SUBJ:
Meeting
with
David
Dunlap
of
the
Uniform
Textile
and
Service
Assocation
FROM:
Jan
Matuszko,
EPA
TO:
304(
g)/
307
Record
DATE:
January
4,
2005
On
March
18,
2004,
the
Uniform
Textile
and
Service
Association
(
UTSA)
submitted
comments
on
the
Preliminary
Effluent
Guidelines
Program
Plan.
In
part,
these
comments
discussed
the
Laundry
Environmental
Stewardship
Program
(
Laundry
ESP)
and
preliminary
results
of
the
industry's
data
collection
as
part
of
this
program.
The
comments
indicated
that
the
Association
planned
to
release
a
final
analysis
of
data
collected
later
in
2004.

In
November,
2004,
I
contacted
David
Dunlap
of
UTSA
to
obtain
additional
information
on
the
Laundry
ESP
Program
as
part
of
our
304(
g)/
307
review
of
Industrial
Laundries.
He
provided
two
items
and
indicated
they
were
in
follow­
up
to
his
March
18,
2004
comments:

1.
A
brochure
on
the
Laundry
ESP
Program,
and
2.
A
Power
Point
presentation
summarizing
the
results
of
the
Laundry
ESP
Program
through
2002
After
reviewing
these
materials,
I
met
with
David
Dunlap
on
December
16
to
clarify
some
of
the
information
provided
in
the
Power
Point
presentation.
This
memo
summarizes
additional
information
obtained
during
the
meeting.
The
information
below
coincides
with
the
Power
Point
presentation.

Data
Quality:

Questionnaire
reviewers
ran
algorithms
that
pointed
out
inconsistencies
with
responses.
Consultants
called
these
respondents
and
corrected
information,
as
applicable.

Outliers
were
determined
using
a
t­
Statistic.

There
was
no
need
to
normalize
slides
presented
as
efficiency
(
since
efficiency
calculation
is
self­
normalizing)
such
as
water
and
energy.

Need
to
see
notes
on
normalizing
pollutants
lbs.

Pollutant
Data
Points
as
a
%
of
2002
Total:

Demonstrates
that
participation
is
increasing
and
that
data
for
1997
represents
approx
60%
of
the
facilities
participating
in
2002.
Facility
Size
Distribution:

Demonstrates
that
participation
by
smallest
facilities
is
low.
UTSA
is
attempting
to
increase
participation
by
small
facilities.

Pollutant
Equivalents
Industry
threw
out
1997
results
because
of
the
smaller
number
of
facilities
participating.
The
industry
does
not
believe
1997
data
is
representative
of
the
industry.

Emphasis
on
pollutants
was
on
metals
since
metals
drive
the
TWPE
for
this
industry.
List
of
metals
included
and
the
TWFs
applied
is
in
an
attached
e­
mail.
Also
see
e­
mail
for
approach
to
organic
constituents.
TWFs
were
obtained
from
Industrial
Laundries
record.

In
performing
the
calculations,
all
concentration
data
for
a
particular
year
was
grouped
together
and
averaged.
PE
was
then
determined
by
applying
TWF
for
each
pollutant
and
summing.

For
a
pollutant
to
be
included
in
this
analysis,
there
had
to
be
at
least
10
data
points
for
a
pollutant
in
all
years
evaluated.
This
was
done
to
decrease
the
chances
that
a
few
data
points
drive
the
results.

Line
is
arbitrary
and
could
be
deleted.
