PRELIMINARY
STUDY
OF
THE
TEXTILE
MILLS
CATEGORY
United
States
Environmental
Protection
Agency
Office
of
Water
Engineering
and
Analysis
Division
401
M
Street,
S.
E.
Washington,
DC
20460
May,
1996
i
PREFACE
This
study
was
conceived
and
documented
by
the
staff
of
the
Engineering
and
Analysis
Division
and
fulfills
an
obligation
of
EPA
under
the
Consent
Decree
in
Natural
Resources
Defense
Council
v
Reilly
(
D.
D.
C.
Civ.
No.
89­
2980,
January
31,
1992).

ACKNOWLEDGEMENTS
The
author,
Hugh
Wise,
would
like
to
acknowledge
the
contribution
of
Ronald
Jordan,
who
initially
organized
the
study.
Besides
reviewing
the
existing
regulation,
he
assisted
the
Association
of
Metropolitan
Sewerage
Agencies
(
AMSA)
with
the
development
of
the
POTW
survey
questionnaire
and
personally
retrieved
hardcopies
of
data
from
the
Annual
Pollutant
Analysis
Monitoring
(
APAM)
files
of
the
North
Carolina
Department
of
Environmental
Managagement
(
DEM).
In
addition
to
AMSA,
the
author
would
like
to
thank
members
of
the
American
Textile
Manufacturing
Institute
(
ATMI)
for
their
cooperation
and
technical
advice.
The
constructive
suggestions
and
review
of
the
document
by
Marvin
Rubin
are
also
gratefully
acknowledged.
ii
TABLE
OF
CONTENTS
I.
Executive
Summary.
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1
II.
Introduction.
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3
III.
Existing
Effluent
Guidelines.
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4
IV.
Industry
Profile.
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V.
Water
Use.
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14
VI.
Characterization
and
Pretreatment
of
Process
Wastewaters.
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18
VII.
Characterization
of
Final
(
treated)
Effluents.
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34
VIII.
Cost
of
Wastewater
Control
and
Treatment.
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43
IX.
Environmental
Assessment.
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44
APPENDICES
APPENDIX
I.
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1
APPENDIX
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2
APPENDIX
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APPENDIX
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16
APPENDIX
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26
APPENDIX
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37
APPENDIX
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38
APPENDIX
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50
APPENDIX
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53
APPENDIX
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APPENDIX
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61
APPENDIX
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66
1
I.
EXECUTIVE
SUMMARY
The
purpose
of
this
special
study
is
to
provide
information
for
determining
whether
the
current
effluent
limitations
guidelines
and
standards
for
the
textile
millls
industry,
contained
within
Title
40
of
the
U.
S.
Code
of
Federal
regulations
at
Part
410
(
cited
as
40
CFR
410),
should
be
revised
or
updated.
This
study
was
conducted
to
meet
EPA's
obligations
under
Section
304(
m)
of
the
Clean
Water
Act,
in
accordance
with
the
settlement
agreement
with
the
Natural
Resources
Defense
Council
Inc.
and
Public
Citizen,
Inc.,
entered
on
January
31,
1992.
This
study
is
a
compilation
of
data
collected
during
1993
and
1994,
and
includes
comparisons
with
data
collected
in
the
late
1970'
s
and
early
1980'
s
that
support
the
existing
limitations.

The
study
presents
a
current
profile
of
the
industry,
in
which
the
numbers
of
establishments
engaged
in
the
manufacture
of
textile
products
were
estimated
at
nearly
6000.
Approximately
35­
50
percent
are
engaged
in
wet
processing
(
dyeing,
finishing,
printing
and
coating),
and
at
least
90
percent
of
these
sources
discharge
their
process
wastewater
to
publicly
owned
treatment
works
(
POTWs).
Water
conservation
programs
developed
by
textile
facilities
have
reduced
the
total
volume
of
wastewater
discharged
through
more
efficient
use
of
process
water.
Compared
with
1980,
the
industry
in
1993
averaged
22
percent
less
water
per
pound
of
fiber
processed.
A
survey
of
POTWs
afforded
a
review
of
the
pretreatment
technologies
and
innovative
"
pollution
prevention"
techniques
that
are
currently
being
employed
by
textile
users
of
POTWs.
Pollutant
parameters
in
textile
process
wastewater
were
characterized
before
and
after
treatment.
Available
data
indicated:(
1)
Few
organic
priority
pollutants
were
identified
consistently
and,
when
detected,
were
quantified
at
very
low
concentrations
(
less
than
100
ppb);
and
(
2)
Metal
parameters
consistently
detected
at
low
levels
include:
copper,
chromium,
and
zinc.
At
textile
operations
using
metallized
dyes,
copper,
chromium
or
nickel
are
often
chelated
by
organic
ligands
to
form
watersoluble
metal
complexes.
While
their
solubility
limits
the
removal
of
such
metal
complexes
during
biological
treatment,
complexation
also
suppresses
the
immediate
and
subsequent
toxicity
(
bioavailability)
of
metal
species
in
the
treated
wastewater.
A
joint
EPA/
Industry
research
effort
is
currently
being
conducted
to
evaluate
a
more
discriminating
analytical
technique
for
measuring
potentially
bioavailable
metal
species.

With
respect
to
direct
dischargers,
the
imposition
of
NPDES
permit
limits
derived
from
water
quality
standards
for
metals,
where
the
new
limits
are
at
or
below
detectable
levels,
has
presented
a
number
of
site­
specific
compliance
problems.
The
main
problem
is
demonstrating
compliance
where
existing
analytical
methods
are
unable
to
measure
metals
at
the
level
prescribed
by
the
permit
limits.
A
small
number
of
site­
specific
problems
were
identified
at
small
POTWs
receiving
a
majority
of
their
flow
from
textile
users,
but
these
problems
were
found
to
be
unique
to
these
communities.

Although
most
textile
facilities
engaged
in
wet
processing
discharge
their
wastewater
to
POTWs,
a
survey
of
POTWs
with
textile
users
did
not
identify
any
general
operational
problems
that
could
be
related
to
the
lack
of
categorical
pretreatment
standards
for
this
industry.
Instead
of
categorical
pretreatment
standards,
each
POTW
has
developed
local
limits
for
those
parameters
it
has
determined
are
necessary
to
assure
compliance
with
its
own
National
Pollutant
Discharge
Elimination
System
(
NPDES)
permit
conditions
and
sludge
standards.
POTWs
serving
textile
users
generally
find
the
application
of
local
limits,
coupled
with
enough
monitoring
of
selected
parameters,
adequately
controls
wastewater
discharges
from
this
industry.
2
II.
INTRODUCTION
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
September
8,
1992,
EPA
published
an
Effluent
Guidelines
Plan
(
57
FR
41000)
in
which
schedules
were
established
for
reviewing
existing
effluent
guidelines
and
developing
new
and/
or
revised
effluent
guidelines
for
several
industry
categories.
One
of
the
industries
selected
for
review
of
existing
effluent
guidelines
was
the
Textile
Mills
Point
Source
Category
(
40
CFR
Part
410).

Issuance
of
the
Effluent
Guidelines
Plan
is
also
consistent
with
a
Consent
Decree
entered
on
January
31,
1992.
In
a
suit
filed
in
U.
S.
District
Court
for
the
District
of
Columbia
(
NRDC
v.
Reilly,
D.
D.
C.
No.
89­
2980),
the
Natural
Resources
Defense
Council,
Inc.
(
NRDC)
and
Public
Citizen,
Inc.,
challenged
an
earlier
Effluent
Guidelines
Plan
charging
that
EPA's
plan
did
not
meet
the
requirements
of
section
304(
m).
The
Consent
Decree
subsequently
entered
into
resolved
this
litigation
by
establishing,
among
other
things,
a
schedule
for
EPA
to
conduct
industry
studies
and
develop
new
or
revised
effluent
guidelines.
The
most
recent
revision
of
the
Effluent
Guidelines
Plan
and
its
time
line
was
published
in
the
Federal
Register
on
August
26,
1994
(
59
FR
at
44234).

This
study
of
the
textile
industry,
conducted
pursuant
to
the
requirements
of
Section
304(
m)
of
the
1987
Clean
Water
Act,
was
undertaken
to
indicate
whether
the
wet
processing
(
dyeing,
finishing,
printing
and
coating)
of
textile
products
currently
results
in
wastewater
discharges
bearing
significant
loadings
of
"
toxic"
and
non­
conventional
pollutant
parameters,
and
whether
these
parameters
are
being
adequately
controlled.
Since
40
CFR
Part
410
is
without
categorical
pretreatment
standards,
another
objective
of
this
study
was
to
ascertain
whether
such
standards
are
needed
for
adequate
control
of
textile
user
discharges
to
POTWs.
It
is
not
EPA's
intention
to
use
the
information
and
data
in
this
study
directly
for
near­
term
rulemaking,
but
to
compare
the
textile
mills
category
to
other
industry
categories
being
considered
for
new
or
revised
effluent
guidelines.

EPA
collected
data
and
information
from
a
variety
of
sources.
The
U.
S.
Department
of
Commerce,
state
agencies,
and
POTW
pretreatment
programs
supplied
information
for
use
in
the
study.
The
Association
of
Metropolitan
Sewerage
Agencies
(
AMSA)
coordinated
a
survey
of
POTW
pretreatment
programs.
Trade
associations,
such
as
American
Textile
Manufacturers
Institute
(
ATMI),
arranged
for
site
visits
to
textile
facilities.
ATMI
also
provided
industry
contacts,
who
were
sources
of
technical
information
that
were
helpful
in
interpreting
the
analytical
data.
3
III.
EXISTING
EFFLUENT
GUIDELINES
Regulatory
and
Litigation
Background
Effluent
limitations
for
existing
sources
based
on
the
use
of
best
practicable
control
technology
currently
available
(
BPT)
and
best
available
control
technology
economically
achievable
(
BAT),
as
well
as
performance
standards
for
new
sources
(
NSPS)
and
pretreatment
standards
for
new
sources
(
PSNS)
for
the
Textile
Mills
Point
Source
Category
were
first
proposed
by
EPA
in
February
1974
(
39
FR
4628;
February
5,
1974).
Final
BPT
and
BAT
effluent
limitations
guidelines
for
existing
sources,
NSPS
and
PSNS
were
subsequently
promulgated
in
July
1974
(
39
FR
24736;
July
5,
1974).
These
regulations
imposed
effluent
limits
on
discharges
of
biochemical
oxygen
demand
(
BOD
5),
chemical
oxygen
demand
(
COD),
total
suspended
solids
(
TSS),
total
chromium,
total
phenols,
sulfide,
pH,
oil
and
grease,
fecal
coliform,
and
color.
In
addition,
pretreatment
standards
for
existing
sources
(
PSES)
were
proposed
(
39
FR
24750;
July
5,
1974).

On
October
1,
1974,
the
American
Textile
Manufacturers
Institute
(
ATMI)
filed
a
petition
for
review
of
the
promulgated
effluent
guidelines
and
standards
with
the
Fourth
Circuit
of
the
U.
S.
Court
of
Appeals.
ATMI
was
joined
in
this
action
by
the
Northern
Textile
Association
(
NTA)
and
the
Carpet
and
Rug
Institute
(
CRI).
The
parties
involved
subsequently
filed
a
joint
motion
requesting
a
stay
of
the
petition
to
allow
for
a
joint
EPA/
industry
study
to
further
evaluate
the
technical
and
economic
achievability
and
impact
of
the
regulations.
In
the
joint
motion,
petitioners
withdrew
their
challenge
to
the
BPT
limitations.
In
response
to
the
joint
motion,
the
Court
remanded
all
the
regulations
except
BPT
to
EPA
for
reconsideration.

PSES
were
promulgated
in
1977
(
42
FR
26979;
May
26,
1977).
These
pretreatment
standards
replaced
the
limits
proposed
for
specific
pollutants
with
general
prohibitions
(
40
CFR
Sec.
403.5:
hydraulic
loading,
corrosivity,
obstructive,
and
fire/
explosion
hazards)
intended
to
protect
POTW
operation
and
performance.

In
1982,
EPA
promulgated
regulations
superseding
all
existing
regulations
for
the
textile
mills
point
source
category,
except
the
BPT
effluent
limitations
(
47
FR
38810;
September
2,
1982).
The
final
rule
imposed
BPT
limits
on
two
new
industry
subcategories,
and
revised
BAT
and
NSPS
for
all
subcategories.
The
general
prohibitions
of
PSES
and
PSNS
were
reserved,
leaving
POTW
pretreatment
programs
with
the
prerogative
of
applying
local
limits
as
necessary
to
control
the
wastewater
discharges
of
textile
users.

The
current
effluent
limitations
and
standards
for
the
Textile
Mills
Point
Source
Category
are
codified
at
40
CFR
Part
410.
Textile
products
and
processes
that
were
allocated
to
the
subcategories
of
Part
410,
together
with
their
applicable
SIC
codes
are
summarized
in
Table
III­
1.
4
Table
III­
1
Summary
of
Subcategories
and
Applicable
SIC
Codes
Subcategory
and
Title
40
CFR
Section
Applicable
SIC
Code(
s)

A.
Wool
Scouring
410.10
2299
B.
Wool
Finishing
410.20
2231
C.
Low
Water
Use
Processing
410.30
2211,2221,2231,2241,2253,2254,2259,
2273,2281,2282,2284,2295,2296,2298
D.
Woven
Fabrics
Finishing
410.40
2261,2262
E.
Knit
Fabric
Finishing
410.50
2251,2252,2257,2258
F.
Carpet
Finishing
410.60
2273
G.
Stock
&
Yarn
Finishing
410.70
2269
H.
Nonwoven
Manufacturing
410.80
2297
I.
Felted
Fabric
Processing
410.90
2299
Effluent
Limits
and
Standards
Effluent
limitations
for
discharges
to
surface
waters
were
established
to
control
the
conventional
pollutants:
biochemical
oxygen
demand
(
BOD),
total
suspended
solids
(
TSS)
and
pH;
the
nonconventional
pollutants:
chemical
oxygen
demand
(
COD),
sulfide,
and
total
phenols;
and
the
priority
pollutant
total
chromium.
The
limitations
are
production­
based
mass
limits
and
are
presented
in
terms
of
pounds
of
pollutant
per
1,000
pounds
of
product
(
lb/
1000
lb)
or,
alternatively,
kilograms
of
pollutant
per
1,000
kilograms
of
product
(
kg/
1000
kg).

Definition
of
Textile
Products
and
Applicability
of
Limitations
Limitations
are
applicable
to
textile
products,
defined
as
the
final
material
produced
or
processed
at
a
textile
mill.
Applicable
products
are
defined
differently
in
the
wool
scouring
and
wool
finishing
subcategories.
For
wool
scouring,
the
limitations
are
based
on
the
dry
raw
wool
as
it
is
received
by
the
wool
scouring
mill.
For
wool
finishing,
the
limitations
are
based
on
the
mass
of
dry
wool
and
other
fibers
as
received
at
the
mill
for
processing
into
wool
and
blended
fibers.

Commissioned
Production
Integrated
mills
finish
their
own
textile
goods,
while
others
may
contract
(
for
a
commission)
to
finish
textile
goods
owned
by
others.
For
textile
mills
qualifying
as
a
commission
finisher,
the
regulation
allows
a
100
percent
(%)
increase
in
the
categorical
effluent
limitations.
In
order
to
qualify
production
as
"
commission
finishing":
1.
The
mill
must
be
independent
(
no
more
than
49%
ownership
by
other
companies
with
greige
or
integrated
operations);
2.
The
mill
owns
less
than
50%
of
the
textile
goods
being
finished
on
commission;
3.
At
least
20%
of
the
commissioned
textile
goods
must
be
finished
by
batch
(
non­
continuous)
operations;
and
4.
At
least
50%
of
the
commissioned
production
must
be
in
lots
of
5000
yards
or
less.
5
Textile
mills
that
qualify
as
commission
finishers
are
almost
exclusively
small
independent
facilities,
located
mostly
in
northeastern
states.
They
were
allowed
exceptional
categorical
effluent
limitations,
because
they
are
batch
operations
(
frequent
equipment
washings)
that
are
engaged
in
finishing
textile
goods
from
a
variety
of
sources.
This
causes
the
wasteload
to
fluctuate,
even
though
the
wastewater
characteristics
are
similar
to
the
rest
of
the
textile
industry.

The
commissioned
scouring
of
wool
is
also
allowed
a
100%
increase
in
effluent
limitations.
In
order
to
qualify
production
as
"
commission
scouring,"
the
mill
must
satisfy
the
first
three
criteria
above.
The
fourth
qualification
is
not
applicable
to
wool
scouring.
6
IV.
INDUSTRY
PROFILE
Estimates
of
Manufacturing
Establishments
in
the
Textile
Industry
Count
from
1993
Davison's
Textile
Blue
Book
(
TBB).

All
textile
establishments
listed
in
the
1993
Davison's
Textile
Blue
Book
(
TBB)
were
counted,
with
the
exception
of
corporate
offices
and
establishments
engaged
in
the
manufacture
of
synthetic
fibers
(
correctly
classified
in
SIC
28).
This
count
gave
a
total
of
3990
establishments,
which
are
tabulated
by
state
in
Table
IV­
2.
To
distinguish
likely
sources
of
textile
process
wastewater,
a
count
was
made
of
those
listings
indicated
to
be
engaged
in
wet
processing
(
scouring,
dyeing,
finishing,
printing,
coating)
of
textile
products.
This
count
gave
1404
establishments,
which
is
approximately
35%
of
the
total
(
3990)
number
of
establishments
listed.

Count
from
the
Census
of
Manufactures.

Counts
of
textile
establishments
for
each
of
the
wet
processing
subcategories
of
40
CFR
Part
410
were
tablulated
from
the
1992
Census
of
Manufactures,
published
every
five
years
by
the
Department
of
Commerce.
These
are
summarized
in
Table
IV­
1.
The
regional
geographic
distribution
of
all
textile
establishments
reporting
production
under
SIC
22
are
illustrated
in
Charts
2
and
3.1
Table
IV­
1
Count
of
Establishments
by
Wet
Processing
Subcategory
Subpart
and
Title
SIC
Code
19871
19921
A.
Wool
Scouring
2299
5512
572
I.
Felted
Fabric
Processing
2299
B.
Wool
Finishing
2231
118
98
D.
Woven
Fabric
Finishing
2261
268
168
2262
182
178
E.
Knit
Fabric
Finishing
2251
161
151
2252
426
448
2257
334
388
2258
240
279
F.
Carpet
Finishing
2273
657
446
G.
Stock
&
Yarn
Finishing
2269
182
137
3119
2865
Total
establishments
reporting
under
SIC
22
6065
5887
1.
From
1992
Census
of
Manufactures,
U.
S.
Department
of
Commerce,
October
1994.
2.
Count
from
Subparts
A
and
I
were
combined
to
avoid
redundant
counting.

