United States

Environmental Protection

Agency

Office of Water

(4303)

EPA Technical Development Document

for the Final Action Regarding

Pretreatment Standards for the

Industrial Laundries Point Source

Category (Revised March 2000)

EPA 821-R-00-006

March 2000
TECHNICAL DEVELOPMENT DOCUMENT FOR

THE FINAL ACTION REGARDING PRETREATMENT STANDARDS

FOR THE 

INDUSTRIAL LAUNDRIES POINT SOURCE CATEGORY

(Revised March 2000)

Carol M. Browner

Administrator

J. Charles Fox

Assistant Administrator, Office of Water

Sheila Frace

Director, Engineering and Analysis Division

Marvin B. Rubin

Chief, Energy Branch

Marta Jordan

Work Assignment Manager

Engineering and Analysis Division

Office of Science and Technology

U.S. Environmental Protection Agency

Washington D.C. 20460

March 2000
ACKNOWLEDGMENT

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

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

support of Eastern Research Group, Inc. under the direction and review of the Office of Science

and Technology.
FOREWORD

This document includes technical support for the options considered during

rulemaking for the Industrial Laundries Point Source Category. 

After the Administrator signed the notice of final action, EPA received revised

analytical data for some of the samples measured for semivolatile organic compounds, due to

errors found in using dilution factors to calculate the sample concentrations. The revised data did

not cause major changes, and provided a stronger basis for EPA’s decision not to regulate this

industry. Based on revised analytical data for semivolatile organic compounds for two sampling

episodes conducted in 1996 and 1998, EPA revised this document in March 2000. The following

chapters and appendices have been revised:

C Chapter 5

—Table 5-11;

—Table 5-12;

—Table 5-14

—Table 5-15; and

—Table 5-16.

C Chapter 7

—Table 7-1;

—Table 7-3;

—Table 7-4;

—Table 7-5;

—Table 7-7;

—Table 7-11; and

—Tables 7-12 through 7-16.

C Chapter 9

—Table 9-1;

—Table 9-4;

—Tables 9-9 through 9-16.

C Appendix C

—Table C-3; and

—Table C-4.

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

C Appendix E.

Throughout the document, EPA refers to many commonly used titles and phrases by their

acronyms to avoid spelling them out each time. As an aid to the reader, EPA has included in

Chapter 12 a glossary of commonly used acronyms and definitions of terms used throughout the

document.
i

TABLE OF CONTENTS

Page

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

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

1.2 Scope and Definition of the Industrial Laundries Industry ..... 1-1

1.3 Overview of the Industrial Laundries Industry .............. 1-2

1.4 Final Action for the Industrial Laundries Point Source 

Category ......................................... 1-3

CHAPTER 2 BACKGROUND ....................................... 2-1

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

2.2 Legal Authority .................................... 2-1

2.3 Background ....................................... 2-1

2.3.1 Clean Water Act (CWA) ............................. 2-1

2.3.2 Pollution Prevention Act (PPA) .................. 2-4

2.3.3 Regulatory Flexibility Act (RFA) as Amended by the 

Small Business Regulatory Enforcement Fairness Act 

of 1996 (SBREFA) ........................... 2-4

2.3.4 Prior Regulation of the Industrial Laundries Point Source

Category ................................... 2-5

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

3.2.6 Industrial Technology Division (ITD)/Resource

Conservation and Recovery Act (RCRA) Sampling Program

and Development of the Preliminary Data Summary (1985

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

3.3 Summary of Industrial Laundries Questionnaire Activity 

After 1992 ........................................ 3-5

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

3.3.2 1994 Industrial Laundries Industry Questionnaire (Detailed

Questionnaire) ............................... 3-8
TABLE OF CONTENTS (Continued)

Page

ii

3.3.3 Detailed Monitoring Questionnaire ............... 3-11

3.4 Summary of EPA’s Site Visit Program (1993-1998) ........ 3-12

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

3.4.2 Types of Information Collected ................. 3-13

3.5 Summary of EPA’s Sampling Program (1993-1998) ........ 3-13

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

3.5.2 Information Collected ........................ 3-14

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

3.6 Summary of EPA’s Method 1664 Characterization Study .... 3-16

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

3.7.1 Data Submitted Prior to 1992 .................. 3-16

3.7.2 Trade Associations Solicitation of Data ........... 3-17

3.7.3 Data Included with Comments on the Proposed Rulemaking

and Notice of Data Availability ................. 3-18

3.7.4 Request for Substantiation of Claims Made in 

Comments ................................. 3-18

3.7.5 The Trade Associations Split-Sampling Efforts ..... 3-19

3.8 POTW Data ...................................... 3-19

3.8.1 AMSA Questionnaire ......................... 3-19

3.8.2 Data Submittals Related to POTWs with Comments 

on the Proposed Rulemaking and Notice of Data 

Availability ................................. 3-20

3.9 Summary of Literature Searches ....................... 3-21

3.10 Summary of Other Data Sources ...................... 3-22

3.10.1 Risk Reduction Engineering Laboratory Treatability

Database .................................. 3-22

3.10.2 Fate of Priority Pollutants in Publicly Owned Treatment

Works Database ............................. 3-23

3.10.3 The Domestic Sewage Study ................... 3-23

3.10.4 Canadian Studies ............................ 3-23

3.10.5 Industrial Pollution Prevention Project ............ 3-24

3.11 References ....................................... 3-25

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

4.1 Introduction ............................................ 4-1

4.2 Overview of the Industry ............................. 4-2

4.2.1 Geographic Distribution of Facilities .............. 4-2

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

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

4.2.4 Items Laundered ............................. 4-7

4.2.5 Customers .................................. 4-7
TABLE OF CONTENTS (Continued)

Page

iii

4.3 Laundering Processes ............................... 4-12

4.3.1 Water-Using/Wastewater-Generating Processes ..... 4-12

4.3.2 Processes with Minimal Wastewater Discharge ..... 4-14

4.3.3 Chemicals Used in Industrial Laundries ........... 4-16

4.4 Facilities and Equipment ............................. 4-16

4.4.1 Washers, Extractors, and Washer-Extractors ....... 4-20

4.4.2 Tunnel Washers ............................. 4-20

4.4.3 Dry-Cleaning Units .......................... 4-20

4.4.4 Equipment Use and Age ....................... 4-21

4.5 Pollution Reduction Activities ........................ 4-21

4.6 Trends in the Industry ............................... 4-26

4.6.1 Trend Away From Drycleaning ................. 4-26

4.6.2 Trend of Small Facilities Being Purchased by Larger

Firms ..................................... 4-26

4.6.3 Trends in Equipment and Technologies ........... 4-27

4.7 Treatment Technologies in Use ........................ 4-27

4.8 Industry Definition ................................. 4-27

4.9 References ....................................... 4-32

CHAPTER 5 WATER USE, WASTEWATER CHARACTERIZATION ,AND

POLLUTANTS OF CONCERN, ........................... 5-1

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

5.2 Sources of Service Water and Water Use ................. 5-2

5.2.1 Sources of Service Water at Industrial Laundries ..... 5-2

5.2.2 Use of Service Water at Industrial Laundries ........ 5-2

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

5.4 Water Conservation Measures ........................ 5-10

5.5 Pollutants Analyzed in Industrial Laundry Wastewater ...... 5-10

5.6 Identification of Pollutants of Concern .................. 5-15

5.7 Characterization of Raw Wastewater by Item Laundered .... 5-27

5.8 Characterization of Total, Heavy, and Light Raw Wastewater

Streams ......................................... 5-27

5.9 Characterization of Method 1664 Constituents ............ 5-27

5.10 References ....................................... 5-42
TABLE OF CONTENTS (Continued)

Page

iv

CHAPTER 6 POLLUTION PREVENTION, RECYCLING, TREATMENT, AND

DISPOSAL TECHNOLOGIES EMPLOYED BY THE INDUSTRIAL

LAUNDRIES INDUSTRY ................................ 6-1

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

6.2 The Environmental Management Hierarchy ............... 6-1

6.3 Pollution Prevention/Source Reduction in the Industrial Laundries

Industry .......................................... 6-3

6.3.1 Preprocess Pollution Prevention Activities .......... 6-4

6.3.2 In-Process Pollution Prevention Activities .......... 6-8

6.4 Waste Recycling/Resource Conservation and the Industrial

Laundries Regulatory Development Process .............. 6-12

6.4.1 Water Conservation in the Industrial Laundries 

Industry ................................... 6-12

6.4.2 Energy Conservation in the Industrial Laundries 

Industry ................................... 6-13

6.4.3 Dry Cleaning of Solvent Laden Items Prior to Water

Washing ................................... 6-13

6.4.4 Steam/Air Tumbling of Solvent Laden Items Prior to 

Water Washing ............................. 6-13

6.4.5 Centrifuging of Solvent Laden Items Prior to Water

Washing ................................... 6-17

6.4.6 Pressing Solvent Laden Items Prior to Water 

Washing ................................... 6-18

6.5 Wastewater Treatment Technologies in the Industrial Laundries

Industry ......................................... 6-18

6.5.1 Gravity Settling ............................. 6-19

6.5.2 Stream Splitting ............................. 6-19

6.5.3 Screening .................................. 6-21

6.5.4 Equalization ................................ 6-24

6.5.5 Chemical Emulsion Breaking ................... 6-25

6.5.6 Chemical Precipitation ........................ 6-27

6.5.7 Dissolved Air Flotation (DAF) .................. 6-32

6.5.8 Sludge Dewatering ........................... 6-33

6.5.9 pH Adjustment .............................. 6-39

6.5.10 Ultrafiltration/Microfiltration ................... 6-39

6.5.11 Centrifugation .............................. 6-40

6.5.12 Oil/Water Separation ......................... 6-41

6.5.13 Media Filtration ............................. 6-42

6.5.14 Carbon Adsorption .......................... 6-42

6.5.15 Air Stripping ............................... 6-43
TABLE OF CONTENTS (Continued)

Page

v

6.5.16 Wastewater Treatment Technologies Used by the 

Industrial Laundries Industry in 1998 ............. 6-45

6.6 Pollution Disposal Practices in the Industrial Laundries 

Industry ......................................... 6-45

6.6.1 Wastewater Disposal ......................... 6-45

6.6.2 Waste Organic Material Disposal ................ 6-47

6.6.3 Sludge Disposal ............................. 6-47

6.7 References ....................................... 6-48

CHAPTER 7 TREATMENT PERFORMANCE DATA USED FOR THE

DEVELOPMENT OF CANDIDATE PRETREATMENT

STANDARDS .......................................... 7-1

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

7.2 Sources of Treatment Technology Performance Data From WellDesigned and Well-Operated Treatment Systems ........... 7-1

7.2.1 Industrial Laundry Sampling Program Data ......... 7-2

7.2.2 Detailed Monitoring Questionnaire (DMQ) Data ..... 7-4

7.2.3 Other Industry-Supplied Data ................... 7-5

7.3 Evaluation of Treatment Performance Data ............... 7-5

7.3.1 Assessment of Treatment System Performance and

Identification of Process Upsets .................. 7-6

7.3.2 Identification of Pollutants Not Treated by the Treatment

Technology ................................. 7-6

7.3.3 Identification of Pollutants Not Present in Influent Samples

at Sufficient Concentrations to Evaluate Treatment

Effectiveness ................................ 7-7

7.3.4 Identification of Treatment Performance Data With

Inconsistent Detection Limits .................... 7-7

7.3.5 Identification of Treatment Performance Data Considered a

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

7.4 Calculation of Long-Term Average Concentrations for the

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

7.5 Methodology for Determining Pollutants of Concern Selected for

Candidate Pretreatment Standards Development ............ 7-8

7.5.1 Elimination of Treatment Chemicals .............. 7-12

7.5.2 Elimination of Pollutants Not Treated or Below Treatable

Concentrations .............................. 7-12

7.5.3 Elimination of Pollutants that Do Not Pass Through or

Otherwise Interfere with Publicly Owned Treatment Works

(POTWs) .................................. 7-12
TABLE OF CONTENTS (Continued)

Page

vi

7.5.4 Pollutants of Concern Selected for Candidate Pretreatment

Standards Development ....................... 7-33

7.6 Long-Term Average and Variability Factors for the Five

Technology Options ................................ 7-36

7.7 Mass-Based Standards .............................. 7-38

7.8 References ....................................... 7-46

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

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

8.2 Initial Technology Control Options Considered ............ 8-1

8.2.1 Postlaundering Wastewater Treatment Technology Control

Options .................................... 8-2

8.2.2 Prelaundering Organics Control (OC-Only) Technology

Control Option .............................. 8-5

8.3 Inclusion of Pollution Prevention in the Technology Control Options 8-12

8.4 Exclusion of Wastewater Recycling Activities from the Technology

Control Options ................................... 8-13

8.5 Subcategorization Analysis ........................... 8-13

8.5.1 Disproportionate Economic Impacts ............. 8-14

8.5.2 Laundry Processes and Water Use Practices ........ 8-14

8.5.3 Plant Age .................................. 8-15

8.5.4 Plant Location .............................. 8-15

8.5.5 Plant Size .................................. 8-15

8.5.6 Raw Materials .............................. 8-16

8.5.7 Non-Water Quality Environmental Impacts ........ 8-16

8.5.8 Type of Item Laundered and Wastewater 

Characteristics .............................. 8-16

8.6 Initial Technology Control Options Not Further Considered . . 8-17

8.7 Additional Technology Control Options Considered ........ 8-18

8.7.1 Industrial Laundry Wastewater (IL) Technology Control

Options ................................... 8-18

8.7.2 Towel (TWL) Technology Control Options ........ 8-18

8.7.3 Combination (Combo) Technology Control Options . 8-19

8.7.4 Towel Only Technology Control Option .......... 8-21

8.7.5 No Regulation Option ........................ 8-22

8.8 Technology Control Options Eliminated from Further Consideration 8-22

8.9 Regulatory Control Options Considered for the Final Action . 8-23

8.10 References ....................................... 8-23
TABLE OF CONTENTS (Continued)

Page

vii

CHAPTER 9 POLLUTANT LOADING AND REMOVAL ESTIMATES ..... 9-1

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

9.2 Data Sources ...................................... 9-2

9.3 Methodology Used to Estimate Pollutant Loadings and 

Removals ......................................... 9-3

9.3.1 Methodology Used to Estimate Industry Untreated

Pollutant Loadings ............................ 9-4

9.3.2 Methodology Used to Estimate Industry Baseline

Wastewater Loadings .......................... 9-7

9.3.3 Methodology Used to Estimate Industry Postcompliance

Wastewater Loadings ......................... 9-13

9.3.4 Methodology Used to Estimate POTW Baseline and

Postcompliance Wastewater Loadings ............ 9-18

9.3.5 Methodology Used to Estimate Industry and POTW

Pollutant Removals .......................... 9-18

9.4 Pollutant Loadings and Removals ...................... 9-22

9.5 Pollutant Loadings and Removals Estimated from 1998 Facility

Treatment-In-Place Data ............................ 9-23

9.6 References ....................................... 9-25

CHAPTER 10 NON-WATER QUALITY ENVIRONMENTAL IMPACTS .... 10-1

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

10.2 Non-Water Quality Environmental Impacts of the CP-IL and DAFIL Options Considered as the Bases for PSES and PSNS .... 10-1

10.2.1 Energy Consumption Impacts .................. 10-2

10.2.2 Air Emissions Impacts ........................ 10-4

10.2.3 Solid Waste Impacts ......................... 10-8

10.2.4 Non-Water Quality Environmental Impacts of the

Regulatory Options Considered for PSNS ......... 10-8

10.3 References ...................................... 10-10

CHAPTER 11 COSTS OF TECHNOLOGY BASES FOR REGULATORY

OPTIONS ............................................ 11-1

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

11.2 Costing Methodology ............................... 11-3

11.2.1 Cost Model Development and Structure ........... 11-4

11.2.2 Components of the Cost of Compliance ........... 11-5

11.2.3 Treatment-in-Place Credit Methodology ......... 11-10

11.2.4 Optimization Cost Allowance .................. 11-15
TABLE OF CONTENTS (Continued)

Page

viii

11.3 Cost Modeling ................................... 11-16

11.3.1 Cost Model Driver .......................... 11-16

11.3.2 Stream Splitting ............................ 11-17

11.3.3 Pumps ................................... 11-18

11.3.4 Screening ................................. 11-19

11.3.5 Equalization ............................... 11-20

11.3.6 Dissolved Air Flotation ...................... 11-21

11.3.7 Chemical Precipitation ....................... 11-23

11.3.8 Sludge Dewatering .......................... 11-26

11.3.9 pH Adjustment ............................. 11-27

11.3.10 Treatment System Building ................... 11-28

11.3.11 Contract Haul In Lieu of Treatment On Site ....... 11-29

11.3.12 Compliance Monitoring ...................... 11-30

11.4 Engineering Costs for the Regulatory Options ........... 11-31

11.5 Compliance Costs Estimated from 1998 Facility Treatment-In-Place

Data ........................................... 11-31

11.6 References ...................................... 11-36

CHAPTER 12 GLOSSARY OF TERMS ................................ 12-1

Appendix A - Tables Referenced in Chapter 3

Appendix B - Tables Referenced in Chapter 4

Appendix C - Tables Referenced in Chapter 5

Appendix D - Tables Referenced in Chapter 7

Appendix E - Tables Referenced In Chapter 9
ix

LIST OF TABLES

Page

4-1 Geographic Distribution of Industrial Laundries by EPA Region 

and State .............................................. 4-4

4-2 Industrial Laundry Size Distribution ......................... 4-6

4-3 Types of Items Laundered ................................. 4-8

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

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

4-6 Industrial Laundering Wash Formula Chemicals Reported in the 

Detailed Questionnaire ................................... 4-17

4-7 Amounts of Detergent Added Per 1,000 Pounds of Laundry for Items

Most Often Laundered ................................... 4-18

4-8 Age of Facilities and Startup of Laundry/Dry-Cleaning Operations

(Estimated Percentage of Total Facilities in Each Time Period) ..... 4-19

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

Questionnaire .......................................... 4-22

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

Questionnaire (Percentage of Equipment Type Installed in Each Time

Period) ............................................... 4-23

4-11 Preprocess Pollution Reduction Activities ..................... 4-24

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

4-13 Comparison of Linen Facility and Industrial Laundry Facility Mean

Pollutant Log Concentrations .............................. 4-29

4-14 Comparison of Linen Facility and Denim Prewash Facility Mean 

Pollutant Log Concentrations .............................. 4-30

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

5-2 Service Water Use ....................................... 5-4
LIST OF TABLES (Continued)

Page

x

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

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

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

5-6 Pollutants Not Detected in Any Samples Analyzed during the 

1993-1996 Industrial Laundries Sampling Program .............. 5-16

5-7 Pollutants Detected in Less Than 10 Percent of Samples Analyzed 

During the 1993-1996 Industrial Laundries Sampling Program ..... 5-19

5-8 Semiquantitative Metal and Elemental Pollutants Excluded from the

Pollutants of Concern for the Industrial Laundries Industry ........ 5-20

5-9 Average Influent Concentrations, Effluent Concentrations, and 

Removals for Phosphorous and Surfactants by Chemical Precipitation 

or Dissolved Air Flotation Technologies ...................... 5-22

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

5-11 Wastewater Characterization for Item-Specific Wastewater at 

Industrial Laundries ..................................... 5-28

5-12 Wastewater Characterization Data for Heavy Wastewater Streams at

Industrial Laundries ..................................... 5-33

5-13 Wastewater Characterization Data for Light Wastewater Streams at

Industrial Laundries ..................................... 5-36

5-14 Wastewater Characterization Data for Total Raw Wastewater Streams 

at Industrial Laundries ................................... 5-39

5-15 Summary of the Semivolatile Organic Pollutants Detected in Influent

Samples during the EPA Method 1664 Characterization Study ..... 5-43

5-16 Summary of the Semivolatile Organic Pollutants Detected in Effluent

Samples during the EPA Method 1664 Characterization Study ..... 5-45

6-1 Number of Industrial Laundries, by Production Category, Reporting

Preprocess Pollution Prevention Activities in the Detailed Questionnaire

for the 1993 Operating Year ................................ 6-5
LIST OF TABLES (Continued)

Page

xi

6-2 Types of Preprocess Pollution Prevention Activities Reported in the

Detailed Questionnaire for the 1993 Operating Year .............. 6-6

6-3 Number of Industrial Laundries, by Production Category, Reporting InProcess Pollution Prevention Activities in the Detailed Questionnaire for

the 1993 Operating Year .................................. 6-9

6-4 Types of In-Process Pollution Prevention Activities Reported in the

Detailed Questionnaire for the 1993 Operating Year ............. 6-10

6-5 Steam Stripping Performance Data Collected from a Sampled 

Facility Processing Printer Towels in a Steam Tumbler Prior to 

Water Washing ......................................... 6-15

6-6 Number of In-Scope Facilities Responding to Detailed 

Questionnaire Using Wastewater Treatment Technologies in the 

1993 Operating Year .................................... 6-20

6-7 Comparison Between Treatment Technologies Reported in 1993 

and 1998 ............................................. 6-46

7-1 Long-Term Average (LTA) Effluent Concentrations for the Five

Treatment Options for the Pollutants of Concern ................ 7-9

7-2 Selected Pollutants of Concern for Treatment Options Considered in

Developing Long-Term Averages and Variability Factors ......... 7-13

7-3 Pollutants Eliminated from Further Consideration From the 

Pass-Through Analysis Because They Are Not Treated or They Are 

Below Treatable Concentrations ............................ 7-14

7-4 Comparison of the Chemical Precipitation Treatment Technology 

and POTW Percent Removals for the Industrial Laundries Pass-Through 

Analysis .............................................. 7-18

7-5 Comparison of the DAF Treatment Technology and POTW Percent

Removals for the Industrial Laundries Pass-Through Analysis ...... 7-21

7-6 Generic Removal for n-Alkanes ............................ 7-26

7-7 POTW Pollutant Removals Based on a Revised POTW Removal

Efficiency for Nonvolatile n-Alkanes (Entire Industry - No Cutoff) . . 7-28
LIST OF TABLES (Continued)

Page

xii

7-8 EPA and PhRMA Sampling Results for Primary Treatment at 

Barceloneta POTW Data from Method 1671 .................. 7-30

7-9 WATER8 Modeling Results for Primary and Secondary Treatment at

Barceloneta Wastewater Treatment Plant ..................... 7-31

7-10 Percent Biodegradation for Industrial Laundries Pollutants of Concern

Found to Be Volatile .................................... 7-32

7-11 Pollutants Considered for Regulation for Chemical Precipitation and 

DAF after the Pass-Through Analysis ........................ 7-34

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

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

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

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

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

8-1 Technology Control Options Initially Considered for the Industrial

Laundries Proposed Rule .................................. 8-3

8-2 Definitions of Additional Technology Control Options Considered

for PSES and PSNS ..................................... 8-20

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

Laundry) .............................................. 9-5

9-2 Analytical Data Transfers .................................. 9-6

9-3 Treatment-In-Place Scenarios for Model Facilities ............... 9-8

9-4 Overall Target Average Concentrations for the Seven Technology 

Control Options for the Pollutants of Concern Used as the Bases 

for Calculation of Baseline Pollutant Loadings ................. 9-10

9-5 Methodology Used to Estimate Baseline Loadings for the Industrial

Laundries Industry ...................................... 9-14
LIST OF TABLES (Continued)

