Page
1
of
12
Memorandum
From:
Jan
Matuszko
USEPA/
OW/
OST
ph:
(
202)
566
1035
matuszko.
jan@
epa.
gov
To:
Public
Record
for
the
2006
Effluent
Guidelines
Program
Plan
EPA
Docket
Number
OW­
2004­
0032
(
www.
epa.
gov/
edockets/)

Date:
August
11,
2005
Re:
Industrial
Laundries
4.1
Introduction
In
1999,
EPA
published
a
final
action
for
facilities
in
the
Industrial
Laundries
point
source
category.
See
64
Fed.
Reg.
45,071
(
Aug.
18,
1999).
EPA
determined
that
all
wastewater
discharges
associated
with
this
industry
were
indirect
to
Publicly
Owned
Treatment
Works
(
POTWs).
EPA
determined
that
indirect
discharges
from
industrial
laundries
did
not
warrant
national
regulation
because
of
the
small
amount
of
pollutants
removed
by
the
pretreatment
options
that
were
found
to
be
economically
achievable.
EPA's
review
found
that
POTWs
are
generally
not
experiencing
problems
with
discharges
from
this
industry,
and
such
discharges
will
rarely,
if
ever,
present
a
problem.
To
the
extent
that
isolated
problem
discharges
occur,
existing
pretreatment
authority
is
available
to
control
these
isolated
discharges.
EPA
concluded
that
for
this
industry,
the
best
way
to
control
effluent
discharges
of
certain
organic
pollutants
is
to
remove
the
pollutants
which
are
contained
on
the
laundry
items
before
they
are
washed.

In
addition,
at
the
time
of
EPA's
final
decision,
representatives
from
this
industry
agreed
to
a
voluntary
pollutant
reduction
program.
The
industry
refers
to
this
program
as
the
Laundry
Environmental
Stewardship
Program
or
LaundryESP
®
.
The
industry
designed
this
program
to
encourage
improvement
in
four
areas:
water
usage;
energy
usage;
pollutant
discharges
to
the
sewer;
and
use
of
wash
chemicals
with
a
more
positive
environmental
profile.
As
part
of
this
program,
the
industry
has
been
collecting
information
from
program
participants
in
the
four
improvement
areas.
In
2004,
the
industry
collated
this
information
and
provided
a
summary
of
the
results
to
date.
This
information
serves
as
the
primary
information
source
for
this
review.

4.2
Industry
Profile
Industrial
laundries
primarily
include
facilities
in
SIC
codes
7211
and
7218.


7211:
Establishments
primarily
engaged
in
operating
mechanical
laundries
with
steam
or
other
power.
Excluded
are
establishments
which
have
power
laundry
equipment
but
which
are
primarily
engaged
in
a
specialty,
such
as
industrial
laundering,
linen
rental,
or
diaper
service.
Page
2
of
12

7218:
Establishments
primarily
engaged
in
supplying
laundered
or
drycleaned
work
uniforms,
wiping
towels,
protective
apparel
(
gloves,
flame
resistant
clothing,
etc.),
dust
control
items
(
treated
mats
or
rugs,
mops,
cloths,
etc.),
and
similar
items
to
industrial,
commercial,
and
government
users.
These
items
may
belong
to
the
industrial
launderers
and
be
supplied
to
users
on
a
rental
basis,
or
they
may
belong
to
the
customers.
Establishments
included
in
this
industry
may
or
may
not
operate
their
own
laundry
or
drycleaning
facilities.

Table
1­
1
presents
Census
data
for
the
Industrial
Laundries
Category.

Table
1­
1.
Census
Data
SIC
Code
NAICS
Code
Number
of
Facilities
in
1997
Number
of
Facilities
in
2002
7211:
Power
laundries,
family
and
commercial
812320:
Laundries,
family
and
commercial
1,740
NA
7218:
Industrial
launderers
812332:
Industrial
launderers
1,613
1,488
NA:
The
2002
data
in
the
U.
S.
Census
lists
the
total
number
of
establishments
for
NAICS
Code
812320,
which
includes
dry
cleaning
plants;
laundries,
family
and
commercial,
and
all
other
laundry
and
garment
services.
The
total
number
of
all
of
these
types
of
facilities
is
27,066,
which
is
not
representative
of
industrial
laundries.