1.
From
1990
County
Business
Patterns,
U.
S.
Census
Bureau
(
DRI/
McGraw­
Hill
report,
p.
5).
7
Regional
Distribution
of
Textile
Facilities
8
Table
IV­
2
Count
of
Establishments
Listed
in
the
Textile
Blue
Book
Textile
Wet
Direct
Indirect
State
Estab's1
Process2
Dischargers3
Dischargers
Alabama
176
50
3
47
Arizona
8
2
1
1
Arkansas
7
2
2
0
California
123
43
0
43
Colorado
4
2
0
2
Connecticut
44
19
0
19
Delaware
7
3
0
3
Florida
41
15
0
15
Georgia
492
132
15
117
Hawaii
1
0
0
0
Idaho
2
0
0
0
Illinois
31
13
0
13
Indiana
12
3
0
3
Iowa
9
3
0
3
Kansas
2
2
0
2
Kentucky
22
9
1
8
Louisiana
5
1
0
1
Maine
30
11
3
8
Maryland
14
3
0
3
Massachusetts
157
51
5
46
Michigan
18
2
0
2
Minnesota
14
4
0
4
Mississippi
25
7
4
3
Missouri
18
5
0
5
Nebraska
2
1
0
1
Nevada
1
0
0
0
New
Hampshire
30
8
0
8
New
Jersey
245
73
2
71
New
Mexico
2
1
0
1
New
York
282
67
0
67
North
Carolina
1136
423
35
388
North
Dakota
1
0
0
0
Ohio
32
10
0
10
Oklahoma
2
0
0
0
Oregon
7
4
0
4
Pennsylvania
255
71
3
68
Rhode
Island
83
37
1
36
South
Carolina
368
236
35
201
Tennessee
87
41
0
41
Texas
42
10
2
8
Utah
4
2
0
2
Vermont
5
3
0
3
Virginia
76
26
12
14
Washington
10
1
1
0
West
Virginia
5
2
1
1
Wisconsin
39
6
0
6
3990
1404
126
1278
1.
Listed
in
1993
Davison's
Textile
Blue
Book
(
TBB).
2.
Establishments
in
TBB
indicated
to
be
engaged
in
dyeing,
printing,
coating,
or
finishing.
3.
From
the
PCS
(
see
Table
IV­
4).
SIC
22
NPDES
permits
discharging
treated
process
wastewater.

Of
a
total
of
5887
establishments
reporting
in
1992
(
Table
IV­
1),
2865
(
49%)
reported
production
under
SIC
codes
that
suggest
wet
processing
is
a
significant
component
of
their
manufacturing
operations.
Using
the
1987
count,
about
51
percent
of
the
textile
establishments
were
similarly
engaged.
In
the
count
taken
from
the
TBB
(
Table
IV­
2),
about
35
percent
of
the
textile
9
establishments
listed
appeared
to
be
engaged
in
wet
processing.
These
evaluations
suggest
that
fewer
than
half
(
35­
50%)
of
all
establishments
manufacturing
textile
products
are
likely
to
be
sources
of
process
wastewater.
The
remaining
establishments
entail
essentially
dry
manufacturing
operations
(
e.
g.,
yarn,
weaving,
knitting,
etc.)
that
generate
little,
if
any,
process
wastewater.

Of
the
thousands
of
textile
facilities
engaged
in
wet
processing,
there
are
only
260
mills
that
are
recognized
by
the
industry
as
major
finishers
of
textile
goods.
2
These
include
integrated
mills
that
finish
their
own
textile
goods
exclusively,
as
well
as
other
mills
that
are
able
to
accomodate
some
commission
finishing
of
textile
goods
owned
by
others.
In
general
for
a
major
finishing
mill
to
operate
profitably,
it
must
have
sufficient
capacity
to
finish
the
greige
goods
manufactured
by
at
least
five
textile
facilities.
None
of
the
major
finishers
would
qualify
as
"
commission
finishers"
(
see
page
5)
that
are
eligible
for
double
the
categorical
effluent
limitations.

The
counts
(
by
state)
of
textile
establishments
listed
in
the
TBB
were
compared
to
counts
(
by
geographic
region)
of
SIC
22
establishments
reporting
annually
to
the
U.
S.
Department
of
Commerce's
Census
of
Manufactures.
This
comparison
is
represented
in
Table
IV­
3,
wherein
the
state
counts
in
TBB
were
aggregated
into
roughly
the
same
geographic
regions
as
in
the
Census
data.

Generally,
the
regional
TBB
counts
were
found
to
be
lower
than
regional
counts
in
the
Census
data,
with
the
exception
of
the
East
S.
Central
region.
3
This
suggests
that
many
textile
establishments
are
not
listed
in
the
TBB.
The
exceptionally
low
count
in
the
Census
data
from
the
East
S.
Central
region
may
have
resulted
from
facilities
mistakenly
reporting
production
under
SIC
23
(
apparel),
instead
of
correctly
under
SIC
22.

In
explaining
why
the
total
number
of
establishments
listed
in
TBB
is
lower
than
the
1992
total
in
Commerce's
Census
of
Manufactures,
TBB's
publisher
conceded
its
listing
is
incomplete.
A
free
listing
is
offered
to
any
textile
facility
that
can
be
identified.
But
those
not
on
the
mailing
list,
or
that
failed
to
respond,
were
not
listed.
California
textile
facilities,
in
particular,
appear
to
be
undercounted.
These
omissions
are
illustrated
by
the
fact
that
the
TBB
gave
a
total
count
of
only
123
textile
establishments
in
California.
But
the
AMSA
survey
confirmed
a
count
of
135
textile
users
of
POTWs
in
three
California
metropolitan
areas
(
Los
Angeles
131;
San
Diego
2;
San
Francisco
2).

2.
Phone
communication:
Edward
Barnhardt,
RMT
Hydroscience,
Inc.,
Hilton
Head,
SC.
3.
Phone
communication
with
Bruce
Nealy
­
Publisher
of
Davison's
TBB.
10
Table
IV­
3
Count
of
Establishments
in
the
Textile
Industry
Textile
Blue
Book
vs.
Department
of
Commerce
Census
Regions
Total
Total
Region
Mills1
Mills2
States
New
England
349
500­
1000
Connecticut,
Maine,
Massachusetts,
New
Hampshire,
Vermont,
Rhode
Island.
Middle
Atlantic
782
1000­
1500
New
York,
New
Jersey,
Pennsylvania.
South
Atlantic
2139
2500­
3000
Delaware,
D.
C.,
Florida,
Georgia,
Maryland,
North
Carolina,
South
Carolina,
Virginia,
W.
Virginia.
East
N.
Central
132
0­
250
Illinois,
Indiana,
Michigan,
Ohio,
Wisconsin.
West
N.
Central
46
0­
250
Iowa,
Kansas,
Minnesota,
Missouri,
Nebraska,
N.
Dakota,
S.
Dakota.
East
S.
Central
310
0­
250
Alabama,
Kentucky,
Mississippi,
Tennessee.
West
S.
Central
56
0­
250
Arkansas,
Louisiana,
Oklahoma,
Texas.
Mountain
One
11
0­
250
Colorado,
Idaho,
Montana,
Nevada,
Utah,
Wyoming.
Mountain
Two
10
0­
250
Arizona,
New
Mexico.
Pacific
One
17
0­
250
Alaska,
Oregon,
Washington.
Pacific
Two
124
250­
500
California,
Hawaii.
3976
1.
From
count
of
listings
by
State
in
the
1993
Davison's
Textile
Blue
Book
2.
From
count
of
establishments
with
textile
SIC
codes
in
1990
County
Business
Patterns,
U.
S.
Census
Bureau
(
DRI/
McGraw­
Hill
report,
p.
5)

Count
from
EPA's
Permit
Compliance
System
(
PCS)
Database
As
a
means
of
estimating
the
number
of
direct
dischargers
in
the
textile
mill
category,
the
PCS
computerized
database
was
searched
for
records
of
NPDES
permits
issued
under
SIC
22.
A
total
of
423
records
were
found.
A
review
of
these
records
revealed
three
permits
that
were
incorrectly
designated
as
SIC
22,
and
two
permits
were
confirmed
as
no
longer
active
(
now
discharge
to
POTWs).
Deletion
of
these
permits
brought
the
total
number
of
textile
mill
NPDES
permits
to
418.
These
records
are
summarized
in
Table
IV­
4.

The
PCS
was
searched
again
to
identify
parameters
that
were
limited
by
each
of
the
418
textile
NPDES
permits
initially
retrieved.
No
specific
parameters
were
found
to
be
associated
with
many
of
these
permits,
perhaps
because
they
were
considered
"
minor"
permits.
Under
EPA
policy,
monitoring
data
or
parameters
for
"
minor"
permits
are
not
required
to
be
reported
to
the
PCS.
Other
textile
NPDES
permits
retrieved
from
PCS
listed
only
a
few
conventional
parameters
(
BOD,
TSS,
pH,
etc.),
along
with
a
description
of
the
discharge
that
indicated
it
was
not
process
wastewater.
Phone
contact
with
some
of
these
permitees
revealed
these
non­
process
wastewater
discharges
included
storm
water,
non­
contact
cooling
water,
filter
backwash,
boiler
blowdown,
etc.
11
Table
IV­
4
Summary
of
Textile
Mill
Records
Extracted
from
PCS
Permits
Reporting
SIC
22
SIC
22
Discharge
SIC
22
NPDES
NPDES
of
Process
NPDES
State
Permits1
Permits
Wastewater2
Permits3
Alabama
26
26
3
3
Arizona
1
1
1
0
Arkansas
2
2
2
0
California
2
2
0
0
Connecticut
13
13
0
0
Georgia
43
43
15
5
Illinois
2
2
0
0
Kansas
1
1
0
0
Kentucky
2
2
1
1
Louisiana
1
1
0
0
Maine
9
9
3
1
Maryland
2
2
0
0
Massachusetts
17
17
5
3
Mississippi
6
6
4
2
New
Hampshire
3
3
0
0
New
Jersey
6
5.4
2
1
New
York
3
3
0
0
North
Carolina
102
101.5
35
0.6
Ohio
4
4
0
0
Pennsylvania
8
8
3
2
Rhode
Island
6
6
1
1
South
Carolina
133
132.7
35
25
Tennessee
5
4.8
0
0.
8
Texas
2
2
2
1
Virginia
22
21.9
12
7.9
Washington
1
1
1
1
West
Virginia
1
1
1
1
423
418
126
54
1.
Records
extracted
from
PCS
by
EPA
(
EAD/
OST/
OW,
C.
White),
6/
1/
93.
Search
variable:
SIC
22.
Printout
listed:
NPDES
permit
number,
name
of
permitee,
location
of
permit
by
state,
county
and
city.
2.
Records
extracted
from
PCS
by
EPA
(
EAD/
OST/
OW,
C.
White),
7/
8/
93.
Search
variables:
SIC
22,
pollutant
parameters.
Printout
listed:
pollutant
parameters
for
each
NPDES
permit.
Used
to
distinguish
permits
that
control
the
discharge
of
treated
process
wastewater.
3.
Records
extracted
from
PCS
by
Versar
for
EPA
(
SASD/
OST/
OW),
10/
12/
94.
Search
variables:
SIC
22,
wastewater
flow
and
pollutant
parameters
with
concentration
data.
4.
Permit
NJ00054330
is
no
longer
active.
5.
Permit
NC0004685
should
have
been
encoded
in
PCS
under
SIC
32
(
glass/
glass
fibers).
6.
Failure
to
extract
any
records
may
be
caused
by
monitoring
data
from
North
Carolina
being
reported
on
a
mass
basis.
Consequently,
there
is
no
concentration
data
encoded
in
PCS
from
these
permits.
7.
Permit
SC0040061
is
no
longer
active.
8.
Permit
TN0002810
should
have
been
encoded
in
PCS
under
SIC
28
(
synthetic
fibers).
9.
Permit
VA0001601
should
have
been
encoded
in
PCS
under
SIC
28
(
synthetic
fibers).

When
a
PCS
permit
listed
parameters
specified
by
categorical
effluent
limits,
or
other
parameters
derived
from
water
quality
criteria,
the
permit
was
judged
as
being
associated
with
process
wastewater.
By
analyzing
the
parameters
listed
for
each
of
these
permits,
a
determination
was
made
that
only
122
of
the
418
NPDES
permits
were
likely
to
be
sources
of
treated
process
wastewater
(
from
dyeing,
finishing,
printing
or
coating).
12
Summary
and
Implications
of
the
Textile
Industry
Profile.

Although
admittedly
undercounted,
the
total
number
of
textile
establishments
listed
in
the
1993
Textile
Blue
Book
was
3990.
It
was
estimated
that
1404
(
35%)
of
these
were
sources
of
process
wastewater.
Perhaps
overcounted,
the
1992
Census
of
Manufactures
indicated
a
total
number
of
textile
establishments
at
5887,
with
2865
(
49%)
estimated
as
being
sources
of
wastewater.
A
search
of
the
PCS
found
only
418
NPDES
permits
issued
under
SIC
22.
Comparing
this
number
of
NPDES
permits
to
the
respective
counts
of
textile
establishments
that
are
sources
of
wet
processing
wastewater,
it
is
estimated
that
15
(
418/
2865)
to
30
(
418/
1404)
percent
have
NPDES
permits.
This
would
indicate
that
70
to
85
percent
discharge
to
POTWs.

A
review
of
the
418
NPDES
permits
issued
under
SIC
22
found
only
122
that
appeared
to
be
valid
sources
of
treated
process
wastewater.
This
suggests
that
9
percent
(
122/
1404)
of
the
Textile
Blue
Book
wet
processors
and
4
percent
(
122/
2865)
of
those
estimated
from
the
Census
of
Manufacturs
have
NPDES
permits,
and
indicates
that
91
to
96
percent
of
the
wet
processors
in
the
textile
industry
discharge
to
POTWs.

As
noted
previously,
there
are
260
mills
that
are
recognized
by
the
industry
as
major
commission
finishers
for
textile
goods
owned
by
others.
These
major
sources
of
process
wastewater
would
be
expected
to
be
among
the
418
NPDES
permits
found
for
the
textile
industry
in
the
PCS.
Since
only
122
of
the
NPDES
permits
were
validated
for
the
entire
industry,
more
than
half
of
the
significant
finishers
must
be
discharging
to
POTWs.

Regardless
of
the
accuracy
of
these
counts,
one
may
reasonably
conclude
that
at
least
90
percent
of
the
textile
facilities
that
are
sources
of
wet
processing
wastewater
discharge
to
POTWs.
Since
the
textile
mills
category
(
40
CFR
Part
410)
is
without
categorical
pretreatment
standards,
it
was
of
interest
to
investigate
whether
POTWs
find
the
absence
of
such
standards
a
problem
in
adequately
controlling
discharges
from
textile
users.
This
question
is
addressed
in
Section
VI.
13
V.
WATER
USE
In
1982
the
total
water
used
for
wet
processing
in
the
textile
mills
category
was
estimated
at
500
to
600
million
gallons/
day
(
mgd).
1
Assuming
textile
mills
operate
345
days/
year,
this
translates
to
an
annual
water
use
by
the
industry
ranging
from
172
to
207
billion
gallons.

Previous
Estimate
of
Water
Use
by
the
Industry
During
the
previous
rulemaking
(
1982),
total
water
used
by
the
industry
was
estimated
on
the
basis
of
wastewater
reportedly
discharged.
1
An
estimate
of
process
wastewater
from
each
of
the
textile
mills
subcategories
was
derived
from
data
collected
by
EPA
industry
surveys
in
1977
and
1980
(
see
Table
V­
1).
Although
uncorrected
for
evaporative
losses
(
both
in­
process
and
during
wastewater
treatment),
the
estimate
included
wastewater
that
was
not
discharged
to
POTWs
or
directly
to
surface
waters.
Disposition
of
this
wastewater
was
by
several
"
zero
discharge"
options.
Examples
include:
spray
irrigation
(
land
application),
contract
hauling
and
recycle
within
the
facility.
The
total
from
all
subcategories
was
estimated
at
490
mgd,
which
is
at
the
lower
end
of
the
range
noted
above.
Assuming
most
textile
mills
are
in
operation
345
days/
year,
this
translates
to
approximately
169
billion
gallons/
year
(
bgy).

With
the
exception
of
raw
wool
scouring,
water
use
efficiencies
(
gal./
lb.)
presented
in
Table
V­
1
are
per
pound
of
textile
product,
rather
than
per
pound
of
fiber
consumed.
But
since
the
water
used
for
scouring
of
raw
wool
is
a
very
small
fraction
of
the
overall
wool
processing
requirements,
it
was
included
in
the
median
value
of
37.9
gal./
lb.
of
finished
wool
fabrics.
Felted
fabrics
use
a
median
value
of
25.5
gal./
lb.
of
product.
Two
subcategories
that
annually
consume
a
large
measure
of
cotton
and
synthetic
fibers
are
woven
fabrics,
using
up
to
24.4
gal./
lb.
of
product;
and
knit
fabrics,
using
up
to
28.8
gal./
lb.
of
product.
2
Estimate
of
Current
Water
Use
by
the
Industry
Lacking
data
for
a
direct
comparison
with
the
prior
estimate
of
water
use
per
unit
of
product
(
fabric),
current
water
use
for
wet
processing
in
the
textile
industry
was
estimated
on
the
basis
of
fiber
consumed.
Data
in
Table
V­
2
shows
the
quantities
of
wool,
cotton
and
synthetic
fibers
that
were
annually
converted
into
textile
products.
While
the
relative
amount
of
each
fiber
varied
from
year­
toyear
the
total
quantity
of
all
fibers
annually
consumed
in
the
manufacture
of
textile
products
increased
36%
during
the
period
1980
to
1993.

To
convert
a
pound
of
fiber
into
a
finished
textile
product,
current
wet
processing
practices
use
the
following
volumes
of
water:
wool
fibers
20
gallons;
cotton
fibers
13
gallons;
synthetic
fibers
11
gallons.
3
Based
on
1993
consumption
of
each
fiber
type
and
its
respective
water
requirement,
the
annual
water
use
in
the
textile
industry
was
calculated
to
be
179
billion
gallons
(
see
Table
V­
3).

