United States Office of Water EPA 821-R-97-007

Environmental Protection (4303) November 1997

Agency

1EPA Technical Development Document

for Proposed Pretreatment

Standards for Existing and New

Sources for the Industrial

Laundries Point Source Category
TECHNICAL DEVELOPMENT DOCUMENT FOR

PROPOSED PRETREATMENT STANDARDS

FOR EXISTING AND NEW SOURCES

FOR THE

INDUSTRIAL LAUNDRIES POINT SOURCE CATEGORY

Carol M. Browner

Administrator

Robert Perciasepe

Administrator, Office of Water

Sheila Frace

Acting Director, Engineering and Analysis Division

Marvin B. Rubin

Chief, Energy Branch

Marta Jordan

Work Assignment Manager

Engineering and Analysis Division

Office of Science and Technology

U.S. Environmental Protection Agency

Washington, D.C. 20460

November 7, 1997
ACKNOWLEDGEMENT AND DISCLAIMER

This report has been reviewed and approved for publication by the Engineering

and Analysis Division, Office of Science and Technology. This report was prepared with the

support of Eastern Research Group, Inc. (Contract No. 68-C5-0032), under the direction and

review of the Office of Science and Technology. Neither the United States Government nor any

of its employees, contractors, subcontractors, or their employees make any warrant, expressed or

implied, or assume any legal liability or responsibility for any third party's use of or the results of

such use of any information, apparatus, product, or process discussed in this report, or represents

that its use by such party would not infringe on privately owned rights.
FOREWORD

This document delineates the development of the proposed pretreatment standards

for the Industrial Laundries Point Source Category. Throughout the document, EPA refers to

many commonly used titles and phrases by their acronyms to avoid spelling them out each time. 

As an aid to the reader, EPA has included in Chapter 16 a glossary of commonly used acronyms

and definitions of terms used throughout the document.
i

TABLE OF CONTENTS

PAGE

CHAPTER 1 BACKGROUND ....................................... 1-1

1.1 Introduction ....................................... 1-1

1.2 Legal Authority .................................... 1-1

1.3 Background ....................................... 1-1

1.3.1 Clean Water Act ............................. 1-1

1.3.2 Pollution Prevention Act (PPA) .................. 1-4

1.3.3 Regulatory Flexibility Act (RFA) as 

Amended by the Small Business

Regulatory Enforcement Fairness

Act of 1996 (SBREFA) ........................ 1-4

1.3.4 Prior Regulation of the Industrial

Laundries Point Source Category ................. 1-5

CHAPTER 2 SUMMARY ........................................... 2-1

2.1 Introduction ....................................... 2-1

2.2 Overview of the Industrial Laundries

Industry .......................................... 2-1

2.3 Scope of the Proposed Regulation ...................... 2-2

2.4 Exclusion ......................................... 2-3

2.5 Pretreatment Standards for Existing Sources

(PSES) ........................................... 2-3

2.6 Pretreatment Standards for New Sources

(PSNS) ........................................... 2-3

2.7 Effluent Limitations Guidelines for Direct

Dischargers ....................................... 2-5

CHAPTER 3 DATA COLLECTION METHODOLOGY AND 

INFORMATION SOURCES .............................. 3-1

3.1 Introduction ....................................... 3-1

3.2 Summary of Data Collection Prior to 1992 ................ 3-2

3.2.1 1971 Survey ................................ 3-2

3.2.2 1975 Data Collection .......................... 3-2

3.2.3 1977 Data Collection Portfolio

(DCP) ..................................... 3-3

3.2.4 1978 Sampling Program ........................ 3-3

3.2.5 1979 Laundries Survey ........................ 3-4
TABLE OF CONTENTS (Continued)

Page

ii

3.2.6 Industrial Technology Division

(ITD)/Resource Conservation and

Recovery Act (RCRA) Sampling

Program and Development of the

Preliminary Data Summary (1985

through 1987) ..................................... 3-5

3.3 Summary of Industrial Laundries

Questionnaire Activity Since 1992 ...................... 3-6

3.3.1 Screener Questionnaires ........................ 3-6

3.3.2 1994 Industrial Laundries Industry

Questionnaire (Detailed

Questionnaire) ............................... 3-9

3.3.3 Detailed Monitoring Questionnaire ............... 3-12

3.4 Summary of EPA’s Site Visit Program

(1993-1997) ...................................... 3-13

3.4.1 Criteria for Site Visit Selection .................. 3-13

3.4.2 Types of Information Collected ................. 3-14

3.5 Summary of EPA’s Sampling Program

(1993-1996) ...................................... 3-14

3.5.1 Criteria for Sampling Site Selection .............. 3-14

3.5.2 Information Collected ........................ 3-15

3.5.3 Sample Collection and Analysis ................. 3-15

3.6 Other Industry-Supplied Data ......................... 3-16

3.7 POTW Data ...................................... 3-17

3.8 Summary of Literature Searches ....................... 3-18

3.9 Summary of Other Data Sources ...................... 3-20

3.9.1 Risk Reduction Engineering

Laboratory Treatability Database ................ 3-20

3.9.2 Fate of Priority Pollutants in

Publicly Owned Treatment Works

Database .................................. 3-20

3.9.3 The Domestic Sewage Study ................... 3-21

3.9.4 Canadian Studies ............................ 3-21

3.9.5 Industrial Pollution Prevention

Project .................................... 3-22

3.10 References ....................................... 3-22

CHAPTER 4 INDUSTRY PROFILE .................................. 4-1

4.1 Introduction ....................................... 4-1
TABLE OF CONTENTS (Continued)

Page

iii

4.2 Overview of the Industry ............................. 4-1

4.2.1 Geographic Distribution of

Facilities ................................... 4-2

4.2.2 SIC Codes Reported .......................... 4-2

4.2.3 Facility Size ................................. 4-2

4.2.4 Items Laundered ............................. 4-8

4.2.5 Customers .................................. 4-8

4.3 Laundering Processes ............................... 4-15

4.3.1 Water-Using/WastewaterGenerating Processes ......................... 4-15

4.3.2 Non-Water-Using/Non-WastewaterGenerating Processes ......................... 4-17

4.3.3 Chemicals Used in Industrial

Laundries .................................. 4-19

4.4 Facilities and Equipment ............................. 4-22

4.4.1 Washers, Extractors, and WasherExtractors ................................. 4-22

4.4.2 Tunnel Washers ............................. 4-24

4.4.3 Dry-Cleaning Units .......................... 4-24

4.4.4 Equipment Use and Age ....................... 4-24

4.5 Pollution Prevention Activities ........................ 4-24

4.6 Trends in the Industry ............................... 4-29

4.6.1 Trend Away from Dry Cleaning ................. 4-29

4.6.2 Trend of Small Facilities Being Purchased by 

Larger Firms ............................... 4-29

4.6.3 Trends in Equipment and Technologies ........... 4-30

4.7 Treatment Technologies in Use ........................ 4-30

4.8 References ....................................... 4-30

CHAPTER 5 WATER USE AND WASTEWATER CHARACTERIZATION . . 5-1

5.1 Introduction ....................................... 5-1

5.2 Sources of Service Water and Water Use ................. 5-1

5.2.1 Sources of Service Water at

Industrial Laundries ........................... 5-1

5.2.2 Use of Service Water at Industrial

Laundries ................................... 5-2

5.3 Wastewater Volume by Type of Discharge ................ 5-6

5.4 Water Conservation Measures ........................ 5-11
TABLE OF CONTENTS (Continued)

Page

iv

5.5 Characterization of Raw Wastewater by

Item Laundered ................................... 5-11

5.6 Characterization of Total, Heavy, and Light

Raw Wastewater Streams ............................ 5-11

CHAPTER 6 INDUSTRY SCOPE AND SUBCATEGORIZATION .......... 6-1

6.1 Introduction ....................................... 6-1

6.2 Regulatory Background .............................. 6-1

6.3 Industry Scope ..................................... 6-2

6.4 Subcategorization Analysis ............................ 6-7

6.4.1 Disproportionate Economic Impacts .............. 6-7

6.4.2 Laundry Processes and Water Use

Practices ................................... 6-8

6.4.3 Plant Age ................................... 6-8

6.4.4 Plant Location ............................... 6-8

6.4.5 Plant Size ................................... 6-9

6.4.6 Raw Materials .............................. 6-10

6.4.7 Non-water Quality Environmental

Impacts ................................... 6-10

6.4.8 Type of Item Laundered and

Wastewater Characteristics .................... 6-10

6.5 References ....................................... 6-11

CHAPTER 7 POLLUTANTS SELECTED FOR REGULATION ............ 7-1

7.1 Introduction ....................................... 7-1

7.2 Pollutants Considered for Regulation .................... 7-1

7.3 Identification of Pollutants of Concern ................... 7-4

7.4 Pollutants Selected for Regulation ..................... 7-10

7.4.1 Elimination of Parameters that

Comprise TPH .............................. 7-16

7.4.2 Elimination of Treatment

Chemicals ................................. 7-16

7.4.3 Elimination of Pollutants Not

Treated or Below Treatable

Concentrations .............................. 7-16

7.4.4 Elimination of Pollutants that Do

Not Pass Through or Otherwise

Interfere with POTWs ........................ 7-18
TABLE OF CONTENTS (Continued)

Page

v

7.4.5 Selection of Regulated Pollutants ................ 7-30

7.5 References ....................................... 7-36

CHAPTER 8 POLLUTION PREVENTION, RECYCLING, TREATMENT, 

AND DISPOSAL TECHNOLOGIES EMPLOYED BY THE

INDUSTRIAL LAUNDRIES INDUSTRY ................... 8-1

8.1 Introduction ....................................... 8-1

8.2 The Environmental Management Hierarchy ............... 8-1

8.3 Pollution Prevention/Source Reduction

in the Industrial Laundries Industry ...................... 8-3

8.3.1 Preprocess Pollution Prevention

Activities ................................... 8-4

8.3.2 In-Process Pollution Prevention

Activities ................................... 8-7

8.4 Pollution Recycling/Resource Conservation

and the Industrial Laundries Regulatory

Development Process ............................... 8-11

8.4.1 Wastewater Conservation in the

Industrial Laundries Industry ................... 8-12

8.4.2 Energy Conservation in the

Industrial Laundries Industry ................... 8-12

8.5 Wastewater Treatment Technologies in the

Industrial Laundries Industry ......................... 8-12

8.5.1 Gravity Settling ............................. 8-13

8.5.2 Stream Splitting ............................. 8-15

8.5.3 Screening .................................. 8-16

8.5.4 Equalization ................................ 8-18

8.5.5 Chemical Emulsion Breaking ................... 8-19

8.5.6 Chemical Precipitation ........................ 8-23

8.5.7 Dissolved Air Flotation (DAF) .................. 8-25

8.5.8 Sludge Dewatering ........................... 8-29

8.5.9 pH Adjustment .............................. 8-33

8.5.10 Ultrafiltration/Microfiltration ................... 8-34

8.5.11 Centrifugation .............................. 8-34

8.5.12 Volatile Organic Compound (VOC)

Removal Technologies ........................ 8-35

8.5.13 Oil/Water Separation ......................... 8-38

8.5.14 Media Filtration ............................. 8-39
TABLE OF CONTENTS (Continued)

Page

vi

8.6 Pollution Disposal Practices in the

Industrial Laundries Industry ......................... 8-39

8.7 References ....................................... 8-40

CHAPTER 9 TREATMENT PERFORMANCE DATA USED FOR THE

DEVELOPMENT OF LONG-TERM AVERAGES, 

VARIABILITY FACTORS, AND STANDARDS ............. 9-1

9.1 Introduction ....................................... 9-1

9.2 Sources of Treatment Technology

Performance Data From Well-Designed and

Well-Operated Treatment Systems ...................... 9-2

9.2.1 Industrial Laundry Sampling

Program Data ............................... 9-2

9.2.2 Detailed Monitoring Questionnaire

(DMQ) Data ................................ 9-4

9.3 Evaluation of Treatment Performance Data ............... 9-5

9.3.1 Assessment of Treatment System

Performance and Identification

of Process Upsets ............................ 9-6

9.3.2 Identification of Pollutants Not

Treated by the Treatment

Technology ................................. 9-6

9.3.3 Identification of Pollutants Not

Present in Influent Samples at

Sufficient Concentrations to

Evaluate Treatment Effectiveness ................. 9-7

9.3.4 Identification of Treatment

Performance Data With Inconsistent

Detection Limits ............................. 9-7

9.3.5 Identification of Data Considered a

Lower Limit of the Actual Value ................. 9-7

9.4 Long-Term Average Concentrations for the

Pollutants of Concern ................................ 9-7

9.5 Long-Term Average Concentrations,

Variability Factors, and Standards for the

Pollutants Proposed for Regulation ...................... 9-8

9.6 Identification of Data Used to Calculate the

Long-Term Average Concentrations for the

Prelaundering Technology Group ...................... 9-25
TABLE OF CONTENTS (Continued)

Page

vii

9.7 Mass-Based Standards .............................. 9-26

9.8 References ....................................... 9-26

CHAPTER 10 DEVELOPMENT OF REGULATORY OPTIONS ........... 10-1

10.1 Introduction ...................................... 10-1

10.2 Pretreatment Standards for Existing Sources

(PSES) .......................................... 10-1

10.2.1 Initial Technology Options

Considered ....................................... 10-1

10.2.2 Inclusion of Pollution Prevention in

the Technology Options ...................... 10-12

10.2.3 Exclusion of Wastewater Recycling

Activities from the Technology

Options .................................. 10-12

10.2.4 Initial Technology Options

Not Further Considered ...................... 10-13

10.2.5 Additional Technology Options

Considered ................................ 10-13

10.2.6 Technology Options Eliminated

from Further Consideration ................... 10-16

10.2.7 Regulatory Options Further

Considered for PSES ........................ 10-17

10.3 Pretreatment Standards for New Sources

(PSNS) ......................................... 10-17

10.4 References ...................................... 10-18

CHAPTER 11 POLLUTANT LOADING AND REMOVAL ESTIMATES .... 11-1

11.1 Introduction ...................................... 11-1

11.2 Data Sources ..................................... 11-2

11.3 Methodology Used to Estimate Pollutant

Loadings and Removals ............................. 11-3

11.3.1 Methodology Used to Estimate

Untreated Pollutant Loadings ................... 11-4

11.3.2 Methodology Used to Estimate

Baseline and Postcompliance

Wastewater Loadings ......................... 11-7

11.3.3 Methodology Used to Estimate

Pollutant Removals ......................... 11-12
TABLE OF CONTENTS (Continued)

Page

viii

11.4 Pollutant Loadings and Removals ..................... 11-17

CHAPTER 12 COSTS OF TECHNOLOGY BASES FOR REGULATIONS ... 12-1

12.1 Introduction ...................................... 12-1

12.2 Costing Methodology ............................... 12-2

12.2.1 Cost Model Development and

Structure .................................. 12-4

12.2.2 Components of the Cost of

Compliance ................................ 12-5

12.2.3 Treatment-in-Place Credit

Methodology .............................. 12-11

12.3 Cost Modeling ................................... 12-14

12.3.1 Cost Model Driver .......................... 12-14

12.3.2 Stream Splitting ............................ 12-15

12.3.3 Pumps ................................... 12-16

12.3.4 Screening ................................. 12-18

12.3.5 Equalization ............................... 12-19

12.3.6 Dissolved Air Flotation ...................... 12-20

12.3.7 Chemical Precipitation ....................... 12-22

12.3.8 Sludge Dewatering .......................... 12-24

12.3.9 pH Adjustment ............................. 12-26

12.3.10 Treatment System Building ................... 12-27

12.3.11 Contact Haul In Lieu of Treatment .............. 12-28

12.3.12 Compliance Monitoring ...................... 12-29

12.4 Engineering Costs by Regulatory Option ............... 12-30

12.5 References ...................................... 12-30

CHAPTER 13 REGULATORY OPTIONS SELECTION .................. 13-1

13.1 Introduction ...................................... 13-1

13.2 Regulatory Options Considered ....................... 13-1

13.2.1 Pretreatment Standards for Existing

Sources (PSES) ............................. 13-1

13.2.2 Pretreatment Standards for New

Sources (PSNS) ............................. 13-2

13.3 Final Regulatory Options Selection ..................... 13-3

13.3.1 Pretreatment Standards for Existing

Sources (PSES) ............................. 13-3
TABLE OF CONTENTS (Continued)

Page

ix

13.3.2 Pretreatment Standards for New

Sources (PSNS) ............................. 13-4

13.3.3 Direct Dischargers ........................... 13-4

CHAPTER 14 NON-WATER QUALITY ENVIRONMENTAL IMPACTS .... 14-1

14.1 Introduction ...................................... 14-1

14.2 Non-Water Quality Environmental Impacts

of the CP-IL and DAF-IL Regulatory

Options Considered as the Basis for PSES ............... 14-1

14.2.1 Energy Consumption Impacts .................. 14-2

14.2.2 Air Emissions Impacts ........................ 14-2

14.2.3 Solid Waste Impacts ......................... 14-9

14.3 Non-Water Quality Environmental Impacts

of the Regulatory Options Considered for

PSNS .......................................... 14-11

14.4 References ...................................... 14-11

CHAPTER 15 PRETREATMENT STANDARDS FOR EXISTING SOURCES

(PSES) AND PRETREATMENT STANDARDS FOR NEW

SOURCES (PSNS) ..................................... 15-1

15.1 Introduction ...................................... 15-1

15.2 Summary of the Proposed PSES and PSNS .............. 15-2

15.2.1 Regulated Facilities .......................... 15-2

15.2.2 POTW Pass-Through Analysis .................. 15-2

15.2.3 Regulated Pollutants ......................... 15-3

15.2.4 PSES and PSNS ............................ 15-3

15.3 Implementation of the PSES and PSNS ................. 15-6

15.3.1 Point of Application .......................... 15-6

15.3.2 Permit Limitations ........................... 15-6

15.3.3 Monitoring and Compliance ................... 15-11

15.4 References ...................................... 15-11

CHAPTER 16 GLOSSARY OF TERMS ............................... 16-1

Appendix A - Tables Referenced in Chapter 3

Appendix B - Tables Referenced in Chapter 5

Appendix C - Tables Referenced in Chapter 6

Appendix D - Tables Referenced in Chapter 7
x

LIST OF TABLES

Page

Table 2-1 Proposed PSES and PSNS for the Industrial Laundries Industry .......... 2-4

Table 4-1 Geographic Distribution of Industrial Laundries by State and 

Region ...................................................... 4-4

Table 4-2 Industrial Laundry Size Distribution ............................... 4-7

Table 4-3 Types of Items Laundered ....................................... 4-9

Table 4-4 Typical Customers for Each Type of Item Laundered ................. 4-11

Table 4-5 Laundering Processes Reported in the Detailed Questionnaire ........... 4-16

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

Questionnaire ............................................... 4-20

Table 4-7 Amounts of Detergent Added Per Pound of Laundry for Items 

Most Often Laundered ......................................... 4-21

Table 4-8 Age of Facilities and Start of Laundry/Dry-Cleaning Operations (Estimated

Percentage of Total Facilities in Each Time Period) ................... 4-23

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

Questionnaire ............................................... 4-25

Table 4-10 Age of Laundry Processing Equipment Reported in the Detailed 

Questionnaire (Percentage of Equipment Type Installed in Each Time

Period) .................................................... 4-26

Table 4-11 Pre-Process Pollution Prevention Activities ......................... 4-27

Table 4-12 In-Process Pollution Prevention Activities .......................... 4-28

Table 5-1 Service Water Sources .......................................... 5-3

Table 5-2 Service Water Use ............................................. 5-4

Table 5-3 Item-Specific Water Use ........................................ 5-7

Table 5-4 Discharge Practices of Industrial Laundries .......................... 5-9

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

Table 5-6 Wastewater Characterization for Item Specific Wastewater 

at Industrial Laundries ......................................... 5-13

Table 5-7 Wastewater Characterization Data for Heavy Wastewater Streams 

at Industrial Laundries ......................................... 5-20

Table 5-8 Wastewater Characterization Data for Light Wastewater Streams 

at Industrial Laundries ......................................... 5-23

Table 5-9 Wastewater Characterization Data for Total Raw Wastewater 

Streams at Industrial Laundries .................................. 5-26

Table 6-1 Comparison of Linen Facility and Industrial Laundry Facility Mean 

Pollutant Log Concentrations .................................... 6-4
LIST OF TABLES (Continued)

Page

xi

Table 6-2 Comparison of Linen Facility and Denim Prewash Facility Mean Pollutant 

Log Concentrations ............................................ 6-5

Table 7-1 Pollutants Not Detected in Any Samples Analyzed during the 

1993-1996 Industrial Laundries Sampling Program .................... 7-5

Table 7-2 Pollutants Detected in Less Than 10 Percent of Samples 

Analyzed During the 1993-1996 Industrial Laundries Sampling 

Program .................................................... 7-8

Table 7-3 Semiquantitative Metal and Elemental Pollutants Excluded from 

the Pollutants of Concern for the Industrial Laundries Industry ........... 7-9

Table 7-4 Average Influent Concentrations, Effluent Concentrations, and Removals 

for Phosphorous and Surfactants ................................. 7-11

Table 7-5 Pollutants of Concern for the Industrial Laundries Industry ............. 7-12

Table 7-6 Pollutants Selected for Proposed Regulation in the Industrial 

Laundries Industry ............................................ 7-17

Table 7-7 Pollutants Eliminated from Consideration for Regulation for the Industrial

Laundries Industry for Chemical Precipitation Options ................. 7-19

Table 7-8 Pollutants Eliminated from Consideration for Regulation for the Industrial

Laundries Industry for Dissolved Air Flotation Options ................ 7-21

Table 7-9 Comparison of the Chemical Precipitation Treatment Technology 

and POTW Percent Removals for the Industrial Laundries 

Pass-Through Analysis ........................................ 7-23

Table 7-10 Comparison of the DAF Treatment Technology and POTW 

Percent Removals for the Industrial Laundries Pass-Through 

Analysis .................................................... 7-25

Table 7-11 Generic Removal for n-Alkanes .................................. 7-31

Table 7-12 Pollutants Considered for Regulation for Chemical Precipitation 

and DAF after the Pass-Through Analysis .......................... 7-32

Table 8-1 Number of Industrial Laundries, by Production Category, Reporting 

Preprocess Pollution Prevention Activities in the Detailed Questionnaire .... 8-5

