Chemicals Used in Water Based Washing Operations at Industrial and Institutional Laundries  Generic Scenario for Estimating Occupational Exposures and Environmental Releases  Draft

U. S. Environmental Protection Agency Office of Pollution Prevention and Toxics Chemical Engineering Branch 1200 Pennsylvania Avenue Washington, D. C. 20460 27 August 2004 TABLE OF CONTENTS Page 1.0 INTRODUCTION.................................................................................................. 1 1 1.1 Scope .................................................................................................... 1 1 1.2 Background........................................................................................... 1 1 1.3 Purpose ................................................................................................. 1 2 1.4 Methodology for Developing Estimation Techniques ............................ 1 2 1.5 Content ................................................................................................. 1 3 1.6 Contact Information .............................................................................. 1 4 2.0 INDUSTRY SUMMARY AND BACKGROUND .......................................................... 2 1 3.0 PROCESS DESCRIPTIONS..................................................................................... 3 1 3.1 Water Based Washing Process .............................................................. 3 1 3.2 Chemicals Used in Water Based Washing............................................. 3 4 3.2.1 Detergent Formulations ............................................................. 3 4 3.2.2 Bleaches .................................................................................... 3 7 3.2.3 Antichlors, Sours, Softeners, and Starches ................................. 3 7 4.0 SCREENING LEVEL ESTIMATION TECHNIQUES/ METHODS .................................... 4 1 4.1 General Facility Calculations................................................................. 4 1 4.1.1 Operating Days.......................................................................... 4 1 4.1.2 Throughput of Chemical of Interest ........................................... 4 2 4.1.3 Number of Sites......................................................................... 4 6 4.1.4 Annual Number of Containers Used per Facility........................ 4 7 4.2 Environmental Release Assessments ..................................................... 4 8 4.2.1 Transfer Operation Losses to Air from Loading Laundry Cleaning Product into Washers ( Release 1) .......................................................... 4 8 4.2.2 Container Residue ( Release 2) ................................................... 4 9 4.2.3 Open Surface Losses to Air During Container Cleaning ................. ( Release 3)............................................................................... 4 12 4.2.4 Release from the Water Washing Process ( Release 4).............. 4 12 4.2.5 Mass Balance........................................................................... 4 14 4.3 Occupational Exposure Assessments ................................................... 4 15 4.3.1 Number of Workers ................................................................. 4 15 4.3.2 Exposure from Loading Laundry Cleaning Products into Washers ( Exposure A)....................................................................................... 4 17 4.3.3 Exposure During Transport Container Cleaning ( Exposure B) .4 21 4.3.4 Exposure to Vaporized Chemicals During Steaming and Drying ( Exposure C) ....................................................................................... 4 25 5.0 SUMMARY OF EQUATIONS AND SAMPLE CALCULATIONS .................................... 5 1 5.1 Summary of Release and Exposure Estimation Equations...................... 5 1 5.2 Chemical Release and Exposure Examples............................................ 5 8 5.3 Additional Examples of Determining the Throughput of the Chemical ...... of Interest ............................................................................................ 5 11 6.0 DATA GAPS/ UNCERTAINTIES AND FUTURE WORK/ CONTROL TECHNOLOGIES...... 6 1 6.1 Data Gaps ............................................................................................. 6 1 6.2 Control Technologies ............................................................................ 6 1 7.0 REFERENCES...................................................................................................... 7 1 TABLE OF CONTENTS ( Continued)