1.
1982
Development
Document
for
the
Textile
Mills
Category,
p.
96.
2.
Calculated
by
adding
water
requirements
for
desizing
and
complex
processing
of
woven
fabrics,
and
adding
both
simple
and
complex
processing
requirements
for
knit
fabrics
(
from
Table
V­
1).
3.
Source:
Edward
Barnhart,
ELBA,
Inc.,
Fripp
Island,
S.
C.
14
Table
V­
1
Estimate
of
Wastewater
Discharged
from
Textile
Mill
Category
in
1980
Estimated
Wastewater
Discharged1
Water
(
million
gallons/
day)
Used
Directs
Indirects
Subcat.
Subcategory
Gal./
lb.
2
(
NPDES)
3
(
to
POTW)
Total
Wool
scouring
1.4
1.0
2.3
3.3
Wool
finishing
36.5
10.9
8.2
19.0
Low
water
use
General
processing
0.8
4.4
16.4
20.8
Water
jet
weaving
10.4
1.196
1.196
2.392
Woven
fabric
finishing
Simple
processing
9.2
17.4
34.8
52.2
Complex
processing
11.7
25.5
38.6
64.1
Desizing
12.7
59.4
40.0
99.5
Knit
Fabric
Finishing
Simple
processing
14.1
17.6
62.9
80.6
Complex
processing
14.7
11.9
27.9
39.9
Hosiery
products
9.0
0.2
6.0
6.2
Carpet
finishing
5.6
5.4
23.1
28.5
Stock
&
Yarn
finishing
11.6
21.8
44.8
66.5
Nonwoven
4.8
0.7
3.8
4.5
Felted
Fabric
processing
25.5
0.2
2.1
2.3
178
312
490
Daily
total
for
the
industry
=
490
million
gallons.
Annual
total
for
the
industry
(
345
days/
yr.)
=
169
billion
gallons.

1.
From
1982
Development
Document
for
Textile
Mills
Category,
Table
V­
3,
p.
100.
The
data
was
collected
by
EPA
industry
surveys
in
1977
and
1980.
"
The
estimates
were
developed
by
adding
the
known
average
discharge
values
for
the
mills
in
each
subcategory
reporting
flow
data
plus
estimates
of
the
average
discharge
for
the
mills
not
reporting
flow.
The
estimates
for
mills
not
reporting
values
were
based
on
the
mills's
assignment
to
a
specific
model.
Model
assignments
were
made
on
the
basis
of
survey
information
and
information
about
products
and
production
equipment
published
in
the
1978
edition
of
Davison's
Textile
Blue
Book."
2.
Wastewater
generated
was
taken
to
represent
water
use,
even
though
it
was
admittedly
uncorrected
for
evaporative
losses.
3.
Includes
wastewater
that
is
not
discharged
to
surface
waters.
"
Zero
discharge"
options
include:
Wastewater
is
recycled,
sent
to
a
holding
pond
or
septic
tank,
disposed
on
land
(
by
spray
irrigation),
or
hauled
from
site
to
a
landfill
by
private
contractor
(
1982
Dev.
Doc.,
Table
III­
8,
p.
28).
15
Table
V­
2
Fiber
Consumption
by
U.
S.
Textile
Mills1
(
Million
Pounds)
Total
Mill
Period
Cotton
Synthetic2
Wool
Consumption
1980
3038.4
8089.5
123.4
11223.3
1981
2715.5
7862.0
138.3
10715.8
1982
2487.9
6775.2
115.7
9378.8
1983
2807.9
8173.9
140.6
11122.4
1984
2714.5
7968.1
142.1
10822.7
1985
2810.5
8225.5
116.6
11152.8
1986
3259.0
8921.7
136.7
12317.4
1987
3753.2
9085.7
142.8
12961.7
1988
3520.3
9217.9
132.7
12848.6
1989
4048.0
9217.6
134.7
13398.4
1990
4115.3
9047.0
132.7
13295.0
1991
4347.5
9102.3
151.5
13601.3
1992
4761.6
9742.7
150.7
14655.0
1993
4937.7
10169.4
156.8
15263.9
1.
Source:
U.
S.
Department
of
Agriculture
Economic
Research
Service.
2.
Same
as
"
man­
made"
fibers.

Table
V­
3
Current
Estimate
of
Textile
Process
Wastewater
Water
to
Process
Wastewater
Discharged2
Annual
Use
Annual
Annual
Year
Fiber
Production1
gal./
lb.
million
gal.
million
gal.

1980
Wool
123.4
37.9
3
4677
4279
Cotton
3038.4
24.6
4
74745
67271
Synthetics
8083.5
20.8
5
168137
156367
11245.3
22.0
6
247560
227917
1993
Wool
156.6
20.0
7
3132
2866
Cotton
4937.7
13.0
7
64190
57771
Synthetics
10169.4
11.0
7
111863
104033
15263.7
11.7
6
179200
164670
1.
Million
pounds
of
fiber
type
converted
into
finished
textile
products.
2.
Corrected
for
evaporative
losses
of
process
water
in
dryers
and
in
wastewater
treatment.
Evaporative
loss
assumed
to
be
10%
for
cotton
fiber,
7%
for
synthetic
fibers
and
8.5%
for
wool.
3.
From
1982
Development
Document
for
Textile
Mills
Category,
Table
V­
1,
page
97.
Average
value,
uncorrected
for
evaporative
losses.
4.
Calculated
from
the
ratio
13/
20
X
37.9.
5.
Calculated
from
the
ratio
11/
20
X
37.9.
6.
Calculated
from
total
fiber
consumption
and
total
water
used
or
discharged.
7.
Average
value,
uncorrected
for
evaporative
losses.
Source:
Ed.
Barnhart,
ELBA,
Inc.,
Fripp
Island,
S.
C.
16
Comparing
total
water
used
in
1980
based
on
survey
data
(
169
billion
gallons),
with
total
water
used
in
1993
calculated
from
fiber
consumption
and
current
water
use
efficiencies
(
179
billion
gallons),
it
would
appear
that
the
industry
is
currently
using
about
6%
more
water.
While
there
was
little
increase
in
water
use,
consumption
of
all
fiber
types
increased
36%
during
this
period
(
see
Table
V­
2).
This
indicates
a
substantial
improvement
in
the
efficient
use
of
water.

Using
total
fibers
consumed
(
11223.3
million
lbs.)
as
a
measure
of
textile
production
in
1980
and
total
water
used
(
169,100
million
gal.)
previously
estimated
for
that
year,
1980
water
use
efficiency
was
calculated
at
15.1
gal./
lb.
of
product.
At
the
same
water
use
efficiency,
1993
fiber
consumption
would
project
a
total
use
of
230,000
million
gallons
by
the
industry.
The
estimated
use
of
only
179,200
million
gallons
by
the
industry
at
the
higher
fiber
consumption
level
of
1993
can
be
explained
by
a
more
efficient
use
of
water
for
wet
processing.
The
industry's
water
use
efficiency
for
all
types
of
fibers
in
1993
was
calculated
at
11.7
gal./
lb.,
which
is
22%
less
water
per
pound
of
fiber
processed
than
was
used
in
1980.
This
recognizes
the
achievement
of
water
conservation
programs
developed
at
textile
mills
throughout
the
industry.
17
VI.
CHARACTERIZATION
and
PRETREATMENT
of
PROCESS
WASTEWATER
In
order
to
characterize
an
industry's
process
wastewater,
it
must
be
sampled
before
treatment
or
mixing
with
non­
process
wastewater.
The
data
available
for
characterization
is
almost
exclusively
from
monitoring
reports
for
NPDES
permits.
But
this
data
characterizes
treated
process
wastewater.
Textile
facilities
discharging
process
wastewater
to
POTWs
(
referred
to
as
"
textile
users")
are
a
better
source
of
data
for
characterizing
textile
process
wastewater,
provided
the
wastewater
is
sampled
before
it
is
discharged
to
the
POTW
sewer
connection.

Data
to
support
the
characterization
of
untreated
(
raw)
process
wastewater
in
the
textile
mills
category
was
drawn
from
a
POTW
that
was
part
of
a
survey
conducted
cooperatively
with
the
Association
of
Metropoliltan
Sewerage
Agencies
(
AMSA),
and
from
two
POTWs
that
were
involved
in
North
Carolina's
Annual
Pollutant
Analysis
Monitoring
(
APAM)
program.

All
industrial
users
(
IUs)
discharging
process
wastewater
to
a
POTW
are
regulated
under
40
CFR
Part
403,
with
Appendix
C
listing
textile
mills
as
an
industrial
category
that
is
subject
to
national
categorical
pretreatment
standards.
1
POTWs
in
the
AMSA
survey
had
developed
specific
local
limits
for
pollutant
parameters
listed
in
the
national
pretreatment
standards,
2
and
local
limits
for
parameters
that
are
mandated
by
the
categorical
pretreatment
standards
of
its
industrial
users.
Since
the
textile
mills
category
(
40
CFR
Part
410)
has
no
specific
categorical
pretreatment
standards,
the
POTWs
applied
local
limits
for
selected
parameters
to
the
IU
permits
of
textile
users
only
to
the
extent
necessary
to
ensure
renewed
and
continued
compliance
with
the
POTW's
NPDES
permit,
and
with
standards
for
the
use
or
disposal
of
the
POTW's
waste
sludge.
3
The
AMSA
Survey
As
noted
previously
(
Section
V),
most
textile
manufacturing
facilities
engaged
in
wet
processing
of
textile
products
discharge
their
process
wastewater
to
POTWs.
Many
of
the
larger
metropolitan
POTWs
are
members
of
AMSA,
who
agreed
to
assist
EPA
in
this
study
by
sending
their
POTW
members
an
information
request
developed
jointly
by
EPA
and
AMSA.
Out
of
153
AMSA
members
receiving
an
information
request,
99
POTWs
responded.
Only
25
of
the
respondents
reported
receiving
wastewater
discharges
from
industrial
users
that
manufacture
textile
products
classified
under
SIC
22.
These
respondents
conveyed
information
about
33
POTWs
with
a
total
of
251
textile
users.

1.
The
word
"
Categorical"
is
used
in
the
title
of
Appendix
C
to
include
a
number
of
the
industrial
categories
listed
that
do
not
have
categorical
pretreatment
standards
with
specific
limitations,
other
than
pH
or
reference
to
prohibitions
of
the
general
pretreatment
regulations.
2.
Section
403.5(
a)
and
403.5(
b).
3.
Section
403.5(
c)(
1).
18
The
North
Carolina
APAM
Database
Beginning
in
1988,
selected
new
and
renewed
NPDES
permits
carried
a
requirement
for
an
annual
priority
pollutant
scan
and
whole
effluent
toxicity
(
WET)
testing.
This
database
was
to
be
used
to
define
any
"
pollutants
of
concern"
that
might
characterize
discharges
of
"
complex"
wastewater,
defined
as
wastewater
from
industrial
sources
discharged
at
a
flow
rate
greater
than
0.5
million
gallons
per
day
(
mgd).
These
annual
monitoring
requirements
continued
to
be
added
to
selected
new
and
renewed
NPDES
permits
until
late
1993,
when
the
practice
was
halted
until
the
collected
data
could
be
encoded
and
analyzed.

The
APAM
database
contains
data
collected
by
the
Department
of
Environmental
Management
(
DEM)
from
158
NPDES
permits
issued
by
North
Carolina.
Hard
copies
of
priority
pollutant
analyses
reported
by
thirty
(
30)
textile
mills
with
NPDES
permits
were
obtained
from
this
uncoded
data
collection,
which
fortuitously
included
data
from
a
POTW's
textile
user.
The
POTW
(
at
Valdese,
NC)
was
requested
to
send
additional
priority
pollutant
data
that
its
eight(
8)
other
textile
users
had
been
required
to
submit
as
part
of
the
POTW's
pretreatment
program.
Through
the
assistance
of
the
North
Carolina
DEM,
another
POTW
(
at
Star,
NC)
was
identified
with
data
characterizing
wastewater
discharged
from
its
four(
4)
textile
users.

Textile
User
Component
of
POTW
Wastewater
Since
most
textile
manufacturing
establishments
discharge
their
wastewater
to
POTWs,
it
was
of
interest
to
characterize
the
textile
user
component
of
wastewater
received
by
POTWs.
Provided
a
POTW
has
adequate
capacity
and
is
being
operated
so
as
to
consistently
achieve
nominal
levels
of
treatment
(
not
always
the
case),
the
impact
of
textile
user
discharges
will
depend
on
whether
this
wasteload
component
is
a
significant
portion
of
the
POTW's
total
daily
wasteload.
When
the
textile
user
component
is
relatively
small,
the
impact
is
likely
to
be
minimal
regardless
of
variations
in
the
loading
and
treatability
of
the
textile
wastewater.
As
the
textile
user
component
becomes
proportionately
larger,
the
POTW's
operations
are
more
likely
to
be
affected.

Although
wastewater
loading
is
a
product
of
parameter
concentrations
and
flow,
the
textile
user
flow
component
of
a
POTW's
total
flow
may
portend
the
potential
impact
of
the
associated
wasteload
on
POTW
operations.
The
AMSA
survey
form
requested
the
POTW
to
give
the
average
daily
wastewater
discharge
(
gallons/
day)
of
each
of
its
textile
users.
POTWs
were
also
asked
for
each
textile
user's
flow
as
a
percentage
of
the
POTW's
average
daily
flow,
but
did
not
request
the
POTW's
average
daily
flow.
A
number
of
the
POTWs
failed
to
respond
to
this
question,
or
had
textile
user
flows
that
were
insignificant
relative
to
the
POTW's
flow.
For
this
reason,
the
POTW'S
average
daily
flow
and
that
of
each
of
its
textile
users
was
requested
from
a
number
of
the
POTWs
in
the
survey.
The
flow
of
each
of
the
POTWs
in
the
AMSA
survey
relative
to
the
combined
flow
from
its
textile
users
is
summarized
in
Table
VI­
1.
Flow
data
for
individual
textile
users
of
each
POTW
are
listed
in
Appendix
II­
3.

Wastewater
flow
to
POTWs
in
the
AMSA
survey,
with
the
exception
of
two
small
suburban
POTWs
in
Greenville,
SC,
ranged
from
3.3
to
332
mgd.
On
average,
the
textile
user
component
at
these
POTWs
amounted
to
only
1%
of
the
wastewater
being
treated
daily
by
the
POTW.
19
Table
VI­
1
Textile
User
(
TU)
Component
of
POTW
Flows
­
AMSA
Data
Mean
TU
Total
TU
POTW
TU/
POTW
City/
POTW
Flow,
mgd
Flow,
mgd
Flow,
mgd
Percent
Boston,
MA
Deer
Island
0.028
300
0.009
Nut
Island
0.095
150
0.06
Cleveland,
OH
Cuyahoga
(
Southerly)
0.181
135
0.13
Chicago,
IL
(
MWRDGC)
0.417
19
2.2
Columbus,
GA
0.53
5.837
28
20.8
Denver,
CO
(
MWRD)
0.032
160
0.02
Elizabeth,
NJ
(
JMEUC)
0.04
67
0.06
Greenville,
SC
Mauldin
0.283
3.396
20
17.0
Lakeside
0.031
0.35
8.8
Pelham
0.012
5.2
0.2
Taylor
0.474
3.3
14.3
Slater­
Marietta
0.055
0.35
15.7
Knoxville,
TN
0.425
21
0.02
Little
Ferry,
NJ
0.937
76
1.2
Los
Angeles,
CA
(
LA
Co.)
Carson
0.135
6.066
328
1.85
Long
Beach
0.098
16
0.6
Los
Coyotes
0.779
33
2.4
Los
Angeles,
CA
(
LA
City)
Hyperion
2.43
332
0.73
Glendale
0.248
20.3
0.01
Orange
County,
CA
0.223
2.015
232
0.87
Nashville,
TN
0.2015
32.9
0.76
Newark,
NJ
0.292
9.11
290
3.14
Philadelphia,
PA
0.331
227
0.15
Phoenix,
AZ
0.0096
150
<
0.001
Portland,
OR
0.0502
57
0.09
Providence,
RI
1.544
21.8
7.0
Rockford,
IL
0.04
29
0.14
Sayreville,
NJ
0.015
75
0.02
San
Diego,
CA
0.0145
180
<
0.0001
San
Francisco,
CA
0.012
67
<
0.02
St.
Louis,
MO
0.0185
120
0.015
St.
Paul,
MN
0.0335
235
0.01
Tacoma,
WA
0.000518
23
0.002
Totals
35
3454
1
%
Avg.

The
33
POTWs
listed
had
a
total
of
251
textile
users.
Average
discharge
of
textile
users:
0.139
mgd.
20
For
POTWs
receiving
less
than
100
mgd,
the
flow
component
from
the
POTW's
textile
users
averaged
slightly
more
than
2
percent.
As
noted
previously,
such
a
small
flow
component
from
textile
users
is
not
likely
to
have
a
significant
impact
on
POTW
operations.

A
POTW's
textile
user
flow
component
is
likely
to
be
higher
in
a
community
that
abounds
in
textile
manufacturing.
Two
POTWs
in
the
AMSA
survey
(
Columbus,
GA
and
Greenville,
SC),
with
total
wastewater
flows
less
than
30
mgd
and
textile
user
flow
components
ranging
from
17
to
21
percent,
experienced
temporary
operational
problems
that
were
attributed
to
wastewater
from
textile
users
(
see
pages
30
and
31
for
details).
But
beyond
these
two
examples,
POTW
responses
to
the
AMSA
survey
gave
no
indication
that
textile
user
wastewater
typically
cause
serious
problems
for
POTW
operations,
or
jeopardize
compliance
with
its
NPDES
permit.

The
textile
user
component
of
wastewater
flow
at
two
additional
POTWs
(
Valdese,
NC
and
Star,
NC)
were
identified
through
the
North
Carolina
APAM
database.
The
textile
user
components
of
wastewater
being
treated
at
these
two
POTWs
are
summarized
in
Table
VI­
2.
Flows
from
individual
textile
users
of
these
two
POTWs
are
listed
in
Appendix
II­
3.