Table 8-2 Types of Preprocess Pollution Prevention Activities Reported in 

the Detailed Questionnaire ....................................... 8-6

Table 8-3 Number of Industrial Laundries, by Production Category, Reporting 

In-Process Pollution Prevention Activities in the Detailed 

Questionnaire ................................................ 8-8

Table 8-4 Types of In-Process Pollution Prevention Activities Reported in 

the Detailed Questionnaire ....................................... 8-9

Table 8-5 Number of Facilities Responding to Detailed Questionnaire Using 

Wastewater Treatment Technologies .............................. 8-14
LIST OF TABLES (Continued)

Page

xii

Table 9-1 Overall Long-Term Average (LTA) Concentrations for the Five 

Postlaundering Treatment Technology Groups for the Pollutants 

of Concern .................................................. 9-9

Table 9-2 Episode Long-Term Average (LTA) Concentrations and 

Variability Factors (VF) for Chemical Emulsion Breaking 

Treatment of Heavy Wastewater for the Pollutants Proposed for

Regulation .................................................. 9-13

Table 9-3 Summary of Long-Term Averages (LTA), Variability Factors (VF), 

and Standards for Chemical Emulsion Breaking Treatment of Heavy 

Wastewater ................................................. 9-14

Table 9-4 Episode Long-Term Average (LTA) Concentrations and Variability 

Factors (VF) for DAF Treatment of Heavy Wastewater for Pollutants 

Proposed for Regulation ....................................... 9-15

Table 9-5 Summary of Long-Term Averages (LTA), Variability Factors (VF), 

and Standards for DAF Treatment of Heavy Wastewater ............... 9-16

Table 9-6 Episode Long-Term Average (LTA) Concentrations and Variability 

Factors (VF) for Chemical Precipitation Treatment of Heavy 

Wastewater for the Pollutants Proposed for Regulation ................ 9-17

Table 9-7 Summary of Long-Term Averages (LTA), Variability Factors (VF), and

Standards for Chemical Precipitation Treatment of Heavy Wastewater .... 9-18

Table 9-8 Episode Long-Term Average (LTA) Concentrations and Variability 

Factors (VF) for DAF Treatment of All Facility Process Wastewater 

for the Pollutants Proposed for Regulation .......................... 9-19

Table 9-9 Summary of Long-Term Averages (LTV), Variability Factors (VF), and

Standards for DAF Treatment of All Facility Process Wastewater ........ 9-21

Table 9-10 Episode Long-Term Average (LTA) Concentrations and Variability 

Factors (VF) for Chemical Precipitation Treatment of All Facility 

Process Wastewater for the Pollutants Proposed for Regulation .......... 9-22

Table 9-11 Summary of Long-Term Averages (LTA), Variability Factors (VF), and

Standards for Chemical Precipitation Treatment of All Facility Process

Wastewater ................................................. 9-24

Table 9-12 Target Effluent Concentrations for Steam Tumbling of Heavy Items 

Before Water Washing for the Pollutants of Concern .................. 9-27

Table 10-1 Technology Options Initially Considered for the Industrial Laundries 

Proposed Rule ............................................... 10-2

Table 10-2 Definitions of Additional Technology Options Considered for PSES ..... 10-14

Table 11-1 Pollutant Loadings per Pound of Item Processed (mg Pollutant/lb Laundry) . 11-5

Table 11-2 Analytical Data Transfers ....................................... 11-6
LIST OF TABLES (Continued)

Page

xiii

Table 11-3 Methodology Used to Estimate Baseline Loadings for the Industrial 

Laundries Industry ............................................ 11-8

Table 11-4 Target Average Concentrations for DAF-IL and CP-IL for the Pollutants 

of Concern ................................................. 11-9

Table 11-5 Methodology Used to Estimate Postcompliance Loadings for DAF-IL 

for the Industrial Laundries Industry ............................. 11-13

Table 11-6 Methodology Used to Estimate Postcompliance Loadings for CP-IL 

for the Industrial Laundries Industry ............................. 11-14

Table 11-7 Methodology Used to Estimate Postcompliance Loadings for Combo-IL 

for the Industrial Laundries Industry ............................. 11-15

Table 11-8 Methodology Used to Estimate Postcompliance Loadings for 

Combo-IL-2LIM for the Industrial Laundries Industry ................ 11-16

Table 11-9 Summary of Pollutant Loadings and Removals for the Entire Industrial

Laundries Industry for OC-Only ................................ 11-18

Table 11-10 Summary of Pollutant Loadings and Removals for the Entire Industrial

Laundries Industry for DAF-IL ................................. 11-23

Table 11-11 Summary of Pollutant Loadings and Removals for the Entire Industrial

Laundries Industry for CP-IL .................................. 11-28

Table 11-12 Summary of Pollutant Loadings and Removals for the Entire Industrial

Laundries Industry for Combo-IL ............................... 11-33

Table 11-13 Summary of Pollutant Loadings and Removals for the Excluded 

Industrial Laundries (141 Facilities) for OC-Only .................... 11-38

Table 11-14 Summary of Pollutant Loadings and Removals for the Excluded 

Industrial Laundries (141 Facilities) for DAF-IL .................... 11-43

Table 11-15 Summary of Pollutant Loadings and Removals for the Excluded 

Industrial Laundries (141 Facilities) for CP-IL ...................... 11-48

Table 11-16 Summary of Pollutant Loadings and Removals for the Excluded 

Industrial Laundries (141 Facilities) for Combo-IL .................. 11-53

Table 12-1 Operation and Maintenance Unit Costs Used by the Cost Model ......... 12-7

Table 12-2 Capital Unit Costs Used by the Cost Model ......................... 12-9

Table 12-3 Components of Total Capital Investment .......................... 12-12

Table 12-4 Summary of PSES Engineering Costs ............................ 12-31

Table 12-5 Summary of PSES Annualized Engineering Costs for Industrial 

Laundries Included in the Proposed Regulation ..................... 12-32

Table 14-1 Incremental Energy Increases Associated With Implementation of the 

CP-IL and DAF-IL Regulatory Options ........................... 14-3

Table 14-2 Fugitive Air Emissions of Organic Pollutants From Industrial Laundry

Wastewater -- Analysis of a Worst-Case Scenario .................... 14-6
LIST OF TABLES (Continued)

Page

xiv

Table 14-3 Incremental Sludge Generation Increases Associated With Implementation 

of the CP-IL and DAF-IL Regulatory Options ...................... 14-10

Table 15-1 Pollutants Proposed to be Regulated Under PSES and PSNS ............ 15-4

Table 15-2 Proposed PSES and PSNS for the Industrial Laundries Industry ......... 15-5

Table 15-3 Alternative Concentration-Based Limits for Example Facilities .......... 15-9

Table 15-4 EPA-Approved Analytical Methods for Analyzing the Regulated 

Pollutants ................................................. 15-12
xv

LIST OF FIGURES

Page

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

Figure 5-1 Distribution of Facilities by Production Normalized Laundry Process

Water Use ................................................... 5-5

Figure 5-2 Distribution of Facilities by Production Normalized Laundry Process 

Water Discharge ............................................. 5-10

Figure 8-1 Environmental Management Options Hierarchy ....................... 8-2

Figure 8-2 Shaker Screen ............................................... 8-17

Figure 8-3 Batch Chemical Emulsion Breaking Unit ........................... 8-21

Figure 8-4 Continuous CEB Unit with Coalescing Plates ....................... 8-22

Figure 8-5 Batch Chemical Precipitation System .............................. 8-24

Figure 8-6 Continuous Chemical Precipitation System ......................... 8-26

Figure 8-7 Dissolved Air Flotation Unit .................................... 8-28

Figure 8-8 Rotary Vacuum Filter ......................................... 8-31

Figure 8-9 Filter Press ................................................. 8-32

Figure 8-10 Fixed Bed Activated Carbon Adsorption Column ..................... 8-37

Figure 10-1 CEB-Heavy Option: Chemical Emulsion Breaking of Heavy Industrial

Laundry Wastewater .......................................... 10-6

Figure 10-2 DAF-Heavy, DAF-IL, and DAF-TWL Options: Dissolved Air Flotation 

of a Portion of a Facility's Process Wastewater ...................... 10-7

Figure 10-3 CP-Heavy, CP-IL, and CP-TWL Options: Chemical Precipitation of a 

Portion of a Facility's Process Wastewater .......................... 10-8
LIST OF FIGURES (Continued)

Page

xvi

Figure 10-4 DAF-All Option: Dissolved Air Flotation of Total Facility Process 

Wastewater ................................................. 10-9

Figure 10-5 CP-All Option: Chemical Precipitation of Total Facility Process 

Wastewater ................................................ 10-10

Figure 10-6 OC-Only Option: In-Process Organics Control ..................... 10-11
Chapter 1 - Background

1-1

CHAPTER 1

BACKGROUND

1.1 Introduction

This chapter presents background information supporting the development of

effluent limitations guidelines and standards for the Industrial Laundries Point Source Category. 

Section 1.2 presents the legal authority to regulate the industrial laundries industry. Section 1.3

discusses the Clean Water Act, the Pollution Prevention Act, and the Regulatory Flexibility Act as

amended by the Small Business Regulatory Enforcement Fairness Act, as well as prior regulation

of the industrial laundries industry. 

1.2 Legal Authority

This regulation for the Industrial Laundries Point Source Category is being

proposed under authority of sections 301, 304, 306, 307, 308, and 501 of the Clean Water Act

(the Federal Water Pollution Control Act Amendments of 1972, 33 U.S.C. 1251 et seq., as

amended by the Clean Water Act of 1977, Pub. L. 95-217, and the Water Quality Act of 1987,

Pub. L. 100-4), also referred to as "the CWA" or "the Act."

1.3 Background

1.3.1 Clean Water Act

The Federal Water Pollution Control Act Amendments of 1972 established a

comprehensive program to "restore and maintain the chemical, physical, and biological integrity of

the Nation's waters" (section 101(a)). To implement the Act, EPA is to issue effluent limitations

guidelines, pretreatment standards, and new source performance standards for industrial

dischargers.

These guidelines and standards are summarized briefly below:

1. Best Practicable Control Technology Currently Available (BPT) (section

304(b)(1) of the Act).

BPT effluent limitations guidelines are generally based on the average of

the best existing performance by plants of various sizes, ages, and unit

processes within the category or subcategory for control of pollutants.

In establishing BPT effluent limitations guidelines, EPA considers the total

cost of achieving effluent reductions in relation to the effluent reduction

benefits, the age of equipment and facilities involved, the processes
Chapter 1 - Background

1-2

 employed, process changes required, engineering aspects of the control

technologies, non-water quality environmental impacts (including energy

requirements) and other factors as the EPA Administrator deems

appropriate (section 304(b)(1)(B) of the Act). The Agency considers the

category- or subcategory-wide cost of applying the technology in relation

to the effluent reduction benefits. Where existing performance is uniformly

inadequate, BPT may be transferred from a different subcategory or

category.

2. Best Available Technology Economically Achievable (BAT) (sections

304(b)(2)(B) and 307(a)(2) of the Act).

In general, BAT effluent limitations represent the best existing

economically achievable performance of plants in the industrial subcategory

or category. The Act establishes BAT as the principal national means of

controlling the direct discharge of priority pollutants and nonconventional

pollutants to navigable waters. The factors considered in assessing BAT

include the age of equipment and facilities involved, the process employed,

potential process changes, and non-water quality environmental impacts,

including energy requirements (section 304(b)(2)(B)). The Agency retains

considerable discretion in assigning the weight to be accorded these

factors. As with BPT, where existing performance is uniformly inadequate,

BAT may be transferred from a different subcategory or category. BAT

may include process changes or internal controls, even when these

technologies are not common industry practice.

3. Best Conventional Pollutant Control Technology (BCT) (section 304(a)(4)

of the Act).

The 1977 Amendments added section 301(b)(2)(E) to the Act establishing

BCT for discharges of conventional pollutants from existing industrial

point sources. Section 304(a)(4) designated the following as conventional

pollutants: biochemical oxygen demanding pollutants (BOD), total

suspended solids (TSS), fecal coliform, pH, and any additional pollutants

defined by the Administrator as conventional. The Administrator

designated oil and grease as an additional conventional pollutant on July

30, 1979 (44 FR 44501).

BCT is not an additional limitation, but replaces BAT for the control of

conventional pollutants. In addition to other factors specified in section

304(b)(4)(B), the Act requires that BCT limitations be established in light

of a two part "cost-reasonableness" test. [American Paper Institute v.

EPA, 660 F.2d 954 (4th Cir. 1981)]. EPA's current methodology for the
Chapter 1 - Background

1-3

general development of BCT limitations was issued in 1986 (51 FR 24974;

July 9, 1986).

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

NSPS are based on the best available demonstrated treatment technology. 

New plants have the opportunity to install the best and most efficient

production processes and wastewater treatment technologies. As a result,

NSPS should represent the most stringent numerical values attainable

through the application of the best available demonstrated control

technology for all pollutants (i.e., conventional, nonconventional, and

priority pollutants). In establishing NSPS, EPA is directed to take into

consideration the cost of achieving the effluent reduction and any

non-water quality environmental impacts and energy requirements.

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

Act).

PSES are designed to prevent the discharge of pollutants that pass through,

interfere with, or are otherwise incompatible with the operation of publicly

owned treatment works (POTWs). The Act requires pretreatment

standards for pollutants that pass through POTWs or interfere with

POTWs' treatment processes or sludge disposal methods. The legislative

history of the 1977 Act indicates that pretreatment standards are to be

technology-based and analogous to the BAT effluent limitations guidelines

for removal of toxic pollutants. For the purpose of determining whether to

promulgate national category-wide pretreatment standards, EPA generally

determines that there is pass through of a pollutant and thus a need for

categorical standards if the nationwide average percent of a pollutant

removed by well-operated POTWs achieving secondary treatment is less

than the percent removed by the BAT model treatment system. 

The General Pretreatment Regulations, which set forth the framework for

the implementation of categorical pretreatment standards, are found at 40

CFR Part 403. Those regulations contain a definition of pass through that

addresses localized rather than national instances of pass through and does

not use the percent removal comparison test described above (52 FR 1586;

January 14, 1987).
Chapter 1 - Background

1-4

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

Act).

Like PSES, PSNS are designed to prevent the discharges of pollutants that

pass through, interfere with, or are otherwise incompatible with the

operation of POTWs. PSNS are to be issued at the same time as NSPS. 

New indirect dischargers, like the new direct dischargers, have the

opportunity to incorporate into their plants the best available demonstrated

technologies. The Agency considers the same factors in promulgating

PSNS as it considers in promulgating NSPS.

1.3.2 Pollution Prevention Act (PPA)

In the Pollution Prevention Act of 1990 (42 U.S.C. 13101 et seq., Pub.L. 101-508,

November 5, 1990), Congress declared pollution prevention to be the national policy of the

United States. The Act declares that pollution should be prevented or reduced whenever feasible;

pollution that cannot be prevented should be recycled or reused in an environmentally safe manner

wherever feasible; pollution that cannot be recycled should be treated; and disposal or release into

the environment should be chosen only as a last resort. The PPA directs the Agency to, among

other things, "review regulations of the Agency prior and subsequent to their proposal to

determine their effect on source reduction" (Sec. 6604; 42 U.S.C. 13103(b)(2)). This proposed

regulation for the Industrial Laundries Point Source Category was reviewed for its incorporation

of pollution prevention as part of EPA's effort. Chapter 8 of this document describes the results

of this effort. 

1.3.3 Regulatory Flexibility Act (RFA) as Amended by the Small Business

Regulatory Enforcement Fairness Act of 1996 (SBREFA)

Under the Regulatory Flexibility Act (RFA), 5 U.S.C. 601 et seq., as amended by

SBREFA, EPA generally is required to conduct an initial regulatory flexibility analysis (IFRA)

describing the impact of the proposed rule on small entities. Under section 605(b) of the RFA, if

the Administrator certifies that the rule will not have a significant impact on a substantial number

of small entities, EPA is not required to prepare the IFRA. 

Although this proposed rule minimizes impacts on small businesses through an

exclusion, EPA conducted an IFRA pursuant to section 603(b) of the RFA addressing:

C The need for, objectives of, and legal basis for the rule.

C A description of, and where feasible, an estimate of the number of small

entities to which the rule would apply.

C The projected reporting, recordkeeping, and other compliance

requirements of the rule, including an estimate of the classes of small
Chapter 1 - Background

1-5

entities that would be subject to the rule and the types of professional skills

necessary for preparation of the report or record.

C An identification, where practicable, of all relevant federal rules which may

duplicate, overlap, or conflict with the proposed rule.

C A description of any significant regulatory alternatives to the proposed rule

which accomplish the stated objectives of applicable statutes and which

minimize any significant economic impact of the proposed rule on small

entities. Consistent with the stated objectives of the CWA, the analysis

discusses significant alternatives such as:

— Establishing differing compliance or reporting requirements or

timetables that take into account the resources available to small

entities.

— Clarification, consolidation, or simplification of compliance and

reporting requirements under the rule for such small entities.

— The use of performance rather than design standards.

— An exclusion from coverage of the rule, or any part thereof, for

such small entities. Based on the IRFA and other factors, this

proposed rule incorporates an exclusion to eliminate

disproportionate impacts on small businesses and also reduces the

number of small businesses affected by the proposed rule.

Pursuant to the RFA as amended by SBREFA, EPA convened a Small Business

Advocacy Review Panel. The Panel is comprised of representatives from three federal agencies:

EPA, the Small Business Administration, and the Office of Management and Budget. The Panel

reviewed materials EPA prepared in connection with the RFA, and collected the advice and

recommendations of small entity representatives. For this proposed rule, the small entity

representatives included owners of small industrial laundries and trade association representatives. 

The Panel prepared a report (available in the administrative record for this rulemaking) that

summarizes their outreach to small entities and the comments submitted by the small entity

representatives. The Panel’s report also presents their findings on issues related to the elements

of an IRFA.

1.3.4 Prior Regulation of the Industrial Laundries Point Source Category

The Federal Water Pollution Control Act Amendments of 1972 established a

program to clean up the nation's waters that consisted of, along with other requirements, a

program of establishing technology-based effluent limitations guidelines for point source

dischargers by industry categories and a timetable for issuing these guidelines. Pursuant to a 1976
Chapter 1 - Background

1-6

settlement agreement and subsequently the 1977 Clean Water Act Amendments, EPA was

required to develop a program and adhere to a schedule in promulgating effluent limitations

guidelines and pretreatment standards for 65 "toxic" pollutants and classes of pollutants, for 21

major industries. Moreover, the Agency is required by section 301 (d) of the Federal Water

Pollution Control Act Amendments of 1972 and the Clean Water Act of 1977 to review and

revise, if necessary, effluent limitations promulgated pursuant to sections 301, 304, 306, 307, 308,

and 501 of the Act.

The Auto and Other Laundries Category, of which industrial laundries was a

subcategory, was one of the categories mandated for study and possible effluent limitations

guidelines and standards development by the 1976 Settlement Agreement. Several studies were

undertaken in 1977 through 1980 to collect more information about the industrial laundries

industry, including two surveys (1977 and 1979) and wastewater sampling and analysis programs

conducted in 1978 (screening and verification study). However, in 1982, the Auto and Other

Laundries Category, including the industrial laundries subcategory, was excluded from regulation. 

The industrial laundries subcategory was excluded because, based on assessments made at that

time, it was determined that 95 percent of the industry discharged pollutants that could be treated

by POTWs and that did not pass through, interfere with, or otherwise prove incompatible with the

operation of POTWs.

However, following these assessments, additional data were collected by the

Industrial Technology Division (ITD - now Engineering and Analysis Division (EAD)) as part of

work efforts in conjunction with EPA's Office of Solid Waste's Resource Conservation and

Recovery Act (RCRA) Program in 1985 through 1987. In 1986, EPA published its Domestic

Sewage Study (DSS), which identified industrial laundries as potential contributors of large

amounts of hazardous pollutants to the POTWs. Based on information gathered to that point, the

Agency compiled a profile of the industrial laundries industry that was published as a Preliminary

Data Summary in 1989. 

Section 304(m) of the Clean Water Act (33 U.S.C. 1314(m)), added by the Water

Quality Act of 1987, requires EPA to establish schedules for (i) reviewing and revising existing

effluent limitations guidelines and standards ("effluent guidelines"), and (ii) promulgating new

effluent guidelines. On January 2, 1990, EPA published an Effluent Guidelines Plan (55 FR 80),

in which schedules were established for developing new and revised effluent guidelines for several

industrial categories. In addition, the plan listed several industrial categories that were to be

studied to determine whether rulemakings to develop effluent guidelines and standards should be

initiated. One of those categories was the Industrial Laundries Point Source Category, based on

the results of the 1985 to 1987 work contained in the DSS. 

Natural Resources Defense Council, Inc. (NRDC) and Public Citizen, Inc.

challenged the Effluent Guidelines Plan in a suit filed in U.S. District Court for the District of

Columbia (NRDC et al. v. Reilly, Civ. No. 89-2980). The plaintiffs charged that EPA's plan did

not meet the requirements of section 304(m). A Consent Decree (the "304(m) Decree") in this

litigation was entered by the Court on January 31, 1992 (57 FR 19748), which established
Chapter 1 - Background

1-7

schedules for, among other things, EPA's proposal and promulgation of effluent guidelines for a

number of categories, including the Industrial Laundries Point Source Category. The most recent

Effluent Guidelines Plan update was published on February 26, 1997 (62 FR 8726). This plan

requires, among other things, that EPA propose effluent limitations guidelines and pretreatment

standards for the Industrial Laundries Point Source Category by September 1997 and take final

action by June 1999. Further modification of the Decree in August 1997 set the proposal date no

later than November 7, 1997.
Chapter 2 - Summary

2-1

CHAPTER 2

SUMMARY

2.1 Introduction

The proposed regulations for the industrial laundries industry include pretreatment

standards for the control of wastewater pollutants. This chapter presents a summary of the

proposed rule. Section 2.2 presents a brief overview of the industry, Section 2.3 discusses the

scope of the proposed rule, Section 2.4 describes the proposed exclusion to the rule, and Sections

2.5 through 2.7 summarize the proposed pretreatment standards and effluent limitations

guidelines. 

2.2 Overview of the Industrial Laundries Industry

The industrial laundries industry includes facilities that launder or dry clean

industrial garments and uniforms, shop towels, printer towels/rags, mops, mats, and dust-control

items. Either the laundry facilities or their customers own the laundered items. Many facilities

covered by the proposed rule also wash other items not classified as industrial laundry items, such

as linen supply garments, linen flatwork, health-care items, and miscellaneous other items.