iii Appendix A: Chemical Engineering Branch Quality Criteria Appendix B: Literature Search Documentation Appendix C: Background and Equations for the EPA/ OPPT Penetration Model and the EPA/ OPPT Mass Balance Model Appendix D: Summary of Constants Used in Inhalation Exposure and Vapor Generation Models Appendix E: Table of Dermal Assessment Factors iv LIST OF TABLES Page 2 1 Amount of Laundry Processed per Facility ...................................................... 2 2 3 1 Typical Detergent Product Formulation ........................................................... 3 4 4 1 Number of Operating Days .............................................................................. 4 1 4 2 Average Annual Use Rate of Powdered Laundry Products............................... 4 5 4 3 Average Annual Use Rate of Liquid Laundry Products .................................... 4 5 4 4 Defaults for the Product in which Chemicals are Typically Received............... 4 6 4 5 Maximum Number of Sites .............................................................................. 4 7 4 6 EPA/ OPPT Penetration Model Parameter Default Values During Transfers ..... 4 9 4 7 Hours of Operation per Day............................................................................. 4 9 4 8 EPA/ OPPT Penetration Model Parameter Default Values During Container Cleaning ......................................................................................................... 4 12 4 9 Number of Total Workers and Production Workers per Site............................ 4 16 4 10 Number of Exposed Workers per Site ............................................................. 4 16 4 11 EPA/ OPPT Mass Balance Model Parameter Default Values During Transfers 4 18 4 12 EPA/ OPPT Mass Balance Model Parameter Default Values During Container Cleaning ......................................................................................................... 4 22 4 13 EPA/ OPPT Mass Balance Model Parameter Default Values During Drying and Steaming Operations....................................................................................... 4 27 5 1 Summary of Release and Exposures Calculation.............................................. 5 1 5 2 Default Value Declaration and Documentation ................................................ 5 7 6 1 On Site Control Technologies and Industrial and Institutional Laundries ......... 6 1 v LIST OF FIGURES Page 3 1 Flow Diagram for Industrial/ Institutional Laundering Operations .................... 3 2 4 1 Decision Logic Diagram for Determining the Use Rate.................................... 4 3 DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 1 1 1.0 INTRODUCTION 1.1 Scope This generic scenario provides information sufficient to estimate potential occupational exposures and environmental releases from the use of laundry chemicals manually or automatically added to water washing machines at industrial and institutional laundries. It does not cover worker exposures or environmental releases from pretreatment, dry cleaning, or other activities that may occur at an industrial or institutional laundry. This scenario covers chemical components of liquid and powder alkaline, antichlor, bleach, builder, detergent, fabric softener, sour, starch, and other laundry cleaning products. Materials used in laundries are generally non volatile; however, fragrances blended in laundry cleaning products to cover the odor of other laundry chemicals are typically volatile. Therefore, this scenario includes assessments for both non volatile and volatile chemicals used in laundries.

1.2 Background Under Section 5 of the Toxic Substances Control Act ( TSCA), the U. S. Environmental Protection Agency's ( EPA's) Office of Pollution Prevention and Toxics ( OPPT) evaluates new chemicals ( i. e., those chemicals not listed on the TSCA inventory), for potential risks associated with their stated and potential uses. Existing chemicals may also be evaluated under Sections 4 and 6 of TSCA for potential risks associated with their various uses. In these cases, EPA may develop regulatory controls and/ or non regulatory actions to protect human health and the environment from harm resulting from manufacturing, processing, transport, disposal, and current and potential new uses of existing and new chemical substances.

A new chemical, with certain exceptions, is any chemical that is not currently on the TSCA Inventory of Chemicals in commerce. The new chemical review under Section 5 of TSCA requires an identification and mitigation of potential risks with the stated and potential uses of new chemicals. Under Section 5 of TSCA, companies are required to submit a Premanufacture Notification ( PMN) at least 90 days prior to commercial production ( including importation). The Chemical Engineering Branch ( CEB) is responsible for preparing the occupational exposure and release assessments of the new chemicals. These assessments are based on information provided by the PMN submitter, information from readily available databases and literature sources, and standard estimating techniques used by CEB. Frequently, data on the new chemical being assessed are not available. In the event that information is unavailable, CEB relies on other approaches for developing exposure and release assessments. One important tool that CEB uses are generic scenarios.