Of
the
approximately
3,000
industrial
laundry
facilities
in
the
U.
S.
(
1997
U.
S.
Census),
none
reported
to
the
2000
TRI
or
PCS.
The
U.
S.
EPA
Technical
Development
Document
for
the
Final
Action
Regarding
Pretreatment
Standards
for
the
Industrial
Laundries
Point
Source
Category
(
2000
TDD),
published
in
March
2000,
contains
data
on
the
laundering
processes
used
by
industrial
laundry
facilities.
Table
1­
2
presents
the
different
types
of
laundering
processes
used,
and
the
number
of
facilities
performing
each
process.

Table
1­
2.
Laundering
Processes
from
2000
TDD
Process
Estimated
Number
of
Facilities
Performing
the
Process
Estimated
Percentage
of
Facilities
Performing
the
Process
Estimated
Percentage
of
Total
Production1
(%)

Water
Washing
1,725
99
97
Dual­
Phase
Washing
­
Petroleum
solvent
wash
followed
by
water
washing
18
1
<
1
Dual­
Phase
Washing
­
Water
wash
followed
by
perchloroethylene
solvent
wash
0
0
0
Dry
Cleaning
­
Charged
system
125
7
<
1
Dry
Cleaning
­
Fresh
soap
added
to
each
load
80
5
<
1
Table
1­
2.
(
Continued)

Process
Estimated
Number
of
Facilities
Performing
the
Process
Estimated
Percentage
of
Facilities
Performing
the
Process
Estimated
Percentage
of
Total
Production1
(%)

Page
3
of
12
Dry
Cleaning
­
No
soap
added
80
5
<
1
Dry
Cleaning
Followed
by
Water
Washing
(
drying
between
steps)
29
2
<
1
Dust
Control
Mop
Treatment
­
Water
wash
followed
by
oil
treatment
applied
outside
wash
wheel
692
40
1
Dust
Control
Mop
Treatment
­
Water
wash
followed
by
oil
treatment
applied
inside
wash
wheel
67
4
<
1
Dust
Control
Mop
Treatment­
Water
wash
followed
by
unspecified
oil
treatment
22
1
<
1
Dust
Control
Mop
Treatment
­
Oil
only
57
3
<
1
Stone/
Acid
Washing
of
Denim
11
1
1
Dyeing2
1
<
1
<
1
Total
­
­
100
1Percentages
reported
are
estimated
based
on
the
193
in­
scope
facilities
(
including
three
facilities
that
were
later
determined
to
be
out­
of­
scope
because
they
process
only
clean
room
items),
extrapolated
using
appropriate
survey
weights
to
represent
the
entire
industry.
2This
process
is
not
considered
a
laundering
process
by
EPA.

4.3
Wastewater
Characteristics
For
2000,
neither
the
PCS
nor
TRI
database
contains
information
for
any
discharging
industrial
laundries.
The
2000
TDD
contains
data
on
pollutants
of
concern
and
their
concentrations
in
untreated
laundry
wastewaters.
Table
1­
3
summarizes
laundries
raw
wastewater
characteristics.

Table
1­
3.
Pollutants
of
Concern
in
Laundries
Raw
Wastewater
from
2000
TDD1
Pollutants
of
Concern
Number
of
Times
Analyzed
Number
of
Times
Detected
Percent
Detected
(%)
Concentration
in
Untreated
Wastewater
(
mg/
L)

Minimum
Maximum
Mean
Conventionals
Biochemical
Oxygen
Demand
5­
Day
(
BOD5)
46
46
100
218
9810
2343.5
Oil
and
Grease
(
measured
as
HEM)
48
48
100
71.5
11790
1943.92
Total
Suspended
Solids
(
TSS)
46
45
97.83
4
7000
1773.93
Table
1­
3
(
Continued)

Pollutants
of
Concern
Number
of
Times
Analyzed
Number
of
Times
Detected
Percent
Detected
(%)
Concentration
in
Untreated
Wastewater
(
mg/
L)