Table
VI­
2
Textile
User
(
TU)
Component
of
POTW
Flows
­
APAM
Data
Mean
TU
Total
TU
Avg.
POTW
TU/
POTW
City/
POTW
Flow,
mgd
Flow,
mgd
Flow,
mgd
Percent
Valdese,
NC
0.3
3.66
6.2
59
Star,
NC
0.1
0.415
0.576
72
While
both
of
these
POTWs
had
a
high
wastewater
flow
component
from
textile
users,
neither
had
operational
problems
in
treating
the
wastewater.
In
complying
with
water
quality
criteria,
however,
the
experiences
of
the
two
POTWs
were
quite
different.
The
Valdese
POTW
had
few
compliance
problems
that
could
not
be
resolved
with
the
cooperation
of
its
textile
users.
The
situation
at
the
Star
POTW
was
unique,
in
effect
portraying
a
worst
case
senario.

Even
with
the
cooperation
of
it
textile
users,
the
Star
POTW
found
compliance
with
the
water
quality
standards
in
its
NPDES
permit
virtually
precluded
by
the
exceedingly
low
flow
of
its
receiving
stream.
Initially
not
allowed
to
dilute
its
treated
effluent
more
than
1
percent
for
the
testing
of
whole
effluent
toxicity
(
WET),
the
Star
POTW's
saline
effluent
had
difficulty
passing
the
test.
After
textile
users
altered
bleaching
and
dyeing
processes
to
reduce
the
salinity
to
a
minimum,
and
the
POTW
was
authorized
an
increase
in
the
allowed
dilution
of
effluent
to
10
percent,
WET
results
were
improved
but
remained
marginal.

Subsequently,
a
technical
effort
was
initiated
and
largely
underwritten
by
Fruit
of
the
Loom
(
FOL)
to
further
reduce
the
toxicity
of
treated
effluent
at
the
Star
POTW.
After
correcting
operational
problems
at
the
POTW,
FOL
began
adding
appropriate
doses
of
cationic
flocculants
to
the
influent
in
order
to
flocculate
soluble
organics
(
dyes,
surfactants,
etc.)
via
anionic
functional
groups.
This
was
followed
by
the
addition
of
coagulants
to
insolubilize
the
resulting
floc.
After
several
months
of
this
21
treatment,
the
POTW's
effluent
more
consistently
passed
the
WET
test
and
the
biological
integrity
of
the
receiving
stream
exhibited
substantial
improvement.

Identification
of
Pollutant
Parameters
in
Textile
User
Wastewater
One
section
of
the
AMSA
survey
form
requested
a
listing
of
those
pollutant
parameters
for
which
the
POTW
has
effluent
monitoring
data.
The
intent
was
to
identify
parameters
that
are
monitored
at
textile
user
sources,
and
POTWs
that
are
potential
reservoirs
of
numerical
data.
The
parameters
identified
are
those
for
which
there
are
local
limits,
and
indicate
the
parameters
that
POTWs
have
some
reason
to
believe
may
be
present
in
textile
users'
process
wastewater.
The
parameters
that
POTWs
reported
monitoring
at
textile
users
are
summarized
in
Table
VI­
3.
The
local
limits
and
responses
of
individual
POTWs
are
presented
in
Appendix
II­
2.

The
parameter
most
frequently
identified
was
pH,
which
is
easy
to
measure
and
can
be
monitored
concomitantly
with
other
parameters.
After
pH
(
monitored
at
85%
of
the
textile
users),
the
parameter
most
often
monitored
at
textile
users
by
POTWs
was
BOD
(
80%).
Other
parameters
often
monitored
included
TSS
(
57%),
COD
(
35%),
O&
G
(
31%)
and
sulfide
(
25%).
Metals
routinely
monitored
were:
copper
(
51%),
chromium
(
46%),
zinc
(
45%),
lead,
cadmium,
nickel
(
43%),
and
silver
(
38%).
Less
frequently
monitored
were:
Arsenic
(
21%)
and
Mercury
(
17%);
and
monitored
at
less
than
1%
of
the
textile
users
were:
Antimony,
Selenium,
Boron
and
Molybdenum.

The
reason
many
POTWs
monitor
BOD
in
textile
users'
wastewater
is
because
the
loading
of
this
parameter
commonly
serves
as
a
basis
for
the
fee
schedule
that
is
charged
to
a
POTW's
industrial
users
(
IUs).
The
local
limit
for
BOD
loading
in
industrial
wastewater
usually
derives
from
the
POTW's
design
capacity
remaining
after
the
demand
for
treating
domestic
wastewater
has
been
satisfied.
The
remaining
design
capacity
is
allocated
among
its
IUs.
When
an
IU's
discharge
exceeds
its
allocated
BOD
loading
limit,
the
IU
must
pay
a
surcharge
calculated
by
a
rate
formula.
An
IU's
discharge
of
excessive
BOD
to
the
sewer
in
slug
amounts
will
interfere
with
POTW
operations
by
temporarily
exceeding
the
POTW's
capacity
to
accomodate
shock
loads
of
high
strength
wastewater.

How
POTWs
Select
Parameters
and
Set
Monitoring
Schedules
Textile
user
permits
issued
by
a
POTW
pretreatment
program
typically
require
certain
parameters
to
be
monitored
initially.
The
initial
menu
may
include
parameters
selected
from
the
baseline
monitoring
report
(
BMR),
which
identifies
chemicals
that
were
analyzed
in
the
IU's
wastewater.
Parameters
may
also
be
selected
from
the
textile
user's
permit
application,
which
lists
chemicals
(
raw
materials,
solvents,
etc.)
purchased
for
use
in
the
facility's
manufacturing
processes.
Purchased
chemicals
must
be
accompanied
by
Material
Safety
Data
Sheets
(
MSDS),
which
list
other
chemicals
that
may
be
present.
Any
of
this
information
in
the
permit
application
may
be
used
to
select
the
pollutant
parameters
to
be
limited
in
the
IU
permit,
as
well
as
identifying
the
textile
users
that
are
potential
sources
of
specific
organic
chemicals.

Table
VI­
3
Summary
of
Parameters
Monitored
by
POTWs
at
Textile
Users
(
TUs)
22
Parameter
TUs1
Per
cent2
BOD
201
80
TSS
142
57
COD
88
35
pH
213
85
O&
G
total
48
19
O&
G
petroleum
31
12
TPH
13
5
Conductivity
12
5
Temperature
17
7
1,1,1­
Trichloroethylene
1
<
1
Tetrachloroethylene
2
1
VOCs
8
3
Acids/
BN
2
1
PCBs
3
1
Acids
(
Method
625)
1
<
1
TTO
15
6
Pesticides
1
<
1
Phenols
5
2
CTAS
(
surfactant)
2
1
MBAS
(
surfactant)
1
<
1
Ammonia­
N
12
5
TKN
5
2
Phosphorus
13
5
Sulfide
63
25
Sulfate
2
1
Cyanide
39
15
Antimony
1
<
1
Arsenic
53
21
Cadmium
108
43
Chromium
116
46
Chromium
+
6
12
5
Copper
129
51
Iron
3
1
Lead
109
43
Mercury
43
17
Molybdenum
2
1
Nickel
108
43
Selenium
1
<
1
Silver
98
39
Zinc
112
45
1.
Number
of
textile
users
at
the
25
POTWs
in
the
AMSA
survey
that
monitor
this
parameter.
2.
Per
centage
of
the
251
textile
industry
users
in
the
AMSA
survey
that
monitor
this
parameter.
23
Initially,
these
parameters
are
monitored
to
verify
the
menu
of
chemicals
suggested
by
the
textile
user's
application.
Subsequent
monitoring
serves
to
check
the
continuing
validity
of
the
initial
parameter
assessment,
as
well
as
documenting
continuing
compliance
with
local
limits
for
the
parameters
in
the
textile
user's
permit.
This
information
could
also
prove
useful
in
mediating
violations
of
the
POTW's
NPDES
permit,
or
in
assuring
compliance
with
waste
sludge
standards.

Once
a
monitoring
record
of
a
textile
user's
discharge
is
established,
and
it
becomes
apparent
that
certain
of
the
parameters
initially
selected
are
not
found
at
significant
levels
(
relative
to
local
limits),
these
parameters
are
often
deleted
from
the
user's
monitoring
menu.
The
record
may
also
convince
the
POTW
that
the
user's
discharge
can
be
monitored
less
frequently,
thereby
avoiding
unnecessary
monitoring
costs
for
both
POTW
and
user.

This
pattern
of
selecting
parameters
and
setting
monitoring
schedules
for
textile
users
became
evident
from
a
review
of
the
responses
of
individual
POTWs
(
see
Appendix
II­
2).
The
parameters
limited
in
textile
user
permits
were
found
to
vary
among
POTWs,
and
reflect
differences
in
the
parameters
that
were
regulated
in
the
respective
NPDES
permits
of
the
POTWs.
While
all
of
a
POTW's
textile
users
were
subject
to
the
same
local
limits,
the
same
parameters
were
not
always
monitored
with
the
same
frequency
at
every
textile
user.
POTW
pretreatment
programs
selected
parameters
and
monitoring
schedules
that
were
appropriate
for
individual
textile
users.

Quantitation
of
Characteristic
Metal
Parameters
Quantitative
data
to
characterize
metals
in
both
pretreated
and
untreated
wastewater
being
discharged
to
POTWs
by
textile
users
was
obtained
from
a
POTW
in
the
AMSA
survey
(
Providence,
RI)
and
two
POTWs
(
Valdese,
NC
and
Star,
NC)
in
the
APAM
database.
Average
concentrations
and
local
limits
for
metal
parameters
at
each
of
the
POTWs
are
summarized
in
Tables
VI­
4,
VI­
5
and
VI­
6.
A
detailed
listing
of
the
textile
user
data
from
each
of
these
three
POTWs
are
shown
in
Appendix
II­
4.

A
review
of
the
data
for
metal
parameters
in
textile
user
wastewater
shows
that,
with
few
exceptions,
average
metal
concentrations
were
well
below
the
local
limits
of
the
respective
POTWs.
Local
limits
were
exceeded
by
the
average
concentrations
of
antimony,
copper
and
zinc
in
the
Burke
Mills'
discharge
in
Table
VI­
5,
but
this
was
the
result
of
the
high
concentrations
measured
in
1990.
During
the
period
1990
to
1993,
the
concentrations
of
these
metals
were
progressively
reduced
below
local
limits
(
see
Appendix
II­
4).
For
example,
antimony
was
reduced
from
16.9
to
0.6
mg/
L;
copper
from
4.1
to
0.4
mg/
L;
and
zinc
from
5.2
to
0.08
mg/
L.

Burke
attributed
reductions
in
concentrations
of
these
metals
to
improvements
in
the
efficiency
of
their
dyeing
process
at
lower
dyebath
loadings
of
the
metallized
dyes
(
pollution
prevention).
The
reduction
in
zinc
was
explained
by
a
change
to
higher
priced
process
chemicals
with
less
zinc
impurity.
Although
prominent
in
the
Burke
analyses,
antimony
is
generally
not
detected
in
textile
user
wastewater.
Only
a
limited
number
of
textile
users
are
engaged
in
applying
antimony­
containing
formulations
to
fabrics
to
impart
flame
retardant
properties.
24
Table
VI­
4
Data
from
Textile
Users
Discharging
to
POTW
(
Bucklin
Point)
at
East
Providence,
RI
Textile
Users
of
Bucklin
Point
POTW
Parameters
LL1
1
2
3
4
5
Cadmium
110
1
4
0.7
­­
0.8
Chromium
2770
55
44
­­
­­
138
Copper
1200
977.2
307
80
315
79
Lead
690
27
­­
­­
­­
13
Nickel
1620
77
46
­­
­­
38
Silver
400
14
18
­­
43
11
Zinc
1670
408
309
34
68
148
Textile
Users
of
Bucklin
Point
POTW
Parameters
LL1
6
7
8
9
10
Cadmium
110
­­
685
4
2
5
Chromium
2770
446
25
33
51
163
Copper
1200
264
3670
60
73
77
Lead
690
6
550
­­
31
38
Nickel
1620
2
340
137
37
18
Silver
400
25
100
­­
15
­­
Zinc
1670
432
2938
408
336
118
1.
Local
limit,
maximum
concentration,
ug/
L
(
ppb)
2.
Averaged
from
53
observations.

Averaged
concentrations
are
ug/
L
(
ppb).
Not
detected
averaged
as
zero.
Codes:
Blank
=
No
data
reported;
(­­)
=
Analyzed,
but
not
detected.

Textile
Users:
1.
Slater
Screen
Print
Corp.
6.
Murdock
Webbing
2.
Crown
Yarn
Dye
Co.
7.
R.
I.
Textile
Co.
3.
Rochambeau
Worsted
8.
Elizabeth
Webbing
Mills,
Health­
Tex
facility
4.
Slater
Dye
Works
9.
Elizabeth
Webbing
Mills,
dyehouse
facility
5.
Microfibres,
Inc.
10.
Worcester
Textile
Co.
(
discharges
to
Field's
Point
POTW
in
Providence,
RI,
and
is
subject
to
different
local
limits)
25
Table
VI­
5
Data
from
Textile
Users
Discharging
to
POTW
at
Valdese,
NC
Textile
Users
of
Valdese
POTW
Parameter
LL1
1
2
3
4
5
Antimony
4845
­­
204
6
20
Arsenic
100
9
­­
4
12
Beryllium
25
­­
Cadmium
200
1.5
13
­­
6
4
Chromium
500
135
40
­­
8
4
Copper
500
1325
10
31
52
276
Lead
100
75
40
­­
43
10
Mercury
100
0.6
­­
­­
0.05
0.2
Nickel
250
100
47
­­
12
7
Selenium
2.6
­­
Silver
30
­­
6.6
­­
5
­­
Zinc
500
2015
33
109
104
293
Textile
Users
of
Valdese
POTW
Parameters
LL1
6
7
8
9
Antimony
­­
­­
­­
2.5
Arsenic
100
12
­­
2
­­
Cadmium
200
­­
­­
6
­­
Chromium
500
31
135
9
74
Copper
500
328
212
319
138
Lead
100
100
­­
40
4
Mercury
100
­­
­­
­­
­­
Nickel
250
238
­­
20
71
Silver
30
­­
­­
­­
­­
Zinc
500
367
60
120
106
1.
Local
limit,
maximum
concentration,
ug/
L
(
ppb).

Averaged
concentration
unit:
ug/
L
(
ppb).
Not
detected
averaged
as
zero.
Codes:
Blank
=
No
data
reported;
(­­)
=
Analyzed,
but
not
detected.

Textile
Users:
1.
Burke
Mills.
6.
Alba­
Waldensian
2.
Neuville
Industries.
7.
Adams
Millis­
Drexel
3.
Valdese
Textiles.
8.
Carolina
Mills
4.
OMS
Textiles.
9.
Valdese
Manufacturing
5.
Valdese
Weavers.
26
Table
VI­
6
Data
from
Textile
Users
Discharging
to
POTW
at
Star,
NC
Textile
Users
of
Star
POTW
Parameters
LL1
1
2
3
4
Arsenic
3
8
Cadmium
0.15
1.1
­­
Chromium
100
4
22
22
Copper
200
120.2
437.3
82
168
Lead
8
3
10
1.3
Mercury
0.05
0.08
0.08
0.05
Molybdenum
13
Nickel
0.8
Zinc
500
232.2
540.4
183
150
Chloride,
mg/
L
929
359
1032
876
Conductance,
umho
4474
3326
4908
3725
1.
Local
limit,
maximum
concentration,
ug/
L
(
ppb)
2.
Average
of
31
observations.
3.
Average
of
47
observations.
4.
Average
of
43
observations.

Averaged
concentration
unit:
ug/
L
(
ppb).
Not
detected
averaged
as
zero.
Codes:
Blank
=
No
data
reported;
(­­)
=
Analyzed,
but
not
detected.

Textile
Users:
1.
Clayson
Knitting
Co.
3.
Montgomery
Hosiery
Mills
2.
Fruit
of
the
Loom
Co.
4.
Pine
Hosiery
Mills
Quantitation
of
Characteristic
Organic
Parameters
Organic
priority
pollutants
are
generally
not
characteristic
of
textile
user
wastewater.
Analyses
of
wastewater
samples
taken
at
textile
users
regularly
detected
very
few
specific
organic
parameters,
other
than
chloroform,
and
concentrations
typically
approached
the
lowest
level
detectable
by
the
test
method.
Chloroform
was
the
organic
parameter
most
frequently
observed,
probably
because
of
its
potential
for
being
generated
in
the
hypochlorite
(
chlorine
+
caustic)
bleaching
process.
Another
source
is
the
potable
water
supply
typically
used
for
wet
processing,
which
averages
about
80
ppb
chloroform
as
a
consequence
of
disinfection
with
chlorine.

Although
the
POTW
at
East
Providence,
RI,
monitored
textile
users'
wastewater
for
the
organic
parameter
TTO
(
total
"
toxic"
organics),
TTO
volatiles
were
observed
only
twice
near
the
detection
limit
of
the
analytical
method.
The
POTW
at
Star,
NC,
did
not
require
textile
users
to
monitor
for
specific
organic
parameters.
Average
concentrations
for
specific
organic
parameters
in
wastewater
being
discharged
to
the
POTW
at
Valdese,
NC,
are
summarized
in
Table
VI­
7.
Detailed
listings
of
specific
organic
parameters
that
were
quantified
in
analyses
of
the
wastewater
of
textile
users
discharging
to
each
of
these
three
POTWs
is
shown
in
Appendix
II­
4.
27
Table
VI­
7
Data
from
Textile
Users
Discharging
to
POTW
at
Valdese,
NC.

Textile
Users
of
Valdese
POTW
Parameters
1
2
3
4
5
6
7
8
9
Acrolein
­­
132
­­
­­
­­
­­
­­
­­
­­
Chloroform
­­
535
9
15
­­
4
­­
23
5
Di­
n­
butyl
phthalate
­­
­­
­­
­­
­­
­­
­­
­­
*
Di(
2­
ethylhexyl)
phthalate
*
*
­­
­­
­­
*
­­
­­
*
Ethylbenzene
­­
­­
­­
13
­­
­­
­­
­­
­­
Naphthalene
­­
­­
­­
156
­­
­­
7
­­
­­
Xylenes
­­
­­
­­
110
­­
­­
­­
­­
­­

Concentration
unit:
ug/
L
(
ppb)
There
are
no
local
limits
for
specific
organic
parameters.
Codes:
*
=
detected,
but
attributable
to
sample
contamination;
(­­)
=
not
detected.