CEB has developed a number of generic scenarios and modeling approaches for quantifying sources and control efficiencies to use in assessing exposures and releases for various industries and unit operations. These generic scenarios contain a compilation of information from readily available sources and from past CEB assessments. They have helped CEB to standardize its assessments. DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 1 2 1.3 Purpose This document presents a standard methodology to calculate the number of sites, number of workers, occupational exposures, environmental releases, media of release, and treatment methods for new chemical substances that will be used in laundry cleaning products. The information in this document can be used to estimate potential occupational exposures and environmental releases from the commercial use of these chemicals in water washing machines at industrial and institutional laundries. The scenario does not cover chemicals used for pretreatment, dry cleaning, or any other chemicals not directly added to a water washing machine. Laundry cleaning products are used in the washing cycle to remove stains and dirt, brighten and soften fabric, eliminate microorganisms, and finish textiles. Laundry cleaning products may include alkalis, antichlors, bleaches, builders, detergents ( including surfactants), fabric softeners, sours, and starches. Materials used in laundries are generally non volatile; however, fragrances used in laundry cleaning products are typically volatile chemicals, and are included in this scenario.

CEB may use the estimation techniques described in this scenario to evaluate PMNs submitted to EPA for new chemicals to be used in water washing machines at industrial and institutional laundries; CEB may also use these techniques to evaluate existing chemicals used in this industry. The selection of this generic scenario for development was due in part to the quantity of PMNs submitted each year for new chemicals used in laundry products.

Releases and exposures from the manufacture of laundry chemicals and the formulation of the chemicals into laundry cleaning products are beyond the scope of this scenario, and therefore not addressed.

1.4 Methodology for Developing Estimation Techniques The scenario supersedes the EPA's scenario for this industry dated April 2002. This document was drafted to meet the May 24, 2004 CEB Quality Criteria for developing generic scenarios, presented in Appendix A. This version of the generic scenario is currently undergoing internal CEB review. This document presents information readily available to the Agency, as well as data collected by the Agency during the proposal development phase of the industrial laundries effluent limitation guidelines and pretreatment standards. The effluent guidelines data were collected from actual field surveys, and are specific to the use of laundry cleaning products in water washing machines at industrial and institutional laundries. These data are considered to be of highest quality, and suitable for use in preparing these estimation methodologies. The estimation methods presented in this scenario use default values based on data obtained from industry specific sources, supplemented with CEB standard industrial defaults from a variety of resources. The industrial defaults are intended to be used when sitespecific information is not available.

Research preformed during the creation of this document include searches for process descriptions, operating information, chemicals used, wastes generated, waste treatment, worker activities, and exposure information. The data presented in the April 2002 generic DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 1 3 scenario were updated to include documents and databases used in the proposal development phase of the industrial laundries effluent limitation guidelines and pretreatment standards, Organisation for Economic Co operation and Development's Emission Scenario Document on Industrial Surfactants, and Kirk Othmer Encyclopedia of Chemical Technology. Appendix B summarizes sources searched while updating this scenario.

This scenario presents environmental release estimation methodology developed from industry specific information. The detailed description of laundry cleaning products and the industry specific operation and use rate data are all strengths of this document. Additional information on the fraction of chemical remaining on the textile item after washing would enhance this document.

1.5 Content This scenario presents methods that can be used to estimate the following releases of and exposures to chemicals during the use of the laundry cleaning products in water based washing at industrial and institutional laundries:

  Transfer operation losses to air of volatile chemicals of interest during unloading;

  Inhalation and dermal exposures to powdered and liquid chemicals of interest during transfer into washing machines;

  Release to water of wastes generated from chemicals of interest remaining in transport containers;

  Open surface losses to air of volatile chemicals of interest during transport container cleaning;

  Inhalation and dermal exposures to powdered and liquid chemicals of interest during transport container cleaning;

  Release of chemicals of interest to a publicly owned treatment works ( POTW) from the water discharge and to air from the evaporation of volatile chemicals of interest during the washing process; and   Inhalation exposures to volatile chemicals of interest during steaming and drying. DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 1 4 1.6 Contact Information Technical questions should be addressed to:

Greg Macek, EPA Work Assignment Officer Chemical Engineering Branch Office of Pollution Prevention and Toxics U. S. Environmental Protection Agency 1200 Pennsylvania Avenue, N. W. Washington, DC 20460 Phone: ( 202) 564 8516 Fax: ( 202) 564 8528 e mail: macek. greg@ epa. gov DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 2 1 2.0 INDUSTRY SUMMARY AND BACKGROUND The laundry industry can be categorized into two main categories: industrial and institutional. Industrial and institutional laundries are of similar size; however they launder different types of items.

