPLING POINTS
ITD/RCRA SAMPLING PROGRAM
32
-------
TABLE 5-6
SUMMARY OF REPORTED ANALYTICAL RESULTS
LAUNDRY A
Pollutant
Category
ted Pollutant
Vastevater (ut/t)
Raw Wastevate r
Day 1 Day 2
Treated wastevater
Day 1 Day 2
Solids
Thickened
Sludge
(UK/kg)
TCLP1
Extract
(pg/i)
Volatile Organic Compounds
toluene* 10,292
1,1,1-trichloroethane*
•etaylene chloride*
ethyl benzene*
acetone
Semi -volatile Organic Compounds
1,780
12,396 1,304
15,831 1,373,430
biphenyl 1,766
butyl benzyl phthalate*
di-n-butyl phthalate*
isophorone*
n-decane •• 3,481
n-docoaane 6,391 "
n-dodecane 3,362 2,141
n-eicosane
N-nitrosodi-n-propylaBiae* 14,945 3,773
n-tetracosane 8,351 1,379
n-tetradecane 18,615 11,212
naphthalene* " 12,963
p-cymene 3,464
2-chloronaphthalene* " "
4-chloro-3-nethylphenol*
alpha-terpineol
Pesticides /Herbicides
aldrin* 7. It
heptachlor* 24.2
etridazone 15t
azinphos ethyl 278
dioxatfaion 5'5
trifluralin
counophos
TEPP
BHC, alpha* ~ 10.4
phoinet "~ 28t
leptophos
Hetal*
calcium 11,000 14,000
•agaesiua 2,400 4,000
sodiuu 710,000 710,000
aluainua 1.9°° *,200
•antanese 1°° 250
lead* 1.300 4,200
vanadiua 7 10
boron 340 430
bariuai 460 MOO
beryllium* "" 2
cadaiuB* 31 72
•olybdenua 320 300
tin - 79
cobalt 80 200
chroniua* 470 780
copper* 990 2,300
iron 3,100 8,500
nickel* 67 99
titaniun 4* 130
zinc* 2,200 3,600
silver* 2.7 26
arsenic* 7.6 10
antimony* 20 20
•ercury* I »-J
2,032
2,574
4,212
2,207
3,797
7,491
65
28t
3.8t
451
18.2t
20,000
5,700
740,000
5,100
390
3,600
18
560
1,500
2
87
410
110
250
660
2,500
17,000
190
120
5,900
4.5
13
30
2.6
1,967
3,033
3,106
3,205
3,204
7,399
5,571
6,628
42t
lit
15,000
2,700
670,000
2,500
110
1,900
5
390
670
38
240
110
570
1,300
3,900
57
67
1,800
19
7.2
16
0.48
4,831
369
2,569
79
397
497
179
114
NA
HA
NA
NA
NA
NA
NA
NA
NA
NA
NA
90,200
1,950
2,490
2,040
179
1,560
929
36
89
67
178
124
1,030
6,700
39
60
1,560
4
31
67
1.6
116
912
33
48
35
93
56
67
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1,350
9,670
151,000
1,350
1,100
850
•k*
535
1,930
208
171
1,620
128
72
701
174
11,500
33
-------
TABLE 5-6 (cent.)
Pollutant
Category Raw
and Pollutant Day 1
Elements
iodine DET
iridium OET
potassium
phosphorus DET
platinun
sulfur DET
silicon DET
strontium
thallium*
tungsten DET
Cyanide
cyanide, total4 300
Other Pollutants
residue, filterable 3,000
residue, non-filterable 930
fluoride 39
anaemia, as N 1.22
nitrogen, Kjeldahl, total 12
nitrate-nitrite, as N 1.4
total phosphorus, as P 34
BOD-S Day (carbonaceous) 1,900
chemical oxygen demand 5,800
oil and grease,
total recoverable l,200c
total organic carbon 1,000
ml fide, total (iodonetric) 2.0c
Solid Waste Characteristics
flash point NA
pH, soil NA
residue, total NA
residue, total volatile NA
sulfide, total
(Homer-Williams) NA
Field Measurements
pH 11.3-11.6
temperature 30-33°C
conductivity(umho) 4400-4600
settleable solids l.Omi
flow (estimated) 0.1HGD
* Priority Pollutant
Indicates pollutant concentration
NA Indicates not analyzed
c Average of grab sample results
t Denotes tentative identification
1 Toxicity Characteristic Leaching
Vastewater (ut/£)
Wastewater Treated
Day 2 Day 1
DET DET
DET
DET
DET DET
DET
DET DET
DET DET
._
DET
DET
230 270
3,400 2,500
1,000 1,000
36 33
l.l1 2.8
35 15
1.5 0.42
36 33
1,800 360
4,900 2,900
840c 310c
1,100 filO
4.3c 4.3c
NA NA
NA NA
NA NA
NA NA
NA NA
11.0 9.9-10.3
32»C 28-32°C
4400-4600 4400-4600
<0.1 ml O.SmJt
0.1MGD 0.1HGD
below detection limit.
below the detection limit.
Procedure
2 Sample pH was not within range specified by analytical method
DET Indicates pollutant concentration
qualitatively detected.
Wastewater
Day 2
DET
-•
DET
DET
--
DET
DET
--
--
--
200
2,600
970
41
2.4
64
1.3
31
440
2,800
180c
620
4.1c
NA
NA
NA
NA
NA
8.5-9.5
32-34«C
4400-4600
1.1 m£
0. 1MCD
Solids
Thickened
Sludge
-------
TABLE 5-7
SUMMARY OF REPORTED ANALYTICAL RESULTS
LAUNDRY B
Pollutant
Cite gory
and Pollutant
Waitewater (m/i)
Raw Waatavater
Day 1 Day
Day I1
Treated Waatevater
Day 1* Day
Solid*
DAT
Sludge
TCLPZ
Extract
(pg/t)
Volatile Organic: Compound!
2-hexaaone
tetrachloroetaene* SB
toluene* 415
trans-1 ^-dichloroethene*
Mthylene chloride* 38
ethyl benzene* 103
acetone 493
Setti-volatile Organic Conpouadi
alpha-terpineol
butyl-benzyl pbtbalate*
di-n-butyl phthalate*'
indeno (1,2,3-CD) pyrene*
iaophorone* 40
n-decaae
bipheayl
n-docosine
a-dodecaoe
n-eicosane
n-hexacoaane
a-hexadecane 94
n-octadecan«
n-tetradecane
N-nitroaodi-n-propylaaiiae*
naphthalene*
nitrobenzene* 38
p-cymene
atyrene
2-chloroaaphtaalene*
2,6 dinitro toluene* ** '
3 , 3-dichlorobenzidine*
1,2:3,4 diepoxybutane
2-oetayloapnthalene 186
Pesticides /Herbicides
41
913
1.840
199
102
4,403
112
aldrin*
trifluralin
BHC, delta*
endosulfan aulfate^
etridazone
0.8
152
32
26
49
36
121
138
72
166
BHC, beta*
Dioxin»/Furana
2,3,7,8-TCDF
2,3,7,4-TCDD
HA
HA
HA
HA
l.St
4.It
2.2
NA
NA
121
l.St
HA
NA
69
140
240
741
16,003
96
663
* *
362
162
22
98
4,565
19
0.2
1.5
5.4t
7t
NA
NA
359
376
838
938
9,979
20,793
HA
NA
NA
NA
NA
NA
NA
28.27
Cng/kg)
18.62
33
55
17
24
_^
20
47
NA
NA
NA
NA
NA
NA
NA
NA
NA
35
-------
TABLE 5-7 (continued)
Pollutant
Category
and Pollutant
Wa«tew«ter (us/*)
Solids
Raw Uasteuater
Day 1 Day 2
Treated Wastevater
Day 1'Day I1 Day 2
DAF
Sludge
Extract
Metals
calcium
magnesium
sodium
aluminum
manganese
lead*
vanadium
boron
barium
beryllium*
cadmium*
molybdenum
tin
cobalt
chromium*
copper*
iron
nickel*
titanium
zinc*
silver*
arsenic*
antimony*
mercury*
Elements
iodine
indium
potassium
phosphorus
sulfur
selenium
silicon
strontium
thaIlium*
tungsten
168,000
35,000
249,000
10,400
1,090
2,850
44
568
1,560
2.3
66
202
234
345
835
2,610
634,000
320
213
6,250
37
12
60
1.3
293,000
5,080
279,000
1,496
105
651
9.1
594
281
--
26
73
31
71
464
548
6,140
57
40
1,450
8.5
<5
28
0.25
399,000
9,700
285,000
4,190
86
97
42
79
823
«
173
118
147
172
652
1,420
17,600
121
103
3,130
21
9.1
57
0.92
42,800
11,100
349,000
5,440
372
1,530
15
523
1,390
1.4
42
189
179
324
251
1,570
20,200
127
118
3,130
19
7.5
40
0.71
264,000
4,660
313,000
1,520
96
506
6.2
701
311
«
28
94
58
95
148
454
4,760
54
43
1,220
7.7
7.2
24
0.27
104,000
8,000
1,580
3,750
311
936
..
--
701
.-
31
160
159
148
218
1,080
19,599
102
88
2,070
49
3.6
14
1.3
4,930,000
27,800
144,000
2,110
1,760
--
..
179
116
--
__
155
..
1,340
119
..
5,200
398
..
4,880
-.
..
50
—
DET
DET
DET
DET
DET
DET
DET
DET
DET
DET
DET
DET
DET
DET
DET
DET
DET
DET
DET
DET
DET
DET
DET
DET
DET
DET
DET
DET
DET
DET
DET
DET
DET
DET
DET
DET
NA
DET
NA
DET
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
36
-------
TABLE 5-7 (continued)
Solidi
Pollutant
Wastewater (a*/ 1) DAF TCLP2
Category R»« Wastewater Treated Wastewater Sludge Extract
and Pollutant Day 1 Day 2 Day 1* Day I1 Day 2 (us/kg) (UR/i)
Cyanide
cyanide, total* 170
Other Pollutants
220 270 210 120 11 NA
residue, filterable 1,000
residue, non-filterable 1,100
fluoride 16
aaBonia, as N
nitrogen, Kjeldahl, total 16
nitrate-nitrite, a« N 1.2
total phosphorous, as P IS
BOD-5 Day (carbonaceous) 680
chenical oxygen demand 3,300
oil and grease,
total recoverable 410c
total organic carbon 470
sulfide, total (iodometric) 1.3c
Solid Waste Characteristics
flash point HA
pH, soil NA
residue, total HA
residue, total volatile NA
sulfide, total
(Monier-Williaos) NA
Field Measurements
2.200
200
14
13
0.35
6.7
390
1,600
140c
390
2.3c
NA
NA
NA
NA
NA
2.200
270
16
13
0.44
9.2
390
1,700
140c
820
3.1c
NA
NA
NA
NA
NA
1,800
740
23
14
0.21
26
1,500
4,800
650c
820
3.8c
NA
NA
NA
NA
NA
2,000
340
15
4.2
0.68
6.9
730
2,000
220c
340
3.4c
NA
NA
NA
NA
NA
NA
NA
NA
420
4,500
NA
NA
NA
NA
HA
NA
57«c
7.3
29%
571
1,lOOog/i
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
pH
temperature
conductivity (umho)
settleable solids
Flow (estimated)
9.2-9.7
36-37'C
1450-1770
1 mi
0.060HGD
6.9-7.8
34-37°C
2360-2900
4 mi
0.060MGD
9.2-9.6
37-40"C
1217-1960
0.5 m£
0.060KCD
7.7-8.2
36-408C
1965-2820
1 mi
0.060MGD
* Priority Pollutant
" Indicates pollutant concentration below detection limit.
NA Indicates not analyzed
c Average of grab saople results
t Denotes tentative identification below the detection limit.
1 Two sets of samples of treated effluent wastewater were collected and analyzed independently on day 1 for quality
control/quality assurance.
2 Toxicity Characteristic Leaching Procedure.
DET Indicates pollutant concentration qualitatively detected.
37
-------
TABLE 5-8
SUMHAKY OF REPORTED ANALYTICAL RESULTS
LAUNDRY C
Pollutant Procen
Category Water
and Pollutant (ug/i)
Volatile Organic Coapounda
•cetone
acrolein*
2-butanone
cblorobeazene*
di-n-butyl phthalate*
ethyl benzene*
iaobutyl alcohol
•ethylene chloride*
te t rachl oroethene*
to luene*
trans- 1,2-dicblorflethene*
1,1,1- trichloroetkaae*
vinyl acetate
Seai-volatile Orginlc Coapounji
bipheayl
bis(2-ethylhexyl) phthalate*
dipheaylaoioe
iaopttorone*
naphthalene*
n-decaoe
N-nitrosodipheayla*ine*
a-triacontaae
p-cymene
pheaanthreae*
Pesticides/Herbicide*
eodoiulfan sulfate
828
--
«
--
—
--
43
--
«
20
--
—
— •
...
--
«
«
--
--
—
—
—
—
..
Veitewater
Raw Wajtewater
Day 1 Day 2
1,701
«
«
--
«
--
138
21
314
233
—
--
14
..
--
--
«
— -
«
• •
--
--
-~
..
17.457
«
16,762
--
--
46
--
--
843
6,638
10
73
••
11
112
36
32
»*
*-
39
--
84
19
74
- (w«/4) Solid*
Treated
Day 1
1,701
«
--
49
—
--
—
--
14S
93
~
™-
__
1,900
•~
--
--
2,687
«
—
—
~*
.. •
Effluent
Day 2
1,116
601
—
—
—
—
—
--
645
914
22
192
•-
_.
129
23
25
25
--
—
224
14
-*
..
Sludge
621,909
~
«
--
--
10,909
4,000
--
50,455
650,727
5,818
«
2,091
..
850,909
--
--
-•
—
--
--
116,818
••
328
TCLP*
Extract
6,245
•-
«
--
20
165
85
-.
146
7,327
5,824
--
--
„_
17
--
--
--
• •
--
--
--
••
NA
Metals
calciua
Bijnesium
ilumnua
lead*-'
boron
barium
so lybdeouai
tin
cobalt
chromium1'
copper*
iron
nickel*
titauiuia
zinc*
jilver*
arsenic*
8.290T
1.420T
9,2SOT
--
--
..
--
-.
--
--
••
--
—
--
133
--
..
-.
--
..
..
«
23,400
7,250
1,310,000
6,730
343
970
242
762
57
»
47
--
185
1,290
19,700
152
227
3,920
--
.-
30
2.2
21,500
5,540
727,000
10,600
373
3,540
551
738
284
102
234
.-
223
1,630
28,900
176
270
4,610
--
15S
123
—
14,900
3,560
476,000
4,210
207
956
163
552
38
— -
43
--
136
902
13,400
88
156
2,440
—
— -
34
2.5
15,600
4.080R
527,000
3.930R
15 1R
2,890
160R
641
53R4
«
92R
--
104
564R
10,200
57Rd
113S
2,670
— •
--
76
—
12,800
4,040
29,400
5.020
396
989
«
639
30
--
232
--
227
1,340
34,500
296
326
2,420
6.0
17S
..
--
20,300
6,490
422,000
7,900
874
1,760
--
967
93
159
335
68
229
2.760
35,900
46
497
4,090
17
--
45
0.3
pbocphorua
tulfur
zircaaiua
tilicoa
J3ET
--
DET
DET
DET
DET
DET
DET
DET
DET
DET
DET
DET
DCT
DET
DCT
DET
DET
DET
DET
DET
DET
DET
DET
NA
HA
NA
NA
MA
NA
38
-------
TABLE 5-8 (coat.)
Pollutant
Category
and Pollutant
stroatiua
lithium
tungsten
omm.ua
Cyaoide
cyanide, total*
Other Pollutants
residue, filterable
residue, non-filterable
fluoride
asnonia, it N
nitrogen, Kjeldafal, total
nitrate-nitrite, as N
total phosphorous, as P
BOD- 5 Day (carbonaceous)
chemical oxygen demand
oil and grease,
total recoverable
total organic carbon
aulfide, total (iodoatetric)
Solid Waste Characteristics
flasb point
pK, soil
residue, total
residue, total volatile
sulfide, total
(Honier-Williams)
corrosivity
Field Measurements
temperature
pH
settleable Solids
flow (estimated)
Process
Water
(p*/i)
__
"
.-
~~
--
—
—
--
••
--
--
--
"
"
--
--
--
NA
NA
NA
NA
HA
NA
NA
NA
NA
Wastewater -
&aw Vaitewater
Day 1 Day 2
DET
DET
..
--
17
A, BOO
760
13
••
IS
0.41
45
800
4,800
920c
710
5.6c
NA
NA
NA
NA
KA
NA
26-27°C
10.3-12.2
5.5«g/JZ
DET
DET
--
--
0.160
2,600
930b
20
--
14
0.48
38
900
6,100
140c
520
5.9c
NA
NA
NA
NA
NA
NA
24-26°C
10.5-11.9
0.7ag/2
(pR/i)
Treated Effluent
Day 1 Day 2
DET
DET
«
DET
0.810
2,300
400
10
--
13
0.56
22
720
3,400
470c
370
3.2c
NA
NA
NA
NA
NA
NA
15-27"C
10,3-11,6
0.4ag/£
0.040MGD
DET
DET
..
--
2.1
2,000
140
12
..
13
0.32
46
290
2,300
460c
420
2.2c
NA
NA
NA
NA
NA
NA
22-24°C
11.5
O.lmg/4
0.040HGD
Solids
TCLP1
Sludge Extract
(lit/kg) (UR/£)
DET
..
--
--
6.6
HA
NA
NA
7.0
48**
0.62
NA
NA
NA
HA
NA
NA
60°C
10.2
11,000
5,300
10
--
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
-- Indicates pollutant concentration below detection linit.
MA Indicates not analyzed.
DET Indicates pollutant concentration qualitatively detected.
* Priority pollutant.
** tfean of 5 replicate analyses.
b Analysis performed after expiration of analytical "hold-ti«e".
c Average of grab taaple results.
d Indicates duplicate analysis not within control liait.
R Indicates spike recovery not within control liaut.
S Indicates value determined by Method of Standard Addition.
1 Toxicity Characteristic Leaching Procecure
39
-------
TABLE 5-9
SUMMARY OF REPORTED ANALYTICAL RESULTS
WATER AND WASTEWATER SAMPLES
LAUNDRY D
Uniform Washer* Wasewater
Shop Towel Washers Waatewater (MS/*)
Pollutant
Category Proceaa
and Water
Pollutant (|ig./<)
Volatile Organic Coaipounda
acetone
acrolein*
benzene*
broawdichloroM thane*
carbon tetrachloride*
cblorehenzene*
chloroform*
dibroMochloroaethane*
ethylbenzene*
•ethacrylonitrlle
•ethylene chloride*
p-dioxane
tetrachloroethene*
toluene*
trana-1.2-dlchloroethene*
tricbloroethene*
1.1-dichloroethane*
1.1-dichloroethene*
1.1,1-tricbloroethane*
1 , 1 ,2 , 2-tetrachloroethine*
2-butanone
2-chloroetbylvinyl ether*
4-Mthyl-2-pentanooe
Se«i-»olaCile Organic Conpounda
alpha terplneol
anthracene*
beazidloe*
bia(2-ethyhexyl)pbthalate*
dl-n-butyl phthalate*
di-n-octyl phthalate*
diawthyl phthalate*
diphenylaaiine
Raw Uastewater
Day 1
141
—
«
—
--
—
— -
--
--
--
1,165
--
92
136
--
«
--
--
—
—
• •
--
580
—
~~
1.040
—
—
—
—
Day 2
61
—
«
--
.-
»
«
-.
--
«
902
--
—
--
«
--
33
--
--
--
«
«
--
..
--
.-
--
•-
29
--
--
Treated Effluent
Day 1
635
1.406
--
—
--
—
—
--
162
—
937
--
351
3.933
--
--
—
--
64
--
—
--
—
1,789
—
--
1.040
--
—
—
--
Day 2
1.079
—
--
—
--
—
--
--
38
--
113
--
66
383
--
--
«
—
47
--
—
--
--
..
..
--
—
..
—
--
—
Raw Uastewater
Day 1
»_
—
--
--
--
—
—
—
36.031
--
39.933
--
55.516
--
713
--
--
1,087
38,331
--
--
"
*-
16,798
--
22,436
9,441
--
—
--
—
Day 2
1.466
—
--
—
--
142
«
«
638
—
32
-•
3.403
11,594
--
64
--
—
691
--
«
108
--
..
--
.-
—
«
--
—
—
Strainer Effluent
Day 1
_.
-~
--
--
--
--
«
-.
1,301
--
5,152
--
2.369
70,742
--
--
«
123
2,323
--
89.429
--
385
21,274
— .
..
9.155
--
—
--
—
Day 2
1,785
— •
--
«
--
202
—
--
1,174
--
28
•-
2,615
7,116
«
57
»
«
934
«
590
23
--
..
..
..
--
--
—
--
—
Treated Effluent
Day 1
-—
—
--
—
--
«
«
--
49
--
887
--
695
1,623
--
--
»
~
375
«
9,294
--
--
727
--
--
—
«
«
13
22
Day 2
16,847
--
--
-.
--
--
--
--
«
--
555
-•
576
2,861
~
--
--
—
540
--
8.124
--
--
..
.-
..
«
«
--
--
—
iiopborone*
n-decane
n-dodecane
n-hexacoiane
488
168
30,652
1.131
203
-------
TABLE 5-9 (continued)
Unitoca Waihtri tfaaewater (pg/t)
Pollutant
Category
and
Pollutant
n-bexadecaoe
N-nitrocodiphenylaauae*
n-octadecaae
•-tetrad«caoe
naphthalene*
o-creiol
p-cynenc
Proceai
Water
--
Ran
Day 1
316
688
Uaatevater
Day 2
29
Treated
Day 1
209
753
253
Effluent
Day 2
--
Raw
Day 1
5,025
8.111
Wastewater
Day 2
17,456
22,089
Strainer
Day 1
4,673
7,601
Effluent
Day 2
21,280
Treated
Day 1
22
400
Effluent
Day 2
254
pheaaathreoe*
ttyreae
1,2-dlchl«roben2eoe*
2-chloronaphthalene*
2,4-dlchlorophenol*
4-chloro-3-*ethyl phenol*
Pettlctdei/Herbic idea
cudoaulfan Sulfate*
heptacbtor*
tetrachlorovinpho*
dloxathioa
leptophoi
ehlorpyrophon actayl
EPH
coiauphoi
phoiact
axinpboa Betliyl
cblorfeavinphoa
crotoxypbof
aaled
Metal»
288
1,067
969
16
HA
NA
HA
MA
NA
MA
NA
NA
NA
HA
NA
HA
NA
1,397
2,524
436
3,563
b
b
NA
2,152
5,529
b
b
NA
NA
b
b
2,898
1,344
6,874
374
—
--
--
--
19,400
—
--
--
72
^_
3,010
36
9,000
806
—
55$
254
47,400
436
73
2,060
63,600
2,620
13.200
880
9,210
943
5
799
105
46,500
268
50
1,470
24,100
1.460
13,400
431
6,550
745
..
635
91
36,800
173
53
1,150
18,500
1,420
9,600
393
6,680
818
-*
557
97
37,300
200
--
1,340
17,300
1,750
10,100
333
19,300
4,480
.._
1,740
856
62,000
1,170
795
9,070
114,000
20,500
18.500
1.950
11,300
2,620
„_
819
365
43,800
815
319
7,690
65,600
15.400
10.300
1,210
17,500
4,10011
»_
I.680R
814
6S.OOOR
1.240
94 1R
10.300
90.400T
19.600
18.300
2,000
1.417
NA
NA
HA
HA
HA
NA
NA
NA
HA
NA
NA
HA
NA
21,500
5,230
6
1,100
786
73,500
1.410
630
29,000
164,000
24,200
20,500
2,300
12
25
109
773
58
1,880
II
8,840
243
112
1,060
407
313
478
664
1,210
7,180
173
83
792
324
-------
TABLE 5-9 (continued)
Uniform Washers Wasewater (pg/1)
Shop Towel Washers Wastewater (pg/t)
S3
Pollutant
Category
and
Pollutant
•olybdenuB
nickel*
sodiuai
tin
titaniusi
vanadiusi
yttriua
zinc*
antisnny*
arsenic*
•ercury*
seleniuB*
silver*
tballius*
Elements
iodine
iridiusi
lanthanus)
lithius.
phosphorus
potassium
silicon
strontiua
sulfur
tungsten
zlrconiuai
Cyanide
cyanide, total*
Process
Water
(US/*)
-..
—
13.000
—
—
—
—
294
—
—
—
--
—
—
—
—
—
«
DET
—
DET
«
—
--
—
HA
Raw
Day I
190
868
175,000
274
242
—
—
5,020
108
1U
2.6
—
48
--
DET
--
--
--
DET
DET
DET
DET
DET
--
—
--
Wastewater
Day 2
100
227
106,000
91
323
SB
—
5,450
28s*
—
3.6
--
35
—
DET
—
—
«
DET
DET
DET
DET
DET
--
--
--
Treated
Day 1
149
173
202,000
72
232
—
—
3,870
91
—
3.3
—
45
—
DET
—
—
—
DET
DET
DET
DET
DET
—
—
37
Effluent
Day 2
_..
152
186,000
--
188
91
—
4,200
91
—
2.5
—
24
—
DET
—
--
--
DET
DET
DET
DET
DET
—
—
41
Raw
Day 1
1,270
1,610
723,000
536
574
113
—
13.100
213
17
3.5
—
877
--
DET
DET
—
DET
DET
DET
DET
DET
DET
DET
—
110
Wastewater
Day 2
369
693
827,000
808
244
56
..
9,480
369
--
--
—
46
--
DET
DET
..
DET
DET
DET
DET
DET
DET
—
--
130
Strainer
Day 1
1.140R
1,660
647,000
521
472
106R
—
13,100
205
2.5
—
732
DET
DET
--
DET
DET
DET
DET
DET
DET
DET
--
92
Effluent
Day 2
699
1.560
805.000
1,410
473
178
....
17,900
633
25
3.2
_,
24
DET
DET
....
DET
DET
DET
DET
DET
DET
DET
130
Treated
Day 1
253
82
787,000
..
..
..
...
137
281
..
...
„_
--
DET
__
DET
DET
DET
DET
__
DET
DET
200
Effluent
Day 2
439
85
651,000
.,
__
_.
_ .
76
179
,„
..
_..
—
DET
• V
DET
DET
DET
DET
DET
DET
280
-------
TABLE 5-9 (continued)
Uniform Washers Wagtewater (mg/l)
Shop Towel Washers Uastewater (mg/t)
Pollutant
Category Process
aad Water
Pollutant (MR/0
Other Pollutants
residue, filterable
residue, non-filterable
fluoride
ammonia, as N
nitrogen, kjeldahl, total
nitrate-nitrite, as N
total phosphorus, as P
BOD-S day (carbonaceous')
chemical oxygen demand
oil and grease
total recoverable
total organic carbon
sulfide, total (iodoswtric)
Solid Waste Characteristics
flash point
PH. soil
residue, total
residue,: total volatile
sulCide, total
(Monier-vllliams)
corrosivitjr
Field Measurements
temperature
pM
settleable Solids
flow (estimated)
NA
NA
NA
NA
HA
HA
NA
NA
NA
NA
NA
NA
NA
NA
MA
NA
HA
NA
NA
NA
NA
Raw Wastewater
Day 1
1,300
770
13
1.7
71
0.82
7.S
540
3,000
240**
280
—
NA
NA
HA
HA
NA
NA
36-40eC
9.1-11.1
2.7 mt/t
Day 2
1.900
490
15
1.4
17
0.70
73
610
3.600
260**
410
3.1**
NA
NA
NA
NA
NA
NA
20-45°C
9.5-11.5
0.6 mt/t
Treated Effluent
Day I
1,400
620
14
1.2
1.5
0.41
32
670
3,000
4,800**
290
--
NA
NA
NA
NA
NA
NA
25-36°C
9.0-11.2
0.4 mt/t
29,200 GPD
Day 2
1,500
500
22
-•
10
0.62
36
420
3.300
570**
290
5.8**
NA
NA
NA
NA
NA
NA
27-40°C
10.2-11.5
0.5 mtft
Raw Wastewater
Day 1
2,000
4,700
2.8
1.9
5.0
0.47
1.9
2,200
10,000
4,500**
750
NR
HA
NA
NA
NA
NA
NA
25-36°C
10.1-10.6
8.0 mill
Strainer
Day 2 Day 1
11,000 1
4,200 7
NR
—
4.2
,100
,000
1.6
—
<20*
1.4 0.83
7.0
2,900 >1
11.000 17
7,700** 3
1.200
5.8**
NA
NA
NA
NA
NA
NA
21-45°C
9.8-11.9
1.0 mt/t
8.5
,400'
,000
,100**
780
1.9**
NA
NA
NA
NA
HA
NA
24-39°C
8. 0-10. 5
3 ml/ 1
Effluent
Day 2
8,800
24,000
NR
--
2.6
0.34
7.8
3,900
7,200
2,800**
690
4.3**
NA
NA
NA
NA
HA
KA
22-45°C
9.7-12.0
-.
