EPA proposes new commercial laundry standards.

Pollutants in water targeted as threat to human health and aquatic

life.
In an effort to reduce the amount of pollution that is being
discharged into public water supplies, the U.S. Environmental Protection
Agency (EPA) has issued a proposed rule requiring pretreatment of
wastewater generated by those commercial laundries that process reusable
shop and printer towels. Wastewater generated during the laundering of
these products has been found by the EPA to contain some 315 "toxic
and unconventional" pollutants and results in the discharge of
approximately five million pounds of these substances into U.S. waters
every year.

The EPA has determined, in fact, that the laundering of reusable shop
and printer towels is responsible for more than 80% of the "toxic
pollutant loading" being discharged into publicly-owned water
treatment facilities (known as "POTW's") by industrial
laundries throughout the country. This is primarily due to the fact
that, according to the EPA, 87% of all industrial laundries that handle
these products do not treat their wastewater before discharging it to
their local POTW.

INDA, Association of the Nonwoven Fabrics Industry, Cary, NC,

strongly supports the EPA's efforts on this issue even though the
proposed rule is not expected to impact demand for wiping products that

are not intended to be laundered. The EPA estimates, in fact, that

adoption of the proposed rule would result in a decrease of business for
industrial laundries of about 0.3% and contrasts this with economic data
showing profits for these facilities are growing at some 4% per year.

Why Pretreatment?
Generally speaking, industrial laundries discharge their wastewater
to POTW's around the country. POTW's are designed to process
human solid waste disposed of through public sewage systems and
typically treat the water using biological methods where microorganisms
consume the bulk of these wastes. Once treated, water is discharged into
streams, rivers and other bodies. Public drinking water is often drawn
from these same sources, although it must be further treated before it
is fit for human consumption. Sludge generated during POTW treatment can
either be disposed of in Commercial washer service Sacramento ordinary landfills or, if
contaminated, must be
handled as hazardous waste.

The EPA began its analysis of industrial laundering practices - and

the impact of these practices on water systems - in 1993. What the
agency found was that commercial laundering of reusable shop and printer

towels was responsible for the production of approximately 13 million

pounds of water pollutants every year and, since POTW's are not
designed to treat these materials, some five million pounds of these
pollutants are 'passing through" POTW's annually.

In addition, according to the EPA, pollutants generated during the

laundering of these products cause problems at the POTW's. The
agency notes, for instance, that POTW operators have told the EPA of oil
and grease contained in the untreated wastewater from these laundries
clogging their pipes and pump stations. The EPA has also received
reports of metals in nonpretreated wastewater injuring POTW workers and
causing the deterioration of concrete pipes and manhole covers. In
addition, POTW operators have reported to the EPA that wastewater from
these laundries inhibits the microorganisms used in their treatment
process and causes pH fluctuations. All told, according to the EPA, 11
of the 40 POTW operators contacted by the agency said they had
encountered difficulties due to discharges from these laundries.

But the real problem, in terms of threat to human health and damage
to aquatic life, is the pollution that passes through the POTW's
and ends up in public waters. EPA data reveal that 23 different
pollutants generated during the laundering of reusable shop and printer
towels can pass through POTW's. Included in this list are toluene,

lead, copper, zinc, silica gel treated N-hexane extractable material

(SGT-HEM), m-xylene and o&p-xylene. These pollutants harm
freshwater, estuarine and marine ecosystems and can cause cancer as well
as other toxic effects in humans who drink the water or consume fish
taken from it.

The EPA estimates that POTW treatment is only capable of removing

between 4-99% of these materials prior to their discharge into public
waters. Depending on the pollutant involved, this means that only four
percent of potentially toxic pollutants are being removed from public
water systems due to POTW treatment.
Proposed Standards

To stem this tide of pollution, the EPA has proposed an inexpensive

pretreatment standard known as chemical precipitation. In this process,
"precipitation aids" (such as lime) are used at the laundry to
react with the pollutants in the wastewater and convert them into an

insoluble form before the water is discharged to the POTW.