Industrial launderers fall under the Standard Industrial Classification ( SIC) code 7218 and the North American Industry Classification System ( NAICS) code 812332.

This U. S. industry comprises establishments primarily engaged in supplying, on a rental or contract basis, laundered industrial work uniforms and related work clothing, such as protective apparel ( flame and heat resistant) and clean room apparel; dust control items, such as treated mops, rugs, mats, dust tool covers, cloths, and shop or wiping towels. ( 1)

Institutional launderers fall primarily under SIC codes 7213 and 7219 and NAICS code 812331.

This U. S. industry comprises establishments primarily engaged in supplying, on a rental or contract basis, laundered items such as table and bed linens; towels; diapers; and uniforms, gowns, or coats of the type used by doctors, nurses, barbers, beauticians, and waitresses. ( 1)

Note that these SIC and NAICS codes exclude coin operated laundries and drycleaners which are outside the scope of this generic scenario.

Most of the data presented in this generic scenario for the industrial and institutional laundry industry are based on data obtained by EPA's Office of Water to develop pretreatment standards for the industrial laundries industry. While data were collected for both institutional and industrial laundries, the Office of Water specifically excluded facilities that laundered only linen items1 and did not launder any industrial textile items2 from the data presented in the 1997 Technical Development Document for Proposed Pretreatment Standards for Existing and New Sources for the Industrial Laundries Point Source Category ( TDD) ( 2). Because the types of items laundered most directly affect the pollutant loading discharged to wastewater, facilities laundering only linen items were excluded so EPA could obtain pollutant loading data related only to industrial textile items.

The TDD summarizes detailed operating data collected by the Office of Water for the 1993 operating year. Over 1,500 laundries submitted general information, including SIC 1 Linen items include the following: linen supply garments, linen flatwork/ full dry, health care items, continuous roll towels, family laundry, new items, executive wear, and other miscellaneous items. ( 2) 2 Industrial textile items include, but are not limited to: shop towels, printer towels/ rags, furniture towels, rags, mops, mats, rugs, tool covers, dust control items, gloves, buffing pads, absorbents, uniforms, filters, and clean room items. If the item has hospital, hotel, or restaurant uses, it was not included in the data. ( 2) DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 2 2 code, in responding to the 1993 Screener Questionnaire ( 3). A subset of the facilities responding to the screener questionnaire reported detailed operating data in response to the 1994 Industrial Laundries Detailed Questionnaire ( DEQ) ( 4). Screener Questionnaire data were compared and matched with Detailed Questionnaire data to determine the SIC codes represented in the data collection. Based on the definitions provided above for industrial and institutional laundries, the DEQ database contains information from 82 industrial laundries ( sites reporting SIC code 7218 only), 45 institutional laundries ( sites reporting SIC codes 7213 and/ or 7219), and 46 combined industrial and institutional laundries ( sites reporting SIC code 7213 and/ or 7219 and 7218). DEQ data referenced throughout this generic scenario are taken from these facilities responses to the DEQ. Data presented in this document for " all laundries" includes industrial, institutional, and combined laundries. According to 2001 Census Bureau data, 1,488 industrial laundries and 1,191 institutional laundries operate in the U. S. ( 5)

The average amount and range of dry, clean laundry processed by industrial and institutional laundry facilities is presented in Table 2 1.

Table 2 1 Amount of Laundry Processed per Facility Amount of Dry, Clean Laundry Processed ( kg/ site yr) Type of Laundry Average Range Industrial 3,000,000 110,000   11,000,000 Institutional 3,300,000 190,000   15,000,000 Source: U. S. EPA, 1994 Industrial Laundries Detailed Questionnaire Database ( 4). DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 3 1 3.0 PROCESS DESCRIPTIONS The following sections discuss the water based washing process and laundry cleaning products used in the laundry process. Section 3.1 presents a detailed discussion of the water based washing process and includes a description of potential releases and exposures attributed to the process. Section 3.2 discusses the chemicals that may be used in water based washing operations, their purpose, and typical chemical composition. While some industrial and institutional laundries may also perform dry cleaning operations, these operations are outside the scope of this scenario. Nationwide, 97% of all industrial laundry items are washed in water ( 2).