Industrial laundry facilities are located in all 50 states and all 10 EPA Regions. By

state, the largest number of laundries are located in California. By EPA Region, the largest

concentration of laundries is in Region IV. Most of the laundering facilities are situated in large

urban areas. EPA estimates that there are 1,747 industrial laundry facilities nationwide.

Industrial laundries vary in size from one- to two-person shops to large

corporations that operate many facilities nationwide. The industry shows a corresponding wide

range of annual laundry production. Facilities laundering more than 15,000,000 pounds per year

account for approximately eight percent of the total industry, whereas facilities laundering less

than 3,000,000 pounds per year account for approximately 37 percent of the total industry. 

Approximately 10 percent of the facilities that meet EPA's definition of an industrial laundry

launder less than 1,000,000 pounds per year.

Facilities launder most items using water washing. Water washing involves

washing items in water. Some facilities launder items using dry cleaning, which involves washing

items in an organic solvent. In some cases, facilities combine the two processes to wash items

that have large amounts of both water-soluble and organic solvent-soluble soils. When water

washing and dry cleaning are performed in series without drying the items between the water and

solvent phases, the process is called dual-phase washing. The order in which these processes are

performed depends on the solvent used, type of soil, and drying energy requirements. Some mops

are laundered through a combination of water washing and oil treatment. The oil is applied to the

mop to help collect dust. 
Chapter 2 - Summary

2-2

Facilities water-wash nearly 97 percent of their items using a standard process. 

Approximately one percent of laundered items are dry-cleaned, including some items that are drycleaned and then water-washed. Dual-phase washing and mop cleaning with water and oil each

accounts for less than one percent of the total production. The remaining laundry items are

processed using other cleaning operations (e.g., oil cleaning of mops in a process that does not

use any water).

Based on data collected by EPA for this rulemaking, industrial laundries use over

90 percent of all incoming service water as laundry process water, followed in descending

amounts by sanitary water, noncontact cooling water, and boiler water. Chemicals frequently

used in industrial laundry operations include alkaline solutions, detergents, bleach, antichlor,

sours, softeners, and starch. A variety of other items that are added to some wash formulas

include enzymes, builders, oil treatment chemicals, water conditioners, dyes, stain treatment

chemicals, and bactericides. The primary pollutants discharged by industrial laundries are all of

the conventional pollutants except fecal coliform (oil and grease, biochemical oxygen demand

(BOD ), and total suspended solids (TSS)), and a number of priority and nonconventional 5

pollutants, including copper, lead, zinc, ethylbenzene, toluene, and total petroleum hydrocarbons

(TPH), measured as silica gel treated hexane extractable material. All of the industrial laundries

identified by EPA discharge their process wastewater to publicly owned treatment works

(POTWs).

2.3 Scope of the Proposed Regulation

The proposed pretreatment standards apply to process wastewater discharges from

new and existing industrial laundries. EPA is proposing the following definition of industrial

laundries: An industrial laundry is any facility that launders industrial textile items from off site as

a business activity (i.e., launders industrial textile items for other business entities for a fee or

through a cooperative arrangement). Either the industrial laundry facility or the off-site customer

may own the industrial laundered textile items. This definition includes textile rental companies

that perform laundering operations. Laundering means washing with water, including water

washing following dry cleaning. This rule would not apply to laundering exclusively through dry

cleaning. Industrial textile items include, but are not limited to industrial: shop towels, printer

towels/rags, furniture towels, rags, mops, mats, rugs, tool covers, fender covers, dust-control

items, gloves, buffing pads, absorbents, uniforms, filters, and clean room items. If any of these

items are used for hotels, hospitals, or restaurants, they are not industrial items.

The proposed rule would not apply to discharges from on-site laundering at

industrial facilities, laundering of industrial textile items originating from the same business entity,

and facilities that exclusively launder linen items, denim prewash items, new items (i.e., items

directly from the textile manufacturer, not yet used for their intended purpose), any other

laundering of hotel, hospital, or restaurant items, or any combination of these items. This

proposed rule would apply to hotel, hospital, or restaurant laundering of industrial textile items. 

In addition, this rule would not apply to discharges from the oil-only treatment of mops. Linen

items include sheets, pillowcases, blankets, bath towels and washcloths, hospital gowns and robes,
Chapter 2 - Summary

2-3

tablecloths, napkins, tableskirts, kitchen textile items, continuous roll towels, laboratory coats,

household laundry (such as clothes, but not industrial uniforms), executive wear, mattress pads,

incontinence pads, and diapers (this list is meant to be all-inclusive).

For facilities covered under the industrial laundry definition, wastewater from all

water-washing operations would be covered, including the washing of linen items, as long as these

items do not constitute 100 percent of the items washed.

2.4 Exclusion

Under Pretreatment Standards for Existing Sources (PSES), EPA is proposing to

exclude existing facilities that launder less than one million pounds of incoming laundry per

calendar year and less than 255,000 pounds of shop and/or printer towels/rags per calendar year. 

EPA proposes this exclusion to eliminate the unacceptable economic impacts on these smaller

facilities. The excluded facilities would be disproportionately adversely impacted relative to all

facilities covered by this rule. Most of the excluded facilities are small entities under the Small

Business Administration (SBA) definition of small entity. The excluded facilities account for less

than three percent of the pollutant removals from U.S. waters than would occur if the rule were

implemented without the exclusion.

Under Pretreatment Standards for New Sources (PSNS), EPA is proposing no

exclusions for new sources since the economic projections indicate that there would be no barrier

to entry as a result of the proposed new source standards.

2.5 Pretreatment Standards for Existing Sources (PSES)

EPA is proposing PSES numerical limitations based on chemical precipitation

technology treatment of industrial laundry wastewater for 11 priority and nonconventional

pollutants. The pretreatment standards are applicable to all process wastewater discharged by

facilities that are within the scope of the rule. Industrial laundries laundering less than one million

pounds per year of industrial laundry and less than 255,000 pounds per year of shop and/or printer

towels/rags are excluded from regulation under PSES. PSES are presented in Table 2-1.

2.6 Pretreatment Standards for New Sources (PSNS)

EPA is proposing PSNS based on chemical precipitation of industrial laundry

wastewater for 11 priority and nonconventional pollutants. The new source standards are

applicable to all process wastewater discharged by industrial laundries that meet the definition of a

new source. PSNS are presented in Table 2-1.
Chapter 2 - Summary

2-4

Table 2-1

Proposed PSES and PSNS for the Industrial Laundries Industry

Pollutant or Pollutant Property (mg/L) (mg/L)

Proposed PSES and PSNS for End-of-Pipe Monitoring Points

Maximum for any 1 day Monthly Average

Copper 0.24 ---

1

Lead 0.27 ---

1

Zinc 0.61 ---

1

Bis(2-ethylhexyl) Phthalate 0.13 ---

1

Ethylbenzene 1.64 ---

1

Naphthalene 0.23 ---

1

Tetrachloroethene 1.71 ---

1

Toluene 2.76 ---

1

m-Xylene2 1.33 ---

1

o-&p-Xylene2 0.95 ---

1

TPH (as SGT-HEM) 27.5 15.4 3

EPA is not proposing monthly average limitations for these pollutants. 1

EPA is proposing the use of EPA Methods 1624 and 624 for the analysis of xylenes, even though xylenes are not specifically listed as an analyte in 2

either of these methods (promulgated at 40 CFR Part 136). EPA used data obtained from the analysis of xylenes by these two methods in the

development of the proposed industrial laundry standards.

TPH (as SGT-HEM) is total petroleum hydrocarbons measured by the silica gel treated-hexane extractable material analytical method proposed 3

January 23, 1996 (Method 1664).
Chapter 2 - Summary

2-5

2.7 Effluent Limitations Guidelines for Direct Dischargers

EPA has not identified any direct dischargers in the industrial laundries industry or

any candidate indirect dischargers, or transfer of performance data from facilities in other

industries or from pilot-scale test results for determining the appropriate level of performance to

set limitations for direct discharging new sources; therefore, EPA has not developed effluent

limitations guidelines for direct wastewater discharges to surface waters. As a result, the Agency

is reserving effluent limitations guidelines and standards for the following levels of control for the

Industrial Laundries Point Source Category: Best Practicable Control Technology Currently

Available (BPT), Best Conventional Pollutant Control Technology (BCT), Best Available

Technology Economically Achievable (BAT), and New Source Performance Standards (NSPS).
Chapter 3 - Data Collection Methodology and Information Sources

3-1

CHAPTER 3

DATA COLLECTION METHODOLOGY AND INFORMATION SOURCES

3.1 Introduction

In 1992, EPA published a notice in the Federal Register (57 FR 19748) indicating

its intent to develop effluent limitations guidelines and standards for the industrial laundries

industry. EPA collected information necessary for the development of this rule from many

sources. EPA initially collected data on a broad group of laundry facilities that included industrial

laundries as well as linen laundries, denim prewash facilities, and other laundry facilities. These

data were necessary to define the scope and applicability of the regulation. Throughout this

chapter, the term "laundry" is used to indicate that information was collected from industrial

laundries as well as other laundry facilities. The scope and applicability of the proposed

regulation are discussed in detail in Chapter 6. 

This chapter summarizes the information collection activities undertaken and the

information sources used for this proposed rulemaking, as follows:

C Section 3.2 summarizes data collection efforts prior to 1992;

C Section 3.3 discusses the questionnaire activities conducted since 1992;

C Section 3.4 summarizes EPA's site visit program conducted from 1993

through 1997;

C Section 3.5 discusses EPA's sampling program conducted from 1993

through 1996;

C Section 3.6 presents other industry-collected data efforts;

C Section 3.7 discusses data collected from publicly owned treatment works

(POTWs);

C Section 3.8 summarizes literature searches performed on the industrial

laundries industry; 

C Section 3.9 summarizes other sources of data on the industrial laundries

industry; and

C Section 3.10 presents the references used in this section.
Chapter 3 - Data Collection Methodology and Information Sources

3-2

3.2 Summary of Data Collection Prior to 1992

Prior to 1992, EPA conducted several studies of the laundries industry. These

efforts consisted of the following:

C The 1971 EPA survey of 160 industrial laundries, linen services, and diaper

services (Section 3.2.1);

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

C The 1977 data collection portfolio (DCP) for approximately 70 facilities

(Section 3.2.3);

C The 1978 screening and verification analysis studying samples from

approximately 10 facilities for priority pollutants (Section 3.2.4);

C The 1979 laundries survey (Section 3.2.5); and

C The 1985 through 1987 Industrial Technology Division (ITD)/Resource

Conservation and Recovery Act (RCRA) sampling program and

development of the Preliminary Data Summary for the Industrial Laundries

Industry (1) (Section 3.2.6). 

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

detail.

3.2.1 1971 Survey

EPA's first study of the industrial laundries industry, initiated in 1971, involved

sending a survey to 160 facilities. These facilities were all members of the Institute of Industrial

Launderers (IIL, now the Uniform and Textile Service Association (UTSA)) or the Linen Supply

Association of America (LSAA, now the Textile Rental Services Association of America

(TRSA)) and included industrial laundries, linen services, and diaper services. In addition to

wastewater analytical data obtained from the survey, EPA collected sampling data for

conventional and nonconventional pollutants and some metals at a small number of facilities. 

3.2.2 1975 Data Collection

In 1975, EPA initiated sampling and analysis of wastewaters generated by the

Auto and Other Laundries Point Source Category, of which the industrial laundries industry was

identified as a subcategory. These early programs concentrated primarily on collecting data on

conventional and nonconventional pollutants and trace metals. EPA collected samples at 73

laundries for conventional pollutants (pH, biochemical oxygen demand (BOD5), total suspended
Chapter 3 - Data Collection Methodology and Information Sources

3-3

solids (TSS), and oil and grease) and nonconventional pollutants (chemical oxygen demand

(COD), total organic carbon (TOC), and phosphorus). 

3.2.3 1977 Data Collection Portfolio (DCP)

In 1977, EPA sent a data collection portfolio (DCP) to a number of laundry

facilities including industrial laundries (SIC Code 7218), power laundries (SIC Code 7211), linen

supply laundries (SIC Code 7213), and institutional laundries. Completed DCPs were received

from approximately 70 industrial laundries. The survey requested the following types of

information:

C Type of laundry;

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

C Types of processes;

C Production information;

C Types of customers serviced;

C Laundering chemicals used;

C Water usage;

C Effluent discharge;

C Information on wastewater treatment and in-plant controls;

C Recommendations for design features;

C Space available for treatment;

C Available priority pollutant data; and

C Unique features.

3.2.4 1978 Sampling Program

In 1978, EPA initiated a sampling program to determine the presence and

concentrations of 129 priority pollutants, which were identified from the 65 toxic pollutants and

classes of pollutants (and subsequently reduced to 126 priority pollutants), as defined by the

Consent Decree (see Section 1.3.4 for discussion of the Consent Decree), in wastewaters from

facilities in the Auto and Other Laundries Point Source Category. EPA sampled a total of 40
Chapter 3 - Data Collection Methodology and Information Sources

3-4

facilities for toxic and conventional pollutants using automatic time-compositing equipment

during operating hours at each facility. In most cases, sampling was for one day only. At

facilities where wastewater treatment was in place, EPA collected samples of both treatment

influent and effluent. EPA also sampled an industrial laundry using a dissolved air flotation

(DAF) treatment system over a one-month period to obtain data on the variability of this type of

treatment system. 

3.2.5 1979 Laundries Survey

In 1979, EPA sent a survey to 31 industrial laundries and 14 linen laundries in five

major cities to determine the availability of sufficient space for installation of treatment systems. 

Approximately 50 percent of the survey dealt specifically with available space at facilities without

treatment. Other information obtained included:

C Business classification;

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

C Processes used;

C Production information;

C Water usage;

C Effluent discharge;

C In-plant controls used; and

C Wastewater treatment practiced.

In 1981, EPA chose not to establish effluent limitations for the Auto and Other

Laundry Point Source Category, of which industrial laundries was a subcategory, because EPA

determined that 95 percent of the discharged pollutants were amenable to treatment by POTWs

and did not pass through, interfere with, or prove otherwise incompatible with the operation of

POTWs. Therefore, no further data collection efforts were undertaken until 1985.
Chapter 3 - Data Collection Methodology and Information Sources

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3.2.6 Industrial Technology Division (ITD)/Resource Conservation and Recovery

Act (RCRA) Sampling Program and Development of the Preliminary Data

Summary (1985 through 1987)

EPA conducted a program to obtain wastewater and solid waste samples at five

industrial laundries located in different regions of the U.S. EPA used information obtained during

previous data-gathering efforts in conjunction with advice and assistance from the UTSA (known

as the Institute of Industrial Launderers (IIL) at the time) to select seven laundries for site visits. 

Four of these facilities were sampled in 1986 and 1987. The fifth facility was sampled in 1985 as

part of the Domestic Sewage Study (discussed in Section 3.9.3).

At the industrial laundry sampled in 1985, EPA collected composite samples of the

final effluent after a settling basin over the course of one operating day. EPA collected

wastewater samples from untreated wastewater streams and final effluent wastewater streams at

the four other industrial laundry facilities. EPA sampled these four facilities for two consecutive

days and composited the wastewater over the course of each operating day. EPA collected final

effluent samples from two dissolved air flotation systems, one ultrafiltration system, and a settling

basin. 

EPA analyzed the samples for conventional pollutants, priority and

nonconventional organic pollutants, priority and nonconventional metal pollutants, and other

nonconventional pollutants, which later comprised the "ITD List of Analytes".

Other sources of information about the industrial laundries industry investigated

during this time period included:

C Telephone interviews with, and visits to, personnel at EPA regional and

state offices, industry trade associations, and representative industrial

laundries; 

C Telephone interviews with POTW representatives; and

C Literature review, including research reports, journals and magazines,

computer-based abstract databases, and computer-based censuses.

The information collected during this time period was used to prepare the Preliminary Data

Summary for the Industrial Laundries Industry (1) and formed the basis for EPA's decision to

develop effluent limitations guidelines and standards for the Industrial Laundries Point Source

Category.
Chapter 3 - Data Collection Methodology and Information Sources

3-6

3.3 Summary of Industrial Laundries Questionnaire Activity Since 1992

EPA's first step in developing the current proposed rule for the industrial laundries

industry was to gather current data from the industry, under the authority of section 308 of the

Clean Water Act. EPA sent four screener questionnaires to different segments of the laundry

industry between 1993 and 1995 to collect information to be used in identifying the population of

the laundry industry, developing the scope of the regulation, and determining which facilities

should receive a more detailed questionnaire. Based on data collected from the screener survey

and a search of the Dun & Bradstreet listing for laundry facilities, EPA sent a detailed

questionnaire to a subset of identified laundry facilities. Based on the responses to the detailed

questionnaire, EPA sent a monitoring questionnaire to a subset of the facilities that had received a

detailed questionnaire. These data-gathering efforts are described in more detail below. 

Additional details on the data-gathering efforts are found in the Statistical Support Document for

Proposed Pretreatment Standards for Existing and New Sources for the Industrial Laundries Point

Source Category (2). Copies of nonconfidential questionnaires are contained in the administrative

record for this rulemaking.

3.3.1 Screener Questionnaires

EPA conducted four separate mailings of slightly different screener questionnaires

to develop the scope of the regulation, identify the population of the industry, and select facilities

to receive the more detailed questionnaire. EPA also used the screener questionnaires to

characterize the industry and to determine that industrial laundries population. More details on

determining the industrial laundries population are provided in the Statistical Support Document

(2). Summarized industry characterization data are provided in Chapters 4, 5, and 8 of this

document. The four different screener questionnaires and their mailings are discussed in the

following sections.

The 1993 Industrial Laundries Industry Screener Questionnaire

In 1993, EPA developed and mailed out the two-page 1993 Industrial Laundries

Industry Screener Questionnaire to a large number of industrial laundries to solicit updated

information on the industry. The purpose of this screener questionnaire was to characterize the

industry and to determine which facilities may be in-scope for the proposed rule. The screener

questionnaire requested information on the relative amounts and types of items received for

laundering, the type of waste treatment operations, the amount of water used, and wastewater

disposal practices. A blank copy of the questionnaire, along with copies of the nonconfidential

portions of the completed screener questionnaires, are contained in Section 6.2 of the

administrative record for this rulemaking.

EPA sent the screener questionnaire to a total of 1,751 facilities. EPA selected

1,745 of these facilities from the UTSA customer and prospective customer lists, the Textile

Rental Service Association (TRSA) mailing list, and the Occupational Safety and Health
Chapter 3 - Data Collection Methodology and Information Sources

3-7

Administration's (OSHA) list of violations for industrial laundries. EPA added six facilities to the

list as a result of companies requesting screeners for their facilities that had not received one.

Of the 1,751 screener questionnaires mailed, 1,543 were returned. In addition,

three facilities that were not on the mailing list received a copy of the screener from their parent

company and returned the completed copy, bringing the total of completed screener

questionnaires returned to 1,546. A summary of the results of the mailout of the screener

questionnaires is shown in the following table.

Status of 1993 Screener Questionnaire Number of Questionnaires

Returned 1,5461

Screener undeliverable or facility known to be out-of- 86

scope

Nonresponsive 122

Duplicate facilities found 462

Total 1,754

Three facilities not on the original mailing list completed and returned the questionnaire at the request of their parent 1

company.

This number is included in the number of screeners returned. 2

EPA received the screener questionnaire responses, reviewed them for

completeness and accuracy, and entered the information into a database. EPA contacted by

telephone respondents who provided incomplete or contradictory technical information to obtain

correct information.

1993 Industrial Laundries Industry Supplemental Screener Questionnaire

The Dun & Bradstreet listing was used to identify industrial laundries not captured

by the trade association mailing lists developed for the original screener questionnaire. Facilities

listed in Dun & Bradstreet with primary SIC codes of 7218 (industrial laundries) or 7213 (linen

supply laundries) and facilities with secondary SIC codes of 7218 were identified and compared to

the original screener questionnaire mailing list. EPA selected 200 facilities identified from the

Dun & Bradstreet listing to receive the supplemental screener questionnaire to obtain more data

representative of the entire industry as follows: 100 facilities with a primary SIC code of 7218;

60 facilities with a primary SIC code of 7213; and 40 facilities with a secondary SIC code of

7218. The table below summarizes the results of the supplemental screener questionnaire mailing.
Chapter 3 - Data Collection Methodology and Information Sources

3-8

Status of Supplemental Screener Questionnaire Mailing

Status of D&B Screener Questionnaires Number of Questionnaires

Returned 134

Screener undeliverable 34

Nonresponsive 32

Total 200

EPA received the screener questionnaire responses, reviewed them for

completeness and accuracy, and entered the information into a database. EPA contacted by

telephone respondents who provided incomplete or contradictory technical information to obtain

correct information.

Large Industrial Laundry Screener

Abbreviated screener questionnaires were sent to five large industrial laundry

companies to identify facilities owned by these five companies that were not identified from the

original screener questionnaire or the supplemental screener questionnaire. Abbreviated screener

questionnaires were also sent to four additional facilities that were not included on the mailing list

for the original screener due to lack of address information. Information from the abbreviated

screener was used to determine the industrial laundry industry population.

1995 Industrial Laundries Industry Screener Questionnaire

In response to comments from industrial laundry and linen trade associations, EPA

mailed 100 modified screener questionnaires in January 1995 to hospitals, hotels, and prisons that

potentially operate on-site laundries. These facilities are not traditional industrial facilities, but

generate wastewater from laundering. EPA randomly selected 25 facility addresses from each of

the following four sources:

C A list provided by the TRSA;

C A list provided by the UTSA;

C Responses to Question 25 (Q25) in Part B of the Industrial Laundries

Detailed Questionnaire; and

C National Association of Institutional Linen Management (NAILM)

members.

The 1995 screener questionnaire requested the following information: discharge

status (i.e., direct, indirect, zero), water use information, amount of laundry accepted from off site

and its annual production, number of employees, SIC code, percentage of items laundered (both
Chapter 3 - Data Collection Methodology and Information Sources

3-9

generated on site and accepted from off site), and type of treatment system. The main goal of this

effort was to obtain a snapshot of the activities of on-site laundries to determine if they should be

included in the scope of the proposed regulations. Of the 100 screener questionnaires mailed,

EPA received 86 responses.