Minimum
Maximum
Mean
Page
4
of
12
Priority
Organics
1,1,1­
Trichloroethane
48
22
45.83
0.01
156.64
4.01
1,2­
Diphenylhydrazine
47
5
10.64
0.02
41.32
1.14
4­
Chloro­
3­
methylphenol
47
8
17.02
0.01
2.06
0.14
Bis(
2­
ethylhexyl)
Phthalate
47
43
91.49
0.04
42.01
6.8
Butyl
Benzyl
Phthalate
47
20
42.55
0.01
74.42
2.69
Chlorobenzene
48
8
16.67
0.01
1.41
0.08
Chloroform
48
25
52.08
0.01
1.19
0.07
Di­
n­
butyl
Phthalate
47
20
42.55
0.01
9.98
0.73
Di­
n­
octyl
Phthalate
47
25
53.19
0.01
2.61
0.3
Ethylbenzene
48
38
79.17
0.01
18.74
1.24
Isophorone
47
5
10.64
0.01
1
0.12
Methylene
Chloride
48
25
52.08
0.01
16.26
0.63
Naphthalene
47
42
89.36
0.01
18.75
2.59
Phenol
47
23
48.94
0.01
0.96
0.15
Tetrachloroethene
48
35
72.92
0.01
46.22
1.97
Toluene
48
44
91.67
0.01
90.97
6.72
trans­
1,2­
Dichloroethene
48
1
2.08
0.01
0.1
0.03
Trichloroethene
48
7
14.58
0.01
20
0.48
Nonconventional
Organics
2­
Butanone
48
32
66.67
0.05
272.29
9.07
2­
Methylnaphthalene
47
32
68.09
0.01
2.24
0.41
2­
Propanone
48
46
95.83
0.05
603.15
20.95
4­
Methyl­
2­
pentanone
48
26
54.17
0.05
65.27
2.65
%­
Terpineol
47
17
36.17
0.01
5.2
0.33
Benzoic
Acid
47
34
72.34
0.05
12.23
1.77
Benzyl
Alcohol
47
21
44.68
0.01
12.52
0.81
Hexanoic
Acid
47
14
29.79
0.01
1.81
0.12
m­
Xylene
48
40
83.33
0.01
25.29
2.29
n­
Decane
47
41
87.23
0.01
712.4
51.6
n­
Docosane
47
31
65.96
0.01
3.04
0.35
Table
1­
3
(
Continued)

Pollutants
of
Concern
Number
of
Times
Analyzed
Number
of
Times
Detected
Percent
Detected
(%)
Concentration
in
Untreated
Wastewater
(
mg/
L)

Minimum
Maximum
Mean
Page
5
of
12
n­
Dodecane
47
40
85.11
0.01
105.57
14.37
n­
Eicosane
47
43
91.49
0.01
84.57
4.06
n­
Hexacosane
47
27
57.45
0.01
3.73
0.36
n­
Hexadecane
47
43
91.49
0.01
91.57
6.7
n­
Octacosane
47
21
44.68
0.01
1.44
0.19
n­
Octadecane
47
42
89.36
0.01
19.36
1.92
n­
Tetracosane
47
25
53.19
0.01
8.34
0.46
n­
Tetradecane
47
37
78.72
0.01
41.58
4.39
n­
Triacontane
47
29
61.7
0.01
1
0.19
o­&
p­
Xylene
48
40
83.33
0.01
17.8
1.59
p­
Cresol
47
1
2.13
0.01
0.2
0.06
p­
Cymene
47
16
34.04
0.01
19.81
1.43
Pentamethylbenzene
47
11
23.4
0.01
2.33
0.22
Priority
Metals
and
Elements
Antimony
47
34
72.34
0.01
8.24
0.26
Arsenic
47
15
31.91
0.01
0.18
0.02
Beryllium
47
18
38.3
0.01
0.02
0.003
Cadmium
47
44
93.62
0.01
0.7
0.1
Chromium
47
45
95.74
0.01
7.31
0.46
Copper
47
47
100
0.04
14.9
3.17
Lead
47
45
95.74
0.03
23.8
1.71
Mercury
47
28
59.57
0.01
0.01
0.001
Nickel
47
45
95.74
0.01
2.87
0.27
Selenium
47
12
25.53
0.01
0.26
0.03
Silver
47
24
51.06
0.01
0.17
0.02
Thallium
47
6
12.77
0.01
0.13
0.01
Zinc
47
46
97.87
0.01
29.4
5.02
Nonconventional
Metals
and
Elements
Aluminum
47
47
100
0.03
20.99
7.96
Barium
47
47
100
0.03
6.26
1.51
Boron
47
36
76.6
0.03
37.2
2.31
Table
1­
3
(
Continued)