Page

xiii

9-6 Methodology Used to Estimate Postcompliance Loadings for the 

DAF-IL Regulatory Option for the Industrial Laundries Industry ... 9-16

9-7 Methodology Used to Estimate Postcompliance Loadings for the 

CP-IL Regulatory Option for the Industrial Laundries Industry ..... 9-17

9-8 POTW Pollutant Removal Efficiencies for the Pollutants of 

Concern .............................................. 9-19

9-9 Summary of Baseline Pollutant Loadings, Postcompliance Pollutant 

Loadings, and POTW Pollutant Removals from Industrial Laundries

Wastewater for CP-IL Entire Industry ....................... 9-26

9-10 Summary of Baseline Pollutant Loadings, Postcompliance Pollutant 

Loadings, and POTW Pollutant Removals from Industrial Laundries

Wastewater for DAF-IL Entire Industry ...................... 9-27

9-11 Summary of Baseline Pollutant Loadings, Postcompliance Pollutant 

Loadings, and POTW Pollutant Removals from Industrial Laundries

Wastewater for CP-IL Excluding Facilities with Less than 1 Million

Pounds per Year Total Production and Less than 255,000 Pounds per 

Year Shop and Printer Towel Production ..................... 9-28

9-12 Summary of Baseline Pollutant Loadings, Postcompliance Pollutant 

Loadings, and POTW Pollutant Removals from Industrial Laundries

Wastewater for DAF-IL Excluding Facilities with Less than 1 Million

Pounds per Year Total Production and Less than 255,000 Pounds per 

Year Shop and Printer Towel Production ..................... 9-29

9-13 Summary of Baseline Pollutant Loadings, Postcompliance Pollutant

Loadings, and POTW Pollutant Removals from Industrial Laundries

Wastewater for CP-IL Excluding Facilities with Less than 3 Million

Pounds per Year Total Production and Less than 120,000 Pounds per 

Year Shop and Printer Towel Production ..................... 9-30

9-14 Summary of Baseline Pollutant Loadings, Postcompliance Pollutant 

Loadings, and POTW Pollutant Removals from Industrial Laundries

Wastewater for DAF-IL Excluding Facilities with Less than 3 Million

Pounds per Year Total Production and Less than 120,000 Pounds per 

Year Shop and Printer Towel Production ..................... 9-31
LIST OF TABLES (Continued)

Page

xiv

9-15 Summary of Baseline Pollutant Loadings, Postcompliance Pollutant 

Loadings, and POTW Pollutant Removals from Industrial Laundries

Wastewater for CP-IL Excluding Facilities with Less than 5 Million

Pounds per Year Total Production and Less than 255,000 Pounds per 

Year Shop and Printer Towel Production ..................... 9-32

9-16 Summary of Baseline Pollutant Loadings, Postcompliance Pollutant 

Loadings, and POTW Pollutant Removals from Industrial Laundries

Wastewater for DAF-IL Excluding Facilities with Less than 5 Million

Pounds per Year Total Production and Less than 255,000 Pounds per 

Year Shop and Printer Towel Production ..................... 9-33

9-17 POTW Pollutant Removal Comparison Between the Removals Estimated

at Proposal and Removals Incorporating UTSA/TRSA Survey Data for the

CP-IL and DAF-IL Regulatory Options Excluding Facilities with 

Less than 1 Million Pounds per Year Total Production and Less than 

255,000 Pounds per Year Shop and Printer Towel/Rag Production . 9-34

9-18 Industry Pollutant Removal Comparison Between the Removals Estimated

at Proposal and Removals Incorporating UTSA/TRSA 

Survey Data for the CP-IL and DAF-IL Regulatory Options 

Excluding Facilities with Less than 1 Million Pounds per Year Total 

Production and Less than 255,000 Pounds per Year Shop and Printer 

Towel/Rag Production ................................... 9-36

10-1 Incremental Energy Consumption Increases Associated With

Implementation of the CP-IL and DAF-IL Regulatory Options .... 10-3

10-2 Fugitive Air Emissions of Organic Pollutants From Industrial Laundry

Wastewater—Analysis of a Worst-Case Scenario ............... 10-6

10-3 Incremental Sludge Generation Increases Associated With Implementation

of the CP-IL and DAF-IL Regulatory Options ................. 10-9

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

11-2 Components of Total Capital Investment ..................... 11-9

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

11-4 Components of Total Capital Investment Estimated for DAF Facilities 

in the CP-IL Regulatory Option ........................... 11-14
LIST OF TABLES (Continued)

Page

xv

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

11-6 Summary of Annualized Engineering Costs for the Regulatory 

Options ............................................. 11-33

11-7 Capital and Annual O&M Compliance Cost Comparison Between the

Costs Estimated at Proposal and Costs Incorporating UTSA/TRSA 

Survey Data for the DAF-IL and CP-IL Regulatory Options Excluding 

Facilities with Less than 1 Million Pounds per Year Total Production and 

Less than 255,000 Pounds per Year Shop and Printer Towel/Rag 

Production ........................................... 11-35
xvi

LIST OF FIGURES

Page

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

5-1 Distribution of Facilities by Production Normalized Laundry Process 

Water Use ............................................. 5-6

5-2 Distribution of Facilities by Production Normalized Laundry Process 

Water Discharge ........................................ 5-11

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

6-2 Shaker Screen ......................................... 6-23

6-3 Batch Chemical Emulsion Breaking Unit ..................... 6-26

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

6-5 Batch Chemical Precipitation System ........................ 6-30

6-6 Continuous Chemical Precipitation System .................... 6-31

6-7 Dissolved Air Flotation Unit ............................... 6-34

6-8 Rotary Vacuum Filter .................................... 6-36

6-9 Filter Press ............................................ 6-37

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

8-1 CEB-Heavy Option: Chemical Emulsion Breaking of Heavy 

Industrial Laundry Wastewater .............................. 8-6

8-2 DAF-Heavy, DAF-IL, and DAF-TWL Options: Dissolved Air 

Flotation of a Portion of a Facility's Process Wastewater .......... 8-7

8-3 CP-Heavy, CP-IL, and CP-TWL Options: Chemical Precipitation 

of a Portion of a Facility's Process Wastewater .................. 8-8

8-4 DAF-All Option: Dissolved Air Flotation of Total Facility Process 

Wastewater ............................................ 8-9
LIST OF FIGURES (Continued)

Page

xvii

8-5 CP-All Option: Chemical Precipitation of Total Facility Process 

Wastewater ........................................... 8-10

8-6 OC-Only Option: In-Process Organics Control ................ 8-11
Chapter 1 - Summary

1-1

CHAPTER 1

SUMMARY

1.1 Introduction

This chapter presents a summary of the U.S. Environmental Protection Agency’s

(EPA’s) decisions regarding effluent limitations guidelines and standards for the Industrial

Laundries Point Source Category. Section 1.2 presents the scope and definition of the industry;

Section 1.3 presents a brief overview of the industry; and Section 1.4 discusses EPA’s final

action.

1.2 Scope and Definition of the Industrial Laundries Industry

EPA has developed the following definition of industrial laundries: 

An industrial laundry is any facility that launders industrial textile items

from off site as a business activity (i.e., launders industrial textile items for

other business entities for a fee or through a cooperative arrangement). 

Either the industrial laundry facility or the off-site customer may own the

industrial textile items. This definition includes textile rental companies

that perform laundering operations. Laundering means washing with

water, including water washing following dry cleaning. Laundering

exclusively through dry cleaning and oil cleaning of mops in a process that

does not use any water are not included in this definition of laundering. 

Industrial textile items include, but are not limited to: industrial shop

towels, printer towels/rags, furniture towels, rags, uniforms, mops, mats,

rugs, tool covers, fender covers, dust-control items, gloves, buffing pads,

absorbents, and filters. If any of these items are used at hotels, hospitals,

or restaurants, they are not considered industrial textile items.

A facility that performs any laundering of industrial textile items is classified as an

industrial laundry, even if the facility also performs activities that are not defined as industrial

laundering. EPA does not include the following activities within the scope of the industrial

laundries industry: on-site laundering at industrial facilities (e.g., a chemical manufacturer that

washes employee uniforms on site), laundering of industrial textile items originating from the

same business entity (e.g., a chain of auto repair shops that operates a central laundry for items

from individual shops), and exclusively laundering linen items, denim prewash items, clean room

items, new items (i.e., items directly from the textile manufacturer, not yet used for their intended

purpose), hotel, hospital, or restaurant items, or any combination of these items. However, EPA

does consider hotels, hospitals, and restaurants to be within the scope of the industrial laundries

industry if they launder industrial textile items originating from industrial facilities. Linen items

include sheets, pillowcases, blankets, bath towels and washcloths, hospital gowns and robes,
Chapter 1 - Summary

1-2

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

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

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

1.3 Overview of the Industrial Laundries Industry

The industrial laundries industry includes facilities that launder industrial garments

and uniforms, shop towels, printer towels/rags, mops, mats, and dust-control items. Either the

laundry facilities or their customers own the laundered items. Many industrial laundries also wash

other items not classified as industrial laundry items, such as linen garments, linen flatwork,

health-care items, and miscellaneous other items.

Industrial laundries are located in all 50 states and all 10 EPA Regions. By state,

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

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

urban areas. EPA estimates that there are 1,742 industrial laundry facilities nationwide.

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

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

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

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

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

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

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

Facilities wash most items using a water-washing process. Water washing involves

washing items in water with detergents and other chemicals. Some facilities wash items using a

dry-cleaning process, which involves washing items in an organic solvent. In some cases, facilities

combine the two processes to wash items that have large amounts of both water-soluble and

organic solvent-soluble soils. Dry cleaning followed by water washing of industrial textile items is

considered an industrial laundry process. When water washing and dry cleaning are performed in

series without drying the items between the water and solvent phases, the process is called dualphase washing. The order in which these processes are performed depends on the solvent used,

type of soil, and drying energy requirements. Some mops are laundered through a combination of

water washing and oil treatment. The oil is applied to the mop to help collect dust during use. 

Both dual-phase washing of industrial textile items and water-washing/oil treatment of mops are

considered industrial laundry processes.

Nationwide, industrial laundry facilities water-wash nearly 97 percent of their

items. Approximately one percent of items are dry-cleaned, including items that are dry-cleaned

and then water-washed. Dual-phase washing and mop cleaning with water and oil each accounts

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

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

water). Chemicals frequently used in laundering operations include alkaline solutions, detergents,

bleach, antichlor, sours, softeners, and starch. Other items that are added to some 
Chapter 1 - Summary

SGT-HEM is measured by Method 1664 (promulgated at 64 FR 26315; May 14, 1999). In this method, EPA 1

defines SGT-HEM as non-polar material (NPM). Throughout this document and the Industrial Laundries

Administrative Record, EPA refers to SGT-HEM as TPH.

1-3

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

treatment chemicals, and bactericides.

Based on data collected by EPA for the 1993 operating year, industrial laundries

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

descending amounts by sanitary water, noncontact cooling water, and boiler water. All of the

industrial laundries identified by EPA discharge their process wastewater to publicly owned

treatment works (POTWs). The primary pollutants discharged by industrial laundries to POTWs

include oil and grease, five-day biochemical oxygen demand (BOD ), and total suspended solids 5

(TSS), which are conventional pollutants, and a number of priority and nonconventional

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

(TPH), measured as silica gel treated-hexane extractable material (SGT-HEM) . 

1

1.4 Final Action for the Industrial Laundries Point Source Category

EPA carefully considered all of the information in the Industrial Laundries

Administrative Record, and has decided not to promulgate national categorical pretreatment

standards for the Industrial Laundries Point Source Category because industrial laundry

discharges to POTWs do not present a national problem warranting national regulation. EPA has

determined that indirect discharges from industrial laundries do not warrant national regulation

because of the small amount of pollutants removed by the pretreatment options determined to be

economically achievable and because EPA believes that POTWs are generally not experiencing

problems from industrial laundry discharges, and to the extent that isolated problem discharges

occur, they will be controlled by the existing pretreatment program. EPA is not issuing effluent

limitations guidelines or new source performance standards for direct dischargers because there

are no direct discharging facilities in the industry and, therefore, EPA has no means to evaluate

performance and develop guidelines.

Although EPA has decided not to promulgate national pretreatment standards,

EPA evaluated technology performance data that can be used by control authorities to develop

local limits on a best professional judgement (BPJ) basis. These data can be found in Chapter 7 of

this document.
Chapter 2 - Background

2-1

2.0 BACKGROUND

2.1 Introduction

This chapter presents background information supporting the development of

effluent limitations guidelines and pretreatment standards for the Industrial Laundries Point

Source Category. Section 2.2 presents the legal authority to regulate the industrial laundries

industry. Section 2.3 discusses the Clean Water Act, the Pollution Prevention Act, and the

Regulatory Flexibility Act as amended by the Small Business Regulatory Enforcement Fairness

Act, as well as prior regulation of the industrial laundries industry. 

2.2 Legal Authority

This final action for the Industrial Laundries Point Source Category is being

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

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

amended), also referred to as “the CWA” or “the Act.”

2.3 Background

2.3.1 Clean Water Act (CWA)

The Clean Water Act (CWA) established a comprehensive program to “restore and

maintain the chemical, physical, and biological integrity of the Nation’s waters” (section 101(a)). 

To implement the Act, EPA is to issue effluent limitations guidelines, pretreatment standards, and

new source performance standards for industrial dischargers.

These guidelines and standards are summarized briefly below:

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

304(b)(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

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 
Chapter 2 - Background

2-2

uniformly inadequate, BPT may be transferred from a different 

subcategory or category.

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

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

In general, BAT effluent limitations represent the best existing

economically achievable performance of plants in the industrial subcategory

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

controlling the direct discharge of priority pollutants and nonconventional

pollutants to navigable waters. The factors considered in assessing BAT

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

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

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

considerable discretion in assigning the weight to be accorded these

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

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

may include process changes or internal controls, even when these

technologies are not common industry practice.

3. Best Conventional Pollutant Control Technology (BCT) (section

301(b)(2)(e) 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

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,
Chapter 2 - Background

2-3

NSPS should represent the most stringent numerical values attainable through the application of

the best available demonstrated control technology for all pollutants (i.e., conventional,

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

consideration the cost of achieving the effluent reduction and any non-water quality environmental

impacts and energy requirements.

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

Act).

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

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

owned treatment works (POTWs). The Act requires pretreatment

standards for pollutants that pass through POTWs or interfere with

POTWs’ treatment processes or sludge disposal methods. The legislative

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

technology-based and analogous to the BAT effluent limitations guidelines

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

promulgate national category-wide pretreatment standards, EPA generally

determines that there is pass through of a pollutant if the nationwide

average percent of a pollutant removed by well-operated POTWs achieving

secondary treatment is less than the percent removed by the BAT model

treatment system. EPA retains discretion not to issue such standards

where the total amount of pollutants passing through is not significant.

The General Pretreatment Regulations, which set forth the framework for

the implementation of categorical pretreatment standards, are found at 40

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

addresses localized rather than national instances of pass through and does

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

January 14, 1987).

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

Act).

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

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

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

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

opportunity to incorporate into their plants the best available demonstrated

technologies. The Agency considers the same factors in promulgating

PSNS as it considers in promulgating NSPS. EPA retains discretion not to

issue such standards where the total amount of pollutants passing through

is not significant.
Chapter 2 - Background

2-4

2.3.2 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;

where the generation of waste materials cannot be prevented, the waste materials should be

recycled or reused in an environmentally safe manner wherever feasible; waste materials that

cannot be recycled should be treated; and disposal or release into the environment should be

chosen only as a last resort. The PPA directs the Agency to, among other things, “review

regulations of the Agency prior and subsequent to their proposal to determine their effect on

source reduction” (Sec. 6604; 42 U.S.C. 13103(b)(2)). EPA considered pollution prevention

during the development of this final action. Chapter 6 of this document describes the results of

this effort.

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

Regulatory Enforcement Fairness Act of 1996 (SBREFA)

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

the Small Business Regulatory Enforcement Fairness Act (SBREFA), EPA generally is required

to conduct a regulatory flexibility analysis describing the impact of the regulatory action on small

entities as part of rulemaking. EPA conducted an initial regulatory flexibility analysis (IRFA) for

the proposal (62 FR 66181; December 17, 1997) for the industrial laundries industry. However,

under section 605(b) of the RFA, if EPA certifies that a rule will not have a significant economic

impact on a substantial number of small entities, EPA is not required to prepare a regulatory

flexibility analysis. Because the Administrator has decided not to promulgate pretreatment

standards for this industry, EPA did not prepare a final regulatory flexibility analysis because the

requirement in section 604 of the RFA to prepare a regulatory flexibility analysis when an agency

promulgates a final rule does not apply to this action.

However, as part of EPA’s decision not to promulgate pretreatment standards for

this industry, EPA conducted an analysis equivalent to a regulatory flexibility analysis addressing:

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

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

entities to which a rule would apply.

C The projected reporting, recordkeeping, and other compliance

requirements of a rule, including an estimate of the classes of small entities

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

for preparation of the report or record.

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

duplicate, overlap, or conflict with a rule.
Chapter 2 - Background

2-5

C A description of any significant regulatory alternatives to a rule which

accomplish the stated objectives of applicable statutes and which minimize

any significant economic impact of a rule on small entities. Consistent with

the stated objectives of the CWA, the analysis discussed significant

alternatives such as:

– Establishing differing compliance or reporting requirements or

timetables that take into account the resources available to small

entities.

– Clarification, consolidation, or simplification of compliance and

reporting requirements under the rule for such small entities.

– The use of performance rather than design standards.

– An exclusion from coverage of a rule, or any part thereof, for such

small entities. Based on the regulatory flexibility analysis and other

factors, EPA considered an exclusion to eliminate disproportionate

impacts on small businesses which reduced the number of small

businesses that would be affected by a rule.

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

Advocacy Review Panel. The Panel comprised representatives from three federal agencies: EPA,

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

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

recommendations of small entity representatives. Small entity representatives included owners of

small industrial laundries and trade association representatives. The Panel prepared a report

(available in the Industrial Laundries Administrative Record) that summarizes their outreach to

small entities and the comments submitted by the small entity representatives. The Panel’s report

also presented their findings on issues related to the elements of the IRFA.

2.3.4 Prior Regulation of the Industrial Laundries Point Source Category

The Federal Water Pollution Control Act Amendments of 1972 established a

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

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

dischargers by industry categories and a timetable for issuing these guidelines. Pursuant to a 1976

settlement agreement and the 1977 Clean Water Act Amendments, EPA was required to develop

a program and adhere to a schedule in promulgating effluent limitations guidelines and

pretreatment standards for 65 “toxic” pollutants and classes of pollutants, for 21 major industries. 

Moreover, the Agency is required by section 301 (d) of the Federal Water Pollution Control Act

Amendments of 1972 and the Clean Water Act of 1977 to review and revise, if necessary, effluent

limitations promulgated pursuant to sections 301, 304, 306, 307, 308, and 501 of the Act.
Chapter 2 - Background

2-6

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

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

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

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

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

conducted in 1978. However, in 1981, the Auto and Other Laundries Category, including the

industrial laundries subcategory, was excluded from regulation. The industrial laundries

subcategory was excluded because, based on assessments made at that time, it was determined

that 95 percent of the industry discharged pollutants that could be treated by POTWs and that did

not pass through, interfere with, or otherwise prove incompatible with the operation of POTWs.

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

Industrial Technology Division (ITD - now Engineering and Analysis Division (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,

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

Data Summary in 1989. 

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

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

effluent limitations guidelines and standards (“effluent guidelines”), and (ii) promulgating new

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

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

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

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

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

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

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

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

Columbia (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

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

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

Guidelines Plan update published on February 26, 1997 (62 FR 8726) required, among other

things, that EPA propose effluent limitations guidelines and pretreatment standards for the

Industrial Laundries Point Source Category by September 1997 and take final action by June

1999. Further modification of the Decree in August 1997 set the proposal date no later than

November 7, 1997.

On December 17, 1997 (62 FR 66181), EPA published proposed pretreatment

standards for the control of wastewater pollutants from the industrial laundries industry. EPA

published a notice of data availability (NODA) on December 23, 1998 (63 FR 71054). The
Chapter 2 - Background

2-7

NODA presented a summary of the data gathered or received from commenters since the

proposal, an assessment of the usefulness of the data in EPA’s analyses, and a discussion of a

voluntary industry program submitted by the industry as part of comments on the proposal.
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 Point

Source Category. EPA collected information necessary for the development of these effluent

guidelines and standards from many sources. EPA initially collected data on a broad group of

laundry facilities that included industrial laundries as well as linen laundries, denim prewash

facilities, and other laundry facilities. These data were necessary to define the scope of the

industry. Throughout this chapter, the term "laundry" is used to indicate that information was

collected from industrial laundries as well as other laundry facilities, such as facilities that launder

only linen items. 

On December 17, 1997 (62 FR 66181), EPA published proposed pretreatment

standards for the Industrial Laundries Point Source Category, based on EPA’s data collection

efforts. In response to this proposal, EPA obtained data from industry and publicly owned

treatment works (POTWs), which were described in the Notice of Data Availability (NODA)

published on December 23, 1998 (63 FR 71054). EPA received additional data from industry and

POTWs in comments on the NODA.

This chapter summarizes the information collection activities undertaken and the

information sources used to develop the final action for the Industrial Laundries Point Source

Category, as presented below:

C Section 3.2 summarizes data collection efforts prior to 1992;

C Section 3.3 discusses the questionnaire activities conducted after 1992;

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

through 1998;

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

through 1998;

C Section 3.6 discusses EPA’s Method 1664 Characterization Study;

C Section 3.7 presents other industry-supplied data;

C Section 3.8 discusses data collected from POTWs;

C Section 3.9 summarizes literature searches performed on the industrial

laundries industry; 
Chapter 3 - Data Collection Methodology and Information Sources

3-2

C Section 3.10 summarizes other sources of data on the industrial laundries

industry; and

C Section 3.11 presents the references used in this chapter.

3.2 Summary of Data Collection Prior to 1992

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

efforts consisted of the following:

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 of 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 analyzed wastewater samples it had

collected at a small number of facilities for conventional and nonconventional pollutants and some

metals. 