3.1 Water Based Washing Process The following process descriptions are based on industry specific literature and may vary on a site by site basis. The description is primarily based on information presented in the Industrial Laundries TDD ( 2). Figure 3 1 presents a flow diagram of the industrial/ institutional laundering operations, including potential release and exposure points for the chemical of interest.

Industrial/ institutional laundries typically receive laundry by truck. The laundry is sorted by hand and transported by cart to a weighing station. During the sorting process, large objects including pens, paper, and similar items are removed from the laundry. After weighing the sorted laundry, stain treatment chemicals may occasionally be applied to treat stains on the items. Items are then bagged and taken to the washers by overhead slings or carts. The items are loaded into the washers directly from the bags. The laundry is washed using a wash formula appropriate for the item type and soil loading. The wash cycle is approximately one hour ( 6); however, some washing machines operate in a continuous process. The typical water washing processes may be broken into the following cycles:

  Flush cycle  Loosely attached solids and a portion of the water soluble soils are removed during a rinsing operation.

  Break cycle  Items are treated with an alkali solution to swell the cellulosic fibers, allowing the soil to be more readily removed. Some detergent formulation may also be added.

  Sudsing cycle   Detergent formulation is added in varying concentrations and the items are agitated until they are clean.

  Bleaching cycle ( optional)  Detergent is replaced with a bleach solution to further clean and brighten the items.

  Rinsing cycle  Excess alkali, detergent, and bleach are removed from the items. DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 3 2 Laundry Received in Trucks Washing Machine ( 0.5   1 h r) Drying and Steaming C Hanging and Folding Stain Treatment Weighing Sorting Laundry Returned to Customers Large Objects ( pens, paper, etc.)

to Landfill Releases During Operations 4 Automatic Loading of Chemicals Manual Loading of Chemicals Connecting Transfer Lines Scooping or Pouring A A Liquid Laundry Cleaning Products Received in Drums or Totes Solid or Liquid Laundry Cleaning Products Received in Pails,

Drums , or Totes Fugitive Air Release During Transfers Container Residue and Cleaning 1 2 3 B Fugitive Air Release During Transfers Container Residue and Clean ing 1 2 3 B Exposures: Dermal and inhalation exposure from connecting transfer lines or from scooping and pouring.

Dermal and inhalation exposure during container cleaning.

Inhalation exposure to vaporized laundry chemicals during operations.

Releases: Transfer operation losses to air from unloading and transferring laundry cleaning product.

Transport container residue from pails, drums, or totes containing laundry cleaning product.

Open surface losses to air during transport container cleaning.

Washing water discharge to POTW ( non volatile and volatile chemicals) and evaporation losses to air during washing and drying operations ( volatile chemicals only).

A B C 1 2 3 4 Figure 3 1. Flow Diagram for Industrial/ Institutional Laundering Operations DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 3 3   Blueing/ brightening cycle  Additional chemicals are added to whiten/ brighten the items.

  Final Rinse and Finish  The water batch is soured or acidified to a pH of 5, preventing the yellowing of fabrics by sodium bicarbonate during pressing ( 2).

After washing, overhead slings or carts transport most of the laundry to dryers. Some of the items are steamed to remove wrinkles. After drying and steaming, the items are typically folded or placed on hangers. The processed laundry is then sorted and returned to customers. While some chemicals may be added before washing ( stain pretreatment) and after washing ( starches before ironing and pressing or pH neutralizers before release to POTW), this scenario focuses on releases of and exposures to laundry cleaning products added to a waterwashing machine.