Pollutants
of
Concern
Number
of
Times
Analyzed
Number
of
Times
Detected
Percent
Detected
(%)
Concentration
in
Untreated
Wastewater
(
mg/
L)

Minimum
Maximum
Mean
Page
6
of
12
Cobalt
47
37
78.72
0
3.1
0.24
Iron
47
47
100
0.06
96.6
27.7
Manganese
47
47
100
0.02
1.77
0.56
Molybdenum
47
43
91.49
0.01
5.17
0.53
Tin
47
32
68.09
0.02
0.58
0.11
Titanium
47
45
95.74
0.01
1.32
0.23
Vanadium
47
31
65.96
0.01
0.19
0.04
Yttrium
47
15
31.91
0.01
0.04
0.01
Bulk
Nonconventionals
Chemical
Oxygen
Demand
(
COD)
47
47
100
80
212000
12730.57
Total
Organic
Carbon
(
TOC)
47
47
100
106
37800
2208.32
Total
Petroleum
Hydrocarbon
(
measured
as
SGT­
HEM)
43
43
100
7
4543
880.86
4.4
On­
Site
Wastewater
Treatment/
Pretreatment
and
Pollution
Prevention
All
of
the
industrial
laundries
identified
by
EPA
discharge
their
process
wastewater
indirectly
to
POTWs.
Based
on
the
Uniform
and
Textile
Service
Association
(
UTSA)
and
the
Textile
Rental
Service
Association
(
TRSA)
survey
conducted
in
1998,
55
percent
of
the
industrial
laundries
do
not
pre­
treat
their
wastewater.
Of
the
remaining
45
percent
of
the
facilities,
the
primary
method
of
wastewater
pre­
treatment
is
dissolved
air
flotation
(
DAF).
Other
wastewater
treatment
technologies
in
use
include
chemical
precipitation
(
CP),
chemical
emulsion
breaking,
microfiltration,
ultrafiltration,
gravity
settling,
stream
splitting,
screening,
equalization,
sludge
dewatering,
pH
adjustment,
centrifugation,
media
filtration,
oil/
water
separation
and
VOC
removal
technologies.

A
review
of
the
2002
LaundryESP
data
by
UTSA
and
TRSA
indicated
that
326
of
the
562
reporting
facilities
(
58%)
used
one
or
more
of
the
following
treatment
systems:
air
stripping,
carbon
absorption,
centrifuge,
chemical
emulsion
breaking,
dissolved
air
flotation,
induced
air
flotation,
microfilter,
oil
skimmer,
oil/
water
separator,
pH
adjustment,
polishing
filters,
reverse
osmosis,
rotary
screen,
and
ultrafilter
Tables
1­
4
and
1­
5
show
the
primary
conventional
and
nonconventional
pollutants
and
their
average
concentrations
in
laundry
effluents
following
one
of
the
two
main
types
of
laundry
pretreatment:
chemical
precipitation
or
dissolved
air
flotation
(
DAF).
Page
7
of
12
Table
1­
4.
Pollutant
Concentrations
(
After
Chemical
Precipitation)
­
Industry­
Wide1
Pollutants
of
Concern
Median
Target
Average
Concentration
(
mg/
L)

Conventionals
Biochemical
Oxygen
Demand
5­
Day
(
BOD5
)
399
Total
Suspended
Solids
(
TSS)
117
Total
Conventionals
516
Non­
Conventionals
4­
Methyl­
2­
pentanone
1.960
Iron
1.780
2­
Butanone
1.680
2­
Propanone
1.540
n­
Dodecane
1.460
Aluminum
1.330
Toluene
0.973
Tetrachloroethene
0.421
1,1,1­
Trichloroethane
0.390
Boron
0.383
Benzyl
Alcohol
0.342
Zinc
0.303
Isophorone
0.300
Molybdenum
0.275
Copper
0.270
m­
Xylene
0.241
Hexanoic
Acid
0.203
o­&
p­
Xylene
0.197
Total
Non­
Conventionals
14.048
1.
Data
obtained
from
the
2000
TDD.
Page
8
of
12
Table
1­
5.
Pollutant
Concentrations
(
After
Dissolved
Air
Flotation)
­
Industry­
Wide1
Pollutants
of
Concern
Median
Target
Average
Concentration
(
mg/
L)