3.2.2 1975 Data Collection

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

Auto and Other Laundries Point Source Category, of which the industrial laundries industry was
Chapter 3 - Data Collection Methodology and Information Sources

3-3

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

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

laundries for conventional pollutants (pH, biochemical oxygen demand (BOD5), total suspended

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

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

3.2.3 1977 Data Collection Portfolio (DCP)

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

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

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

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

information:

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
Chapter 3 - Data Collection Methodology and Information Sources

3-4

1976 Consent Decree (see Section 2.3.4 of this document for discussion of the Consent Decree),

in wastewaters from facilities in the Auto and Other Laundries Point Source Category. EPA

sampled a total of 40 facilities for toxic and conventional pollutants using automatic timecompositing equipment during operating hours at each facility. In most cases, sampling was for

one day only. At facilities where wastewater treatment was in place, EPA collected samples of

both treatment system influent and effluent. Over a one-month period, EPA also sampled an

industrial laundry that used a dissolved air flotation (DAF) treatment system to obtain data on the

variability of treatment efficiency for this type of technology. 

3.2.5 1979 Laundries Survey

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

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

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

treatment. Other information obtained included:

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.

EPA conducted the Industrial Technology Division (ITD)/Resource Conservation

and Recovery Act (RCRA) Sampling Program and the Preliminary Data Study in response to a

recommendation made in the Domestic Sewage Study and because of concern for the potential

discharge of toxic pollutants. In 1981, EPA decided not to establish effluent limitations guidelines

and standards for the Auto and Other Laundries Point Source Category, of which industrial

laundries were a subcategory, because EPA determined that 95 percent of the discharged

pollutants were amenable to treatment by POTWs and did not pass through, interfere with, or

prove otherwise incompatible with the operation of POTWs. Therefore, no further data

collection efforts were undertaken until 1985.
Chapter 3 - Data Collection Methodology and Information Sources

3-5

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

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

Summary (1985 through 1987)

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

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

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

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

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

part of the Domestic Sewage Study (discussed in Section 3.10.3 of this document).

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

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

of untreated wastewater streams and final effluent at the four other industrial laundry facilities. 

EPA sampled these four facilities for two consecutive days and composited the wastewater over

the course of each operating day. EPA collected final effluent samples from two DAF systems,

one ultrafiltration system, and a settling basin. 

EPA analyzed the samples for conventional pollutants, priority and

nonconventional organic pollutants, metal pollutants, and other nonconventional pollutants.

Other EPA activities to collect information about the industrial laundries industry

investigated during this time period included:

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 1985 to 1987 was used to prepare the Preliminary Data

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

initiate work on effluent limitations guidelines and standards for the Industrial Laundries Point

Source Category in 1992.

3.3 Summary of Industrial Laundries Questionnaire Activity After 1992

EPA's first step in developing a rule for the industrial laundries industry was to

gather current data from the industry, under the authority of section 308 of the Clean Water Act. 

EPA conducted a screener survey by sending questionnaires to four different segments of the

laundry industry between 1993 and 1995. The screener questionnaires requested information to

be used in identifying the population of the laundry industry, developing the scope of the
Chapter 3 - Data Collection Methodology and Information Sources

3-6

regulation, and determining which facilities should receive a more detailed questionnaire. Based

on data collected from the screener survey and a search of the Dun & Bradstreet listing for

laundry facilities, EPA identified a representative subset of laundries to receive a detailed

questionnaire. Based on the responses to this detailed questionnaire, EPA sent an additional

questionnaire to a subset of the facilities that had received the detailed questionnaire to obtain

effluent monitoring data. These data-gathering efforts are described in more detail below. 

Additional details on the data-gathering efforts are also contained in the Statistical Support

Document for Proposed Pretreatment Standards for Existing and New Sources for the Industrial

Laundries Point Source Category (2). Copies of completed nonconfidential questionnaire

responses are contained in the Industrial Laundries Administrative Record.

3.3.1 Screener Questionnaires

EPA conducted four separate mailings of slightly different screener questionnaires

to collect data it could use to define the scope of the industrial laundries industry, identify the

population of the industry, and select facilities to receive the more detailed questionnaire. EPA

also used the screener questionnaires to characterize the industry and to determine the size of the

industrial laundries population. More details on determining the industrial laundries population

are provided in the Statistical Support Document (2). Summarized industry characterization data

are provided in Chapters 4, 5, and 6 of this document. The four different screener questionnaires

and their mailings are discussed in the following sections.

3.3.1.1 The 1993 Industrial Laundries Industry Screener Questionnaire

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

Industry Screener Questionnaire to 1,751 industrial laundries to solicit updated information on the

industry. The screener questionnaire requested information on the relative amounts and types of

items received for laundering, the type of waste treatment operations, the amount of water used,

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

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

the Industrial Laundries Administrative Record.

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

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

Rental Service Association (TRSA) mailing list, and the Occupational Safety and Health

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

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

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

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

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

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

is shown in the following table.
Chapter 3 - Data Collection Methodology and Information Sources

3-7

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.

3.3.1.2 1993 Industrial Laundries Industry Supplemental Screener Questionnaire

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

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

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

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

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

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

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

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

7218. The table below summarizes the results of the supplemental screener questionnaire mailing.

Status of D&B Screener Questionnaires 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.
Chapter 3 - Data Collection Methodology and Information Sources

3-8

3.3.1.3 Large Industrial Laundry Screener

Abbreviated screener questionnaires were sent to five large industrial laundry

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

original screener questionnaire or the supplemental screener questionnaire. Abbreviated screener

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

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

screener, along with information from the other screener questionnaire, was used to determine the

industrial laundry industry population.

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

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

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

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

facilities, but generate wastewater from laundering. EPA randomly selected 25 facility addresses

from each of the following four sources:

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 1994 Industrial Laundries

Industry 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, the amount of total laundry processed, number of employees, SIC code, percentage of items

laundered (both generated on site and accepted from off site), and type of treatment system. The

main goal of this effort was to obtain a snapshot of the activities of on-site laundries to determine

if they should be included in the scope of the industrial laundries industry. EPA received 86

responses to the 1995 screener questionnaire.

3.3.2 1994 Industrial Laundries Industry Questionnaire (Detailed Questionnaire)

EPA designed the 1994 Industrial Laundries Industry Questionnaire (detailed

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

linen facilities. EPA sent the detailed questionnaire to laundries statistically selected from the

1993 Industrial Laundries Industry Screener Questionnaire database (screener questionnaire

database) and from the Dun & Bradstreet database. Additional information concerning the

selection of facilities to receive the detailed questionnaire is presented in the Statistical Support

Document (2). EPA used the information reported by the respondents in the detailed

questionnaire to develop an industry profile, characterize industry production and water use,
Chapter 3 - Data Collection Methodology and Information Sources

3-9

develop pollutant loadings and reduction estimates, and develop compliance cost estimates, as

discussed throughout this document. A blank copy of the detailed questionnaire and copies of the

nonconfidential portions of the completed detailed questionnaires are contained in the Industrial

Laundries Administrative Record.

3.3.2.1 Detailed Questionnaire Recipient Selection and Mailing

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

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

the industrial laundries industry screener database. After mailing the questionnaires, EPA

deactivated the questionnaires for one of the selected Dun & Bradstreet facilities and three of the

selected screener questionnaire facilities because they were closed, out of scope, or otherwise

unable to respond to the questionnaire. EPA replaced these facilities with other facilities not

previously selected. The methods used to select the recipients of the detailed questionnaires are

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

254 detailed questionnaires is shown in the following table.

Activity 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 conduct a final action

EPA originally selected 250 recipients of the detailed questionnaire and later selected another four to replace facilities 1

that had been deactivated.

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

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

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

3.3.2.2 Information Collected by the Detailed Questionnaire

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

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

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

potential use of the information.

EPA developed the detailed questionnaire in conjunction with the industrial

laundries trade associations (TRSA and UTSA), EPA’s Office of Pollution Prevention and
Chapter 3 - Data Collection Methodology and Information Sources

3-10

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

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

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

the final version of the detailed questionnaire.

The detailed questionnaire comprised the following parts:

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.

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
Chapter 3 - Data Collection Methodology and Information Sources

3-11

disposal, and space availability at the facility. EPA used this information to evaluate current

treatment in place at industrial laundries and the costs of operating this treatment.

Part B requested detailed financial and economic information for each site and the

owner companies of each site. Detailed information on this section is presented in the Economic

Assessment for the Final Action Regarding Pretreatment Standards for the Industrial Laundries

Point Source Category (4).

3.3.2.3 Data Review and Data Entry

EPA completed a detailed engineering review of Part A of the detailed

questionnaires to evaluate the accuracy of information provided by the respondents. During

engineering review, responses to questions were coded to facilitate data entry into the detailed

questionnaire database. The Data Element Dictionary for the Industrial Laundries Industry

Questionnaire Part A Database (5) contains the codes used by reviewers. EPA contacted, by

telephone, respondents who provided incomplete or contradictory technical information to obtain

correct information. 

EPA developed a database for the technical information provided by the detailed

questionnaire respondents. After engineering review and coding, data from the detailed

questionnaires were double-key entered using a data entry and verification system. Reviewers of

the questionnaire verified errors in the double-key entry. EPA entered basic information (i.e.,

name, address, telephone number, etc.) for all 254 facilities into the database. EPA entered other

information provided by the 231 facilities responding to Part A. EPA also entered the information

for three pretest facilities.

3.3.2.4 Compilation of Respondent Data

EPA compiled information reported in the detailed questionnaire and summaries of

this information are located in Chapters 4, 5, and 6 of this document. These chapters include

information on facility location, process and production information, water use and discharge

practices, and wastewater characteristics and treatment.

3.3.3 Detailed Monitoring Questionnaire

In 1995, EPA mailed a detailed monitoring questionnaire (DMQ) to 37 industrial

laundries that had received the detailed questionnaire in 1994. After reviewing responses to the

detailed questionnaire, EPA identified facilities with available monitoring data that could be used

to identify effluent discharge quality after certain treatment technologies and in conjunction with

laundering certain industrial items. EPA selected the industrial laundries that would receive the

DMQ based on the following criteria:

C Facilities that EPA had sampled;

C Facilities with paired monitoring data (i.e., facilities that monitor both

influent and effluent pollutant concentrations);
Chapter 3 - Data Collection Methodology and Information Sources

3-12

C At least one facility with each technology being considered for inclusion in

the treatment technology options; and

C Facilities that had no treatment (or that have gravity settling and screens

only) to characterize untreated industrial laundry wastewater and current

pollutant discharge loadings.

The DMQ requested that facilities submit analytical data they had reported (but

not submitted) in their detailed questionnaire responses and any additional data that were available

(e.g., raw wastewater data, POTW data, chemical vendor data, wastewater treatment vendor

data, disposal company data). The facilities were also asked to include a process diagram for

verification of sampling points. All 37 recipients completed and returned their DMQ.

3.3.3.1 Data Review and Data Entry

EPA completed a detailed engineering review of the DMQs to evaluate the

accuracy of information provided by the respondents. The engineering review also included

coding of responses to questions to facilitate data entry into the DMQ database. The Data

Element Dictionary for the DMQ Database (6) contains the codes used by reviewers. EPA

contacted, by telephone, respondents who provided incomplete or contradictory technical

information to obtain correct information. 

EPA developed a database for the technical information provided by the DMQ

respondents. After engineering review and coding, data from the DMQ were double-key entered

using a data entry and verification system. Reviewers of the questionnaires verified errors in the

double-key entry. EPA entered information for all 37 facilities into the DMQ database.

3.3.3.2 Compilation of Respondent Data

EPA compiled information reported in the DMQ responses and summarized it in

Chapter 5 of this document, which includes information on wastewater characteristics. DMQ

data were also used to develop summaries reflecting wastewater control technology performance

for the industrial laundries industry, as presented in Chapter 7 of this document.

3.4 Summary of EPA’s Site Visit Program (1993-1998)

EPA conducted 38 site visits to industrial laundries between 1993 and 1998 to

collect information about industrial laundry processes, water use practices, pollution reduction

practices, wastewater treatment technologies, and waste disposal methods. EPA also visited

these sites to evaluate potential sampling locations (as described in Section 3.5 of this document). 

EPA visited a range of laundry facilities, such as industrial laundries, linen facilities, hospital

cooperative laundries, clean room facilities, and denim prewash facilities, to collect data it could

use to define the scope of the industry.
Chapter 3 - Data Collection Methodology and Information Sources

3-13

3.4.1 Criteria for Site Visit Selection

EPA based site selection on information in responses to the screener and detailed

questionnaires and information obtained from the industrial laundries trade associations. In

addition to choosing sites of varying sizes, EPA used the following general criteria to select sites

that encompassed the range of processes and treatment technologies within the industrial

laundries industry:

C The site laundered a broad range of industrial textile 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.

3.4.2 Types of Information Collected

EPA documented information for each site visit in a site visit report; these reports

are contained in the Industrial Laundries Administrative Record. During the site visits, EPA

collected the following information for each facility:

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 (1993-1998)

EPA conducted sampling episodes at nine facilities between 1993 and 1998 to

obtain data on the characteristics of industrial laundry wastewaters and to assess the following:

the amount of pollutants discharged to POTWs from industrial laundries; the effectiveness of
Chapter 3 - Data Collection Methodology and Information Sources

3-14

technologies designed to reduce and remove pollutants from industrial laundry wastewater; and

the variation of wastewater characteristics across item type.

3.5.1 Criteria for Sampling Site Selection

EPA used information collected during industrial laundry site visits to identify

candidate sites for sampling. EPA used the following general criteria to select sites for sampling:

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 treatment technology option

development.

After selecting a site for sampling, EPA prepared a detailed sampling and analysis

plan, based on the information obtained during the site visit and follow-up contact with the site. 

The sampling and analysis plans were prepared to ensure collection of samples that would be

representative of the sampled waste streams, and contained the following types of information: 

site-specific selection criteria for sampling; information about site operations; sampling point

locations and sample collection, preservation, and transportation procedures; site contacts; and

sampling schedules.

3.5.2 Information Collected

In addition to wastewater samples, EPA collected the following types of

information during each sampling episode:

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 (SER) for each sampled site; these reports are contained in the Industrial

Laundries Administrative Record. The sampling episode reports also contain preliminary

technical analyses of treatment system performance.
Chapter 3 - Data Collection Methodology and Information Sources

In Method 1664 (promulgated at 64 FR 26315; May 14, 1999), EPA defines SGT-HEM as non-polar material (NPM). 1

Throughout this document and the Industrial Laundries Administrative Record, EPA refers to SGT-HEM as TPH.

3-15

3.5.3 Sample Collection and Analysis

All samples were collected, preserved, and transported according to EPA

protocols as specified in EPA's Sampling and Analysis Procedures for Screening of Industrial

Effluents for Priority Pollutants (7). This document is contained in the Industrial Laundries

Administrative Record.

In general, EPA collected composite samples from the wastewater streams from

laundering operations over the course of the operating day. Most facilities were sampled for a

consecutive five-day period. For item-specific sampling, EPA collected wastewater samples from

individual laundered loads during each discharge from the washer and composited the samples. 

EPA collected the required types of quality control samples as described in the Industrial

Laundries Quality Assurance Project Plan (QAPP), such as blanks and duplicate samples, to verify

the precision and accuracy of sample analyses. 

EPA had samples shipped via overnight air transportation to EPA-approved

laboratories, which analyzed the samples for metal and organic pollutants and additional

parameters (including several water quality parameters). The laboratories analyzed metal

pollutants using EPA Method 1620 (8), volatile organic pollutants using EPA Method 1624 (9),

and semivolatile organic pollutants using EPA Method 1625 (10). Tables A-1 and A-2 in

Appendix A of this document list the metal and organic pollutants, respectively, analyzed using

these methods. The laboratories analyzed oil and grease and total petroleum hydrocarbon (TPH)

using EPA Method 1664 (11), which is now promulgated at 40 CFR, Part 136. Method 1664

measures oil and grease as n-hexane extractable material (HEM) and measures TPH as silica gel

treated-hexane extractable material (SGT-HEM ). Method 1664 may extract a different fraction 1

of oil and grease and TPH than is extracted by the freon methods. The amount extracted by nhexane and freon is dependent upon the composition of oils and grease in the samples. Sludge

samples were analyzed using both the regular wastewater methods and the Toxicity Characteristic

Leaching Procedure (TCLP), using SW-846, Method 1311 (12). Table A-3 in Appendix A of this

document lists other parameters analyzed during the sampling program and the methods by which

they were analyzed (13, 14).

Quality control (QC) measures used in performing all analyses complied with the

guidelines specified in the analytical methods and in the QAPP. EPA reviewed all analytical data

to ensure that these measures were followed and that the resulting data were within the QAPPspecified acceptance criteria for accuracy and precision.

As discussed previously, upon receipt and review of the analytical data for each

site, EPA wrote a sampling episode report (SER) to document the sampling episode, the data

collected during sampling, the analytical results, and the technical analyses of the results. The

SERs include sampling and analysis plans and correspondence with site personnel as appendices.
Chapter 3 - Data Collection Methodology and Information Sources

3-16

3.6 Summary of EPA’s Method 1664 Characterization Study

In response to comments on the proposed rule, EPA conducted a characterization

study of wastewater generated at industrial laundries to determine the specific constituents of oil

and grease and TPH, measured using EPA Method 1664. EPA collected influent and effluent

samples from six facilities that operate DAF or chemical precipitation, and were previously

sampled by EPA.

Samples from the facilities were analyzed for volatile organics by Method 1624,

semivolatile organics by Method 1625, and oil and grease and TPH by Method 1664. Two

additional oil and grease/TPH aliquots were collected for the Method 1664 characterization study

analysis. These aliquots were subjected to the Method 1664 oil and grease and TPH analytical

protocols, and the oil and grease and TPH residues were subsequently dissolved in an appropriate

solvent and analyzed for volatile organics by modified Method 1624 and semivolatile organics by

modified Method 1625. These analyses allow for comparison between the organic constituents

measured in the wastewater and the organic constituents of the fractions measured as oil and

grease and TPH. The analytical protocols prepared by EPA’s Sample Control Center (SCC) used

in this characterization study are presented in The Study Plan for Determination of the

Components of n-Hexane Extractable Material (HEM) and Silica Gel Treated n-Hexane

Extractable Material (SGT-HEM; Non-polar Material) in Discharges from Selected Industrial

Laundry Facilities (15).

All samples were collected, preserved, and transported according to EPA

protocols as specified in EPA’s Sampling and Analysis Procedures for Screening of Industrial

Effluents for Priority Pollutants (7) and the Industrial Laundries QAPP. All samples were

preserved on site and shipped via overnight air transportation to the EPA-approved laboratories.

Quality control (QC) measures used in performing all analyses complied with the

guidelines specified in the analytical methods and in the QAPP. EPA reviewed all analytical data

to ensure that these measures were followed and that the resulting data were within the QAPPspecified acceptance criteria for accuracy and precision.

The results and data collected during this study are presented in Chapter 5 of this

document and Section 16.2 of the Industrial Laundries Administrative Record.

3.7 Other Industry-Supplied Data

The industrial laundry trade associations, the Uniform and Textile Service

Association (UTSA), and the Textile Rental Services Association (TRSA), as well as individual

laundries and other interested parties, submitted data to be used in the development of the

proposed rule and in the final action.\

3.7.1 Data Submitted Prior to 1992 

In 1977, TRSA sponsored a wastewater study of linen and industrial laundries. In

addition to pH, this study analyzed wastewater for the following 10 pollutants: BOD , TSS, oil 5
Chapter 3 - Data Collection Methodology and Information Sources

3-17

and grease, lead, mercury, nickel, cadmium, zinc, total chromium, and TOC. The two-part study

first analyzed untreated wastewater from 20 laundries and then analyzed untreated and treated

wastewater from five laundries.

The first part of the study presented sampling and analytical data from 20 linen and

industrial laundries. Samples were collected for untreated wastewater at 15-minute intervals

during an 8- to 10-hour period and composited based on the flow rate at the time of sampling. 

The wastewater flow was calculated from process water meter readings and flow readings in the

wastewater treatment system. The process water flows were used to calculate maximum

pollutant loadings. These are maximum loadings because all of the water metered into the facility

is not discharged as wastewater. The production-normalized pollutant loading level was based on

the maximum pollutant loading level and the actual poundage of laundry produced on the

sampling days. The types of items laundered on the sampling days were not reported; soil

classification provided information on the soil loading only. Also, from the sampling point

location information, it was difficult to determine the exact location of the sampling point and the

source of wastewater sampled. In some cases, the untreated wastewater sampled may have

passed through settling pits or screens before sampling.

The second part of the TRSA study presented data from five linen and industrial

laundries. All of these laundries had treatment systems in place. Four facilities had DAF systems

and one facility had a proprietary filter system. Sampling was conducted as described for the first

part of the study, except that both untreated and treated wastewater samples were collected. 

Process water flows were used to calculate maximum pollutant loadings, and wastewater flows in

the treatment system were used to calculate actual pollutant loadings. The production-normalized

pollutant loading level was based on the maximum pollutant loading level and the average

poundage of clean, dry laundry produced per week at the facility.

This study included information on the percentages of different types of items

laundered at sampled laundries, although no information was provided on the types of articles

laundered during the sampling days. Also, the descriptions of the sampling point locations were

more extensive than those presented in the first part of the study. Diagrams of the wastewater

treatment systems were provided and the operations of the treatment systems were discussed

briefly. Several of the facilities sampled experienced difficulties with their treatment system

during the sampling days. Also, unlike in the first part of the study, the production-normalized

pollutant loading levels were based on average production levels instead of actual production

levels. 

3.7.2 Trade Associations Solicitation of Data

After the publication of the proposed rule, the industrial laundries trade

associations, UTSA and the TRSA, solicited data from all of the facilities that were sent a detailed

questionnaire. The purpose of the solicitation, as stated by UTSA and TRSA, was to provide

EPA with updated data to calculate new baseline information on the industry, because the EPA

questionnaire data are for the 1993 operating year.
Chapter 3 - Data Collection Methodology and Information Sources

3-18

The trade associations’ solicitation requested the following information: the year

the data were supplied, the average flow rate of wastewater, modifications to treatment system

since 1993, the year modifications to treatment system occurred, a description of the current

wastewater treatment system, the portion of the wastewater treated, the facility’s discharge permit

limits and the facility’s average discharge concentration for 13 parameters, the weekly production

of the facility, the average percentage of total pounds per item laundered, whether a subcontractor

is used to process towels, the amount of towels subcontracted out for processing, whether the

subcontractor water-washes or dry-cleans the towels, and whether the subcontractor’s wash

water from the laundering of the towels is treated.

Of the 193 facilities that EPA used to model compliance costs and pollutant

loading reductions for the proposed rule, 165 responded to the UTSA/TRSA survey. EPA

reviewed the data from the survey and compared, for each facility, the treatment system

description contained in the UTSA/TRSA solicitation to the treatment system components

reported in the detailed questionnaire. 