Treated Effluent
Day 1
2,600
23
15
--
13
0.72
24
770
1,900
8.6*
500
1.5**
NA
MA
NA
NA
NA
MA
34»C
10.1-11.0
--
11,700 GPD
Day 2
2,500
16
3.1
--
10
0.43
20
1,000
2,000
76**
480
3.3**
NA
NA
NA
NA
NA
MA
32-36°C
11. 1-12.2
.-
* Priority pollutant
— Indicates pollutant concentration below detection limit
** Composite of results for 3 grab samples
NA Indicates not analyzed
NR Ho data reported due to matrix interference
*** Low bias indicated based on recovery of sulfide standard analyzed concurrently with sample
1 Seed inhibition indicated
2 Oxygen depletion exceeded limiting value of 1 mg/C during incubation. BOD5 result calculated from limiting value
a Estimated long-term average
S Indicates value determined by Method of Standard Addition
» Indicates the correlation coefficient for Method of Standard Addition is less than 0.995
R Indicates spike recovery is not within control limits
T Indicates duplicate analysis is not within control limits
b Indicates compound was found above the detection limit, but the analysis could not be confirmed. The results may be found in the Appendix.
-------
TABLE 5-10
SUMMARY OF REPORTED ANALYTICAL RESULTS
SOLIDS AND OILS SAMPLES
LAUNDRY D
Uoifon Washers
Shop Towel Washer*
Pollutant
Category
and
Pollutant
1st Settling Basin
Solids TCLP
(M/kg) (pg/l)
Shaker Screen 2nd Settling Basin
Solids TCLP Solids TCLP
(jJg/kg) (Mg/') (tig/kg) (HE/*)
Disc Strainer
Solids TCLP
Volatile Organic Compounds
•cetone 2,900 70S
acrolein*
benzene*
broDodichloroaethane*
carbon tetrachlocide* -- -- 122
chlorobenzene*
calorofora*
dibroaoch1oro*etbane*
ethylbenzene* — -- 104
•ethacrylonitrile
•ethyleae chloride* 100 59 396
p-dioxane
tetracbloroethene* 1,535 20 196
toluene* 869 38 U
trani-l,2-dichloroelhene*
trichloroethene*
1,1-dlchloroethaoe* W
1,1-dichloroethene*
1,1,1-Uichloroethane*
1,1,2,2-tetrachlocoethane*
2-butanone -- 56
2-chloroethylvlnyl ether*
(-•ethyl-2-peotaaoae
Se«i-vclatile Organic Coapoundi
alpha terpioeol
anthracene* -- -- J.OJ9
benzidine*
bii(2-ethyhexy1)phtha1ate*
dl-o-butyl phthalite* — — 13.987
di-n-octyl phthalate*
diaetbyl phthalate* — -- 3,191
diphenylasiine
isopborone*
n-decane
n-dodecane
n-hexacosane — -- 40,135
179 1.772
1,298
1,314
26
72
97
63
22
78
30
169
22
25
78
231
29,995
5,579
192
62
136
44
1,660
425
101
71
31
20,881
13
10.374
17,852
—
--
—
..
—
6,233
--
838
—
117,868
92,109
1,138
--
2,531
36,041
— •
69
22
118
142
IS
64,950
109
7,119
75,785
1,620,900
518,720
116
153
15,794
153,681
343
222,110
146,470
241,880
140,330
1,618,540
496,320
HA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
HA
NA
HA
HA
NA
KA
KA
NA
NA
NA
NA
NA
NA
NA
NA
NA
-------
TABLE S-IO (continued)
Unifom Washers
Shop Touel Washers
ui
Pollutant
Category
and
Pollutant
1st Settling Basin
Solids TCLP
(Mg/kg) (Mg/t)
Shaker Screen
Solids TCLP
(ME/kg) (MK/O
2nd Settling Basin
Solids TCLP
(MR/kg) (Mg/t)
Disc Strainer
Solids TCLP
(M8/kg) (pg/i)
Oil
Ski— er
Oil
(PR/**)
Ultrafilter
Concentrate
TCtP
n-hexadecane
N-oitrosodiphenylaanne*
n-octadecane
o-tetradecane
naphthalene*
o-cresol
p-cyaeae
phenanthrene*
ttyrene
1,2-dichlorobenzene*
2-chloronaphthalene*
2,4-dichlorophenol*
4-chloro-3-«et.hyl phenol*
Peiticidet/HerbtciJti
endosulfaa tulfate
heptachlor
tetrachlorovinphoi
dioxathion
leptophos
chlorpyropho* Dethyl
EPN
couaopboi
pbotawt
azinpbos aMthyl
chlorfenvinphot
crotoxyphoi
naled
HetaU
aluaiinua
bariiw
berylluai*
boroa
eadaiua*
calciuai
chroaiua*
cobalt
copper*
iron
lead*
•agnesiu*
•anganese
2S.330
3S.813
4,378
3.122
19
HA
NA
NA
NA
MA
NA
NA
NA
NA
NA
NA
NA
HA
2,378
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
8.867
22.241
17,168
NA
NA
NA
NA
NA
NA
HA
NA
NA
NA
NA
NA
HA
452,000
1,090
9
225
106
140,000
4,780
309
53,200
921,000
4,770
59,900
3,420
671
599
--
--
491
180,000
39
183
170
280,000
137
4,640
3,860
14,200
177
6
21
13
13,300
325
25
5,080
36,800
640
5,550
329
1.180
651
--
342
139
83,300
75
78
398
56.700
457
4.350
1,080
7.590
572R
1
4SR
99T
22,300
372T
59R
2,550
57.200T
1,100
8,450
460
3,040
1,490
—
736
559
395 ,000
29T
483
180T
99 , 100
1.200T
la.ooor
3,810
16,900
331
8
57
79
8,380
923
153
8,790
83,900
1,700
3,900
606
292
1,110
..
649
584
132,000
70
590
88
359,000
1,140
5,860
4,210
217.380
114,800 147,790
110,120
1,239
22,671
825
1,065
1,921
NA
NA
NA
NA
HA
NA
MA
NA
NA
HA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1,860
277
24
105
7,190
216
79
3,550
15,600
6,930
1,880
215
1.350
340
-.
• 68
5.020
38
36
520
4,400
2,890
1.500
130
1,250
4,640
2,190
725
97,100
23
396
1,060
1,650
5.J50
14,300
1,760
-------
TABLE S-10 (continued)
Unifora Washers
Shop Towel Washer*
Pollutant
Category
and
Pollutant
BMlybdenusi
nickel*
sodium
tin
titanium
vanadium
yttrium
zinc*
antimony*
arsenic*
mercury*
selenium*
silver*
thallium*
Element*
iodine
iridium
lanthanum
lithium
phosphorus
potassium
silicon
strtntium
sulfer
tungsten
zirconium
Cyanide
cyanide, total*
1st Settling Basin
Solids
(Mg/kg)
561
4.150
5,380 1
997
2,070
239
45
12,600
44
2S
0.5
1
417
•—
— ^
DET
--
—
DET
«
DET
DET
DET
--
--
2,200
TCLP
..
1,240
,390,000
--
--
--
—
15,700
—
--
—
--
—
-•
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Shaker
Solids
(Mg/kg)
40
225
646
303
160
22
—
1,520
16
5St
--
"
17
--
__
DET
—
--
DET
—
DET
DET
DET
--
•-
—
Screen
TCLP
(nit)
313
1,320,000
«
—
--
—
5,990
—
—
0.3
—
—
—
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
2nd Settling
Solids
(Mg/kg)
9BR
541
996 1,
154
417
243T
7
2,090
23R
—
1.1
2T
145
--
DET
DET
DET
--
DET
--
DET
DET
DET
DET
DET
—
Basin
TCLP
__
2,900
380,000
--
--
--
—
20,200
—
—
—
—
—
--
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Disc
Solids
(Mg/kg)
254
1,120
2,140
248
184
60
7
3,110
34
--
0.9
1
85
--
__
DET
—
--
DET
--
DET
DET
DET
DET
--
3,100
Strainer
TCLP
(Mg/0
2,080
1,440,000
--
—
«
—
22,600
22S*
—
--
_,
--
--
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Oil
Skiamer
Oil
(Mg/kg)
179
279
3,580
101
72
14
3
3,440
312
—
--
—
40.3
--
__
DET
—
--
DET
--
DET
--
DET
—
-•
NA
Ultrafilter
Concentrate
TCLP
(Mg/kg) (Mg/D
44
43
3,570 1,740
46
42
--
--
1 ,480 2
41
--
0.1
3T
8.0
— '
_ ^
..
-.
—
DET
«
DET
DET
DET
—
•-
600
__
466
,000
--
—
--
—
,180
40
—
—
--
--
—
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
-------
TABE.E 5-10 (continued)
tin if on Washers
Shop Tovel Washers
Pollutant
Category 1st Settling Basin
Shaker Screen
and Solids TCLP Solids
Pollutant (ng/kg) (ng/t)
Other Pollutants
residue, filterable NA HA
residue, non-filterable NA NA
fluoride NA NA
ammonia, as H -- NA
bitrogen, kjeldabl. total 1,100 NA
nitrate-nitrite, as K 1.1 HA
total phosphorus, as P NA NA
BOIHS day (carbonaceous) NA HA
chemical oxygen denand NA t)A
oil and grease
total recoverable NA NA
total organic carbon NA NA
tulfide, total (iodometric) NA NA
Solid Waste Characteristics
flat* point. 31'C Hfc
pH, «oil 8.8 HA
residue, total 491 NA
residue, total volatile 3.9* NA
tulfide, total
(Honier-Williaaw) 110*** MA
corrosivity -- HA
Field Measurement*
temperature NA NA
pH NA NA
settleable Solids NA NA
* Priority
(«g/kg)
NA
HA
NA
120
3,900
It. I
HA
NA
NA
NA
NA
NA
we
8.1
231
201
87
—
HA
HA
HA
TCLP
(.8/0
HA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
HA
HA
NA
NA
NA
HA
NA
NA
NA
NA
2nd Settling
Solids
(«g/kg)
HA
NA
NA
830
4,200
S.5
NA
NA
NA
NA
NA
NA
30-C
7.5
32J
311
330
--
NA
HA
NA
Basin
TCLP
(mg/t)
NA
NA
NA
HA
HA
NA
NA
NA
NA
NA
HA
NA
HA
NA
NA
NA
NA
HA
HA
HA
HA
Disc Strainer
Solids
(mjt/kg)
HA
NA
NA
--
1,600
5.5
NA
NA
HA
NA
NA
NA
S2«C
9.9
391
26X
150***
HA
NA
NA
TCLP
(ng/l)
NA
HA
NA
HA
HA
HA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Oil
Skimmer
Oil
(ng/kg)
NA
NA
NA
NA
NA
NA
HA
HA
NA
NA
NA
NA
HA
HA
HA
HA
HA
HA
NA
NA
HA
Ultrafilter
Concentrate
(mg/kg)
1.300
SB. 000
KR
33
HR
0.87
NR
>23,000J
(40,000
29,000
HR
NR
NA
NA
NA
KA
HA
HA
31°C
11.8
NA
TCLP
HA
NA
NA
NA
KA
NA
NA
HA
NA
NA
HA
NA
NA
NA
NA
NA
NA
NA
HA
NA
NA
Indicates pollutaat concentration below detection linit
** Composite of ces«lt* for 3 grab sample*
HA Indicates not analyzed
HR Ho data reported due to matrix interference
*** Low bits indicated based
-------
TABLE 5-11
SUMMARY OF AVERAGE RAW
WASTE CONCENTRATIONS FOR COMBINED UNIFORM WASHERS AND
TOWEL WASHERS WASTEWATER STREAMS AT LAUNDRY D
Pollutant Category
and Pollutant
Combined Average Raw Waste Load1
Day 1 Day 2
Volatile Organic Compounds
acetone
chlorobenzene*
ethylbenzene*
raethylene chloride*
tetrachloroethene*
toluene*
trans- 1 , 2-dichloroethene*
trichloroethene*
1 , 1-dichloroethane*
1, 1-dichloroethene*
1,1, 1-trichloroe thane*
2-chloroethylvinyl ether*
Semi-volatile Organic Compounds
alpha- terpineol
benzidine*
bis (2-ethylhexyl)phthalate*
di-n-octyl phthalate*
n-decane
n-hexadecane
n-octadecane
n-tetradecane
naphthalene*
p-cymene
2-chloronaphthalene*
Pesticides /Herbicides
endosulfan sulfate*
tetrachlorovinphos
EPN
Metals
aluminum
barium
beryllium*
boron
cadmium*
calcium
chromium*
cobalt
copper*
101
--
10,307
12,255
15,947
97
204
--
—
311
10,965
--
5,219
6,418
3,443
--
9,117
—
226
—
1,929
2,320
206
1,377
692
1,582
6,164
1,857
—
894
426
51,577
646
280
4,065
463
41
183
653
973
3,317
--
18
24
— —
198
31
—
• •»
«••
21
*""
4,994
6,319
21
~~
** •
—
--
9,808
1,423
4
805
179
45,728
424
127
3,249
-------
TABLE 5-11 (continued)
Pollutant Category
and Pollutant
Combined Average Raw Waste Load1
Day 1 Day 2
iron
lead*
magnesium
manganese
molybdenum
nickel*
sodium
tin
titanium
vanadium
zinc*
antimony*
arsenic*
mercury*
selenium*
silver*
78,018
2,457
14,716
1,186
499
1,080
331,763
349
337
32
7,331
138
87
2.9
251
34
35,972
5,448
12,513
654
177
360
312,252
296
300
57
6,603
126
--
2.6
--
38
Cyanide
cyanide, total*
Other Pollutants
residue, filterable
residue, non-filterable
fluoride
ammonia, as N
nitrogen, kjeldahl, total
nitrate-nitrite, as N
total phosphorus, as P
BOD-5 day (carbonaceous)
chemical oxygen demand
oil and grease
total recoverable
total organic carbon
sulfide, total (iodometric)
0.031
(mg/£)
1,500
1,894
10
1.8
52
0.72
5.9
1,015
5,002
1,459
414
m
0.037
(mg/2)
4,503
1,551
NR
1.0
13
0.90
54
1,265
5,719
2,388
636
3.9
1 These values are flow weighted average pollutant concentrations based on the
concentrations listed in Table 5-12 for uniform washers stream and towel washers
stream and the long-term average flows for each stream. The uniform washers stream
flow equals 29,200 GPD and the towel washers stream flow equals 11,700 GPD. The
combined average raw wasteload concentration for Pollutant A is given by the
formula:
(concentration A - Uniforms)(29.200)+(concentration A - towels)(11.700)
40,900
* Priority Pollutant
49
-------
TABLE 5-12
ITD/RCRA SAMPLING PROGRAM
SUMMARY OF REPORTED ANALYTICAL RESULTS
PLANT E
Pollutant
Category
and Pollutant
Final
Effluent
(MS/*)
Volatile Organic Compounds
acetone
chloroform*
ethylbenzene*
tetrachloroethene*
toluene*
trichloroethene*
1,1,1-trichloroethane*
2-butanone
Semi-Volatile Organic Compounds
bis (2-ethylhexyl) phthalate*
isophorone*
n-decane
n-dodecane
n-eicosane
n-hexadecane
n-octadecane
n-tetradecane
naphthalene*
Metals
antimony*
arsenic*
cadmium*
chromium*
copper*
lead*
mercury*
zinc*
barium
lithium
iron
nickel
strontium
Cyanide
cyanide, total*
Conventional Pollutants
residue, non-filterable
BOD-5 Day (carbonaceous)
Nonconventional Pollutants
chemical oxygen demand
fluoride
nitrate-nitrite, as N
total organic carbon
ammonia, as N
0.04c
1542
10
177
213
548
15
478
427
1192
690
394
180
159
162
115
85
40
121
5
25
261
487
400
0.8
1960
429
26
13,000
106
420
464
222
1,520
1.2
0.27
353
1.02
* Priority pollutant
c Average of grab sample results
50
-------
TABLE 5-13
SUMMARY OF POLLUTANT CONCENTRATIONS
IN INDUSTRIAL LAUNDRY WASTEWATERS
OBTAINED FROM
THE MASSACHUSETTS WATER RESOURCES AUTHORITY
Pollutant
Organics
1,1, 1-trichloroethane*
ethylbenzene*
methylene chloride*
naphthalene*
N-nitrosodiphenylamine*
bis(2-cthylhexyl)
phthalate*
butyl benzyl phthalate*
di-n-butyl phthalate*
tetrachloroethene*
toluene*
acetone
benzyl alcohol
benzole acid
petroleum hydrocarbons
2-methylnaphthelene
phenanthrene*
chlorobenzene*
chloroform*
trans-l,2-dichloroethene*
Metals
aluminum
antimony*
arsenic*
cadmium*
chromium*
chromium(+6)
copper*
lead*
mercury*
nickel*
selenium*
silver*
zinc*
Conventional Pollutants
residue, nonfilterable
BOD-5 day
oil & grease
Nonconventional Pollutants
Number1
3/2
9/5
2/1
6/4
3.2
9/5
7/4
6/3
7/6
7/6
3/2
2/2
1/1
10/4
6/4
2/2
2/2
1/1
1/1
4/1
3/2
3/2
9/3
10/4
2/1
11.4
11/4
7/4
9.4
3/2
1/1
11/4
10/6
11/5
15/6
Maximum
Concentration
(mg/A)
0.30
6.000
1.4
0.75
0.30
42.00
0.280
0.590
90.0
24
4.4
0.53
0.022
600.000
0.200
0.020
5.30
0.01
0.08
0.0092
0.047
0.055
0.120
0.39
0.9
4.20
2.30
0.0086
0.190
0.024
0.030
7.40
944
2610
1800
Median
Concentration
(mi?/*)
0.021
1.05
0.075
0.26
0.100
1.10
0.14
0.155
0.070
1.90
0.76
0.53
0.022
87.000
0.058
0.015
2.80
0.01
0.08
0.006
0.006
0.012
0.020
0.071
0.49
0.060
0.48
0.00040
0.080
0.006
0.030
1.40
205
501
419
Mean
Concentration
Cm*/*)
0.11
1.950
0.075
0.33
0.146
1.460
0.141
0.197
13.7
5.16
1.89
0.53
0.022
152.000
0.092
0.015
2.80
0.01
0.08
0.006
0.019
0.025
0.036
0.127
0.49
0.086
0.690
0.0016
0.095
0.011
0.030
1.95
338
623
542
volatile solids
5/4
1070
493
643
Ratio indicates the number of samples in which the specific pollutant was
found compared to the total number of facilities at which pollutant
was detected.
51
-------
TABLE 5-14
SUMMARY Of REPORTED ANALYTICAL RESULTS
FROM THREE LAUNDRIES DISCHARGING TO
A NEW YORK "STATE POTW
Found at
Pollutant No. of
Parameter Facilities
benzene*
toluene*
xylenes
methylene chloride*
chloroform*
1,1,1 trichloroethane*
trichloroe thene
tetrachloroethene*
3
2
3
2
2
2
2
2
Found in No
of samples1
4/6
4/6
5/6
3/6
3/6
2/6
2/6
3/6
Range
Cu*/2)
170-4400
200-9000
200-4000
200-1050
30-900
20-50
5-100
250-1200
Average
(MR/2)
2040
3900
2460
830
360
35
53
590-
*Priority pollutant
1Ratio indicates the number of samples in which pollutant was found to the
total number of samples analyzed. Two samples were analyzed per facility.
52
-------
TABLE 5-15
SUMMARY OF POLLUTANT CONCENTRATIONS
FOUND IN INDUSTRIAL AND COMMERCIAL LAUNDRY
WASTEWATERS OBTAINED FROM STATE
AND LOCAL SOURCES1
Pollutant
antimony*
arsenic*
cadmium*
chromium*
copper*
cumene
cyanide*
lead*
mercury*
n-butyl alcohol
nickel*
phenol*
selenium*
silver*
xylene
zinc*
flow (MGD)
Number
of
Samples
7
4
19
15
22
1
4
37
9
1
19
7
3
8
2
24
17
Average
(MR/A)
9.4
1.7
73.8
311.5
675.4
50.0
235.7
1059.4
4673.3
275.0
181.6
8115.7
5.0
19.7
275.0
1629.3
0.0305
Minimum
Value
(M8/A)
1.0
1.0
8.0
3.0
40.0
50.0
10.0
50.0
290.0
275.0
30.0
100.0
3.0
3.0
50.0
100.0
0.005
Maximum
Value
(MS/A)
24.0
2.0
427.0
1400.0
3560.0
50.0
900.0
6600.0
32300.0
275.0
950.0
24800.0
8.0
86.0
500.0
10000.0
0.085
1 Source of data: Appendix I of The Domestic Sewage Study.
53
-------
pollutants and a small number of common, toxic metals. Some
POTWs are beginning to recognize the possibility that organic
pollutants may cause problems, but as yet most are unwilling to
incur the expense of a complete analyses for all priority
pollutants. Nonetheless, some organics data have been obtained
from local sources, however. The Massachusetts Water Resources
Authority (MWRA) has required extensive sampling and analyses of
wastewater discharged to its sewers by industrial users. MWRA
has had the effluent from five industrial laundries within its
jurisdiction analyzed for the entire list of priority pollutants
plus some classical pollutants. The sampling occurred between
April 1982 and November 1985, and appears to include most but not
all of the major dischargers (more than 10,000 gallons per day).
No data have been obtained for a number of laundries, most of
which are apparently minor dischargers. A limited amount of data
was obtained for one small laundry. Analyses have been obtained
for six industrial laundries and are summarized in Table 5-13.
The data for the individual laundries are presented in Appendix
C.
In addition to the Massachusetts data, a POTW in New York State
has provided the Agency with data from the three industrial
laundries within its jurisdiction. The wastewater from these
laundries were analyzed for purgeable halocarbons and purgeable
aromatics plus some conventional and nonconventional pollutants.
These analyses were made annually for the past several years.
(This document contains data collected in 1983 and 1984.) These
data may not be typical as they were collected because the
sanitary district considered the waste effluents from at least
one of these laundries were a problem. The organics data from
these laundries are summarized in Table 5-14. Data for the
individual laundries are presented in Appendix C.
During the course of the Domestic Sewage Study, a number of state
and local agencies were contacted to obtain toxic pollutant data
and other relevant information. Information so obtained,
concerning the laundries industry, is summarized in Section 3 and
Appendix I of the Domestic Sewage Study (1). A summary of the
pollutant concentrations is presented in this document in Table
5-15.
54
-------
SECTION 6
6.0 POLLUTANT PARAMETERS
The conventional, nonconventional, and priority, pollutants that
characterize industrial laundry wastewater were shown in Section
5. The most prevalent of these pollutants are examined in this
section to determine, if possible, which may present problems,
either in wastewater or sludges. These pollutant groups are
defined in Section 5.0. In addition, the total pollutant
discharge by the industry is estimated.
The priority and nonconventional pollutant groups discussed in
the following sections and presented in associated tables are
divided, for convenience, into the following subgroups.
o volatile organic compounds
o semi-volatile organic compounds
o pesticides and herbicides
o metals and elements
o miscellaneous pollutants
The reader should note that, except as specifically defined
otherwise in Section 6.4, references to average concentrations of
a specific pollutant mean the sum of all concentrations of that
pollutant found in raw waste streams, during the 1986-1987
sampling episode, divided by the number of samples that were
analyzed for that pollutant.
6.1 Conventional Pollutants
The Clean Water Act of 1977 required the Administrator to
establish effluent limitations and standards for conventional
pollutants. The conventional pollutants, biochemical oxygen
demand (BOD), total suspended solids (TSS), pH, and oil and
grease were considered for regulation but none were found to be
such specific and persistent pollution problems across the
laundries industry to warrant rulemaking efforts. The industry
was exempted from regulation under paragraph 8 of the consent
decree.
The aforementioned conventional pollutant parameters were
identified in all plant effluents for which data were obtained in
both the past and recent sampling episodes. Pollutant levels for
these parameters in raw waste and treatment effluent streams are
frequently high, conventional pollutant raw waste data collected
during the recent ITD/RCRA sampling program are summarized in
Table 6-1. These results can be compared to results from
previous sampling programs presented in Table 5-3. As can be
seen, the two data sets are in close agreement.
6.2 Priority Pollutants
Because of the diversity of materials laundered by the industry,
many priority pollutants may be present in the raw wastewater of
a plant. Table 5-4 presents information on the occurrence,
55
-------
TABLE 6-1
SUMMARY OF CONVENTIONAL POLLUTANT CONCENTRATIONS
IN INDUSTRIAL LAUNDRY WASTEWATERS
ITD/RCRA SAMPLING PROGRAM
Minimum Maximum Median Mean
Concentration Concentration Concentration Concentration
Pollutant Number1 (mg/£) (mg/£) (mg/£) (mg/l)
BODS
TSS
oil and grease
pH (standard units)
9/9
9/9
8/6
6/6
222
464
140
9.2
1,900
1,894
2,388
12.2
1,015
930
880
1,120
1,041
1,001
Ratio indicates the number of samples in which the specific pollutant was found as compared to the total number of
samples analyzed.
-------
frequencies, and levels of priority pollutants found in samples
collected by EPA in the 1978 screening/verification program and
Table 6-2 presents similar information from the current ITD/RCRA
sampling program. A comparison of the data shown in the tables
demonstrates the variability found in the wastewaters generated
by the industry. The results of the analyses for pollutants in
the different pollutant categories are discussed in the following
sections.
6.2.1 ITD/RCRA Sampling and Analysis Program-Wastewater Samples
Volatile Qraanics - Twelve volatile organic priority pollutants
were detected one or more times in the wastewaters from the five
laundries sampled during the ITD/RCRA sampling program. Only
seven of these compounds had been detected in laundry wastewater
during the earlier screening/verification program, reflecting the
variability of the industry's wastewaters due in part to the
diversity of the industry's products.
Five compounds were found relatively frequently and at relatively
high average concentrations (mg/1 range or above) during the
present study. The compounds, ethylbenzene, methylene chloride,
tetracnloroethene, toluene, and 1,1,1-trichloroethane, are common
industrial solvents. All of these, except the last, were found
at approximately the same high frequency and levels during the
1978 study. Although benzene and chloroform had been found
frequently and at high levels during the earlier study, only
chloroform was detected during the current study (once, at a very
low concentration). All other compounds detected during either
study were found infrequently and at low average concentrations.
Semi-volatile Qraanics - Ten semi-volatile organic priority
pollutants were detected one or more times during the ITD/RCRA
program. Seven of these had been detected in the earlier study.
Three compounds, isophorone, naphthalene, and N-nitrosodi-n-
propylamine, were found more than twice and at relatively high
average concentrations. Of these, only naphthalene had been
detected frequently during the earlier study. One compound,
bis(2-ethylhexyl)phthalate, had been found frequently during the
screening/verification program but was found less frequently and
at a lower average level during the ITD/RCRA program. All other
compounds detected during either study were found infrequently
and at low average concentrations.
Pesticides and flerbicides - Although no priority pollutant
pesticides or herbicides were detected during the 1978 study,
four were detected once or twice during the ITD/RCRA program.
Only one compound, endosulfan sulfate, was found at a relatively
high concentration (1.4 mg/1).