Textile
Users:
1.
Burke
Mills
6.
Alba­
Waldensian
2.
Neuville
Industries
7.
Adams
Millis­
Drexel
3.
Valdese
Textiles
8.
Carolina
Mills
4.
OMS
Textiles
9.
Valdese
Manufacturing
5.
Valdese
Weavers
Pretreatment
Technologies
and
Practices
Employed
by
Textile
Users
In
responding
to
another
section
of
the
AMSA
survey,
96
textile
users
(
out
of
a
total
of
251)
indicated
that
their
process
wastewater
was
pretreated
by
one
or
more
technologies
before
being
discharged
to
the
POTW.
The
pretreatment
technologies
employed
by
textile
users
and
reported
in
the
AMSA
survey
may
be
summarized
as
follows.

Equalization
­
Storage
basins
above
and
below
ground,
as
well
as
ponds,
were
reportedly
used
for
retention
and
mixing
(
equalizing)
of
wastewater
from
various
in­
plant
processes.
In
one
case,
a
sluice
gate
was
installed
for
the
control
of
peak
flow.
Provisions
for
wastewater
equalization
afford
a
more
consistent
wastewater
and
avoid
surges
of
more
concentrated
wastewater
(
so­
called
"
slugs")
from
being
discharged
to
the
POTW.

Oil­
Water
Separation
­
Centrifugation
was
employed
for
the
separation
of
lanolin
from
wool
processing
wastewater,
before
it
was
discharged
to
the
POTW.

Neutralization
­
Among
textile
users,
control
of
pH
is
the
pretreatment
most
widely
practiced.
Many
have
installed
systems
that
control
pH
automatically.
In
order
to
neutralize
(
pH
6­
9)
the
wastewater
prior
to
discharge
to
the
POTW,
soda
ash
(
sodium
carbonate),
caustic
(
sodium
hydroxide)
and
acetic
acid
were
all
reportedly
in
use
for
adjusting
pH.
28
Temperature
Control
­
The
National
Pretreatment
Standards
(
40
CFR
Section
403.5)
prohibit
the
discharge
of
hot
wastewater
in
amounts
that
will
cause
the
temperature
of
wastewater
received
at
the
POTW
to
be
raised
above
40oC
(
104oF).
In
accordance
with
this
requirement,
some
textile
users
have
installed
heat
exchangers
to
cool
wastewater
prior
to
discharge
to
the
POTW.
The
heat
recovered
has
also
been
used
to
pre­
heat
water
being
supplied
to
dyeing
machines,
thereby
reducing
energy
costs.

Filtration
­
Various
types
of
filters
are
utilized
by
textile
users
to
control
suspended
solids
(
TSS).
Chemical
flocculents
are
used
to
enhance
the
effectiveness
of
filtration.
Textile
users
reported
removal
of
floc
and
solids
by:
filter
media
in
columns,
"
Hydrosieve"
filter,
rotating
drum
filter
and
cotton
fiber
drum
filter.

Screening
­
Lint
can
present
a
problem
in
wastewater,
when
it
becomes
woven
in
combination
with
hair
and
other
fibrous
detritus
into
stringy
rope­
like
mats.
Various
types
of
screens
are
utilized
to
control
lint
in
wastewater
discharged
to
POTWs.
The
metal
screens
average
40
mesh,
with
finer
screens
ranging
from
120
to
200
mesh.
Textile
users
reported
removing
lint
with:
static
screens,
shaker
screens,
trench
screens,
double
basket
strainers,
Sweco
screen
and
screen
filters.
A
pre­
screen
filter
(
3/
8"
mesh)
was
utilized
by
one
textile
user
to
protect
lint
screens
from
blockage
by
small
pieces
of
fabric.

Sedimentation
­
Textile
users
reported
the
use
of
gravity
separation
to
satisfy
pretreatment
requirements
for
control
of
solids.
Most
employed
some
type
of
clarifier,
or
sedimentation
chamber.
One
textile
user
referred
to
this
as
a
"
settling
pit."

Color
Removal
­
Generally,
textile
users
remove
color
by
oxidative
destruction
of
the
dyes.
The
most
widely
used
pretreatment
is
bleaching
with
sodium
hypochlorite
solution,
where
chlorine
is
the
oxidant.
Another
oxidant
that
was
used
was
potassium
permanganate
solution.
One
textile
user
reduced
the
color
intensity
of
a
portion
of
its
process
wastewater
by
equalizing
it
with
other
colorless
(
perhaps
reactive)
wastewater
in
a
holding
pond
prior
to
discharge.

Sulfide
Oxidation
­
Some
textile
users
reported
pretreating
wastewater
to
diminish
sulfide
concentration
by
oxidation
with
hydrogen
peroxide.

Biological
­
While
biological
treatment
is
exclusively
used
by
direct
dischargers
to
meet
NPDES
permit
limits,
few
textile
users
in
the
AMSA
survey
reported
biological
pretreatment.
Examples
of
biological
pretreatment
reported
by
textile
users
included:
an
extended
aeration
system
(
package
plant);
a
bio­
tower,
with
solids
recovery
by
dissolved
air
floatation
(
DAF).

POTW
user
fees
are
typically
based
on
the
BOD
load
of
industrial
users'
wastewater.
When
an
industrial
user's
discharge
exceeds
the
BOD
load
allocated
by
the
POTW,
the
user
usually
pays
a
surcharge
calculated
by
a
formula
published
with
the
local
limits.
Although
the
BOD
load
of
textile
user
wastewater
is
usually
well
below
the
maximum
permitted,
increased
production
coupled
with
process
changes
can
sometimes
result
in
a
textile
user's
BOD
load
exceeding
the
maximum
permitted.
If
the
POTW
is
already
operating
near
its
design
capacity
for
BOD
load,
and
an
additional
allocation
is
unavailable
from
other
users,
the
POTW
may
require
pretreatment.
29
An
example
of
this
was
reported
by
one
POTW
in
the
AMSA
survey.
In
order
to
comply
with
pretreatment
requirements
in
a
court­
ordered
upgrade,
one
textile
user
had
to
install
a
complete
activated
sludge
process,
which
included:
primary
clarifier,
aeration,
secondary
clarifier,
aerobic
digester,
and
thickener
(
for
sludge
dewatering).

Impact
of
Textile
Process
Wastewater
on
POTWs
Generally,
textile
user
discharges
were
not
problematic
at
the
POTWs
surveyed
in
this
study.
This
conclusion
was
reached
after
reviewing
responses
to
Section
A
of
the
AMSA
survey,
and
after
phone
conversations
with
staff
responsible
for
pretreatment
programs
at
most
of
the
POTWs
involved.
In
those
cases
where
monitoring
data
has
confirmed
a
textile
user's
discharge
is
out
of
compliance
with
its
IU
permit,
or
there
are
reasonable
grounds
for
suspecting
that
textile
user
discharges
are
causing
problems
at
the
POTW,
textile
users
and
the
POTW
pretreatment
program
enter
into
a
cooperative
effort
to
resolve
the
difficulty.
A
remedy
is
often
achieved
by
textile
users
modifying
one
or
more
manufacturing
processes
to
the
extent
practicable,
or
by
installing
pretreatment
technology
so
as
to
comply
with
local
limits.

The
AMSA
survey
asks
three
questions
about
the
impact
of
textile
process
wastewaters
being
discharged
to
POTWs.
1.
(
A­
4)
Does
it
"
pass
through"
the
POTW,
or
cause
"
interference"?
Survey
responses:
Yes
=
4;
No
=
21
2.
(
A­
5)
Does
it
cause
a
nuisance,
or
otherwise
impair
POTW
operations?
Survey
responses:
Yes
=
5;
No
=
20
3.
(
A­
6)
Were
additional
capital
or
O&
M
costs
incurred
by
the
POTW
that
could
be
attributed
specifically
to
textile
wastewater?
Survey
responses:
Yes
=
2;
No
=
23
The
following
synopses
of
the
"
yes"
responses
serve
as
examples
of
problems
that
textile
user
discharges
sometimes
present
to
POTWs,
as
well
as
the
technical
remedies
that
were
employed
in
these
cases
to
resolve
the
problems.

POTW
at
Columbus,
GA
Response
to
A­
4:
The
pretreatment
system
at
a
textile
user's
plant
(
0.6
MGD)
was
taken
off­
line
for
approximately
8
weeks
to
repair
the
aeration
basin.
During
this
time,
the
POTW
exceeded
its
permit
limits
for
BOD
and
TSS.
The
POTW
could
not
specifically
attribute
these
exceedances
to
excessive
BOD
loading
from
the
textile
user.
But
since
the
wastewater
lacked
pretreatment,
unidentified
constituents
in
the
textile
user's
discharge
were
alleged
to
have
been
responsible
for
an
inhibitory
effect
on
the
POTW's
treatment
efficiency
(
interference).

Response
to
A­
5:
(
a)
A
textile
user's
(
2
MGD)
discharge
was
suspected
of
having
caused
excessive
foaming
problems
in
the
POTW
grit
chamber
for
about
2
weeks
during
the
initial
operation
of
a
new
dyeing
process;
(
b)
A
textile
user's
discharge
with
excessive
conductivity
and
dissolved
solids
was
suspected
of
causing
corrosion
problems
in
a
collection
system
pump
station.
30
POTW
at
Columbus,
GA
(
continued)

Response
to
A­
6:
To
meet
their
NPDES
permit
limits
for
BOD
and
TSS
during
episodes
such
as
those
described
in
the
A­
4
response,
the
POTW
uses
polymeric
flocculants.
These
"
chemical
costs"
are
recovered
by
surcharging
its
industrial
users
(
IUs)
an
additional
fee.
Simply
because
of
their
potential
as
a
source
of
wastewater
with
high
BOD
and
TSS
concentrations,
textile
facilities
are
among
the
POTW's
users
that
are
surcharged
during
these
excursions.
Surcharges
allocated
to
textile
users
of
the
POTW
were
not
given.

POTW
at
Greenville,
SC
Response
to
A­
4:
In
the
Fall
of
1986,
the
POTW
(
Travelers
Rest
East)
began
to
consistently
violate
its
TSS
limits.
This
continued
for
6­
8
months,
until
polymer
addition
became
necessary
to
bring
TSS
within
limits.
These
violations
began
close
to
the
time
a
textile
user
(
Kreiger)
installed
a
bleach
line,
which
raised
the
pH
and
substantially
increased
the
BOD
of
its
discharge
to
the
POTW.
This
discharge
affected
the
POTW's
operation
by
raising
its
influent
pH
by
1.2
units
and
doubling
its
BOD
loading
rate.
Consequently,
the
POTW's
design
load
for
BOD
was
reached
at
only
60%
of
its
design
flow.

The
textile
user's
new
bleach
line
also
changed
the
treatability
of
its
wastewater.
Contributing
to
the
problem
was
a
variation
in
the
types
of
sizes
(
e.
g.
CMC
vs.
starch)
being
removed
from
the
textile
goods
being
processed,
which
resulted
in
a
microbial
food
source
of
varying
biodegradability.
It
was
suggested
that
the
type
of
surfactants
being
used
with
the
bleach
line
might
have
also
contributed
to
the
problem.

Remedies:
Two
textile
users
(
Kreiger
and
M­
TEX)
were
required
to
install
automatic
pH
control
systems.
In
addition,
the
two
users
were
required
to
install
equalization
tanks
to
intercept
wastewater
from
static
scour
and
finishing
boxes,
as
well
as
finish
mix
tanks.
The
equalized
wastestream
was
to
be
incrementally
mixed
("
bled
in")
with
other
plant
wastewaters
before
being
discharged
to
the
POTW.
Kreiger
was
also
required
to
halve
its
BOD/
COD
load
by
pretreatment
to
come
into
compliance
with
the
limits
of
its
industrial
user
permit.
Unless
this
user's
BOD
load
was
reduced,
the
POTW
would
have
continued
to
have
trouble
maintaining
acceptable
dissolved
oxygen
levels
and
MLSS
in
the
aeration
basin.
It
was
anticipated
that
these
measures
would
allow
the
POTW
to
control
TSS
in
its
effluent
without
the
addition
of
polymer
flocculant.

Response
to
A­
6:
The
sewer
authority
obtained
an
Administrative
Consent
Order
against
the
textile
user
(
Krieger)
to
recover
the
cost
of
the
polymer
needed
to
control
TSS
during
the
period
of
the
POTW
operational
problems.

POTW
at
Chicago,
IL.

Response
to
A­
5:
Investigating
complaints
of
noxious
odors,
POTW
personnel
repeatedly
detected
ammonia
concentrations
in
excess
of
short­
term
limits
in
the
vicinity
of
a
textile
user's
facility
from
1981
to
1992.
This
nuisance
prompted
the
POTW
to
issue
several
violations
during
this
time
period.
To
eliminate
the
odors
in
the
vicinity
of
its
facility,
the
textile
user
eventually
31
POTW
at
Chicago,
IL
(
continued)

upgraded
an
existing
ammonia
scrubber
and
rerouted
in­
plant
sewer
lines.
This
nuisance
did
not
affect
wastewater
treatment
operations
at
the
POTW.

POTW
at
Philadelphia,
PA.

Response
to
A­
5:
Nuisances
prohibited
by
general
pretreatment
regulations
occurred,
but
these
incidents
did
not
significantly
affect
wastewater
treatment
operations
at
the
POTW.
Description
of
incidents:
(
a)
Sewer
outside
textile
user's
facility
became
choked
by
felt
and
jute;
and
(
b)
Hot
wastewater
from
a
wool
scouring
textile
user
caused
fogging
at
the
POTW.

POTW
(
Bucklin
Point)
at
East
Providence,
RI.

Response
to
A­
5:
Red
dye
passed
through
the
POTW
(
Bucklin
Point)
on
several
occasions.
While
the
dye
did
not
adversely
affect
wastewater
treatment
operations,
it
did
present
the
POTW
with
a
compliance
problem
(
see
below).
The
textile
user
responsible
for
the
discharge
was
identified
and
agreed
to
install
a
pretreatment
system
to
remove
color.
The
textile
user
has
experienced
operational
difficulties
in
fully
implementing
the
new
system.

The
POTW
recognizes
color
as
a
largely
aesthetic
parameter.
But
in
1993
a
specific
clause
prohibiting
the
discharge
of
wastewater
with
"
objectionable"
color
was
added
to
its
NPDES
permit.

POTW
at
Nashville,
TN.

Reponse
to
A­
5:
Foaming
and
poor
settling
of
solids
in
primary
clarifier
attributed
to
a
textile
user.
This
was
a
transient
occurrence
and
did
not
significantly
affect
wastewater
treatment
operations
at
the
POTW.

Pollution
Prevention
at
Textile
Users
The
AMSA
survey
also
asked
respondents
to
indicate
the
"
types
of
pollution
prevention
techniques
(
defined
by
several
examples)
that
are
being
utilized,"
or
are
under
consideration,
at
their
textile
IU
facilities.
Respondents
reported
a
number
of
these
techniques
had
been
implemented
in
order
to
reduce
regulatory
liability
and
improve
operating
efficiency.
These
changes
may
be
summarized
as
follows.

Alternative
Process
Chemicals
­
When
technically
feasible,
process
chemicals
were
changed
to
use
more
biodegradable/
water­
soluble
chemicals
and
dyes;
use
pigment
solutions
with
lower
volatiles
content;
eliminate
ammonia
(
alternative
unreported);
discontinue
use
of
mineral
petroleum
products
as
solvents
(
alternative
unreported).
32
Pollution
Prevention
(
continued)

Process
Changes
­
Dyeing
process
was
altered
to
use
less
dyestuff.
Dyeing
cycles
were
shortened.
More
precise
calculation
of
the
amount
needed
resulted
in
less
pigment
per
run.
Dye
systems
were
converted
to
others
that
are
less
water­
intensive.
Conversion
of
batch
to
continuous
bleach
ranges.
Began
recovery
of
sizing
for
reuse.
Inventory
control
was
improved
by
"
production
labelling,"
which
also
lowered
levels
of
contaminants
in
wastewater.
Overall
chemical
usage
was
reduced
by
limiting
services
to
clients.

Equipment
Changes
­
Installation
of
more
efficient
dye
machinery.
Batch
replaced
with
continuous
dyeing
machines,
which
decreased
water
use.
Conversion
to
liquor
and
ratio
dyeing
equipment.
Evaluation
of
a
dye
machine
that
will
use
recycled
dye.
Replaced
conventional
atmospheric
rotaries
with
pressure
equipment,
which
offers
better
containment
of
volatiles
and
improved
workplace
environment.
Upgraded
efficiency
of
boiler.
Existing
lint
screens
replaced
with
revolving
lint
screens
(
continuously
self­
cleaning).
Grates
were
installed
to
retain
wastewater
detritus
(
rags,
trash,
etc.).

Water
Reuse
­
Rinses
from
latex
pump
cleaning
were
reused
in
process.
Print
screen
rinse
water
was
reused
for
rinsing.
The
last
rinse
of
a
scouring
machine
was
reused
in
the
first
and
second
scours.
On
a
washing
line,
water
from
the
last
rinse
bath
was
reused
in
the
first
bath.
Rinse
water
from
later
stages
(
3rd
or
4th
rinse)
being
considered
for
reuse
in
earlier
stages.
Sizing
was
reused
after
being
removed
from
fabric
by
counterflow
washing.

Water
Recycle
­
Roller
dryer
was
equipped
with
a
water
recycle
bath.
A
system
was
installed
to
recycle
pump
seal
cooling
water.
Condensers
were
installed
to
capture
water
exhausted
from
dryer
for
recycle
to
process.

Water
Conservation
­
Volume
of
process
wastewater
was
reduced
by
changing
from
regular
batch
("
piece")
dyeing
to
a
dyebath
schedule
known
as
"
color
sequencing,"
or
dyeing
in
a
sequence
of
batches
that
progress
from
light
to
dark
colors.
The
dye
beck
is
merely
drained
(
no
rinse)
after
each
batch,
and
only
rinsed
with
water
upon
completion
of
the
sequence.
Process
water
was
conserved
by
keeping
the
number
of
dyeing
cycles
to
a
minimum.
Non­
contact
cooling
water
was
reclaimed
for
process
use.
Condensate
from
steam
lines
was
recycled.
Boiler
was
modified
to
give
more
concentration
cycles
between
blowdowns.
Less
frequent
boiler
blowdown
reduced
the
total
volume
of
wastewater
discharged.
Water
conservation
training
was
provided
for
employees.