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

Data Availability

In response to the proposal published on December 17, 1997 and the NODA

published on December 23, 1998, EPA received additional data from the industrial laundries in

individual comment submittals. The data received included: industrial laundry effluent loadings,

treatment technology costs, the constituents of TPH, data on the analytical variability of bis(2-

ethylhexyl) phthalate, local limits for specific laundries, and POTW treatability of specific

pollutants. Costs submitted by commenters included: general annual and capital costs for both

chemical precipitation and DAF, the annual costs associated with treating 1,000 gallons of

wastewater with DAF, analytical costs, the costs associated with the construction of a new

building for an industrial laundry, and facility-specific cost information.

The industrial laundries industry and its trade associations also submitted reports

and case studies. Reports and studies submitted by commenters ranged in content from data

pertaining to the calculation of the toxic weighting factor for TPH to general economic and

industry profiles for the industrial laundries industry. 

These data are contained in Section 14 of the Industrial Laundries Administrative

Record. Data submitted with comments and used by EPA as part of specific analyses are

described in more detail in other sections of this document.

3.7.4 Request for Substantiation of Claims Made in Comments

Many of the commenters on the proposed rule stated that EPA underestimated

compliance costs and that EPA overestimated the treatment performance of chemical precipitation

and DAF. However, many commenters did not present data to substantiate these claims. 

Without additional data to support these claims, EPA would have to rely on data obtained prior to

proposal (vendor quotes, previously submitted cost data and comment
Chapter 3 - Data Collection Methodology and Information Sources

3-19

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

activities. 

To obtain data to support unsubstantiated comments made on the proposed rule,

EPA contacted some commenters directly to request additional information. EPA developed a set

of four questions that requested specific information that would enable EPA to consider the

commenter's information in development of the final action. 

EPA requested the following information: a diagram presenting the facility’s

wastewater treatment system, including all treatment units, average and residual flows, chemical

addition locations; a description of the facility’s operations including total production and itemspecific production, average operation days and hours per year; and specific wastewater treatment

system capital and annual costs.

To comply with the Paperwork Reduction Act, EPA sent letters to nine of the

commenters that submitted unsubstantiated comments. EPA selected commenters to receive

letters based on the content of their comments, the number of comments submitted, whether or

not the comment was a standard letter prepared by the trade associations, and the size of the firm. 

The methodology used to select these nine letter recipients and copies of the letters sent to each

of them are presented in Section 14.6.1 of the Industrial Laundries Administrative Record. EPA

also solicited comments from the public on these issues in the NODA.

3.7.5 The Trade Associations Split-Sampling Efforts

The industrial laundries trade associations split samples with EPA during one of

the nine facility sampling episodes (Episode 4900) and several of the Method 1664

Characterization Study sampling episodes. The data collected by the industry during Episode

4900 were supplied to EPA in a comment submittal; these data are located in Section 14 of the

Industrial Laundries Administrative Record. The industry did not supply EPA with the split

sample data collected during the Method 1664 Characterization Study.

3.8 POTW Data

Several POTWs submitted data and comments that were used for the final action,

and are discussed below.

3.8.1 AMSA Questionnaire

The Association of Metropolitan Sewerage Agencies (AMSA), in an effort to

assist EPA in collecting data for the development of effluent limitations guidelines and standards

for the industrial laundries industry, developed and distributed a questionnaire to its member

POTWs in 1993. The questionnaire asked the POTWs to provide already collected data on

industrial laundries, which were defined as facilities with the SIC code of 7218 (facilities that

supply laundered and dry-cleaned work uniforms, wiping towels, safety equipment (such as

gloves, flame-resistant clothing), dust covers and cloths, and other items to commercial and
Chapter 3 - Data Collection Methodology and Information Sources

3-20

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); and

C Provide the following specific information for each industrial laundry that

discharges to the POTW:

— Industrial user information (facility location information, average

daily wastewater discharge in gallons per day, and permit

information);

— Industrial discharge sampling information, including the following:

whether the sample point contained only industrial laundry

wastewater, and, if not, what other types of waste streams; whether

the wastewater was treated prior to the sampling point; types of

treatment used; and the types of pollution prevention techniques

used at the facility; and 

— Sampling data for each sampling point (either POTW or Industrial

User (IU) self-monitoring data) for calendar year 1992 (including

parameter, measurement, type of sample, whether an 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 are located in Section 6.6 of

the Industrial Laundries Administrative Record.

3.8.2 Data Submittals Related to POTWs with Comments on the Proposed

Rulemaking and Notice of Data Availability

EPA received comment submittals from numerous commenters pertaining to

POTW data related to the pass-through analysis. These commenters included: individual

POTWs, local control authorities, and AMSA, along with the industry’s trade associations. 

Individual POTWs primarily provided data related to the following subjects: the method used to

measure TPH, estimated POTW pollutant removal efficiencies, influent and effluent 
Chapter 3 - Data Collection Methodology and Information Sources

3-21

concentration values to be used in the calculation of POTW pollutant removal efficiencies for the

pass-through analysis, industrial laundry facility monitoring data, and local limits covering

industrial laundries. These data and results of any evaluations of these data are contained in

Sections 14 and 17 of the Industrial Laundries Administrative Record, respectively.

3.9 Summary of Literature Searches

EPA conducted several searches of the open literature throughout the development

of the rule to provide information on the industrial laundries industry. The sources searched

included the following:

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).

EPA conducted additional literature searches in 1993 to gather publicly available

information on the industrial laundries industry. EPA conducted one literature search to obtain

information about industrial laundry wastewater, wastewater treatment technologies, operations,

and costs of operations, and also a search to obtain information about printer towels/rags, wipers,

and shop towels.

The literature searches focused on the following topics: waste streams, waste

treatment technologies, operations, and costs of operation. The following databases were

searched:

Database Description

Water Resources Abstracts Water resources topics

Waternet Index of the American Water Works

Association Publications

NTIS Government-sponsored research,

development, and engineering reports and

analysis

COMPENDEX Engineering and technology applications

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

Database Description

3-22

Pollution Abstracts Pollution control and research

Books in Print Books in print, forthcoming books, and

books going out of print in the U.S.

LC Mark Library of Congress catalogued

publications

Textile Technology Digest Worldwide coverage of textiles and

related subjects

World Textiles Textiles in areas of technology and

management

As part of the literature search, EPA identified three trade journals important in the

industrial laundries industry: Textile Rental, Industrial Launderer, and Laundry News. These

journals provide up-to-date information on the industrial laundries industry. EPA conducted

regular reviews of these journals during the development of this final action. 

EPA conducted a separate literature search for data on pollution prevention in the

industrial laundries industry by examining various on-line databases, including EPA's Pollution

Prevention Information Exchange System (PIES).

3.10 Summary of Other Data Sources

In developing the industrial laundries effluent guidelines, EPA also evaluated the

following existing data sources:

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 final action are discussed below.

3.10.1 Risk Reduction Engineering Laboratory Treatability Database

EPA's ORD developed the RREL treatability database to provide data on the

removal and destruction of chemicals in various types of media, including water, soil, debris,
Chapter 3 - Data Collection Methodology and Information Sources

3-23

sludge, and sediment. This database contains treatability data from POTWs for various

pollutants. This database includes physical and chemical data for each pollutant, the types of

treatment used to treat the specific pollutants, the type of wastewater treated, the size of the

POTW, and the treatment concentrations achieved. EPA used this database to assess POTW

removal efficiencies of various pollutants.

3.10.2 Fate of Priority Pollutants in Publicly Owned Treatment Works Database

In September 1982, EPA published the Fate of Priority Pollutants in Publicly

Owned Treatment Works (16), referred to as the 50 POTW Study. The purpose of this study was

to generate, compile, and report data on the occurrence and fate of the 129 priority pollutants in

50 POTWs. The report presents all of the data collected, the results of preliminary evaluations of

these data, and the results of calculations to determine the following:

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

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

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

3.10.3 The Domestic Sewage Study

In February 1986, EPA issued the Report to Congress on the Discharge of

Hazardous Wastes to Publicly Owned Treatment Works (17), referred to as the Domestic Sewage

Study (DSS). This report, which was based in part on the 50 POTW Study, demonstrated that a

significant number of sites discharging pollutants to POTWs were a threat to the treatment

capability of these POTWs and were not regulated by national categorical pretreatment standards. 

Among the unregulated sources were industrial laundries, which at the time were estimated to

discharge significant quantities of toxic and hazardous pollutants on a facility-specific basis. 

During the course of the DSS, EPA contacted a number of state and local agencies to obtain toxic

pollutant data and other relevant data. EPA used the information in the DSS in developing the

Preliminary Data Summary for the Industrial Laundries Industry (1).

3.10.4 Canadian Studies

EPA studied other sources of data, as described below, to obtain as comprehensive

a picture of the industrial laundries industry as possible. One of these sources was the Ministry of

the Environment and Energy (MOEE) of Canada. As in the U.S., industrial laundries in Canada

have been found to be a source of oil and grease in sewer systems. The MOEE's

Municipal/Industrial Strategy for Abatement (MISA) section and the Ontario, Canada industrial

laundry associations conducted a survey of Canadian industrial laundries to assess the 
Chapter 3 - Data Collection Methodology and Information Sources

3-24

amount of oil and grease and other pollutants discharged into sewer systems. The survey was

conducted to obtain an overview of the industrial laundries industry, sources of contamination,

and treatment used to reduce the pollutant loads to sewers.

The laundries surveyed in this report included industrial laundries, linen

establishments, and commercial launderers and excluded retail-only, coin-operated, dry cleaning,

and health-care facilities. The industrial laundries processed industrial garments and wiper towels,

which, according to this survey, were considered major sources of oil and grease. The survey

showed that many industrial laundries in this study used some wastewater pretreatment; however,

only four facilities used advanced pretreatment techniques, and several facilities did not pretreat

their wastewater.

In addition, the Ontario Laundry Industry Pollution Prevention Task Force has

been meeting regularly to discuss pollution prevention measures in the laundries industry and how

to promote those practices. The Task Force consists of the following entities: the Ontario

Ministry of Environment and Energy, the Metropolitan Area of Toronto, the City of Brantford,

and several Canadian laundries, some of which represent the laundry associations Dry Cleaners

and Launderers Institute (DCLI) and Textile Rental Institute of Canada (TRIO). In 1994, the

Task Force held a workshop on pollution prevention in the laundries industry, which discussed

pollution prevention in general, how using pollution prevention practices benefits industrial

laundries, and approaches to and techniques for reducing waste in the industry.

3.10.5 Industrial Pollution Prevention Project

EPA has undertaken several pollution prevention-related activities involving the

industrial laundries industry. Some of the efforts were Agency-wide, including ORD and EPA’s

Region IX, while other efforts were part of the engineering studies in the development of the

proposed rule. 

The Agency-wide efforts, called the Industrial Pollution Prevention Project (IP3),

were multimedia and examined how industrial pollution prevention can be incorporated into

EPA’s regulatory framework and how the pollution prevention ethic can be promoted throughout

industry, the public, and government. A report summarizing the results of these efforts, entitled

Industrial Pollution Prevention Project (IP3) - Summary Report (18), included the results of two

case studies involving industrial laundries. More detailed discussions of the two studies are

contained in the individual reports, Pollution Prevention at Industrial Laundries: Assessment

Observations and Waste Reduction Options (19), and Pollution Prevention at Industrial

Laundries: A Collaborative Approach in Southern California (20). These studies identified a

number of “best management practices” (BMPs) and water and energy savings technologies as

potential pollution prevention at industrial laundries. 

Similarly, during the engineering study phase of the development of a final action,

EPA identified a number of potential pollution prevention practices and technology applications. 

Section VI of the preamble to the proposed rule and Chapters 6 and 8 of this document discuss

the pollution prevention technologies and practices and their uses with respect to the final action.
Chapter 3 - Data Collection Methodology and Information Sources

3-25

3.11 References

1. U.S. Environmental Protection Agency. Preliminary Data Summary for the

Industrial Laundries Industry. EPA 440/1-89/103, September 1989.

2. U.S. Environmental Protection Agency. Statistical Support Document for

Proposed Pretreatment Standards for Existing and New Sources for the Industrial

Laundries Point Source Category. EPA-821-R-97-006, Washington, D.C.,

November 1997.

3. U.S. Environmental Protection Agency. Information Collection Request. U.S. 

Environmental Protection Agency 1994 Industrial Laundries Industry

Questionnaire. March 3, 1994.

4. U.S. Environmental Protection Agency. Economic Assessment for the Final

Action Regarding Pretreatment Standards for the Industrial Laundries Point

Source Category (Revised February 2000). EPA-821-R-00-004, Washington,

D.C., February 2000.

5. Eastern Research Group, Inc. Data Element Dictionary for the Industrial

Laundries Industry Questionnaire Part A Database. Prepared for the U.S. 

Environmental Protection Agency, Office of Water, Washington, D.C., November

1997.

6. Eastern Research Group, Inc. Data Element Dictionary for the DMQ Database. 

Prepared for the U.S. Environmental Protection Agency, Office of Water,

Washington, D.C., November 1997.

7. U.S. Environmental Protection Agency. Sampling and Analysis Procedures for

Screening of Industrial Effluents for Priority Pollutants. April 1977.

8. U.S. Environmental Protection Agency. Method 1620 Draft - Metals by

Inductively Coupled Plasma Atomic Emission Spectroscopy and Atomic

Absorption Spectroscopy. September 1989.

9. U.S. Environmental Protection Agency. Method 1624 Revision C - Volatile

Organic Compounds by Isotope Dilution GCMS. 40 CFR 136, Appendix A, June

1989.

10. U.S. Environmental Protection Agency. Method 1625 Revision C - Semivolatile

Organic Compounds by Isotope Dilution GCMS. 40 CFR 136, Appendix A, June

1989.
Chapter 3 - Data Collection Methodology and Information Sources

3-26

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 Non-polar Material). 

EPA-821-B-94-004b, April 1995.

12. U.S. Environmental Protection Agency. SW-846: Test Methods for Evaluating

Solid Waste, Physical/Chemical Methods; Method 1311, Toxicity Characteristic

Leaching Procedure. 63 FR 32452, June 13, 1997.

13. U.S. Environmental Protection Agency. Methods for Chemical Analysis of Water

and Wastes. EPA-800-4-79-020, Revised March 1983.

14. Standard Methods for the Examination of Water and Wastewater. A.D. Eaton,

L.S. Clesceri and A.E. Greenberg, eds. 19th Edition. American Public Health

Association, Washington, D.C., 1995.

15. DynCorp Environmental. The Study Plan for Determination of the Components of

n-Hexane Extractable Material (HEM) and Silica Gel Treated n-Hexane

Extractable Materials (SGT-HEM: Non-polar Material) in Discharges from

Selected Industrial Laundry Facilities. Prepared for the U.S. Environmental

Protection Agency, Office of Water, Washington, D.C., July 1998.

16. U.S. Environmental Protection Agency. Fate of Priority Pollutants in Publicly

Owned Treatment Works. EPA 440/1-82/303, September 1982.

17. U.S. Environmental Protection Agency. Report to Congress on the Discharge of

Hazardous Wastes to Publicly Owned Treatment Works. EPA-530-SW-86-004,

February 1986.

18. U.S. Environmental Protection Agency. Industrial Pollution Prevention Project

(IP3)-Summary Report. EPA-820-R-95-007, July 1995.

19. U.S. Environmental Protection Agency. Pollution Prevention at Industrial

Laundries: Assessment Observations and Waste Reduction Options. EPA-820-R95-010, July 1995.

20. U.S. Environmental Protection Agency. Pollution Prevention at Industrial

Laundries: A Collaborative Approach in Southern California. EPA-820-R-95-

012, July 1995.
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. This

chapter also provides a definition of the industrial laundries industry. Most of the data presented

in this chapter are from facility responses to the 1994 Industrial Laundries Industry Questionnaire

(detailed questionnaire), additional data are from the 1993 Industrial Laundries Screener

Questionnaire. EPA sent the detailed questionnaires to 250 facilities, and 231 facilities returned

the questionnaire, as described in Section 3.3.2 of this document. Two hundred eight (208)

facilities that responded to the detailed questionnaire provided sufficient data to perform complete

technical and economic analyses. The percentages and number of facilities performing various

processes discussed in this section were estimated based on the responses from all facilities

determined to be industrial laundries. The data for these facilities were then extrapolated to

represent the industry population of 1,747 facilities, using appropriate survey weights. The survey

weights calculated for each of the facilities can be found in the Statistical Support Document for

the proposed rule (1). Three facilities of the 193 identified industrial laundries were later

determined to be out-of-scope because they process only clean room items (see Section 4.8). The

following topics are discussed in this section:

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;

C Section 4.8 provides EPA’s definition of the industry; and

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

4-2

4.2 Overview of the Industry

This section provides an overview of the industrial laundries industry. This

overview includes general information pertaining to the industry, including geographic location,

SIC codes, facility size, types of items laundered, and customers.

4.2.1 Geographic Distribution of Facilities

Information on geographic distribution was based on the 1993 Industrial Laundries

Screener Questionnaire. This questionnaire was completed by 1,500 industrial laundries that EPA

identified using trade association mailing lists. Since there were no direct discharging industrial

laundries identified by the questionnaire responses, only industrial laundries that reported

generating laundry process wastewater and discharging a wastewater to a publicly owned

treatment works (POTW) were used to determine the geographic distribution of facilities. These

facilities are located in all 50 states and in all 10 EPA Regions, as well as several U.S. territories. 

Figure 4-1 and Table 4-1 present the geographic distribution of these facilities. By state, the

greatest number of in-scope laundries (102 facilities) are in California. By EPA region, the

greatest number of in-scope laundries (203 facilities) are in Region V, followed by Region IV,

which has 181 facilities. Most of the laundries are located in large urban areas.

4.2.2 SIC Codes Reported

The facilities responding to the detailed questionnaire reported 7218 (Industrial

Laundries) and 7213 (Linen Supply Laundries) as their primary SIC codes. Other secondary and

tertiary SIC codes reported were 7211 (Power Laundries, Family and Commercial), 7216 (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 there are a

fewer 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

4-3

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

4-4

Table 4-1

Geographic Distribution of Industrial 

Laundries by EPA Region and State

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

North Carolina 35

South Carolina 13

Tennessee 16

Region V 203

Illinois 42

Indiana 33

Michigan 36
Table 4-1 (Continued)

Chapter 4 - Industry Profile

Region/State Number of Facilities in Region/State1

4-5

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

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 discharging that wastewater to a POTW.
Chapter 4 - Industry Profile

4-6

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 using the detailed questionnaire, based on 193 in-scope facilities extrapolated to 1

represent the entire industry (including three facilities that were later determined to be out-of-scope because they process

only clean room items).

Source: 1994 Industrial Laundries Industry Questionnaire.
Chapter 4 - Industry Profile

4-7

4.2.4 Items Laundered

As reported by the 193 facilities, industrial laundries wash a variety of items. The

three main types of items reported in the detailed questionnaire responses were industrial laundry

items, linen laundry items, and other items. Typically, industrial laundry items include industrial

garments, shop towels, printer towels, floor mats, and fender covers. Linen items typically

include linen garments, flatwork/full dry linen, and health-care items. Other items are specialty

items or items that are not generally considered to be either industrial laundry items or linen items.

Brief descriptions of industrial laundry, linen items, and other items are provided in Chapter 5 of

this document.

Table 4-3 presents the number of facilities that launder each item and the 

percentage of total production by item. Many facilities reported laundering several items. The

total extrapolated item-specific production reported in the detailed questionnaire is 9,360,000,000

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 for the items identified in

these categories.

4.2.5 Customers

Industrial laundries wash items for many different types of customers, ranging from

gasoline stations to restaurants. The pollutants present on an item laundered depend primarily on

the customer who used the item and the specific use of the item. For instance, a shop towel from

a gasoline station is more likely to have a high concentration of oil and grease or total petroleum

hydrocarbon than a napkin from a restaurant. Table 4-4 lists the laundered items reported in the

detailed questionnaire responses, the typical customers using these items, and the percentage of

the total industry production of each item laundered from each customer. For example,

automobile repair, services, dealers, and gas stations represent 31.1 percent of the customers who

use industrial garments.
Chapter 4 - Industry Profile

4-8

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) - - -

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 (including three facilities that were later

determined to be out-of-scope because they process only clean room items).

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 Questionnaire.
Chapter 4 - Industry Profile Chapter 4 - Industry Profile

4-9

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 11.1

Processing, 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 24.7

Processing, and Food Stores (C08)

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 20.2

Processing, and Food Stores (C08)

- Health Services (C10) 7.46
4-10

Table 4-4 (Continued)

Chapter 4 - Industry Profile Chapter 4 - Industry Profile

Item Type Customers Item from Customer 1 1

Percentage

of Total Production of

2

Linen Garments (B06) - Eating/Drinking Establishments, Food/Beverage Manufacturing and 91.1

Processing, and Food Stores (C08)

Linen Flatwork/Full Dry (B07) - Eating/Drinking Establishments, Food/Beverage Manufacturing and 85.2

Processing, 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 29.2

Processing, and Food Stores (C08)

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 9.25

Processing, and Food Stores (C08)

Family Laundry (B15) - Industrial Metal, Machinery, and Equipment Manufacturing (C04) 8.92

- Eating/Drinking Establishments, Food/Beverage Manufacturing and 8.33

Processing, and Food Stores (C08)

- Families (C23) 69.8
4-11

Table 4-4 (Continued)

Chapter 4 - Industry Profile Chapter 4 - Industry Profile

Item Type Customers Item from Customer 1 1

Percentage

of Total Production of

2

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 96.0

(B19) Processing, and Food Stores (C08)

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 100

Processing, 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 was greater than 5 percent. 3

Source: 1994 Industrial Laundries Industry Questionnaire.
Chapter 4 - Industry Profile

4-12

4.3 Laundering Processes

For all laundering processes, the methods by which the items are received, sorted,

and transported to the washing area are similar. Industrial laundries receive soiled items in trucks

and weigh the items before washing. These items are typically sorted based on item type, fabric

type, color, degree and/or type of soil, and ownership. Sorted items are then placed in slings or

carts, which are either automatically or manually moved to the washing area. The items are then

cleaned using the appropriate process.

Table 4-5 presents laundering processes reported by the facilities responding to the

detailed questionnaire, as well as the percentage of total production laundered by each process

and the number of facilities performing each process. Many facilities reported conducting more

than one of the listed processes. One process included in Table 4-5, dyeing of new fabrics is not

considered a laundering process by EPA. EPA reviewed laundry processes and associated water

use and wastewater discharge practices to determine if facilities that used and/or discharged little

or no water could be eliminated from the scope of the rule. Only water-washing laundering

processes are included in the scope of the rule. EPA does not consider dyeing of new items to be

a laundering process; therefore, it is also excluded from the scope of the proposed rule. Dyeing of

used textile items such as shop and printer towels/rags, which is often performed as part of the

washing process, is included in the scope of the rule. The remaining processes listed in Table 4-5

can be divided into two basic categories: processes that generate wastewater and processes that

generate little or no wastewater. The individual processes within these categories are described in

more detail below.