Metals - All priority pollutant metals were detected in laundry
wastewater, and roost were detected in over half the samples
analyzed. Only beryllium, selenium, and thallium (which was not
analyzed for quantitatively) were detected in less than half the
samples. Copper, lead, and zinc were found at concentrations
over 1 mg/1 The relative frequencies of detection and the levels
57
-------
TABLE 6-2
SUMMARY OF PRIORITY POLLUTANT DATA
FROM INDUSTRIAL LAUXDIRES RAW WASTEVATER
ITD/RCRA SAMPLING PROGRAM
Pollutant
Category
aad
Pollutaat
Total
Nunber
of
Samples
Total
Number
of Detected
Analyses
Concentration
Range
(US/I)
Average
Concentration
Median
Volatile Organic Compounds
cblorobenzene 9
2-chloroethylvinyl ether 9
cblorofom 9
1,1-dicbloroetbane 9
1,1-dichloroetbene 9
trans-1,2-dichloroethene 9
ethylbenzeae 9
•ethylene chloride 9
tetrachloroetbene 9
toluene 9
1,1,1-trichloroethane 9
trichloroethene 9
Semi-volatile Organic Compounds
benzidine 9
bis(2-ethylhexyl)phth»l»te 9
di-n-octyl phtbalate 9
isophorone 9
naphthalene 9
nitrosobenzene 9
N-nitrosodiphenylaaune 9
N-niirojodi-n-propylaaine 9
pbenantfarene 9
2-chloronapbthalene 9
Pesticides/Herbicide*
aldrin 8
endosulfan sulfate 8
BHC, alpha 7
beptacblor 8
Metals
antimony 9
arsenic 9
beryliua 9
cadmium 9
chromium 9
copper 9
lead 9
mercury 9
nickel 9
selenium 9
silver 9
zinc 9
Cyanide
Cyanide, total 9
41
31
10
24
311
10-204
46-12,396
21-12,255
58-15,947
97-10,292
73-10,965
15-204
6,418
112-3,443
21
32-8,217
40-12,963
38
39
850-14,945
19
206-4,403
0.8-7.1
74-1,377
10.4
24.2
20-138
5-87
1.4-4.0
25-426
185-835
487-4,065
400-7,735
0.7-2.9
67-1,080
251
2.7-38
1,960-7,331
31-17,000
5
3
1
3
35
24
2,825
1,450
2,039
2,591
1,302
26
713
527
2
998
1,659
4
It
2,174
2
512
1
181
1
3
75
16
1
131
453
2,021
3,108
1
276
28
17
4,400
2,020
0
0
0
0
0
0
183
41
213
548
0
0
60
7.6
0
66
424
1,630
2,850
1.2
152
0
19
3,920
170
58
-------
at which they were detected during the ITD/RCRA program are
approximately equal to the frequencies and levels found during
the earlier screening/verification program.
Cyanide - Cyanide was detected in all the raw wastewater streams
sampled during the ITD/RCRA program. It was found once at a
relatively high level (17 mg/1), and several other times above
0.1 mg/1 Cyanide was detected slightly less frequently and at a
slightly lower average level during the earlier study.
Process chemicals used in laundering operations account for only
some of the detected priority and nonconventional pollutants.
The source of many of the pollutants detected in industrial
laundry wastewater was the materials submitted to the laundries.
Among the process sources of pollutants at industrial laundries
are soaps and detergents which contribute to BOD5. and oil and
grease loadings, zinc compounds in sours and germicides, solvents
used for spot removal, phenolic compounds used in germicides,
bacteriostats, dust treating compounds, detergent additives, and
chlorine bleaches that can generate chlorinated hydrocarbons in
wastewater.
The major source of many priority and nonconventional pollutants
(including volatiles, semivolatiles, metals, and pesticides)
appears to be the soiled shop towels and cloths sent for cleaning
by industrial customers. Examples of contaminants which are sent
to laundries in this manner are pesticides such as EPN and
aldrin, semivolatiles such as naphthalene and benzidine, and
volatiles such as methylene chloride, an often used degreaser.
The fact that many pollutants are found infrequently and at
varying concentrations is consistent with the changing nature of
the materials laundered at individual facilities.
6.2.2 TTD/RCRA Sampling and Analysis Program -
Solids and Sludge Samples
Sludge samples were obtained from four of the five laundries
sampled during the ITD/RCRA program. Thickened sludge samples
from dissolved air flotation units were obtained at laundries A
and B. Settling basin sediment was obtained at one settling
basin at laundry C and two basins at laundry D. In addition,
several other solids samples were obtained at laundry D. These
were solids from a lint screen, solids from a disc strainer, oil
from an oil skimmer, and final concentrate from an ultrafilter.
Each of the sludge samples taken were analyzed for the priority
pollutants. In addition, the toxicity characteristic leaching
procedure (TCLP) was applied, in most cases, to the sludge
samples and the TCLP extracts were also analyzed for priority
pollutants. If certain pollutants are present above designated
levels in the TCLP extract of a solid waste, the solid waste is
said to exhibit the characteristic of toxicity. Solid wastes
with this characteristic are designated hazardous wastes and must
be handled and disposed of in conformance with hazardous waste
regulations. The priority pollutants found in solids samples
59
-------
obtained at the four laundries are indicated in Table 6-3.
Solids samples were not collected during the
screening/verification program, and no comparisons are
60
-------
TABLE 6-3
SUMMARY OF PRIORITY POLLUTANTS FOUND
IN SLUDGE SAMPLES
ITD/RCRA SAMPLING PRCGRAH
Pollutant
Category
and
Pollutant
Laundry A
DAF
Thickened
Sludge
(Mg/kg)
TCLP
(pg/*)
Laundry B
DAF
Thickened
Sludge TCLP
(pg/kg) (MK/*)
Laundry C
Settling
Basin
Sludge TCLP
(Pg/kg) (Mg/«)
Regulatory
Levels
for TCLP
(Pg/i)
Volatile Organic Compounds
beozeae
broModichloroBethaae
carbon tetrachloride
chlorofora
dibroBochloroaethane
etbylbenzene 2,569
•ethylene chloride
tetrachloroethene
toluene A,831
trans-l,2-dichloroethene
trichloroethene
1,1-dichloroethane
1,1-dichloroethene
1,1,1-trichloroethaae 369
1,1,2,2-tetrachloroethaae
Seat-volatile Organic Compounds
•atbraceae
bi*(2-ethybexyl)phtbal*te
di-n-butyl phtbalate 497
butyl benzyl phthalate 39?
diaethyl phthilate
naphthalene 179
phenanthrene
2-chlorooaphthalene 114
Het«l»
beryl iw
cadBlua 36
cbroaiuai 124
copper 1,030
lead 1.560
nickel 39
zinc 1,560
antiaony 67
arsenic 31
mercury 1.6
seleniua
silver 4
912
116
93
56
208
128
72
850
174
11,500
938
376
838
9,979
31
218
1,080
936
102
2,070
14
36
1.3
49
33
55
119
398
4,880
50
10,909
50,455
650,727
5,818
850,909
30
227
1,340
989
296
2,420
17
6.0
165
146
7,327
5,824
17
20
93
229
2,760
1,760
46
4,090
45
0.3
17
70(p)
70(p)
70(p)
8,600(p)
100(p)
I4,400(p)
100(p)
30,000(p)
1.300(p)
i,oeo(n
5,000(f)
5,000(f)
5,000(f)
200(f)
l,000(f)
5,000(f)
-------
TABLE 6-3 (continued)
ON
to
Pollutant
Category
and
Pollutant
Pesticides/Herhicidet
Laundry A
DAF
Thickened
Sludge TCLP
(Mg/kg) ((Jg/t)
Laundry B
bAf
Thickened
Sludge
(MR/kR)
TCLP
(ME/*)
Laundry C
Settling
Basin
Sludge
(MS/kg)
TCLP
(ng/t)
Regulatory
Levels
for TCLP
endosulfan lulfate
Cyanide
cyanide, total
NA
NA
NA
NA
NA
11
NA
NA
328
6.6
NA
NA
-------
U>
TABLE 6-3 (continued)
Uniform Washers - Laundry D
Shop Towel Washers - Laundry D
Pollutant
Category
and
Pollutant
1st Settling Basin
Solids TCLP
(pg/kg) (pg/t)
Shaker Screen
Solids
(Mg/kg)
TCLP
(Mg/t)
2nd Settling Basin Disc Strainer
Solids
(Mg/kg)
TCLP Solids TCLP
(Pg/t) (pg/kg) (Mg/t) 1
Ultrafilte'r Regulatory
Concentrate Levels
TCLP for TCLP
Volatile Organic Compounds
benxene
browxlichloroaethane
carbon tetracbloride
chlorofora
dibroBOcbloroaethane
ethylbenzene
•etbylene chloride 100
tetracbloroethene 1,535
toluene 669
trani-1,2-dlchloroethene
tricbloroetbeoe
1,1-dicbloroethaoe 49
1,1-dicbloroetbeoe
1,1,1-tcichloroetbane
1,1,2,2-tetrachloroethane
Seal-volatile Orianic Compounds
anthracene
bii(2-ethybezyl)phthalate
di-n-butyl phthalate
butyl benzyl phthalate
diMthyl pbtbalate
oapbthalene
pheoanthrene
2-chloronaphtbalene
Metals
berylliM
cadaiua
chroBiuai
copper
lead
nickel
zinc
antiaony
arsenic
•ercury
seleniua)
silver
9
106
4.780
53.200
4,770
4,150
12,600
44
2S
0.5
I
417
59
20
38
491
39
170
137
1,240
15,700
122
104
396
196
78
3,039
13,987
3,191
4,378
26
72
19
97
63
22
78
30
169
22
25
--
--
•-
--
«
231
—
29,995
5,579
--
192
62
--
136
—
—
--
—
--
--
--
44
1,660
425
--
101
71
--
—
— •
69
22
118
142
15
64,950
7,119
1,620,900
518,720
--
116
153
15,794
153,681
343
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
20,881
13
241,880
140,330
147,790
NA
NA
NA
NA
NA
NA
NA
NA
5
1
6
13
325
,080
640
225
,520
16
5St
—
—
17
--
139
75
398
457
313
5,990
—
..
0.3
—
—
1
99T
372T
2,550
1,100
541
2,090
23R
--
t.l
2T
145
--
559
29T
180T
1.200T
2,900
20,200
--
--
—
--
--
8
79
923
8,790
1,700
1,120
3,110
34
--
0.9
1
85
..
584
70
88
1,140
2,080
22,600
22S*
..
—
..
--
..
68
38
520
2,890
43
1,480
41
-_
0.1
3T
8.0
._
725
23
1,060
5,750
466
2,180
40
__
..
..
—
70(p)
70(p)
70(p)
8,600(p)
100(p)
14,400(p)
100(p)
30,000(p)
l,300(p)
l.OOO(f)
5,000(f)
S,000(f)
5,000(f)
200(f)
l.OOO(f)
5,000(f)
-------
TABLE 6-3 (continued)
Uniform Washers - Laundry D
Shop Towel Wishers - Laundry D
Pollutant
Category
and
Pollutant
1st Settling Basin
Solids TCLP
(Mg/kg) (pg/t)
Shaker Screen
Sol ids TCLP
(Mg/kg) (MS/*)
2nd Settling Basin
Solids TCLP
(UK/kg) (Mg/0
Disc Strainer
Solids TCLP
(Mg/kg) (H8/«)
Ultrafilter
Concentrate
TCLP
(Mg/kg) (pg/t)
Regulatory
Levels
for TCLP
(pg/4)
Cyanide
cyanide, totil
2.2
NA
HA
3.1
NA
600
NA
Peittcides/Herbtcidei
endosulfan sulfate
NA
2,378
NA
NA
NA
Indicate* pollutant concentration below detection liaut
NA Indicates not analyzed
S Indicates value deterained by Method of Standard Addition
t Indicates the correlation coefficient for Method of Standard Addition is less than 0.995
R Indicate* spike recovery is not within control limits
T Indicate* duplicate analysis is not within control Units
(f) Final rales for EF Toxicity Characteristic, see 40 CFR 261 Subpart C
(p) Proposed rule* for Toxicity Characteristic, see SI FR 21648
TCLP Toxicity characteristic leaching procedure
-------
possible. The sludge analyses and the TCLP extract analyses are
also presented in Table 6-32. Table 6-3 presents final and
proposed hazardous waste identification regulations (regulatory
levels) as defined by the Resource Conservation and Recovery Act
(RCRA) for TCLP extracts, for the pollutants to which the
regulations are applicable. The pollutants found in each of the
pollutant groups are discussed briefly in the following
paragraphs.
Volatile Oraanics - Fourteen volatile organic priority pollutants
were detected one or more times in the various sludges sampled, a
number at levels higher than 1 nig/kg. The TCLP extracts of these
samples contained most of the same compounds usually at low
levels. Two samples exceeded the proposed regulatory level for
tetrachloroethene. One of these, the sludge from a disc strainer
for shop towel wastewater at laundry D is treated as a hazardous
waste. We do not believe that the other, sediment from a
settling basin at laundry C, is handled as a hazardous waste.
Semi-volatile Orqanics - Eight semi-volatile organic priority
pollutants were detected in one or more sludge samples, some at
levels above 1 mg/kg. TCLP extracts for these samples contained
the same pollutants at low levels. No compounds were found for
which final or proposed regulatory levels for the TCLP extracts
exist.
Meta1s - Twelve of the thirteen priority pollutant metals were
found in the sludge samples. All samples contained at least half
of the metals. Copper, lead, nickel and zinc were frequently
found at relatively high concentrations. Most metals were also
found in the TCLP extract, several at relatively high
concentrations. The ultrafilter concentrate was the only sludge
sample with TCLP extract containing any metal at a concentration
above the regulatory level. Lead was found in the concentrate
extract at 5,750 g/kg and the regulatory level is 5,000 g/kg.
The concentrate, which by its nature contains high levels of many
other pollutants, is treated as a hazardous waste. Cadmium was
found in the TCLP extract of several samples at levels less than,
but approaching, the regulatory levels.
Cyanide - Cyanide was found at relatively low levels (2.2 to 11
/zg/1) in all of the sludge samples except one in which it was not
detected, and the ultrafilter concentrate in which it was found
at a higher concentration (600 Mg/1)• The TCLP extracts were not
analyzed for cyanide.
Pesticides and Herbicides - One priority pollutant pesticide,
endosulfan sulfate, was found in two solids samples, once at
approximately 1 mg/kg. The TCLP extracts were not analyzed for
2The analyses of the oil sample from the oil skimmer are not
presented in Table 6-3, Table 6-5 or discussed in the following
text because analyses of the TCLP extract were not performed.
The oil analyses are presented in Table 5-10. The oil is
disposed of by incineration.
65
-------
pesticides and herbicides. There are, however, no regulations
applicable to the compound found.
6.3 Nonconventional Pollutants
To obtain a more complete characterization of industrial
laundries wastewater than was obtained during earlier studies, an
expanded list of pollutants was analyzed for (see Table 5-2).
The nonconventional pollutants found at high frequency or
relatively high concentrations are discussed briefly in this
section.
6.3.1 ITD/RCRA Sampling and Analysis Program -
Wastewater Samples. The nonconventional pollutants listed in
the "1987 ITD List of Analytes" and found in the raw wastewaters
of the five laundries sampled are presented in Table 6-4.
Miscellaneous Pollutants - The Clean Water Act of 1977 required
the Administrator to establish effluent limitations and standards
for several nonconventional pollutants. Chemical oxygen demand
(COD), total organic carbon (TOC), ammonia, nitrogen, and
phosphorus were considered for regulation but none were
previously found to be such specific and persistent pollution
problems across the laundries industry to warrant rulemaking
efforts. The industry was exempted from regulation under
paragraph 8 of the consent decree.
Most of the aforementioned pollutants were identified in all
plant effluents for which data were obtained in both the past and
recent sampling episodes. Pollutant levels for these parameters
in raw waste and treatment effluent streams are frequently high.
Miscellaneous nonconventional pollutant raw waste data collected
during the recent ITD/RCRA sampling program and summarized in
Table 6-4 can be compared to results from previous sampling
programs presented in Table 5-3. As can b^ seen, the two data
sets are in close agreement.
Volatile Oraanics - Four hazardous nonconventional pollutant
volatile organic compounds were detected in laundry raw
wastewaters. Of these, acetone was found in all the samples,
sometimes at significant levels (15 mg/1 to 1 gm/1). 2-butanone
was found in two samples, once at 16 mg/1 Both are common indus-
trial solvents. The remaining compounds were found once each at
low concentrations.
Semi-volatile Oraanics - Fourteen hazardous nonconventional
pollutant semi-volatile organic compounds were detected in
laundry raw wastewaters. Eight of these compounds were detected
in only one or two samples each and found at low overall average
concentrations although some were found at an individual facility
at relatively high concentrations. The remaining six compounds
were found at higher frequencies and at relatively high average
concentrations (0.7 to 5 mg/1). These compounds, all straight
chain hydrocarbons with a variety of industrial uses, are n-
decane, n-dodecane, n-tetradecane, n-hexadecane, n-octadecane,
and n-eicosane.
66
-------
TABLE 6-4
SUMMARY OT NOHCOHVEHTIONAL POLLUTANT DATA
IRON INDUSTRIAL LAUNDRIES WASTEWATER
ITD/RCRA SAMPLING PROGRAM
Pollutant
Category
and
Pollutant
Total
Number
of
Sample*
Total
Number
of Detected
Analvita
Concentration
Range
(pg/t)
Average
Concentration
(.UK/1)
Median
(pg/t)
Volatile Organic Compound!
acetone 9
2-butanone 9
iiobutyl alcohol 8
vinyl acetate 8
Semi-volatile Organic Compound*
alpha terpineol 9
biphenyl 9
p-cymene 9
diphenylamioe 9
n-decane 9
n-dodecane 9
n-eicoiane 9
o-hexadecane 9
2-methylnapbthalene 8
n-octadecana 9
n-tetradecane 9
n-tetracotaae 9
n-docosane 9
styrene 9
Pesticides/Herbicidei
dioxathioa 7
azinphoi ethyl 7
EPN 8
etridazone 7
pnosmet 7
tetrachlorovinpho* 8
Betali
aluminum 8
barium 9
boron 8
calciua 8
cobalt 9
iron 9
magnesium 8
manganese 8
•olybdeauB
sodium
tin
titanium
vanadium
Hiscellaneou* Pollutants
residue, filterable 8
TOC 9
fluoride
phoiphorus
chemical oxygen demand
ammonia (a* N)
nitrogen. Kjeldahl
nitrate*nitrite
sulfide, total (iodometric)
101-1,373,430
427-16,762
138
14
199-5219
11-1,766
84-3,464
36
394-34,154
180-8,218
159-2,515
94-4,994
112-186
115-6,319
21-18,615
1,379-8,351
6,391
102
565
278
1,582
15
28
692
1,900-10,600
429-1,857
242-894
11,000-168,000
80-345
3,100-78,018
2,400-35,000
100-1,186
102-499
249,000-1,310,000
47-349
48-337
7-57
1,000-4,800
353-1,100
1.2-39
5.9-S4
1.520-6,100
1.0-1.8
0.27-52
0.21-1.5
1.3-5.9
156,980
1,910
17
2
602
201
652
4
5,238
1,545
297
677
37
740
3,399
1,081
710
11
81
40
198
2
4
87
6,905
1,113
569
47,251
151
30,088
11,565
546
224
587,377
177
205
18
2,825
669
19.8
32
4,660
0.68
19.4
0.85
3.8
1,701
0
0
0
0
0
0
0
0
0
0
0
0
0
21
v 0
0
0
6,447
1,390
546
33,100
127
20,200
9,175
373
196
529,500
207
210
10
2,800
636
18
35
4,900
1.0
14
0.81
3.9
67
-------
Herbicides and Pesticides - Six nonconventional pollutant
herbicides and pesticides were detected in laundry raw
wastewaters during the ITD/RCRA sampling program. All were
detected only once but three (dioxathion, etriadazone, and
tetrachlorovinphos) were found at relatively high levels
(>l/2 mg/1).
Metals and Elements - A wide variety of metals and elements, both
hazardous and non-hazardous, were quantitatively or qualitatively
analyzed for (see Tables 5-6 through 5-12). The hazardous
nonconventional pollutant metals and non-hazardous metals
(included here for convenience) are presented in Table 6-4 and
discussed here. All the metals detected in laundry raw
wastewaters were detected in at least two-thirds of the samples,
and most in all the samples.
Sodium, calcium, iron, and magnesium were found at relatively
high average concentrations (10 mg/1 to 600 mg/1). Aluminum and
barium were found at average concentrations over 1 mg/1 and boron
and manganese at average concentrations of over 0.5 mg/1 The
remainder, although detected frequently, were found at relatively
lower concentrations.
6.3.2 ITD/RCRA Sampling and Analysis Program -
Solids and Sludae Samples. The solids and sludge samples
obtained at four industrial laundries were analyzed for the
nonconventional pollutants listed in the "1987 ITD List of
Analytes". The sources of the samples obtained are discussed in
detail in Section 5 of this document and summarized in this
section under the discussion of priority pollutants
(Section 6.2.2).
In addition to the sludge analyses, the TCLP extract from most
sludge samples were analyzed for the same pollutants. These
analyses were used to determine whether the solids exhibited the
hazardous waste characteristic of toxicity. Several other
solids-specific pollutant parameters were also analyzed for to
determine whether the solids exhibited any hazardous waste
characteristics other than toxicity. Other characteristics
directly determined were ignitability (flash point less than
60°C), and corrosivity (soil pH of less than 2 or greater than
12.5 or corrosion of steel at a rate greater than 250 mil per
year). A fourth characteristic of hazardous solids, reactivity,
was not directly determined.
The pollutants detected in the solids samples and the solids-
specific pollutant parameters, are presented by pollutant group
in Table 6-5 and discussed briefly in the following paragraphs.
Volatile Orqanics - Six volatile hazardous nonconventional
pollutant organic compounds were detected in the solid wastes
sampled. Of these only acetone was detected more than once or
twice in either the sludges or the TCLP extracts. There are no
applicable regulatory levels in effect or proposed for any of the
compounds detected.
68
-------
Laundry A
TABLE 6-5
SUMMARY OF NONCOHVENTIONAL POLLUTANTS, AHD
SOLID WASTE CHARACTERISITICS FOUND IN SLUDGE SAMPLES
ITD/RCRA SAMPLING PROGRAM
Laundry B
Volatile Organic Compounds
acetone
isobutyl alcohol
•ethacrylonitrile
p-dioxane
2-butanooe
2-bexanone
Seat -volatile Organic Compounds
alpba ttrpineol
blpbenyl
n-decane
o-docoi»ne
u-dodecaoe
n-elcoiane
a-hexacoaaae
n-hexadecane
•-octadecane
a-tetradecaoe
(tyreoe
2,6-dlaltrotolueae
Pe»tlcide»/Herbicidei
tetracblorovinpboi
leptopbot
EPM
couaophoi
phosaet
Metali
aluaiouat
bariiui
cobalt
iron
•anganese
tin
vanadiua
HA
HA
HA
NA
HA
2,040
929
178
6,700
1,950
!79
67
67
33
48
35
HA
NA
NA
NA
NA
1,350
1,930
1,620
701
9,670
1.100
359
20.793
NA
NA
NA
NA
NA
3,750
701
148
19,599
8,000
311
159
17
24
20
NA
NA
NA
NA
NA
2,110
116
1,340
5,200
27.800
1,760
Laundry C
Pollutant
Category
and
Pollutant
OAF
Thickened
Sludge
(pg/kg)
TCLP
(pg/t)
DAF
Thickened
Sludge
TCLP
(pg/0
Settling
Basin
Sludge TCLP
(pg/kg) (pg/*)
Regulatory
Levels
for TCLP
(Pg/0
621,909
4,000
1,285
5,020
639
34,500
4,040
396
232
6,245
85
NA
NA
NA
NA
7,900
967
68
35,900
6,490
874
335
100,000(f)
-------
TABLE 6-5 (continued)
laundry A
laundry B
Laundry C
Pollutant
Category
and
Pollutant
DAF
Thickened
Sludge
(Pit/kg)
TCLP
DAT
Thickened
Sludge
(pg/kg)
TCLP
(pg/«)
Settling
Basin
Sludge
(PR/kg)
TCLP
Regulatory
Levels
for TCLP
(pg/t)
HUcelUntom Pollutant!
iBMonla, at H
Solid Watte Chatactetiatict
fifth point
pH, toil
cctiduc, total
retidue, total volatile
cuUide, total
(Konier-Uilliau)
Coicosivit.7
140
60°C
9.»
in
681
78 .g/l
UO
MA
NA
Kh
NA
NA
420
576C
7.3
57X
1,100 Mg/l
KA
NA
NA
Hfc
NA
NA
MA
7.0
10.2
UX
5t
10
NA
NA
NA
HA
NA
NA
NA
<60«C(f)
<2;>12.5(f)
>250(f)
-------
TABLE 6-5 (continued)
Unifora Washers - laundry D
Shop Towel Washers - Laundry P
Pollutant
Category
and
Pollutant
1st Settling Basin
Solids
(Ml/kg)
TCLP
Shaker Screen
Solids
(Yg/kg)
TCLP
dig/*)
2nd Settling Basin
Solids TClT
Disc Strainer
Solids
(MK/kg)
TCLT
Volatile Organic Compounds
acetone
iaobutyl alcohol
•etbacrylonitrile
p-dioxane
2-butaaone
2-hexanoae
Se«i-volatile Organic
alpha terpineol
biphenyl
-de cane
-docosaoe
-dodecane
-eicosane
-hexacosane
-bexadeeane
-ocladecane
-letradecaae
p-cyaene
ityrene
2,6-dinitrotoluene
Pesticides/Herbicides
tetrachloroviapbos
leptopbos
It*
couBophos
phosatet
Hetali
aluaioua
barim
cobalt
iron
•agnesim
•aogaoese
tin
vana'dim
2,900
—
--
—
—
—
Compounds
..
--
—
--
—
—
—
«
—
—
—
— •
--
--
-•
—
-•
452,000
1,090
309
921,000
59,900
3,420
997
239
705
—
— -
—
56
--
..
--
—
--
--
--
—
--
--
--
—
--
"
NA
NA
NA
NA
NA
671
599
183
280,000
4,640
3,860
--
—
._
—
—
--
--
--
..
--
—
--
—
--
40,335
28,330
35,813
—
—
3,822
--
—
--
--
—
--
14,200
177
25
36,800
5,550
329
303
22
179
—
—
—
—
--
_*
—
—
—
—
--
—
--
—
--
—
—
NA
NA
NA
NA
NA
1,180
651
78
56,700
4.350
1,080
—
—
1,772
—
—
—
—
--
—
—
--
--
—
—
--
--
—
—
—
--
—
--
—
—
7,590
572R
59R
57.200T
8,450
460
154
243T
1,298
--
—
—
78
--
__
--
--
--
.-
—
--
--
--
--
---
--
--
HA
HA
NA
NA
—
3,040
1,490
483
99,100
18.000T
3,810
--
—
--
—
«
—
—
--
..
—
10,374
--
-.
—
—
8,867
--
«
—
—
—
-.
—
22,241
17,168
—
16,900
331
153
83,900
3,900
606
248
60
1,314
--
—
--
—
--
31
• -
—
--
—
-.
—
--
--
-.
—
--
—
HA
NA
NA
NA
NA
292
1,110
590
359,000
5,860
4,210
--
—
Ultrafilter Regulatory
Concentrate Levels
(Mg/kg)
__
—
109
75,785
--
--
146,470
..
1,618,540
—
496,320
—
~,
—
217,380
..
—
--
—
825
1,065
--
—
1,921
1,350
340
36
4,400
1,500
130
46
--
TCLP for TCLP
KA
NA
NA
NA
NA
NA
NA
NA
NA
NA.
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1,250
4,640 I00,000(f)
396
1,650
14,300
1,760
--
—
-------
TABLE 6-5 (continued)
Pollutant
Category
and
Pollutant
Unitora Washers - Laundry P
Shop Towel Washers - Laundry D
1st Settling Basin
SoTiai TCTF~
Solids
Shaker Screen
TCTP
2nd Settling Basin
Solids TCTF
(UK/kg) (M8/*)
Disc Strainer
Solids
TClP
Ultrafilter
Concentrate
TCTF
Regulatory
Levels
for TCLP
(MR/0
to
Mitcellaneous Pollutant*
aiaonia, ai If
Solid Waste Characterittics
KA
120
KA
830
NA
NA
* Priority Pollutant
Indicates pollutant concentration below detection limit
MA Indicate* not analyzed
R Indicate* spike recovery is not within control Units
T Indicate* duplicate analysis is not within control limits
(f) Final rule* for EP Toxicity Characteristic, see 40 CFR 261 Subpart C
(p) Proposed rules for Toxicity Characteristic, see 51 FR 21648
TCLP Toxicity characteristic leaching procedure
33
flash point
pH, soil
residue, total
residue, total volatile
sulfide, total
(Honier-ViUiaw)
Corrosivity («py)
32eC
8.8
«9X
3.9X
110
NA
NA
NA
NA
NA
NA
42"C
8.1
23X
20X
8?