3.3.2 1994 Industrial Laundries Industry Questionnaire (Detailed Questionnaire)

EPA designed the 1994 Industrial Laundries Industry Questionnaire (detailed

questionnaire) to collect detailed technical and economic information from industrial laundry and

linen facilities. EPA sent the detailed questionnaire to laundry facilities selected from the 1993

Industrial Laundries Industry Screener Questionnaire database (screener questionnaire database)

and from the Dun & Bradstreet database. EPA used the information reported by the respondents

in the detailed questionnaire to develop an industry profile, characterize industry production and

water use, develop pollutant loadings and reduction estimates, and develop compliance cost

estimates, as discussed throughout this document. A blank copy of the detailed questionnaire,

along with copies of the nonconfidential portions of the completed detailed questionnaires, are

contained in the administrative record for this rulemaking.

Detailed Questionnaire Recipient Selection and Mailing

EPA mailed the detailed questionnaire in June and July 1994 to 250 selected

laundry facilities. EPA selected 24 facilities from the Dun & Bradstreet database and 226

facilities from the industrial laundries industry screener database. After mailing the

questionnaires, EPA deactivated the questionnaires for one of the selected Dun & Bradstreet

facilities and three of the selected screener questionnaire facilities because they were closed, out

of scope, or otherwise unable to respond to the questionnaire. EPA replaced these facilities with

other facilities not previously selected. The methods used to select the recipients of the detailed

questionnaires are described in the Statistical Support Document (2). A summary of the results of

the mailout of the 254 detailed questionnaires is shown in the following table.

Activity Number of Sites

Mailed detailed questionnaire (four questionnaires were mailed to replace four facilities 254

determined to be inactive within a few days of the initial mail out)

1

Questionnaires received 231

Questionnaires not received 23

Questionnaires deactivated (deactivated because facility closed, facility was a pretest 16

facility, facility destroyed by fire, facility did not generate laundry wastewater, or (Not received-12)

otherwise could not provide the necessary information) (Received-4)

Questionnaires with sufficient technical and economic information to perform the 208

analyses necessary to develop the proposed rule.

EPA originally selected 250 recipients of the detailed questionnaire and later selected another four to replace facilities that had been deactivated. 1
Chapter 3 - Data Collection Methodology and Information Sources

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In addition, EPA mailed pretest questionnaires to nine facilities in November 1993. 

Although not identical, the pretest questionnaire contained questions similar to the questionnaire

mailed in June and July 1994. EPA received eight pretest questionnaire responses.

Information Collected by the Detailed Questionnaire

This section describes the information collected in each part of the detailed

questionnaire and the reasons this information was collected. The Information Collection Request

(ICR) (3) for this project contains further details on the types of information collected and the

potential use of the information.

EPA developed the detailed questionnaire in conjunction with the industrial

laundries trade associations (TRSA and UTSA), EPA’s Office of Pollution Prevention and

Toxics, and EPA’s Office of Solid Waste to collect information necessary to develop effluent

guidelines and standards for the industrial laundries industry. EPA sent a draft version of the

questionnaire to nine pretest facilities, and incorporated comments from these facilities into the

final version of the detailed questionnaire.

The detailed questionnaire comprised the following parts:

C Part A: Technical Information

-- Section 1: Facility Identification,

-- Section 2: Operating Information; and

C Part B: Financial and Economic Information

-- Section 1: Facility Financial Information,

-- Section 2: Owner Company Financial Information,

-- Section 3: Parent Company Financial information.

Part A, Section 1 requested information necessary to identify the site and to

determine wastewater discharge locations (to surface water or POTWs). The information

requested in this section included site name, address, parent company name, address, site contact,

age of facility, major modifications made to the facility, operating hours and days, permits held by

the facility, and wastewater discharge location.

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

C Process Operations and Production Information;

C Water Use and Conservation Practices; and

C Wastewater Treatment Operations.
Chapter 3 - Data Collection Methodology and Information Sources

3-11

The section on process operations and production information requested detailed

information on laundering processes, types of items laundered, production of laundered items,

types of customers, laundering formulas, laundering chemicals, laundering equipment, and

pollution reduction activities. EPA used the information collected in this section to determine the

types and amounts of each item laundered at a facility, the types of customers a facility has, the

amount of laundering chemicals and water used for laundering each item type, and pollution

reduction practices at laundry facilities.

The section on water use and conservation practices requested detailed

information on water intake amounts for various uses, water conservation practices in place,

wastewater generation and discharge locations, and a facility process diagram showing a water

balance for the facility and wastewater treatment in place. EPA used this information to evaluate

the overall water use and wastewater discharge for the site.

The section on wastewater treatment operations requested detailed information on

wastewater treatment operations, costs of wastewater treatment equipment, wastewater sample

collection, wastewater treatment residual types and generation amounts, costs of residual

disposal, and space availability at the facility. EPA used this information to evaluate current

treatment in place at industrial laundries facilities and the costs of operating this treatment.

Part B requested detailed financial and economic information for each site and the

owner companies of each site. Detailed information on this section is presented in the Economic

Assessment of Proposed Pretreatment Standards for Existing and New Sources for the Industrial

Laundries Point Source Category (4).

Data Review and Data Entry

EPA completed a detailed engineering review of Part A of the detailed

questionnaires to evaluate the accuracy of information provided by the respondents. The

engineering review also included coding responses to questions to facilitate data entry into the

detailed questionnaire database. The Data Element Dictionary for the Industrial Laundries

Industry Questionnaire Part A Database (5) contains the codes used by reviewers. EPA

contacted, by telephone, respondents who provided incomplete or contradictory technical

information to obtain correct information. 

EPA developed a database for the technical information provided by the detailed

questionnaire respondents. After engineering review and coding, data from the detailed

questionnaires were double-key entered using a data entry and verification system. Reviewers of

the questionnaire verified errors in the double-key entry. EPA entered basic information (i.e.,

name, address, telephone number, etc.) for all 254 facilities into the database. EPA entered other

information provided by the 231 facilities responding to Part A. EPA also entered the information

for three pretest facilities.
Chapter 3 - Data Collection Methodology and Information Sources

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Compilation of Respondent Data

EPA compiled information reported in the detailed questionnaire and summaries of

this information are located in Chapters 4, 5, and 8 of this document. These chapters include

information on facility location, process and production information, water use and discharge

practices, and wastewater characteristics and treatment.

3.3.3 Detailed Monitoring Questionnaire

In 1995, EPA mailed a detailed monitoring questionnaire (DMQ) to 37 industrial

laundries that received the detailed questionnaire. After reviewing responses to the detailed

questionnaire, EPA identified facilities with available monitoring data that could be used to

identify effluent discharge quality after certain treatment technologies and in conjunction with

laundering certain industrial items. EPA selected the industrial laundries that would receive the

DMQ based on the following criteria:

C Facilities that EPA sampled;

C Facilities with paired monitoring data (i.e., facilities that monitor both

influent and effluent pollutant concentrations);

C At least one facility with each technology being considered for inclusion in

the regulatory options; and

C Facilities that had no treatment (or that have gravity settling and screens

only) to characterize industrial laundry raw wastewater.

The DMQ requested that facilities submit analytical data identified in their detailed

questionnaire responses and any additional data that were available (e.g., raw wastewater data,

POTW data, chemical vendor data, wastewater treatment vendor data, disposal company data). 

The facilities were also asked to include a process diagram for verification of sampling points. All

37 recipients completed and returned their DMQ.

Data Review and Data Entry

EPA completed a detailed engineering review of the DMQs to evaluate the

accuracy of information provided by the respondents. The engineering review also included

coding of responses to questions to facilitate data entry into the DMQ database. The Data

Element Dictionary for the DMQ Database (6) contains the codes used by reviewers. EPA

contacted, by telephone, respondents who provided incomplete or contradictory technical

information to obtain correct information. 

EPA developed a database for the technical information provided by the DMQ

respondents. After engineering review and coding, data from the DMQ were double-key entered
Chapter 3 - Data Collection Methodology and Information Sources

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using a data entry and verification system. Reviewers of the questionnaires verified errors in the

double-key entry. EPA entered information for all 37 facilities into the DMQ database.

Compilation of Respondent Data

EPA compiled information reported in the DMQ responses and summarized it in

Chapter 5 of this document, which includes information on wastewater characteristics. DMQ

data were also used to develop the standards for the industrial laundries industry, as presented in

Chapter 9 of this document and the Statistical Support Document (2).

3.4 Summary of EPA’s Site Visit Program (1993-1997)

EPA conducted 32 site visits to industrial laundry facilities between 1993 and 1997

to collect information about industrial laundries processes, water use practices, pollution

reduction practices, wastewater treatment technologies, and waste disposal methods. EPA also

visited these sites to evaluate potential sampling locations (as described in Section 3.5 of this

document). In general, EPA visited sites to encompass a range of industrial laundry facilities and

other facilities, such as linen facilities, hospital cooperative laundries, and denim prewash facilities,

to determine the scope of the regulation.

3.4.1 Criteria for Site Visit Selection

EPA based site selection on information in responses to the screener and detailed

questionnaires. In addition to choosing sites of varying sizes, EPA used the 

following general criteria to select sites that encompassed the range of processes and treatment

technologies within the industrial laundries industry:

C The site laundered a broad range of industrial items;

C The site performed specific operations, such as denim prewashing or dry

cleaning followed by water washing;

C The site had wastewater treatment technologies that were believed to be

representative of the "best" within the industry;

C The site split heavy and light wastewater streams; and

C The site practiced water reuse.
Chapter 3 - Data Collection Methodology and Information Sources

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3.4.2 Types of Information Collected

EPA documented information for each site visit in a site visit report. During the

site visits, EPA collected the following information for each facility:

C Types of laundering processes conducted and the types of items laundered,

as well as the production volume of each item;

C Types of customers served;

C Types and sizes of laundering equipment used;

C Types, amounts, and disposition of wastewater generated;

C Types of pollution reduction activities performed;

C Types of wastewater treatment technologies operated; and

C Logistical information for sampling.

3.5 Summary of EPA’s Sampling Program (1993-1996)

EPA conducted sampling episodes at eight facilities between 1993 and 1996 to

obtain data on the characteristics of industrial laundry wastewaters and to assess the following: 

the loading of pollutants to POTWs from industrial laundries; the effectiveness of technologies

designed to reduce and remove pollutants from industrial laundries wastewater; and the variation

of wastewater characteristics across item type.

3.5.1 Criteria for Sampling Site Selection

EPA used information collected during industrial laundry site visits to identify

candidate sites for sampling. EPA used the following general criteria to select sites for sampling:

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

C The site operated in-process source reduction or end-of-pipe treatment

technologies that were considered for technology option development.

After selecting a site for sampling, EPA prepared a detailed sampling and analysis

plan, based on the information contained in the site visit report and follow-up correspondence

with the site contact. The sampling and analysis plans were prepared to ensure collection of

samples that would be representative of the sampled waste streams, and contained the following

types of information: site-specific selection criteria for sampling; information about site
Chapter 3 - Data Collection Methodology and Information Sources

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operations; sampling point locations and sample collection, preservation, and transportation

procedures; site contacts; and sampling schedules.

3.5.2 Information Collected

In addition to wastewater samples, EPA collected the following types of

information during each sampling episode:

C Dates and times of sample collection;

C Flow data corresponding to each sample;

C Production data corresponding to each wastewater sample;

C Design and operating parameters for source reduction and treatment

technologies characterized during sampling; 

C Information about site operations that had changed since the site visit or

that was not included in the site visit report; and

C Temperature and pH of the sampled wastewater streams.

EPA documented all data collected during sampling episodes in the sampling

episode report for each sampled site; the sampling episode reports are contained in the

administrative record for this rulemaking. The sampling episode reports also contain preliminary

technical analyses of treatment system performance.

3.5.3 Sample Collection and Analysis

All samples were collected, preserved, and transported according to EPA

protocols as specified in EPA's Sampling and Analysis Procedures for Screening of Industrial

Effluents for Priority Pollutants (7) and the Industrial Laundries Quality Assurance Project Plan

(QAPP). These documents are contained in the administrative record for this rulemaking.

In general, EPA collected composite samples from the wastewater streams from

laundering operations over the course of the operating day. Most facilities were sampled for a

five-day consecutive period. For item-specific sampling, EPA collected wastewater samples from

individual laundered loads during each discharge from the washer and composited the samples. 

EPA collected the required types of quality control samples as described in the QAPP, such as

blanks and duplicate samples, to verify the precision and accuracy of sample analyses. 
Chapter 3 - Data Collection Methodology and Information Sources

3-16

EPA had samples shipped via overnight air transportation to EPA-approved

laboratories, which analyzed the samples for metal and organic pollutants and additional

parameters (including several water quality parameters). The laboratories analyzed metal

pollutants using EPA Method 1620 (8), volatile organic pollutants using EPA Method 1624 (9),

and semivolatile organic pollutants using EPA Method 1625 (10). Tables A-1 and A-2 in

Appendix A list the metal and organic pollutants, respectively, analyzed using these methods. The

laboratories analyzed oil and grease and total petroleum hydrocarbons (TPH) using the proposed

Method 1664 (11). Method 1664 measures oil and grease as hexane extractable material (HEM)

and measures TPH as silica gel treated-hexane extractable material (SGT-HEM). Method 1664

measures a different fraction of oil and grease and TPH than is measured by the currently

approved methods, which use freon. Table A-3 in Appendix A lists other parameters analyzed

during the sampling program and the methods by which they were analyzed (12, 13).

Quality control measures used in performing all analyses complied with the

guidelines specified in the analytical methods and in the QAPP. EPA reviewed all analytical data

to ensure that these measures were followed and that the resulting data were within the QAPPspecified acceptance criteria for accuracy and precision.

As discussed previously, upon receipt and review of the analytical data for each

site, EPA wrote an SER to document the sampling episode, the data collected during sampling,

the analytical results, and the technical analyses of the results. The SERs include sampling and

analysis plans and correspondence with site personnel as appendices.

3.6 Other Industry-Supplied Data

In 1977, TRSA sponsored a wastewater study of linen and industrial laundries. In

addition to pH, this study analyzed wastewater for the following 10 pollutants: BOD , TSS, oil 5

and grease, lead, mercury, nickel, cadmium, zinc, total chromium, and TOC. The two-part study

first analyzed untreated wastewater from 20 laundries and then analyzed untreated and treated

wastewater from five laundries.

The first part of the study presented sampling and analytical data from 20 linen and

industrial laundries. Samples were collected for untreated wastewater at 15-minute intervals

during an 8- to 10-hour period and composited based on the flow rate at the time of sampling. 

The wastewater flow was calculated from process water meter readings and flow readings in the

wastewater treatment system. The process water flows were used to calculate maximal pollutant

loadings. These are maximal loadings because all of the water metered into the facility is not

discharged as wastewater. The production normalized pollutant loading level was based on the

maximal pollutant loading level and the actual poundage of laundry produced on the sampling

days. The types of items laundered on the sampling days were not reported; soil classification

provided information on the soil loading only. Also, from the sampling point location

information, it was difficult to determine the exact location of the sampling point and the source

of wastewater sampled. In some cases, the untreated wastewater sampled may have passed

through settling pits or screens before sampling.
Chapter 3 - Data Collection Methodology and Information Sources

3-17

The second part of the TRSA study presented data from five linen and industrial

laundries. All of these laundries had treatment systems in place. Four facilities had DAF systems

and one facility had a proprietary filter system. Sampling was conducted as described for the first

part of the study, except that both untreated and treated wastewater samples were collected. 

Process water flows were used to calculate maximal pollutant loadings, and wastewater flows in

the treatment system were used to calculate actual pollutant loadings. The production normalized

pollutant loading level was based on the maximal pollutant loading level and the average

poundage of clean, dry laundry produced per week at the facility.

This study included information on the percentages of different types of items

laundered at sampled laundries, although no information was provided on the types of articles

laundered during the sampling days. Also, the descriptions of the sampling point locations were

more extensive than those presented in the first part of the study. Diagrams of the wastewater

treatment systems were provided and the operations of the treatment systems were discussed

briefly. Unfortunately, several of the facilities sampled experienced difficulties with their

treatment system during the sampling days. Also, the production normalized pollutant loading

levels were based on average production levels instead of actual production levels, which were

used in the first part of the study. 

3.7 POTW Data

The Association of Metropolitan Sewerage Agencies (AMSA), in an effort to

assist EPA in collecting data for the development of effluent guidelines and standards for the

industrial laundries industry, developed and distributed a questionnaire to its member POTWs in

1993. The questionnaire asked the POTWs to provide already-collected data on industrial

laundries, which were defined as facilities with the SIC code of 7218 (facilities that supply

laundered and dry-cleaned work uniforms, wiping towels, safety equipment (such as gloves,

flame-resistant clothing), dust covers and cloths, and other items to commercial and industrial

facilities). The questionnaire asked the POTWs for the following information about the industrial

launderers that discharge to their facilities:

C Identify facilities that discharge to the POTW that do industrial laundering

on a contract basis (outside of their normal business classification) that are

not classified as an industrial laundry (i.e., hotels, hospitals, prisons, etc.);

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

C Specify what numerical discharge standards the POTW applies to industrial

laundries (i.e., local limits, category-specific local limits, other limits);

C Provide the following specific information for each industrial laundry that

discharges to the POTW:
Chapter 3 - Data Collection Methodology and Information Sources

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— Industrial user information (facility location information, average

daily wastewater discharge in gallons per day, and permit

information);

— Industrial discharge sampling information, including the following:

whether the sample point contained only industrial laundry

wastewater, and, if not, what other types of waste streams; whether

the wastewater was treated prior to the sampling point; types of

treatment used; and the types of pollution prevention techniques

used at the facility; and 

— Sampling data for each sampling point (either POTW or Industrial

User (IU) self-monitoring data) for calendar year 1992 (including

parameter, measurement, type of sample, whether an EPAapproved method was used to analyze the sample, and, if not, what

type of method was used).

Approximately 280 POTWs returned completed questionnaires. EPA analyzed the

data included in the responses to the questionnaires and used the data to evaluate current local

limits imposed on industrial laundries. The completed questionnaires can be found in the

administrative record for this rulemaking.

3.8 Summary of Literature Searches

EPA has conducted several searches of the open literature throughout the

development of this proposed regulation to provide information on the industrial laundries

industry. The sources searched have included the following:

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

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

C Computerized databases containing information on treatment technologies

for industrial laundries (1986);

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

and 

C POTW and State Water Quality Agency lists (1986).
Chapter 3 - Data Collection Methodology and Information Sources

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EPA conducted other literature searches in 1993 to gather publicly available

information on the industrial laundries industry. EPA conducted one literature search to obtain

information about industrial laundries wastewater, wastewater treatment technologies, operations,

and costs of operations, and also a search to obtain information about printer towels/rags, wipers,

and shop towels.

The literature search focused on the following topics: waste streams, waste

treatment technologies, operations, and costs of operation. The following databases were

searched:

Database Description

Water Resources Abstracts Water resources topics

Waternet Index of the American Water Works

Association Publications

NTIS Government-sponsored research,

development, and engineering reports and

analysis

COMPENDEX Engineering and technology applications

ENVIRONLINE Environmental Sciences

Pollution Abstracts Pollution control and research

Books in Print Books in print, forthcoming books, and

books going out of print in the U.S.

LC Mark Library of Congress catalogued

publications

Textile Technology Digest Worldwide coverage of textiles and

related subjects

World Textiles Textiles in areas of technology and

management

As part of the literature search, EPA identified three trade journals important in the

industrial laundries industry: Textile Rental, Industrial Launderer, and Laundry News. These

journals provide up-to-date information on the industrial laundries industry. EPA has conducted

regular reviews of these journals during the development of this regulation. 

EPA conducted a separate literature search for data on pollution prevention in the

industrial laundries industry by examining various on-line databases, including EPA's Pollution

Prevention Information Exchange System (PIES).
Chapter 3 - Data Collection Methodology and Information Sources

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3.9 Summary of Other Data Sources

In developing the industrial laundries effluent guidelines, EPA also evaluated the

following existing data sources:

C The Office of Research and Development (ORD) Risk Reduction

Engineering Laboratory (RREL) treatability database;

C The Fate of Priority Pollutants in Publicly Owned Treatment Works (50

POTW Study) database;

C The Domestic Sewage Study (DSS); 

C Canadian studies; and

C Industrial Pollution Prevention Project.

These data sources and their uses in the development of the industrial laundries rulemaking are

discussed below.

3.9.1 Risk Reduction Engineering Laboratory Treatability Database

EPA's ORD developed the RREL treatability database to provide data on the

removal and destruction of chemicals in various types of media, including water, soil, debris,

sludge, and sediment. This database contains treatability data from POTWs for various

pollutants. This database includes physical and chemical data for each pollutant, the types of

treatment used to treat the specific pollutants, the type of wastewater treated, the size of the

POTW, and the treatment concentrations achieved. EPA used this database to assess POTW

percent removals of various pollutants.

3.9.2 Fate of Priority Pollutants in Publicly Owned Treatment Works Database

In September 1982, EPA published the Fate of Priority Pollutants in Publicly

Owned Treatment Works (14), referred to as the 50 POTW Study. The purpose of this study was

to generate, compile, and report data on the occurrence and fate of the 129 priority pollutants in

50 POTWs. The report presents all of the data collected, the results of preliminary evaluations of

these data, and the results of calculations to determine the following:

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

C The quantity of priority pollutants discharged from the POTWs;

C The quantity of priority pollutants in the effluent from intermediate process

streams; and
Chapter 3 - Data Collection Methodology and Information Sources

3-21

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

EPA used the data from this study to assess POTW percent removals of various pollutants.

3.9.3 The Domestic Sewage Study

In February 1986, EPA issued the Report to Congress on the Discharge of

Hazardous Wastes to Publicly Owned Treatment Works (15), referred to as the Domestic Sewage

Study (DSS). This report, which was based in part on the 50 POTW Study, revealed a significant

number of sites discharging pollutants to POTWs that are a threat to the treatment capability of

these POTWs and were not regulated by national categorical pretreatment regulations. Among

the unregulated sources were industrial laundries, which tend to discharge significant quantities of

toxic and hazardous pollutants on a facility-specific basis. During the course of the DSS, EPA

contacted a number of state and local agencies to obtain toxic pollutant data and other relevant

data. EPA used the information in the DSS in developing the Preliminary Data Summary for the

Industrial Laundries Point Source Category (1).