4.3.1 Water-Using/Wastewater-Generating Processes

Laundering processes that use significant amounts of water and generate

wastewater include water-washing processes and dual-phase washing. Almost all (97 percent) of

the industry’s production involves water-washing processes. Of the 1,747 in-scope facilities

(including three facilities that were later determined to be out-of-scope because they process only

clean room items), EPA estimates that 1,443 perform water washing on 100 percent of their

production. Water washing is performed on almost all items. Brief descriptions of the different

water-using processes are provided below.

4.3.1.1 Water Washing

Water washing involves the washing of soiled items in a water/chemical solution. 

The concentration, type, and amount of chemicals added during the water-washing process

depend on the item type and the degree to which items are soiled. Wash formulas are used to

determine the different washing cycles used in water washing, including the chemicals added. 

Wash formulas are also used to set the order, number, and duration of each wash cycle that is

performed during the water-washing process. The typical order of these cycles and brief

descriptions of the processing operations that occur in each cycle are described below. 
Chapter 4 - Industry Profile

4-13

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 by 18 1 <1

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 between 29 2 <1

steps) (A12)

Dust Control Mop Treatment - Water wash followed by oil 692 40 1

treatment applied outside wash wheel (A10)

Dust Control Mop Treatment - Water wash followed by oil 67 4 <1

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 (including three facilities that were later 2

determined to be out-of-scope because they process only clean room items), extrapolated using appropriate survey

weights to represent the entire industry.

This process is not considered a laundering process by EPA. 3

Source: 1994 Industrial Laundries Industry Questionnaire.
Chapter 4 - Industry Profile

4-14

In typical water-washing processes, the first cycle is the flush, which is defined as

any rinsing operation prior to bleaching. This cycle removes loosely attached solids and a portion

of the water-soluble soils. The next cycle is the break, during which items are treated with an

alkali solution that swells the cellulosic fibers, allowing the soil to be more readily removed. 

Detergents may also be added during the break cycle. Sudsing occurs after the break cycle and is

the cycle in which the actual washing of the items occurs. During sudsing, detergent is added in

varying concentrations and the items are agitated until they are clean. After sudsing, a bleaching

cycle may be performed, during which the detergent is replaced with a bleach solution and

agitation continues. Following the sudsing and bleaching cycles, a rinsing cycle is typically

performed, which removes the excess alkali and soap from the items. Additional chemicals are

added in the blueing/brightening cycle to whiten/brighten the items. The final operation in water

washing is the finish, which involves souring or acidifying the final bath water to a pH of 5, which

prevents the yellowing of fabrics by sodium bicarbonate during pressing.

4.3.1.2 Dual-Phase Processing

Some facilities combine the water-washing and dry-cleaning processes to wash

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

these processes are performed in series, without drying the item between the solvent and water

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

carried out is determined by the solvent used, type of soil, and drying energy requirements. 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.

4.3.1.3 Water-Washing of Mops

This process entails first water washing mops and then applying oil to the mops by

a sprayer either outside or inside the washer. This method of washing mops generates

wastewater.

4.3.2 Processes with Minimal Wastewater Discharge

There are several laundering processes that generate minimal to no wastewater. 

Dry cleaning is a processes that generates minimal amounts of wastewater. Data from the

detailed questionnaire indicate water use associated with dry cleaning typically ranges from zero

gallons of process water per pound of laundry processed to 0.25 gallons of process water per

pound of laundry processed. (Water use associated with water washing ranges between 1.5 and

3.6 gallons of process water per pound of laundry, for over 60 percent of the industry.) Dust

control mop treatment using only oil is the only industrial laundry process that generates no

wastewater. Each of the processes represents less than one percent of the total industry

production and is described in more detail below.
Chapter 4 - Industry Profile

4-15

4.3.2.1 Dry Cleaning

Dry cleaning involves the use of an organic solvent instead of an aqueous

detergent solution to clean laundry items. Water washing of certain items causes hydrophilic

fibers to swell and undergo dimensional changes, causing wrinkles and shrinkage that can be

avoided by the use of dry-cleaning solvents. These solvents dissolve soils at low temperatures

and under relatively mild conditions, unlike water washing, which usually involves high

temperatures and the use of harsh chemicals, such as alkalis and bleaches. The primary solvents

used by industrial laundries are perchloroethylene (“perc”) and petroleum-based solvent. Because

these solvents are typically expensive and are considered hazardous wastes, they are commonly

recycled and reused in subsequent dry-cleaning loads. During dry cleaning, the solvent becomes

contaminated with dirt, oil, and grease removed from the items processed. To minimize the

solvent contamination, industrial laundries use multiple solvent rinses to process items. As with

water washing, the first few rinses typically contain the most pollutants, and subsequent rinses

become less contaminated.

The general process steps for dry cleaning are similar to those for water washing. 

The items may be washed and dried in the same unit or washed in one unit and manually

transferred to a dryer. In the drying step, steam is injected into the unit to volatilize the solvent. 

The steam and solvent are captured in a condenser. The water/solvent mixture is transferred to a

phase separator where the solvent and water are separated. The solvent is either reused or

contract hauled off-site for disposal. The water is discharged to a POTW either with or without

pretreatment. The three major methods of dry cleaning items at industrial laundries are listed

below. 

1) Charged system: A small percentage of water and detergent (between 0.5

percent and 4 percent) is added to the dry-cleaning solvent. The water and

detergent concentration in the solvent is maintained throughout the

washing processes by using conductivity meters to control the addition of

water and detergent automatically.

2) Fresh soap added to each load: A given amount of soap or detergent is

added at the beginning of each load; no additional detergent is added

during the cleaning cycle. Because the process is not monitored as closely

as the charged system, excess water, soap, and energy may be expended

with this system.

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

4.3.2.2 Oil Treatment of Dust Mops

At some facilities, dust mops are not water-washed but are cleaned and treated

with heated oil instead of water. After cleaning, the oil is extracted from the mops, leaving them

coated with the desired quantity of treatment oil. The dirty oil is then purified by filtration and is

reused. This is a closed-loop processing system that uses no process water.
Chapter 4 - Industry Profile

4-16

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 (including sodium hypochlorite

and hydrogen peroxide);

C Bleach - to brighten the items (including sodium sulfites);

C Antichlor - to remove excess bleach from the items;

C Sour - to reduce the pH of the water to prevent yellowing of the items

(including acetic acid and sodium silica fluorides); 

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 1,000 pounds of

laundry for the items laundered in the greatest amounts. Buffing pads, filters, shop towels, and

printer towels require on average the highest amounts of detergent per pound of laundry, whereas

health-care items and floor mats require significantly less detergent per pound of laundry.

4.4 Facilities and Equipment

Table 4-8 presents the history of industrial laundries construction and startup from

before 1940 to 1995. Facility construction refers to the year the building that the facility operates

in was built. Facility startup refers to the year that actual industrial laundry processing began. As

shown in the table, construction of laundries has fluctuated to some degree over the years. In the

1940s, construction of facilities dipped, then rose in the 1960s, and has declined somewhat into 
Chapter 4 - Industry Profile

4-17

Table 4-6

Industrial Laundering Wash Formula Chemicals

Reported in the Detailed Questionnaire

Type of Chemical Chemical (gal/yr) (lb/yr)

Estimated Total Estimated 

Number of Amount Total Estimated

Facilities Adding Added Amount Added 

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 1

total amounts added per year do not necessarily represent the total industry chemical use. In the detailed questionnaire,

facilities were given the choice of reporting the amount of a chemical in either pounds per year or gallons per year. 

This category includes chemicals such as pH adjustors, lubricants, fabric coatings, emulsifiers, dispersants, and 2

desizers.

Source: 1994 Industrial Laundries Industry Questionnaire.
Chapter 4 - Industry Profile

4-18

Table 4-7

Amounts of Detergent Added Per 1,000 Pounds of Laundry

 for Items Most Often Laundered

Item Pounds of Laundry Laundry 1

Average Gallons of Average Pounds of Detergent

Detergent Added per 1,000 Added per 1,000 Pounds of

2 2

Industrial Garments (B01) 1.66 23.5

Shop Towels, Industrial Wipers, etc. (B02) 11.2 32.2

Printer Towels (B03) 23.7 35.5

Floor Mats (B04) 0.393 5.37

Mops, Dust Cloths, Tool Covers, etc. (B05) 2.59 21.3

Linen Garments (B06) 2.23 21.2

Linen Flatwork/Full Dry (B07) 1.77 22.8

Health-Care Items (B08) 0.575 8.98

Fender Covers (B09) 1.89 23.0

Continuous Roll Towels (B10) 1.23 14.2

Clean Room Garments (B11) 2.99 12.3

Other (B13) 0.500 ---

Laundry Bags (B14) --- 20.2

Family Laundry (B15) 0.667 12.4

New Items (B17) 0.696 6.05

Executive Wear (B18) 1.36 8.65

Miscellaneous NOG (not our goods) (B19) 7.71 ---

Rewash Items (B20) --- 31.4

Filters (B23) --- 48.6

Buffing Pads (B24) 48.9 ---

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. 

Source: 1994 Industrial Laundries Industry Questionnaire.
Chapter 4 - Industry Profile

4-19

Table 4-8

Age of Facilities and Startup of Laundry/Dry-Cleaning Operations

(Estimated Percentage of Total Facilities in Each Time Period)

Time Period Constructed Operations

Estimated Number of Facilities Starting Laundry or Dry-Cleaning

1

Estimated Number of Facilities

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 (including three facilities that were later determined to be out-of-scope because they

process only clean room items).

Totals may not equal 100% due to rounding. 2

Source: 1994 Industrial Laundries Industry Questionnaire.
Chapter 4 - Industry Profile

4-20

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

construction time periods.

Industrial laundries typically operate five days per week with one or two shifts per

day. Based on information provided in responses to the detailed questionnaire, the average

number of operating hours per day is 11 (the range is 5 to 24 hours) and the average number of

operating days per year is 261 (the range is 203 to 365 days).

The types of laundering equipment used at these facilities include washing

equipment, drying equipment, and finishing equipment. In addition, some facilities have machines

specially designed to launder specific items, such as continuous roll towels, mats and rugs, and

mops. The most common types of washing equipment used in the industry are washers,

extractors, washer-extractors, tunnel washers, and dry-cleaning units; descriptions of these five

equipment types are provided below.

4.4.1 Washers, Extractors, and Washer-Extractors

Washers in industrial laundries wash and rinse items without removing excess

water. Extractors remove excess rinse water from items after laundering or, in some cases, 

remove excess liquids from dirty items. Some washers automatically deposit the wash load into

adjacent extractors, but others must be emptied manually at the completion of the washing cycle

and the laundry transferred into an extractor. Washer-extractors come equipped with an internal

extractor where both the washing and extraction of excess liquids occurs in one machine. 

Conventional washers used in industrial laundries can handle loads of 15 to 1,200

pounds, as reported by facilities responding to the detailed questionnaire. The average capacity

reported by facilities in the detailed questionnaire is 421 pounds per load. A conventional washer

consists of a perforated horizontal cylinder rotating in a shell. The cylinder is equipped with ribs

that lift the items as the cylinder rotates and drops them back into the washing solution. 

Conventional washers are traditionally equipped with thermometers for temperature control,

gauges for control of water levels, timers, and devices to reverse the direction of rotation every

four or five revolutions.

4.4.2 Tunnel Washers

Tunnel washers are washers that operate in a continuous mode. In a tunnel

washer, the items move forward through the washer by an “Archimedes screw” arrangement. 

Rinse water at the discharge end of the washer is recycled back to the first section of the washer. 

Water, steam, and laundry chemicals are mechanically injected into the washer, and, following

washing, the load is moved by conveyer to extractors and dryers. 

4.4.3 Dry-Cleaning Units

Dry-cleaning units are similar to those used in water washing, except that the

fabrics are cleaned in an organic solvent instead of a detergent solution. Standard dry-cleaning

equipment consists of a rotating cylinder in a stationary shell and one or more solvent storage
Chapter 4 - Industry Profile

4-21

tanks, a filter system for cleaning the solvent as it is used, a solvent/water separator, distillation

equipment for solvent purification, and often a device for recovering solvent vapors (a condenser

or an activated carbon filter). The water separated from the solvent is discharged with other

process wastewater. 

4.4.4 Equipment Use and Age

Tables 4-9 and 4-10 present information on the types of laundry process

equipment reported by industrial laundries and the age of this equipment, respectively. As shown

in Table 4-9, 95 percent of the facilities have washer-extractors and 42 percent of the facilities

own separate washers and extractors. Overall, separate washers and extractors are slightly older

than washer-extractors. Facilities reported few tunnel washers and, of those reported, most were

purchased in the 1980s or 1990s. Most of the dry-cleaning units reported were also purchased in

the 1980s and 1990s. Table 4-10 indicates that, in 1993, 68 percent of all laundry equipment was

reported to be 15 years old or less, even though only 16 percent of the facilities were built in the

past 15 years and only 25 percent of the facilities started laundering operations in the past 15

years.

4.5 Pollution Reduction Activities

Based on the detailed questionnaire responses, extrapolated to represent the entire

industry, 503 facilities have a written pollution reduction policy. Seven hundred forty (740)

facilities of the 1,747 extrapolated facilities conduct pollution prevention activities prior to the

laundering process (preprocess activities) and 473 of these facilities conduct pollution prevention

activities during the laundering process (in-process activities). 

Tables 4-11 and 4-12 list the types of preprocess and in-process pollution

prevention activities, respectively, reported in responses to the detailed questionnaire. Chapter 6

of this document discusses these activities in greater detail. Although the detailed questionnaire

specifically requested that wastewater treatment and water reuse/reduction information not be

reported in response to these particular questions, several facilities provided this information. 

(Water reuse/reduction information was specifically requested by the detailed questionnaire in a

different section and is discussed in greater detail in Chapter 5 of this document). 

Table 4-11 shows that the preprocess pollution reduction activity that was

performed by most facilities was the refusal of items with free liquids. These items are commonly

shop towels and printer towels.

This industry has a potential to incorporate preprocess and in-process reduction

practices such as the activities presented in Tables 4-11 and 4-12. In addition, industrial laundries

have an opportunity to recycle/reuse water and conserve energy, helping to conserve natural

resources and reduce the need for end-of-pipe treatment or disposal. However, the pollution

reduction activities are so varied that identifying one set of BMPs to apply to all facilities is not

practical.
Chapter 4 - Industry Profile

4-22

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 95.5

Separate Washers (D01) 737 42.2

Separate Extractors (D03) 740 42.4

Dry-Cleaning Units (D04) 252 14.4

Tunnel Washers (D05) 39 2.23

Continuous Roll Towel (CRT) Washers (D07) 35 2.00

Closed-Loop Oil Washers (D08) 34 1.95

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 the 193 in-scope facilities, extrapolated using 2

appropriate survey weights to represent 1,747 facilities.

Source: 1994 Industrial Laundries Industry Questionnaire.
Chapter 4 - Industry Profile

4-23

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 (32.4%) 0 0 0 869 (6.0%)

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 (64.7%) 0 0 0 5,864

(45.4%) (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 Questionnaire.
Chapter 4 - Industry Profile

4-24

Table 4-11

Preprocess Pollution Reduction Activities

Activity Performing Activity Activities

Estimated Number Total Number of

of Facilities Reporting

Facilities Pre-Laundering

Estimated Percentage 

of

1

Items with Free Liquids Refused 447 26

Certain Items Refused 273 16

Miscellaneous Activities 26 1

2

Items Centrifuged to Remove Liquids 6 <1

Items Sent to Another Site with Wastewater Treatment 67 4

Steam/Air Stripping of Volatile Organics from Items 2 <1

Items Dry-Cleaned Before Water Washing 24 1

Items Presorted to Remove Objects 32 2

Percentages are estimated based on the 193 in-scope facilities extrapolated using appropriate survey weights to 1

represent the entire industry.

Miscellaneous activities include a combination of the specific activities listed in the table. 2

Source: 1994 Industrial Laundries Industry Questionnaire.
Chapter 4 - Industry Profile

4-25

Table 4-12

In-Process Pollution Reduction 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 Used 132 8

2

Liquid Injection System for Wash Chemical Addition 109 6

2

Wastewater Treatment 79 4

Improved Housekeeping 49 3

2

Improved Training of Employees 149 8

2

Water Softening 46 3

2

Equipment Modifications/Installations 43 2

Removal of Lint Before Air Venting to Atmosphere 26 1

Miscellaneous Activities 25 1

3

Reduced Fuel Consumption 6 <1

Recycling of Laundry Materials 3 <1

Percentages are estimated based on the 193 in-scope facilities extrapolated using appropriate survey weights to 1

represent the entire industry.

Data for these specific in-process pollution reduction activities were specifically requested in the detailed questionnaire. 2

Miscellaneous activities include a combination of the specific activities listed in this table. 3

Source: 1994 Industrial Laundries Industry Questionnaire.
Chapter 4 - Industry Profile

4-26

The detailed questionnaire requested data for five specific in-process pollution

reduction activities. Facilities were requested to report any additional in-process pollution

reduction activities; these activities were labeled as “other.” Based on descriptions provided by

the facilities, supplemental pollution prevention categories were then created for these “other”

activities. Table 4-12 presents data for the five activities specified in the questionnaire, as well as

for the remaining seven activities. According to responses to the detailed questionnaire, the

facilities reporting pollution prevention activities are equally distributed through all production

category sizes.

4.6 Trends in the Industry

Several business and operating trends are emerging in the industrial laundries

industry, including changes in industrial laundry processes, facility size, and pollution reduction

technologies. These trends are discussed in greater detail below.

4.6.1 Trend Away from Dry Cleaning

Based on information supplied by the industry and gathered by EPA on site visits,

EPA has determined that many facilities are moving away from dry-cleaning because of the

hazardous nature of the dry cleaning solvents and the expense of their disposal. Nineteen percent

of the facilities responding to the detailed questionnaire reported owning dry-cleaning units. In

addition, the largest percentage (45 percent) of dry-cleaning units was purchased in the 1980s;

only 39 percent of all dry-cleaning units in operation today were purchased between 1990 and

1995, as shown in Table 4-10. The facilities that do operate dry cleaning units have moved away

from perchlorethylene as a solvent and are now using petroleum-based solvents.

4.6.2 Trend of Small Facilities being Purchased by Larger Firms

In the past several years, there has been a trend toward large firms purchasing

smaller firms. Larger firms realize an economy of scale in their operations and can often offer

lower prices than smaller companies. Many smaller single-owner companies are finding it difficult

to compete with the larger multi-facility firms due to the rising costs of both washroom and

treatment equipment, the difficulty in raising capital, the utilization of new technologies, and the

requirement of more professional management (2). Because of this increased difficulty to

compete, these smaller facilities are being purchased by the larger firms.

There are many reasons that the larger firms are purchasing smaller facilities. One

of the benefits of a large firm is that they have the capability to offer many specialized laundering

services, (e.g., laundering of clean room items). In essence, the larger firms are more diversified

and thus have the capability to process laundry and treat the wastewater generated from a variety

of customers. A 1997 analysis showed that the largest five firms controlled about 55 percent of

the market (2). 
Chapter 4 - Industry Profile

4-27

4.6.3 Trends in Equipment and Technologies

The industry as a whole is moving towards automation in the washing, drying,

folding, and packaging of items laundered. This includes practices ranging from installing

automatic detergent dispensers in the washers to purchasing washer-extractors instead of separate

washers and extractors. Another trend is the installation of tunnel washers; these washers have a

built-in “reuse cycle” where the final rinse water is automatically cycled back to the first rinse. 

The use of these washers lowers the average water used per pound of item laundered and thus

saves the facilities money.

 The preprocess pollution prevention activities reported by facilities responding to

the detailed questionnaire were initiated primarily in the late 1980s to 1994. The trend within the

industry appears to be to continue and increase pollution prevention activities. Some of these

pollution prevention activities include the installation of more efficient washers and extractors,

detergents that allow for lower wash temperatures and a lower pH for the removal of oils and

grease from the items which may result in lower residual solids volume and less energy use.

Chapter 6 of this document discusses pollution prevention practices in more detail.

4.7 Treatment Technologies in Use

The principal types of wastewater treatment reported by industrial laundries in the

detailed questionnaire include gravity settling, screens, equalization/neutralization, air flotation,

clarification, and oil/water separation. Chapter 6 of this document discusses wastewater

treatment technologies used by the industry in greater detail.

4.8 Industry Definition

One of the steps in developing the proposed pretreatment standards and the final

action for the industrial laundries industry was to define the scope of the industry. EPA reviewed

data collected from responses to the detailed questionnaires, during site and sampling visits to

industrial laundries, and in previous Agency efforts to regulate this industry to define the scope of

the industry. 

Initially, EPA reviewed laundry processes and associated water use and

wastewater discharge practices to determine if facilities that used and/or discharged little or no

water could be eliminated from the scope of the industry. Processes generating minimal or no

wastewater would have little to no pollutants being discharged into the wastewater stream

requiring control. Based on the data collected by EPA, 97 percent of all laundering performed by

industrial laundries is water washing. As discussed in this Chapter and Chapter 5, industrial

laundry treated by oil-only dust control mop treatment generates no wastewater. Therefore, EPA

excluded oil-only dust control mop treatment from the scope of the industry. Industrial laundry

treated by dry cleaning generates little wastewater (ranging from zero gallons per pound of

laundry processed to 0.25 gallons per pound of laundry processed). Because this process

generates an insignificant amount of wastewater, EPA excluded it from the scope of the industry. 

Only water-washing laundering processes are included in the scope of the industry. In addition,

one facility reported dyeing of new items. EPA does not consider dyeing of new items to be a
Chapter 4 - Industry Profile

4-28

laundering process; therefore, it is also excluded from the scope of the industry. Dyeing of used

textile items such as shop and printer towels/rags, which is often performed as part of the washing

process, is included in the scope of the industry. 

EPA looked at the types of items that were water-washed to determine if any

specific items should be excluded from the scope. EPA performed a statistical comparison of raw

wastewater from facilities laundering primarily linen items and raw wastewater from facilities

laundering primarily industrial laundry items. EPA also performed a statistical comparison of raw

wastewater from facilities laundering primarily linen items and raw wastewater from facilities

performing denim prewashing. A summary of the statistical comparison is presented below and a

detailed discussion is presented in the Statistical Support Document (1).

Data from EPA’s sampling program and the detailed monitoring questionnaire

(DMQ) were used in comparing raw linen wastewater to raw industrial laundry wastewater. EPA

used data from facilities processing between 60 and 99 percent linen items to represent raw linen

wastewater; EPA did not have data available for facilities processing 100 percent linen items. 

EPA first performed a statistical analysis of the linen wastewater data and a statistical analysis of

the industrial laundry wastewater data to determine whether the data were statistically different. 