NA
NA
NA
NA
NA
NA
30°C
7.5
321
31%
330
NA
NA
NA
NA
NA
NA
52°C
9.9
3«
26X
150
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
<60°C(f)
<2;>12.5(f)
>250(f)
-------
Semi-volatile Organics - Fifteen semi-volatile hazardous
nonconventional organic compounds were detected in the solid
wastes were detected in the solid wastes or the corresponding
TCLP extracts. All were detected infrequently and most at low
levels (except several were found at high levels in the
ultrafiltrate concentrate). None were found in the TCLP extract
at levels above 70ug/l, although it is important to note that the
ultrafilter concentrate TCLP extract was not analyzed for
organics. The concentrate is disposed of as a hazardous waste.
There are no applicable regulatory levels for the semi-volatile
organic pollutants detected in these samples.
Pesticides and Herbicides - Five pesticides or herbicides were
detected in solids generated by laundering shop towels at Laundry
D. Two, EPN and Coumaphos, were found at about 20 mg/kg in the
disc strainer sludge. Three others, tetrachlorovinphos,
leptophos, and phosmet were found at 1 to 2 mg/kg in the
ultrafilter concentrate. TCLP extracts were not analyzed for
these compounds for which there are no direct regulations in
effect or proposed.
Metals - Each of the eight metals listed in Table 6-5 were
detected in most of the sludges sampled and in most of the
corresponding TCLP extracts. All, except tin and vanadium were
found, at least once, at relatively high levels in the sludges
and in the extracts. Of the eight metals, regulatory levels have
been established only for barium, which was detected at levels
well below the regulatory levels in all TCLP extracts.
Solid Waste characteristics - The solid waste characteristics of
toxicity, corrosivity, and ignitability were determined for all
of the solids samples except the ultrafilter concentrate for
which no determinations were made except toxicity for metals.
Toxicity was discussed in previous paragraphs and corrosivity and
ignitability are discussed here.
No sludge samples exhibited the characteristic of corrosivity, as
the soil pH was within the range 2 to 12.5 and the corrosivity
was less than 250 mil per year. All of the solids analyzed for
ignitability at laundry p had flash points below 60*C and thus
all except the disc strainer sludge show the characteristics of
ignitability. The disc strainer sludge was probably a solid
rather than a liquid sludge to which other criteria are
applicable. The thickened DAF sludge from laundries A and B are
also solid sludges and no conclusion can be drawn about them.
The sludge from laundry C was a liquid sludge with a flash point
of 60*C and therefore not ignitable but potentially so. The
solids from laundries A and B are not disposed of as hazardous
wastes and those from laundry C are believed not to be.
6.4 Industry Mass Loadings
Analytical data obtained during the current ITD/RCRA Sampling
Program and during the earlier 1978 Screening Program were used
to develop estimates of the annual mass pollutant discharge for
the industrial laundries industry during these two periods. The
73
-------
estimates are discussed and compared in the following sections.
6.4.1 Annual Raw Waste Mass Loading - ITD/RCRA Program - The
analytical results from the recent sampling done at Laundries A,
B, C, D, and E have been used to develop an estimate of the
annual mass discharge of ITD-listed pollutants from industrial
laundries. Three methods were used to estimate the mass
loadings. For each method, average concentrations were developed
for all pollutants found at one or more facilities at concen-
trations above their analytical detection limits. These average
concentrations were then summed in groups by the type of
pollutant. The group concentrations were then used to calculate
the total industry loadings using an estimate of the total
industry flow.
The loadings are presented for pollutant groups rather than
individual pollutants because the ITD/RCRA data base is not
extensive enough to estimate individual pollutant loadings for
the entire industry with confidence. The pollutant groups for
which loadings have been estimated are as follows:
o volatile organic compounds
o semi-volatile organic compounds
o pesticides and herbicides
o metals and elements
o miscellaneous priority pollutants
o miscellaneous nonconventional pollutants
o conventional pollutants
The differences in the three approaches are the methods used to
calculate the average concentrations of individual pollutants.
The methods are as follows.
o ^Method A - The average concentration of each pollutant was
developed assuming "not detected" observations are equal to
zero. The average concentration for each pollutant was
computed by summing over all detected concentrations and
dividing by the number of analyses for that pollutant.
o Method B - The average concentration of each pollutant was
developed assuming "not detected" observations are equal to
the analytical detection limit. The average concentration
for each pollutant was computed by summing over all detected
concentrations plus the detection limit concentrations for
all analyses at or below the detection limit, and dividing
by the number of analyses for that pollutant.
o Method C - The average concentration of each pollutant was
developed including only observations reported above the
analytical detection limit. The average concentration for
each pollutant was computed by summing over all detected
concentrations and dividing by the number of analyses above
the detection limits for that pollutant.
These methods were developed because, in cases where detection
limits are high or where detected levels of a pollutant are not
74
-------
much greater than the detection limit, the interpretation of the
detection limit presents a problem. A pollutant, undetected in a
sample, might be present at any level between zero and the
detection limit. To avoid any ambiguity, method A provides a
lower limit for the over all average concentration of each
pollutant and method B provides an upper limit.
Estimated industry average concentrations were developed for each
pollutant detected one or more times in the raw waste streams of
the five laundries sampled during the ITD/RCRA study. Average
concentrations for each of the previously defined groups was
calculated by summing the concentrations of all the pollutants in
each group. Groups comprising both priority and nonconventional
pollutants were subdivided into priority and nonconventional pol-
lutants and average concentrations were calculated for each
subgroup. This was done for each of the three averaging methods.
The group and subgroup average concentrations and an estimated
yearly average total flow for the industry were used to calculate
an annual average mass loading for the industry for each group.
Based on data obtained during the 1977 survey of the industrial
laundries industry, the average wastewater discharge is 68,000
gallons per day per laundry. There are currently approximately
1000 industrial laundries operating an average of 5 days per week
and 52 weeks per year. The total yearly industry wastewater
discharge is, therefore, approximately 17,680 million gallons.
The pollutants, the average concentrations determined by each of
the three methods, the group priority pollutant and nonpriority
pollutant concentrations, and the group priority pollutant and
nonpriority pollutant annual mass loadings for each method are
presented in Table 6-6. The annual mass loadings for each
subgroup and group are summarized in Table 6-7.
These estimates of the industry's pollutant mass loadings appear
reasonable within the constraints of the extremely limited amount
of data available, with one possible exception. Approximately
90 percent of the volatile organics annual mass discharge is the
result of a single analysis for one compound (see Table 6-6,
acetone, laundry A, day 2) . As each of these volatile organics
analyses are based on only three grab samples taken during the
course of an 8 to 10 hour work day it is possible for the results
to be strongly biased by one anomalous sample. As a result the
total annual discharge of volatile organics may be overestimated
by a factor of ten.
6.4.2 Annual Raw Waste Mass Loadings - 1978 Screening Program -
In addition to estimated industry average raw waste
concentrations for the several pollutant groups based on data
obtained during the 1986-87 ITD/RCRA study, additional estimates
of the average concentrations were developed based on data
obtained during the 1978 screening and verification sampling
program. Data for the earlier program were available for
conventional pollutants, priority pollutants and a small number
of nonconventional pollutants (COD, phosphorus, etc.) but were
75
-------
not available for hazardous non-priority organic, metallic or
elemental pollutants.
The estimated industry average concentrations were developed as
described in Section 6.4.1 for each pollutant detected one or
more times in the raw waste streams of nine industrial laundries
sampled during the screening program. Individual laundry data
are presented in Table 6-8. Two distinct sampling episodes
occurred at two of the laundries and data are presented for each
episode separately. Method B, which assumes concentrations of
"not detected" observations are equal to the analytical detection
limits, was not used as the analytical detection limits for these
analyses are generally not available.
The pollutants, the average concentrations determined by methods
A and C, the group priority and non-priority pollutant
concentrations and the group priority and non-priority pollutant
annual mass loadings for each method are presented in Table 6-8.
The annual mass loadings for each group and subgroup are
summarized in Table 6-9. The data presented in Table 6-8 were
obtained from Appendix A of the 1982 Guidance Document (6) and
can be found in Appendix D of this document. Annual mass
loadings are based, as for the ITD/RCRA data, on an average
discharge of 68,000 gallons per day per laundry by 1,000
laundries operating 5 days per week and 52 weeks per year.
76
-------
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6.618
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ti in
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to m
24 111
111 111
107 IZt
1.179 B9X
2.175 ATX
J.05B 671
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79 1 HI
14, KB
2,192,117
6.41B 1 111
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2.105 2 221
21 1 111
2,2*i 4 441
4,977 1 1»
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19 1 IK
6,523 1 111
19 1 111
Jt.lb7
1.M5.52B
-------
IMll 6-6
IKKISIIIU IMMMIIS IttUSItT MASS IOM1IK CIIIMIC
CD
,«,«»,,.,„ «u
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million Md Mrtictdtt (u|/II
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W7.P97 297,997
-------
1AILE 6-6
IWXJS1IIU UUMMKS IIDUSItl MSS ICMDIHC ESIINME
•
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1(6 112
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(1,000)
(1.000)
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(i.ooO)
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(1.000)
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11
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(10)
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5,219
(1.000)
2.320
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9.117
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(1.000)
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(1,000)
226
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11.272
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-------
l«Ll 6-6
IMUSMIM uuMiEt imsiir MIS LOU IK Eirimn
M HOP *
CO
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DMNUD lAUOtl «1 11
FMlicitfn mi MrblcidM do/1)
tttimJm t1»»t 271
IN (2501
•trMHvw 15
ClKKMl ($00)
t«lr»6lil«foyin0iM (250)
(UMMtl
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-------
1UU 6-6
IHDUSIIIU lUMMItt IWJflM lUSt IOWIK fSIIMIE
CO»0*0 IAIMMI »1 IAL
CannMunal reuutemt (•«/()
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EstieBted *•» Oitckaree
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1.100 610 1.JOO
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e
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•
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ion
ion
ion
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00 OB $-BO° 4-900 J-100 *.*°° <.MO «.'M S.002 5.717 ' 1.S20 4.660 4,640 (.660 9 V 10OI
4.640 (.660 (.660
UtioMedMM OiecMre* llb/yrl 6»7.;i(,t(] 687,51«,U1 4B7.5U.143
IKMt • Indicates BOllucent concentretion I* less than tne detection lieiit.- XV is the detection li«it.
M of detected concentration* and detection limits al undetected poUuttntt divided by ruiber of aa^ilet analyied.
"elhad t • Uofnff only tke result* which acre above tfte detection lieiit. Average is SUM of detected concentrations divided bv rurt>er of detection*.
•etkod C • Uainf only «•« rttutls mock uere ecwve the detection li»u. Average is sue, e» delected concentrations divided b» e«aAer ol leapt tt ana I tied.
• a Castxisile «f restill* Irex |rat> saaplri.
b • bat analyied.
-------
TABLE 6-7
ESTIMATED ANNUAL RAW WASTE LOADINGS
FOR ITD-LISTED ANALYTES
FOR THE INDUSTRIAL LAUNDRIES INDUSTRY
ITD/RCRA SAMPLING PROGRAM
Estimated Annual Loading (1,000 lb/
Pollutant Group Method A1" Method B1'* Method C"
Volatile Organic Compounds5
Priority Pollutants 1,520 1,537 2,192
Hazardous Nonconventional Pollutants 23.446 23.546 24,452
Total 24,966 25,083 26,644
Semivolatile Organic Compounds5
Priority Pollutants 973 2,016 3,566
Hazardous Nonconventional Pollutants 2,242 3.110 6,384
Total 3,215 5,126 9,950
Pesticides and Herbicides5
Priority Pollutants 28 29 113
Hazardous Nonconventional Pollutants 6_1 233 466
Total 89 262 579
Metals and Elements5
Priority Pollutants 1,553 1,556 1,589
Hazardous Nonconventional Pollutants 1,462 1,471 1,483
Total 3,015 3,027 3,072
Miscellaneous Priority Pollutants
Cyanide 298 298 298
Miscellaneous Nonconventional Pollutants
Common Ions (Ca, Fe, Mg, Na) 99,778 99,778 99,778
COD 687,518 687,518 687,518
Conventional Pollutants
BODS 165,245 165,245 165,245
Oil and grease 147,688 147,688 147,688
TSS 153,589 153,589 152,589
1 Based on 1000 facilities operating 260 days per year and discharging 68,000 gallons
per day per facility.
2 Mass load estimates are based on individual pollutant average concentrations that
were developed assuming "not detected" observations were equal to zero.
3 Masa load estimates are based on individual pollutant average concentrations that
were developed assuming "not detected" observations were equal to the analytical
detection Unit.
4 Mass loading estimates are based on individual pollutant average concentrations
that only included observations reported above analytical detection limits.
5 See Table 6-6 for list of specific compounds.
82
-------
IU1E 4-8
tUMMlES 1KUSI1T MSS LOWING EtTlHAIE
03
10
CDNrOUO HUH 1
KtOtITT MLLUIMIS
VoUlIU Orfmlci (U8/I) <•)
btnun*
urban ittwklerldt
MlkyUn* eMorldi
UtrKhlorottMn*
talucne
f,l,t-tr
1,200
110
4999)
1,100
92
158
440
4,808
180
98
C999)
(999)
100
(01
11
54
1,200
1.200
4.480
1
50
(29)
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MM
PlUT 4
no
(999)
(999)
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10
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(999)
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2.400
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(999)
(999)
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140
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980
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8 (999)
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(999)
6
1.700
4
1
1
5
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(999)
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(979)
2!
8
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9
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810
1,050
2
455
117
2,550
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44
600
(50)
20
18
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100
t
50
(999)
1,000
PLANT 8
(999)
(999)
(999)
(099)
(999)
(999)
(999)
(999)
(999)
(999)
5.100
1,500
(999)
(999)
440
410
(999)
(999)
410
(999)
(999)
8
170
25
60
600
4,000
9,000
2
100
(2)
4,000
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b
b
fa
b
b
b
b
b
b
fa
b
b
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120
390
CW9)
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(20)
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2.J70
b
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88
(99»)
210
1,57*
7,94*
(99»)
140
(999)
1,280
K1NOO A
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22
1
284
9
3,111
109
219
1.019
554
16
5,181
791,722
1.501
102
1
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in
9!
rr
12
1.519
KM
6!
125
4.194
448.211
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9
55
551
1.154
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I
144
14
2,881
10,141
1,495.185
MEIWO C
ME*Mt
87
6
851
11
1,758
217
241
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1,641
107
8,145
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1.100
151
280
440
190
2,101
1.800
194
145
10.00}
1,475,284
512
11
55
551
1.521
4.712
2
IM
41
2,881
10,494
1,547,751
•UMK* Of
SAMPLES
uukiueo
4
6
6
&
6
4
6
6
6
6
6
4
7
WM8H
or
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2
1
2
4
5
3
5
5
2
2
4
2
1
1
1
2
1
1
4
1
2
6
KICEMT
or
OCOXAKE
1JX
17X
11X
67X
SIX
50X
SIX
IIX
13K
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17X
\n
50X
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17X
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m
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tm
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61X
B9X
22X
IOOX
-------
TAILE 6-8
INDUSTRIAL LAUNDRIES INOUSII* MASS LOADING ESTIMATE
COMPOUND nun t PLANT 2 PLANT i
Priority Pollutant Nltc. (ui/l)
cyanide 57 (999) (999)
SUMotil
CttlMtad NMI Dltdi.ru (Ib/yr)
MNCONVt«tlONAL POUUtA*TI («•/!)
coo 6.*oo i.eoo i.zoo
Stttotal
IttlMted Maet Olacharao (Ib/yr)
OWVEITIOMI POLLUTANT! («g/U
MO b b b
DI«. tout rtcorcriM* 831 UO 760
T» 190 700 S20
WbUUl
IitlMttd NMI Oltckvc* (Ib/yr)
IAU WASrCUAlE* DAFA
riAKI ^ atANI S PLANT 6 PLANT 7 PIAKI 7 PLANT 8 PLANT 8 PLANT 9
280 2(0 (9991 26 (10) (20) (999) (999)
7.100 4.900 b 2,550 I.2W 1,600 b (999)
2.400 1,700 877 Jt6 180 l.tOO 119 1.2S1
1.400 210 S1J 20S m 430 1.090 860
940 900 792 (99 5.1S1 520 «9S 1,057
US! WO A
AVENUE
67
67
9.879
*, 10$
»,105
60S, 287, 176
1,111
598
S90
2,119
1U.880.16S
KTNGD C MMEI Of
SAMPLES
AVEtAGE ANALYZED
IS1 9
151
22,228
*,105 8
4,105
605,287,176
1.151 6
598 9
S90 9
2.119
1U.880.16S
MMEI PEtCENT
Of Of
DETECTS OCCUtAIICE
^ ux
8 torn
6 100X
9 IOOX
9 IOOX
(no Indicate* pollutant cencantratlon It IMS than tha datactlon Halt; M It tha datactlon Halt.
(999) Indicate* pollutant uai not dalactad. Oatactlen Holt 1* uiknoun.
Method A Ualnfl only tha ratult* «hlck wara abova th« dttacclon lf«lt. Avara0« la tu* of detected concentrat lana divided by rubber of aa«plat analyzed.
Hathod C IMlnf only the rtiultt JilcK uer* above the detection Halt. Averege It n* of detected concentration* divided by n*t*r of detection*.
• Coapotlt* of retull* froa grab impln.
b lot analyiad.
-------
TABLE 6-9
ESTIMATED ANNUAL RAW WASTE LOADINGS FOR PRIORITY POLLUTANTS
AND SELECTED CONVENTIONAL AND NONCONVENTIONAL POLLUTANTS
FOR THE INDUSTRIAL LAUNDRIES INDUSTRY
1978 SCREENING PROGRAM
Estimated Annual Loading (1.000 Ib/yr)
Pollutant Group Method A1" Method B*'J Method C1'*
Volatile Organic Compounds5
Priority Pollutants 794 1,204
Seuivolatile Organic Compounds5
Priority Pollutants 648 1,475
Pesticides and Herbicides
Priority Pollutants 0 0
Metals and Elements5
Priority Pollutants 1,495 l(54g
Miscellaneous Priority Pollutants
Cyanide 10 22
Miscellaneous Nonconventional Pollutants
COD 605,287 605,287
Conventional Pollutants
BODS 169,716 169,716
Oil and grease 88,176 88,176
TSS 86,996 86,996
1 Based on 1000 facilities operating 260 days per year and discharging 68,000 gallons
per day per facility.
2 Mass load estimates are based on individual pollutant average concentrations that
were developed assuming "not detected" observations were equal to zero.
3 Mass load estimates are based on individual pollutant average concentrations that
were developing assuming "not detected" observations were equal to the analytical
detection limit. Detection limits were not available and this method was not used.
* Mass loading estimates are based on individual pollutant average concentrations
that only included observations reported above analytical detection limits.
5 See Table 6-8 for list of specific compounds.
85
-------
6.4.3 Comparison of Annual Average Raw Waste Mass Loadings
Table 6-10 presents a comparison of the average raw waste
concentration of each pollutant group using data from the current
ITD/RCRA Sampling Program and data from the 1978 Screening
Sampling Program. Table 6-11 presents a comparison of the annual
average mass loadings developed for each pollutant group based on
the two sampling programs. The estimates of the industry average
concentrations and mass loadings presented in Tables 6-10 and 6-
11 are based on the determination of average pollutant
concentrations by Method A and are therefore conservative. No
comparisons were possible for the hazardous nonconventional
volatile or semivolatile organics or any nonconventional metals
as no samples were analyzed for these pollutants during the 1978
screening sampling program.
The mass loadings developed from the ITD/RCRA data and the 1978
data for BOD£5, COD, and priority pollutant metals agree very
closely. The loadings for TSS, oil and grease, and priority
pollutant volatile and semivolatile organics developed from 1978
data are 40 to 50 percent less than the loadings developed from
the ITD/RCRA data. The difference may reflect the highly
variable nature of industrial laundry wastewaters.
6.4.4 Annual Final Effluent Pollutant Mass Loadings - No attempt
has been made during this study to estimate the annual mass
pollutant loadings discharged by the industrial laundries
industry to the nation's POTWs. Settling basins, dissolved air
flotation clarifiers, and membrane filtration systems are the
types of pretreatment systems known to be used by the industry.
Data are available to estimate the pollutant removals of each
type of pretreatment. The first is relatively ineffective and
the second and third types achieve relatively high pollutant
removals. However, we have no data on the number of laundries
that use each type of pretreatment system. It is therefore not
possible to make any reasonable estimate of the pollutant
reduction achieved by the industry as a whole before discharge to
the sewer.
86
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TABLE 6-10
COMPARISON OF ESTIMATED INDUSTRY AVERAGE CONCENTRATIONS
OF INDIVIDUAL POLLUTANTS IN INDUSTRIAL LAUNDRIES RAW WASTEWATERS
ITD/RCRA SAMPLING PROGRAM vs. 1978 SCREENING PROGRAM
Pollutant
Category and
Pollutant
Priority Pollutant Metals
antimony
arsenic
beryllium
cadmium
chromium
copper
lead
mercury
nickel
selenium
silver
zinc
Priority Pollutant Volatile Organic Compounds
benzene
carbon tetrachloride
1,1, 1-trichloroe thane
chloroform
ethylbenzene
methylene chloride
dichlorobromome thane
tetrachloroethene
toluene
trichloroethene
chlorobenzene
2-chloroethylvinyl ether
1,1-dichloroethane
1,1-dichloroethene
trans- 1 ,2-dichloroethene
ITD/RCRA1
Average3
Concentration
(LJ8/D
75
16
1
131
453
2,021
3,108
1
276
28
17
4,400
mm
..
1,302
1
2,825
1,450
--
2,039
2,591
26
5
3
3
35
24
Screening2
Average3
Concentration
(PR/2)
384
13
--
59
564
1,670
5,120
1.3
176
--
31
3,160
22
142
553
8
3,131
109
1
219
1,019
36
--
--
•-
—
--
Priority Pollutant Semi-volatile Organic Compounds
2-chloronaphthalene
dichlorobenzenes
2,4-dimethylpbenol
isophorone
naphthalene
N-nitrosodiphenylamine
phenol
bis(2-ethylhexyl)
phthalate
butyl benzyl phthalate
di-n-butyl phthalate
di-n-octyl phthalate
anthracene/phenanthrene
benzidine
nitrobenzene
N-nitrosodi-n-propylamine
512
998
1,659
4
527
2
2
713
4
2,174
3
183
77
32
1,539
300
136
1,170
301
175
93
143
Cyanide
cyanide, total
2,020
121
87
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TABLE 6-10 (continued)
Pollutant
Category and
Pollutant
ITD/RCRA1
Average3
Concentration
Screening2
Average3
Concentration
Pesticides and Herbicides
aldrin
BHC; alpha
endosulfan sulfate
heptachlor
1
1
181
3
Conventional Pollutants
BOD5
oil~and grease
TSS
1,120,000
1,001,000
1,041,000
1,420,000
695,000
691,000
Nonconventional Pollutants
COD
4,660,000
3,684,000
—Not detected in any sample.
'Data are from 1986-7 ITD/RCRA Sampling Program.
2Data are from 1978 Screening Program. See 1982 Guidance Document,
Section 5 and Appendix A (6). Data presented here are average influent
concentrations at Plants A, fi, C, D, E, X, L, and Z.
^Estimated averages are based on the assumption that "not detected" observations
are equal to zero (see Method A in text).
-------
TABLE 6-11
COMPARISON OF ESTIMATED ANNUAL RAW WASTE LOADINGS FOR PRIORITY
POLLUTANTS AND SELECTED CONVENTIONAL AND NONCONVENTIONAL POLLUTANTS
FOR THE INDUSTRIAL LAUNDRIES INDUSTRY
ITD/RCRA SAMPLING PROGRAM vs. 1978 SCREENING PROGRAM
Estimated Annual Loading (1.000 Ib/yr)1'2
Pollutant Group
Volatile Organic Compounds3
Priority Pollutants
Semivolatile Organic Compounds3
Priority Pollutants
Pesticides and Herbicides3
Priority Pollutants
Metals and Elements3
Priority Pollutants
Miscellaneous Priority Pollutants
Cyanide
Miscellaneous Nonconventional Pollutants
COD
Conventional Pollutants
BODS
Oil and grease
TSS
ITD/RCRA
1,520
973
28
1,553
298
678,518
165,245
147,668
153,589
1978 Screening
794
648
0
1,495
10
605,287
169,716
88,176
86,996
1 Based on 1000 facilities operating 260 days per year and discharging 68,000 gallons
per day per facility.
2 Mass load estimates are based on individual pollutant average concentrations that
were developed assuming "not detected" observations were equal to zero (see Text-
Method A).
3 See Table 6-10 for list of specific compounds.
-------
SECTION 7
7.0 CONTROL AND TREATMENT TECHNOLOGY
The following descriptions and evaluations of technologies for
the control and treatment of laundry wastewaters are based on
their applicability in removing various pollutants prior to the
discharge of the wastewater to a POTW. The pollutants found most
consistently or at highest concentrations, as presented in
Section 5, are the basis for evaluation of currently applicable
technology. In addition, handling and disposal of sludges
generated by these technologies are discussed.
All known industrial laundries discharge to POTWs. Therefore,
removal of pollutants incompatible with POTW operation is a major
concern of the laundry industry. The extent and type of control
practiced by individual laundries has been dependent on local
sewer ordinances, geographic location, and economic
considerations.
Conventional in-plant controls and physical-chemical treatment
systems presently used for pretreatment of laundry wastewater
prior to discharge to a POTW are discussed in this section.
Potentially applicable treatment technology not known to be in
use in the industry at present is discussed in earlier EPA
documents (6).
Some conventional controls remove gross pollutants such as lint
and sand which may obstruct piping and sewer drains and disrupt
laundry operations. Another conventional control, heat
reclamation, may be used to reduce the temperature of the
effluent wastewater and preheat incoming fresh water. Physical-
chemical treatment systems (PCSs) are designed to meet municipal
sewer ordinances established for the control of pollutants which
may include oil and grease, organics, heavy metals, and pH.
Sludges resulting from the treatment of laundry wastewater must
be handled and disposed of. Ultimate disposal of laundry sludge
can be accomplished by landfilling or incineration.
In 1977, an EPA technical survey showed that approximately 70
percent of the industrial laundry facilities had lint screens, 70
percent had catch basins, and 72 percent had heat reclaimers.
One to two percent had physical-chemical systems (dissolved air
flotation), 15 percent had oil skimmers, and 8 percent had
filtration, separators, oil hold-back devices, or other
miscellaneous operations. Trade association personnel and
laundry personnel have stated that more laundries have installed
pretreatment systems since the Agency's previous data gathering
efforts. Physical-chemical systems have been installed, includ-
ing both dissolved air flotation and ultra-filtration systems.
However, no plant-specific information is currently available.
90
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7.1 CONVENTIONAL TECHNOLOGY
Generally, conventional technology is designed to remove gross
pollutants such as solids (lint, sand, grit) and free oil. Heat
reclaimers are used to recover heat from the wastewater prior to
discharge and to preheat incoming fresh water.
7.1.1 Solids Remova1
Bar screens, lint screens, and catch basins (settling pits) are
used to remove sand, grit, lint, and other noncolloidal solids
from laundry wastewater. Solids removal is accomplished in many
laundries to prevent the obstruction of piping and drains.
Bar screens are flat steel bars welded together in a grid pattern
forming spaces typically 0.25 in. by 0.75 in. They are designed
to allow the free flow of effluent while removing large objects
from the wastewater stream, and are usually cleaned by hand.
Lint screens are usually installed after bar screens to remove
lint and other particles such as sand and grit. They are
generally cylindrical or rectangular, and are constructed of wire
mesh or perforated metal plate, with openings typically 0.37 in.
by 0.12 in. They are cleaned manually or mechanically.
Mechanical cleaning is usually accomplished by a rotating or
vibrating lint screen which causes the trapped lint to fall off
the screen into a collection container.
Catch basins may also be used in combination with lint screens to
remove sand and grit from laundry wastewaters by gravity
settling. They are typically built below ground and have
hydraulic detention times of between 15 and 40 minutes. The
effectiveness of solids settling depends on the characteristics
of the particular laundry wastewater, basin geometry, and the
hydraulic detention time of the catch basin.
Flow equalization of laundry effluent is generally required to
optimize the performance of additional physical-chemical
treatment technologies such as dissolved air flotation. Holding
tanks with detention times of 2 to 4 hours are considered
adequate. Detention times of this magnitude will also usually
provide the maximum removal of suspended solids achievable
without resorting to additional technology. Holding tanks also
provide thermal equalization and some reduction in variability of
pollutant concentrations, both of which facilitate operation of
additional treatment systems. Physical, chemical, and biological
reactions can occur in an equalization tank, and may cause reduc-
tions in pollutant concentrations (9).