3.9.4 Canadian Studies

EPA studied other sources of data, as described below, to obtain as comprehensive

a picture of the industrial laundries industry as possible. One of these sources was the Ministry of

the Environment and Energy (MOEE) of Canada. As in the U.S., industrial laundries in Canada

have been found to be a source of oil and grease in sewer systems. The MOEE's

Municipal/Industrial Strategy for Abatement (MISA) section and the Ontario, Canada industrial

laundries associations conducted a survey of Canadian industrial laundries to assess the amount of

oil and grease and other pollutants that were being discharged into the sewer systems. The survey

was conducted to obtain an overview of the industrial laundries industry, the sources of

contamination, and the treatment used to reduce the pollutant loads to the sewers.

The laundries surveyed in this report included industrial laundries, linen

establishments, and commercial launderers and excluded retail-only, coin-operated, dry cleaning,

and health-care facilities. The industrial laundries processed industrial garments and wiper towels,

which, according to this survey, were considered major sources of oil and grease. The survey

showed that many industrial laundries in this study used some pretreatment; however, only four

facilities used advanced pretreatment techniques, and several facilities did not pretreat their

wastewater.

In addition, the Ontario Laundry Industry Pollution Prevention Task Force has

been meeting regularly to discuss pollution prevention measures in the laundries industry and how

to promote those practices. The Task Force comprises the following entities: Ontario Ministry of

Environment and Energy, Metro Toronto, City of Brantford, and several Canadian laundries,

some of which represent the laundry associations Dry Cleaners and Launderers Institute (DCLI)

and Textile Rental Institute of Canada (TRIO). In 1994, the Task Force held a workshop on
Chapter 3 - Data Collection Methodology and Information Sources

3-22

pollution prevention in the laundries industry, which discussed pollution prevention in general,

how using pollution prevention practices benefits industrial laundries, and approaches to and

techniques for reducing waste in the industry.

3.9.5 Industrial Pollution Prevention Project

EPA has undertaken several pollution prevention-related activities involving the

industrial laundries industry. Some of the efforts were Agency-wide, including ORD and EPA’s

Region IX, while other efforts were included as part of the engineering studies in the development

of the proposed rule. 

The Agency-wide efforts, called the Industrial Pollution Prevention Project (IP3),

were multimedia and examined how industrial pollution prevention can be incorporated into

EPA’s regulatory framework and how the pollution prevention ethic can be promoted throughout

industry, the public, and government. A report summarizing the results of these efforts, entitled

Industrial Pollution Prevention Project (IP3) - Summary Report (16), included the results of two

case studies involving industrial laundries. More detailed discussions of the two studies are

contained in the individual reports, Pollution Prevention at Industrial Laundries: Assessment

Observations and Waste Reduction Options (17), and Pollution Prevention at Industrial

Laundries: A Collaborative Approach in Southern California (18). These studies identified a

number of “best management practices” (BMPs) and water and energy savings technologies as

potential pollution prevention at industrial laundries. 

Similarly, during the engineering study phase of the development of the proposed

rule, a number of potential pollution prevention practices and technology applications were

identified. Section VI of the preamble to the proposed rule and Chapters 8 and 10 of this

document discuss the pollution prevention technologies and practices and their uses with respect

to this proposed rule.

3.10 References

1. U.S. Environmental Protection Agency. Preliminary Data Summary for the

Industrial Laundries Industry. EPA 440/1-89/103, September 1989.

2. U.S. Environmental Protection Agency. Statistical Support Document for

Proposed Pretreatment Standards for Existing and New Sources for the Industrial

Laundries Point Source Category. EPA-821-R-97-006, Washington, D.C.,

November 1997.

3. U.S. Environmental Protection Agency. Information Collection Request. U.S.

Environmental Protection Agency 1994 Industrial Laundries Industry

Questionnaire. March 3, 1994.
Chapter 3 - Data Collection Methodology and Information Sources

3-23

4. U.S. Environmental Protection Agency. Economic Assessment of Proposed

Pretreatment Standards for Existing and New Sources for the Industrial Laundries

Point Source Category. EPA-821-R-97-008, Washington, D.C., November 1997.

5. Eastern Research Group, Inc. Data Element Dictionary for the Industrial

Laundries Industry Questionnaire Part A Database. Prepared for the U.S.

Environmental Protection Agency, Office of Water, Washington, D.C., November

1997.

6. Eastern Research Group, Inc. Data Element Dictionary for the DMQ Database. 

Prepared for the U.S. Environmental Protection Agency, Office of Water,

Washington, D.C., November 1997.

7. U.S. Environmental Protection Agency. Sampling and Analysis Procedures for

Screening of Industrial Effluents for Priority Pollutants. April 1977.

8. U.S. Environmental Protection Agency. Method 1620 Draft - Metals by

Inductively Coupled Plasma Atomic Emission Spectroscopy and Atomic

Absorption Spectroscopy. September 1989.

9. U.S. Environmental Protection Agency. Method 1624 Revision C - Volatile

Organic Compounds by Isotope Dilution GCMS. 40 CFR 136, Appendix A, June

1989.

10. U.S. Environmental Protection Agency. Method 1625 Revision C - Semivolatile

Organic Compounds by Isotope Dilution GCMS. 40 CFR 136, Appendix A, June

1989.

11. U.S. Environmental Protection Agency. Method 1664: N-Hexane Extractable

Material (HEM) and Silica Gel Treated N-Hexane Extractable Material (SGTHEM) by Extraction and Gravimetry (Oil and Grease and Total Petroleum

Hydrocarbons). EPA-821-B-94-004b, April 1995.

12. U.S. Environmental Protection Agency. Methods for Chemical Analysis of Water

and Wastes. EPA-800-4-79-020, Revised March 1983.

13. Standard Methods for the Examination of Water and Wastewater. A.D. Eaton,

L.S. Clesceri and A.E. Greenberg, eds. 19th Edition. American Public Health

Association, Washington, D.C., 1995.

14. U.S. Environmental Protection Agency. Fate of Priority Pollutants in Publicly

Owned Treatment Works. EPA 440/1-82/303, September 1982.
Chapter 3 - Data Collection Methodology and Information Sources

3-24

15. U.S. Environmental Protection Agency. Report to Congress on the Discharge of

Hazardous Wastes to Publicly Owned Treatment Works. EPA-530-SW-86-004,

February 1986.

16. U.S. Environmental Protection Agency. Industrial Pollution Prevention Project

(IP3)-Summary Report. EPA-820-R-95-007, July 1995.

17. U.S. Environmental Protection Agency. Pollution Prevention at Industrial

Laundries: Assessment Observations and Waste Reduction Options. EPA-820-R95-010, July 1995.

18. U.S. Environmental Protection Agency. Pollution Prevention at Industrial

Laundries: A Collaborative Approach in Southern California. EPA-820-R-95-

012, July 1995.
Chapter 4 - Industry Profile

4-1

CHAPTER 4

INDUSTRY PROFILE

4.1 Introduction

Chapter 4 discusses the processes, items, customers, chemicals, facilities and

equipment, and pollution reduction activities found in the industrial laundries industry. Most of

the data presented in this chapter are from facility responses to the 1994 Industrial Laundries

Industry Detailed Questionnaire. EPA sent the detailed questionnaires to 250 facilities, and 231

facilities returned the questionnaire, as described in Section 3.3.2 of this document. Two hundred

eight (208) facilities that responded to the detailed questionnaire provided sufficient data to

perform complete technical and economic analyses. EPA defined 193 of these facilities as being

in scope (industry scope is discussed in detail in Chapter 6). The percentages and number of

facilities performing various processes discussed in this section were estimated based on the

responses from the 193 in-scope facilities, and then extrapolated to represent the industry

population of 1,747 facilities, using appropriate survey weights. The following topics are

discussed in this section:

C Section 4.2 discusses the geographic location, relative size, types of items

laundered, customers, and Standard Industrial Classification (SIC) code

distribution of facilities in the industrial laundries industry;

C Section 4.3 discusses general information on industrial laundering

processes and chemicals used in the laundering processes;

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

C Section 4.5 presents pollution reduction activities;

C Section 4.6 discusses trends within the industry; 

C Section 4.7 lists treatment technologies in use; and

C Section 4.8 presents the references used in this section.

4.2 Overview of the Industry

This section provides an overview of the industrial laundries industry. This

overview comprises general information pertaining to the industry, including geographic location,

SIC codes, facility size, types of items laundered, and customers.
Chapter 4 - Industry Profile

4-2

4.2.1 Geographic Distribution of Facilities

Information on geographic distribution was based on the 1993 Industrial Laundries

Screener Questionnaire. This questionnaire was completed by 1,500 industrial laundries that were

identified by trade association mailing lists. Only industrial laundries that reported generating

laundry process wastewater and discharged that wastewater to a publicly owned treatment works

(POTW) were used to determine the geographic distribution of facilities. These facilities are

located in all 50 states and in all 10 EPA Regions, as well as several U.S. territories. Figure 4-1

and Table 4-1 present the geographic distribution of these facilities. By state, the greatest number

of in-scope laundries (102 facilities) are in California. By EPA region, the greatest number of inscope laundries (203 facilities) are in Region V, followed by Region IV, which has 181 facilities. 

Most of the laundries are located in large urban areas.

4.2.2 SIC Codes Reported

The facilities responding to the detailed questionnaire reported 7218 (Industrial

Laundries) and 7213 (Linen Supply Laundries) as their primary SIC codes. Other secondary and

tertiary SIC codes reported were 7211 (Power Laundries, Family and Commercial), 7216 (Drycleaning Plants, except rug cleaning), and 7219 (Laundry and Garment Services, not elsewhere

classified).

4.2.3 Facility Size

Industrial laundries vary in size from one- to two-person shops to large

corporations that operate many facilities nationwide. For the purpose of this section, EPA based

the relative size of each facility on the pounds of dirty (as-received) laundry washed per year.

Table 4-2 presents the national estimates of the number of industrial laundries by

production category. Annual laundry production per facility ranges from 44,100 to 32,600,000

pounds and the total annual industry production is 9,360,000,000 pounds. Although a smaller

percentage of large facilities exist (more than 15 million pounds/year (lbs/yr) production) than

small facilities (less than 1 million lbs/yr production), the larger facilities represent a significant

percentage of the total industry production. One hundred thirty-eight (138) facilities launder

more than 15 million lbs/yr each. These facilities represent 8 percent of the facilities in the

industry, but their combined production (2,660,000,000 lbs/yr) accounts for 28 percent of the

total industry production. Facilities laundering less than 1 million lbs/yr represent 10 percent of

the facilities in the industry and account for less than 1 percent of the total industry production. 
Chapter 4 - Industry Profile

United States 

Number of Facilities

69 to 102 (2)

35 to 69 (7)

1 to 35 (42)

4-3

Figure 4-1

Geographic Distribution of Industrial Laundires
Chapter 4 - Industry Profile

4-4

Table 4-1

Geographic Distribution of Industrial 

Laundries by State and Region

Region/State Number of Facilities in Region/State1

Region I 55

Connecticut 11

Maine 4

Massachusetts 29

New Hampshire 6

Rhode Island 4

Vermont 1

Region II 72

New Jersey 19

New York 51

Puerto Rico 2

Region III 101

Delaware 4

District of Columbia 3

Maryland 17

Pennsylvania 49

Virginia 21

West Virginia 7

Region IV 181

Alabama 14

Florida 42

Georgia 28

Kentucky 27

Mississippi 6
Table 4-1 (Continued)

Chapter 4 - Industry Profile

Region/State Number of Facilities in Region/State1

4-5

North Carolina 35

South Carolina 13

Tennessee 16

Region V 203

Illinois 42

Indiana 33

Michigan 36

Minnesota 17

Ohio 56

Wisconsin 19

Region VI 131

Arkansas 18

Louisiana 16

New Mexico 10

Oklahoma 15

Texas 72

Region VII 57

Iowa 14

Kansas 8

Missouri 24

Nebraska 11

Region VIII 36

Colorado 16

Montana 3

North Dakota 1

South Dakota 4

Utah 6
Table 4-1 (Continued)

Chapter 4 - Industry Profile

Region/State Number of Facilities in Region/State1

4-6

Wyoming 6

Region IX 136

Arizona 14

California 102

Guam 3

Hawaii 8

Nevada 9

Region X 39

Alaska 4

Idaho 8

Oregon 14

Washington 13

Number of facilities is based on number of facilities identified by the 1993 Industrial Laundries Screener Questionnaire, that reported generating 1

laundry process wastewater and discharged that wastewater to a POTW.
Chapter 4 - Industry Profile

4-7

Table 4-2

Industrial Laundry

Size Distribution 

Production Category Number of Reporting this Category Total

(lbs/yr) Facilities Production Data (lbs/yr) Production

Estimated Number of Facilities Production for Percentage of

1

Estimated

Percentage of Total Total Estimated Estimated

< 1,000,000 167 10 76,600,000 <1

1,000,000 to < 3,000,000 475 27 886,000,000 10

3,000,000 to < 6,000,000 629 36 2,740,000,000 29

6,000,000 to <9,000,000 199 11 1,390,000,000 15

9,000,000 to < 15,000,000 139 8 1,600,000,000 17

> 15,000,000 138 8 2,660,000,000 28

Total 1,747 100 9,360,000,000 100

Number of facilities is estimated based on the 193 in-scope facilities, extrapolated to represent the entire industry. 1

Source: 1994 Industrial Laundries Industry Detailed Questionnaire
Chapter 4 - Industry Profile

4-8

4.2.4 Items Laundered

As reported by the in-scope facilities, industrial laundries wash a variety of items. 

The three primary categories of items reported in the detailed questionnaire responses were

industrial laundry items, linen laundry items, and other items. Typically, industrial laundry items

include industrial garments, shop towels, printer towels, floor mats, and fender covers. Linen

items typically include linen garments, flatwork/full dry linen, and health-care items. Other items

are specialty items or items that are not generally considered to be either industrial laundry items

or linen items. Brief descriptions of industrial laundry, linen items, and other items are provided in

Chapter 5.

Table 4-3 presents the number of facilities that launder each item and the 

percentage of total production by item. Many facilities reported laundering several items. The

total extrapolated item-specific production reported in the detailed questionnaire is 9,360,000,000

lbs/yr (calculated by summing the item-specific subtotals reported in the detailed questionnaire

and extrapolating the data to represent the entire industry). 

The detailed questionnaire requested production data for twelve specific items

(questionnaire category codes B01 through B12), as listed on Table 4-3. EPA requested facilities

to report any items laundered that did not fall in the B01 through B12 categories and place them

in category B13 (Other Items). Based on item types and descriptions provided by the facilities,

EPA created supplemental categories B14 through B24 for these “other” B13 items. Items that

could not be classified in categories B14 through B24 remained in the B13 “other” category. 

Because the data for category codes B13 through B24 were collected through "write-in"

responses rather than through pre-printed selections, EPA believes that the data for category

codes B13 through B24 may not represent total industry production.

4.2.5 Customers

Industrial laundries wash items for many different types of customers, ranging from

gasoline stations to restaurants. The pollutants present on an item laundered depend primarily on

the customer who used the item and the specific use of the item. For instance, a shop towel from

a gasoline station is more likely to have a high concentration of oil and grease or total petroleum

hydrocarbon than a napkin from a restaurant. Table 4-4 lists the laundered items reported in the

detailed questionnaire responses, the typical customers using these items, and the percentage of

the total industry production of each item laundered from each customer. For example,

automobile repair, services, dealers, and gas stations represent 31.1 percent of the customers who

use industrial garments.
Chapter 4 - Industry Profile

4-9

Table 4-3

Types of Items Laundered

Item Type Laundering Item Facilities Production 1

Estimated Number Percentage of Percentage of

of Facilities Total Total

Estimated Estimated

2

Industrial Garments (B01) 1,441 82.5 24.4

Shop Towels, Industrial Wipers, etc. (B02) 1,332 76.2 3.7

Printer Towels (B03) 480 27.5 1.4

Floor Mats (B04) 1,644 94.1 19.3

Mops, Dust Cloths, Tool Covers, etc. (B05) 1,400 80.1 1.3 3

Linen Garments (B06) 942 53.9 2.9

Linen Flatwork/Full Dry Linen (B07) 1,364 78.1 35.2

Health-Care Items (B08) 648 37.1 7.9

Fender Covers (B09) 687 39.3 <1

Continuous Roll Towels (B10) 927 53.1 1.2 3

Clean Room Garments (B11) 28 1.6 <1

Clean Wipes (B12) - - -

Other Items (B13) 31 1.8 <1 4

Laundry Bags (B14) 28 1.6 <1

Family Laundry (B15) 84 4.8 <1

Absorbents (B16) - - -

New Items (B17) 74 4.2 1.6

Executive Wear (B18) 43 2.5 <1

Miscellaneous Not Our Goods (NOG) (B19) 14 < 1 <1

Rewash Items (B20) 38 2.2 <1

Airline Carpet and Seat Covers (B22) - - -
Table 4-3 (Continued)

Chapter 4 - Industry Profile

Item Type Laundering Item Facilities Production 1

Estimated Number Percentage of Percentage of

of Facilities Total Total

Estimated Estimated

2

4-10

Filters (B23) 7 < 1 <1

Buffing Pads (B24) 6 <1 <1

Total - - 100

The codes in parentheses are from the detailed questionnaire and were used in the questionnaire database. 1

Total industry production is estimated based on data from the detailed questionnaire from the 193 in-scope facilities, 2

extrapolated using appropriate survey weights to represent the entire industry.

One facility (with a survey weight of 1.3333) did not report production for this item; therefore, the estimated percentage 3

of total production may be less than the actual amount processed.

Includes items not specified in detailed questionnaire responses. 4

Source: 1994 Industrial Laundries Industry Detailed Questionnaire
4-11

Section 1 - Summary

Table 4-4

Typical Customers for Each Type of Item Laundered

Item Type Customers Item from Customer 1 1

Percentage

of Total Production of

2

Industrial Garments (B01) - Automobile Repair, Services, Dealers, Gasoline Stations (C01) 31.1

- Special Trade Contractors for Building Construction (C02) 10.2

- Dwellings and Other Building Services (C03) 5.49

- Industrial Metal, Machinery, and Equipment Manufacturing (C04) 17.2

- Chemicals and Allied Products Manufacturing (C05) 9.65

- Transportation, Communication, Utility, and Sanitary Services (C07) 10.5

- Eating/Drinking Establishments, Food/Beverage Manufacturing and Processing, 11.1

and Food Stores (C08)

Shop Towels, Industrial Wipers, etc. - Automobile Repair, Services, Dealers, Gasoline Stations (C01) 48.1

(B02) - Special Trade Contractors for Building Construction (C02) 6.74

- Dwellings and Other Building Services (C03) 5.14

- Industrial Metal, Machinery, and Equipment Manufacturing (C04) 19.6

- Chemicals and Allied Products Manufacturing (C05) 7.52

- Transportation, Communication, Utility, and Sanitary Services (C07) 6.12

Printer Towels (B03) - Publishing and Printing Industries (C06) 86.1

- Other Laundries (C20) 13.4

Floor Mats (B04) - Automobile Repair, Services, Dealers, Gasoline Stations (C01) 26.8

- Dwellings and Other Building Services (C03) 11.0

- Industrial Metal, Machinery, and Equipment Manufacturing (C04) 11.4

- Chemicals and Allied Products Manufacturing (C05) 5.92

- Transportation, Communication, Utility, and Sanitary Services (C07) 6.63

- Eating/Drinking Establishments, Food/Beverage Manufacturing and Processing, 24.7

and Food Stores (C08)
4-12

Section 1 - Summary

Table 4-4 (Continued)

Item Type Customers Item from Customer 1 1

Percentage

of Total Production of

2

Mops, Dust Cloths, Tool Covers, etc. - Automobile Repair, Services, Dealers, Gasoline Stations (C01) 15.4

(B05) - Dwellings and Other Building Services (C03) 23.1

- Industrial Metal, Machinery, and Equipment Manufacturing (C04) 8.17

- Transportation, Communication, Utility, and Sanitary Services (C07) 7.37

- Eating/Drinking Establishments, Food/Beverage Manufacturing and Processing, 20.2

and Food Stores (C08)

- Health Services (C10) 7.46

Linen Garments (B06) - Eating/Drinking Establishments, Food/Beverage Manufacturing and Processing, 91.1

and Food Stores (C08)

Linen Flatwork/Full Dry (B07) - Eating/Drinking Establishments, Food/Beverage Manufacturing and Processing, 85.2

and Food Stores (C08)

- Hotel and Lodging Establishments (C09) 14.1

Health-Care Items (B08) - Health Services (C10) 90.8

- Customer Not Reported (C11) 8.65 3

Fender Covers (B09) - Automobile Repair, Services, Dealers, Gasoline Stations (C01) 77.1

- Industrial Metal, Machinery, and Equipment Manufacturing (C04) 11.6

- Transportation, Communication, Utility, and Sanitary Services (C07) 8.24

Continuous Roll Towels (B10) - Automobile Repair, Services, Dealers, Gasoline Stations (C01) 21.1

- Special Trade Contractors for Building Construction (C02) 7.31

- Dwellings and Other Building Services (C03) 8.33

- Industrial Metal, Machinery, and Equipment Manufacturing (C04) 9.51

- Transportation, Communication, Utility, and Sanitary Services (C07) 9.23

- Eating/Drinking Establishments, Food/Beverage Manufacturing and Processing, 29.2

and Food Stores (C08)
4-13

Section 1 - Summary

Table 4-4 (Continued)

Item Type Customers Item from Customer 1 1

Percentage

of Total Production of

2

Clean Room Garments (B11) - Industrial Metal, Machinery, and Equipment Manufacturing (C04) 17.2

- Chemicals and Allied Products Manufacturing (C05) 21.2

- Customer Not Reported (C11) 28.2 3

- Electronics Industry (C18) 30.3

Laundry Bags (B14) - Automobile Repair, Services, Dealers, Gasoline Stations (C01) 23.7

- Special Trade Contractors for Building Construction (C02) 9.34

- Industrial Metal, Machinery, and Equipment Manufacturing (C04) 5.82

- Publishing and Printing Industries (C06) 7.52

- Transportation, Communication, Utility, and Sanitary Services (C07) 39.2

- Eating/Drinking Establishments, Food/Beverage Manufacturing and Processing, 9.25

and Food Stores (C08)

Family Laundry (B15) - Industrial Metal, Machinery, and Equipment Manufacturing (C04) 8.92

- Eating/Drinking Establishments, Food/Beverage Manufacturing and Processing, 8.33

and Food Stores (C08)

- Families (C23) 69.8

Absorbents (B16) - Industrial Metal, Machinery, and Equipment Manufacturing (C04) 13.2

- Publishing and Printing Industries (C06) 6.79

- Retail/Wholesale Stores (C12) 19.3

- Miscellaneous Service Industries (C15) 19.9

- Agricultural Industry (C16) 5.61

- Miscellaneous Manufacturing (C19) 16.8

New Items (B17) - Retail/Wholesale Stores (C12) 31.8

- Miscellaneous Manufacturing (C19) 27.2

- Textile Manufacturing (C24) 41.0

Executive Wear (B18) - Other Laundries (C20) 56.3

- General Offices (C21) 36.2

- Families (C23) 5.47

Miscellaneous Not Our Goods (NOG) - Eating/Drinking Establishments, Food/Beverage Manufacturing and Processing, 96.0

(B19) and Food Stores (C08)
4-14

Section 1 - Summary

Table 4-4 (Continued)

Item Type Customers Item from Customer 1 1

Percentage

of Total Production of

2

Rewash Items (B20) - Transportation, Communication, Utility, and Sanitary Services (C07) 94.0

Filters (B23) - Chemicals and Allied Products Manufacturing (C05) 17.3

- Wood Product/Furniture Manufacturing (C14) 82.7

Buffing Pads (B24) - Eating/Drinking Establishments, Food/Beverage Manufacturing and Processing, 100

and Food Stores (C08)

The codes in parentheses are from the detailed questionnaire and were used in the questionnaire database. 1

Customers representing less than 5 percent of the total production for an item are not shown in the table; therefore, the percentages may not add up to 100 percent for 2

each item.