Heat
Recovery
­
Heat
exchangers
are
used
to
recover
heat
that
would
otherwise
be
wasted.
Heat
exchangers
were
installed
for
individual
dye
becks.
Heat
exchanger
("
economizer")
in
boiler
stack
was
used
to
preheat
water.
Steam
was
more
efficiently
cogenerated
by
preheating
boiler
feed
with
water
returned
from
in­
plant
heat
exchangers.
This
also
reduced
the
volume
of
boiler
blowdown.
33
VII.
CHARACTERIZATION
of
FINAL
EFFLUENTS
The
Permit
Compliance
System
(
PCS)

The
PCS
is
a
computerized
information
management
system
that
serves
as
a
repository
for
monitoring,
compliance
and
enforcement
data,
as
well
as
conditions
for
NPDES
permits.
Compliance
with
NPDES
permits
is
verified
via
Monthly
Discharge
Monitoring
Reports
(
DMRs).
DMR
data
is
entered
into
the
PCS
by
EPA
Regional
Offices
or
States,
and
may
include
concentration
or
quantity
data
(
as
specified
in
the
permit)
for
each
parameter
that
is
measured
at
each
permitted
outfall.

Parameters
Limited
in
Textile
Mills
NPDES
Permits
The
PCS
database
was
searched
for
NPDES
permits
issued
under
SIC
22.
While
413
NPDES
permits
were
identified,
only
122
of
these
permits
were
validated
(
see
Appendix
VII)
as
being
applicable
to
the
discharge
of
treated
process
wastewater.
The
others
were
apparently
for
noncontact
cooling
water,
filter
backwash,
storm
water,
etc.
Still
others
were
for
expired
NPDES
permits,
where
the
textile
facilities
now
discharge
to
a
POTW.
There
were
also
at
least
three
NPDES
permits
that
had
presumably
been
issued
and
encoded
in
the
PCS
under
an
incorrect
SIC
code
(
i.
e.,
the
permitted
facility
should
not
have
been
assigned
to
the
textile
mills
category).

The
122
validated
permits
for
textile
facilities
were
reviewed
to
identify
the
parameters
that
had
been
limited.
This
would
give
an
indication
of
the
parameters,
beyond
those
in
the
categorical
standards,
that
had
been
added
to
permits
in
order
to
assure
compliance
with
limitations
based
on
water
quality
standards
or
other
site­
specific
conditions.
Parameters
regulated
by
categorical
standards
are
listed
in
Table
VII­
1,
while
additional
parameters
are
listed
in
Table
VII­
2.

Regulated
by
categorical
standards,
BOD,
COD,
TSS,
chromium,
sulfide,
phenols
(
total)
and
pH
were
the
parameters
most
frequently
limited
in
the
NPDES
permits
of
textile
facilities.
Although
"
phenols
(
total)"
is
the
parameter
regulated
in
NPDES
permits
and
monitored
by
permitees,
for
some
permits
the
parameter
had
been
incorrectly
encoded
in
the
PCS
as
"
phenol
single
compound."
This
confusion
apparently
stems
from
the
listing
of
the
regulated
parameter
in
some
subcategories
(
40
CFR
Part
410)
as
"
phenols,"
while
in
other
subcategories
it
is
shown
as
"
phenol."
Oil
&
Grease
was
limited
less
frequently,
mostly
in
permits
issued
to
textile
mills
processing
wool.

Among
the
other
pollutant
parameters,
ammonia,
phosphorus,
chlorine
(
residual)
and
fecal
coliform
were
the
most
common.
Ammonia
and
phosphorus
are
generated
by
the
biodegradation
of
sanitary
wastewater
(
human
waste)
and
nitrogen­
containing
dyes.
Fecal
coliform
and
chlorine
(
residual)
are
a
consequence
of
the
wide­
spread
practice
of
mixing
sanitary
wastewater
with
process
wastewater
in
order
to
obtain
nutrients
to
support
biological
treatment
systems.
Chromium
is
the
metal
most
frequently
found
on
textile
NPDES
permits,
because
it
is
regulated
by
categorical
standards.
Zinc
and
copper
are
the
next
most
frequently
limited
metals
on
the
permits
of
textile
facilities,
as
reported
in
Table
VII­
2.
34
Table
VII­
1
NPDES
Permit
Parameters
Regulated
by
Categorical
Standards
Facilities
Percentage
of
Parameter
Reporting
Total
(
122)

BOD1
117
96
BOD2
1
<
1
COD3
99
81
COD4
14
11
TSS5
116
95
Chromium6
106
87
Chromium7
5
4
Sulfide8
101
83
Phenols9
105
86
Oil
&
Grease10
22
18
Oil
&
Grease11
1
<
1
Oil
&
Grease12
1
<
1
pH
120
98
PCS
Parameter
Descriptors:
1.
BOD,
5­
Day
(
20
deg.
C)
7.
Chromium,
hexavalent
(
as
Cr)
2.
BOD,
Carbonaceous
05
Day,
20C
8.
Sulfide,
total
(
as
S)
3.
Oxygen
demand,
chem.
(
high
level)
9.
Phenols,
total
4.
Oxygen
demand,
chem.
(
low
level)
10.
Oil
&
Grease
Freon
extract­
grav.
method
5.
Solids,
total
suspended
11.
Oil
&
Grease
(
soxhlet
extract),
total
6.
Chromium,
total
(
as
Cr)
12.
Oil
&
Grease
(
Freon
extr.­
IR
method)
total
recov.

Specific
organic
chemicals
were
found
to
be
limited
on
very
few
permits.
In
such
cases,
it
is
likely
that
an
organic
chemical
was
initially
identified
in
the
analysis
of
treated
effluent
for
the
permit
application,
and
this
prompted
the
permitting
authority
to
require
additional
monitoring
of
the
chemical
by
limiting
it
in
the
permit.
Also,
an
organic
chemical
(
e.
g.,
formaldehyde)
may
have
been
limited
in
the
permit
because
it
was
known
to
be
in
process
use
at
the
facility.
Organic
priority
pollutants
were
collectively
limited
on
some
permits
under
the
parameter
TTO
(
total
"
toxic"
organics).

The
North
Carolina
Annual
Pollutant
Analysis
Monitoring
(
APAM)
Database
Beginning
in
1988,
new
and
renewed
NPDES
permits
selected
by
the
state
permitting
authority
carried
a
requirement
for
an
annual
priority
pollutant
scan
and
whole
effluent
toxicity
(
WET)
testing.
The
stated
intention
was
to
use
this
database
to
define
any
"
pollutants
of
concern"
that
might
characterize
discharges
of
"
complex
wastewater,"
which
was
defined
as
wastewater
being
discharged
from
industrial
sources
at
a
flow
rate
greater
than
0.5
million
gallons
per
day
(
mgd).
These
annual
monitoring
requirements
continued
to
be
added
to
selected
new
and
renewed
NPDES
permits
through
late
1993,
when
the
practice
was
halted
until
the
collected
data
could
be
encoded
and
analyzed.

The
APAM
database
contains
data
collected
from
158
industrial
NPDES
permits,
but
only
29
were
NPDES
permits
of
textile
mills.
One
was
fortunately
the
permit
of
a
POTW
(
Valdese)
35
Table
VII­
2
Additional
NPDES
Permit
Parameters
Facilities
Percentage
of
Parameter
Reporting
Total
(
122)

Coliform1
50
41
Coliform2
24
20
Turbidity,
NTU
1
<
1
Solids,
settleable
6
5
Solids,
total
dissolved
3
2.4
Surfactants
(
MBAS)
4
3
Color
(
ADMI
units)
13
11
Color
(
Pt­
Co
units)
15
12
Specific
conductance
2
1.6
Inorganics
Oxygen,
dissolved
73
60
Cyanide,
total
(
as
CN)
7
6
Ammonia3
2
1.6
Nitrogen4,
ammonia
48
39
Nitrogen5,
total
29
24
Nitrogen6,
Kjeldahl
6
5
Nitrogen7,
nitrate
1
<
1
Nitrogen8,
NO2
+
NO3
1
<
1
Phosphorus,
total
40
33
Chlorine,
total
resid.
50
41
Chloride,
(
as
Cl)
11
9
Fluoride,
total
(
as
F)
1
<
1
Sulfate,
total
1
<
1
Hydrogen
sulfide
1
<
1
Hardness,
total
(
as
CaCO3)
1
<
1
Organics
TOC9
1
<
1
TTO10
17
14
Chlorodibromomethane
1
<
1
Dichlorobromomethane
1
<
1
Chloroform
2
1.6
Methylene
chloride
1
<
1
1,1­
Dichloroethylene
1
<
1
Trichloroethylene
1
<
1
Formaldehyde
3
2.4
Di(
2­
ethylhexyl)
phthalate
2
1.6
4­
Chloro­
m­
cresol
1
<
1
2,4­
Dimethylphenol
1
<
1
Dieldrin
1
<
1
4,4'­
DDD
1
<
1
Parameter
Descriptors:
1.
Coliform,
fecal
general
6.
Nitrogen,
Kjeldahl
total
(
as
N)
2.
Coliform,
fecal
MF,
M­
FC
broth,
44.5o
C
7.
Nitrogen,
Nitrate,
total
(
one
det.
as
N)
3.
Ammonia
(
as
N)
+
unionized
ammonia
8.
Nitrite
+
Nitrate,
total
(
one
det.
as
N)
4.
Nitrogen,
ammonia
total
(
as
N)
9.
Total
organic
carbon
36
5.
Nitrogen,
total
10.
Total
"
toxic"
organics
37
Table
VII­
2
(
continued)
Additional
NPDES
Permit
Parameters
Facilities
Percentage
of
Parameter
Reporting
Total
(
122)

Metals
Aluminum,
total
1
<
1
Antimony,
total
2
1.6
Arsenic,
total
(
as
As)
2
1.6
Beryllium,
total
1
<
1
Cadmium,
total
(
as
Cd)
3
2.4
Cobalt,
total
1
<
1
Copper,
total
(
as
Cu)
37
30
Lead,
total
(
as
Pb)
12
10
Mercury,
total
(
as
Hg)
7
6
Nickel,
total
(
as
Ni)
7
6
Selenium,
total
1
<
1
Silver,
total
(
as
Ag)
4
3
Zinc,
total
(
as
Zn)
44
36
Whole
Effluent
Toxicity
(
WET)
48­
hr.
acute
toxicity
test1
23
19
48­
hr.
acute
toxicity
test2
18
15
7­
day
chronic
toxicity
test3
48
39
Acute
toxicity
test4
2
1.6
1.
LF
P/
F
statre
48­
hr
acu
Daphnia
pulex
2.
LF
P/
F
statre
48­
hr
acu
Pimephales
promel
3.
LF
P/
F
statre
7­
day
chr
Ceriodaphnia
4.
Toxicity,
final
conc.
toxicity
units
with
a
substantial
flow
component
from
textile
users.
Although
28
permits
had
been
issued
correctly
under
SIC
22
(
the
primary
code
for
textile
facilities),
two
permits
had
been
issued
under
an
incorrect
primary
SIC
code.
The
correct
primary
codes
were
obtained
from
these
two
facilities
and
forwarded
to
the
state
coordinator
in
charge
of
electronic
data
transfer
to
EPA's
Permit
Compliance
System
(
PCS).

Compiled
directly
from
the
standard
form
on
which
North
Carolina
required
participating
labs
to
submit
analytical
results,
these
data
are
shown
in
Appendix
III­
2.
The
reported
concentrations
of
priority
pollutants
were
averaged
and
are
summarized
in
Table
VII­
3.
The
APAM
data
summaries
reflect
the
parameters
and
range
of
concentrations
being
discharged
directly
to
surface
waters
from
textile
sources.

Evaluation
of
the
APAM
Data
Summaries
The
data
in
Table
VII­
3
identify
the
priority
pollutant
parameters
and
average
concentrations
that
characterize
treated
wastewater
being
discharged
by
30
textile
facilities
in
North
Carolina.
Table
VII­
4
shows
how
frequently
the
parameters
were
identified,
and
tabulates
their
average
and
maximum
concentrations
at
each
of
the
participating
textile
facilities.
These
concentrations
are
also
compared
to
the
technology­
based
BAT
effluent
limitations
of
two
other
industrial
categories:
metal
finishing
(
MF)
and
organic
chemicals,
plastics
and
synthetic
fibers
(
OCPSF).
38
Table
VII­
3
Summary
of
North
Carolina
APAM
Data
Textile
Mills
Parameters
1
2
3
4
5
6
7
8
9
10
Bromomethane
(
10)
­­
21
­­
­­
­­
­­
­­
­­
­­
­­
Trichloroethylene
(
5)
­­
­­
­­
­­
­­
­­
­­
8
­­
­­
Antimony
(
50)
83
­­
­­
­­
472
­­
­­
­­
57
97
Arsenic
(
10)
­­
­­
­­
­­
­­
71
113
­­
19
33
Chromium
(
5)
­­
35
­­
­­
175
­­
­­
­­
19
­­
Copper
(
2)
82
6
91
13
107
20
30
273
230
75
Lead
(
10)
­­
­­
­­
­­
34
12
­­
­­
13
­­
Mercury
(
0.2)
­­
­­
­­
0.2
­­
­­
1.3
0.2
­­
0.2
Nickel
(
10)
­­
­­
­­
­­
18
11
­­
­­
28
­­
Silver
(
5)
­­
­­
­­
­­
­­
­­
19
­­
35
­­
Zinc
(
10)
40
60
59
58
85
61
181
106
441
31
Parameters
11
12
13
14
15
16
17
18
19
20
Bromodichloromethane(
5)
­­
6
­­
­­
­­
­­
5
­­
­­
5
Chloroform
(
5)
­­
9
­­
­­
­­
­­
26
243
­­
13
Dibromochloromethane(
5)
­­
5
­­
­­
­­
­­
­­
­­
­­
­­
Methylene
chloride
(
5)
­­
­­
­­
­­
12
­­
­­
­­
­­
­­
1,1,1­
Trichloroethane
(
5)
­­
­­
­­
208
­­
­­
­­
­­
­­
­­
1,2,4­
Trichlorobenzene(
5)
­­
­­
­­
­­
­­
­­
­­
190
­­
­­
Antimony
(
50)
­­
123
150
­­
­­
580
­­
­­
­­
­­
Arsenic
(
10)
­­
13
­­
­­
­­
­­
49
13
­­
­­
Cadmium
(
2)
­­
3
2.5
­­
6
­­
­­
3
­­
3
Chromium
(
5)
­­
­­
5
­­
­­
96
7
35
508
16
Copper
(
2)
47
57
25
250
70
290
53
117
15
36
Lead
(
10)
­­
53
45
10
90
­­
­­
26
­­
13
Mercury
(
0.2)
­­
­­
­­
0.2
­­
­­
0.5
­­
0.5
­­
Nickel
(
10)
­­
­­
­­
­­
­­
­­
­­
34
­­
14
Zinc
(
10)
167
76
35
413
128
90
680
76
95
147
Concentration
unit:
ug/
L
(
ppb).
Code:
(­­)
=
Not
detected.
Averaging
criteria:
Not
detected
averaged
as
zero.
If
the
concentration
average
was
less
than
the
"
quantitation
limit
target"
(
indicated
parenthetically)
specified
by
the
APAM
reporting
form,
the
average
is
represented
in
this
table
as
not
detected.

Textile
Mills:
1.
American
Thread
­
Charlotte
11.
Fieldcrest
Cannon
­
Eden
2.
Burlington
Industries
­
Forest
City
12.
Fieldcrest
Cannon
­
Salisbury
3.
Burlington
Industries
­
Wake
Forest
13.
Fieldcrest
Cannon
­
Laurel
Hill
4.
Burlington
Industries
­
Cordova
14.
Glen
Raven
Mills
­
Altamahaw
5.
Chatham
Manufacturing
­
Elkin
15.
Grover
Industries
­
Grover
6.
Cone
Mills
­
Greensboro
16.
Guilford
Mills
­
Kenansville
7.
Cone
Mills
­
Cliffside
17.
Huffman
Finishing
­
Granite
Falls
8.
Cleveland
Mills
­
Lawndale
18.
Minnette
Textiles
­
Grover
9.
Cranston
Print
Works
­
Fletcher
19.
Monarch
Hosiery
Mills
­
Burlington
10.
Delta
Mills
­
Maiden
20.
National
Spinning
­
Washington
39
Table
VII­
3
(
cont.)
Summary
of
North
Carolina
APAM
Data
Textile
Mills
Parameters
21
22
23
24
25
26
27
28
29
30
Bromodichloromethane(
5)
­­
14
­­
­­
­­
­­
­­
­­
­­
­­
Chloroform
(
5)
­­
21
5
­­
9
­­
­­
­­
­­
­­
Ethylbenzene
(
8)
­­
­­
22
­­
­­
­­
­­
­­
­­
­­
Methylene
chloride
(
5)
­­
­­
­­
­­
­­
­­
­­
­­
7
­­
Tetrachloroethylene
(
5)
­­
­­
­­
­­
­­
16
­­
­­
­­
­­
Antimony
(
50)
­­
­­
­­
64
­­
76
­­
­­
­­
95
Arsenic
(
10)
­­
11
­­
29
­­
13
­­
­­
­­
­­
Cadmium
(
2)
­­
­­
­­
6
­­
3.6
­­
­­
­­
2.5
Chromium
(
5)
­­
­­
118
19
­­
­­
50
6
21
17
Copper
(
2)
41
143
26
10
13
152
140
45
476
278
Lead
(
10)
­­
­­
­­
­­
­­
20
­­
­­
23
28
Mercury
(
0.2)
­­
­­
­­
­­
0.2
0.4
­­
­­
1.6
­­
Nickel
(
10)
45
­­
10
13
­­
12
­­
50
­­
­­
Zinc
(
10)
219
36
79
43
24
109
36
40
57
382
Concentration
unit:
ug/
L
(
ppb).
Code:
(­­)
=
Not
detected.
Averaging
criteria:
Not
detected
averaged
as
zero.
If
the
concentration
average
was
less
than
the
"
quantitation
limit
target"
(
indicated
parenthetically)
specified
by
the
APAM
reporting
form,
the
average
is
represented
in
this
table
as
not
detected.