Conventionals
Biochemical
Oxygen
Demand
5­
Day
(
BOD5
)
497.0
Total
Suspended
Solids
(
TSS)
85.5
Total
Conventionals
582.5
Non­
Conventionals
2­
Butanone
17.40
2­
Propanone
13.60
Iron
2.79
Benzoic
Acid
1.58
Aluminum
1.31
Zinc
0.84
Toluene
0.71
4­
Methyl­
2­
pentanone
0.60
Methylene
Chloride
0.55
Boron
0.52
Copper
0.48
alpha­
Terpineol
0.47
Total
Non­
Conventionals
40.84
1.
Data
obtained
from
the
2000
TDD.

Industrial
laundry
pollution
prevention
can
be
divided
into
two
categories:
preprocess
pollution
prevention
and
in­
process
pollution
prevention.

The
pre­
process
pollution
prevention
activities
include:
refusal
of
items
with
free
liquids,
refusal
of
certain
items,
centrifugation
of
items
to
remove
liquids,
drycleaning
of
items
before
water
washing,
pre­
sorting
to
remove
objects
and
stream/
air
stripping
of
volatile
organics.
The
most
common
pre­
process
pollution
prevention
activities
are
the
refusal
of
items
with
free
liquids
and
the
refusal
of
certain
items.

The
in­
process
pollution
prevention
activities
include:
change
in
laundering/
drycleaning
chemicals
used,
improved
training
of
employees,
use
of
a
liquid
injection
system
for
exact
wash
chemical
addition,
improved
housekeeping,
water
softening,
equipment
modifications/
installations,
recycling
of
laundry
materials,
removal
of
lint
before
air
venting
to
the
atmosphere
and
reduced
fuel
consumption.
The
most
common
in­
process
pollution
prevention
activities
are
a
change
in
laundering/
drycleaning
chemicals
used,
improved
training
of
employees
and
use
of
a
liquid
injection
system
for
exact
wash
chemical
addition.
1The
industry
calculated
the
TWPE
estimates
using
information
in
its
database
and
TWFs
from
the
1999
Industrial
Laundries
record.

Page
9
of
12
4.5
Laundry
Environmental
Stewardship
Program
(
LaundryESP
®
)

In
addition,
this
industry
also
embarked
on
a
voluntary
resource
conservation
and
recovery
program.
The
industry
designed
this
program,
LaundryESP
®
,
to
achieve
better
performance
in
the
areas
of:


Water
usage;


Energy
usage;


Wash
chemical
usage;
and

Pollutant
discharges.

The
industry
established
goals
of
reductions
of
10
to
25
percent
water
and
energy
usage
per
pound
of
textile
processed;
a
reduction
of
20,000
TWPE
of
pollutants
discharged,
and
10
to
25
percent
substitution
of
wash
chemicals
with
chemicals
with
a
more
positive
environmental
profile.
As
part
of
this
program,
the
industry
established
a
way
for
participating
facilities
to
provide
relevant
data
and
to
monitor
the
program's
performance.
In
2004,
the
industry
reviewed
its
performance
through
2002.
The
results
are
summarized
below.

As
of
2002,
170
textile
service
companies
(
750
laundry
plant
facilities)
were
participating
in
the
LaundryESP
®
.
According
to
this
industry,
this
participation
accounts
for
nearly
70
percent
of
the
industry's
revenue
(
2002).
From
1997­
2002,
the
industry
conducted
three
facility
surveys,
one
pollutant
data
survey,
and
three
wash
chemical
surveys
with
the
result
being
2.3
million
fields
in
the
database.
For
quality
control,
outside
consultants
reviewed
the
raw
data,
the
industry
performed
QA
checks
and
corrections,
and
the
industry
also
removed
outliers
(
using
a
standard
t­
statistic).