 Production data were provided for these items; however, the percentage of customers not reported by the facilities were greater than 5 percent. 3

Source: 1994 Industrial Laundries Industry Detailed Questionnaire
Chapter 4 - Industry Profile

4-15

4.3 Laundering Processes

For all laundering processes, the methods by which the items are received, sorted,

and transported to the washing area are similar. Industrial laundries receive soiled items in trucks

and weigh the items before washing. These items are typically sorted based on item type, fabric

type, color, degree and/or type of soil, and ownership. Sorted items are then placed in slings or

carts, which are either automatically or manually moved to the washing area. The items are then

cleaned using the appropriate process.

Table 4-5 presents laundering processes reported by the facilities responding to the

detailed questionnaire, as well as the percentage of total production laundered by each process

and the number of facilities performing each process. Many facilities reported conducting more

than one of the listed processes. One process included in Table 4-5, dyeing of new fabrics is not

considered a laundering process by EPA. (Chapter 6 discusses the scope of the industry under

this proposed regulation.) The remaining processes listed in Table 4-5 can be divided into two

basic categories: processes that generate wastewater and processes that generate little or no

wastewater. The individual processes within these categories are described in more detail below.

4.3.1 Water-Using/Wastewater-Generating Processes

Laundering processes that use significant amounts of water and generate

wastewater include water-washing processes and dual-phase washing. Almost all (97 percent) of

the industry’s production involves water-washing processes. Of the 1,747 in-scope facilities,

1,443 perform water washing on 100 percent of their production. Water washing is performed on

almost all items. Brief descriptions of the different water-using processes are provided below.

Water Washing

Water washing involves the washing of soiled items in a water/chemical solution. 

The concentration, type, and amount of chemicals added during the water-washing process

depend on the item type and the degree to which items are soiled. Wash formulas are used to

determine the different washing cycles used in water washing, including the chemicals added. 

Wash formulas are also used to set the order, number, and duration of each wash cycle that is

performed during the water-washing process. The typical order of these cycles and brief

descriptions of the processing operations that occur in each cycle are described below. 

In typical water-washing processes, the first cycle is the flush, which is defined as

any rinsing operation prior to bleaching. This cycle removes loosely attached solids and a portion

of the water-soluble soils. The next cycle is the break, during which items are treated with an

alkali solution that swells the cellulosic fibers, allowing the soil to be more readily
Chapter 4 - Industry Profile

4-16

Table 4-5

Laundering Processes

Reported in the Detailed Questionnaire

Process Process the Process Production 1

Estimated Estimated

Number of Percentage of Estimated

Facilities Facilities Percentage of

Performing the Performing Total

2

Water Washing (A01) 1,725 99 97

Dual-Phase Washing - Petroleum solvent wash followed 18 1 <1

by water washing (A02)

Dual-Phase Washing - Water wash followed by 0 0 0

perchloroethylene solvent wash (A03)

Dry Cleaning - Charged system (A04) 125 7 <1

Dry Cleaning - Fresh soap added to each load (A05) 80 5 <1

Dry Cleaning - No soap added (A06) 80 5 <1

Dry Cleaning Followed by Water Washing (drying 29 2 <1

between steps) (A12)

Dust Control Mop Treatment - Water wash followed by 692 40 1

oil treatment applied outside wash wheel (A10)

Dust Control Mop Treatment - Water wash followed by 67 4 <1

oil treatment applied inside wash wheel (A11)

Dust Control Mop Treatment- Water wash followed by 22 1 <1

unspecified oil treatment (A07)

Dust Control Mop Treatment - Oil only (A08) 57 3 <1

Stone/Acid Washing of Denim (A13) 11 1 1

Dyeing (A14) 1 <1 <1 3

Total - - 100

The codes in parentheses are from the detailed questionnaire and were used in the questionnaire database. 1

Percentages reported are estimated based on the 193 in-scope facilities, extrapolated using appropriate survey weights 2

to represent the entire industry.

This process is not considered a laundering process by EPA. 3

Source: 1994 Industrial Laundries Industry Detailed Questionnaire
Chapter 4 - Industry Profile

4-17

removed. Detergents may also be added during the break cycle. Sudsing occurs after the break

cycle and is the cycle in which the actual washing of the items occurs. During sudsing, detergent

is added in varying concentrations and the items are agitated until they are clean. After sudsing, a

bleaching cycle may be performed, during which the detergent is replaced with a bleach solution

and agitation continues. Following the sudsing and bleaching cycles, a rinsing cycle is typically

performed, which removes the excess alkali and soap from the items. Additional chemicals are

added in the blueing/brightening cycle to whiten/brighten the items. The final operation in water

washing is the finish, which involves souring or acidifying the final bath water to a pH of 5, which

prevents the yellowing of fabrics by sodium bicarbonate during pressing.

Dual-Phase Processing

Some facilities combine the water-washing and dry-cleaning processes to wash

items that have large amounts of both organic-solvent-soluble and water-soluble soils. When

these processes are performed in series, without drying the item between the solvent and water

phases, the process is called dual-phase processing. The order in which these processes are

carried out is determined by the solvent used, type of soil, and drying energy requirements. Dualphase processing involving a petroleum solvent wash followed by water washing is used by only

one percent of the industry. None of the facilities responding to the detailed questionnaire

reported performing dual-phase processing involving water washing followed by solvent wash.

Water-Washing of Mops

This process entails first water washing mops and then applying oil to the mops by

a sprayer either outside or inside the washer. This method of washing mops generates

wastewater.

4.3.2 Non-Water-Using/Non-Wastewater-Generating Processes

Several laundering processes generate little if any wastewater. Processes that

generate small amounts of wastewater include various methods of dry cleaning (charged system,

fresh soap added to each load, and no soap added). Dust control mop treatment using only oil is

the only industrial laundry process that generates no wastewater. Each of the processes

represents less than one percent of the total industry production and is described in more detail

below.

Dry Cleaning

Dry cleaning involves the use of an organic solvent instead of an aqueous

detergent solution to clean laundry items. Water washing of certain items causes hydrophilic

fibers to swell and undergo dimensional changes, causing wrinkles and shrinkage that can be

avoided by the use of dry-cleaning solvents. These solvents dissolve soils at low temperatures

and under relatively mild conditions, unlike water washing, which usually involves high

temperatures and the use of harsh chemicals, such as alkalis and bleaches. The primary solvents
Chapter 4 - Industry Profile

4-18

used by industrial laundries are perchloroethylene (“perc”) and petroleum-based solvent. Because

these solvents are typically expensive and are considered hazardous wastes, they are commonly

recycled and reused in subsequent dry-cleaning loads. During dry cleaning, the solvent becomes

contaminated with dirt, oil, and grease removed from the items processed. To minimize the

solvent contamination, industrial laundries use multiple solvent rinses to process items. As with

water washing, the first few rinses typically contain the most pollutants, and subsequent rinses

become less contaminated.

The general process steps for dry cleaning are similar to those for water washing. 

The items may be washed and dried in the same unit or washed in one unit and manually

transferred to a dryer. In the drying step, steam is injected into the unit to volatilize the solvent. 

The steam and solvent are captured in a condenser. The water/solvent mixture is tranferred to a

phase separator where the solvent and water are separated. The solvent is either reused or

contract hauled off-site for disposal. The water is discharged to a POTW either with or without

pretreatment. The three major methods of dry cleaning items at industrial laundries are listed

below. 

1) Charged system: A small percentage of water and detergent (between 0.5

percent and 4 percent) is added to the dry-cleaning solvent. The water and

detergent concentration in the solvent is maintained throughout the

washing processes by using conductivity meters to control the addition of

water and detergent automatically.

2) Fresh soap added to each load: A given amount of soap or detergent is

added at the beginning of each load; no additional detergent is added

during the cleaning cycle. Because the process is not monitored as closely

as the charged system, excess water, soap, and energy may be expended

with this system.

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

Oil Treatment of Dust Mops

At some facilities, dust mops are not water-washed but are cleaned and treated

with heated oil instead of water. After cleaning, the oil is extracted from the mops, leaving them

coated with the desired quantity of treatment oil. The dirty oil is then purified by filtration and is

reused. This is a closed-loop processing system that uses no process water. 
Chapter 4 - Industry Profile

4-19

4.3.3 Chemicals Used in Industrial Laundries

Industrial laundries use a variety of chemicals in their laundering processes. 

Chemicals that are frequently added to wash formulas include:

C Alkaline solution - to swell the fibers in the items;

C Detergent - to remove soil from the items;

C Bleach - to brighten the items;

C Antichlor - to remove excess bleach from the items;

C Sour - to reduce the pH of the water to prevent yellowing of the items;

C Softener - to soften the items; and

C Starch - to finish the items.

A variety of other chemicals are added to some wash formulas, including enzymes, builders, oil

treatment chemicals, water conditioners, dyes, stain treatment chemicals, and bactericides. 

Table 4-6 lists, based on the detailed questionnaire, the types of chemicals that are

added during laundering operations, the number of facilities that add each chemical, the amount

of each chemical added per year and the number of facilities that reported using the chemical but

did not report the amount of the chemical used. Facilities that did not report chemical amounts

were included in the number of facilities that added the chemicals, but they were not reflected in

the amounts of chemicals added per year. As shown in Table 4-6, the two chemicals added most

frequently to industrial laundering processes (besides detergent) are bleach and sour. The

majority of the facilities (89 percent) use bleach as part of their laundering process. Eighty-one

percent of the facilities use sour to prevent the yellowing of laundered items.

Some facilities reported using a chemical for more than one purpose. For these

facilities, Table 4-6 includes only the primary purpose of the chemical. The amounts of mop oil

treatment and dry-cleaning solvents listed in Table 4-6 are lower than actual use because many

respondents who reported conducting mop oil treatment or dry cleaning processes did not report

the amounts of chemicals used in these processes.

Table 4-7 presents the average amount of detergent added per pound of laundry

for the items laundered in the greatest amounts. Buffing pads, filters, shop towels, and printer

towels require on average the highest amounts of detergent per pound of laundry, whereas healthcare items and floor mats require significantly less detergent per pound of laundry.
Chapter 4 - Industry Profile

4-20

Table 4-6

Industrial Laundering Wash Formula Chemicals

Reported in the Detailed Questionnaire

Type of Chemical Chemical (gal/yr) (lb/yr)

Estimated Number Amount Total Estimated

of Facilities Adding Added Amount Added 

Total Estimated 

1 1

Detergent 1,742 3,923,590 105,087,072

Bleach 1,562 5,603,861 3,768,844

Sour 1,419 639,586 4,942,014

Antichlor 1,059 200,546 2,144,738

Softener/Antistatic 990 329,038 1,074,365

Starch 972 198,754 8,741,770

Alkaline Solution 547 2,018,373 7,256,211

Mildewcide/Bactericide 533 81,304 955,824

Solvent-Based Detergent 470 530,513 0

Dye Products 436 46,127 456,012

Builder 275 851,861 1,962,176

Oil Treatment Chemical 258 1,552,455 33,314

Stain Treatment Chemical 157 3,879 124,059

Water Conditioner 141 53,920 1,467,531

Miscellaneous Others 105 239,056 32,140 2

Solvent (Dry Cleaning) 116 244,278 0

Enzymes 55 861 42,160

Denim Treatment 9 23,018 12,874

Some facilities reported using a specific type of chemical but did not provide the amount added per year. Therefore, the total amounts 1

added per year do not necessarily represent the total industry chemical use. In the detailed questionnaire, facilities were given the

choice of reporting the amount of a chemical in either pounds per year or gallons per year. Quantities listed are additive, not inclusive.

This category includes chemicals such as pH adjustors, lubricants, fabric coatings, emulsifiers, dispersants, and desizers. 2

Source: 1994 Industrial Laundries Industry Detailed Questionnaire
Chapter 4 - Industry Profile

4-21

Table 4-7

Amounts of Detergent Added Per Pound of Laundry

 for Items Most Often Laundered

Item of Laundry Added per Pound of Laundry 1

Average Gallons of

Detergent Added per Pound Average Pounds of Detergent

2 2

Industrial Garments (B01) 0.00166 0.0235

Shop Towels, Industrial Wipers, etc. (B02) 0.0112 0.0322

Printer Towels (B03) 0.0237 0.0355

Floor Mats (B04) 0.000393 0.00537

Mops, Dust Cloths, Tool Covers, etc. (B05) 0.00259 0.0213

Linen Garments (B06) 0.00223 0.0212

Linen Flatwork/Full Dry (B07) 0.00177 0.0228

Health-Care Items (B08) 0.000575 0.00898

Fender Covers (B09) 0.00189 0.0230

Continuous Roll Towels (B10) 0.00123 0.0142

Clean Room Garments (B11) 0.00299 0.0123

Other (B13) 0.000500 ---

Laundry Bags (B14) --- 0.0202

Family Laundry (B15) 0.000667 0.0124

New Items (B17) 0.000696 0.00605

Executive Wear (B18) 0.00136 0.00865

Miscellaneous NOG (not our goods) (B19) 0.00771 ---

Rewash Items (B20) --- 0.0314

Filters (B23) --- 0.0486

Buffing Pads (B24) 0.0489 ---

The codes in parentheses are from the detailed questionnaire and were used in the questionnaire database. 1

Facilities were given the choice of reporting the amount of detergent in either pounds per year or gallons per year. 2

These averages reflect the average amount of detergent added, for facilities/formulas that add either liquid detergent or

powdered detergent, not a combination of the two. Quantities listed are additive, not inclusive.

Source: 1994 Industrial Laundries Industry Detailed Questionnaire
Chapter 4 - Industry Profile

4-22

4.4 Facilities and Equipment

Table 4-8 presents the history of industrial laundries construction and startup from

before 1940 to 1995. Facility construction refers to the year the building that the facility operates

in was built. Facility startup refers to the year that actual industrial laundry processing began. As

shown in the table, construction of laundries has fluctuated to some degree over the years. In the

1940s, construction of facilities dipped, then rose in the 1960s, and has declined somewhat into

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

construction time periods.

Industrial laundries typically operate five days per week with one or two shifts per

day. Based on information provided in responses to the detailed questionnaire, the average

number of operating hours per day is 11 (the range is 5 to 24 hours) and the average number of

operating days per year is 261 (the range is 203 to 365 days).

The types of laundering equipment used at these facilities include washing

equipment, drying equipment, and finishing equipment. In addition, some facilities have machines

specially designed to launder specific items, such as continuous roll towels, mats and rugs, and

mops. The most common types of washing equipment used in the industry are washers,

extractors, washer-extractors, tunnel washers, and dry-cleaning units; descriptions of these five

equipment types are provided below.

4.4.1 Washers, Extractors, and Washer-Extractors

Washers in industrial laundries wash and rinse items without removing excess

water. Extractors remove excess rinse water from items after laundering or, in some cases, 

remove excess liquids from dirty items. Some washers automatically deposit the wash load into

adjacent extractors, but others must be emptied manually at the completion of the washing cycle

and the laundry deposited into an extractor. Washer-extractors come equipped with an internal

extractor where both the washing and extraction of excess liquids occurs in one machine. 

Conventional washers used in industrial laundries can handle loads of 15 to 1,200

pounds, as reported by facilities responding to the detailed questionnaire. The average capacity

reported by facilities in the detailed questionnaire is 421 pounds per load. The equipment consists

of a perforated horizontal cylinder rotating in a shell. The cylinder is equipped with ribs that lift

the items as the cylinder rotates and drops them back into the washing solution. Conventional

washers are traditionally equipped with thermometers for temperature control, gauges for control

of water levels, timers, and devices to reverse the direction of rotation every four or five

revolutions.
Chapter 4 - Industry Profile

4-23

Table 4-8

Age of Facilities and Start of Laundry/Dry-Cleaning Operations

(Estimated Percentage of Total Facilities in Each Time Period)

Time Period Facilities Constructed or Dry-Cleaning Operations

Estimated Number of Facilities Starting Laundry

1

Estimated Number of

Before 1940 478 (27%) 385 (22%)

1940-1949 108 (6%) 107 (6%)

1950-1959 199 (11%) 192 (11%)

1960-1969 318 (18%) 365 (21%)

1970-1979 207 (12%) 247 (14%)

1980-1989 178 (10%) 274 (16%)

1990-1995 113 (6%) 164 (9%)

Not Specified 147 (8%) 14 (<1%)

Total 1,747 (100%) 1,747 (100%) 2

Percentages reported are estimated based on the 193 in-scope facilities, extrapolated using appropriate survey weights 1

to represent the entire industry.

Totals may not equal 100% due to rounding. 2

Source: 1994 Industrial Laundries Industry Detailed Questionnaire
Chapter 4 - Industry Profile

4-24

4.4.2 Tunnel Washers

Tunnel washers are washers that operate in a continuous mode. In a tunnel

washer, the items move forward through the washer by an “Archimedes screw” arrangement. 

Rinse water at the discharge end of the washer is recycled back to the first section of the washer. 

Water, steam, and laundry chemicals are mechanically injected into the washer, and, following

washing, the load is moved by conveyer to extractors and dryers. 

4.4.3 Dry-Cleaning Units

Dry-cleaning units are similar to those used in water washing, except that the

fabrics are cleaned in an organic solvent instead of a detergent solution. Standard dry-cleaning

equipment consists of a rotating cylinder in a stationary shell and one or more solvent storage

tanks, a filter system for cleaning the solvent as it is used, a solvent/water separator, distillation

equipment for solvent purification, and often a device for recovering solvent vapors (a condenser

or an activated carbon filter). The water separated from the solvent is discharged with other

process wastewater. 

4.4.4 Equipment Use and Age

Tables 4-9 and 4-10 present information on the types of laundry process

equipment reported by industrial laundries and the age of this equipment, respectively. As shown

in Table 4-9, 95 percent of the facilities have washer-extractors and 42 percent of the facilities

own separate washers and extractors. Overall, separate washers and extractors are slightly older

than washer-extractors. Facilities reported few tunnel washers and, of those reported, most were

purchased in the 1980s or 1990s. Most of the dry-cleaning units reported were also purchased in

the 1980s and 1990s. Table 4-10 indicates that 68 percent of all laundry equipment was reported

to be 15 years old or less, even though only 16 percent of the facilities were built in the past 15

years and only 25 percent of the facilities started laundering operations in the past 15 years.

4.5 Pollution Prevention Activities

Based on the detailed questionnaire responses, extrapolated to represent the entire

industry, 503 facilities have a written pollution prevention policy. Seven hundred forty (740)

facilities of the 1,747 extrapolated facilities conduct pollution prevention activities prior to the

laundering process (pre-process activities) and 473 of these facilities conduct pollution prevention

activities during the laundering process (in-process activities). 

Tables 4-11 and 4-12 list the types of pre-process and in-process pollution

prevention activities, respectively, reported in responses to the detailed questionnaire. Chapter 8

discusses these activities in greater detail. Although the detailed questionnaire specifically

requested that wastewater treatment and water reuse/reduction information not be reported in 
Chapter 4 - Industry Profile

4-25

Table 4-9

Types of Laundry Processing Equipment Reported in the Detailed

Questionnaire

Type of Equipment Equipment Reporting Equipment 1

Estimated Number of Estimated Percentage

Facilities Reporting of Total Facilities

2

Washer-Extractors (D02) 1,668 95.47

Separate Washers (D01) 737 42.20

Separate Extractors (D03) 740 42.36

Dry-Cleaning Units (D04) 252 14.40

Tunnel Washers (D05) 39 2.23

Continuous Roll Towel (CRT) Washers (D07) 35 2.00 

Closed-Loop Oil Washers (D08) 34 1.98

Other (Unspecified) (D06) 8 <1

Dip Tanks (D10) 6 <1

Mat/Rug Washers (D09) 0 0

The codes in parentheses are from the detailed questionnaire and were used in the questionnaire database. 1

Percentages and number of facilities reported are estimated based on 190 in-scope facilities that responded to the 2

question, extrapolated using appropriate survey weights to represent 1,743 facilities.