"Coagulation and flocculation aids" are also typically used in
this process so that large, amalgamated pollutant particles will form.
These particles can then be removed from the wastewater before it is
discharged.

The EPA estimates that the added cost for adopting this technology
equals about $0.003/pound of laundry and the agency has even included an
exemption for smaller facilities out of concern that it would be

economically difficult for them to adopt these practices. Under this

exemption, existing facilities that launder less than one million pounds
of incoming laundry - or 255,000 pounds of shop and/or printer towels -
per calendar year would be excluded from pretreatment requirements.
There would be no size-based exemption for new facilities. Dry cleaners,
onsite laundries at industrial facilities and facilities that launder
textiles exclusively for use by hospitals, hotels or restaurants would
also be exempt from the proposed regulation.

In addition to the reduction in pollution to public waters expected

to result from this proposed rule, the EPA points out that it would also
reduce POTW operating costs, Not only would they suffer less damage from
pollutants that they were not intended to handle, they would also be
able to dispose of a greater portion of their sludge in regular
landfills (instead of having to handle it as hazardous waste).

A number of industrial laundries that handle reusable shop and

printer towels have already adopted chemical precipitation, or some
other pretreatment process, largely as a result of requirements by their
local POTW. But without federal regulations there are no guarantees that
the nation's water systems will be safe from pollutants discharged
during the laundering of these products. By relying on local
requirements alone, certain areas of the country will be protected, but
others will not. Considering that there are approximately 1600
industrial laundries affected by the EPA's proposal, it would seem
that many areas of the country are not currently receiving adequate
protection.

Nevertheless, both the Textile Rental Services Association (TRSA) and

the Uniform and Textile Service Association (UTSA) are opposing the EPA
on this issue. The TRSA and UTSA argue that federal regulations are
unnecessary since some localities and certain POTW's have already
taken action. Claiming that the proposed standards will have a
significantly negative impact on the economic viability of industrial
laundries, both of these organization are working to enlist
Congressional support for their cause. They are also asking their
members to contact local POTW's and urge them to oppose the

proposed regulations as well.

Since the EPA estimates that some 33 laundries may be forced to close
if this regulation is adopted (out of 1600 facilities total), TRSA and
USTA efforts may be successful. Members of Congress don't like to
see businesses closed, especially if those facilities are located in
their Congressional district. Moreover, even though POTW operators have
much to gain under these proposed rules, they may be sympathetic to

claims of impending economic doom by one or more of their commercial

laundry "customers." This is most likely why POTW's have
been targeted by the reusables' industry associations in its
efforts to block EPA action.

But if these regulations are not adopted, millions of pounds of

pollutants will continue to be discharged into our waters every year.
Humans and aquatic life will continue to suffer and the reusables
industry will continue to claim that their products are
"environmentally superior" to single-use products. But if more
people become aware of the impact that commercial laundering practices
are having on our environment, hopefully the political tactics employed

by the reusables industry will fail.

It is for these reason that INDA will file comments with the EPA in
support of the proposed pretreatment standards. A task force of member
companies from INDA's Wiper Focused Interest Group has already been
formed, in fact, and will take the lead in drafting these comments.
Other members of the nonwovens industry are also encouraged to spread
the word about the EPA's efforts on this issue. The more people who
are aware of the fact that some 1600 industrial laundries are
responsible for discharging 13 million pounds of potentially toxic
pollutants to POTW's annually - and that five million pounds of
these pollutants actually end up in our waters every year - the more
likely it is that something will be done to address the problem on a

national level.

Peter Mayberry is the director of government affairs for INDA,

Association of the Nonwoven Fabrics Industry. He works out of the law
offices of Kutak Rock in Washington D.C. This Capital Comments column

appears monthly.

in NONWOVENS INDUSTRY.