The
data
demonstrate
that
from
1997
to
2002
the
participating
facilities
reduced
water
usage
per
pound
of
textile
processed
by
12.5
percent
from
an
average
of
2.61
gallons/
pound
of
textile
processed
to
an
average
of
2.28
gallons/
pound
of
textile
processed.
In
addition,
the
industry
reduced
its
water
usage
by
5.5
billion
gallons
from
1997
to
2002.
Energy
usage
showed
a
similar
trend
with
an
11.8
percent
reduction
in
the
energy
use/
pound
of
textile
processed.
The
average
energy
usage
dropped
from
3650
BTU/
lb
to
3219
BTU/
lb.
The
industry
also
saw
a
100
percent
increase
(
from
3
to
6
million
lbs/
yr)
in
the
use
of
peroxide
bleaches
as
wash
chemicals
which
have
fewer
toxic
byproducts
than
the
standard
wash
chemicals.

The
LaundryESP
®
database
also
demonstrated
overall
toxic
pollutant
reductions
from
1998
to
2002.
Table
1­
6
below
shows
the
toxic
weighted
pounds
discharged
by
the
industry
as
a
whole
from
1998
to
2002,
based
on
information
in
the
LaundryESP
®
database1.
Page
10
of
12
Table
1­
6.
Pollutant
Discharges
from
Industrial
Laundry
Facilities
(
Measured
as
TWPE)

Year
TWPE
1998
40,677
1999
29,090
2000
32,830
2001
22,277
2002
23,162
Data
Source:
LaundryESP
®
4.6
Multimedia
Environmental
Releases
4.6.1
Sludge
Generation
Industrial
laundries
generate
sludge
from
sources
such
as
trenches;
catch
basins;
settling
pits,
or
other
structures
that
retain
the
process
wastewater
prior
to
discharge;
shaker
or
rotary
screens;
and
wastewater
treatment
units
such
as
DAF
or
CP
that
are
designed
to
remove
solids.
Sludge
may
include
large
objects,
sand,
grit,
lint,
lime
(
used
as
a
coagulant),
metal
compounds
precipitated
from
the
wastewater
and
agglomerated
organic
materials.
The
sludge
is
not
usually
considered
to
be
a
hazardous
waste,
and
is
normally
disposed
of
in
a
non­
hazardous
landfill.
However,
some
municipalities
may
require
the
sludge
to
be
disposed
of
in
an
industrial
waste
landfill.
If
the
sludge
contains
a
significant
amount
of
organic
material,
it
is
suitable
for
incineration
or
fuel
blending.
EPA
estimates
that
DAF
units
generate
a
median
of
0.031
pounds
of
sludge
per
gallon
of
wastewater,
while
chemical
precipitation
units
generate
a
median
of
0.039
pounds
of
sludge
per
gallon
of
wastewater.

4.6.2
Volatilization
Prior
to
Reaching
POTW
Industrial
laundry
facilities
generate
volatile
organic
compounds
(
VOCs)
in
wastewater
during
the
laundering
of
heavily
soiled
items.
VOCs
may
be
emitted
from
wastewater
prior
to
and
during
the
wash
cycle
and
during
wastewater
discharge.
Air
pollutants
may
also
be
emitted
from
wastewater
collection
and
treatment
units.
EPA's
evaluation
of
potential
air
emissions
from
Industrial
laundry
facilities
is
described
in
Chapter
10
of
the
Technical
Development
Document
for
the
1999
final
decision.
In
that
chapter,
EPA
explained
that
it
believed
volatile
emissions
would
be
similar
from
facilities
with
or
without
treatment
because
the
wastewater
comes
in
contact
with
the
ambient
air
in
either
scenario.
In
addition,
EPA
estimated
a
"
worst­
case"
scenario
for
volatile
emissions
from
industrial
laundry
facilities.
EPA
estimated
these
emissions
based
on
a
facility
with
the
highest
raw
wastewater
concentrations
out
of
seven
industrial
laundries
analyzed.
EPA
also
assumed
that
all
organic
pollutants
in
the
raw
wastewater
would
volatilize
during
treatment.
The
resulting
annual
estimate
of
organic
emissions
was
92
Mg
per
year,
with
the
most
dominant
pollutants
being
n­
decane,
2­
propanone
and
tetrachloroethene.
It
is
important
to
note,
however,
that
EPA
also
indicated
that
because
of
its
methodology,
the
calculated
emissions
are
much
higher
than
would
actually
occur
at
an
industrial
laundry.
Page
11
of
12
4.7
Industry
Trends
Several
business
and
operating
trends
are
emerging
in
the
industrial
laundries
industry,
including
changes
in
industrial
laundry
processes,
facility
size
and
pollution
reduction
technologies.
See
Section
5.5
for
a
discussion
of
industry
trends
in
water,
energy,
and
wash
chemical
usage
as
well
as
pollutant
reductions.