Source: 1994 Industrial Laundries Industry Detailed Questionnaire
4-26

Section 1 - Summary

Table 4-10

Age of Laundry Processing Equipment

Reported in the Detailed Questionnaire

(Percentage of Equipment Type Installed in Each Time Period)

Time Washer- Cleaning Tunnel CRT Loop Oil Rug Dip (UnspeciPeriod Washers Extractors Extractors Units Washers Washers Washers Washers Tanks fied) Total

Estimated Number of Units Installed

Dry- Closed- Mat/ Other

Before 1960 43 (1.3%) 0 22 (1.2%) 0 0 0 0 0 0 0 65 (<1%)

1960-1969 529 (15.4%) 114 (1.3%) 193 (10.7%) 18 (3.2%) 0 4 (10.8%) 11 0 0 0 869 (6.0%)

(32.4%)

1970-1979 1,323 (38.6%) 1,452 (16.9%) 341 (18.9%) 63 (11.3%) 0 14 (37.8%) 1 (2.9%) 0 0 8 (100%) 3,202

(22%)

1980-1989 924 (26.9%) 3,763 (43.7%) 857 (47.6%) 253 28 (45.2%) 17 (45.9%) 22 0 0 0 5,864

(45.4%) (64.7%) (40.3%)

1990-1995 524 (15.3%) 2,930 (34%) 347 (19.3%) 219 34 (54.8%) 2 (5.4%) 0 0 0 0 4,056

(39.3%) (27.9%)

Not Specified 86 (2.5%) 357 (4.1%) 42 (2.3%) 4 (<1%) 0 0 0 0 6 (100%) 0 495 (3.4%)

Total 3,429 8,616 1,802 557 62 37 34 0 6 8 14,551 1

Totals may not equal 100 percent due to rounding. 1

Source: 1994 Industrial Laundries Industry Detailed Questionnaire
Chapter 4 - Industry Profile

4-27

Table 4-11

Pre-Process Pollution Prevention Activities

Activity Activity Activities

Estimated

Number of Estimated Percentage of

Facilities Total Number of Facilities

Performing Reporting Pre-Laundering

1

Items with Free Liquids Refused 447 60

Certain Items Refused 273 37

Miscellaneous Activities 26 4

Items Centrifuged to Remove Liquids 6 1

Items Sent to Another Site with Wastewater Treatment 67 9

Steam/Air Stripping of Volatile Organics from Items 2 <1

Items Dry-Cleaned Before Water Washing 24 3

Items Presorted to Remove Objects 32 4

Percentages are estimated based on a total of 740 extrapolated facilities (responses of in-scope facilities that reported 1

pre-process pollution prevention activities).

Source: 1994 Industrial Laundries Industry Detailed Questionnaire
Chapter 4 - Industry Profile

4-28

Table 4-12

In-Process Pollution Prevention Activities

Activity Activity Activities

Estimated Number of Total Number of Facilities

Facilities Performing Reporting In-Process

Estimated Percentage of

1

Change in Laundering/Dry-Cleaning Chemicals 132 28

Used2

Liquid Injection System for Wash Chemical Addition 109 23 2

Wastewater Treatment 79 17

Improved Housekeeping 49 10 2

Improved Training of Employees 149 31 2

Water Softening 46 10 2

Equipment Modifications/Installations 43 9

Removal of Lint Before Air Venting to Atmosphere 26 5

Miscellaneous Activities 25 5

Reduced Fuel Consumption 6 1

Recycling of Laundry Materials 3 1

Percentages are estimated based on the extrapolated responses of 473 extrapolated facilities (responses of in-scope 1

facilities that reported in-process pollution prevention activities).

Data for these specific in-process pollution prevention activities were specifically requested in the detailed 2

questionnaire.

Source: 1994 Industrial Laundries Industry Detailed Questionnaire
Chapter 4 - Industry Profile

4-29

response to these questions, several facilities provided this information. (Water reuse/reduction

information was specifically requested by the detailed questionnaire in a different section and is

discussed in greater detail in Chapter 8). 

Table 4-11 shows that the pre-process pollution reduction activity that was

performed by most facilities was the refusal of items with free liquids. These items are commonly

shop towels and printer towels.

The detailed questionnaire requested data for five specific in-process pollution

prevention activities. Facilities were requested to report any additional in-process pollution

prevention activities; these activities were labeled as “other.” Based on descriptions provided by

the facilities, supplemental pollution prevention categories were then created for these “other”

activities. Table 4-12 presents data for the five activities specified in the questionnaire, as well as

for the remaining seven activities. According to responses to the detailed questionnaire, the

facilities reporting pollution prevention activities are equally distributed through all production

category sizes. As shown in Table 4-12, the two most common in-process pollution reduction

activities were change in laundering/dry-cleaning chemicals used and the use of a liquid injection

system for wash chemical addition. 

4.6 Trends in the Industry

Several business and operating trends are emerging in the industrial laundries

industry, including changes in industrial laundry processes, facility size, and pollution reduction

technologies. These trends are discussed in greater detail below.

4.6.1 Trend Away from Dry Cleaning

Many facilities are moving away from dry-cleaning because of the hazardous

nature of the dry cleaning solvents and the expense of their disposal. Nineteen percent of the

facilities responding to the detailed questionnaire reported owning dry-cleaning units. The largest

percentage (45%) of dry-cleaning units was purchased in the 1980s; only 39% of all dry-cleaning

units in operation today were purchased between 1990 and 1995, as shown in Table 4-10. The

facilities that do operate dry cleaning units have moved away from perchlorethylene as a solvent

and are now using petroleum based solvents.

4.6.2 Trend of Small Facilities being Purchased by Larger Firms

In the past several years, there has been a trend toward large firms purchasing

smaller firms. Larger firms realize an economy of scale in their operations and can often offer

lower prices than smaller companies. Many smaller single-owner companies are finding it difficult

to compete with the larger multi-facility firms due to the rising costs of both washroom and

treatment equipment, the difficulty in raising capital, the utilization of new technologies, and the
Chapter 4 - Industry Profile

4-30

requirement of more professional management (1). Because of this increased difficulty to

compete, these smaller facilities are being purchased by the larger firms.

There are many reasons that the larger firms are purchasing smaller facilities. One

of the benefits of a large firm is that they have the capability to offer many specialized laundering

services, (e.g., laundering of cleanroom items). In essence, the larger firms are more diversified

and thus have the capability to process laundry and treat the wastewater generated from a variety

of customers. A recent analysis showed that the largest five firms control about 55 percent of the

market (1). 

4.6.3 Trends in Equipment and Technologies

The industry as a whole is moving towards automation in the washing, drying,

folding, and packaging of items laundered. This includes practices ranging from installing

automatic detergent dispensers in the washers to purchasing washer-extractors instead of separate

washers and extractors. Another trend is the installation of tunnel washers; these washers have a

built-in “reuse cycle” where the final rinse water is automatically cycled back to the first rinse. 

The use of these washers lowers the average water used per pound of item laundered and thus

saves the facilities money.

 The pre-process pollution prevention activities reported by facilities responding to

the detailed questionnaire were initiated primarily in the late 1980s to 1994. The trend within the

industry appears to be to continue and increase pollution prevention activities. Some of these

pollution prevention activities include the installation of more efficient washers and extractors,

detergents that allow for lower wash temperatures and a lower pH for the removal of oils and

grease from the items, and the installation of more sophisticated wastewater treatment systems. 

Chapter 8 discusses pollution prevention practices in more detail.

4.7 Treatment Technologies in Use

The principal types of wastewater treatment reported by industrial laundries in the

detailed questionnaire include gravity settling, screens, equalization/neutralization, air flotation,

clarification, and oil/water separation. Chapter 8 discusses wastewater treatment technologies

used by the industry in greater detail.

4.8 References

1. K. Koepper. “Don’t Count Out More Public Company Acquisitions.” Industrial

Launderer. August 1997: page 24.
Chapter 5 - Water Use and Wastewater Characterization

5-1

CHAPTER 5

WATER USE AND WASTEWATER CHARACTERIZATION

5.1 Introduction

This chapter discusses water use practices for the industrial laundries industry and

presents a raw wastewater characterization of item-specific and total wastewater streams at

industrial laundries. The water use data presented in this chapter are from the 193 in-scope

facilities responding to the 1994 Industrial Laundries Industry Detailed Questionnaire (in-scope

facilities are those that meet the definition of an industrial laundry as presented in Chapter 6,

regardless of annual production). Where appropriate, these data have been extrapolated using

statistically-derived survey weights to represent the entire industry. 

The remainder of this chapter is presented as follows:

C Section 5.2 discusses the sources of industrial laundry service water and

the uses of service water within the industry;

C Section 5.3 discusses wastewater volume by type of discharge;

C Section 5.4 discusses water conservation measures implemented by the

industrial laundries industry;

C Section 5.5 discusses characterization of raw wastewater by item

laundered; and

C Section 5.6 discusses characterization of total, heavy, and light raw

wastewater streams.

5.2 Sources of Service Water and Water Use

This section provides information on sources of service water and water use

breakdown as reported by industrial laundries responding to the detailed questionnaire. 

5.2.1 Sources of Service Water at Industrial Laundries

Service water in the industrial laundries industry refers to any water used at a

facility, ranging from sanitary water to laundry process water. The primary source of service

water at industrial laundries is a water authority or municipal source. Well water is also used as

service water at some facilities. None of the industrial laundries that responded to the detailed

questionnaire reported surface water as the direct intake source of their service water. Table 5-1

presents the sources of service water for the industrial laundries industry; these data have been

extrapolated to represent the entire industry.
Chapter 5 - Water Use and Wastewater Characterization

5-2

5.2.2 Use of Service Water at Industrial Laundries

Industrial laundries use service water for a variety of purposes. Table 5-2 presents

the various uses of service water, the number of facilities reporting each use, and the percentage

of the total industry service water represented by each use. These amounts are based on the first

use of the service water. Water recycle/reuse is not included in Table 5-2. Table 5-2 is based on

available data from the detailed questionnaire extrapolated to represent the entire industrial

laundries industry. 

Laundry Process Water Use. 

The majority of service water is used for laundry processes. As discussed in Chapter

4, the laundering processes that use water and generate wastewater include:

C Water washing;

C Dual-phase washing; and

C Dust control mop treatment (water washing of mops followed by oil

treatment).

Facilities use varying amounts of laundry process water per pound of laundry

processed due to the following factors:

C Type of items laundered;

C Customers;

C Soil loading on items;

C Laundering chemicals used in wash formulas; and

C Laundry processing equipment used.

Process water use at a facility is most directly related to the quantity of items

laundered. Figure 5-1 shows the distribution of facilities by amount of laundry process water used

per pound of laundry processed. Water used in laundry processing comprises the service water that

is allocated to laundry processing, the process water that is reused before and/or after wastewater

treatment, and the water from other processes that is reused as laundry process water (e.g.,

noncontact cooling water). This water use was normalized to account for all laundry production from

processes that generate wastewater. The average amount of wastewater discharged per pound of

laundry processed is 2.74 gallons per pound. Over 86 percent of the industry uses between 1 and 4

gallons of process water per pound of laundry that is water-washed.
Chapter 5 - Water Use and Wastewater Characterization

5-3

Table 5-1

Service Water Sources

Service Water Source Facilities By Source Facilities By Source

Estimated Number of Estimated Percentage of Total

1

Water Authority/Municipal Source Only 1,572 90

Private Well Only 1 < 1

Water Authority/Municipal Source and Private 174 10

Well

Surface Water (Directly) 0 0

Total 1,747 100

Based on responses to the detailed questionnaire from the 193 in-scope facilities, extrapolated to represent the entire industrial laundries industry. 1

Source: 1994 Industrial Laundries Industry Detailed Questionnaire
Chapter 5 - Water Use and Wastewater Characterization

5-4

Table 5-2

Service Water Use

Service Water Use Number of Facilities By Use Service Water By Use

Estimated Estimated Percentage of Total

1

Laundry Process Water 1,745 92.1

Sanitary Water 1,670 3.1

Floor/Equipment Washing 956 <1

Boiler Water 599 1.8

Vehicle Washing 584 <1

Noncontact Cooling Water 490 1.4

Water Softener Regeneration Water 94 <1

Other Uses Not Reported 72 <1

Wastewater Treatment 37 <1

Air Conditioning 26 <1

Landscaping 25 <1

Dish Washing 22 <1

Irrigation 1 <1

Total - 100

Number of facilities reporting water use is based on the responses to the detailed questionnaire from 193 in-scope facilities, extrapolated to represent the 1

entire industrial laundries industry. The number of facilities reporting each service water use is based on the first use of the service water. One facility

reported using service water first as noncontact cooling water, then as process water. This facility has a survey weight of 2.

Source: 1994 Industrial Laundries Industry Detailed Questionnaire
0 

100 

200 

300 

400 

500 

Number of Facilities

0

0.0 - 0.5

0.5 - 1.0

1.0 - 1.5

1.5 - 2.0

2.0 - 2.5

2.5 -3.0

3.0 - 3.5

3.5 - 4.0

4.0 - 4.5

4.5 - 5.0

5.0 - 5.5

5.5 - 6.0

6.0 - 6.5

6.5 - 7.0

7.0 - 7.5

7.5 - 8.0

8.0 - 8.5

8.5 - 9.0

9.0 - 9.5

9.5 - 10

>10

Average Gallons of Water Used Per Pound of Laundry Processed (gal/lb)

5-5

Chapter 5 - Water Use and Wastewater Characterization

 Based on responses to the detailed questionnaire from the 193 in-scope facilities, extrapolated to represent the entire industry. 1

Figure 5-1. Distribution of Facilities by Production Normalized Laundry Process Water Use1
Chapter 5 - Water Use and Wastewater Characterization

5-6

Water use is also related to type of item laundered. An analysis of item-specific water

use per pound of laundry processed (gal/lb) was conducted using data from facility responses to the

detailed questionnaire. Table 5-3 presents the item-specific water use in gallons of water per pound

of laundry (gal/lb) by process as reported by the 193 in-scope facilities responding to the detailed

questionnaire. These amounts were calculated from information provided in the wash formulas

reported by facilities. For most items, EPA calculated a median water use ranging from 2.40 to 3.30

gal/lb. Denim prewashing of new items requires the highest use of water with a median value of 5.40

gal/lb. Water washing of buffing pads requires the least amount of water (0.50 gal/lb), but this

amount is based on information from only one facility. 

Other Industrial Laundry Water Uses. 

Although most of the incoming service water used at industrial laundries (92.1

percent) is used as laundry process water, there are a number of other service water uses, as

presented in Table 5-2. After laundry process water, sanitary water accounts for the second largest

amount (3.1 percent) of total service water used at industrial laundries. Boiler water accounts for

the third most significant use of service water (1.8 percent), followed closely by noncontact cooling

water (1.4 percent). Noncontact cooling water includes water used in evaporative coolers and other

heat exchangers. Approximately 95 percent of the facilities that reported noncontact cooling water

use recycle their noncontact cooling water. In many instances, the recycled water is used as laundry

process water. Other uses of service water at industrial laundries include vehicle washing,

floor/equipment washing, and water used in wastewater treatment systems. These uses each

represent less than one percent of the total service water used at industrial laundry facilities.

5.3 Wastewater Volume by Type of Discharge

All of the in-scope facilities that responded to the detailed questionnaire discharge

laundry wastewater to a POTW. Some facilities also discharge some of their process wastewater to

off-site disposal or land application. None of the facilities reported discharging laundry process

wastewater or noncontact cooling water directly to surface water. Residual wastewater found in the

sludge and oil wastes generated during wastewater pretreatment is also disposed of off site or land

applied. Table 5-4 presents process wastewater discharge practices reported by the facilities that

responded to the detailed questionnaire. 

Figure 5-2 shows the distribution of facilities by amount of laundry process

wastewater discharged per pound of laundry processed. The total wastewater discharged comprises

the laundry process wastewater that is discharged to a POTW, the laundry process wastewater that

is land applied, and the laundry process wastewater that is shipped off site for disposal. This

calculated wastewater discharge was normalized for all laundry production
5-7

Section 1 - Summary

Table 5-3

Item-Specific Water Use1

Item Process (gal/lb) (gal/lb) (gal/lb) Facilities in Calculations 2 3

Mean Median Deviation Estimated Number of

Standard

Industrial Garments (B01) A01 2.66 2.40 1.47 148

A02 3.73 2.80 2.46 3

Shop Towels (B02) A01 4.18 3.10 8.73 126

Printer Towels (B03) A01 4.12 3.60 2.32 65

A02 3.70 3.80 0.29 3

Floor Mats (B04) A01 1.87 1.60 0.98 163

A02 2.10 2.10 0.00 1

Mops, Dust Cloths, Tool Covers, etc. (B05) A01 3.00 2.80 1.57 83

A07 3.03 2.90 1.58 45

Linen Supply Garments (B06) A01 3.51 3.30 1.62 99

Linen Flatwork/Full Dry (B07) A01 3.03 2.80 1.34 121

Health-Care Items (B08) A01 2.53 2.40 1.02 67

Fender Covers (B09) A01 3.55 2.70 3.65 65

Continuous Roll Towels (B10) A01 2.88 2.40 4.32 79

Clean Room Garments (B11) A01 2.93 3.00 0.52 9

Other (B13) A01 4.00 4.00 0.00 1

Laundry Bags (B14) A01 1.45 1.45 0.45 2
5-8

Section 1 - Summary

Table 5-3 (Continued)

Item Process (gal/lb) (gal/lb) (gal/lb) Facilities in Calculations 2 3

Mean Median Deviation Estimated Number of

Standard

Family Laundry (B15) A01 3.35 3.05 1.28 6

New Items (B17) A01 3.00 2.75 1.17 6

A13 5.63 5.40 1.76 3

Executive Wear (B18) A01 4.74 2.90 4.67 5

Miscellaneous NOG (Not Our Goods) (B19) A01 3.00 3.00 0.00 1

Rewashed Items (B20) A01 2.18 2.10 0.77 5

Filters (B23) A01 4.20 4.20 1.20 2

Buffing Pads (B24) A01 0.50 0.50 0.00 1

 The process/item gallon-per-pound ratios were calculated from water washing formula data provided in Table C of the detailed questionnaire. This analysis was performed using data from the 193 in-scope facilities; 1

the data were not extrapolated to represent the entire industry. The ratios for each formula at a facility were calculated and the ratios were averaged for each item/process combination at individual facilities. The

number of times the formula was used per day was taken into account. The facility-specific ratios were then used to calculate an industry mean and median gallon/pound ratio for each item/process combination.

There were no usable data to calculate the water use requirements for absorbents, clean wipes, or airline carpet and seat covers.

 The codes in parentheses reflect the item codes used in the detailed questionnaire. 2

 Process codes used in the detailed questionnaire: 3

A01 - Water Washing

A02 - Dual Phase Washing: Petroleum solvent wash followed by water washing

A07 - Dust Control Mop Treatment: Water washing followed by oil treatment

A13 - Denim Prewash

Source: 1994 Industrial Laundries Industry Detailed Questionnaire
Chapter 5 - Water Use and Wastewater Characterization

5-9

Table 5-4

Discharge Practices of Industrial Laundries1

Discharge Practice (Percent of Facilities) (Percent of Facilities)

Estimated Number of Estimated Number of Facilities

Facilities Discharging Discharging Noncontact Cooling

Laundry Process Wastewater Water

Discharge to POTW 1,747 (100%) 313 (18%)

Off-Site Disposal 221 (13%) 0 (0%)

Land Application 84 (5%) 0 (0%)

Discharge to Surface Water 0 (0%) 0 (0%)

Based on responses to the detailed questionnaire from the 193 in-scope facilities, extrapolated to represent the entire industry. Some facilities reported 1

more than one discharge practice.

Source: 1994 Industrial Laundries Industry Detailed Questionnaire
0 

100 

200 

300 

400 

500 

Number of Facilities

0

0.0 - 0.5

0.5 - 1.0

1.0 - 1.5

1.5 - 2.0

2.0 - 2.5

2.5 -3.0

3.0 - 3.5

3.5 - 4.0

4.0 - 4.5

4.5 - 5.0

5.0 - 5.5

5.5 - 6.0

6.0 - 6.5

6.5 - 7.0

7.0 - 7.5

7.5 - 8.0

8.0 - 8.5

8.5 - 9.0

9.0 - 9.5

9.5 - 10

>10

Average Gallons of Water Discharged Per Pound of Laundry Processed (gal/lb)

5-10

Chapter 5 - Water Use and Wastewater Characterization

 Based on responses to the detailed questionnaire from the 193 in-scope facilities, extrapolated to represent the entire industry. 1

Figure 5-2. Distribution of Facilities by Production Normalized Laundry Process Water Discharge1
Chapter 5 - Water Use and Wastewater Characterization

5-11

from processes that generate wastewater. Over 60 percent of the facilities discharge between 1.5 and

3.5 gallons of process wastewater per pound of laundry that is water-washed. 

A comparison of the values in Figures 5-1 and 5-2 shows that more laundry process

water is used than is discharged. This difference is due to evaporation losses and laundry process

wastewater recycle/reuse before and after wastewater treatment. (The average evaporation loss

reported by facilities in the detailed questionnaire was approximately 10 percent. For 81 percent of

the facilities, the difference between laundry process water use and discharge is less than 0.5 gal/lb.

Most of the reported amounts of laundry process wastewater discharged are estimates; less than 15

percent of the facilities measure the amount of wastewater that is discharged at their facilities.

5.4 Water Conservation Measures

Approximately 85 percent of the facilities that responded to the detailed questionnaire

reported performing some type of water conservation practice. Table 5-5 presents activities that were

reported as standard water conservation techniques at industrial laundries. Table 5-5 also presents

the reported water use reduction due to implementation of these conservation practices. As shown

in the table, prompt attention to faulty equipment, leaks, and other problems is practiced by the

greatest number of laundries, followed by routine monitoring of water use. Chapter 8 provides

additional information on wastewater recycle/reuse.

5.5 Characterization of Raw Wastewater by Item Laundered

As discussed in Chapter 4, items laundered at industrial laundries can have significantly

different pollutant loads based on item type and customer. This section presents raw wastewater

characterization data for specific items laundered for the 72 pollutants most frequently detected in

industrial laundry wastewater. Table 5-6 presents for the 72 pollutants the mean pollutant

concentration by item type. Table B-1 in Appendix B of this document presents for the 72 pollutants

the minimum, maximum, and mean concentrations, as well as the number of times each pollutant was

analyzed, the number of times the pollutant was detected, and the percentage of times the pollutant

was detected, by item type.