7.1.2 Free Oil Removal
Oil and grease, by definition, comprises compounds that can be
separated from water by freon, hexane, or ether extraction.
Data collected from industrial laundries indicate that 5% to 10%
of the total oil and grease loading is free or non-emulsified
oil. The remainder exists as a water-oil emulsion.
91
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Free oil removal treatment techniques (10) consist of retaining
the oily water in a holding tank and allowing gravity separation
of the oily material from water. The oils rise to the surface
and are mechanically skimmed from the water.
7.1.3 Temperature Control
Heat reclaimers are used in the laundry industry to preheat
incoming fresh water prior to use in the wash process.
Preheating is accomplished by noncontact heat transfer from
laundry wastewater. Laundry effluent temperatures can be reduced
from 140°F-160°F to 80°F-100°F with corresponding savings of
fuel.
7.1.4 Capabilities of Conventional Technology
Data presented in earlier documents, and summarized in Table 7-1,
indicate that the effectiveness of conventional treatment in
removing pollutants is extremely variable, and the results of
earlier studies were inconclusive. Median removal rates for
several conventional and toxic pollutants ranged from zero to 32
percent. Data characterizing pollutant removals by conventional
treatment were obtained at two facilities during the current EPA
sampling program. These data are presented in Table 7-2. They
show the same extreme variability as the earlier data and are
equally inconclusive.
7 . 2 INCOMPATIBLE POLLUTANT REMOVAL
PRESENTLY APPLIED TECHNOLOGIES
Incompatible pollutants are pollutants that interfere with POTW
operation or pass through a POTW and prevent it from meeting its
limitations. To avoid these problems, POTWs must regulate the
discharge of incompatible pollutants at the source.
Laundries operating under regulations that limit the discharge of
incompatible pollutants have, in the past, used dissolved air
flotation systems (DAF) for wastewater treatment. in recent
years, ultrafiltration (U/F) systems have been installed in a
number of laundries and appear to be operating satisfactorily.
Both DAF and U/F systems are described in the following sections.
7.2.1 Dissolved Air Flotation (DAF1 Treatment Technology
DAF treatment of laundry wastewater comprises the following unit
operations: flow equalization, chemical addition, flocculation,
flotation, and sludge disposal. Figure 7-1 is a block diagram
for laundry wastewater pretreatment using DAF technology.
Conventional controls, such as lint screens and catch basins, are
assumed to be in place.
Flow Equalization - Constant flow and reduced variation of
pollutant concentrations will allow more efficient operation of a
particular treatment system. As laundry wastewater flows and
pollutant concentrations can vary by orders of magnitude during a
92
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CHEMICAL
FEED
SKIMMERS
INFLUENT-
WEIR
EQUALIZATION
TANK
MIX
TANK
CO
SLUDGE
PIT
I I
FLOTATION
TANK
SLUDGE
RECYCLE
EFFLUENT
COMPRESSED
AIR
FIGURE 7-1
DISSOLVED AIR FLOATATION
TREATMENT SYSTEM
FOR LAUNDRY WASTEWATER
-------
TABLE 7-1
SUMMARY OF REMOVAL EFFICIENCIES OF SELECTED POLLUTANTS BY
CONVENTIONAL TREATMENT1 AT THREE INDUSTRIAL LAUNDRIES2
Range of
Pollutant
Parameter
oil and grease
BOD5
TSS
copper
lead
zinc
Median
Percent
Removal
19
6
0
28
32
0
Range of
Percent
Removals
0
0
0
0
0
0
- 65
- 18
- 20
- 66
- 91
- 99
Median Influent Influent
Concentration Concentrations
(rng/i) Cm*/*)
620
310
500
0.12
0.52
0.45
190 -
170 -
210 -
0.03 -
0.22 -
0.38 -
1,350
660
1,300
0.69
2.4
0.86
Number
of
Samples
9
9
9
8
9
5
1 Includes bar screen, lint screen, catch basin and heat reclaimer.
2 Data are from 1978 Screening Program. See 1982 guidance document (6).
94
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TABLE 7-2
SUMMARY OF REMOVAL EFFICIENCIES OF SELECTED
POLLUTANTS BY CONVENTIONAL TREATMENT1 AT
TWO INDUSTRIAL LAUNDRIES
ITD/RCRA SAMPLING PROGRAM2
Pollutant
Parameter
oil and grease
BOD5
TSS
copper
Lead
zinc
calcium
iron
acetone
tetrachlorethene
toluene
Median
Percent
Removal
0
15
39
37
10
31
25
49
0
23
86
Range of
Percent
Removals
0
0
0
8
0
23
20
28
0
0
0
- 49
- 68
- 56
- 65
. 46
- 42
- 63
- 71
- 94
- 53
- 100
Range of
Median Influent Influent
Concentration Concentrations
(mg/2) (mg/£)
250
705
765
1.55
2.04
4.82
34.5
26.7
0.92
0.31
0.23
140
540
490
1.29
0.97
3.92
21.5
19.7
0.06
0.09
0.136
- 920
- 900
- 930
- 2.06
- 3.50
- 5.45
- 47.4
- 63.6
- 17.5
- 0.84
- 6.64
Number
of
Samples
4
4
4
4
4
4
4
4
4
3
3
1 Bar screen, 2 catch basins, and heat reclaimer at facility C; lint screen, heat
reclaimer, and 2 catch basins at facility D (uniform washers only). See
Section 5.
2 Data are from 1986 EPA Sampling Program. See Section 5.
95
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day's operation, equalization of flow and pollutant loads prior
to DAF treatment is necessary to obtain optimal operation of a
DAF system (25). This usually can be accomplished with
equalization basins of one-half days hydraulic detention time.
Equalization tanks at laundries may require cleaning on a regular
basis to remove settled solids and grease deposits, or they may
be agitated to prevent settling.
Chemical Addition - Pollutants, such as oil and heavy metals, are
usually found in laundry wastewater in the form of colloidal
suspensions which cannot be effectively treated solely by
physical techniques. Chemical addition is used to aggregate the
colloidal material into particles that can be physically removed
by flotation, sedimentation, or filtration.
Emulsified oil and grease is aggregated by chemical addition
using coagulation, acidification, or both in conjunction with
flocculation mechanisms. Coagulation is accomplished with
chemical additives that destabilize the colloidal material,
either by reducing the electrostatic repulsive forces between
colloids or by forming positively charged hydrous oxides which
are absorbed on the surface of the colloid (10, 11) . Other
pollutants which exist as colloids in laundry wastewater, such as
lead, copper, and zinc, are also destabilized by coagulation.
Acidification of oil and grease colloids is accomplished by
lowering the pH to a point where dispersed oil droplets aggregate
and the emulsion is said to be broken (10) . Coagulation and
acidification may both be used in a DAF system to treat laundry
wastewater.
The chemicals are added at prescribed rates to the raw wastewater
to destabilize colloidal suspensions in laundry wastewater. The
following coagulants are currently in use.
Aluminum sulfate (Alum, A12(SOJ3)
Calcium chloride (CaCl2)
Ferric sulfate (Fe2(S04)3)
Ferrous sulfate (Fe(SOJ)
Cationic polyelectrolytes
The choice is based on efficiency of particle formation and ease
of hauling and disposing of the solids generated.
Flocculation - Flocculation is defined as particle transport,
contact, and formation occurring as a result of colloidal
destabilization (coagulation). Particle transport results from
thermal motion, bulk fluid motion (accomplished by mechanical
stirring), and differential settling (12). Floe particles that
form as a result of chemical coagulation contain the colloidal
material intended for removal. In all cases floes properly
formed from interparticle contact can be removed by physical
means. Since proper floe formation is dependent on various
particle transport mechanisms (flocculation), the physical design
of chemical addition equipment must provide adequate time and
mixing for interparticle contacts during coagulation.
96
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Design parameters necessary to achieve proper particle contact
include hydraulic detention time in the mix tank and the physical
methods used for mixing. The required detention time for
flocculation is generally inversely proportional to solids
concentration (12). Mixing must provide adequate particle con-
tact, and it is achieved by baffles in mix tanks and turbulence
caused by pumping and air injection into the stream.
Flotation - In the pretreatment of laundry effluents, floe is
brought to the surface of a thickener unit by means of dissolved
air flotation. DAF is accomplished by pressurizing all or part
of the effluent stream with air to 40 to 80 psig. The increased
pressure on the wastewater causes additional air to dissolve in
the wastewater.
The pressure is then reduced back to atmospheric, forcing
dissolved air out of solution in the form of minute bubbles
throughout the entire volume of the liquid (13). These bubbles
become attached to floe particles causing them to rise to the
surface of a flotation tank (thickener) where the floe solids are
skimmed off by rotating troughs or moving blades.
The principal components of a DAF unit are the pressurizing pump,
retention tank, pressure-reducing valve, air injector, and a
flotation tank. For laundry wastewater, two modes of
pressurization are currently in use: full flow pressurization
(FFP) and recycle pressurization (RP). In FFP the entire
effluent stream is pressurized. In RP a stream of treated water
is drawn from the flotation tank, ranging in volume from 50% to
120% of the effluent stream; this recycle stream is pressurized
and mixed with the effluent as it enters the flotation tank.
Factors that affect the design of a DAF unit include feed solids
concentration, hydraulic loading rate, and particle rise velocity
(14). Air:solids ratios are frequently used to determine the
design criteria for DAF systems. This ratio is defined as the
weight of compressed air used during pressurization compared to
the weight of solids entering the flotation tank (13). Typical
air:solids ratios for DAF units are in the range of 0.005 to 0.1
(11, 13). Higher air:solids ratios can cause floe shearing due
to increased turbulence, resulting in an overall loss of system
efficiency.
The operating variables, air:solids ratio, hydraulic loading
rate, and solids loading rate, have a direct effect on the
performance of a DAF unit. For effective treatment, it is
usually necessary to conduct pilot tests at the particular
laundry before installation of a full-scale DAF unit. Large
variations exist in contaminant loadings and hydraulic loadings
between laundries.
Pretreatment technology using DAF is being practiced at a number
of industrial laundries. Sampling data characterizing the
treatment efficiencies in terms of percent removal by DAF
clarifier were obtained at seven industrial laundries during an
earlier Agency study. These data were presented in the 1982
97
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Guidance Document. They are summarized and presented in this
document in Table 7-3 (percent removals of selected conventional
and nonconventional pollutants and priority pollutant metals) and
Table 7-4 (percent removals of organic priority pollutants) .
During the present EPA sampling program additional sampling data
were obtained at two facilities, both of which had previously
been sampled. The most recent data characterizing DAF treatment
efficiency for these facilities are presented in Table 7-5
(conventional and nonconventional pollutants, and miscellaneous
priority pollutant metals) and Table 7-6 (priority and hazardous
nonpriority organic pollutants) . These data are the results of
two separate days sampling at each facility.
The data obtained during earlier sampling events, shown in Table
7-3, indicate that DAF treatment can be effective in reducing
metals, TSS, BOD5, COD, and oil and grease. The data obtained in
the most recent sampling efforts (presented in Table 7-5) show
removals for the same pollutants that range from lower to much
lower than the average removals obtained during the earlier
sampling program. The removal efficiencies for DAF treatment
obtained during the current study are lower for each of the two
facilities sampled than they were during the earlier study.3 The
most likely reason for lower removal efficiencies is that the
POTWs to which these facilities discharge do not reguire the low
pollutant levels previously attained.
DAF systems are not designed to remove hazardous organic
compounds from the wastewater stream, but two mechanisms may
accomplish an incidental removal of hazardous organics: through
volatilization of many volatile organics, and through flotation
of free or emulsified oil in which are dissolved some volatile
and most semivolatile organics. In a single phase, aqueous
solution, air bubbles formed as dissolved air comes out of
solution would be expected to rapidly and effectively strip
(volatilize) all but the most water soluble volatile organics
from the solution. Laundry wastewater, however, is a two-phase
system (oil and water) in which a large portion of the organics
are selectively dissolved in the oil phase. Stripping of
volatiles will occur but probably at a lower rate and possibly
not to completion in the detention time of the DAF unit. The
presence of large quantities of surfactants may also effect the
volatilization of organic compounds.
Substantial fractions of volatile organics are not air-stripped
and are dissolved in the oil phase of the laundry effluent with
the semivolatile organics and both are removed by the floatation
of the oil and grease. Data are not sufficient to determine
principle removal pathways of specific compounds but the data do
suggest that both volatilization and oil solubilization are
significant removal mechanisms.
3Compare data in Tables 5-6 and 5-7 with data for facilities
D and E presented in Tables A-4 and A-5, respectively, of the
1982 Guidance Document (6).
98
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Data presented in Table 7-4 shows highly variable removals of
specific organic priority pollutants but significant removal of
priority organics taken as a whole. Table 7-6 shows similar
variability in removal of priority and hazardous nonconventional
organics during the recent sampling, with good removals for many
compounds. The removals of priority organics are roughly
comparable to those found earlier, probably in part because
removals of oil and grease are comparable. It is difficult to
quantify effluent quality in terms of priority and hazardous
nonconventional organics because of the variations in specific
hazardous compounds found from plant to plant, the range of
solubilities of those compounds in oil versus water, and the
variations in oil and grease removals from plant to plant.
Sludae Disposal - The floe formed by coagulation and collected in
the DAF unit results in a sludge composed of coagulant chemical
precipitates and pollutants removed from the wastewater. Sludges
from DAF units are typically liquid with a solids content of 5%
to 8% by weight.
Dewatering techniques are used to convert sludge into a more
solid form and reduce the overall volume of solid waste.
Dewatering will usually make handling and disposal of sludges
easier and less costly. Some laundries with DAF currently use
rotary vacuum filters to dewatering sludge. These devices
produce sludge cake with a solids content of between 20% and 30%.
A vacuum filter consists of a cylindrical rotating drum partially
submerged in a vat of sludge. Sludge adheres to the drum surface
which is made of cloth or steel mesh filter. Vacuum imparted to
the inside of the rotating drum draws water from the sludge
through the filter material to the drum interior where it
collects and is either discharged as final effluent or directed
back to treatment. The resulting dewatered sludge (filter cake)
is scraped from the filter and collected. Some laundries with
high solvent concentrations in their effluent have reported that
the resulting sludges are difficult to dewater by rotary vacuum
filtration, but no data are available and the reasons for the
difficulty are not known.
Most laundries operating DAF systems employ outside contractors
for sludge disposal. The contractors use either sanitary
landfills or incinerators but previous site surveys have
indicated that contractors predominantly use sanitary landfills.
However, some laundry sludges have been found to be hazardous as
defined by the Resource Conservation and Recovery Act (RCRA) and
must be disposed of in RCRA approved landfills.
99
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TABLE 7-3
SUMMARY OF REMOVAL EFFICIENCIES FOR COMMONLY MONITORED POLLUTANTS
AT SEVEN INDUSTRIAL LAUNDRIES USING DISSOLVED
AIR FLOTATION1
Pollutant
TSS
BOD5
COD
oil a ad grease
antimony
cadmium
chromium
copper
lead
nickel
zinc
Average
Percent
Removal
(%)
79.7
60.6
67.0
72.3
50.9
95.4
57.1
75.2
93.4
70.0
92.0
Range of
Concentrations
(mf?/i)
390-1,060
1,253-3,600
1,300-7,100
230-1,600
0.025-0.170
0.017-0.110
0.230-1.200
1.00-4.00
3.00-9.40
0.050-0.350
2.00-4.50
Range of
Percent
Removals
(%)
42.0-98.0
33.6-82.1
50.0-77.6
47.2-95.6
0-89.4
86.5-98.2
41.8-99.7
40.1-97.5
40.1-99.8
35.7-100
65.2-97.4
Number of
Facilities
With Data
7
4
6
7
5
6
7
7
7
6
7
1 Data are from 1978 screening program. See 1982 Guidance Document (6), Section 7
and Appendix A.
100
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TABLE 7-4
SUMMARY OF REMOVAL EFFICIENCIES BY DISSOLVED AIR FLOTATION
FOR SELECTED1
ORGANIC PRIORITY POLLUTANTS AT FOUR INDUSTRIAL LAUNDRIES2
Pollutant
dichlorobenzenes
2,4-dimethylphenol
naphthalene
phenol
bis (2-ethylhexyl)phthalate
di-n-butyl phthalate
anthracene/phenanthrene
tetrachloroethene
toluene
ethylbenzene
methylene chloride
isophorone
N-nitrosodiphenylamine
trichloroethylene
benzene
cyanide
Average
Percent
Removal
76
100
82
35
72
79
83
31
20
54
4
100
68
86
0
2
Range of
Influent
Concentration
(ms/i)
1.1
0.46
4.0-4.8
0.098-0.78
1.2-2.6
0.092-0.15
0.38
0.084-0.88
0.36-2.6
0.26-17.5
0.11-0.54
0.19
1.8
0.21
0.13
0.057-0.28
Range of
Percent
Removals
76
100
80-83
0-80
61-82
78-79
83
0-94
0-65
3-100
0-7
100
68
86
0
0-3
Number
of times
Detected
1
1
2
4
2
2
1
3
4
3
2
1
1
1
1
2
1 Pollutants shown here are those found at concentrations greater than 0.05 mg/2 in the
DAF influent.
2 Data are from 1978 screening program. See 1982 Guidance Document (6), Appendix A,
Tables A-l, A-2, A-3, and A-4.
101
-------
TABLE 7-5
SUMMARY OF REMOVAL EFFICIENCIES BY DISSOLVED AIR
FLOTATION FOR SELECTED1 CONVENTIONAL AND NONCONVENTIONAL POLLUTANTS
AT TWO INDUSTRIAL LAUNDRIES
ITD/RCRA SAMPLING PROGRAM2
Average
Percent
Pollutant Removal
calcium
magnesium
sodium
aluminum
manganese
lead*
boron
barium
cadmium*
molybdenum
tin
cobalt
chromium*
copper*
iron
nickel*
titanium
zinc*
mercury*
residue, filterable
residue, non-filterable
cyanide , total*
fluoride
ammonia, as N
nitrogen, Kjeldahl, total
nitrate-nitrite, as N
total phosphorous, as P
BOD- 5 Day (carbonaceous)
chemical oxygen demand
oil and grease,
total recoverable
total organic carbon
sulfide, total (iodometric)
0
57
5
62
74
70
16
65
24
41
77
60
34
59
76
57
49
58
59
10
34
17
17
0
22
38
34
63
50
71
33
4
Range of
Percent
Removals
0
33-79
0-10
40-73
56-91
55-87
0-40
52-78
0-47
20-53
62-100
45-71
27-41
43-71
54-98
42-72
48-66
50-63
55-62
0-24
0-79
0-43
0-35
0
0-89
0-70
0-47
43-81
43-58
66-79
0-59
0-15
Range of
Influent
Concentrations
(ma/i)
14-168
4-35
249-710
4.2-10.4
0.250-1.09
0.372-4.20
0.430-0.568
1.4-1.56
0.042-0.072
0.189-0.300
0.079-0.234
0.200-0.345
0.251-0.835
1.570-2.610
0.850-634
0.099-0.320
0.118-0.213
3 . 130-6 . 250
0.00071-.0013
1000-3400
740-1100
0.17-0.30
16-39
1.1-1.2
12-35
0.21-1.5
15-36
680-1900
3300-5800
410-1200
470-1100
1.3-4.3
Number
of
Samples
3
3
3
3
3
3
3
3
2
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
4
4
4
4
4
* Priority Pollutant
1 Pollutants shown here are those found at concentrations greater than 0.05 tng/2 in the
influent to the DAF clarifier.
2 Data are from 1986 EPA Sampling Program (see Section 5).
102
-------
TABLE 7-6
SUMMARY OF REMOVAL EFFICIENCIES BY DISSOLVED AIR
FLOTATION FOR SELECTED1 PRIORITY AND NONPRIORITY ORGANIC POLLUTANTS
AT TWO INDUSTRIAL LAUNDRIES
ITD/RCRA SAMPLING PROGRAM2
Range of Found in
Pollutant
Volatile Organic
Compounds
tetrachloroethene*
toluene^
ethyl benzene*
acetone
Semi-volatile
Organic Compounds
alpha-terpineol
isophorone*
n-decane
bipbenyl
n-docosane
n-dodecane
n-eicosane
n-octadecane
n-tetradecane
N-nitrosodi-n-
propylamine*
naphthalene"*
p-cymene
styrene
2-chloronaphthalene*
2-methylnapththalene
n-tetracosane
Pesticides /Herbicides
azinphos ethyl
dioxathion
Average
Percent
Removal
100
54
93
73
0
30
77
100
50
45
96
29
80
72
49
50
100
0
67
28
100
95
Range of
Percent
Removal
100
0-82
79-100
0-100
0
0-91
53-100
100
0-100
0-100
96
22-36
45-100
15-100
49
0-100
100
0
67
0-55
100
95
Influent
Concentrations
(m*/£)
58
415-10,292
103-12,396
493-15,831
199
0-8,217
3,481-34,154
1,766
0-6,391
2,141-8,218
2,515
94-846
' 655-111,212
850-14,945
12,963
0-3,464
102
0-4,565
186
1,379-8,351
278
565
Number
of
Samples
1
3
4
4
1
3
2
1
2
3
1
2
3
3
1
2
1
2
1
2
1
1
1 Pollutants shown here are those found at concentrations greater than 0.05 mg/Jt in the
influent to the DAF clarifier.
2 Data are from 1986 EPA Sampling Program (see Section 5).
103
-------
7.2.2 Membrane Filtration
Recent developments in membrane filtration technology have
allowed the successful full scale application of the technology
to industrial laundry wastewaters (15, 16) . In 1982 no known
full scale membrane filtration treatment system was operating in
an industrial laundry. The key to the application of this tech-
nology to the laundries industry has been development of
membranes which can withstand the chemical and physical
environment of laundry wastewaters, and the use of a technique
known as crossflow membrane filtration.
Membrane filtration is used to separate the components of a
pressurized influent stream into two effluent streams by means of
a semipermeable membrane (17,18,19). In crossflow filtration,
the direction of the influent stream flow is parallel to the
surface of the filtering membrane rather than perpendicular, as
in the more familiar barrier type of filtration (20). The normal
construction of the crossflow filter is tubular (see Figure 7-2)
with the influent stream (the wastewater feed) flowing through
the tube under pressure. A fraction of the feed stream consists
of molecules, ions, and particles of low molecular weight which
are small enough to pass through the pores of the membrane. A
large portion of these, water, and water soluble solvents and
solutes, do permeate the membrane forming a stream called the
permeate. The remainder of the feed stream becomes the
concentrate, containing high concentrations of larger molecules,
suspended solids, and colloidal particles which can not permeate
the membrane.
The greatest advantage to operating in a crossflow mode is that
the flow of the feed-concentrate stream tends to prevent the
build up of solids, and oils and greases, which would otherwise
clog the filter and reduce the flow rate to below practical
levels. The feed stream is operated at turbulent flow and
prevents build-up of the concentrating solids on the membrane
surface. The system is thus self-cleaning.
There are three classes of membranes used, leading to three types
of filtration: reverse osmosis (R/0), ultrafiltration (U/F), and
microfiltration (M/F). The principal difference in these
membranes is the size of the pores, which limits the size of the
materials which can pass through the membrane. R/o membranes
have the smallest pores (0.0001 to 0.0015 microns) and can effect
separation of solutes of molecular or atomic weights as low as
100. U/F membranes (pore size 0.0015 to 0.2 microns) allow
permeation of solvents and solutes with maximum molecular weights
of 500 to 300,000 depending on the pore size selected. M/F
membranes (pore size greater than 0.1 micron) can be used to
separate out solutes and particles with molecular weights greater
than 100,000.
The physical-chemical mechanisms by which the three types of
membrane filtration operate are different, and need not be
discussed here. The results of the mechanisms are that R/O
104
-------
operates at highest pressure and lowest flux (rate of passage of
permeate through the membrane in gallons per square foot per
day) , and M/F at the lowest pressure and highest flux rate. U/F
is intermediate between the two. The membrane characteristics
and operating parameters for each type of filtration are
presented in Table 7-7.
R/O is relatively expensive to operate, and it can produce an
effluent free of all but the lowest molecular weight pollutants.
Because R/O systems are expensive to operate, and they produce an
effluent of much greater quality than is necessary for
pretreatment of industrial laundries wastewater, R/O is not used
in the industry, so far as is known (18, 21) . There is little
mention in the literature of the application of R/O to industrial
laundry wastewater, and consequently very little relevant data
are available. Therefore R/O will not be discussed further in
this document.
Microfiltration (also referred to as advanced membrane
filtration) has been used to treat industrial laundries
wastewaters and data are available in the literature (15, 22).
Because M/F can pass relatively large sized pollutants it has
been found necessary to chemically and physically treat the
wastewater before application of M/F. At one industrial laundry
the raw wastewater is chemically conditioned, solids are settled
out, adsorbing or absorbing agents, or both, are added to
aggregate the remaining pollutants before M/F. The result, after
filtration, is an effluent of sufficient quality to recycle or
even possibly to discharge directly to surface waters. M/F
requires considerable preconditioning of the influent wastewater
and, after conditioning, provides pretreated effluent of greater
quality than usually required.
Since 1982, ultrafiltration has been installed in at least
several industrial laundries to pretreat wastewater before
discharge to the sewer. The literature contains some discussion
of this technology (16, 23, 24), but the discussion and available
data appear in conjunction with other technologies (e.g., carbon
adsorption) to produce higher quality effluents than are required
for pretreatment and discharge to a POTW. Wastewater data have
been obtained for one U/F treatment system which is used to treat
wastewater from washers dedicated to washing shop towels and
printers' rags. These data were obtained during the present EPA
study of the industrial laundries industry. The U/F system ob-
served and the related analytical wastewater data obtained during
the recent sampling episode are discussed in the following
section.
105
-------
SEMI-PERMEABLE
MEMBRANE
FEED
I FLOW
CONCENTRATE
1 1 I I i I
PERMEATE
FLOW
FIGURE 7-2
CROSSFLOW MEMBRANE FILTER
106
-------
TABLE 7-7
MEMBRANE FILTRATION CHARACTERISTICS
AND OPERATING PARAMETERS
Type of
Membrane
Microfiltration
Ultrafiltration
Reverse Osmosis
Pore
Size1
(P)
>0.1
0.0015-0.2
0.0001-0.0015
Maximum Particle
Size Passed
Through Membrane
(Molecular Weight)
100,000+
500-300,000
100-500
Operating
Pressure1
(psi)
40-50
50-100
300-400
Flux Rate1
(gal/ft2/d)
200-400
30-75
10-25
1 Data are from Tran, T.V. (15).
107
-------
7.2.3 Ultrafiltration Treatment Technology
As discussed previously, U/F is a crossflow membrane filtration
process which, when applied to industrial laundry wastewaters,
separates the wastewater stream into the permeate stream (which
passes through the membrane) and a stream of concentrated
pollutants (the concentrate). The permeate consists of water and
other low molecular weight solvents and low molecular weight
solutes, ranging from ionized metallic salts to organics,
including some surfactants. The concentrate includes some water
and other low molecular weight substances and relatively high
concentrations of materials rejected by the membrane. These
include suspended solids, emulsified oils, chelatea metal ions,
and a wide variety of organics selectively dissolved in the
emulsified oils.
The key elements of the Ultrafiltration system are the
semipermeable membranes made of strong, relatively inert
polymers. The polymers used for treating industrial laundries
wastewaters must be able to withstand high pH, relatively high
temperatures, and an otherwise harsh chemical environment. They
are generally made from polysulfones or similar, proprietary
polymers. The membranes have a anisotropic pore structure, with
a thin dense layer (less than 1 micron thick) covering a more
porous substructure. The thin layer faces the influent
wastewater stream and has pore openings of 0.05 to 0.1 microns.
The substructure has larger pores.
The membrane is constructed to offer minimum resistance to the
water fraction of the wastewater stream but does not pass
suspended solids and emulsified oils. The pores in the membrane
are, in effect, generally cone shaped; with the smallest opening
facing the wastewater flow. As a result of the membrane
structure, and as a result of operation in a crossflow mode,
large substances, which cannot permeate the barrier, do not plug
the pores or disrupt operation of the system.