The industrial or institutional laundry may receive its cleaning products in bags, cardboard boxes, or drums of various types and sizes as a solid powder or liquid solution ( 7). However, most of the cleaning products are liquid, received in drums or totes ( 8). Laundry cleaning products may be added automatically or manually to the washing machine. In almost all larger facilities and many smaller facilities, liquid products are pumped directly from their transport containers into the washing machine. Automatic loaders reduce labor costs, minimize spills, add up to ten chemicals precisely, and allow chemical addition at various times during the washing process. Automatic loaders also reduce worker exposure during the washing process, but workers may face dermal and possible inhalation exposure to volatile chemicals when connecting chemical transfer lines or transferring the liquid chemicals from the transport container to storage tanks ( Exposure A). If automatic loaders are not used, workers manually scoop or pour solid or liquid products into the washing machine, either directly from its transport container, or from a transfer container ( such as a pail for easy transport around the facility) prior to being loaded into the machine. During manual loading, workers may undergo a dermal exposure and possible inhalation exposure to volatile liquids or powder chemicals ( Exposure A). During both automatic and manual transfer operations, volatile components may vaporize resulting in a fugitive air release ( Release 1). Empty transport containers are typically sent to a drum recycler/ reconditioner ( Release 2, Release 3, Exposure B) ( 8).

Laundry cleaning products may be added at various times during the washing process. Alkaline, builder, bleach, and detergent products are generally added near the beginning of the washing process during the break and sudsing cycles, while antichlors, sours, softeners, and starches are generally added later in the washing process, before the final rinse ( 9,10). During the washing process, volatile components may vaporize and be released to the atmosphere, while the remaining non volatile components are typically discharged to a POTW after the wash cycle ( Release 4). The water may first pass through on site wastewater treatment ( collection or settling basins, pH neutralization) before release to POTW; however, these control technologies are generally designed to remove dirt, oil, and other materials removed from the textile during the laundering process, not the laundry cleaning product. Control technologies are discussed further in Section 6.2. After the final rinse and water removal from the washer, very DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 3 4 small amounts of chemicals may still remain on the item. When workers are transferring, drying, steaming, or pressing the item, workers may be exposed to any residual volatile components as they evaporate ( Exposure C).

3.2 Chemicals Used in Water Based Washing Laundries may use one detergent formulation product without the addition of any other chemicals to the washing machine; however, laundries typically add other laundry cleaning products along with a detergent formulation, depending on water hardness, textile type, and textile soiling. Other laundry cleaning products added may include alkalis, antichlors, bleaches, builders, softeners, sours, and starches. The following sections describe products that may be used in water based washing operations, their purpose and typical chemical composition. Many chemicals may be used in multiple laundry cleaning products. Table 4 4 summarizes the defaults presented in this section for the type of laundry cleaning product in which chemicals are typically received.

3.2.1 Detergent Formulations A detergent is not an individual chemical, but a formulation of multiple chemical types. The major components of detergents are builders and surfactants. Detergents also typically contain antimicrobial agents, anti redeposition agents, bleaches, brighteners, corrosion inhibitors, enzymes, fabric softeners, fragrances, hydrotopes, preservatives, solvents, sours ( acids), stabilizers, and suppressors ( 11). Many of these components such as bleaches, builders, fabric softeners, and sours ( acids) may also be added to the washing machine as components of other laundry cleaning products. Table 3 1 provides information on a typical detergent formulation.

Table 3 1 Typical Detergent Product Formulation Component Percent in Formulation ( Chem. Book, 1995)* Percent in Formulation ( C& EN, 1996)*

Builders 58 59 Surfactants 36 32 Bleach, brighteners, enzymes 2.5 3 Fragrances & fabric softener 1.5 2 Others 2 4 * Percentages as presented in Reference 11.

Surfactants Surfactants are surface active agents that reduce the tension at the surface between the water and the fabric to be cleaned. The surfactant's main function is to suspend the soil that has been removed from the surface, but it also plays a key role in loosening soil ( 6,11). DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 3 5 Surfactants can be split into four separate classes: anionic, nonionic, cationic, and amphoteric surfactants.

  Anionic  Anionic surfactants are negatively charged. These surfactants resist the effects of water acidity and hardness ( 11). Typical anionic surfactants are sulfated fatty alcohols, sulfonated amides, and sulfated nonionics ( 6,11).