Textile
Mills:
21.
Schneider
Mills
­
Taylorsville
26.
United
Piece
Dye
Works
­
Edenton
22.
StevcoKnit
Fabrics
­
Wallace
27.
WestPoint
Pepperell
­
Elizabethtown
23.
Stowe­
Pharr
Mills
­
McAdenville
28.
WestPoint
Pepperell
­
Wagram
24.
Swift
Textiles
­
Erwin
29.
WestPoint
Pepperell
­
Lumberton
25.
Tuscarora
Yarns
­
China
Grove
30.
WestPoint
Pepperell
­
Hamilton
Like
untreated
or
pretreated
textile
user
process
wastewater
discharged
to
POTWs
(
see
Section
VI),
metal
priority
pollutant
parameters
predominantly
characterize
treated
effluent.
Copper
and
zinc
were
found
at
every
textile
mill,
while
chromium,
lead,
antimony
and
arsenic
were
reported
less
frequently.
The
summaries
in
Table
VII­
4
show
average
concentrations
of
these
metals
in
treated
textile
wastewater
are
lower
than
their
respective
BAT
effluent
limitations
in
the
MF
and
OCPSF
categories.
This
suggests
that,
at
least
at
these
30
textile
mills,
these
metal
parameters
are
being
effectively
controlled
well
below
technology­
based
standards
by
the
existing
treatment
systems.
While
concentrations
of
copper
and
chromium
in
treated
effluent
sometimes
exceeds
water
quality
standards,
the
metals
are
often
present
bound
in
an
organic
complex
that
manifests
low
toxicity
for
aquatic
organisms
(
WET
testing).

Textile
wastewater
is
characterized
by
low
levels
of
a
limited
number
of
volatile
organics
from
the
list
of
priority
pollutants.
Chloroform
is
most
frequently
observed,
sometimes
in
association
with
bromodichloromethane.
Often
used
for
wet
processing,
potable
water
supplies
in
the
U.
S.
average
83
ppb
chloroform
as
a
consequence
of
disinfection
with
chlorine.
Bromomethane,
dibromochloromethane,
methylene
chloride
and
tetrachloroethylene
were
each
found
at
only
one
textile
facility,
and
maximum
concentrations
were
20
ug/
L
(
ppb)
or
less.
This
level
approximates
the
lower
limits
of
quantitation
for
the
analytical
methods
that
were
used.
In
fact,
methylene
chloride
may
well
be
a
contaminant
introduced
by
the
lab
performing
the
analysis.
Hypochlorite
bleaching
40
(
chlorine
+
caustic)
is
the
most
likely
source
of
chloromethanes.
Bromomethanes
result
from
low
levels
of
bromine
in
commercially
available
chlorine.

Semi­
volatile
organic
parameters
were
absent,
except
for
1,2,4­
trichlorobenzene.
Phthalates
were
reported,
but
their
detection
was
attributable
to
contamination
of
the
wastewater
sample
by:
a)
use
of
plasticized
tubing
in
the
sampler;
or
b)
use
of
phthalate­
tainted
anhydrous
sodium
sulfate
in
the
analytical
procedure.
The
acid
fraction
(
i.
e.,
substituted
phenols)
are
apparently
not
characteristic
of
textile
wastewater,
since
these
organics
were
not
detected
in
any
of
the
APAM
analyses
reviewed
for
this
study.

Possible
Process
Sources
of
the
Parameters
Copper
is
an
integral
part
of
metallized
dyes
that
are
widely
used
within
the
industry.
While
zinc
salts
are
used
as
a
dyeing
auxillary,
they
are
also
used
for
color
destruction
in
discharge
printing.
There
are
also
complexed
metal
dyes
based
on
chromium
and
nickel.
Lead
is
associated
with
pigments
that
may
be
used
in
printing
on
fabrics.
Oxides
of
antimony
are
used
to
impart
flame
retardant
properties
to
fabrics.
Arsenic
in
process
wastewater
often
results
from
the
commission
finishing
of
foreign
cotton
(
e.
g.,
from
Egypt),
where
arsenical
pesticides
were
used
in
its
cultivation.

As
noted
previously,
the
most
likely
source
of
chloroform
is
hypochlorite
bleaching,
which
uses
chlorine
and
caustic.
These
chemicals
form
chloroform
by
reaction
with
alcohol,
aldehyde
or
ketone
groups
that
may
be
appended
to
soluble
humic
substances
(
e.
g.,
fulvic
acids)
found
in
the
potable
water
supply
used
for
wet
processing
of
textile
products.
Likewise,
chloroform
may
also
result
from
the
chlorination
of
treated
wastewater
to
meet
permit
limits
for
fecal
coliform.
Chloroform
from
this
source
is
expected
to
diminish,
as
textile
facilities
increasingly
disinfect
only
segregated
sanitary
wastewater.

Two
organic
parameters
(
1,2,4­
trichlorobenzene
and
1,1,1­
trichloroethane)
that
are
used
as
carrier
solvents
for
the
application
of
disperse
dyes
to
polyester
were
found
only
once
in
the
treated
wastewater
of
different
textile
mills
(
14
and
18
in
Table
VII­
3).
The
textile
mills
may
have
used
these
solvents
at
one
time,
but
have
eliminated
these
parameters
from
the
process
wastewater
by
changing
to
alternative
carrier
solvents
that
are
not
on
the
priority
pollutant
list
(
e.
g.,
biphenyl).
Although
naphthalene
did
not
appear
in
this
data,
it
is
also
used
as
a
solvent
(
carrier)
for
the
application
of
disperse
dyes
to
polyester.

Qualitative
Data
From
The
PCS
As
a
basis
for
estimating
the
environmental
impact
of
wastewater
discharges
from
textile
facilities
(
see
Section
IX),
EPA
used
a
computer
routine
called
the
Effluent
Data
Statistics
(
EDS)
to
generate
annual
loading
values
(
quantities)
from
the
PCS.
The
EDS
selects
concentration
and
flow
data
from
the
PCS
for
computation
of
loadings,
but
the
routine
does
not
retain
the
selected
values
in
readily
accessible
memory.
Thus,
despite
its
utility
in
retrieving
data
from
the
PCS
for
estimating
parameter
loadings,
the
EDS
routine
precludes
ready
assessment
of
the
input
data
(
concentration
and/
or
flow).
Table
VII­
4
Evaluation
of
APAM
Data
Summaries
41
No.
of
Max.
Avg.
3
BAT
Eff
Limit
Parameters
QLC1
Tex
Fac2
Conc.
Conc.
MF4
OCPSF5
Bromomethane
5
1
21
Bromodichloromethane
5
4
14
8
Chloroform
5
5
243
63
21
Dibromochloromethane
5
1
5
Ethylbenzene
8
1
22
32
Methylene
chloride
5
2
12
10
40
Tetrachloroethylene
5
1
16
22
1,1,1­
Trichloroethane
5
1
208
21
1,2,4­
Trichlorobenzene
5
1
190
68
Antimony
50
10
580
180
Arsenic
10
10
113
36
Cadmium
2
8
6
3.7
260
Chromium
5
15
508
75
1710
1110
Copper
2
30
476
107
2070
1450
Lead
10
12
90
31
430
320
Mercury
0.2
10
1.6
0.5
Nickel
10
10
50
24
2380
1690
Silver
5
2
35
27
240
Zinc
10
30
680
135
1480
1050
1.
"
Quantitation
limit"
concentration.
Concentration
unit:
ug/
L
(
ppb)
2.
Number
of
textile
facilities
(
from
30
with
APAM
data)
where
the
parameter
was
found
at
an
average
concentration
at
or
above
the
"
quantitation
limit"
concentration
specified
by
the
APAM
reporting
form.
3.
Average
includes
only
concentration
values
above
the
quantitation
limit.
The
average
does
not
include
a
value
of
zero
where
a
parameter
was
not
found
above
this
concentration
criteria.
4.
Metal
Finishing
Category
(
40
CFR
Part
433).
Maximum
for
monthly
average.
5.
Organic
Chemicals,
Plastics
and
Synthetic
Fibers
(
40
CFR
Part
414).
Maximum
for
monthly
average.

Although
denying
recovery
of
concentration
data,
the
EDS
routine
did
identify
the
priority
pollutant
parameters
that
are
limited
in
NPDES
permits
of
textile
facilities
nationwide.
The
concentrations
of
some
of
these
same
parameters
were
quantified
in
the
North
Carolina
APAM
database.
Since
data
from
both
PCS
and
APAM
characterize
treated
wastewater
from
textile
processing,
a
parameter's
concentration
range
in
PCS
data
is
likely
to
be
similar
to
its
concentration
in
the
APAM
data.

Out
of
122
NPDES
permits
in
the
PCS
that
were
found
to
be
valid
outfalls
for
discharges
of
treated
process
wastewater
from
textile
facilities,
the
EDS
routine
identified
only
59
with
usable
data
for
calculation
of
parameter
loadings.
Parameters
for
which
loadings
were
calculated
by
the
EDS
routine
are
tabulated
in
Appendix
III
and
summarized
in
Table
VII­
5.

Table
VII­
5
42
Priority
Pollutant
Parameters
Retrieved
from
PCS
by
EDS
Routine
Textile
Percent
Parameters
Facilities1
of
Total2
Bromodichloromethane
1
<
2
Chloroform
3
5
Dibromochloromethane
1
<
2
Di(
2­
ethylhexyl)
phthalate
2
3
Cyanide
1
<
2
Antimony
2
3
Arsenic
4
7
Cadmium
2
3
Chromium
40
68
Copper
16
27
Lead
6
10
Thallium
1
<
2
Zinc
25
42
1.
Number
of
textile
facilities
(
out
of
59
total)
that
reported
this
parameter.
2.
Percentage
of
the
59
textile
facilities
reporting
this
parameter.

As
in
Table
VII­
4,
chloroform
is
the
organic
priority
pollutant
most
frequently
detected
at
low
levels
in
textile
process
wastewater.
With
the
exception
of
chromium,
there
are
no
technology­
based
effluent
limitations
for
other
priority
pollutant
parameters
in
the
textile
mills
category.
Copper
and
zinc
often
characterize
process
wastewater
from
dye
baths
(
or
becks),
so
it
is
not
surprising
to
find
these
two
metal
parameters
limited
in
textile
NPDES
permits
through
the
application
of
water
quality
standards.

While
some
textile
permits
have
initial
monitoring
requirements
for
priority
pollutants
and
other
unregulated
parameters,
data
from
both
the
PCS
and
the
North
Carolina
APAM
indicate
only
a
few
organic
priority
pollutant
parameters
characterize
treated
textile
wastewater,
and
concentrations
are
nominally
low.
43
VIII.
COST
of
WASTEWATER
TREATMENT
Cost
of
Wastewater
Treatment
Since
the
promulgation
of
effluent
limitations
and
standards
in
1983,
most
of
the
textile
industry
has
continued
investing
in
water
pollution
control
systems
needed
to
comply
with
both
categorical
discharge
standards
and
POTW
local
limits.
NPDES
permits
based
upon
more
stringent
water
quality
standards
have
spurred
investment
in
additional
capital
improvements
for
systems
that
pretreat
wastewater
before
discharge
to
POTWs.

In
1991,
total
pollution
abatement
costs
for
the
industry
amounted
to
0.4%
of
the
value
of
shipments.
Pollution
abatement
equipment
accounted
for
2.7%
of
the
industry's
total
capital
expenditures.
Of
the
capital
expenditures
for
pollution
abatement
equipment,
84%
went
towards
the
purchase
of
equipment
for
water
pollution
control.
It
is
likely
that
equipment
for
wastewater
treatment
was
given
priority
in
order
to
meet
the
requirements
of
new
or
revised
NPDES
permits.
The
operating
expenses
for
water
pollution
control
systems
were
2.3%
of
profits.
1
Industry
Investment
Cycle
Although
the
U.
S.
had
been
a
net
importer
of
textiles
since
1982,
the
trade
deficit
decreased
steadily
after
1987.
The
movement
of
the
domestic
industry
away
from
commodity
products
has
left
the
bulk
textiles
market
to
producers
with
lower
labor
costs.
All
categories
of
broadwoven
fabrics
have
been
particularly
hard
hit.
The
ability
of
foreign
competition
to
capture
this
part
of
the
market
became
evident
in
the
early
1980s.
The
U.
S.
textile
industry
became
competitive
by
investing
in
capital
equipment
that
is
capable
of
producing
high
quality
products
that
consumers
can
readily
distinguish
from
lower­
priced
products.
In
order
to
remain
competitive
with
foreign
producers,
the
domestic
industry
has
continued
to
invest
in
capital
equipment.
This
is
expected
to
become
increasingly
important,
if
global
trade
restrictions
are
loosened
by
the
North
American
Free
Trade
Agreement
(
NAFTA)
and
the
General
Agreement
on
Trade
and
Tariffs
(
GATT).
2
Since
1983,
the
industry
has
continued
investing
in
more
efficient
production
equipment,
computer
controlled
in
many
cases.
Batch
dyeing
machinery
has
been
replaced
by
continuous
dyeing
machines
that
transfer
dyes
more
efficiently
and
use
less
water.
Conventional
atmospheric
rotary
dryers
have
been
replaced
by
reduced
pressure
equipment,
which
offer
better
containment
of
volatiles.

Purchase
of
new
equipment
usually
follows
from
interest
created
by
exhibits
at
trade
shows.
Domestic
manufacturers
of
production
equipment
particpate
in
a
U.
S.
exhibit
every
two
years,
while
foreign
manufactures
exhibit
every
four
years
in
Europe.
This
gradual
upgrade
of
production
equipment
alters
the
usual
long­
term
investment
cycle
that
characterizes
other
industries.

1.
Original
source:
"
1991
Survey
of
Manufacture,"
compiled
annually
by
the
Bureau
of
the
Census
and
published
by
the
U.
S.
Department
of
Commerce.
Exerpted
from
a
report
by
DRI/
McGraw­
Hill,
"
Status
of
the
US
Textile
Manufacturing
Industry,"
December,
1993.
2.
Ibid,
DRI/
McGraw­
Hill
report,
page
35.
44
IX.
ENVIRONMENTAL
ASSESSMENT
Pursuant
to
the
selection
of
two
industries
for
development
of
new
or
revised
categorical
regulations
(
see
Section
II),
EPA
ranked
six
industrial
categories
according
to
their
respective
estimated
annual
loadings
(
pounds
per
year)
of
an
inventory
of
pollutant
parameters
and
selected
chemicals
that
were
reportedly
discharged
to
both
surface
waters
and
POTWs
in
1992.
Aside
from
ranking,
the
loading
estimates
are
useful
as
a
weighted
menu
of
chemicals
that
are
characteristic
of
textile
process
wastewater.

Parameter
loadings
were
estimated
from
NPDES
monitoring
data
in
EPA's
Permit
Compliance
System
(
PCS),
and
from
estimated
"
releases"
to
wastewater
that
industries
reported
on
Form
R
to
EPA's
1992
Toxic
Release
Inventory
(
TRI).
The
PCS
database
derives
from
monthly
discharge
monitoring
reports
(
DMRs)
required
by
NPDES
permits
(
direct
dischargers).
In
contrast,
the
TRI
embodies
estimated
amounts
of
chemicals
reported
by
sources
that
discharge
both
to
POTWs
(
indirect
dischargers)
and
directly
to
surface
waters.

Loading
Estimates
from
the
PCS
Database
As
a
comprehensive
source
of
NPDES
monitoring
data,
the
PCS
has
a
number
of
limitations
(
see
Appendix
IV­
1).
Monitoring
data
has
not
been
encoded
for
many
NPDES
permits
in
the
PCS,
because
only
permits
considered
"
major"
are
required
to
submit
monthly
discharge
monitoring
reports
(
DMRs)
to
the
PCS.
Even
if
encoded,
it
is
also
not
always
possible
to
directly
retrieve
data
in
the
units
of
choice
from
all
NPDES
permits
in
the
PCS.
For
example,
out
of
122
NPDES
permits
in
the
PCS
that
were
validated
as
discharging
treated
process
wastewater
from
textile
facilities,
the
EDS
computer
routine
identified
only
59
with
usable
data
for
estimating
the
annual
loadings
of
pollutant
parameters
that
were
monitored
in
textile
wastewater
discharges.

Depending
on
monitoring
requirements
imposed
by
the
permits,
concentrations
may
be
reported
in
different
units.
The
EDS
routine
estimates
loadings
only
for
records
with
both
concentration
and
corresponding
flow
data,
and
assumes
each
facility
operates
thirty
days
per
month.
After
adjusting
the
PCS's
different
measures
of
concentration
and
flow
to
compatible
units,
the
EDS
routine
multiplies
concentration
and
flow
values
to
estimate
loadings
for
each
parameter.

The
total
annual
loadings
of
individual
parameters
estimated
from
textile
facilities'
PCS
data
are
summarized
in
Table
IX­
1.
The
estimated
annual
loadings
of
parameters
for
individual
NPDES
permits
are
tabulated
in
Appendix
IV­
1.
This
Appendix
also
presents
summaries
of:
limitations
of
the
PCS
database;
assumptions
that
were
made
in
data
selection;
and
criteria
that
were
used
to
edit
parameter
loading
estimates
and
data
outliers.
45
Table
IX­
1
Total
Estimated
Annual
Parameter
Loadings
­
PCS
Database
Permits
Parameters
Monitored
LBYO1
LBYE2
Ammonia
10
48784
48784
Chlorine
10
86598
865983
Sulfide
10
32254
71118
Bromodichloromethane
1
2
2
Chloroform
3
25
25
Di(
2­
ethylhexyl)
phthalate
3
17
19
Formaldehyde
2
986
986
Cyanide
1
4
4
Antimony
2
72
72
Arsenic
4
85
111
Cadmium
2
191
191
Chromium
8
1639
1825
Chromium
+
6
2
5142
5142
Copper
10
25218
25228
Lead
6
28
29
Silver
4
1132
1133
Zinc
10
233856
233856
1.
Calculated
minimum
amount
discharged
annually
(
pounds
per
year).
Calculation
assumed
a
concentration
value
of
ZERO,
when
reported
concentration
was
below
detection
limit.
2.
Calculated
maximum
amount
discharged
annually
(
pounds
per
year).
Calculation
assumed
a
concentration
value
of
HALF
DETECTION
LIMIT,
when
reported
concentration
was
below
detection
limit.
3.
Calculated
maximum
amount
of
chlorine
at
HALF
DETECTION
LIMIT
is
inappropriate,
because
most
textile
facilities
with
NPDES
permits
dechlorinate
treated
effluent
prior
to
discharge.
For
this
reason,
the
amount
was
estimated
using
an
assumed
concentration
value
of
ZERO.