5.6 Characterization of Total, Heavy, and Light Raw Wastewater Streams

This section presents raw wastewater characterization data for total, heavy, and light

raw wastewater streams at industrial laundries. EPA sampling program data and detailed monitoring

questionnaire (DMQ) data from facilities that do not split their wastewater stream were used to

characterize total raw wastewater streams. The total stream is then discharged, with or without

treatment, to a POTW. EPA sampling program data from facilities that split their wastewater streams

were used to characterize heavy and light wastewater streams. The heavy and light wastewater

streams were designated as such by the sampled facilities; generally, the heavy wastewater stream is

generated from laundering items with high pollutant
Chapter 5 - Water Use and Wastewater Characterization

5-12

Table 5-5

Water Conservation Practices and Water Use Reduction

Water Conservation Practice Range (gal/day) Practice Practice

Water Facilities Facilities

Reduction With This With This

Estimated Percentage

Number of of Total

1 1

Prompt Attention to Faulty Equipment, Leaks, and Other 0 - 25,000 1,180 68%

Problems

Routine Monitoring of Water Use 0 - 57,693 996 57%

Installation of Laundering Equipment That Uses Less 16 - 165,000 266 15%

Water

Implementation of Alternative Laundry Wash Formulas 6 - 26,000 261 15%

That Require Less Water

Reuse of Noncontact Cooling Water as Process Makeup 150 - 31,623 246 14%

Water

Recycling/Reuse of Laundry Wastewater Before 60 - 53,000 155 9%

Treatment

Implementation of Alternative Production Processes 82 - 20,000 44 2%

That Require Less Water

Other Practices 200 - 6,000 19 1%

Installation of Automatic Monitoring and Alarm Systems 500 - 7,985 17 1%

on In-plant Discharges

Recycle/Reuse of Laundry Wastewater After Treatment 3,000 - 29,000 13 1%

Reuse of Nonlaundry Wastewater as Laundry Process 8,967 4 <1%

Water

Based on responses to the detailed questionnaire, extrapolated to represent entire industry. Only 1,468 extrapolated facilities responded to this question. 1

Percentages are based on the entire estimated industry of 1,747.

Source: 1994 Industrial Laundries Industry Detailed Questionnaire
Chapter 5 - Water Use and Wastewater Characterization

5-13

Table 5-6

Wastewater Characterization for Item Specific Wastewater at Industrial

Laundries

Constituent Name Garments Shop Towels Printer Towels Mats

Mean Concentration (mg/L)1

Industrial

Conventionals

Biochemical Oxygen Demand 5-Day (BOD5) 386 2,060 3,940 248

Oil and Grease (measured as HEM) 91 2,550 5,890 84

Total Suspended Solids (TSS) 348 4,590 1,250 365

Priority Organics

1,1,1-Trichloroethane 0.0550 5.16 4.50 1.60

1,2-Diphenylhydrazine 0.110 1.36 1.00 0.0200

4-Chloro-3-methylphenol 0.178 1.03 0.433 0.0100

Bis(2-ethylhexyl) Phthalate 0.224 3.30 19.0 2.02

Butyl Benzyl Phthalate 0.0550 0.678 5.55 0.0197

Chlorobenzene 0.0550 0.313 0.467 0.0100

Chloroform 0.0550 0.370 0.370 0.0100

Di-n-butyl Phthalate 0.0550 0.678 3.20 0.0100

Di-n-octyl Phthalate 0.0600 0.678 1.24 0.0494

Ethylbenzene 0.151 6.25 13.2 0.283

Isophorone 0.0550 0.678 0.500 0.361

Methylene Chloride 0.0558 5.28 0.614 0.442

Naphthalene 0.0550 2.88 9.64 0.0244

Phenol 0.0702 0.381 0.500 0.0100

Tetrachloroethene 0.0550 8.03 3.92 0.125

Toluene 0.0666 4.81 20.5 1.29

trans-1,2-Dichloroethene 0.0550 0.456 0.371 0.0100

Trichloroethene 0.0550 0.294 0.476 0.0100

Nonconventional Organics

2-Butanone 0.275 1.92 3.09 0.579

2-Methylnaphthalene 0.0550 0.946 0.836 0.0100

2-Propanone 0.313 3.98 49.7 2.11

4-Methyl-2-pentanone 0.275 1.88 2.07 0.458

%-Terpineol 0.0550 0.874 1.07 0.0825

Benzoic Acid 0.450 3.23 3.30 0.231

Benzyl Alcohol 0.0699 0.678 0.500 0.0724

Hexanoic Acid 0.0885 0.373 0.433 0.0737

m-Xylene 0.0100 1.69 1.44 0.520

n-Decane 0.0550 49.5 90.6 1.98

n-Docosane 0.0632 0.949 0.668 0.0130

n-Dodecane 0.0630 18.2 23.1 0.121
Table 5-6 (Continued)

Chapter 5 - Water Use and Wastewater Characterization

Constituent Name Garments Shop Towels Printer Towels Mats

Mean Concentration (mg/L)1

Industrial

5-14

n-Eicosane 0.0694 29.8 1.29 0.0166

n-Hexacosane 0.130 1.83 2.01 0.0197

n-Hexadecane 0.0759 9.85 9.51 0.0305

n-Octacosane 0.0956 1.11 0.402 0.0100

n-Octadecane 0.0471 11.4 2.43 0.0152

n-Tetracosane 0.0679 0.831 0.605 0.0100

n-Tetradecane 0.0634 16.9 7.89 0.0190

n-Triacontane 0.0620 0.926 0.626 0.0306

o-&p-Xylene 0.0100 0.563 1.08 0.291

p-Cresol 0.0550 0.373 0.433 0.0100

p-Cymene 0.0764 2.54 12.4 0.0100

Pentamethylbenzene 0.0550 0.678 0.500 0.0100

Priority Metals and Elements

Antimony 0.454 0.211 0.0556 0.0203

Arsenic 0.0116 0.0238 0.00313 0.00380

Beryllium 0.000758 0.00100 0.00100 0.00100

Cadmium 0.0246 0.391 0.0253 0.00950

Chromium 0.0936 0.478 2.65 0.0806

Copper 0.672 6.65 11.0 0.220

Lead 0.214 7.34 8.91 0.307

Mercury 0.000408 0.00122 0.000230 0.000430

Nickel 0.103 0.600 0.101 0.0543

Selenium 0.0102 0.0138 0.0177 0.00460

Silver 0.00710 0.174 0.207 0.0171

Thallium 0.00360 0.00467 0.00767 0.0120

Zinc 1.47 13.9 3.62 1.06

Nonconventional Metals and Elements

Aluminum 5.19 11.3 8.22 3.42

Barium 0.254 3.98 4.53 0.214

Boron 0.195 1.81 0.670 0.0500

Cobalt 0.0171 0.336 0.614 0.0135

Iron 9.70 55.2 8.51 6.87

Manganese 0.139 1.18 0.898 0.115

Molybdenum 0.0213 0.351 2.10 0.0240

Tin 0.0922 0.270 0.0990 0.0439

Titanium 0.148 0.199 0.184 0.0100

Vanadium 0.00700 0.0433 0.00900 0.00920

Yttrium 0.00215 0.00810 0.00570 0.00500
Table 5-6 (Continued)

Chapter 5 - Water Use and Wastewater Characterization

Constituent Name Garments Shop Towels Printer Towels Mats

Mean Concentration (mg/L)1

Industrial

5-15

Bulk Nonconventionals

Chemical Oxygen Demand (COD) 1,740 14,000 16,900 80

Total Organic Carbon (TOC) 359 1,950 2,740 186

Total Petroleum Hydrocarbon (measured as SGT-HEM) 47 1,630 1,730 33
Table 5-6 (Continued)

Chapter 5 - Water Use and Wastewater Characterization

5-16

Constituent Name Mops Printer Towels Washing Items

Mean Concentration (mg/L)1

Steam-Tumbled Prior to Water Linen Supply

Items Dry Cleaned

Conventionals

Biochemical Oxygen Demand 5-Day (BOD5) 1,150 1,440 113 881

Oil and Grease (measured as HEM) 286 1,720 NA 108

Total Suspended Solids (TSS) 1,100 1,320 82 269

Priority Organics

1,1,1-Trichloroethane 1.04 0.0118 NA 0.00833

1,2-Diphenylhydrazine 0.200 0.0800 NA 0.0200

4-Chloro-3-methylphenol 0.100 0.0400 NA 0.0100

Bis(2-ethylhexyl) Phthalate 1.10 8.77 NA 0.574

Butyl Benzyl Phthalate 0.895 0.366 NA 0.0944

Chlorobenzene 0.0550 0.0100 NA 0.00833

Chloroform 0.0565 0.0100 NA 0.889

Di-n-butyl Phthalate 0.434 0.117 NA 0.0306

Di-n-octyl Phthalate 0.108 0.325 NA 0.0572

Ethylbenzene 0.0550 0.0100 0.0458 0.00833

Isophorone 0.100 0.0400 NA 0.0100

Methylene Chloride 0.0767 0.0100 NA 0.0112

Naphthalene 0.471 0.226 NA 0.108

Phenol 0.100 0.0432 NA 0.0674

Tetrachloroethene 0.0550 0.0100 NA 0.00833

Toluene 0.0597 0.0436 0.225 0.0241

trans-1,2-Dichloroethene 0.0550 0.0100 NA 0.00833

Trichloroethene 0.0550 0.0100 NA 0.00833

Nonconventional Organics

2-Butanone 1.13 0.0500 NA 0.0500

2-Methylnaphthalene 0.432 0.0400 NA 0.0164

2-Propanone 2.22 0.681 NA 0.0607

4-Methyl-2-pentanone 0.275 0.0500 NA 0.0500

%-Terpineol 0.100 0.0400 NA 0.0339

Benzoic Acid 2.35 0.977 NA 0.150

Benzyl Alcohol 0.610 0.819 NA 0.202

Hexanoic Acid 0.216 0.384 NA 0.0279

m-Xylene 0.100 0.0151 NA 0.0100

n-Decane 0.965 0.499 NA 2.63

n-Docosane 0.157 0.131 NA 0.0392

n-Dodecane 8.07 2.65 NA 0.270

n-Eicosane 0.291 3.05 NA 0.0862
Table 5-6 (Continued)

Chapter 5 - Water Use and Wastewater Characterization

Constituent Name Mops Printer Towels Washing Items

Mean Concentration (mg/L)1

Steam-Tumbled Prior to Water Linen Supply

Items Dry Cleaned

5-17

n-Hexacosane 0.210 0.0904 NA 0.0267

n-Hexadecane 1.07 91.6 NA 0.160

n-Octacosane 0.221 0.0633 NA 0.0212

n-Octadecane 0.875 1.48 NA 0.0720

n-Tetracosane 0.100 0.0724 NA 0.0630

n-Tetradecane 1.47 12.8 NA 0.140

n-Triacontane 0.163 0.0587 NA 0.0551

o-&p-Xylene 0.100 0.0146 NA 0.0100

p-Cresol 0.100 0.0400 NA 0.0100

p-Cymene 0.100 0.0400 NA 0.108

Pentamethylbenzene 0.100 0.0400 NA 0.0100

Priority Metals and Elements

Antimony 0.0556 0.0261 NA 0.114

Arsenic 0.0178 0.00380 0.00500 0.156

Beryllium 0.00100 0.00100 NA 0.00100

Cadmium 0.0373 0.0358 0.0825 0.0219

Chromium 0.184 0.275 0.0933 0.0492

Copper 3.52 4.86 0.668 0.527

Lead 1.76 0.957 0.519 0.151

Mercury 0.00840 0.000200 0.000150 0.00165

Nickel 0.195 0.0372 0.0200 0.0771

Selenium 0.00460 0.0230 NA 0.151

Silver 0.0160 0.0653 0.00500 0.0291

Thallium 0.00240 0.0120 NA 0.00700

Zinc 5.32 2.10 0.450 0.381

Nonconventional Metals and Elements

Aluminum 17.3 2.80 NA 3.08

Barium 0.953 1.63 NA 0.301

Boron 0.327 0.0500 NA 0.0970

Cobalt 0.0620 0.202 NA 0.00990

Iron 31.9 2.62 NA 3.26

Manganese 0.638 0.277 NA 0.0812

Molybdenum 0.0940 2.64 NA 0.0263

Tin 0.128 0.0761 NA 0.0290

Titanium 0.307 0.0178 NA 0.0654

Vanadium 0.0320 0.0221 NA 0.00990

Yttrium 0.00500 0.00500 NA 0.00470
Table 5-6 (Continued)

Chapter 5 - Water Use and Wastewater Characterization

Constituent Name Mops Printer Towels Washing Items

Mean Concentration (mg/L)1

Steam-Tumbled Prior to Water Linen Supply

Items Dry Cleaned

5-18

Bulk Nonconventionals

Chemical Oxygen Demand (COD) 5,410 9,000 638 844

Total Organic Carbon (TOC) 518 1,770 NA 401

Total Petroleum Hydrocarbon (measured as SGT-HEM) 111 468 NA 12

The detection limit concentration was used in calculations for data points reported as non-detects. 1

NA - Not Available. No data were available for this constituent.
Chapter 5 - Water Use and Wastewater Characterization

5-19

loadings and the light wastewater stream is generated from laundering items with low pollutant

loadings. At some facilities, the heavy stream is generated from wastewater from the first several

breaks of laundering a variety of items. The heavy stream is typically treated and combined with the

untreated light stream prior to discharge to a POTW.

Tables 5-7 through 5-9 present for 72 pollutants the mean concentrations for heavy,

light, and total raw wastewater streams. Table B-2 in Appendix B of this document presents for the

72 pollutants the minimum, maximum, and mean concentrations, as well as the number of times the

pollutant was analyzed, the number of times the pollutant was detected, and the percentage of times

the pollutant was detected. In general, the concentrations of pollutants in heavy wastewater streams

are greater than the concentrations of pollutants in total wastewater streams, and the concentrations

of pollutants in total wastewater streams are greater than the concentrations of pollutants in light

wastewater streams.
Chapter 5 - Water Use and Wastewater Characterization

5-20

Table 5-7

Wastewater Characterization Data for Heavy Wastewater 

Streams at Industrial Laundries

Pollutant (mg/L)

Mean Concentration1

Conventionals

Biochemical Oxygen Demand 5-Day (BOD5) 4,160

Oil and Grease (measured as HEM) 2,950

Total Suspended Solids (TSS) 2,320

Priority Organics

1,1,1-Trichloroethane 1.16

1,2-Diphenylhydrazine 2.60

4-Chloro-3-methylphenol 0.260

Bis(2-ethylhexyl) Phthalate 11.6

Butyl Benzyl Phthalate 8.96

Chlorobenzene 0.271

Chloroform 0.296

Di-n-butyl Phthalate 1.45

Di-n-octyl Phthalate 0.599

Ethylbenzene 3.65

Isophorone 0.207

Methylene Chloride 0.854

Naphthalene 5.07

Phenol 0.303

Tetrachloroethene 1.79

Toluene 9.69

trans-1,2-Dichloroethene 0.271

Trichloroethene 1.27

Nonconventional Organics

2-Butanone 25.5

2-Methylnaphthalene 0.892

2-Propanone 8.49

4-Methyl-2-pentanone 5.82
Table 5-7 (Continued)

Chapter 5 - Water Use and Wastewater Characterization

Pollutant (mg/L)

Mean Concentration1

5-21

%-Terpineol 0.379

Benzoic Acid 3.36

Benzyl Alcohol 1.56

Hexanoic Acid 0.210

m-Xylene 4.47

n-Decane 86.5

n-Docosane 0.504

n-Dodecane 29.5

n-Eicosane 4.41

n-Hexacosane 0.354

n-Hexadecane 9.49

n-Octacosane 0.370

n-Octadecane 4.00

n-Tetracosane 0.316

n-Tetradecane 7.23

n-Triacontane 0.366

o-&p-Xylene 3.59

p-Cresol 0.204

p-Cymene 3.55

Pentamethylbenzene 0.412

Priority Metals and Elements

Antimony 0.788

Arsenic 0.0125

Beryllium 0.00142

Cadmium 0.121

Chromium 0.296

Copper 5.37

Lead 1.60

Mercury 0.000816

Nickel 0.266

Selenium 0.0174
Table 5-7 (Continued)

Chapter 5 - Water Use and Wastewater Characterization

Pollutant (mg/L)

Mean Concentration1

5-22

Silver 0.199

Thallium 0.00989

Zinc 7.79

Nonconventional Metals and Elements

Aluminum 9.97

Barium 3.63

Boron 4.93

Cobalt 0.449

Iron 42.1

Manganese 1.51

Molybdenum 0.668

Tin 0.130

Titanium 0.344

Vanadium 0.0381

Yttrium 0.0101

Bulk Nonconventionals

Chemical Oxygen Demand (COD) 13,700

Total Organic Carbon (TOC) 2,790

Total Petroleum Hydrocarbon (measured as SGT-HEM) 1,440

The detection limit concentration was used in calculations for data points reported as non-detects. 1
Chapter 5 - Water Use and Wastewater Characterization

5-23

Table 5-8

Wastewater Characterization Data for Light Wastewater 

Streams at Industrial Laundries

Pollutant of Concern (mg/L)

Mean Concentration1

Conventionals

Biochemical Oxygen Demand 5-Day (BOD5) 568

Oil and Grease (measured as HEM) 154

Total Suspended Solids (TSS) 344

Priority Organics

1,1,1-Trichloroethane 0.0160

1,2-Diphenylhydrazine 0.220

4-Chloro-3-methylphenol 0.0411

Bis(2-ethylhexyl) Phthalate 1.10

Butyl Benzyl Phthalate 0.0690

Chlorobenzene 0.0160

Chloroform 0.0455

Di-n-butyl Phthalate 0.104

Di-n-octyl Phthalate 0.0667

Ethylbenzene 0.0620

Isophorone 0.0400

Methylene Chloride 0.0213

Naphthalene 0.358

Phenol 0.105

Tetrachloroethene 0.0977

Toluene 0.0553

trans-1,2-Dichloroethene 0.0160

Trichloroethene 0.0160

Nonconventional Organics

2-Butanone 0.147

2-Methylnaphthalene 0.0566

2-Propanone 0.518

4-Methyl-2-pentanone 0.240
Table 5-8 (Continued)

Chapter 5 - Water Use and Wastewater Characterization

Pollutant of Concern (mg/L)

Mean Concentration1

5-24

%-Terpineol 0.123

Benzoic Acid 0.306

Benzyl Alcohol 0.102

Hexanoic Acid 0.0557

m-Xylene 0.0555

n-Decane 0.354

n-Docosane 0.0591

n-Dodecane 0.973

n-Eicosane 0.124

n-Hexacosane 0.0465

n-Hexadecane 0.330

n-Octacosane 0.0432

n-Octadecane 0.0850

n-Tetracosane 0.0680

n-Tetradecane 0.103

n-Triacontane 0.0492

o-&p-Xylene 0.0765

p-Cresol 0.0400

p-Cymene 0.0473

Pentamethylbenzene 0.0787

Priority Metals and Elements

Antimony 1.32

Arsenic 0.00653

Beryllium 0.000938

Cadmium 0.0211

Chromium 0.113

Copper 0.858

Lead 0.348

Mercury 0.000715

Nickel 0.101

Selenium 0.0133
Table 5-8 (Continued)

Chapter 5 - Water Use and Wastewater Characterization

Pollutant of Concern (mg/L)

Mean Concentration1

5-25

Silver 0.00432

Thallium 0.00313

Zinc 1.47

Nonconventional Metals and Elements

Aluminum 4.65

Barium 0.421

Boron 0.391

Cobalt 0.0264

Iron 10.3

Manganese 0.184

Molybdenum 0.0357

Tin 0.0625

Titanium 0.206

Vanadium 0.0138

Yttrium 0.00313

Bulk Nonconventionals

Chemical Oxygen Demand (COD) 1,410

Total Organic Carbon (TOC) 338

Total Petroleum Hydrocarbon (measured as SGT-HEM) 85

The detection limit concentration was used in calculations for data points reported as non-detects. 1
Chapter 5 - Water Use and Wastewater Characterization

5-26

Table 5-9

Wastewater Characterization Data for Total Raw Wastewater 

Streams at Industrial Laundries

Pollutant (mg/L)

Mean Concentration1

Conventionals

Biochemical Oxygen Demand 5-Day (BOD5) 879

Oil and Grease (measured as HEM) 1,450

Total Suspended Solids (TSS) 849

Priority Organics

1,1,1-Trichloroethane 0.334

1,2-Diphenylhydrazine 0.0984

4-Chloro-3-methylphenol 0.070

Bis(2-ethylhexyl) Phthalate 5.42

Butyl Benzyl Phthalate 0.139

Chlorobenzene 0.155

Chloroform 0.0344

Di-n-butyl Phthalate 0.273

Di-n-octyl Phthalate 0.103

Ethylbenzene 0.681

Isophorone 0.0790

Methylene Chloride 0.390

Naphthalene 1.72

Phenol 0.0861

Tetrachloroethene 3.69

Toluene 2.49

trans-1,2-Dichloroethene 0.0230

Trichloroethene 0.0211

Nonconventional Organics

2-Butanone 2.98

2-Methylnaphthalene 0.157

2-Propanone 12.8

4-Methyl-2-pentanone 1.89
Table 5-9 (Continued)

Chapter 5 - Water Use and Wastewater Characterization

Pollutant (mg/L)

Mean Concentration1

5-27

%-Terpineol 0.326

Benzoic Acid 0.779

Benzyl Alcohol 0.0753

Hexanoic Acid 0.0854

m-Xylene 5.56

n-Decane 97.0

n-Docosane 0.680

n-Dodecane 6.75

n-Eicosane 2.12

n-Hexacosane 0.529

n-Hexadecane 5.57

n-Octacosane 0.103

n-Octadecane 1.82

n-Tetracosane 1.63

n-Tetradecane 5.08

n-Triacontane 0.160

o-&p-Xylene 3.02

p-Cresol 0.0713

p-Cymene 0.143

Pentamethylbenzene 0.313

Priority Metals and Elements

Antimony 0.0945

Arsenic 0.0185

Beryllium 0.00752

Cadmium 0.0574

Chromium 0.263

Copper 1.36

Lead 0.809

Mercury 0.00110

Nickel 0.165

Selenium 0.0648
Table 5-9 (Continued)

Chapter 5 - Water Use and Wastewater Characterization

Pollutant (mg/L)

Mean Concentration1

5-28

Silver 0.0278

Thallium 0.0248

Zinc 2.16

Nonconventional Metals and Elements

Aluminum 5.86

Barium 1.18

Boron 0.701

Cobalt 0.184

Iron 30.9

Manganese 0.504

Molybdenum 0.386

Tin 0.176

Titanium 0.166

Vanadium 0.0710

Yttrium 0.0127

Bulk Nonconventionals

Chemical Oxygen Demand (COD) 5,290

Total Organic Carbon (TOC) 1,440

Total Petroleum Hydrocarbon (measured as SGT-HEM) 530

The detection limit concentration was used in calculations for data points reported as non-detects. 1