If data for a pollutant were determined to be significantly different among the linen wastewater

data or among the industrial laundry wastewater data, that pollutant was not included in the

comparison. Based on this analysis, a comparison of linen wastewater data and industrial laundry

wastewater data could be performed for eight pollutants. These pollutants and the results of the

comparison are shown in Table 4-13. Table 4-13 shows that industrial laundry raw wastewater

concentrations are significantly different from linen raw wastewater concentrations for all eight

pollutants. Also, the industrial laundry wastewater mean concentration is consistently at a

significantly higher value than the linen wastewater mean concentration for all eight pollutants. 

Although the linen facilities were processing less than 100 percent linen, EPA assumes that the

results of the statistical comparison would be valid if these facilities were processing 100 percent

linen items.

Data from EPA’s sampling program, the DMQ, and data obtained from a site visit

were used in comparing raw linen wastewater to raw denim prewash wastewater. Raw denim

prewash wastewater data were available for only one facility. EPA performed a statistical analysis

of the linen wastewater data to determine whether the data were statistically different. Based on

this analysis, a comparison of linen wastewater data and denim prewash wastewater data could be

performed for seven pollutants. These pollutants and the results of the comparison are shown on

Table 4-14. Table 4-14 shows that raw linen wastewater concentrations are significantly higher

than raw denim prewash wastewater concentrations for cadmium, chromium, and copper, but the

concentrations are similar for the other five pollutants.

Based on the results of the statistical analyses and the relatively low pollutant

concentrations found in linen and denim prewash wastewater, EPA decided to exclude linen and

denim prewash items from the scope of the industrial laundries industry.
Chapter 4 - Industry Profile

4-29

Table 4-13

Comparison of Linen Facility and Industrial Laundry Facility Mean Pollutant

Log Concentrations

Analyte Facility Size Concentration (mg/L) P-value a=0.01?

Type of Sample Mean log Concentration Significant at

Mean

TPH (as Industrial 30 6.05 425 0.0001 Yes

SGT-HEM) Laundry

Linen 5 2.64 14

Oil and Industrial 8 7.18 1310 0.0012 Yes

Grease (as Laundry

HEM) Linen 8 4.56 96

Total Industrial 34 7.10 1206 <0.0001 Yes

Suspended Laundry

Solids Linen 9 5.08 161

Cadmium Industrial 34 -2.66 .070 0.0001 Yes

Laundry

Linen 15 -4.33 .013

Chromium Industrial 34 -1.47 .230 <0.0001 Yes

Laundry

Linen 15 -3.19 .041

Copper Industrial 34 0.85 2.32 <0.0001 Yes

Laundry

Linen 15 -1.54 .21

Iron Industrial 34 3.23 25.2 <0.0001 Yes

Laundry

Linen 5 1.00 2.71

Zinc Industrial 34 1.47 4.16 <0.0001 Yes

Laundry

Linen 17 1.15 0.32

Source: U.S. Environmental Protection Agency, Statistical Support Document for Proposed Pretreatment Standards for

Existing and New Sources for the Industrial Laundries Point Source Category, EPA 821-R-97-006, Washington, DC,

November 1997.
Chapter 4 - Industry Profile

4-30

Table 4-14

Comparison of Linen Facility and Denim Prewash Facility Mean Pollutant Log

Concentrations

Analyte Facility Size (Conc) (mg/L) p-value at a=0.01?

Type of Sample Mean log Concentration Significant

Mean

Oil and Grease (as Linen 8 4.56 95 0.018 No

HEM) Denim 7 2.96 19

Prewash

Total Suspended Linen 9 5.08 161 0.021 No

Solids Denim 15 6.15 470

Prewash

Cadmium Linen 15 -4.33 0.013 0.0001 Yes

Denim 13 -5.68 0.003

Prewash

Chromium Linen 15 -3.19 0.04 0.0014 Yes

Denim 13 -4.47 0.01

Prewash

Copper Linen 15 -1.54 0.21 0.001 Yes

Denim 13 -2.85 0.06

Prewash

Iron Linen 5 1.00 2.71 0.027 No

Denim 12 -0.69 0.50

Prewash

Zinc Linen 17 -1.15 0.32 0.114 No

Denim 8 -2.87 0.06

Prewash

Source: U.S. Environmental Protection Agency, Statistical Support Document for Proposed Pretreatment Standards for

Existing and New Sources for the Industrial Laundries Point Source Category, EPA 821-R-97-006, Washington, DC,

November 1997.
Chapter 4 - Industry Profile

4-31

As part of comments on the proposed rule, EPA received data including

wastewater monitoring data on clean room items. The term “clean room items” refers to specialty

items used in particle- and static-free environments by computer manufacturing, pharmaceutical,

biotechnology, aerospace, and other industrial customers. EPA evaluated the data and

determined that the concentrations of pollutants found in clean room item wastewater were lower

than the concentrations found in wastewater from most other items defined as industrial laundry

items in the proposed rule, and the characteristics of the clean room wastewater were similar to

linen wastewater. Thus, the data support the removal of clean room items from the definition of

industrial textile items, which excludes laundering of clean room items from the scope of the

industry. The clean room data are presented in Section 17 of the Industrial Laundries

Administrative Record.

EPA also excluded on-site laundries from the applicability of the rule. The focus

of the rulemaking effort was industrial laundries that function independently of other industrial

activities that generate wastewater. EPA believes it is more appropriate to address on-site

laundry discharges at industrial facilities as part of the effluent controls from the facility as a

whole, for several reasons. First, many such facilities commingle laundry wastewater with

wastewater from other processes. Second, EPA anticipates that contaminants removed from

laundered items can best be treated with process wastewater containing similar contaminants. 

EPA has already established categorical effluent guidelines and standards for 51 industries, as

listed in Appendix B of this document. These regulations generally apply to processcontaminated wastewaters generated from the facility operations, including on-site laundering. 

For example, the OCPSF effluent guidelines control discharges from garment laundering at

OCPSF facilities. For industries not yet covered by effluent limitations guidelines and standards,

EPA will examine these industries and their wastewater treatment processes in the context of the

entire industrial facility, not just the laundering portion of the facility. Addressing on-site

laundering discharges along with other industrial discharges in an industry allows EPA to examine

all of the production and processing equipment used by the industry, all of the discharges in an

industry, all the potential wastewater treatment applicable to the industry, and all of the economic

impacts of any such national regulation for the industrial category (or subcategory) as a whole. 

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

laundries:

An industrial laundry is any facility that launders industrial textile items from off

site as a business activity (i.e., launders industrial textile items for other business

entities for a fee or through a cooperative agreement). Either the industrial

laundry or the off-site customer may own the industrial textile items. This

definition includes textile rental companies that perform laundering operations. 

Laundering in this definition means washing with water, including water washing

following dry cleaning. Laundering exclusively through dry cleaning and oil

cleaning of mops in a process that does not use any water are not included in this

definition of laundering, even if these operations are conducted by an industrial

laundry. Industrial textile items include, but are not limited to: industrial shop

towels, printer towels/rags, furniture towels, rags, uniforms, mops, mats, rugs,
Chapter 4 - Industry Profile

4-32

tool covers, fender covers, dust-control items, gloves, buffing pads, absorbents,

and filters. If any of these items are used at hotels, hospitals, or restaurants, they

are not considered industrial items. 

A facility that performs any laundering of industrial textile items is classified as an

industrial laundry, even if the facility also performs activities that are not defined as industrial

laundering. EPA does not include the following within the scope of the industrial laundries

industry: on-site laundering at industrial facilities (e.g., a chemical manufacturer that washes

employee uniforms on site), laundering of industrial textile items originating from the same

business entity (e.g., a chain of auto repair shops that operates a central laundry for items from

individual shops), and exclusively laundering linen items, clean room items, denim prewash items,

new items (i.e., items directly from the textile manufacturer, not yet used for their intended

purpose), hospital, hotel, and restaurant items or any combination of these items. However, EPA

does consider hotels, hospitals, or restaurants to be within the scope of the industrial laundries

industry if they launder industrial textile items originating from industrial facilities. Linen items

are sheets, pillow cases, blankets, bath towels and washcloths, hospital gowns and robes,

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

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

incontinence pads, and diapers. EPA intends this to be an all-inclusive list of linen items. 

4.9 References

1. U.S. Environmental Protection Agency. Statistical Support Document for

Proposed Pretreatment Standards for Existing and New Sources for the Industrial

Laundries Point Source Category. EPA-821-R-97-006, Washington, DC,

November 1997. 

2. K. Koepper. “Don’t Count Out More Public Company Acquisitions.” Industrial

Launderer. August 1997: page 24.
Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern

5-1

CHAPTER 5

WATER USE, WASTEWATER CHARACTERIZATION, 

AND POLLUTANTS OF CONCERN

5.1 Introduction

This chapter discusses water use practices for the industrial laundries industry and

presents raw wastewater characterization data for item-specific and total wastewater streams at

industrial laundries. This chapter also presents pollutants analyzed and pollutants of concern for

the industrial laundries industry. The water use data presented in this chapter are from 193

facilities responding to the 1994 Industrial Laundries Industry Questionnaire (detailed

questionnaire) that were considered in scope for the proposed rule. These facilities include three

clean room facilities that are out of scope for the final action (the industry definition is presented

in Chapter 4 of this document). Where appropriate, these data have been extrapolated using

statistically-derived survey weights to represent the entire industry. The wastewater

characterization data presented in this chapter are from EPA sampling episodes and facility self

monitoring data from the Detailed Monitoring Questionnaire (DMQ). 

The remainder of this chapter is presented as follows:

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 some

industrial laundries;

C Section 5.5 discusses the pollutants analyzed in industrial laundry

wastewater;

C Section 5.6 identifies the pollutants of concern for the industrial laundries

industry;

C Section 5.7 discusses characterization of raw wastewater by item

laundered;

C Section 5.8 discusses characterization of total, heavy, and light raw

wastewater streams; and

C Section 5.9 presents the characterization of EPA Method 1664

constituents.

C Section 5.10 presents the references used in this chapter.
Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern

5-2

5.2 Sources of Service Water and Water Use

This section provides information on sources of service water and water use

breakdown as reported by industrial laundries responding to the detailed questionnaire. 

5.2.1 Sources of Service Water at Industrial Laundries

Service water in the industrial laundries industry refers to any water used at a

facility, ranging from sanitary water to laundry process water. The primary source of service

water at industrial laundries is a water authority or municipal source. Well water is also used as

service water at some facilities. None of the industrial laundries that responded to the detailed

questionnaire reported surface water as the direct intake source of their service water. Table 5-1

presents the sources of service water for the industrial laundries industry; these data have been

extrapolated to represent the entire industry.

5.2.2 Use of Service Water at Industrial Laundries

Industrial laundries use service water for a variety of purposes. Table 5-2 presents

the various uses of service water, the number of facilities reporting each use, and the percentage

of the total industry service water represented by each use. These amounts are based on the first

use of the service water. Water recycle/reuse is not included in Table 5-2. Table 5-2 is based on

available data from the detailed questionnaire extrapolated to represent the entire industrial

laundries industry. 

Laundry Process Water Use

The majority of service water is used for laundry processes. As discussed in

Chapter 4 of this document, the laundering processes that use water and generate wastewater

include:

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

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 facilities that were in scope for the proposed rule 1

(including three clean room facilities determined to be out of scope for the final action), extrapolated to represent the

entire industrial laundries industry.

Source: 1994 Industrial Laundries Industry Questionnaire.
Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern

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 facilities that 1

were in scope for the proposed rule (including three clean room facilities determined to be out of scope for the final

action), extrapolated to represent the entire industrial laundries industry. The number of facilities reporting each service

water use is based on the first use of the service water; recycle/reuse is not included in Table 5-2. One facility reported

using service water first as noncontact cooling water, then as process water. This facility has a survey weight of 2.

Source: 1994 Industrial Laundries Industry Questionnaire.
Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern

5-5

The amount of process water used at a facility is most directly related to the

quantity of items laundered. Figure 5-1 shows the distribution of facilities by amount of laundry

process water used per pound of laundry processed. Water used in laundry processing comprises 

the service water that is allocated to laundry processing, the process water that is reused before

and/or after wastewater treatment, and the water from other processes that is reused as laundry

process water (e.g., noncontact cooling water). This water use was normalized to account for all

laundry production from processes that generate wastewater. The average amount of wastewater

discharged per pound of laundry processed is 2.74 gallons per pound. Over 86 percent of the

industry uses between 1 and 4 gallons of process water per pound of laundry that is waterwashed.

Water use is also related to type of item laundered. An analysis of item-specific

water use per pound of laundry processed (gal/lb) was conducted using data from facility

responses to the detailed questionnaire. Table 5-3 presents the item-specific water use in gallons

of water per pound of laundry (gal/lb) by process. These amounts were calculated from

information provided in the wash formulas reported by facilities in the detailed questionnaire. For

most items, EPA calculated a median water use ranging from 2.40 to 3.30 gal/lb. Denim

prewashing of new items requires the highest use of water with a median value of 5.40 gal/lb. 

Water washing of buffing pads requires the least amount of water (0.50 gal/lb), but this amount is

based on information from only one facility. 

Other Industrial Laundry Water Uses

Although most of the incoming service water used at industrial laundries (92.1

percent) is used as laundry process water, there are a number of other service water uses, as

presented in Table 5-2. After laundry process water, sanitary water accounts for the second

largest amount (3.1 percent) of total service water used at industrial laundries. Boiler water

accounts for the third most significant use of service water (1.8 percent), followed by noncontact

cooling water (1.4 percent). Noncontact cooling water includes water used in evaporative

coolers and other heat exchangers. Approximately 95 percent of the facilities that reported

noncontact cooling water use recycle their noncontact cooling water. In many instances, the

recycled water is used as laundry process water. Other uses of service water at industrial

laundries include vehicle washing, floor/equipment washing, and water used in wastewater

treatment systems. These uses each represent less than one percent of the total service water used

at industrial laundry facilities.

5.3 Wastewater Volume by Type of Discharge

All of the 193 facilities responding to the detailed questionnaire were considered in

scope for the proposed rule. None of the facilities reported discharging laundry process

wastewater or noncontact cooling water directly to surface water. Residual wastewater found in

the sludge and oil wastes generated during wastewater pretreatment is also not discharged

directly, but disposed of off site or land applied. Table 5-4 presents process wastewater discharge

practices reported by the facilities that responded to the detailed questionnaire. 
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)

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

Based on responses to the detailed questionnaire from the 193 facilities that were in scope for the proposed rule (including three clean room facilities determined to be 1

out of scope for the final action), extrapolated to represent the entire industrial laundries industry.

5-6

Figure 5-1. Distribution of Facilities by Production-Normalized Laundry Process Water Use1
Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern

5-7

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 --- 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 --- 1

Laundry Bags (B14) A01 1.45 1.45 0.45 2

Family Laundry (B15) A01 3.35 3.05 1.28 6
5-8

Table 5-3 (Continued)

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

Item Process (gal/lb) (gal/lb) (gal/lb) Facilities in Calculations 2 3

Mean Median Deviation Estimated Number of

Standard

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 --- 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 --- 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 1

performed using data from 193 facilities that were in scope for the proposed rule (including three clean room facilities determined to be out of scope for the final

action); the data were not extrapolated to represent the entire industry. The ratios for each formula at a facility were calculated and the ratios were averaged for each

item/process combination at individual facilities. The number of times the formula was used per day was taken into account. The facility-specific ratios were then

used to calculate an industry mean and median gallon/pound ratio for each item/process combination. There were no usable data to calculate the water use

requirements for absorbents, clean wipes, or airline carpet and seat covers.

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

5-9

Table 5-4

Discharge Practices of Industrial Laundries1

Discharge Practice (Percent of Facilities) (Percent of Facilities)

Estimated Number of

Facilities Discharging Estimated Number of

Laundry Process Facilities Discharging

Wastewater Noncontact Cooling 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 193 facilities that were in scope for the proposed rule (including 1

three clean room facilities that were determined to be out of scope for the final action), extrapolated to represent the

entire industrial laundries industry.

Source: 1994 Industrial Laundries Industry Questionnaire
Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern

5-10

Figure 5-2 shows the distribution of facilities by amount of laundry process

wastewater discharged per pound of laundry processed. The total wastewater discharged

comprises the laundry process wastewater that is discharged to a POTW, the laundry process

wastewater that is land applied, and the laundry process wastewater that is shipped off site for

disposal. This calculated wastewater discharge was normalized for all laundry production from

processes that generate wastewater. Over 60 percent of the facilities discharge between 1.5 and

3.5 gallons of process wastewater per pound of laundry that is water-washed. 

A comparison of the values in Figures 5-1 and 5-2 shows that more laundry

process water is used than is discharged. This difference is due to evaporation losses and laundry

process wastewater recycle/reuse before and after wastewater treatment. (The average

evaporation loss reported by facilities in the detailed questionnaire was approximately 10 percent. 

For 81 percent of the facilities, the difference between laundry process water use and discharge is

less than 0.5 gal/lb. Most of the reported amounts of laundry process wastewater discharged are

estimates; less than 15 percent of the facilities measure the amount of wastewater that is

discharged at their facilities.

5.4 Water Conservation Measures

Approximately 85 percent of the facilities that responded to the detailed

questionnaire reported performing some type of water conservation practice. Table 5-5 presents

activities that were reported as standard water conservation techniques at industrial laundries. 

Table 5-5 also presents the reported water use reduction due to implementation of these

conservation practices. As shown in the table, prompt attention to faulty equipment, leaks, and

other problems is practiced by the greatest number of laundries, followed by routine monitoring of

water use. Chapter 6 provides additional information on wastewater recycle/reuse.

5.5 Pollutants Analyzed in Industrial Laundry Wastewater

EPA collected data to determine the conventional, priority, and nonconventional

pollutants to be regulated for the industrial laundries proposed rule. Conventional pollutant

parameters are defined in section 304(a)(4) of the Clean Water Act (CWA) and in 40 CFR Part

401.16 and include biochemical oxygen demand (BOD ), total suspended solids (TSS), total 5

recoverable oil and grease, pH, and fecal coliform. These pollutants are subject to regulation as

specified in sections 301(b)(2)(E) and 304(b)(4)(B) of the CWA. Toxic or priority pollutants are

defined in section 307(a)(1) of the CWA. The list of priority pollutants, presented in Table C-1 in

Appendix C of this document, consists of 126 specific pollutants listed in 40 CFR Part 423,

Appendix A. Sections 301(b)(2)(C) and 304(b)(2)(B) of the CWA authorize EPA to regulate

priority pollutants. Nonconventional pollutants are those that are neither priority pollutants or

conventional pollutants. Sections 301(b)(2)(F), 301(g), and 304(b)(2)(B) of the CWA give EPA

the authority to regulate nonconventional pollutants.

EPA considered four conventional, 98 priority, and 213 nonconventional organic,

metal, and elemental pollutant parameters for potential control for the industrial laundries

industry. Three hundred twelve (312) of these pollutants are listed in The Industrial 
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)

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

Based on responses to the detailed questionnaire from the 193 facilities that were in scope for the proposed rule (including three clean room facilities determined to be 1

out of scope for the final action), extrapolated to represent the entire industrial laundries industry.

5-11

Figure 5-2. Distribution of Facilities by Production-Normalized Laundry Process Wastewater Discharge1
Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern

5-12

Table 5-5

Water Conservation Practices and Water Use Reduction

Water Conservation Practice (gal/day) Practice Practice

Water Number of of Total

Reduction Facilities Facilities

Range With This With This

Estimated Percentage

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 from 193 facilities that were in scope for the proposed rule, 1

extrapolated to represent entire industry. 

Source: 1994 Industrial Laundries Industry Questionnaire.
Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern

In Method 1664 (promulgated at 64 FR 263125 on May 14, 1999), EPA defines SGT-HEM as non-polar material 2

(NPM). Throughout this document and the Industrial Laundries Record, EPA refers to SGT-HEM as TPH.

5-13

Technology Division List of Analytes, which was derived from the List of Lists (1). Three

pollutants not on this list were also considered for regulation. EPA analyzed industrial laundry

wastewater for these 315 pollutants during the industrial laundries sampling program, which is

discussed in Chapter 3 of this document. Table C-2 in Appendix C lists the 315 pollutants

analyzed by EPA in industrial laundry wastewater during this sampling program. EPA used data

collected from seven industrial laundries during the period of 1993-1996 for selecting pollutants

of concern. 

EPA used EPA Method 1664 to analyze oil and grease and total petroleum

hydrocarbons because the other approved methods (EPA Methods 413.1, 413.2, and 415.1) use

freon, which is being phased out of use in EPA’s CWA and RCRA programs. Method 1664

measures oil and grease as hexane extractable material (HEM) and measures TPH as silica gel

treated hexane extractable material (SGT-HEM) .

2

Several conventional and priority pollutants were not considered for regulation for

the industrial laundries industry based on the following: information collected during the 1985-

1987 industrial laundries sampling program, described in Chapter 3; information collected from

the Detailed Monitoring Questionnaire (DMQ), described in Chapter 3; and EPA's knowledge of

industrial laundry wastewater. The DMQ was sent to 37 facilities selected from respondents to

the 1994 Industrial Laundries Industry Questionnaire. The DMQ recipients submitted monitoring

data collected at their facility during 1993. 

EPA did not consider the following conventional and priority pollutants for

regulation for the industrial laundries industry:

C Fecal coliform;

C Asbestos;

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

C Twenty-five (25) pesticides and PCBs (pollutants 89 through 113 on Table

C-1 in Appendix C); and

C Cyanide.

EPA does not expect fecal coliform bacteria to be present in industrial laundry

wastewaters because the laundering chemicals added to laundry process water and the

temperature of the water will likely destroy fecal coliform that may have been present on

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

5-14

EPA does not expect asbestos to be present in industrial laundry wastewaters

because it is not expected to be present on items laundered by industrial laundries or generated

during the washing process. 

EPA does not expect dioxins and furans, including 2,3,7,8-TCDD, to be present

on industrial laundry items and EPA does not expect dioxins and furans to be formed during

industrial laundry processes. Dioxins and furans were not detected in available industrial laundry

wastewater samples collected during three sampling episodes during the 1985-1987 sampling

program (dioxins and furans were not analyzed for during the other two episodes). One facility

responding to the DMQ questionnaire submitted data for 2,3,7,8-TCDD; this compound was not

detected at the facility. A review of POTW permits for 92 industrial laundries indicated that none

of the permits includes limits for dioxins and furans.

EPA did not consider PCBs for regulation because PCBs were not detected in

available industrial laundry wastewater samples from four sampling episodes during the 1985-

1987 sampling program (PCBs were not analyzed for during one other episode). Four facilities

responding to the DMQ submitted data for up to seven PCBs; PCBs were not detected at any of

the four facilities. A review of publicly owned treatment works (POTW) permits for 92 industrial

laundries indicated that only one of the permits includes limits for PCBs.

EPA did not consider any pesticides for regulation because most of the priority

pollutant pesticides were detected in less than 10 percent of available industrial laundry

wastewater samples and the presence of pesticides in industrial laundry wastewater is a sitespecific issue related to a particular customer base. Pesticides are best addressed through caseby-case review of specific circumstances rather than a national regulation. Industrial laundry

wastewater was analyzed for pesticides at four facilities during the 1985-1987 sampling program.

