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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

                                12

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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

                                13

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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.
                                14

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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

                               15

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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

                                16

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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

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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

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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

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Table  5-2  presents  the  remainder  of  the  1987  ITD  List  of
Analytes.
                                21

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                                                 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

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                                                     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

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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

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                                      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

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                                   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

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                                                        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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              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


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btnun*
urban ittwklerldt
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talucne
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110
4999)
1,100
92
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100 647
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1
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1,101
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4,1
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2
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117
2,550



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20
18
540
100
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(999)
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5.100
1,500
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(999)
440
410
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(999)
410
(999)
(999)
8


170
25
60
600
4,000
9,000
2
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210
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7,94*
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140
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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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9!
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1.519
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125
4.194
448.211
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55
551
1.154
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I
144
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2,881
10,141
1,495.185
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ME*Mt
87
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851
11
1,758
217
241
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1,641
107
8,145
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IT
1.100
151
280
440
190
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1.800
194
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1,475,284
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4.712
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10,494
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-------
                     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

-------
                                      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

-------
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

-------
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

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                                          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

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                                          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

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                                          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

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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

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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

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        SEMI-PERMEABLE
          MEMBRANE
FEED
                     I FLOW
                                            CONCENTRATE
                    1 1  I  I i  I
                     PERMEATE
                       FLOW
                                             FIGURE  7-2
                            CROSSFLOW MEMBRANE FILTER
                        106

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                                          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

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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

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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

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          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

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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

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                                                    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

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                                                           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

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                                              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

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(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

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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
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     350 -
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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

-------
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                    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

-------
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    Figure  9-5    Number of industrial  laundry  establishments by state,  1985,
                                     130

-------
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  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

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          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
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•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

-------
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    Source:   U.S.  Census Bureau  1982
 Figure  g_g    Total industrial laundry  receipts by establishment revenues,

                1982.
                                       135

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      430
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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

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Figure 9-12   Total industrial laundry employment by  state,  1985.
                                      139

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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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           Census Bureau, Census of Service Industries
Figure  g_i3   Industrial laundry employment,  1967-1982,
                                     141

-------
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               (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%.

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                             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».

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                   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%.

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                                  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
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3.  Modular  Wastewater Treatment  System  Demonstration for  the
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    Protection Agency, Washington, D.C., January 1974.

4.  Technical  Support  Document  for   Auto  and  Other  Laundries
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5.  Development Document for  Effluent  Limitations  Guidelines and
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6.  Guidance Document  for  Effluent Discharges from the Auto and
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7.  Kaufman, R.,  "Wastewater Heat  Recovery and Low  Temperature
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8.  Riggs,   C.L.,  and   Sherrill,   J.C.,   Textile   Laundering
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11.  Process   Design   Manual   for  Suspended   Solids   Removal-
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                               177

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13. Wastewater Engineering.  Collection.  Treatmentf  and Disposal.
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17. Bhattacharyya, D., Garrison,  K.A.,  The,  P.W.E., and Grieves,
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18. Noll,  K.E.,   Haas,  C.N.,   Schmidt,  C.  and  Kodukula,  P.,
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22. Miniturn,  R.E.,  Johnson,  J.S.,  Jr.,  Schofield,  W.M.,  and
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23. Bhattacharyya,  D.,  Jumawan,  A.B.,  Jr.,  Greives,  R.B.  and
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24. "Memtek Corporation:   The  Technology  of Today,"  Industrial
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                               178

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25. Process  Design  Manual  for  Upgrading  Existing  Wastewater
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26. County  Business  Patterns.    U.S. Department  of  Commerce.
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27. Census of Service Industries. U.S. Census Bureau.  1982.

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30. Stoll,   Barry.      Personal   communication.      Telephone
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31. RMA  Annual  Statement  Studies.    Robert  Morris  Associates.
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32. Industry Norms  and  Kev Business Ratios.   Dun and Bradstreet
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33. Troy,  Leo;   1987.     Almanac  of  Business  and  Industrial
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    Inc.

34. Economic   Analysis   of  Proposed  Effluent   Guidelines  and
    Standards   in  the  Auto   and  Other  Laundries   Industry.
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    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
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36. Rosenthal,  B.L.  et  al.     Industrial  Laundry  Waste  Water
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37. Cogely, D.R. and B.A.  Weschler.   Occurrence and Treatability
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    Environmental Protection Agency, Cincinnati, Ohio.   January
    1978.

38. Guarino,  V.J.,  and R.A. Bambenek.   Development  and Testing
    of  a  Wastewater  Recycler  and  Heater.    EPA-600/2-76-289.
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    December 1976.

39. Linen  Supply Association  of  America.    Report of  20 Member
    Plants.  1978.   Unpublished.
                               180

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