An Ultrafiltration unit is manufactured by casting the membrane
inside a porous support tube, which is placed inside a permeate
collection tube. The ends of the tubes are sealed so that the
influent waste steam flows into the center of the tubular
membrane, through the length of the tube, and the remaining
wastes exit as the concentrate stream. The water fraction having
permeated the membrane is contained in the collection tube and
flows from that shell to be collected separately from the
concentrate. Typically the support tube is one-half or one inch
in diameter and five to twenty feet long. An ultrafilter module
consists of some number of these tubular units operating in
series, in parallel, or both.
The principal components of an Ultrafiltration treatment system
capable of adequately treating industrial laundries wastewater
include some method of removing gross solids and lint (either a
settling basin or lint screen), an equalization or collection
basin, some method for free oil removal, process water tank or
tanks, the ultrafilter module, pumps, valves, gauges, and other
108
-------
monitoring equipment. One successfully operating system is
configured as shown in Figure 7-3. Wastewater drains
discontinuously from the washing machines into a collection pit,
and it is pumped through a rotating lint screen, and then drains
into an equalization basin of approximately 8 hours detention
time. Free oil rises to the surface of the equalization basin
and is skimmed from the top. Equalization is necessary to level-
off the wide variations in both temperature and pollutant
concentrations of the effluent from various wash and rinse
cycles.
The wastewater is pumped discontinuously from the equalization
basin into the ultrafiltration module which operates in a
semibatch mode. The water is pumped into the process tank, which
has approximately eight hours detention time. From the process
tank the water is pumped continuously to the ultrafilter, the
permeate from which is discharged continuously to the sewer, and
the concentrate is returned to the process tank for recycle to
the ultrafilter. When the level in the process tank drops below
some preset level, or the level in the equalization basin goes
above a preset level, wastewater is again transferred from the
equalization basin to the process tank. The process is operated,
and concentrate is accumulated in the process tank for a period
of time ranging up to several weeks. Eventually the
concentration of oils and solids in the concentrate becomes high
enough to depress the flux rate through the membrane to a point
where the ultrafilter can not process the wastewater fast enough.
When this occurs, the influent to the process tank is stopped and
the concentrate is "cooked down" (i.e., as much water as possible
is removed) in the ultrafilter for a period of time (usually
overnight). The final concentrate is then removed from the
process tank for disposal, and the cycle is repeated.
Typical removal efficiencies for an ultrafiltration treatment
system are given in the literature (19) in terms of oil and
grease. Concentrate consisting of 40 to 60 percent oil and
grease can be obtained from wastewater containing 1 to 5 percent
oil and grease. The system operates most efficiently on
emulsified oil. Free oil and grease tend to coat the filter
tubes eventually and reduce the permeate flux, but is easily
removed before filtration. The permeate may contain less then
0.005 percent oil and grease. The expected reduction in volume
from influent feed stream to concentrate is 95 to 98 percent.
The BOD5. removal efficiency will vary, depending on the nature of
pollutants present. The total suspended solids removal will also
vary, but the level of suspended solids in the permeate will
always be very low as nonfilterable solids can not pass through
the membrane.
109
-------
COLLECTION
PIT
DISCO
STRAINER
EQUALIZATION
BASIN
FREE OIL
OIL SKIMMER
PROCESS
TANK
WASTEWATER
FROM -
WASHERS
CONCENTRATE
DISPOSAL
lULTRAFILTER
PERMEATE TO
SEWER
FIGURE 7-3
ULTRAFILTER TREATMENT SYSTEM
FOR LAUNDRY WASTEWATER
-------
Table 7-8 presents removal efficiencies for conventional,
nonconventional, and priority pollutants by an U/F treatment
system operated at an industrial laundry during the current EPA
study. It should be noted, however, that the treatment was not
applied to the entire wastewater stream, but only the effluent
generated from laundering shop towels and rags. This portion of
the laundry's effluent contains higher concentrations of most
pollutants than the remaining effluent and over one-half of the
total mass loadings of the pollutants discharged. See Tables 4-1
and 5-12.
The data presented in Table 7-8 indicate the effectiveness of an
ultrafilter in reducing the pollutant loading of laundry
washwater. The ultrafilter operates in conjunction with a lint
screen and an equalization basin with an oil skimmer. As
expected, the system achieves removals of both total suspended
solids and oil and grease that are greater than 99 percent. The
reduction in BOD5 is about 65 percent, and the reduction in COD
is over 80 percent. The percent removals for most metals are
over 75 percent and for the majority are over 95 percent. The
removals for most volatile and semi-volatile organics are over 75
percent and usually over 95 percent. The percent removals of the
remainder of the organics shown in Table 7-8 are zero percent but
many of these were detected in the effluent and had detection
limits in the influent greater than their detected effluent
concentration. The high removals of semivolatile organics are
undoubtedly because of their solubility in oil and grease as
compounds in this size range would otherwise pass through the
ultrafilter membrane. High concentrations of some volatile
organic compounds in the ultrafilter concentrate demonstrate that
these compounds are also removed in this fashion, although
volatilization in the collection pit, the strainer, and the
equalization basin is also to be expected. There are
insufficient data to determine the predominant removal pathway.
The principle design criterion for U/F is the flux or volume of
wastewater passing through the membrane per unit of membrane
surface area per unit time (19). The flux is basically
determined by membrane characteristics. It is an increasing
function of the feed temperature and pressure, and a decreasing
function of the pollutant concentration. Given the flux for
available membranes and the quantity of wastewater to be
processed, the area of membrane and the size of the U/F -system
required, can be determined. The operating pressure is
determined by membrane costs, pumping costs, and other equipment
manufacturing costs, and is usually in the range of 50 to 100
pounds per square inch. The operating temperature is usually the
average discharge temperature of the washwaters.
Much fine tuning may be required to optimize the operation of an
U/F treatment system on laundry wastewaters after the system is
installed, but the most critical factor for continuous
satisfactory operation is proper cleaning of the membranes.
Although operating in the crossflow mode is self-cleaning to a
large degree, build-up of oil and solid particle concentrations
occurs at the membrane surface as water permeates the membrane.
Ill
-------
TABLE 7-8
SUMMARY OF REMOVAL EFFICIENCIES FOR
SELECTED POLLUTANTS1 BY ULTRAFILTRATION
APPLIED TO SHOP TOWEL WASHER WASTEWATER
Day 1
Raw
Waste
Day 2
Percent
Removal
Raw
Waste
Percent
Removal
Volatile Organic Compounds
acetone
chlorobenzene*
ethylbenzene* 36.031
•ethylene chloride* 39.933
tetrachloroethene* 55.516
toluene* **
trans-l,2-dichloroethene* 0.713
trichloroethene*
1,1-dichloroethene* 1.087
1,1,1-trichloroethane- 38.331
2-butanone **
2-chloroethylvinyl ether*
Seal-volatile Organic Compounds
alpha terpineol 16.798
benzidine* 22.436
bis(2-ethyhexyl)phthalate* 9.441
isophorone*
n-decane 30.652
n-hexadecane
n-octadecane
naphthalene* 5.025
o-cresol
p-cy«ene 8.111
4-chloro-3-methyl phenol* ***
100
98
99
0
100
100
99
0
96
100
100
100
92
100
0
1.466
0.142
0.638
3.403
11.594
0.064
0.691
**
0.108
'trlrlc
17.456
22.089
0
100
100
83
75
100
22
0
100
100
100
0
0
-------
TABLE 7-8 (continued)
Day 1
Day 2
u>
Pesticides/Herbicides
endosulfan Sulfate*
EPN
Metals
aluminum
barium
boron
cadmium*"
calcium
chromium*
cobalt
copper
iron
lead*
magnesium
manganese
molybdenum
nickel*
sodium
tin
titanium
vanadium
zinc*
antimony*
silver
Raw
Waste
(mg/£)
Percent
Reraova1
2.152
5.529
19.300
4.
1
.480
.740
0.856
62.000
1.170
0.795
9.070
114.00
20.500
18.500
1.950
1.270
1.610
723.000
0.536
0.574
0.113
13.100
0.213
0.877
100
100
96
99
0
99
86
79
100
99
99
98
98
100
80
95
0
100
100
100
99
0
100
Raw
Waste
(mg/A)
11.300
2.620
0.819
0.365
43.800
0.815
0.319
7.690
65.600
15.400
10.300
1.210
0.369
0.693
827.00
0.808
0.244
0.056
9.480
0.369
Percent
Removal
94
100
0
100
84
79
100
99
99
98
100
100
0
88
21
100
100
100
99
51
-------
TABLE 7-8 (continued)
Day 1
Day 2
Conventional and Other Pollutants
residue, filterable
residue, non-filterable
cyanide, total--
fluoride
ammonia, as N
nitrogen, kjeldahl, total
nitrate-nitrite, as N
total phosphorus, as P
BOD- 5 day (carbonaceous)
chemical oxygen demand
oil and grease
total recoverable
total organic carbon
sulfide, total (iodometric)
Raw
Waste
2,000
4,700
0.110
2.8
1.9
5.0
0.47
1.9
2,200
10,000
4,500
750
NR
Percent
Remova 1
0
100
0
0
100
0
0
0
65
81
100
33
Raw
Waste
(mg/£)
11,000
4,200
0.130
NR
--
4.2
1.4
7.0
2,900
11,000
7,700
1,200
5.8
Percent
Removal
72
100
0
0
69
0
66
82
99
60
43
* Priority pollutant
— Indicates pollutant concentration less than the detection limit or less than
50 pg/£, whichever is greater
NR No data reported due to matrix interference
** Found in the effluent but not detected in the influent
*** Found in the effluent. Detection limit in the influent is greater than the effluent
concentration
1 Pollutants shown here are those found at concentrations of greater than 0.05 mg/£ in
the ultrafilter influent or effluent.
-------
Eventually there is some adhesion to the surface. As particles
aggregate on the membrane surface, a drop in flux rate occurs.
To maintain the flux rate it is necessary to clean the membranes
periodically. Cleaning can be done mechanically by forcing
sponge balls through the membranes under pressure, or chemically
with detergents or solubilizing agents, or some combination of
these three methods. The frequency of cleaning (usually once or
twice per week) and the methods used will depend on the nature of
the wastewater being treated.
The end result of ultrafiltration treatment is two streams. One
is a high quality permeate stream containing water, sundry ionic
pollutants, and relatively low molecular weight organic
pollutants. The permeate of the laundry sampled during the
current study was well within limits acceptable to the POTW. The
second stream, the concentrate, is two to five percent of the
treated wastewater in volume. The concentrate consists of solids
(lint and other fine particles) and an oil-water emulsion. The
literature reports that concentrations as high as 40 to 60
percent oil can be obtained in the concentrate. The laundry
sampled during this study reports that their concentrate contains
about 50 percent water, 25 percent oil, and 25 percent solids,
but analyses of samples collected by EPA were found to have much
lower percentages of oil and solids (3 percent oil, 6 percent
solids; see Table 5-12).
The permeate from treated laundry wastewaters can be discharged
to the sewer, but the concentrate must be disposed of otherwise.
The concentrate from the laundry sampled is considered to be a
hazardous waste and is disposed of by a contract hauler. It has
been landfilled in the past, but the considerable cost of
disposing of hazardous wastes by landfill has induced the laundry
to attempt to break the oil-water emulsion into separate oil and
water fractions. When this is done the considerable water
fraction need not be hauled away as a hazardous waste. It can
probably be returned to the treatment system. Breaking
(generally called cracking) the emulsion can be accomplished by
mixing the emulsion with a strong acid. If the crack is
successful the emulsion will divide into an oil fraction and a
water fraction (and probably, in the case of laundry wastewater,
also a solids fraction) . The facility has not yet found an
entirely satisfactory method of cracking the emulsion. By
separating the water fraction, disposal costs will be reduced;
less volume will have to be transported, and probably the oil-
lint fraction can be incinerated, a less costly disposal method
than landfilling.
115
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ECONOMIC IMPACT ANALYSIS
116
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SECTION 8
8.0 INTRODUCTION TO THE ECONOMIC IMPACT STUDY
Sections 8 through 11 of this document present an outline and the
results of a study of the economic characteristics of the
industrial laundries industry. The purpose of the study was to
determine the economic health of the industry and the likely
economic impact on the industry of governmental regulations on
industrial laundries wastewater discharge.
8.1 Introduction
This industry profile and preliminary economic impact analysis is
divided into four sections:
o Section 8 provides an introduction and a brief review of vthe
goods and services provided and the processes employed by
the industry.
o Section 9 describes the characteristics of and recent trends
in the industry. Section 9.1 describes the number of firms
and establishments. Section 9.2 presents data on industry
revenues. Section 9.3 discusses employment and wages in the
industry. Section 9.4 presents data on revenues per
employee, a measure of productivity in the industry.
o Section 10 presents financial characteristics of firms in
the industry, and analyzes the potential impacts on
industrial laundry profits of a requirement for an
ultrafiltration pretreatment system for laundry wastewater.
o Section 11 describes influences on the industry, including
competition, the availability of substitute goods and
services, and environmental regulation.
There were approximately 1,200 industrial laundry establishments
in the United States in 1985 (26, 1985, 1986), owned by 800 firms
(27), with total employment of approximately 55,000 (largely
unskilled and semi-skilled laborers) (26, 1985, 1986). Total
1985 industry revenues were approximately $2.4 billion (27; 26,
1985, 1986), and total wages paid out equalled about $800 million
(26, 1985, 1986).
The industrial laundries industry has grown very little in the
past 25 years. Revenue growth has been only about 1 percent per
year (in constant dollars). Because new entrants have joined the
industry, revenues per establishment have actually declined. The
industry has contracted along with America's industrial base in
the Northeast and Midwest, and has expanded only in a few states
in the South and West.
8.2 Nature of Laundry Services and Processes
The industrial laundries industry provides goods and services to
commercial and industrial customers in three primary areas:
117
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o Clean work apparel (uniforms and other work clothes).
o Shop towels and wiping cloths.
o Floor mats and dust mops.
The industry engages primarily in rental service. Articles are
owned by the industrial laundry firm and rented to its customers.
On a regular schedule, the industrial launderer delivers cleaned
articles to each client firm and picks up soiled articles and
returns them to his plant for laundering.
Historically, the industry's primary customer base has been among
manufacturing industries, particularly those associated with the
automobile (including auto service stations and dealerships).
However, the industrial laundry clientele has mirrored the
gradual shift in the American economy away from heavy industry
and toward service-based commercial and light industrial
concerns. Today more than 40 percent of the garments rented by
the industry are placed in commercial and industrial environments
not subject to heavy soil conditions (28, p. 11).
The industry relies primarily on water-based cleaning techniques.
Through the early 1970s, dry cleaning technologies were also
heavily employed in the industry, but their use has declined
rapidly in the past decade. Although the industry has witnessed
the partial or complete automation of many processes, it remains
relatively labor-intensive, relying on unskilled or semi-skilled
laborers to perform the relatively routine tasks associated with
the laundering process.
This section provides an overview of the goods and services
provided by the industrial laundry industry and of the laundering
processes it employs. Section 8.1 describes the three classes of
articles which are the industry's major products (garments, shop
towels, and dust control articles). Section 8.2 provides a brief
description of the cleaning processes employed. Both sections
provide information on recent trends within the industry.
8.2.1 Services Provided. Table 8-1 shows the distribution of
revenues from the major classes of goods and services provided by
the industrial laundries industry in 1985. Table 8-2 provides
additional information on some of the minor industry revenue
sources in 1982.
More than half of 1985 industry revenues were earned by garment
rental and laundering services. Floor mats and dust mops and
cloths accounted for approximately 14 percent of revenues, while
shop towels and wiping cloths contributed nearly 10 percent of
revenues. Additional revenues are provided by the direct sale of
garments and other goods (5 percent) and by miscellaneous
services such as rental and laundering of linens, miscellaneous
commercial laundering and dry cleaning, rug and carpet cleaning,
and others. Tables 8-3 and 8-4 show the growth rates of the
major industrial laundry market segments from 1978 through 1984.
118
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Growth has been relatively even across these categories; the only
market segment which has consistently grown faster than the
industry average is the floor mat category, which has grown to
account for over 10 percent of 1985 industry revenues.
8.2.2 Processes Employed. This section provides only a very
brief overview of the cleaning processes employed by industrial
launderers. More complete information has been presented in
Section 3 of this report.
Two basic processes (water washing and dry cleaning) account for
nearly 95 percent of the poundage washed by industrial
launderers. A third process (dual-phase laundering) combining
both water wash and solvent wash (dry cleaning) cycles, is used
on less than 5 percent of industrial laundry volume. A fourth
nonaqueous process may be employed to clean and treat dust mops
in an oil bath, the residue of which retains dust collected on
the mops.
Materials to be laundered are sorted into batches to receive
similar processing. The laundering process consists of a series
of wash cycles separated by rinses. The washes employ different
combinations of detergents, pH, temperature, and agitation,
depending on the nature of the garments and soils. After
washing, most garments are finished by means of automatic or
semi-automatic steam saturation and air drying processes. Shop
towels, dust cloths, and floor mats are finished by tumble drying
and folding.
Most of the labor involved in the industry is related to sorting
of articles before and after the wash cycles and to transferring
batches of articles among machines. The most modern equipment
has automated virtually the entire wash process, but the industry
has been relatively slow to take advantage of modernization and
automation.
Water washing is by far the dominant process employed by
industrial laundries, accounting for over 80 percent of the
volume of articles washed. Dry cleaning follows many of the same
steps as water washing, but articles are cleaned in an organic
solvent instead of an aqueous detergent solution. Dry cleaning
accounts for 10 to 15 percent of the poundage cleaned by
industrial launderers, and this proportion is decreasing.
119
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TABLE 8-1
DISTRIBUTION 01 REVENUE FROM INDUSTRIAL LAUNDRY
PRODUCTS AND SERVICES, 1985l
Percent of 1985
Product/Service Industry Revenues
Garment Rental and Laundering 52.6
Shop Towels 9.4
Mats 10.5
Dust Mops/Cloths 3.7
Direct Sale of Garments, Mats, etc. 5.0
Other Products/Services (including Linens) 18.8
1 Data only from member firms of the Institute of Industrial Launderers
Source: Institute of Industrial Launderers (28)
120
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TABLE 8-2
PERCENT DISTRIBUTION OF RECEIPTS
FROM MAJOR SOURCES IN 1982
Percent of
Source Total Revenues
Coin operating laundry and dry cleaning (store) 1
Drycleaning work (except coin operated, 1
industrial, and rug)
Family and bachelor laundry work 1
Commercial laundry work 1
Industrial laundry/dry-cleaning work
and rental
Garments 60
Wiping cloths and dust control materials 24
Laundry work and rental
Linen garments and full dry linens 3
Linen flatwork 5
Carpet and upholstery cleaning 1
Sales of disposables and other merchandise 3
Other sources 2
TOTAL 100
Total Number of Establishments: 1,288
Total Value of receipts: $1,895 million
Source: 1982 U.S. Census of Service Industries, Industry Series, U.S.
Department of Commerce
121
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TABLE 8-3
INDUSTRIAL LAUNDRY MARKET SEGMENT
REVENUE GROWTH RATES, 1978 TO 19841
Market Segment
Garments
Shop Towels
Floor Mats
Dust Mops
1984*
%
12
17
17
7
.8
.4
.1
.6
1983
%
7.4
5.9
9.6
6.9
1982
%
6
6
16
9
.1
.1
.4
.0
Year
1981
%
8.1
8.4
18.5
8.8
1980
%
9
15
26
14
.2
.3
.7
.3
1979
%
16
18
21
16
.6
.7
.8
.1
1978
%
14.4
11.5
17.8
5.7
and Cloths
Direct Sale 10.5 9.2 1.9 14.1 11.4 17.2 18.2
and Other
Total 12.9 7.9 6.1 10.5 11.8 17.3 14.9
GNP Price Deflator 3.8 3.9 6.4 9.7 9.0 8.9 7.3
1 Growth rates expressed in current year, or inflated, dollars
Data from member firms of Institute of Industrial Launderers only
2 1984 growth rate is estimated based on preliminary data
Source: Institute of Industrial Launderers (28, 29), and EPA estimates based
on raw data presented in these documents.
122
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TABLE 8-4
INDUSTRIAL LAUNDRY MARKET SEGMENT
REVENUES AND GROWTH, 1978 TO 1985
Tear
Market Segment
Industry Revenues
Garments
Shop Towels
Floor Mats
Dust Mops
and Cloths
Direct Sale
and Other
Total
Share of Revenues
Garments
Shop Towels
Floor Mats
Dust Mops
and Cloths
Direct Sale
and Other
1985
1984
1983
1982
1981
1980
1979
1978
by Market Segment
1,288
230
257
91
583
2,449
1,142
196
220
84
527
2,169
1,063
185
200
79
483
2,011
1,002
175
172
72
474
1,895
927
161
145
66
415
1,715
849
140
115
58
372
1,534
728
118
94
50
318
1,308
637
106
80
47
269
1,138
by Market Segment
52.6%
9.4%
10.5%
3.7%
23.8%
100%
52.6%
9.0%
10.1%
3.9%
24.3%
100%
52.9%
9.2%
10.0%
3.9%
24.0%
100%
52.9%
9.2%
9.1%
3.8%
25.0%
100%
54.1%
9.4%
8.5%
3.9%
24.2%
100%
55.4%
9.1%
7.5%
3.8%
24.3%
100%
55.7%
9.0%
7.2%
3.8%
24.3%
100%
55.9%
9.3%
7.0%
4.2%
23.6%
100%
Note: 1978 to 1981 growth rates are ERG estimates
Source: Institute of Industrial Launderen (28, 29), and EPA estimates based
on raw data presented in these documents.
123
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SECTION 9
9.0 INDUSTRY CHARACTERISTICS AND TRENDS
The most recent, relatively comprehensive, collection of
statistics for this industry was published in the 1982 Census of
Service Industries (12). Some data on employment, payrolls, and
establishment size are published annually in the U.S. Census
Bureau's County Business Patterns series, and additional data are
collected by the industry's trade association (the Institute of
Industrial Launderers, or IIL). The picture that emerges from
these data is of a small, relatively static industry, which has
exhibited little growth over the past 20 years.
9.1 Number and Size of Firms and Establishments
In 1982 the U.S. Census Bureau reported that 1,288 industrial
laundry establishments were in operation in the United States.
These are owned by approximately 800 firms (27).
Figures 9-1 and 9-2 display the distribution of firms by size
class in 1982. The mean size of all firms in the country in 1982
was 64 employees; mean revenues per firm were approximately $2.3
million. As Figures 9-1 and 9-2 show, however, these averages
are skewed by the presence in the industry of a small number of
very large firms. The industry is actually characterized by the
existence of a large proportion of relatively small firms. For
example, 44 percent of all firms generated 1982 revenues of less
than $500,000, and 63 percent generated revenues of less than $1
million. Only 16 percent of all firms generated revenues greater
than $2.5 million. Similarly, over a quarter of all firms
employed less than 10 employees, and nearly half employed less
than 20 employees. (Large firms, however, are responsible for
the bulk of revenue generation and employment in the industry
[see Section 9.2]).
The mean size of all industrial laundry establishments in 1982
was 40 employees (Figure 9-3); mean revenues were approximately
$1.5 million per establishment (Figure 9-4). Again, these data
mask the significant numbers of small establishments in the
industry; over 40 percent of all establishments had less than 20
employees, and over half generated revenues of less than $1
million per year.
Industrial laundry establishments are concentrated in the
nation's metropolitan areas, and exhibit significant regional
clustering. California and Texas contain 11.5 percent and 9.7
percent of all establishments, respectively (Figure 9-5). Six of
the next seven states (New York, Ohio, Illinois, Michigan,
Pennsylvania, and Indiana) are in the industrialized Northeast
and Midwest. Between them, the top nine states (including
Florida in addition to those above) account for approximately 53
percent of all establishments.
9.1.1 Trends. Between 1967 and 1982, the number of
establishments in the industry grew from 918 to 1,288 (28).
124
-------
(Comparisons with 1985 data are not valid because data were
collected by different agencies.) This growth was not uniform
across the country, however. Figure 9-6 displays the number of
establishments by EPA region for the years 1967, 1972, 1977, and
1982. EPA Regions 1 and 2 accounted for almost 20 percent of all
establishments operating in 1967 (175 out of 901) , but have
experienced virtually no growth since then. Regions 4 and 9
accounted for the bulk of industry growth from 1967 to 1977,
while Regions 5 and 6 also witnessed rapid expansion in the
number of establishments from 1977-1982.
125
-------
220
o
a
3-9
10-19 20-±9 50-99 100-2*9 250-499 500-999 > 1.000
FIRM SIZE (N OF EMPLOYEES)
MEDIAN SIZE = 64 EMPLOYEES
Source: O.S. Census Bureau 1982
Figure g_i Number of industrial laundry firms by firu employment, 1982,
126
-------
u.
o
a
<100 >!00 >250 >500 >1,000 >2.500 >5.000 >IO,000 > 23,000 >50,000
REVENUES PE^ FIRM (51,000)
MEAN REVENUE = $2.3 MILLION
Source: U.S. Census Bureau 1932
Figure 9-2- Number of industrial laundry firms by firra revenues, 1982
127
-------
I
I
u_
o
£
350 -
300 -
250 -
200 -
150 -
100 -
50 -
3-*
5-5
7-9
10-14. 15-19 20--I-9 50-99
MOO
SIZE CLASS (NUMBER OF EMPLOYEES;
MEAN = 40 EMPLOYEES
Source: U.S. Census Bureau 1982
Figure 9.3 Number of industrial laundry establishments by establishment
employment, 1932.
128
-------
I
1
s
350
300 -
250 -
200 -
150 -
100 -
50 -
F771
Kb
<25 <50
<100
~~^— ~"i ' •-•
5,000
ESTABLISHMENT SIZE (REVENUES * SI,000)
MEAN =51.5 MILLION
Source: U.S. Census Bureau 1982
Figure g_4-
Number of industrial laundry establishments by establishment
revenues, 1982.
129
-------
I
ISO -
1*0 -
130 -
120 -
no -
100 -
90 -
ao -
70 -
60 -
30 -
40 -
30 -y
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STATE
Source: Q.S. Department of Commerce 1985, 1986
Figure 9-5 Number of industrial laundry establishments by state, 1985,
130
-------
V)
U
u_
o
£
280
2SO -
2*0 -
220 -
200 -
180 -
160 -
1*0 -
120 -
100 -
80 -
60 -
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20 -
0
^
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ks^l
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tXN
^
1367
EPA RESIQN
1972 1377
(i
^8
10
1982
Source: Industrial Laundry Industry and its Markets (29), based on U.S
Census Bureau, Census of Service Industries
Pigure 9-6 Number of industrial laundry establishments, 1967-1982,
131
-------
Figure 9-7 (based on a consistent series of County Business
Pattern data) plots the percent of all establishments in each of
eight size classes for 1978, 1982, and 1985. There have been no
discernible trends over the eight years represented.
9.2 Industry Revenues
Industrial laundries generated revenues in 1982 of approximately
$1.9 billion. In 1985 revenues were $2.4 to $2.5 billion (27;
26, 1985, 1986). Although the large majority of firms and
establishments in the industry are small (see Section 9.1),
larger firms/establishments generate the majority of revenues in
the industry. For example, the 2 percent of all firms with 1982
revenues greater than $25 million per firm accounted for nearly
40 percent of industry revenues (Figure 9-8).
A similar concentration of revenue generation is apparent in data
on individual laundry establishments (Figure 9-9). Over -55
percent of total 1982 revenues were generated by establishments
with revenues greater than $2.5 million; 66 percent of industry
revenues were generated by the 369 establishments (29 percent of
all establishments) with 50 or more employees (27).
9.2.1 Trends. In constant (1982) dollars, industry revenues
grew by only 14 percent between 1967 and 1982, from $1.66 billion
to $1.90 billion (29, based on U.S. Census Bureau, Census of
Service Industries for 1967, 1972, 1977, and 1982). Revenue
growth was thus less than 1 percent per year. Revenue growth has
apparently been higher since 1982, approximately 8 percent per
annum in nominal terms (26, 1982, 1986). This estimate relies on
the comparability of data from the 1982 Census of Service
Industries and that from the annual County Business Patterns. In
fact, comparability is uncertain because different methodologies
are used in the two documents.
Revenues contracted in four EPA regions in the Northeast (EPA
Regions 1 and 2), Mid-Atlantic states (Region 3), and Midwest
(Region 5) from 1967 through 1982, although the Midwestern states
(Region 5) continued to lead the industry in terms of total
revenues generated (Figure 9-10). Significant growth in revenues
occurred only in the Southeast (Region 4), the West South Central
states, particularly Texas (Region 6), and in California (Region
9).