Ammonia,
chlorine
and
sulfide
are
among
the
inorganic
chemical
parameters
that
were
most
frequently
monitored.
It
follows
that
sulfide,
a
parameter
with
BPT
and
BAT
limitations
in
every
wet­
processing
subcategory
of
the
regulation
(
40
CFR
Part
410),
would
be
frequently
limited
in
NPDES
permits
of
textile
facilities.
This
would
also
explain
the
monitoring
of
chromium,
which
is
limited
in
several
subcategories.
Even
though
categorical
limits
for
copper
and
zinc
are
unspecified,
these
are
the
metal
parameters
most
frequently
limited
in
textile
NPDES
permits.
The
greater
availability
of
monitoring
data
for
copper
and
zinc
probably
accounts
for
the
higher
loadings
estimated
by
the
EDS
routine
for
these
metals,
in
comparison
with
loadings
estimated
for
the
other
metals.

As
noted
in
Section
VII
of
this
report,
metals
characteristic
of
textile
wastewater
are
being
effectively
controlled
well
below
concentration
levels
of
technology­
based
standards
in
other
industrial
categories
by
technologies
currently
employed
within
the
textile
industry's
existing
treatment
systems.
The
loadings
of
organic
chemicals
in
wastewaters
discharged
by
textile
facilities
are
effectively
controlled
by
limitations
on
BOD
5,
COD
and
TSS
in
the
NPDES
permits.
This
is
evidenced
by
the
low
concentrations
of
the
few
organics
from
the
priority
pollutant
list
that
are
routinely
measured
in
treated
textile
wastewaters
(
see
Table
VII­
4).
46
Loading
Estimates
from
the
TRI
Database
The
TRI
database
has
a
number
of
limitations
as
a
comprehensive
source
of
chemical
release
data
(
see
Appendix
IV­
3).
It
does
not
include
all
textile
facilities
or
TRI­
listed
chemicals
in
use
at
those
facilities.
Only
textile
facilities
using
minimum
threshold
amounts
of
TRI­
listed
chemicals
on
site
are
required
to
report
estimated
releases
on
Form
R.
Reporting
thresholds:
TRI­
listed
chemicals
that
are
"
manufactured
or
processed"
on­
site
in
excess
of
a
25,000
lbs/
yr,
or
"
otherwise
used"
on­
site
in
excess
of
10,000
lbs/
yr.
While
the
TRI
database
is
useful
for
identifying
chemicals
that
might
be
expected
to
be
found
in
an
industry's
wastewater,
the
reporting
thresholds
compromise
the
accuracy
of
wastewater
loading
estimates
for
these
chemicals.

The
1992
TRI
records
of
228
textile
facilities
were
accessed
to
obtain
the
amounts
of
TRI­
listed
chemicals
that
each
of
these
facilities
reported
as
annual
releases
to
POTWs,
or
from
on­
site
treatment
systems
to
surface
waters.
Estimated
releases
to
surface
waters
may
include
process
outfalls
(
e.
g.,
pipes,
open
trenches)
and
stormwater
runoff,
if
applicable.
This
industry's
experience
with
the
1990
stormwater
permitting
requirements
indicated
that
few,
if
any,
textile
facilities
have
discharges
other
than
those
to
POTWs,
or
from
on­
site
treatment
systems.
The
amounts
of
TRIlisted
chemicals
that
textile
facilities
reported
in
1992
as
being
released
to
surface
waters
and
POTWs
are
summarized
in
Table
IX­
2.
Releases
of
these
chemicals
that
were
reported
by
individual
textile
facilities
are
tabulated
in
Appendix
IV­
3.

Releases
are
typically
estimated
from
the
quantities
of
TRI­
listed
chemicals
that
a
textile
facility
annually
purchases
for
its
manufacturing
processes.
It
follows
that
chemicals
used
in
the
largest
quantities
will
be
the
chemicals
with
the
highest
estimated
releases.
Table
IX­
2
indicates
that,
of
the
total
number
of
textile
facilities
(
228)
that
submitted
Form
R
to
the
TRI
database,
relatively
few
facilities
reported
the
release
of
any
given
chemical.
This
suggests
that
only
a
limited
number
of
textile
facilities
use
that
chemical,
or
the
amount
used
annually
by
many
facilities
was
below
the
reporting
threshold.

Only
five
organic
chemicals
in
Table
IX­
2
are
from
the
priority
pollutant
list:
dichloromethane,
di(
2­
ethylhexyl)
phthalate,
naphthalene,
toluene,
and
tetrachloroethylene.
These
chemicals
are
shown
to
be
among
those
ranking
lower
in
total
amount
discharged
annually.
This
is
consistent
with
the
concentration­
based
effluent
monitoring
data
in
Section
VII,
which
indicates
that
these
five
chemicals
are
not
found
at
significant
levels
in
treated
textile
wastewater
discharged
to
surface
waters,
or
in
either
untreated
or
pretreated
wastewater
discharged
to
POTWs.

Several
chemicals
in
Table
IX­
2
have
recently
been
removed
from
the
TRI
list
and
Form
R
reporting
requirements.
These
include
acetone
(
FR
60
at
31643);
ammonium
sulfate,
ammonium
nitrate
and
water­
dissociable
ammonium
salts
(
FR
60
at
34172);
and
sulfuric
acid
(
FR
60
at
34182).
Non­
ionic
surfactants
(
ethoxylates
of
alkylphenol
and
long­
chain
alcohols)
no
longer
have
to
be
reported
as
"
glycol
ethers."
Eliminating
the
estimated
releases
of
these
chemicals
will
significantly
reduce
the
total
annual
wastewater
loading
reported
to
the
TRI
database
by
the
textile
industry.

Table
IX­
2
47
Total
1992
Chemical
Loadings
Reported
­
TRI
Database
Facilities
Surface
Annual
Chemical
Reporting(%)
1
Waters2
POTW3
Total
Acetone
11
(
5)
37750
17493
55243
Acrylic
acid
1
0
2463
2463
Benzyl
chloride
1
0
12000
12000
Biphenyl
23
(
10)
3890
664638
668528
n­
Butanol
1
1566
0
1566
Butylbenzyl
phthalate
2
250
500
750
Cresol
(
mixed
isomers)
1
0
2
2
Cumene
1
245
0
245
Decabromodiphenyl
oxide
16
(
7)
3300
112656
115956
Dichloromethane
2
0
14
14
Diethanolamine
3
26700
47800
74500
Di(
2­
ethylhexyl)
phthalate
3
250
3553
3803
Dyes:
CI
Basic
Green
4
1
0
2900
2900
CI
Disperse
Yellow
3
1
0
755
755
Ethylene
glycol
19
(
8)
18295
621162
639457
Formaldehyde
11
(
5)
683
88542
89225
Glycol
ethers
27
(
12)
43504
329849
373353
Methanol
20
(
9)
2877
219727
222604
Methylethyl
ketone
(
MEK)
3
252
2354
2606
Methylisobutyl
ketone
(
MIBK)
2
0
255
255
Naphthalene
2
6410
0
6410
Toluene
3
250
260
510
Tetrachloroethylene
10
(
4)
770
66681
67451
1,2,4­
Trichlorobenzene
12
(
5)
952
73344
74296
1,1,1­
Trichloroethane
1
250
0
250
Trichloroethylene
1
250
0
250
1,2,4­
Trimethylbenzene
8
(
4)
2234
67589
69823
Xylene
(
mixed
isomers)
14
(
6)
2296
220021
222317
Ammonia
62
(
27)
34851
943583
978434
Ammonium
nitrate
(
solution)
3
9866
0
9866
Ammonium
sulfate
(
solution)
38
(
17)
965
2571414
2572379
Chlorine
21
(
9)
39696
219905
259601
Hydrochloric
acid
9
(
4)
0
45124
45124
Phosphoric
acid
4
0
115
115
Sulfuric
acid
19
(
8)
6000
1278439
1284439
1.
Out
of
228
records
retrieved
from
the
1992
TRI
database,
this
number
of
textile
facilities
reported
an
estimated
release
of
the
chemical.
Shown
in
parenthesis
as
a
percentage
of
228.
2.
Reported
amount
(
pounds)
released
annually
to
surface
waters.
Includes
releases
from
on­
site
treatment
systems,
process
outfalls
(
e.
g.,
pipes,
open
trenches)
and
stormwater
runoff.
3.
Reported
amount
(
pounds)
released
annually
to
POTWs.
48
Table
IX­
2
(
cont.)

Total
1992
Chemical
Loadings
Reported
­
TRI
Database
Facilities
Surface
Annual
Chemical
Reporting(%)
Waters1
POTW2
Total
Antimony
1
0
250
250
Antimony
compounds
12
(
5)
1521
51013
52534
Barium
compounds
2
24
5
29
Cadmium
compounds
2
3
8
11
Chromium
1
512
0
512
Chromium
compounds
20
(
9)
3210
122262
125472
Cobalt
compounds
3
250
411
661
Copper
1
0
278
278
Copper
compounds
18
(
8)
2479
86349
88828
Lead
compounds
4
17
41
58
Nickel
1
0
131
131
Nickel
compounds
2
0
2673
2673
Zinc
compounds
13
103
32334
32437
1.
Reported
amount
(
pounds)
released
annually
to
surface
waters.
2.
Reported
amount
(
pounds)
released
annually
to
POTWs.

Comparison
of
Loading
Estimates
from
PCS
vs.
TRI
The
estimated
releases
reported
to
the
TRI
database
do
not
include
TRI­
listed
chemicals
that
are
used
or
produced
in
quantities
below
reporting
thresholds.
Even
so,
the
total
annual
load
for
any
given
chemical
reported
to
the
TRI
database
far
exceeds
the
chemical's
total
annual
load
calculated
from
the
PCS
(
NPDES
permits).
The
obvious
explanation
for
this
difference
is
that
at
least
90%
of
the
textile
facilities
engaged
in
wet
processing
discharge
to
POTWs
(
Section
IV)
and,
therefore,
do
not
report
data
to
the
PCS.
Thus,
the
PCS
database
reflects
the
loadings
of
no
more
than
about
10%
of
the
of
the
total
number
of
textile
facilities
that
discharge
wet
processing
wastewater.

When
the
two
databases
are
compared
on
a
basis
of
average
annual
load
per
facility,
and
when
the
loads
of
a
chemical
calculated
from
the
PCS
are
compared
to
TRI
loads
reported
as
being
discharged
to
surface
waters
(
i.
e.,
associated
with
NPDES
permits),
there
is
less
difference
between
a
chemical's
loading
estimate
derived
from
the
two
databases.
The
data
for
such
a
comparison
are
summarized
in
Table
IX­
3.

Widely
used
in
textile
wet
processing,
ammonia
and
copper
(
from
copper­
based
premetallized
dyes)
are
two
chemicals
for
which
data
are
frequently
reported
to
both
the
PCS
and
the
TRI
database
by
textile
facilities.
The
availability
of
data
for
ammonia
and
copper
in
both
databases
made
these
two
chemicals
logical
choices
for
comparing
annual
loadings
derived
from
the
two
databases.

While
the
PCS
listed
418
NPDES
permits
issued
under
SIC
22,
only
122
could
be
validated
as
sources
of
treated
process
wastewater
(
pages
12,
34).
Of
the
122
NPDES
permits,
a
computer
routine
(
EDS,
Appendix
IV­
1)
identified
only
10
permits
with
usable
data
for
Table
IX­
3
49
Annual
Loadings
From
Textile
Wet
Processors
Discharging
to
Surface
Waters
PCS
TRI
Variable
Ammonia
Copper
Ammonia
Copper
Number
of
SIC
22
facilities
in
database
122
122
228
228
Facilities
with
usable
or
reported
data
10
10
62
18
Facilities
discharging
to
surface
waters
10
10
6.2
1.8
Total
annual
loading,
lbs/
yr
48,7841
25,2181
34,8512
2,4792
Average
annual
loading
per
facility,
lbs/
yr
4,878
2,522
5,621
1,377
1.
Total
annual
loading
estimated
by
computer
routine
(
EDS)
from
the
PCS
database.
2.
Total
annual
loading
released
to
surface
waters
from
facilities
that
reported
these
two
parameters
to
the
TRI
database.

estimating
the
textile
industry's
total
annual
loading
for
ammonia
and
copper
(
Table
IX­
1,
p.
45).
From
these
totals,
an
average
annual
loading
per
facility
was
calculated
for
each
of
the
two
parameters.

Under
SIC
22,
the
1992
TRI
showed
228
facilities
that
use
or
produce
TRI­
listed
chemicals
in
quantities
that
exceeded
mandatory
reporting
thresholds
(
p.
46).
While
62
of
these
facilities
reported
the
release
of
an
estimated
annual
loading
of
ammonia,
only
18
facilities
reported
an
estimated
release
of
"
copper
compounds"
(
Table
IX­
2,
p.
48).
Assuming
10%
of
these
facilities
discharge
to
surface
waters
(
i.
e.,
have
NPDES
permits),
an
annual
loading
per
facility
would
be
averaged
on
a
basis
of
6.2
facilities
for
ammonia
and
1.8
facilities
for
copper.

Applications
of
TRI
Chemicals
in
Textile
Processing
It
is
obvious
from
Table
IX­
2
that
some
TRI­
listed
chemicals
are
more
widely
used
in
larger
quantities
than
others.
Some
applications
of
these
chemicals
at
textile
facilities
are
listed
in
Table
IX­
4.

Disperse
dyes
are
the
only
practical
means
of
coloration
for
polyester
and
cellulose
acetate
fibers.
Applied
as
an
aqueous
dispersion,
these
water­
insoluble
dyes
will
not
readily
penetrate
the
fibers
interstices.
Dye
carriers,
such
as
biphenyl,
act
as
a
solvent
that
expands
the
fibers,
enabling
disperse
dyes
to
penetrate
the
fiber
interstices
at
lower
temperatures
and
ambient
pressure.
The
carrier
assists
in
the
uniformity
of
dye
distribution
in
the
fabric
and
also
increases
the
rate
of
dyeing.
After
dyeing
is
completed,
the
carrier
solvent
is
removed
from
the
fabric
in
a
heated
drying
chamber.
This
contracts
the
fibers,
leaving
the
dye
trapped
(
heat
set)
in
the
fiber
interstices.

Formaldehyde
is
used
to
impart
shape­
retaining
properties
("
permanent
press")
to
fabrics
by
crosslinking
the
fibers
through
chemical
bonding.
Commercially
available
as
an
aqueous
solution,
the
37%
formaldehyde
typically
contains
11%
methanol.
50
Table
IX­
4
Applications
of
TRI
Chemicals
in
Textile
Processing
TRI
Chemical
Textile
Process
Application
Acetone1
Solvent
for
acetate
fiber
manufacture
Biphenyl
Dye
carrier
in
polyester
dyebaths
Decabromodiphenyl
oxide
Flame
retardant
Ethylene
glycol
Wetting
agent
Formaldehyde
Finishing
cotton
fabrics
(
perm.
press)
Glycol
ethers
(
surfactants)
Textile
scouring
(
washing)
Methanol
Finishing
cotton
fabrics
(
perm.
press)
Naphthalene
Dye
carrier
in
polyester
dyebaths
Tetrachloroethylene
Dry
cleaning
1,2,4­
Trichlorobenzene
Dye
carrier
in
polyester
dyebaths
1,2,4­
Trimethylbenzene
Dye
carrier
in
polyester
dyebaths
Xylene
(
mixed
isomers)
Solvent
Ammonia
pH
control
Ammonium
sulfate
pH
control
in
nylon
dyebaths
Chlorine
Bleaching
Sulfuric
acid
Neutralization
Antimony
compounds
Flame
retardant
Copper
compounds
Metallized
dyes
Chromium
compounds
Metallized
dyes
Zinc
compounds
Dyeing
and
printing
auxiliary,
Finishing
catalyst
1.
Manufacturers
of
cellulose
acetate
fibers
purchased
by
textile
mills
specify
the
acetone
content
present
in
the
fiber
as
a
contaminant.
Because
acetone
is
both
volatile
and
water
soluble,
it
accrues
in
water
from
the
HVAC
(
heating,
ventilation,
and
air
conditioning)
system,
and
in
wastewater
from
slashing
operations
(
application
of
sizing).

Nonylphenol
ethoxylates
and
long­
chain
ethoxylates
are
nonionic
surfactants
that
are
commonly
used
to
scour
(
wash)
textile
products.
In
1992,
the
EPA
required
these
surfactants
to
be
reported
in
the
TRI
chemical
category,
"
glycol
ethers."
EPA
has
subsequently
discontinued
this
requirement,
and
these
surfactants
are
no
longer
reported
on
Form
R.

Ammonia
finds
some
use
in
controlling
pH
and
viscosity
of
polymer
emulsions
in
fabric
coating
operations.
The
main
use
of
ammonia
is
dyeing
nylon,
where
control
of
pH
is
critical
to
the
uniform
application
of
the
dye.
Ammonia
is
used
to
establish
the
initial
pH
at
7.
The
pH
is
lowered
by
the
evolution
of
ammonia,
during
the
programmed
heating
of
the
dyebath.
Ammonium
sulfate
(
recently
delisted
from
the
TRI)
buffers
the
dyebath
at
pH
5,
where
it
is
held
for
the
duration
of
the
dyeing
cycle.
In
commerce,
ammonium
sulfate
is
used
almost
exclusively
as
a
fertilizer
material
and
is
an
important
source
of
nutrient
sulfur
and
nitrogen.
Absorbed
on
suspended
solids
(
sludge),
that
are
routinely
wasted
from
biological
treatment
systems
and
spread
on
agricultural
lands,
this
textile
process
chemical
would
be
expected
to
benefit
soils
and
enhance
productivity.

Chlorine
is
used
mainly
for
bleaching,
especially
white
socks.
Minor
uses
are
for
disinfection
of
treated
wastewater
and
occasionally
color
removal
from
wastewater.
51
Sulfuric
acid
is
used
mainly
for
pH
adjustment,
but
is
also
used
for
"
carbonizing"
(
oxidation
of
organic
matter)
raw
wool.
When
used
to
neutralize
high
pH
wastewater,
sulfuric
acid
is
chemically
changed
to
a
sulfate
salt.
Thus,
reporting
the
release
of
sulfuric
acid
in
wastewater
is
misleading.
The
same
criticism
could
be
leveled
at
estimated
releases
for
the
other
mineral
acids
(
hydrochloric
and
phosphoric),
which
are
converted
respectively
to
chlorides
and
phosphates.

Antimony
compounds
are
used
in
combination
with
decabromodiphenyl
oxide
to
give
fabrics
flame­
retardant
properties.
52
