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. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 II. Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 III. Existing Effluent Guidelines. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 IV. Industry Profile. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 V. Water Use. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 VI. Characterization and Pretreatment of Process Wastewaters. . . . . . . . . . . . 18 VII. Characterization of Final ( treated) Effluents. . . . . . . . . . . . . . . . . . . . . 34 VIII. Cost of Wastewater Control and Treatment. . . . . . . . . . . . . . . . . . . . . . 43 IX. Environmental Assessment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44 APPENDICES APPENDIX I. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 APPENDIX II 1. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 APPENDIX II 2. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 APPENDIX II 3. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 APPENDIX II 4. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 APPENDIX III 1. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37 APPENDIX III 2. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38 APPENDIX III 3. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50 APPENDIX III 4. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53 APPENDIX IV 1. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57 APPENDIX IV 2. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61 APPENDIX IV 3. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 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