Because the number of establishments in the industry grew at a
faster rate than revenues between 1967 and 1982, revenues per
establishment (in constant 1982 dollars) declined noticeably
during these years. Nationally, revenues per establishment
declined nearly 20 percent, from $1.81 million in 1967 to $1.47
million in 1982 (Figure 9-11). Nearly all regions of the country
were affected by this trend. Most affected was EPA Region 1,
where revenues per establishment declined by over 50 percent.
Region 8 was the only region to buck this trend; this region also
had, by far, the lowest revenues per establishment throughout the
period 1967 to 1982.
132
-------
1-4.
5-9
10-19
20—4.9
30-99 100-24.9 250-4.99
>500
I97H
EMPLOYEES
13a2
1985
Source: U.S. Department of commerce, County Business Patterns, 1978. 1982,
and 1985
Figure 9-7
Number of industrial laundry establishments by establishment
employment, 1978-1985.
133
-------
s
400
330 -
300 -
250 -
200 -
150 -
100 -
50 -
•000 >IOO
>250 >500 > 1.000 >2.500 >5.000 >10.000 >25,000 >:Q.OOO
RRM SIZE (RSCEPTS • 51,000)
Source: U.S. Census Bureau 1932
Figure 9.3 Total industrial laundry receipts by firm revenues, 1982
134
-------
fe!
11
aoo
700 -
~ 600 -
300 -i
300 -
200 -
100 -
7
V /> /\
/]
<25
<50 <100
ES^aUSHMENT SIZE (RECEIPTS • Si,000)
i i
<«00 <1,000 <2.500 <5.000 >5.000
Source: U.S. Census Bureau 1982
Figure g_g Total industrial laundry receipts by establishment revenues,
1982.
135
-------
430
g
I
1967
1972
EPA REGION
1977
1932
Source: Industrial Laundry Industry and its Markets (29), based on U.S.
Census Bureau, Census of Service Industries
Figure 9-10 Industrial laundry revenues (constant dollars), 1967-1982,
136
-------
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9.3 Revenues bv Market Segment
Rental and laundering of garments accounted for over 50 percent
of industrial laundry revenues in 1985 (Table 8-1). Floor mats
contributed 10.5 percent to revenues, shop towels 9.4 percent,
and dust mops and cloths 3.7 percent. Direct sales of garments,
floor mats, and other items accounted for 5 percent of revenues,
while miscellaneous other services (e.g., linen rental and
laundering) accounted for approximately 19 percent of revenues
(28)
9.3.1 Trends. Table 8-4 presents approximate industry revenues
by market segment for 1978 through 1985. The distribution of
revenues by market segment has remained fairly constant over this
period; the market share for garments has declined by a few
percent, and only the floor mat category has exhibited
significant growth. The values in Table 8-4 are in current year
(inflated) dollars, and thus do not reflect real revenue growth.
Also, these data are from member firms of the Institute of
Industrial Launderers, which may over-represent the larger and
more successful firms in the industry.
9.4 Employment and Wages
Total 1985 employment by industrial laundries nationwide was
approximately 54,000 workers (including management and clerical
employees) (26, 1985, 1986). The total industry payroll was
approximately $800 million (26, 1985, 1986). The mean salary in
the industry was approximately $14,800. There is very little
part-time employment in this industry (30).
Figure 9-12 displays industrial laundry employment by state.
Texas and California each account for over 11 percent of all
industry employees. Employment is also concentrated in New York,
Pennsylvania, Florida, Ohio, Illinois, Michigan, and Indiana.
Between them, these top nine states account for 57 percent of
total industry employment. With the exception of California and
Texas, Figure 9-12 reflects again the concentration of the
industry in the heavily industrialized states running from New
York and Pennsylvania west to Illinois.
Total industry employment reflects the dominance of larger firms
and establishments in the industry. For example, while firms
with less than 20 employees include almost 45 percent of all
firms in the industry, they account for only 6 percent of
industry employment. The 37 percent of all firms with revenues
over $1 million account for over 86 percent of industry
employment. For individual establishments, the 20 percent of all
establishments with receipts over $2.5 million account for over
50 percent of industry employment.
Census Bureau data indicate that payroll equals approximately 35
percent of receipts for all industrial laundry establishments.
There is no consistent trend in these data related to
establishment size.
138
-------
7 -
6 -
5 -
4. -
3_
2 -
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1 i i t i 1 1 i i 1 i i i i * TT I i i
STATE
Source: O.S. Department of Commerce 1985, 1986
Figure 9-12 Total industrial laundry employment by state, 1985.
139
-------
9.4.1 Trends. As noted, employment in 1985 was reported at
54,000. The employment total in 1967 was 45,000. The industry
thus exhibited an annual growth rate in employment of only
approximately 1 percent per year for the period 1967-1985.
Again, these national data mask considerable regional variation.
Employment remained nearly stagnant or contracted in the
Northeast, Mid-Atlantic states, and Midwest (EPA Regions 1, 2, 3,
and 5) (Figure 9-13). Most employment growth in the industry
occurred in EPA Region 4 (where growth occurred throughout the
region), Region 6 (particularly in Texas and New Mexico), and
Region 9 (particularly in California).
9.5 Revenues Per Employee
Revenues per employee may serve as a very crude indicator of the
efficiency of production in the industry; better indices of
productivity are pounds processed per operator-hour or garments
processed per operator-hour (28). Revenues per employee are the
only data readily available on productivity in this industry,
however, and provide some insight into industry characteristics
and trends.
Figures 9-14 and 9-15 plot revenues per employee against
establishment size. A clear trend toward increasing revenues per
employee with increasing establishment revenues emerges from the
data (Figure 9-14). No such trend is apparent when firm size is
plotted as number of employees (Figure 9-15). One inference
which may be drawn from these results is that those large
establishments responsible for the trend discernible in Figure 9-
14 are achieving significant revenue gains without adding large
number of staff (i.e., that significant productivity gains can be
achieved within this industry) but that many large establishments
(in terms of employment) have opted not to invest, or do not have
the resources to invest in productivity-increasing expenditures.
9.5.1 Trends. Both nationally and in individual regions, there
is no clear trend in these data (Figure 9-16); certainly there
has been no increase in revenues per employee. This result may
be related either to the fact that no productivity increases have
been achieved in the industry, or that productivity increases
have been entirely consumed by cost competition. Given the
evidence that there has been a continual addition of new entrants
into this essentially stagnant industry, the latter
interpretation appears likely to be correct.
140
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Source: Industrial Laundry Industry and its Markets (29), based on U.3,
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Figure g_i3 Industrial laundry employment, 1967-1982,
141
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Figure 9_j4 Industrial laundry revenues per employee, by establishment size
(revenues), 1982.
142
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Source: U.S. Census Bureau 1982
Figure 9-15 Industrial laundry revenues per employee, by establishment size
(n of employees), 1932.
143
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SECTION 10
10.0 ECONOMIC INFLUENCES ON THE INDUSTRIAL LAUNDRY INDUSTRY
Major influences on the industrial laundries industry are
competition, availability of substitute goods and services, and
environmental regulation. These are discussed in this section.
10.1 Competition
The industry has witnessed some growth in the number of
establishments competing for a market which has itself exhibited
little growth. The clear implication is that there must exist
increasing competition for a stable customer base.
The industry's traditional primary markets, garments and shop
towels, have not grown significantly in the past 20 years. In
the garment market segment, contraction of the market among heavy
soil industrial establishments has been offset by the growth of
the market among light soil commercial and light industrial
environments, but the net effect has been essentially a flat
market. The shop towel market has exhibited no clear trend in
recent years; certainly this market segment has not been growing.
The only market segment which is experiencing significant growth
is that for floor mats, which now account for over 10 percent of
industrial laundry revenues (28).
Regionally, competition has been and remains intense in the
Northeast and Midwest, where industrial laundry firms are
competing for shrinking markets in their traditional heavy soil
markets. Only California and Texas have witnessed significant
revenue growth since 1967 (and one may assume that the Texas
market has stabilized or contracted with the collapse of the oil
industry there since 1982).
The industry has responded to increased competition mainly
through price-cutting. Price cuts have apparently been achieved
at the expense of profits and quality, since there is little
evidence that productivity has increased significantly (28).
10.2 Availability of Substitute Goods and Services
Although some industrial laundry clients have moved toward
ownership and in-house cleaning of the traditional industry
laundry rental products, it does not appear that this trend poses
a significant threat to the industry. Industrial laundries
provide a service unrelated to their clients' own lines of
business. They employ equipment and provide services much more
efficiently than their clients could hope to if they did their
own laundering in-house (28).
The one market segment in which substitute goods may replace
industrial laundry goods and services is the shop towel market.
Disposable, non-woven alternatives are currently available. The
industry trade association has expressed concern that the
availability of alternatives, coupled with fear of liability for
145
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environmental damage or potential environmental regulation of
this heavy soil market segment, or both/ may diminish the size of
this market (28).
10.3 Environmental Regulation
Environmental regulation has already had a significant impact on
this industry, since it has resulted in the virtual elimination.
of dry cleaning as an industrial laundering process. It appears
unlikely that environmental regulation would pose a serious
threat to the industrial laundry garment market, since there is
no apparent replacement for work uniforms in heavy soil
environments, and since much of the industrial laundry garment
volume now comes from light soil environments from which heavily
contaminated wastewaters are not a concern. One can envision
scenarios, however, in which environmental regulation of
launderers (resulting in higher prices), might cause some large
customers with wastewater pretreatment systems already installed
to move toward in-house laundering of soiled garments.
As noted above, environmental regulation is of concern to the
industry in that it may reinforce a movement to develop cost-
effective, disposable substitutes for laundered shop towels in
heavy soil environments.
146
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SECTION 11
11.0 FINANCIAL CHARACTERISTICS OF INDUSTRIAL LAUNDRIES AND ECONO
MIC IMPACTS OF PRETREATMENT SYSTEM INSTALLATION AND OPERATION
This section describes the financial characteristics of
industrial laundry firms and presents the estimated impact on
firm profits of a requirement for ultrafiltration as a wastewater
pretreatment system. Section 11.1 presents data on financial
characteristics; Section 11.2 presents an analysis of the
economic impacts of pretreatment system installation and
operation on firm profits for three model industrial laundry
plant sizes.
ll.l Financial Characteristics of the Industrial Laundries Indus
try.
Several primary and secondary sources were consulted to locate
data on the financial characteristics of this industry. Because
of the industry's small size, it is omitted from most public
compilations of industrial financial data (e.g., Internal Revenue
Service data on industry income and profits). Private data
sources (e.g., Robert Morris Associates 1987 [31], Dun and
Bradstreet 1987 [32], Troy 1987 [33]) provide, at best, only
summary data on the financial characteristics of firms in this
industry.
For a 1981 analysis of the financial characteristics of the
industry, EPA solicited and received industry financial data from
the Institute of Industrial Laundries (IIL), the industry trade
association. The IIL supplied summary financial data gathered
from the voluntary submissions of over 100 industrial laundry
firms. For the current analysis, IIL was asked to estimate the
level of effort required to duplicate the data set provided for
the 1981 EPA analysis. Based on their response, IIL was not
asked to provide the same type of detailed industry data for this
preliminary analysis that was compiled for the 1981 EPA analysis
(34).
The financial data on which the current analysis is based are
derived from Dun and Bradstreet's
Industry Norms and Key Business Ratios(32). These data are based
on a sample of 88 firms out of the approximately 800 in the
entire industry. Dun and Bradstreet provide no information to
indicate whether these firms are representative of the entire
industry; based on sales volume, however, the mean firm size in
the D&B sample is very nearly that estimated using Department of
Commerce data on industry revenues (26, 1985, 1986). The D&B
data provide a balance sheet and summary income statement which
reflect the mean of all industrial laundry firms in D&B's
database, as well as selected business ratios (liabilities:net
worth, assets:sales, etc.).
Table 11-1 presents a summary balance sheet and income statement
for the 88 firms in the D&B database. Table 11-2 presents 10 key
business ratios for these firms; it presents the ratios
147
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TABLE 11-1
CONSOLIDATED BALANCE SHEET AND INCOME STATEMENT
FOR 88 INDUSTRIAL LAUNDRY FIRMS
Assets
Cash
Accounts Receivable
Notes Receivable
Inventory
Other Current Assets
Total Current
Fixed Assets
Other Long-Term Assets
TOTAL ASSETS
Liabilities and Net Worth
Accounts Payable
Bank Loans
Notes Payable
Other Current Liabilities
Total Current Liabilities
Long Term Liabilities
Deferred Credits
Net Worth
Liabilities Plus Net Worth
Net Sales
Gross Profit
Net Profit After Tax
Dollars
Percent of
Category
Balance Sheet
63,927
140,346
5,878
96,993
56,579
363,723
124,915
246,156
734,794
60,988
8,083
28,657
106,545
204,273
132,263
1,470
396,789
734,795
Condensed
Dollars
1,400,000
665,000
78,400
8.7
19.1
0.8
13.2
7.7
49.5
17.0
33.5
100.0
8.3
1.1
3.9
14.5
27.8
18.0
0.2
54.0
100.0
Income Statement
Percent
of Sales
100.0
47.5
5.6
Source: Dun & Bradstreet 1987
148
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TABLE 11-2
SELECTED FINANCIAL RATIOS FOR 88 INDUSTRIAL LAUNDRY FIRMS
Upper Lower
Quartile Median Quartile
Ratio '_& % %
Quick Ratio [1] 1.7 1.1 0.7
Current Ratio [2] 3.5 1.9 1.2
Current Liabilities / Net Worth 15.6 35.8 77.0
Total Liabilities / Net Worth 21.8 60.8 126.8
Assets / Sales 37.8 58.3 70.1
Sales / Net Working Capital 13.1 6. A 3.7
Accounts Payable / Sales 2.5 3.6 6.0
Return on Sales (After Tax) 9.2 A. 6 1.2
Return on Assets (After Tax) 11.7 6.9 2.0
Return on Net Worth (After Tax) 29.7 16.1 A.5
Notes:
[1] Cash + Accounts Receivable / Current Liabilities
[2] Current Assest / Current Liabilities
Source: Dun & Bradstreet 1987
1A9
-------
applicable to the median firm in the D&B database and to the
firms at the upper and lower quartile of the D&B sample for each
ratio. A review of the following business ratios provides
insight into the financial condition of this industry.
11.1.1 Quick Ratio. Current Ratio. The quick ratio expresses
the ratio of the most liquid current assets (cash and accounts
receivable) to current liabilities; the current ratio expresses
the ratio of all current assets (including notes receivable,
inventories, and other current assets) to current liabilities.
Both ratios provide an indication of a firm's ability to cover
current liabilities with current cash and near-cash assets. The
lower quartile quick ratio of 0.7, and lower quartile current
ratio of 1.2 reflected in Table 11-2 indicate that many firms in
this industry operate on very slim margins of current income over
current liabilities. Although this is a characteristic of many
firms in high-volume, quick-turnaround industries, the lower
quartile values for industrial laundries are extremely low, and
suggest that for a significant fraction of laundries any
diminution of cash flow might pose a serious threat to the firm's
ability to meet the demands of short-term creditors.
11.1.2 Current Liabilities to Net Worth. Total Liabilities to Ne
t Worth. These ratios compare the resources extended to the firm
by its creditors with the capital invested by the firm's owners.
High ratios indicates that the firm is heavily reliant on loans
or trade credit or both for continuing operations, and signal
that additional credit may be difficult to obtain. There is a
great disparity when comparing the ratios of the median firm in
the industry (current liabilities/net worth equal 36 percent;
total liabilities/net worth equal 61 percent) and the firm at the
lower ,quartile (current liabilities/net worth equal 77 percent;
total liabilities/net worth equal 127 percent). Again, the
ratios for the firm at the lower quartile suggest that a
significant proportion of firms in this industry are already
heavily in debt to outside creditors, and that additional
financing (e.g., to cover the cost of pollution control
equipment) may be difficult to obtain.
11.1.3 Return on Sales. This ratio provides a basic measure of
the rate of profit generation by the firm. Again, more revealing
than the absolute value of these figures (which may vary widely
from industry to industry) is the size of the spread between the
median and the quartile firms in the industry. Twenty-five
percent of all firms in the industry earn a profit after taxes of
less than 1.2 percent; the spread between the median firm and the
firm at the lower quartile is nearly four times. These data
suggest that a large number of industrial laundry firms are
characterized by very slim operating margins, and may be
extremely sensitive to any economic or regulatory pressures that
tend to reduce industry profits.
[D&B provide no information about whether the firms in their
database are publicly- or privately-held. Privately-held firms
may deliberately reduce taxable profits (e.g., through bonuses or
profit-sharing plans) in order to reduce their corporate income
150
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tax liability. Thus, if the D&B data are based on a significant
proportion of privately-held firms, reported profits may tend to
understate profits actually achieved in the industry.]
11.1.4 Return on Assets. This is a key indicator of
profitability, comparing annual profit with the size of the
assets employed to generate that profit. Because they are based
on accounting values for assets (which may be very different from
market or replacement value), summary ratios provide only a very
crude indicator of actual economic returns. Nonetheless, the
very low return on assets not only of the lower guartile firm,
but of the median firm in this industry, suggest that this
industry provides a relatively low return on invested assets, and
that economic or other forces that tend to reduce profits will
generate significant pressure to remove assets from this industry
(i.e., to cease laundry operations in favor of other investment
opportunities).
11.2 Economic Impact of Installation of Ultrafiltration Pretreat
ment System
This section provides an estimate of the economic impact of
installation and operation of a wastewater pretreatment system
for three model industrial laundry firms representing three plant
sizes. For this analysis, economic impacts have been defined as
the impact on pretax profits (defined as return on sales),
assuming that none of the cost of the pretreatment system can be
passed on to customers in the form of higher prices.
Section 11.2.1 specifies the three model firm sizes defined for
the economic impact analysis. Section 11.2.2 provides the
capital and operating costs of Ultrafiltration pretreatment
systems for each of the three model industrial laundry firms.
Section 11.2.3 calculates the impact on pretax profits of
Ultrafiltration system installation and operation for each model
firm.
11.2.1 Selection of Model Plants and Profit Categories. Three
model plants were selected based on the distribution of plant
size (defined by annual revenues) presented in Figure 9-4. The
three model plants selected for analysis generate revenues as
follows:
o Plant A: $ 300,000 per year
o Plant B: $1,000,000 per year
o Plant C: $2,500,000 per year
Table 11-3 compares the three model plants to the distribution of
all establishments in the industry. Based on total revenues,
Plant A represents approximately the 25th percentile of all
establishments, Plant B represents nearly the median
establishment in the industry, and Plant C represents
approximately the 80th percentile of all establishments.
151
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TABLE 11-3
DISTRIBUTION OF INDUSTRIAL LAUNDRY ESTABLISHMENTS BY ANNUAL REVENUES,
AND COMPARISON WITH MODEL PLANT SIZES
Revenues
($1.000)
< $10
$10 - $25
$25 - $50
$50 - $100
$100 - $250
$250 - $500
$500 - $1,000
$1,000 - $2,500
$2,500 - $5,000
> $5,000
TOTAL
Number
8
15
31
50
145
179
223
350
202
50
1,253
Percent
0.6
1.2
2.5
4.0
11.6
14.3
17.8
27.9
16.1
4.0
100.0
Cumulative
Percent
0.6
1.8
4.3
8.3
19.9
34.2
52.0
79.9
96.0
100.0
Model Plant A: Revenues = $300,000/yr
Model Plant B: Revenues = $1 ,000,000/yr
Model Plant C: Revenues = $2,500,000/yr
Source: U.S. Department of Commerce 1985, 1986
-------
This analysis is based on the assumption that the plant is the
relevant unit for the estimation of economic impacts. D&B
financial data (from which profitability estimates are derived)
use the firm as the basic unit of analysis. To the extent that
firms which operate more than one plant realize operating
economies (e.g., reduction in overhead cost per unit of
production), the D&B profitability estimates may tend to
overstate the profits which may be obtained by a single-plant
firm; the economic impacts on such single-plant firms may thus be
greater than those estimated here.
Dun & Bradstreet provide after-tax return on sales for the median
firm in the industry and for the firm at the lower and upper
quartile in the D&B database. Eastern Research Group (ERG) made
the assumption that the D&B quartile and median values apply to
firms of all size classes in the industry. ERG estimated state
and federal income taxes on the basis of gross revenues and after
tax rate of profit; Table 11-4 specifies the tax rates applied to
each model plant at the lower quartile, median, and upper
quartile after tax profit rate specified in the D&B data. Using
these values, ERG calculated before tax profits for each model
plant at the lower quartile, median, and upper quartile profit
rates; before tax profits approximate the annual cash flow in
excess of operating costs (and therefore available to cover
expenses related to installation and operation of effluent
pretreatment systems, assuming that these expenses are not passed
on to consumers through price increases).
For Plant A ($300,000 annual revenues), Figure 11-1 plots percent
return on sales (before tax) against the dollar amount of these
profits, and displays the percent and dollar profit rates for the
lower quartile, median, and upper quartile firm in the industry;
the upward sloping line equates percent profit (on the X-axis) to
the corresponding dollar profit (Y-axis). Figure 11-2 plots
these data for Plant B ($1,000,000 annual revenues), and Figure
11-3 plots the corresponding data for Plant C ($2,500,000 annual
revenues). Given the percent pre-tax profit rate for an
individual plant, the dollar volume of profits can be estimated
by moving vertically to the sloping line, and then horizontally
to the corresponding point on the Y-axis (e.g., in Figure 11-1,
the median profit rate of 5.5 percent represents dollar profits
of approximately $16,600/year).
11.2.2 Capital and Operating Costs of Ultrafiltration Pretreatme
nt gystems. Ultrafiltration has been identified as the
pretreatment technology for which costs and economic impacts
should be calculated. Capital and operating costs for
Ultrafiltration systems were estimated based on information
supplied by two system vendors. The vendors were asked to
provide cost estimates for systems applicable to each of the
three plant sizes defined above.
Table 11-5 summarizes the calculation of pretreatment system size
applicable to each model plant, and presents the annualized
capital and operating cost of each Ultrafiltration system.
Calculation of system size depends first on the conversion of
153
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annual revenues into pounds of laundry processed per year; ERG
employed a value of $0.80/pound to make this conversion. This
value is the same as that used in EPA's 1981
Economic Analysis of Proposed Effluent Guidelines in this
industry (34). ERG was unable to develop a summary cost estimate
based on more recent information, primarily because the basic
cost information was not readily available. IIL pointed out that
there exists significant pricing variation geographically between
regions, temporally within individual regions or markets, and
even between individual accounts held by a single launderer (30).
ERG based its decision to retain the 1981 estimate of $0.80/pound
on its assessment of the economic and competitive forces which
have affected this industry since the 1981 EPA estimate was made.
A second calculation generates an estimate of total annual
effluent production on the basis of wastewater generation per
pound of laundry processed; ERG employed a value of 4.3 gallons
effluent/pound laundry on the basis of information presented in
the technology section of this document. A final conversion from
gallons per year to gallons per day (the common sizing unit for
pretreatment systems) was based upon an estimate of 260 days of
system operation per year.
Based on these calculations, system suppliers provided estimates
of the capital and operating costs of ultrafiltration
pretreatment systems of the following three size classes.
o Plant A: 6,000 Gallons Per Day (GPD)
o Plant B: 20,000 GPD
o Plant C: 50-55,000 GPD
Table 11-5 presents the capital and operating system costs
provided by the ultrafiltration system vendors for each of the
three hypothesized pretreatment systems. Capital cost estimates
represent the lump sum payment for a turnkey system, installed
and ready for operation. To translate this single payment into
an annual cost, the capital cost was amortized over 15 years
using a 10 percent discount rate. Table 11-4 presents this
calculation, and presents the annualized capital and operating
cost of installation and operation of each system.
154
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Pretreatment System Financial Impact
Plant A: Revenues - $300,000/Yr
Wl
40
PRETREATMENT SYSTEM COST ($1,000)
30
20
e.OOO QPO Pretreatmenl
System-\
Quartlle
4 6 8 10
PERCENT RETURN ON SALES, BEFORE TAX
12
14
Figure ll-i Analysis of pretreatnent system financial Impact: Model plant A
(Revenues - $300,000/Year). Median pre-tax profit rate - 5.5%.
-------
Pretreatment System Financial Impact
Plant B: Revenues - $1,000,000/Yr
Ul
160
PRETREATMENT SYSTEM COST ($1,000)
140.:
120 -
100 -
21,000 QPD Pretreatment
System
0
2
4 6 8 10 12
PERCENT RETURN ON SALES, BEFORE TAX
14
16
Figure 11-2 Analysis of pretreatment system financial Impact: Model plant B
(Revenues » $l,000,000/Year). Median pre-tax profit rate - 5.7».
-------
Pretreatment System Financial Impact
Plant C: Revenues - $2,500,000/Yr
500
400
300 -
PRETREATMENT SYSTEM COST ($1,000)
62,000 QPD
Prelreatmentj
System /*
200 -
100 -
5 10 15
PERCENT RETURN ON SALES, BEFORE TAX
Figure 11-3 Analysis of pretreatment system financial impact: Model plant C
(Revenues = $2,500,000/Year). Median pre-tax profit rate » 7.2%.
-------
TABLE 11-4
STATE AND FEDERAL INCOME TAXES APPLIED TO INDUSTRIAL LAUNDRIES
OF THREE SIZE AND PROFIT CLASSES
After Tax Profit
Lower Quartile Median. Upper Quartile
L2% 4.6% 9.2%
MODEL PLANT A: REVENUES = $300,000/yr
Revenues $300,000 $300,000 $300,000
After Tax Profits 3,600 13,800 27,600
State Income Tax 100 400 830
Federal Income Tax 600 2,400 4,900
Before Tax Profits 4,300 16,600 33^330
Before Tax Profit Rate 1.4% 5.5% 11.1%
Overall Tax Rate 16% 17% 17%
MODEL PLANT B: REVENUES = $l,000,000/yr
Revenues 1,000,000 1,000,000 1,000,000
After Tax Profits 12,000 46,000 92,000
State Income Tax 350 1,500 3,400
Federal Income Tax 2,100 9,500 41^000
Before Tax Profits 14,450 57,000 136,400
Before Tax Profit Rate 1.4% 5.7% 13.6%
Overall Tax Rate 17% 19% 33%
MODEL PLANT C: REVENUES = $2,500,000/yr
Revenues 2,500,000 2,500,000 2,500,000
After Tax Profits 30,000 115,000 230,000
State Income Tax 900 4,500 10,000
Federal Income Tax 5,300 60,500 158,500
Before Tax Profits 36,200 180,000 398,500
Before Tax Profit Rate 1.4% 7.2% 15.9%
Overall Tax Rate 17% 36% 42%
Source: Revenue and after tax profits from Dun & Bradstreet 1987. Tax
calculation based on U.S. Tax Guide 1988. published by Commerce
Clearing House, Inc.
158
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TABLE 11-5
ANNUAL EFFLUENT PRODUCTION AND PRETREATMENT SYSTEM COSTS
FOR THREE MODEL INDUSTRIAL LAUNDRY PLANTS
MODEL PLANT A / ANNUAL REVENUES - $300,000
PLANT CHARACTERISTICS
Annual Revenue
Price ($/lb)
Annual Ibs Processed
Weekly Ibs Processed
Effluent (gal/lb)
Weekly Effluent
Daily Effluent
TREATMENT SYSTEM COSTS
System Cost (Includes
Installation/Startup)
Amortization Factor
Annual Capital Cost
Operating Cost/Gallon
GalIons/Year
Operating Cost/Year
TOTAL COST/YEAR
300,000 $/year
0.80 $/lb
375,000 Ib/year
7,212 Ib/week
4.3 gal/lb
31,010 gal/week
6,202 gal/day
$100,000
7.606
$13,148 per year
0.25 cents/gal
1,612,500 gal/year
$4,031 per year
$17,179 per year
Source: See text for discussion of laundering price. Calculation of
wastewater volume based on data presented in Section 5.1 of this
document. Treatment system costs based on information supplied by
system vendors.