In addition, 10 DMQ facilities submitted pesticide data. Of the 18 priority pollutant pesticides,

the following three pesticides were detected in 10 percent or greater of industrial laundry

wastewater samples:

C Heptachlor (10 percent);

C delta-BHC (14 percent); and

C Endosulfan sulfate (14 percent).

Heptachlor was detected at 2 facilities (sampled at 14 facilities), delta-BHC was

detected at 2 facilities (sampled at 11 facilities), and endosulfan sulfate was detected at 4 facilities

(sampled at 11 facilities). Endosulfan sulfate and dieldrin were the only priority pollutant

pesticides detected at concentrations greater than 0.1 mg/L, and detections at these

concentrations occurred at only one facility of 11 facilities sampled for each pesticide. Also,

review of POTW permits for 92 industrial laundries indicated that only one of the permits includes

limits for pesticides.

EPA did not consider cyanide for regulation because cyanide was detected at most

facilities at insignificant concentrations. Cyanide was analyzed at five facilities during the 1985-

1987 sampling program, and 16 DMQ facilities submitted cyanide data. Only two of these

facilities reported detected concentrations of cyanide greater than 1 mg/L and only one of these
Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern

5-15

facilities had an average detected concentration greater than 1 mg/L. Cyanide was not detected at

five facilities, and cyanide was detected at average concentrations of less than 0.1 mg/L at eight

facilities. The maximum contaminant level for cyanide, as established in the National Primary

Drinking Water Regulations (40 CFR Part 141), is 0.2 mg/L, as free cyanide. Only one DMQ

facility reported an average cyanide concentration greater than 0.2 mg/L. This facility did not

report the analytical method used. Two facilities from the 1985-1987 sampling program had

average cyanide concentrations greater than 0.2 mg/L, but these concentrations were measured as

total cyanide.

5.6 Identification of Pollutants of Concern

In assessing the 315 pollutant parameters analyzed during the 1993-1996 industrial

laundries sampling program, EPA used the following criteria to identify pollutant parameters of

concern. EPA reduced the list of 315 pollutants to 72 pollutants for further consideration using

the following criteria:

C Pollutants never detected in any samples collected during seven sampling

episodes during the 1993-1996 industrial laundries sampling program. 

Table 5-6 lists the 175 pollutants meeting this criterion.

C Pollutants detected in less than 10 percent of samples collected during

seven sampling episodes during the 1993-1996 industrial laundries

sampling program. Table 5-7 lists the 50 pollutants meeting this criterion. 

C Pollutants identified during screening, but not quantified due to a lack of an

acceptable analytical method. EPA used analytical Method 1620 (ICP) to

quantitate certain metals and elemental pollutants. Eight metal and

elemental pollutants that were detected in industrial laundry samples

greater than 10 percent of the time were not analyzed in a quantitative

manner. Analyses for these pollutants were not subject to the quality

assurance/quality control (QA/QC) procedures required by analytical

Method 1620. These results were used for screening purposes only and the

metals and elements detected were excluded from the pollutants of concern

because they are not quantified. Table 5-8 lists these metal pollutants.

C Pollutants detected in source water at comparable concentrations to

industrial laundry raw wastewater. Three nonconventional metal pollutants

(calcium, magnesium, and sodium) were excluded because EPA believes

that these pollutants are not present in industrial laundry wastewater at

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

5-16

Table 5-6

Pollutants Not Detected in Any Samples Analyzed during the 

1993-1996 Industrial Laundries Sampling Program

Pollutant Class Code Pollutant Class Code

Acenaphthene TXO Vinyl Chloride TXO

Acenaphthylene TXO 1,1,2-Trichloroethane TXO

Anthracene TXO 1,2-Dichlorobenzene TXO

Benzidine TXO 1,2-Dichloropropane TXO

Benzo(a)anthracene TXO 1,2,4-Trichlorobenzene TXO

Benzo(a)pyrene TXO 1,3-Dichlorobenzene TXO

Benzo(b)fluoranthene TXO 1,4-Dichlorobenzene TXO

Benzo(ghi)perylene TXO 2-Chloronaphthalene TXO

Benzo(k)fluoranthene TXO 2,4-Dinitrotoluene TXO

Bis(2-chloroisopropyl)ether TXO 3,3'-Dichlorobenzidine TXO

Bromomethane TXO 4-Bromophenyl Phenyl Ether TXO

Chloroethane TXO 4-Chlorophenylphenyl Ether TXO

Chloromethane TXO Aniline, 2,4,5-Trimethyl NCO

Chrysene TXO Aramite NCO

Di-n-propylnitrosamine TXO Benzanthrone NCO

Dibenzo(a,h)anthracene TXO Benzenethiol NCO

Fluoranthene TXO Benzonitrile, 3,5-dibromo-4- NCO

hydroxyFluorene TXO Beta-Naphthylamine NCO

Hexachlorobenzene TXO Biphenyl, 4-Nitro NCO

Hexachlorobutadiene TXO Carbazole NCO

Hexachlorocyclopentadiene TXO Carbon Disulfide NCO

Hexachloroethane TXO Chloroacetonitrile NCO

Indeno(1,2,3-cd)pyrene TXO cis-1,3-Dichloropropene NCO

N-Nitrosodimethylamine TXO Crotonaldehyde NCO

Nitrobenzene TXO Crotoxyphos NCO

Pyrene TXO Dibenzothiophene NCO

Tribromomethane TXO Dibromomethane NCO

Diethyl Ether NCO Phenacetin NCO

Diphenyldisulfide NCO Phenothiazine NCO
Table 5-6 (Continued)

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

Pollutant Class Code Pollutant Class Code

5-17

Ethane, Pentachloro- NCO Pronamide NCO

Ethyl Cyanide NCO Pyridine NCO

Ethyl Methacrylate NCO Resorcinol NCO

Ethyl Methanesulfonate NCO Squalene NCO

Ethylenethiourea NCO Thianaphthene NCO

Hexachloropropene NCO Thioacetamide NCO

Iodomethane NCO Thioxanthe-9-one NCO

Isosafrole NCO Toluene, 2,4-diamino NCO

Longifolene NCO Trans-1,4-dichloro-2-butene NCO

Malachite Green NCO Triphenylene NCO

Mestranol NCO Vinyl Acetate NCO

Methapyrilene NCO 1-Bromo-2-chlorobenzene NCO

Methyl Methanesulfonate NCO 1-Bromo-3-chlorobenzene NCO

N-Nitrosodi-N-butylamine NCO 1-Chloro-3-nitrobenzene NCO

N-Nitrosodiethylamine NCO 1-Naphthylamine NCO

N-Nitrosomethylethylamine NCO 1-Phenylnaphthalene NCO

N-Nitrosomethylphenylamine NCO 1,1,1,2-Tetrachloroethane NCO

N-Nitrosopiperidine NCO 1,2-Dibromo-3-chloropropane NCO

N,N-Dimethylformamide NCO 1,2-Dibromoethane NCO

o-Anisidine NCO 1,2,3-Trichlorobenzene NCO

o-Toluidine NCO 1,2,3-Trichloropropane NCO

o-Toluidine, 5-Chloro- NCO 1,2,3-Trimethoxybenzene NCO

p-Chloroaniline NCO 1,2,4,5-Tetrachlorobenzene NCO

p-Dimethylaminoazobenzene NCO 1,2,3,4-Diepoxybutane NCO

p-Nitroaniline NCO 1,3-Butadiene, 2-Chloro NCO

Pentachlorobenzene NCO 1,3-Dichloro-2-propanol NCO

Perylene NCO 1,3-Dichloropropane NCO

1,3,5-Trithiane NCO Bismuth NCM

1,4-Dinitrobenzene NCO Cerium NCM

1,4-Naphthoquinone NCO Dysprosium NCM

1,5-Naphthalenediamine NCO Erbium NCM

2-(Methylthio)benzothiazole NCO Europium NCM
Table 5-6 (Continued)

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

Pollutant Class Code Pollutant Class Code

5-18

2-Isopropylnaphthalene NCO Gadolinium NCM

2-Methylbenzothioazole NCO Gallium NCM

2-Nitroaniline NCO Germanium NCM

2-Phenylnaphthalene NCO Gold NCM

2-Picoline NCO Hafnium NCM

2-Propen-1-ol NCO Holmium NCM

2-Propenenitrile, 2-Methyl- NCO Indium NCM

2,3-Benzofluorene NCO Lanthanum NCM

2,3-Dichloronitrobenzene NCO Lutetium NCM

2,3,4,6-Tetrachlorophenol NCO Neodymium NCM

2,6-Di-tert-butyl-p-benzoquinone NCO Niobium NCM

2,6-Dichloro-4-nitroaniline NCO Osmium NCM

2,6-Dichlorophenol NCO Palladium NCM

3-Chloropropene NCO Platinum NCM

3-Methylcholanthrene NCO Praseodymium NCM

3-Nitroaniline NCO Rhenium NCM

3,3'-Dimethoxybenzidine NCO Rhodium NCM

3,6-Dimethylphenanthrene NCO Ruthenium NCM

4-Aminobiphenyl NCO Samarium NCM

4-Chloro-2-nitroaniline NCO Scandium NCM

4,4'-Methylenebis(2-chloroaniline) NCO Tantalum NCM

4,5-Methylene Phenanthrene NCO Tellurium NCM

5-Nitro-o-toluidine NCO Terbium NCM

7,12-Dimethylbenz(a)anthracene NCO Thorium NCM

Thulium NCM Ytterbium NCM

Tungsten NCM Zirconium NCM

Uranium NCM

NCM - Nonconventional metal or element.

NCO - Nonconventional organic.

TXO - Toxic organic.
Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern

5-19

Table 5-7

Pollutants Detected in Less Than 10 Percent of Samples Analyzed During the

1993-1996 Industrial Laundries Sampling Program

Priority Organics Nonconventional Organics

Acrylonitrile Acetophenone

Benzene Aniline

Bis(2-chloroethoxy)methane Biphenyl

Bis (2-chloroethyl)ether Dibenzofuran

Bromodichloromethane 2,3-Dichloroaniline

2-Chloroethylvinyl ether Dimethyl sulfone

2-Chlorophenol 1,4-Dioxane

Dibromochloromethane Diphenylamine

1.1-Dichloroethane Diphenyl ether

1,2-Dichloroethane 2-Hexanone

1,1-Dichloroethene Isobutyl alcohol

2,4-Dichlorophenol 1-Methylfluorene

Diethyl phthalate 1-Methylphenanthrene

2,4-Dimethylphenol Methyl methacrylate

Dimethyl phthalate N-Nitrosomorpholine

2,4-Dinitrophenol o-Cresol

2,6-Dinitrotoluene Safrole

2-Nitrophenol Styrene

4-Nitrophenol Trichlorofluoromethane

N-Nitrosodiphenylamine 2,3,6-Trichlorophenol

Pentachlorophenol 2,4,5-Trichlorophenol

Phenanthrene Tripropyleneglycol methyl ether

Phenol,2-Methyl-4,6-Dinitro2-Propenal

1,1,2,2-Tetrachloroethane

Tetrachloromethane

Trans-1,3-Dichloropropene

2,4,6-Trichlorophenol
Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern

5-20

Table 5-8

Semiquantitative Metal and Elemental Pollutants Excluded from the Pollutants

of Concern for the Industrial Laundries Industry

Nonconventional Metals and

Elements

Iodine

Iridium

Lithium

Phosphorus

Potassium

Silicon

Strontium

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

5-21

C Pollutants likely to be regulated on a case-by-case basis by POTWs. The

following six pollutants were eliminated from the pollutant-of-concern list:

– pH: this pollutant is typically regulated as necessary by POTWs. 

pH is not considered for national regulation for the industrial

laundries industry.

– Total orthophosphate, total phosphorous, and total hydrolyzable

phosphate: Table 5-9 presents the average influent concentrations,

effluent concentrations, and percent removals for these pollutants

by both the dissolved air flotation (DAF) and chemical precipitation

treatment technologies (based on six sampling episodes between

1993-1998). These pollutants were not considered for national

regulation for the industrial laundries industry since they would be

removed incidentally by the DAF and chemical precipitation

treatment technologies.

– Surfactants (nonionic (CTAS) and anionic (MBAS)): Table 5-9

presents the average influent concentrations, effluent

concentrations, and percent removals for these pollutants by both

the dissolved air flotation and chemical precipitation treatment

technologies (based on six sampling episodes between 1993-1998). 

These pollutants were analyzed to evaluate the effect of emulsions

on treatment technologies for the industrial laundries industry. 

Surfactants are not considered for national regulation for the

industrial laundries industry since they would be removed

incidentally by the DAF and chemical precipitation treatment

technologies. 

In addition to the pollutants above, EPA eliminated total solids from further

consideration. Total solids is a measure of total dissolved solids and total suspended solids.

Industrial laundry wastewater contains both total suspended solids and total solids. Because the

measurement of total solids includes total suspended solids and because the treatment

technologies under consideration as the bases of the regulation are designed to remove the total

suspended solids but not the dissolved solids, EPA eliminated total solids from further

consideration.

Of the 315 pollutants considered for regulation, 72 were identified as pollutant

parameters of concern, including 31 priority pollutants (18 organic pollutants and 13 metal and

elemental pollutants), three conventional pollutants, and 38 nonconventional pollutants (24

organic pollutants, 11 metal and elemental pollutants, and three other nonconventional

pollutants). Table 5-10 presents these 72 pollutants, along with the number of times each

pollutant was analyzed and detected in untreated industrial laundry wastewater, and the

corresponding mean, minimum, and maximum concentrations based on data collected between

1993 and 1996 (seven facilities).
Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern

5-22

Table 5-9

Average Influent Concentrations, Effluent Concentrations, 

and Removals for Phosphorous and Surfactants by 

Chemical Precipitation or Dissolved Air Flotation Technologies

Pollutant (mg/L) (mg/L) Removal

Average Influent Average Effluent Average Percent

Chemical Precipitation

Total Hydrolyzable 75.6 9.43 88

Phosphorous

Total Orthophosphate 2.80 1.70 39

Total Phosphorous 30.8 6.83 78

Surfactants (anionic) 12.0 6.23 48

Surfactants (nonionic) 149 116 22

Dissolved Air Flotation

Total Hydrolyzable 10.8 5.15 52

Phosphorous

Total Orthophosphate 6.88 2.95 57

Total Phosphorous 21.4 8.94 58

Surfactants (anionic) 7.64 0.818 89

Surfactants (nonionic) 446 202 55
Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern

5-23

Table 5-10

Pollutants of Concern for the Industrial Laundries Industry1

Pollutant of Concern Analyzed Detected (%) Minimum Maximum Mean

Number of Number of Percent

Times Times Detected

Concentration in Untreated Wastewater (mg/L)

Conventionals

Biochemical Oxygen Demand 5-Day (BOD5) 46 46 100.00 218.00 9810.00 2343.50

Oil and Grease (measured as HEM) 48 48 100.00 71.50 11790.00 1943.92

Total Suspended Solids (TSS) 46 45 97.83 4.00 7000.00 1773.93

Priority Organics

1,1,1-Trichloroethane 48 22 45.83 0.01 156.64 4.01

1,2-Diphenylhydrazine 47 5 10.64 0.02 41.32 1.14

4-Chloro-3-methylphenol 47 8 17.02 0.01 2.06 0.14

Bis(2-ethylhexyl) Phthalate 47 43 91.49 0.04 42.01 6.80

Butyl Benzyl Phthalate 47 20 42.55 0.01 74.42 2.69

Chlorobenzene 48 8 16.67 0.01 1.41 0.08

Chloroform 48 25 52.08 0.01 1.19 0.07

Di-n-butyl Phthalate 47 20 42.55 0.01 9.98 0.73

Di-n-octyl Phthalate 47 25 53.19 0.01 2.61 0.30

Ethylbenzene 48 38 79.17 0.01 18.74 1.24

Isophorone 47 5 10.64 0.01 1.00 0.12

Methylene Chloride 48 25 52.08 0.01 16.26 0.63

Naphthalene 47 42 89.36 0.01 18.75 2.59

Phenol 47 23 48.94 0.01 0.96 0.15

Tetrachloroethene 48 35 72.92 0.01 46.22 1.97

Toluene 48 44 91.67 0.01 90.97 6.72

trans-1,2-Dichloroethene 48 1 2.08 0.01 0.10 0.03

Trichloroethene 48 7 14.58 0.01 20.00 0.48
5-24

Table 5-10 (Continued)

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

Pollutant of Concern Analyzed Detected (%) Minimum Maximum Mean

Number of Number of Percent

Times Times Detected

Concentration in Untreated Wastewater (mg/L)

Nonconventional Organics

2-Butanone 48 32 66.67 0.05 272.29 9.07

2-Methylnaphthalene 47 32 68.09 0.01 2.24 0.41

2-Propanone 48 46 95.83 0.05 603.15 20.95

4-Methyl-2-pentanone 48 26 54.17 0.05 65.27 2.65

%-Terpineol 47 17 36.17 0.01 5.20 0.33

Benzoic Acid 47 34 72.34 0.05 12.23 1.77

Benzyl Alcohol 47 21 44.68 0.01 12.52 0.81

Hexanoic Acid 47 14 29.79 0.01 1.81 0.12

m-Xylene 48 40 83.33 0.01 25.29 2.29

n-Decane 47 41 87.23 0.01 712.40 51.60

n-Docosane 47 31 65.96 0.01 3.04 0.35

n-Dodecane 47 40 85.11 0.01 105.57 14.37

n-Eicosane 47 43 91.49 0.01 84.57 4.06

n-Hexacosane 47 27 57.45 0.01 3.73 0.36

n-Hexadecane 47 43 91.49 0.01 91.57 6.70

n-Octacosane 47 21 44.68 0.01 1.44 0.19

n-Octadecane 47 42 89.36 0.01 19.36 1.92

n-Tetracosane 47 25 53.19 0.01 8.34 0.46

n-Tetradecane 47 37 78.72 0.01 41.58 4.39

n-Triacontane 47 29 61.70 0.01 1.00 0.19

o-&p-Xylene 48 40 83.33 0.01 17.80 1.59

p-Cresol 47 1 2.13 0.01 0.20 0.06

p-Cymene 47 16 34.04 0.01 19.81 1.43

Pentamethylbenzene 47 11 23.40 0.01 2.33 0.22
5-25

Table 5-10 (Continued)

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

Pollutant of Concern Analyzed Detected (%) Minimum Maximum Mean

Number of Number of Percent

Times Times Detected

Concentration in Untreated Wastewater (mg/L)

Priority Metals and Elements

Antimony 47 34 72.34 0.01 8.24 0.26

Arsenic 47 15 31.91 0.010 0.18 0.02

Beryllium 47 18 38.30 0.010 0.02 0.003

Cadmium 47 44 93.62 0.010 0.70 0.10

Chromium 47 45 95.74 0.010 7.31 0.46

Copper 47 47 100.00 0.04 14.90 3.17

Lead 47 45 95.74 0.03 23.80 1.71

Mercury 47 28 59.57 0.010 0.01 0.001

Nickel 47 45 95.74 0.01 2.87 0.27

Selenium 47 12 25.53 0.010 0.26 0.03

Silver 47 24 51.06 0.010 0.17 0.02

Thallium 47 6 12.77 0.010 0.13 0.01

Zinc 47 46 97.87 0.010 29.40 5.02

Nonconventional Metals and Elements

Aluminum 47 47 100.00 0.03 20.99 7.96

Barium 47 47 100.00 0.03 6.26 1.51

Boron 47 36 76.60 0.03 37.20 2.31

Cobalt 47 37 78.72 0.000 3.10 0.24

Iron 47 47 100.00 0.06 96.60 27.70

Manganese 47 47 100.00 0.02 1.77 0.56

Molybdenum 47 43 91.49 0.010 5.17 0.53

Tin 47 32 68.09 0.02 0.58 0.11

Titanium 47 45 95.74 0.01 1.32 0.23

Vanadium 47 31 65.96 0.010 0.19 0.04

Yttrium 47 15 31.91 0.010 0.04 0.01
5-26

Table 5-10 (Continued)

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

Pollutant of Concern Analyzed Detected (%) Minimum Maximum Mean

Number of Number of Percent

Times Times Detected

Concentration in Untreated Wastewater (mg/L)

Bulk Nonconventionals

Chemical Oxygen Demand (COD) 47 47 100.00 80.00 212000.00 12730.57

Total Organic Carbon (TOC) 47 47 100.00 106.00 37800.00 2208.32

Total Petroleum Hydrocarbon (measured as 43 43 100.00 7.00 4543.00 880.86

SGT-HEM)

Results are based on sampling data collected between 1993 and 1996 from seven industrial laundries facilities. 1
Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern

5-27

5.7 Characterization of Raw Wastewater by Item Laundered

As discussed in Chapter 4 of this document, items laundered at industrial laundries

can have significantly different pollutant loads based on item type and customer. This section

presents raw wastewater characterization data for specific items laundered for the 72 pollutants of

concern detected in industrial laundry wastewater. Table 5-11 presents for the 72 pollutants the

mean pollutant concentration by item type. Table C-3 in Appendix C of this document presents

for the 72 pollutants the minimum, maximum, and mean concentrations, as well as the number of

times each pollutant was analyzed, the number of times the pollutant was detected, and the

percentage of times the pollutant was detected, by item type based on sampling data from nine

facilities and DMQ data.

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

This section presents raw wastewater characterization data for total, heavy, and

light raw wastewater streams at industrial laundries. The heavy and light wastewater streams

were designated as such by the sampled facilities; generally, the heavy wastewater stream is

generated from laundering items with high pollutant loadings and the light wastewater stream is

generated from laundering items with low pollutant loadings. At some facilities, the heavy stream

is generated from wastewater from the first several breaks of laundering a variety of items. The

heavy stream is typically treated and combined with the untreated light stream prior to discharge

to a POTW. 

EPA sampling program data and detailed monitoring questionnaire (DMQ) data

from facilities that do not split their heavy and light wastewater streams were used to characterize

total raw wastewater streams. The total stream is then discharged, with or without treatment, to

a POTW. EPA sampling program data from facilities that split their wastewater streams were

used to characterize heavy and light wastewater streams. 

Tables 5-12 through 5-14 present for 72 pollutants of concern the mean

concentrations for heavy, light, and total raw wastewater streams based on data collected through

EPA’s sampling program (nine facilities) and data from the detailed monitoring questionnaire. 

Table C-4 in Appendix C of this document presents for the 72 pollutants of concern the minimum,

maximum, and mean concentrations, as well as the number of times the pollutant was analyzed,

the number of times the pollutant was detected, and the percentage of times the pollutant was

detected. In general, the concentrations of pollutants in heavy wastewater streams are greater

than the concentrations of pollutants in total wastewater streams, and the concentrations of

pollutants in total wastewater streams are greater than the concentrations of pollutants in light

wastewater streams.