In
the
2000
TDD,
EPA
determined
that
many
industries
are
moving
away
from
dry
cleaning
due
to
the
hazardous
nature
of
the
dry
cleaning
solvents
and
the
expense
of
their
disposal.
Forty
five
percent
of
drycleaning
units
were
purchased
in
the
1980s
whereas
only
39
percent
of
the
drycleaning
units
were
purchased
between
1990
and
1995.

There
has
been
a
trend
towards
larger
firms
purchasing
smaller
firms.
The
larger
firms
realize
the
benefits
of
diversification
(
through
having
a
larger
number
of
specialized
laundering
services).
The
smaller
firms
have
difficulty
competing
with
the
larger
firms
due
to
rising
costs
of
laundry
equipment,
difficulty
in
raising
capital
and
utilization
of
new
technologies.

The
industry
as
a
whole
is
moving
towards
automation
in
the
washing,
drying,
folding
and
packaging
of
items
laundered.
Another
trend
is
the
installation
of
tunnel
washers,
which
have
a
built­
in
"
reuse
cycle"
where
the
final
rinse
water
is
automatically
cycled
back
to
the
first
rinse.
There
is
also
an
industry­
wide
increase
in
pollution
prevention
activities
such
as
installation
of
more
efficient
washers
and
extractors,
and
use
of
detergents
that
allow
for
lower
wash
temperatures
and
a
lower
pH
for
the
removal
of
oils
and
grease.

EPA's
Design
for
the
Environment
(
DfE)
Program
was
created
to
build
on
the
current
industry
trends
to
incorporate
environmental
factors
into
design
decisions.
The
DfE
maintains
partnership
projects
with
the
following
industries:
adhesives,
automotive
refinishing,
computer
display,
printing,
formulator,
garment
and
textile
care,
industrial
and
institutional
laundry,
integrated
environmental
management
systems,
lead­
free
solder
partnership,
nail
salons
and
printed
wiring
board.
The
DfE
work
is
on­
going;
information
obtained
from
the
EPA
website
was
last
updated
in
March,
2004.

4.8
References
1.
U.
S.
EPA.
Technical
Development
Document
for
the
Final
Action
Regarding
Pretreatment
Standards
for
the
Industrial
Laundries
Point
Source
Category.
March,
2000.

2.
Federal
Register.
Effluent
Limitations
Guidelines
and
Pretreatment
Standards
for
the
Industrial
Laundries
Point
Source
Category.
Volume
64,
Number
159.
August
18,
1999.

3.
Uniform
and
Textile
Service
Association
(
UTSA).
Comments
to
the
Preliminary
Effluent
Guidelines
Program
Plan
(
Docket
OW­
2003­
0074).
March
18,
2004.
Page
12
of
12
4.
Uniform
and
Textile
Service
Association
(
UTSA)
and
Textile
Rental
Service
Association
(
TRSA).
LaundryESP
®
:
Laundry
Environmental
Stewardship
Program,
2004
Results
Report
(
Docket
OW­
2003­
0074).
2004.

5.
Uniform
and
Textile
Service
Association
(
UTSA).
Meeting
and
Correspondence
Notes
between
David
Dunlap,
UTSA
and
Jan
Matuszko,
EPA.
November,
2004­
January
2005.

6.
U.
S.
EPA.
Design
for
Environment:
Considerations
for
Partnership.
Available
online
at:
http://
www.
epa.
gov/
dfe/
pubs/
formulat/
consider/
index.
htm.
Accessed
March
24,
2004.