159
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TABLE 11-5 (Continued)
ANNUAL EFFLUENT PRODUCTION AND PRETREATMENT SYSTEM COSTS
FOR THREE MODEL INDUSTRIAL LAUNDRY PLANTS
MODEL PLANT B / ANNUAL REVENUES = $1,000,000
PLANT CHARACTERISTICS
Annual Revenue
Price ($/lb)
Annual Ibs Processed
Weekly Ibs Processed
Effluent .(gal/lb)
Weekly Effluent
Daily Effluent
TREATMENT SYSTEM COSTS
System Cost (Includes
Installation/Startup)
Amortization Factor
Annual Capital Cost
Operating Cost/Gallon
Gallons/Year
Operating Cost/Year
TOTAL COST/YEAR
1,000,000 $/year
0.80 $/lb
1,250,000 Ib/year
24,038 Ib/week
4.3 gal/lb
103,365 gal/week
20,673 gal/day
$225,000
7.606
$29,582 per year
0.25 Cents/gal
5,375,000 gal/year
$13,438 per year
$43,019 per year
Source: See text for discussion of laundering price. Calculation of
wastewater volume based on data presented in Section 5.1 of tnis
document. Treatment system costs based on information supplied
by system vendors.
160
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TABLE 11-5 (Continued)
ANNUAL EFFLUENT PRODUCTION AND PRETREATMENT SYSTEM COSTS
FOR THREE MODEL INDUSTRIAL LAUNDRY PLANTS
HODEL PLANT C / ANNUAL REVENUES = $2,500,000
PLANT CHARACTERISTICS
Annual Revenue 2,500,000 $/year
Price ($/lb) 0.80 $/lb
Annual Ibs Processed 3,125,000 lb/year
Weekly Ibs Processed 60,096 Ib/week
Effluent (gal/lb) 4.3 gal/lb
Weekly Effluent 258,413 gal/week
Daily Effluent 51,683 gal/day
TREATMENT SYSTEM COSTS
System Cost (Includes $325,000
Installation/Startup)
Amortization Factor 7.606
Annual Capital Cost $42,729 per year
Operating Cost/Gallon 0.25 cents/gal
Gallons/Year 13,437,500 gal/year
Operating Cost/Year $33,594 per year
TOTAL COST/YEAR $76,323 per year
Source: See text for discussion of laundering price. Calculation of
wastewater volume based on data presented in Section 5.1 of this
document. Treatment system costs based on information supplied
by system vendors.
161
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11.2.3 Economic Impacts of Ultrafiltration Pretreatment Systems.
Three indicators are frequently developed to estimate the impact
of increased costs on an industry:
o Impact on profits assuming that costs cannot be passed on to
customers in the form of higher prices.
o Impact on prices if current profit margins or dollar profit
volumes are to be maintained.
o Impact on the industry's ability to attract capital to
finance the required investment.
For the current analysis, only the first indicator, impact on
profits assuming no cost pass-through, has been estimated.
Calculation of the second indicator, impact on prices to maintain
current profits, requires data on the cost structure of the
industry (specifically, data defining the relationship between
fixed and variable costs) which are not contained in the data
sources available for this analysis. Calculation of the third
indicator, ability to attract capital, hinges on a more exact
specification of model plant financial condition than has been
attempted here.
Impact on Model Plant A (Annual Revenues = $300.000) - Figure 11-
1 plots the annual cost of an approximately 6,000 Gallon Per Day
(GPD) ultrafiltration pretreatment system against the
distribution of pre-tax profits (return on sales) for a firm in
this size class. The annualized cost of the pretreatment system
(approximately $17,200/year) corresponds to a pre-tax rate of
profit of approximately 5.7 percent. This is greater than the
pre-tax profit of the median firm for this plant size. Over
50 percent of all firms of this size, therefore, could not
maintain a positive rate of profit if they were required to
install this pretreatment system (assuming that pretreatment
costs are not passed on to consumers in the form of higher
prices).
Impact on Model Plant B (Annual Revenues • $1.000.000) - Figure
11-2 plots annualized pretreatment system costs against the
distribution of pre-tax profits (return on sales) for a model
plant with annual revenues of $1,000,000. The estimated
annualized cost of the pretreatment system ($43,000/year)
corresponds to a pre-tax profit rate of 4.3 percent. This is
approximately 2.5 times the profits earned by the lower quartile
firm in the industry, and indicates that significantly more than
25 percent of all firms of this size could not maintain a
positive rate of profit if required to install and operate the
hypothesized ultrafiltration system.
Impact on Model Plant C fAnnual Revenues » Sa.soo.OOOT
Figure 11-3 compares annualized pretreatment system costs for an
approximately 52,000 GPD pretreatment system against the
distribution of pre-tax profits (return on sales) for Model Plant
C. The annualized cost of this pretreatment system is
approximately $76,000/year, and corresponds to a pre-tax rate of
162
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profit of 3.0 percent. Again, this value is significantly
greater than the rate of profit earned by the lower quartile firm
in the industry; that is, over one fourth of all firms
represented by this model plant would have negative earnings if
required to install and operate this pretreatment system.
11.3 Summary of Economic Impacts
Under the assumption that costs cannot be passed through to
customers in the form of higher prices, this analysis has
indicated that installation and operation of an ultrafiltration
pretreatment system may result in severe economic impacts for a
large proportion of firms in the industrial laundry industry.
For all three model plants analyzed, the annualized cost of
pretreatment system operation is greater than the pre-tax rate of
profit earned by over one-fourth of all firms in the industry.
Calculated impacts are much greater for smaller firms in the
industry. Annual pretreatment costs are greater than the
estimated pre-tax profits earned by over one-half of all firms of
this size, and (as Table 11-6 demonstrates) a smaller firm would
require a much higher rate of profit to cover pretreatment costs
than would a larger firm.
Given the distribution of firm sizes reflected in Table 11-3, one
can infer that the profits of a large proportion of all firms in
the industry could be severely impacted if this pretreatment
technology is required (assuming no cost pass through). One can
also infer that the magnitude of the impact may be inversely
proportional to firm size, and therefore that the competitive
position of smaller firms vis-a-vis larger firms in the industry
would be eroded. This situation would hasten a trend toward
consolidation which is already apparent in the industry.
The majority of revenues and employment in the industry are
currently generated by the largest firms (see Figure 9-9 and
Section 9.3). Thus, although the profitability and perhaps the
viability of many small firms may be threatened by a potential
requirement for an ultrafiltration pretreatment system, the
majority of the industry workforce is employed by firms less
jeopardized by this requirement.
With the data in hand, it is difficult to predict the potential
impact of a pretreatment system requirement on such variables as
the cost of industrial laundry services or industry
competitiveness. A significant unknown is the proportion of
privately-held firms in the industry and the extent to which
their reported profits may understate their true financial
health; the impacts calculated here will be mitigated if this is
true for significant numbers of firms. It is virtually certain
that prices would rise as industrial laundries pass along their
higher costs to consumers. It is also apparent that larger firms
would be likely to require a smaller price increase to meet
profit targets than would smaller firms; again, this fact should
tend to increase the dominance of larger firms in the industry,
as smaller firms either leave the industry or are absorbed by the
larger firms.
163
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The preceding argument also suggests that a pretreatroent system
requirement may ultimately tend to reduce competitiveness in the
industry. If smaller firms are in fact driven from the industry,
each geographic market may come to be dominated by one or a very
few large firms.
164
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TABLE 11-6
ANNUALIZED COST OF PRZTREATMENT SYSTEM EXPRESSED AS PERCENT OF REVENUES
FOR THREE INDUSTRIAL LAUNDRY MODEL PLANTS
Annualized Pretreatment
Cost of Cost as
Model Plant A
Model Plant B
Model Plant C
Annual
Revenues
$300,000
$1,000,000
$2,500,000
Pre treatment
System
$17,179
$43,019
$76,323
Percent of
Revenues
5.7%
4.3%
3.1%
Note: Annualized costs based on 15-year equipment life and discount rate of
10%
Source: Calculations presented in Table 11-5
165
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ENVIRONMENTAL IMPACT ANALYSIS
166
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SECTION 12
12.0 ENVIRONMENTAL IMPACT ANALYSIS
A study is presented in this section of the impact of the
wastewater discharge from the industrial laundries industry on
the publicly owned treatment works (POTWs) and the streams to
which the POTWs subsequently discharge.
12.1 Summary of the Environmental Impact Study
This study evaluates the impacts of fourteen indirect discharging
industrial laundry plants on receiving streams and on publicly
owned treatment works (POTWs).
Receiving stream impacts are evaluated by comparing estimated
instream pollutant concentrations with aquatic life toxic effects
levels and EPA Water Quality Criteria developed for human health
and aquatic life protection. Two sets of data are used to
estimate instream concentrations: l) effluent monitoring
pollutant concentrations and plant flows from five indirect
laundries along with the (actual receiving) POTW flows, and low
receiving stream flows (7-Q-10); and 2) effluent monitoring
pollutant concentrations and plant flows from nine indirect
discharging laundries with two representative POTW and two
representative receiving stream flow conditions (the 25th and
50th percentile of indirect laundry POTWs and receiving streams).
The 25th percentile analysis means that 75 percent of the POTWs
with indirect laundries and 75 percent of their receiving streams
have flows greater than the flow used in the model.
Impacts on POTWs are evaluated in terms of inhibition of POTW
operations and contamination of POTW sludges. Inhibition
problems are estimated by comparing calculated POTW influent
pollutant concentrations with POTW inhibition levels. Sludge
contamination problems are estimated by comparing calculated
sludge pollutant concentrations with phytotoxic sludge
contamination levels; human health criteria are applied to the
cadmium and lead levels, while phytotoxic criteria are used for
the five other pollutants.
The first set of sampling data from five indirect laundry plants
reveals that these plants discharge from 32 pollutants (Plant F)
to 56 pollutants (Plants A and B). A total of 86 pollutants are
evaluated; 47 are priority pollutants. Inhibition and sludge
contamination levels are available for only a limited number of
priority pollutants. Therefore, only 14 and 7 pollutants are
evaluated for potential inhibition and sludge contamination
problems, respectively.
The second set of sampling data from nine plants reveals that
these indirect dischargers discharge from 7 (Plant 6) to 30
pollutants (Plant 1) . A total of 51 pollutants are evaluated:
47 are priority pollutants. Eighteen priority pollutants are
evaluated for potential inhibition problems, as well as seven for
sludge contamination.
167
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The first data set analysis projects minimal water quality
impacts. Two pollutants, benzidine and arsenic, exceed the human
health criteria by magnitudes of only 10 and 1, respectively
(Table 12-1). Benzidine and arsenic are known carcinogens.
Although benzidine is not generally persistent, it has a half-
life in water of six hours. Only one pollutant, cyanide, exceeds
the chronic aquatic life criteria by a magnitude of one. Cyanide
is not persistent in surface water; it has a half-life of between
10 to 50 hours in natural waters. No pollutants exceed the acute
aquatic life criteria.
The second set of data analyzed projects water quality impacts.
Two pollutants, arsenic and lead, exceed both the human health
and chronic aquatic life criteria at the 50th percentile flow
(Table 12-2). At the 25th percentile, six pollutants exceed
criteria. Four pollutants, bis(2-ethylhexyl)phthalate, arsenic,
methylene chloride, and carbon tetrachloride exceed human health
criteria. .All of these pollutants are known or suspected
carcinogens. These pollutants are solvents introduced from the
laundering of shop towels. Two pollutants, lead and bis(2-
ethylhexyl)phthalate, exceed chronic aquatic life criteria. No
pollutants exceed the acute aquatic life criteria.
Two pollutants, zinc and lead, exceed POTW inhibition levels. No
pollutants exceed the sludge contamination levels.
Major findings based on available discharge monitoring data
indicate minimal impacts on water quality and on POTWs, except
for solvents such as benzidine. Benzidine is an example of a
solvent found in the laundering of shop towels (rags used in
paint spray booths and automotive repair shops). In this
industry, there is no product control regarding the type of
solvents in the soiled material to be laundered. Therefore, the
potential for other solvents similar to benzidine to enter into
the laundry water discharge is present.
12.2 Methodology
A POTW model was used to predict the potential environmental
impacts associated with the raw indirect discharge of industrial
laundries' wastewaters into POTWs and, ultimately, into receiving
streams. The potential environmental impacts evaluated through
the use of the POTW model include: (l) inhibition of POTW
processes (determined by comparing calculated influent pollutant
levels with available inhibition criteria or levels; (2)
contamination of POTW sludge and thereby limiting its use
(determined through comparison of expected pollutant
concentrations in POTW sludge with sludge contamination
criteria); and (3) effect on surface water into which the POTW
discharges (determined through comparison of calculated POTW
effluent concentrations with acute water quality criteria for
aquatic life, and calculated instream concentrations under low
stream flow [7-Q-1O] conditions with chronic aquatic life and
human health water quality criteria, and drinking water
standards).
168
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TABLE 12-1
SUMMARY OF WATER QUALITY CRITERIA EXCEEDANCES
RCRA/ITD SAMPLING DATA
Plant Number
Pollutant
Criteria Exceedances*
At Actual POTW Flow
And Low Receiving Stream Flow
A & B
C
D
E
Arsenic
Cyanide
Benzidine
Arsenic
No Exceedances
H(7.2)
C(2.2)
H(640)
H(2.9)
No Exceedances
^Criteria exceedances denoted by:
Type of Criteria (Concentration/Criteria)
Types of Criteria: H - Human Health-Ingesting water and organisms
C - Aquatic Life-Chronic
169
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TABLE 12-2
SUMMARY OF WATER QUALITY CRITERIA EXCEEDANCES
1978 SAMPLING DATA
Plant
Number
Criteria Exceedances*
Pollutant
50th Percentile
(POTV & Rec. Stream)
25th Percentile
(POTW & Rec. Stream)
1 Bis(2-ethylhexyl)phthalate
Arsenic
Lead
Zinc
2 Methylene Chloride
Arsenic
Lead
Zinc
3 Arsenic
Lead
Zinc
4 Lead
Zinc
5 Arsenic
Lead
6 Lead
Zinc
7 Carbon Tetrachloride
Arsenic
8 Bis(2-ethylhexyl)phthalate
Arsenic
Lead
Zinc
9 Lead
Zinc
H(3.2)
H(3.8)
C(l.O)
H(3.5)
HC1.4)
H(4.0)
HC1.3)
HC21.7)
C(3.5)
1(1-8)
H(l.l)
H(26.0)
K2.2)
H(28.2)
C(3.2)
1(1.3)
C(4.0)
1(1.3)
H(23.8)
C(2.2)
C(4.0)
1(1.4)
H(3.0)
H(9.7)
C(3.2)/H(5.5)
H(27.1)
C(3.3)
K1.6)
1(1.6)
^Criteria exceedances denoted by:
Type of Criteria (Concentration/Criteria)
Type of Criteria: H - Human Health-Ingesting water and organisms
A - Aquatic Life-Acute
C - Aquatic Life-Chronic
I - POTW Inhibition
170
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To determine potential environmental impacts of indirect
dischargers, two approaches were used. The first approach used
plant-specific information (i.e., actual plant, POTW, and
receiving stream flows) for five laundries that were sampled
under the ITD/RCRA program. The second approach was used when
plant-specific data were not available. Plant-specific data were
not available for data collected under a 1978 sampling program
and, therefore, average plant flows and 50th (median) and 25th
percentile POTW and receiving stream flows for the entire
industry were used for each of these nine plants. These
POTW/receiving stream flows were based on information provided by
the Agency's IFD and GAGE files for indirect facilities with a
SIC code of 7218. Plant flows and concentrations were obtained
from Section V of this document. Average values were used when
plants were sampled more than once.
The profile of the industrial laundries industry used in the
environmental impact analysis is presented in Table 12-3. The
profile is based on information in the Technical Support Section
of this document.
The concentrations and criteria for each facility analyzed and
for the receiving POTWs and model POTWs are presented in
Appendices E through H.
12.3 Environmental Analysis Results and Conclusions
Impacts of the discharge from POTWs on their receiving streams
were projected for human health and aquatic life. Impacts on
POTWs were also projected. In addition, profiles of receiving
streams and the environmental fate of the pollutants of concern
are presented.
12.3.1 Impacts on Human Health
Seventeen of the 82 pollutants discharged by the ITD/RCRA
facilities are known, suspected, or potential human carcinogens.
Of the five ITD/RCRA facilities modeled, two caused instream
exceedances of arsenic water quality criteria and one exceeded
the criteria for benzidine. For the "1978" facilities: six of
the nine exceeded the arsenic water quality criteria at both the
25th and 50th percentile flows; two plants exceed the water
quality criteria for bis(2-ethylhexyl)phthalate (DEHP) at. the
25th percentile only; one plant caused a slight exceedance (1.1
times the criteria) for methylene chloride at low flow; and one
exceeded the water quality criteria for carbon tetrachloride at
low flow.
12.3.2 Impacts on Aquatic Life.
The only exceedance of aquatic life water quality criteria for
the ITD/RCRA facilities was for cyanide (exceedance factor of
2.2). The water quality criteria for lead was exceeded at eight
of the nine "1978" facilities at the 25th percentile flows, but
only one facility at average flows. Also, one exceedance of the
171
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water quality criteria for DEHP was projected at the 25th
percentile.
172
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TABLE 12-3
PROFILE OF INDUSTRIAL LAUNDRIES INDUSTRY
USED IN THE ENVIRONMENTAL IMPACT ANALYSIS
Number of Facilities
Laundry or dry-cleaning facilities: 1,000
Type of Discharge
Indirect discharging facilities: 1,000
o Total Flow: 68 MGD
o Average Flow per Plant: 0.068 MGD
o Operating Days per Year: 260
o Frequency of Discharge: Variable
Raw Pollutant Loadings to Water
Priority Pollutant Loadings:
o Priority Pollutant Organics: The discharge of
13,770 Ibs/day of priority pollutant organics is slightly
less than the amount discharged by the Petroleum Refining
Industry at the raw treatment level. It is also 13 times
greater than the level discharged by the Organic Chemicals
Industry at the PSES.
o Priority Pollutant Inorganics: These loadings
are estimated at 7,130 Ibs/day, roughly twice the amount
discharged by the Leather Tanning and Finishing Industry at
raw and slightly more than the Metal Finishing/Electroplating
Industry at PSES.
Conventional Pollutant Loadings:
o TSS: Raw loadings of 590,400 Ibs/day are six
times greater than the Organic Chemicals
current load and one-sixth the load discharged by all
priority industries at PSES.
o BODS: The total raw load of 635,173 Ibs/day
for industrial laundries is ten times greater than the
Organic Chemicals current load and roughly twice the load
discharged by the Leather Tanning Industry at PSES.
173
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12.3.3 POTW Impacts
No POTW impacts (inhibition or sludge contamination) were
projected for the ITD/RCRA facilities. The only impact projected
for the "1978" facilities was for inhibition at the 25th
percentile flows. Zinc exceeded inhibition criteria at seven of
the nine facilities and lead exceeded at two facilities.
12.3.4 Receiving Stream Profiles
The following is a statistical breakdown of the flows for the
industrial laundries, as obtained from EPA's IFD and GAGE files,
together with a comparison of rivers with similar flow rates.
Receiving Stream
Percentile Plant Flow POTW Flow Average Flow 7-Q-10 Flow
25 0.048 4.600 176.664 4.103
50 0.094 12.300 662.218 47.016
75 0.175 44.900 2,750.263 527.021
The average flow in receiving stream at the 25th percentile is
equivalent to the average flow in Bull Run at Clifton, Virginia.
The average flow in receiving stream at the 50th percentile is
slightly greater than the Monocacy River at Frederick, Maryland.
The average flow in receiving stream at the 75th percentile is
greater than that in the Rappahannock River at the mouth (1,100
MGD) and less than the James River at Richmond, Virginia (4,900
MGD) .
12.3.5 Pollutant Fate
The environmental fates of pollutants of concern are presented in
Table 12-4.
174
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TABLE 12-4
ENVIRONMENTAL FATE OF POLLUTANTS OF CONCERN
Pollutant
Fate
Arsenic
Benzidine
Bis (2-ethylhexyl)phthalate
Carbon tetrachloride
(Tetrachloromethane)
Arsenic is very mobile in the aquatic
environment and is constantly transported
between the water, sediments, and
biota. It is sorbed as an inorganic ion
but biotransfonnation to methylated
forms may release it to the water and
atmosphere. It is not highly
concentrated in the biota (BCF=44). Not
persistent.
Sorption to sediments (especially clay)
is the principal fate process.
Oxidation by dissolved and precipitated
metals cations, such as Fe+"*, Cu+2 will
degrade benzidine in surface waters
(half-life=6.0 hours). Not persistent.
Strongly sorbed to organic material of
surface water but it is not considered
to be persistent in riverine systems.
It is bioaccumulated but also
biodegraded by most organisms.
Transport downstream considered to be
the principal fate.
Volatilization is the principal fata
from surface water. The half-lives
range from less than one hour to several
hours, depending on the agitation of the
water. Other fate processes are
probably not important, but since
volatilization is rapid,
tetrachloromethane should not be
persistent in surface water.
175
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TABLE 12-4 (Continued)
ENVIRONMENTAL FATE OF POLLUTANTS OF CONCERN
Pollutant
Fate
Cyanide
Lead
Methylene chloride
'(Dichloromethane)
Zinc
Cyanide is not persistent in the
environment. The half-life for
volatilization ranges from 0.5 to 50
hours, depending on pH. Cyanide is also
metabolized by all aquatic organisms.
Field studies have demonstrated that
cyanide is not persistent in surface
waters.
Lead is persistent in the sediments of
surface water, although biomethylation
may remobilize this metal as tetramethyl
lead. The BCF for aquatic organisms is
49.
Volatilization is the principal forte
from the surface water. The half-life
ranges from less than one hours to
several hours, depending on the
agitation of the water. Biodegradation
may occur in stagnant swamp water
(cometabolism) but, generally, other
forte processes are unimportant. This
compound is not considered to be
persistent. Bioaccumulative potential
is low (BCF=5.0).
Zinc is strongly sorbed to both organic
and inorganic components of the sediment
where it will be persistent. Zinc is
bioaccumulated by all organisms. BCF
for freshwater fish is 432.
176
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SECTION 13
13.0 REFERENCES
1. Report to Congress on the Discharge of Hazardous Wastes to
Publicly Owned Treatment Works. United States Environmental
Protection Agency, Washington, D.C., February 1986.
2. Development Document for Proposed Effluent Limitations
Guidelines and New Source Performance Standards for the Auto
and Other Laundries. United States Environmental Protection
Agency, Washington, D.C., (EPA draft document April 1974).
3. Modular Wastewater Treatment System Demonstration for the
Textile Maintenance Industry. United States Environmental
Protection Agency, Washington, D.C., January 1974.
4. Technical Support Document for Auto and Other Laundries
Industryf United States Environmental Protection Agency,
Washington, D.C., October 1979.
5. Development Document for Effluent Limitations Guidelines and
Standards for the Auto and Other Laundries Point Source
Category, United States Environmental Protection Agency,
Washington, D.C., October 1980.
6. Guidance Document for Effluent Discharges from the Auto and
Other Laundries Point Source Category. United States
Environmental Protection Agency, Washington, D.C., February
1982.
7. Kaufman, R., "Wastewater Heat Recovery and Low Temperature
Washing," Textile Rental. pp. 72-76, August 1985.
8. Riggs, C.L., and Sherrill, J.C., Textile Laundering
Technology. Textile Rental Services Association of America,
Hallandale, Florida, 1972.
9. Nemerow, N.L., Liguid Waste of Industry. Theories.
Practices, and Treatment. Addison-Westey Publishing Company,
Reading, Massachusetts, 1971.
10. Patterson, I.W., Wastewater Treatment Technology. Ann Arbor
Science Publishers, Inc., Ann Arbor, Michigan, 1975. pp.
175-189.
11. Process Design Manual for Suspended Solids Removal-
Technology Transfer. U.S. Environmental Protection Agency,
Cincinnati, Ohio, January 1975. pp. 4-1, 4-2.
12. O'Meilia, C.R., "Coagulation and Flocculation."
Phvsicochemical Processes for Water Quality Control. Chapter
2, W.J. Webster, Jr., ed. Wiley-Interscience, New York, New
York, 1972. pp. 61-91.
177
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13. Wastewater Engineering. Collection. Treatmentf and Disposal.
Metcalf and Eddy, Inc., McGraw Hill Book Company, New York,
New York, 1972.
14. Wastewater Treatment Plant Design. Manual pj£ Practice No. 8,
Water Pollution Control Federation, Washington, D.C., 1977.
15. Tran, T.V., "Advanced Membrane Filtration Process Treats
Industrial Wastewater Efficiently," Chemical Engineering
Progressf March 1985.
16. Gils, G.J., Pirbazari, M., Sung-Huyn, K. and Shorr, J.,
"Treatment of Emulsified and Colloidal Industrial Wastewater
Using a Combined Ultrafiltration Carbon Adsorption Process,"
Proceedings of the 39th Purdue Industrial Waste Conference,
Purdue University, Lafayette, Indiana, 1984.
17. Bhattacharyya, D., Garrison, K.A., The, P.W.E., and Grieves,
R.B., "Membrane Ultrafiltration: Wastewater Treatment
Application for Water Reuse," Proceedings of the 39th Purdue
Industrial Waste Conference, Purdue University, Lafayette,
Indiana, 1975.
18. Noll, K.E., Haas, C.N., Schmidt, C. and Kodukula, P.,
Recovery. Recycle f and Reuse of Industrial Wastes,. Lewis
Publishers, Inc., Chelsea, Michigan, 1985. pp. 119-133.
19. Pinto, S.D., "Ultrafiltration for Dewatering of Waste
Emulsified Oils," Proceedings, First International
Conference, Lubrication Challenges in Metal Working and
Processing, IIT Research Institute, Chicago, Illinois, 1978.
20. Paulson, D.J., Wilson, R.L. and Spatz, D.D., "Crossflow
Membrane Technology and Its application," "Food Technology.
pp. 77-111. December 1984.
21. Jeng, F., and Shih, C., "Treatment of Laundry Wastewater
From a Nuclear Power Plant by Reverse Osmosis," Proceedings
of the 39th Purdue Industrial Waste Conference, Purdue
University, Lafayette, Indiana, 1984.
22. Miniturn, R.E., Johnson, J.S., Jr., Schofield, W.M., and
Todd, O.K., "Hyperfiltration of Laundry Wastewater," Water
Research. 8(11):921-926. 1974.
23. Bhattacharyya, D., Jumawan, A.B., Jr., Greives, R.B. and
Witherup, S.O., "Ultrafiltration of Complex Wastewaters:
Recycling for Nonpotable Use." Journal of the Water
Pollution Control Federation. 846-861. May 1978.
24. "Memtek Corporation: The Technology of Today," Industrial
Launderer. 36(11):70-73. November 1985.
178
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25. Process Design Manual for Upgrading Existing Wastewater
Treatment Plants- Technology Transfer. U.S. Environmental
Protection Agency, Cincinnati, Ohio, October 1974.
26. County Business Patterns. U.S. Department of Commerce.
1978, 1982, 1985, 1986.
27. Census of Service Industries. U.S. Census Bureau. 1982.
28. An Analysis of the Industrial Laundry Industry. Institute
of Industrial Launderers. 1987.
29. The Industrial Laundry Industry and its Markets. Institute
of Industrial Launderers. 1987.
30. Stoll, Barry. Personal communication. Telephone
conversation between Mark Lennon of Eastern Research Group
and Barry Stoll, Administrator of the Alliance of Textile
Care Associations (Washington, DC), on March 10, 1988.
31. RMA Annual Statement Studies. Robert Morris Associates.
1987. Philadelphia, PA.
32. Industry Norms and Kev Business Ratios. Dun and Bradstreet
Credit Services. 1987.
33. Troy, Leo; 1987. Almanac of Business and Industrial
Financial Ratios. Englewood Cliffs, NJ: Prentice-Hall,
Inc.
34. Economic Analysis of Proposed Effluent Guidelines and
Standards in the Auto and Other Laundries Industry.
U.S. Environmental Protection Agency. Economic Analysis
Branch, Office of Water Regulations and Standards.
November 1981.
179
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35. Kleper, M.H., R.L Goldsmith, and A.Z. Gollen. Demonstration
of Ultrafiltration and Carbon Adsorption for Treatment of
Industrial Laundering Wastewater. EPA-600/2-78-177, U.S.
Environmental Protection Agency, Cincinnati, Ohio, August
1978.
36. Rosenthal, B.L. et al. Industrial Laundry Waste Water
Treatment Study. Project #48, Massachusetts Health Research
Institute, Inc., Boston, Massachusetts. April 1964.
37. Cogely, D.R. and B.A. Weschler. Occurrence and Treatability
of Priority Pollutants in Industrial Laundry Wastewaters.
Draft Final Report. Grant No. S-804367-01, U.S.
Environmental Protection Agency, Cincinnati, Ohio. January
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