5.9 Characterization of Method 1664 Constituents

In response to comments on the proposed rule, EPA conducted a characterization

study on wastewater generated at industrial laundries to determine the specific constituents of oil

and grease and TPH, measured using EPA Method 1664. EPA collected influent and effluent
Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern

5-28

Table 5-11

Wastewater Characterization for Item-Specific Wastewater 

at Industrial Laundries

Pollutant of Concern Garments Shop Towels Printer Towels Mats

Mean Concentration (mg/L)1

Industrial

Conventionals

Biochemical Oxygen Demand 5-Day (BOD5) 350 2,780 3,940 179

Oil and Grease (measured as HEM) 149 3,250 5,890 105

Total Suspended Solids (TSS) 304 4,450 1,250 690

Priority Organics

1,1,1-Trichloroethane 0.0400 4.13 4.50 0.860

1,2-Diphenylhydrazine 0.110 1.07 1.00 0.0200

4-Chloro-3-methylphenol 0.130 0.795 0.433 0.0100

Bis(2-ethylhexyl) Phthalate 0.838 3.63 19.0 1.70

Butyl Benzyl Phthalate 0.111 1.46 5.55 0.0350

Chlorobenzene 0.0400 0.252 0.467 0.0100

Chloroform 0.0400 0.292 0.370 0.0100

Di-n-butyl Phthalate 0.0736 0.558 3.20 0.114

Di-n-octyl Phthalate 0.0583 0.538 1.24 0.0369

Ethylbenzene 0.104 5.27 13.2 0.147

Isophorone 0.194 9.58 0.500 0.186

Methylene Chloride 0.0406 4.22 0.614 0.226

Naphthalene 0.107 2.91 9.64 0.0172

Phenol 0.0544 0.310 0.500 0.0134

Tetrachloroethene 0.0400 8.92 3.92 0.0676

Toluene 0.0486 5.33 20.5 0.654

trans-1,2-Dichloroethene 0.0400 0.367 0.371 0.0100

Trichloroethene 0.0400 0.247 0.476 0.0100

Nonconventional Organics

2-Butanone 0.200 5.40 3.09 0.314

2-Methylnaphthalene 0.102 0.826 0.836 0.0100

2-Propanone 0.226 3.98 49.7 1.10

4-Methyl-2-pentanone 0.200 1.88 2.07 0.254

%-Terpineol 0.0550 0.956 1.07 0.0463

Benzoic Acid 0.353 2.55 3.30 0.156

Benzyl Alcohol 0.132 9.26 0.500 0.0520

Hexanoic Acid 0.0962 0.305 0.433 0.0611

m-Xylene 0.0100 2.12 1.44 0.265

n-Decane 0.807 42.2 90.6 0.995

n-Docosane 0.271 1.10 0.668 0.0175

n-Dodecane 1.26 19.1 23.1 0.0654

n-Eicosane 0.471 25.1 1.29 0.0206

n-Hexacosane 0.117 1.40 2.01 0.0211

n-Hexadecane 0.602 10.0 9.51 0.0206

n-Octacosane 0.0821 0.858 0.402 0.0134
Table 5-11 (Continued)

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

Pollutant of Concern Garments Shop Towels Printer Towels Mats

Mean Concentration (mg/L)1

Industrial

5-29

Nonconventional Organics (Continued)

n-Octadecane 0.445 11.2 2.43 0.0160

n-Tetracosane 0.281 1.95 0.605 0.0394

n-Tetradecane 0.612 15.0 7.89 0.0145

n-Triacontane 0.123 0.719 0.626 0.0292

o-&p-Xylene 0.0100 1.47 1.08 0.151

p-Cresol 0.0417 0.305 0.433 0.0100

p-Cymene 0.0873 2.05 12.4 0.0100

Pentamethylbenzene 0.0550 0.534 0.500 0.0100

Priority Metals and Elements

Antimony 0.312 0.198 0.0556 0.0204

Arsenic 0.00907 0.0224 0.00313 0.00905

Beryllium 0.000605 0.000890 0.00100 0.000775

Cadmium 0.0269 0.358 0.0253 0.0147

Chromium 0.0959 0.490 2.65 0.167

Copper 0.688 6.48 11.0 1.31

Lead 0.238 6.52 8.91 0.711

Mercury 0.000395 0.00183 0.000230 0.00142

Nickel 0.0999 0.599 0.101 0.152

Selenium 0.00767 0.0145 0.0177 0.00305

Silver 0.0146 0.139 0.207 0.0168

Thallium 0.00293 0.00390 0.00767 0.00680

Zinc 1.50 13.5 3.62 2.42

Nonconventional Metals and Elements

Aluminum 4.85 13.1 8.22 10.3

Barium 0.273 4.08 4.53 0.376

Boron 0.187 1.99 0.670 0.0818

Cobalt 0.0134 0.288 0.614 0.0184

Iron 10.9 55.8 8.51 24.7

Manganese 0.148 1.09 0.898 0.318

Molybdenum 0.0213 0.382 2.10 0.0321

Tin 0.0722 0.370 0.0990 0.0938

Titanium 0.150 0.232 0.184 0.364

Vanadium 0.00707 0.0420 0.00900 0.0273

Yttrium 0.00178 0.00794 0.00570 0.00675

Bulk Nonconventionals

Chemical Oxygen Demand (COD) 1,170 13,300 16,900 515

Total Organic Carbon (TOC) 367 2,030 2,740 111

Total Petroleum Hydrocarbon (measured as SGT- 47.4 1,760 1,730 48.5

HEM)
Table 5-11 (Continued)

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

5-30

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

n-Hexacosane 0.210 0.0904 NA 0.0267

n-Hexadecane 1.07 91.6 NA 0.160
Table 5-11 (Continued)

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

Constituent Name Mops Printer Towels Washing Items

Mean Concentration (mg/L)1

Steam-Tumbled Prior to Water Linen Supply

Items Dry Cleaned

5-31

Nonconventional Organics (Continued)

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 0.0294 0.0261 NA 0.114

Arsenic 0.0102 0.00380 0.00500 0.156

Beryllium 0.00100 0.00100 NA 0.00100

Cadmium 0.0212 0.0358 0.0825 0.0219

Chromium 0.101 0.275 0.0933 0.0492

Copper 1.97 4.86 0.668 0.527

Lead 0.903 0.957 0.519 0.151

Mercury 0.00466 0.000200 0.000150 0.00165

Nickel 0.106 0.0372 0.0200 0.0771

Selenium 0.0123 0.0230 NA 0.151

Silver 0.0111 0.0653 0.00500 0.0291

Thallium 0.00620 0.0120 NA 0.00700

Zinc 3.00 2.10 0.450 0.381

Nonconventional Metals and Elements

Aluminum 9.78 2.80 NA 3.08

Barium 0.571 1.63 NA 0.301

Boron 0.190 0.0500 NA 0.0970

Cobalt 0.0360 0.202 NA 0.00990

Iron 17.9 2.62 NA 3.26

Manganese 0.358 0.277 NA 0.0812

Molybdenum 0.0612 2.64 NA 0.0263

Tin 0.0785 0.0761 NA 0.0290

Titanium 0.184 0.0178 NA 0.0654

Vanadium 0.0220 0.0221 NA 0.00990

Yttrium 0.004500 0.00500 NA 0.00470
Table 5-11 (Continued)

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

Constituent Name Mops Printer Towels Washing Items

Mean Concentration (mg/L)1

Steam-Tumbled Prior to Water Linen Supply

Items Dry Cleaned

5-32

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 nondetects. 1

NA - Not available. No data were available for this constituent.
Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern

5-33

Table 5-12

Wastewater Characterization Data for Heavy Wastewater 

Streams at Industrial Laundries

Pollutant of Concern (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 11.3

Butyl Benzyl Phthalate 8.89

Chlorobenzene 0.271

Chloroform 0.296

Di-n-butyl Phthalate 1.30

Di-n-octyl Phthalate 0.599

Ethylbenzene 3.65

Isophorone 0.207

Methylene Chloride 0.854

Naphthalene 4.76

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

%-Terpineol 0.379
Table 5-12 (Continued)

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

Pollutant of Concern (mg/L)

Mean Concentration1

5-34

Nonconventional Organics (Continued)

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 4.28

n-Hexacosane 0.354

n-Hexadecane 9.11

n-Octacosane 0.370

n-Octadecane 4.00

n-Tetracosane 0.289

n-Tetradecane 7.23

n-Triacontane 0.366

o-&p-Xylene 3.59

p-Cresol 0.204

p-Cymene 3.16

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

Silver 0.199
Table 5-12 (Continued)

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

Pollutant of Concern (mg/L)

Mean Concentration1

5-35

Priority Metals and Elements (Continued)

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 1

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

5-36

Table 5-13

Wastewater Characterization Data for Light Wastewater 

Streams at Industrial Laundries

Pollutant of Concern (mg/L)

Mean Concentration1

Conventionals

Biochemical Oxygen Demand 5-Day (BOD )5 568

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

%-Terpineol 0.123
Table 5-13 (Continued)

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

Pollutant of Concern (mg/L)

Mean Concentration1

5-37

Nonconventional Organics (Continued)

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

Silver 0.00432
Table 5-13 (Continued)

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

Pollutant of Concern (mg/L)

Mean Concentration1

5-38

Priority Metals and Elements (Continued)

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 nondetects. 1
Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern

5-39

Table 5-14

Wastewater Characterization Data for Total Raw Wastewater 

Streams at Industrial Laundries

Pollutant (mg/L)

Mean Concentration1

Conventionals

Biochemical Oxygen Demand 5-Day (BOD )5 933

Oil and Grease (measured as HEM) 1,670

Total Suspended Solids (TSS) 1,200

Priority Organics

1,1,1-Trichloroethane 0.283

1,2-Diphenylhydrazine 0.0918

4-Chloro-3-methylphenol 0.0684

Bis(2-ethylhexyl) Phthalate 4.99

Butyl Benzyl Phthalate 0.140

Chlorobenzene 0.131

Chloroform 0.0359

Di-n-butyl Phthalate 0.245

Di-n-octyl Phthalate 0.0910

Ethylbenzene 0.634

Isophorone 0.154

Methylene Chloride 0.366

Naphthalene 1.47

Phenol 0.0777

Tetrachloroethene 3.91

Toluene 2.64

trans-1,2-Dichloroethene 0.0204

Trichloroethene 0.0346

Nonconventional Organics

2-Butanone 2.51

2-Methylnaphthalene 0.166

2-Propanone 10.9

4-Methyl-2-pentanone 1.67

%-Terpineol 0.258
Table 5-14 (Continued)

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

Pollutant (mg/L)

Mean Concentration1

5-40

Nonconventional Organics (continued)

Benzoic Acid 0.648

Benzyl Alcohol 0.143

Hexanoic Acid 0.125

m-Xylene 4.35

n-Decane 73.6

n-Docosane 0.659

n-Dodecane 6.16

n-Eicosane 1.97

n-Hexacosane 0.413

n-Hexadecane 4.76

n-Octacosane 0.0853

n-Octadecane 1.78

n-Tetracosane 1.51

n-Tetradecane 4.44

n-Triacontane 0.144

o-&p-Xylene 2.48

p-Cresol 0.0585

p-Cymene 0.138

Pentamethylbenzene 0.242

Priority Metals and Elements

Antimony 0.0913

Arsenic 0.0183

Beryllium 0.00598

Cadmium 0.0641

Chromium 0.315

Copper 1.74

Lead 0.955

Mercury 0.00128

Nickel 0.305

Selenium 0.0550

Silver 0.0316
Table 5-14 (Continued)

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

Pollutant (mg/L)

Mean Concentration1

5-41

Priority Metals and Elements (continued)

Thallium 0.0190

Zinc 2.85

Nonconventional Metals and Elements

Aluminum 8.24

Barium 1.31

Boron 0.689

Cobalt 0.169

Iron 39.5

Manganese 0.627

Molybdenum 0.363

Tin 0.278

Titanium 0.251

Vanadium 0.0678

Yttrium 0.0199

Bulk Nonconventionals

Chemical Oxygen Demand (COD) 6,090

Total Organic Carbon (TOC) 1,160

Total Petroleum Hydrocarbon (measured as SGT-HEM) 682

The detection limit concentration was used in calculations for data points reported as nondetects. 1
Chapter 5 - Water Use, Wastewater Characterization, and Pollutants of Concern

5-42

samples from six facilities that operate DAF or chemical precipitation and that were previously

sampled by EPA. See Chapter 3 of this document for a description of EPA’s Method 1664

Characterization Study.

For the study, EPA analyzed wastewater samples for HEM, SGT-HEM, volatile organics, and

semivolatile organics. EPA also analyzed extracts from the HEM and SGT-HEM procedures for

volatile organics and semivolatile organics. The data from this study are in the Industrial

Laundries Administrative Record.

Volatile organics were only detected in the HEM extracts at one facility; the only volatile organics

detected in the HEM extracts were o-xylene and m-&p-xylene. Semivolatile organics were

detected in all HEM and SGT-HEM extracts. Tables 5-15 and 5-16 show, for influent and

effluent samples, respectively, the semivolatile organics detected in the extracts and the number of

detects and average concentration of the detects in the wastewater, HEM extract, and SGT-HEM

extract samples. Tables 5-15 and 5-16 also show the HEM and SGT-HEM concentrations. For

one facility, no effluent concentrations are reported because there were zero percent recoveries in

the matrix spike/matrix spike duplicate samples. The effluent results for this facility were

excluded due to matrix interference.

The analytes that were detected in the influent samples for both the HEM and SGT-HEM extracts

were 2-methylnaphthalene, bis(2-ethylhexyl) phthalate, n-decane, n-docosane, n-dodecane, neicosane, n-hexacosane, n-hexadecane, n-octacosone, n-octadecane, n-tetracosane, n-tetradecane,

and naphthalene. The highest concentrations detected in the influent samples for both the HEM

and SGT-HEM extracts were for bis(2-ethylhexyl) phthalate, n-decane, n-dodecane, nhexadecane, n-octadecane, and n-tetradecane. Only bis(2-ethylhexyl) phthalate, n-eicosane, nhexadecane, n-octadecane, and n-tetradecane were detected in the effluent samples for both the

HEM and SGT-HEM extracts. These analytes were detected in lower concentrations in the

effluent samples than in the influent samples.

Based on the characterization study, EPA was able to identify several constituents measured as

part of the SGT-HEM (TPH) parameter. Most of the constituents identified in the influent

samples were n-alkanes, as well as naphthalene, bis(2-ethylhexyl) phthalate and 2-

methylnaphthalene. The identified constituents, however, represent only a small portion of the

total SGT-HEM (TPH) measurement.

5.10 References

1. U.S. Environmental Protection Agency. List of Lists: A Catalog of Analytes and

Methods. 121W-4005. Washington, DC, August 1991.
5-43

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

Table 5-15

Summary of the Semivolatile Organic Pollutants Detected in Influent Samples during the

EPA Method 1664 Characterization Study

Pollutant Samples Samples Sample (ug/L) Samples Extracts (ug/L) Samples Extracts (ug/L)

Total of Nondetects Average Total Number of Nondetects Concentration Number of for Concentration

Number of for Pollutant Concentration of HEM for Pollutants in HEM SGT-HEM Pollutants in in SGT-HEM

Wastewater in Wastewater in Wastewater Extract in HEM Extracts Extract SGT-HEM Extracts

Total Number Total Number Average Total Nondetects Average

1

1

Total

Number of

1

HEM 6 0 1,920,000 NA NA NA NA NA NA

SGT-HEM 6 0 391,000 NA NA NA NA NA NA

1,2-Diphenylhydrazine 6 3 2,380 6 5 299 6 6 222

2-Methylnaphthalene 6 4 1,180 6 3 173 6 4 109

4-Chloro-3-methylphenol 6 3 420 6 6 111 6 6 111

Acetophenone 6 5 1,360 6 6 111 6 6 111

"-Terpineol 6 0 340 6 3 224 6 6 111

Aniline 6 6 1,340 6 6 111 6 6 111

Benzoic Acid 6 2 2,270 6 6 556 6 6 556

Benzyl Alcohol 6 2 1,090 6 6 111 6 6 111

Bis(2-ethylhexyl) 6 1 4,780 6 0 1,400 6 1 321

Phthalate

Butyl Benzyl Phthalate 6 0 299 6 1 139 6 6 111

Di-n-butyl Phthalate 6 0 912 6 3 363 6 6 111

Di-n-octyl Phthalate 6 5 1,390 6 4 232 6 6 111

Diethyl Phthalate 6 5 1,340 6 6 111 6 6 111

Diphenylamine 6 4 1,350 6 6 111 6 6 111

Fluoranthene 6 5 1,180 6 6 111 6 6 111

Fluorene 6 5 1,180 6 6 111 6 6 111
5-44

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

Table 5-15 (Continued)

Pollutant Samples Samples Sample (ug/L) Samples Extracts (ug/L) Samples Extracts (ug/L)

Total of Nondetects Average Total Number of Nondetects Concentration Number of for Concentration

Number of for Pollutant Concentration of HEM for Pollutants in HEM SGT-HEM Pollutants in in SGT-HEM

Wastewater in Wastewater in Wastewater Extract in HEM Extracts Extract SGT-HEM Extracts

Total Number Total Number Average Total Nondetects Average

1

1

Total

Number of

1

Hexanoic Acid 6 3 539 6 6 111 6 6 111

Isophorone 6 4 1,520 6 5 117 6 6 111

n-Decane 6 0 26,800 6 0 2,330 6 3 1150

n-Docosane 6 0 1,660 6 1 240 6 0 210

n-Dodecane 6 0 20,500 6 0 1,590 6 0 1180

n-Eicosane 6 0 3,720 6 0 777 6 0 705

n-Hexacosane 6 2 1,400 6 2 206 6 3 193

n-Hexadecane 6 0 9,750 6 0 1,290 6 0 1220

n-Nitrosodiphenylamine 6 4 2,680 6 6 222 6 6 222

n-Tetradecane 6 0 6,320 6 0 1,570 6 0 1400

Naphthalene 6 0 1,240 6 2 583 6 2 217

o-Cresol 6 4 1,450 6 6 111 6 6 111

p-Cresol 6 6 507 6 6 111 6 6 111

p-Cymene 6 2 793 6 4 296 6 6 111

Phenanthrene 6 2 212 6 6 111 6 6 111

Phenol 6 0 91.8 6 6 111 6 6 111

Pyrene 6 3 1,180 6 6 111 6 6 111

Tripropyleneglycol 6 1 182,000 6 6 1,100 6 6 1100

Methyl Ether

The detection limit concentration was used in calculations for data points reported as nondetects. 1

NA - Not applicable.

HEM - Hexane extractable material.

SGT-HEM - Silica gel treated-hexane extractable material.
5-45

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

Table 5-16

Summary of the Semivolatile Organic Pollutants Detected in Effluent Samples during the

EPA Method 1664 Characterization Study

Pollutant Samples Samples Sample (ug/L) Samples Extracts (ug/L) Samples Extracts (ug/L)

Total of Nondetects Average Total Number of Nondetects Concentration Number of for Concentration

Number of for Pollutant Concentration of HEM for Pollutants in HEM SGT-HEM Pollutants in in SGT-HEM

Wastewater in Wastewater in Wastewater Extract in HEM Extracts Extract SGT-HEM Extracts

Total Number Total Number Average Total Nondetects Average

1

1

Total

Number of

1

HEM 5 0 45,900 NA NA NA NA NA NA

SGT-HEM 4 0 11,000 NA NA NA NA NA NA

1,2-Diphenylhydrazine 5 3 27.5 5 5 48 5 5 48

2-Methylnaphthalene 5 5 10 5 5 24 5 5 24

4-Chloro-3-methylphenol 5 1 99.2 5 5 24 5 5 24

Acetophenone 5 5 10 5 5 24 5 5 24

"-Terpineol 5 0 274 5 1 25.4 5 5 24

Aniline 5 3 13.8 5 5 24 5 5 24

Benzoic Acid 5 0 1,130 5 5 120 5 5 120

Benzyl Alcohol 5 2 292 5 5 24 5 5 24

Bis(2-ethylhexyl) 5 1 154 5 1 67.4 5 3 29.1

Phthalate

Butyl Benzyl Phthalate 5 3 10.2 5 4 26 5 5 24

Di-n-butyl Phthalate 5 5 10 5 5 24 5 5 24

Di-n-octyl Phthalate 5 4 10.2 5 5 24 5 5 24

Diethyl Phthalate 5 5 10 5 5 24 5 5 24

Diphenylamine 5 5 10 5 5 24 5 5 24

Fluoranthene 5 5 10 5 5 24 5 5 24

Fluorene 5 5 10 5 5 24 5 5 24

Hexanoic Acid 5 1 331 5 5 24 5 5 24

Isophorone 5 1 289 5 4 42 5 5 24
5-46

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

Table 5-16 (Continued)

Pollutant Samples Samples Sample (ug/L) Samples Extracts (ug/L) Samples Extracts (ug/L)

Total of Nondetects Average Total Number of Nondetects Concentration Number of for Concentration

Number of for Pollutant Concentration of HEM for Pollutants in HEM SGT-HEM Pollutants in in SGT-HEM

Wastewater in Wastewater in Wastewater Extract in HEM Extracts Extract SGT-HEM Extracts

Total Number Total Number Average Total Nondetects Average

1

1

Total

Number of

1

n-Decane 5 1 502 5 4 30.1 5 5 24

n-Docosane 5 1 38 5 5 24 5 5 24

n-Dodecane 5 1 250 5 4 38.5 5 5 24

n-Eicosane 5 1 67.2 5 4 28.3 5 4 27

n-Hexacosane 5 1 53.9 5 5 24 5 5 24

n-Hexadecane 5 1 116 5 3 47.2 5 4 36.2

n-Nitrosodiphenylamine 5 5 20 5 5 48 5 5 48

n-Octacosane 5 5 10 5 5 24 5 5 24

n-Octadecane 5 2 90.5 5 3 34.8 5 4 30.7

n-Tetracosane 5 1 37.1 5 5 24 5 5 24

n-Tetradecane 5 1 134 5 4 37.8 5 4 27.3

Naphthalene 5 0 90.3 5 4 25.1 5 5 24

o-Cresol 5 1 120 5 5 24 5 5 24

p-Cresol 5 2 24.5 5 5 24 5 5 24

p-Cymene 5 3 13.1 5 5 24 5 5 24

Phenanthrene 5 5 10 5 5 24 5 5 24

Phenol 5 0 175 5 5 24 5 5 24

Pyrene 5 5 10 5 5 24 5 5 24

Tripropyleneglycol Methyl 5 1 11,800 5 5 238 5 5 238

Ether

The detection limit concentration was used in calculations for data points reported as nondetects. 1

NA - Not applicable.

HEM - Hexane extractable material.

SGT-HEM - Silica gel treated-hexane extractable material.