  Nonionic  Nonionic surfactants, which contain no charge, are the most widely used today in laundry detergents ( 11,12). They effectively remove oily soil from fabrics. Typical nonionic surfactants are ethylene oxide or propylene oxide with fatty alcohol, fatty acid condensates with ethylene oxide, amides from fatty acids and diethanolamine, and condensate of ethylene oxide with an amine or amide ( 6,11).

  Cationic  Cationic surfactants are positively charged. These surfactants are poor detergents but good fabric softeners and antibacterial agents. They are commonly used in conjunction with nonionic surfactants; however, they cannot be used with anionic surfactants because oppositecharged ions will clump together and precipitate out of solution ( 11). Most cationic surfactants are quaternary ammonium salts; however, amine and imidazoline salts also fall under this category ( 6).

  Amphoteric  Amphoteric surfactants have the ability to act either as an acid or base, displaying either a positive or negative charge. These surfactants are well suited as recyclable cleaners because they exhibit low foaming properties, provide good detergency and compatibility with alkaline formulations, and exhibit excellent water solubility ( 11). Amphoteric surfactants include betaines, glycinates, aminopropionates, and imidazoline based surfactants ( 6).

Typically, laundries receive surfactants as part of a formulated detergent and not as a separate agent; therefore, no use rate data has been provided in Section 4.1.2.

Builders ( Alkalis, Water Softeners, and Anti Redeposition Agents)

Builders are chemicals added to detergent formulations or to wash loads directly to enhance the surfactant's performance and increase the overall effectiveness. Builders increase the alkalinity, soften the water, and prevent redeposition of soil on the items. Increasing the alkalinity is important as surfactants work more effectively in an alkaline medium ( 11). Alkalis raise the pH of the wash water to ensure the effectiveness of the surfactant and help to swell cellulosic fibers, allowing the soil to be more easily removed. Detergent formulations and separately added builder products may contain between 30% and 85% alkalis ( 6). The laundry industry uses alkalis such as hydroxides, silicates, carbonates, and phosphates ( 11,13) DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 3 6 Hardness ions like calcium and magnesium can decrease the detergency of the surfactant. They directly interact with the surfactant or interact with the negative charges on the fabric or soil, reducing the electric repulsion between them ( 13). Water softeners sequester these ions and prevent their interaction with the surfactant. In detergent formulations or separately added builder products, water softeners may account for between 15% and 55% of the formulation ( 6). Note that this percentage is based on the phosphate concentration, which acts as both a water softener and an anti redeposition agent. Typical water softeners are phosphates, zeolites, sodium carbonate, sodium silicate, sodium citrate, ethylendiaminetetraacetic acid ( EDTA), and nitrilotriacetic acid ( NTA) ( 11,13).

Once the soil or stain has been removed from the laundered article and suspended in water, anti redeposition agents help suspend the soil to prevent it from re depositing on or getting trapped within the textile. Builders with multiple charges are the most effecting antiredeposition agents ( 13). In typical detergent formulations and separately added builder products, anti redeposition agents account for less than 5% of the formulation ( 6). The laundry industry typically uses polycarboxylates, polyacrylates, polyethylene glycol, sodium silicate, and polyaspartic acid as anti redeposition agents ( 11).

Builders and alkalis are standard in most detergent formulations; however, they may also be added individually to adjust the supply water, especially if it is acidic or hard. To clean heavily soiled loads, builders may also be added individually.

Other Additives in Detergent Formulations Detergent formulations may contain several other additives. Additives commonly found in detergent formulations ( and not added separately to the wash water) are briefly discussed below.

  Antimicrobial Agents  Inhibit microbial growth. Typical microbial agents are pine oil, quaternary ammonium compounds, sodium hypochlorite, triclocarbon, and triclosan.

  Optical Brighteners  Absorb invisible ultraviolet light and re emit it as visible light within the blue spectrum. ( 11) The blue tint counterbalances the yellow tint present in off white fabrics, and imparts a greater whiteness from the fabric. Brighteners are generally used only on cotton articles ( nearly all washroom supplies) and are best absorbed at high temperatures. Typical optical brighteners are stilbene disulfonates and coumarin derivates.

  Enzymes  Act as catalysts to facilitate in the destruction of soil particles and stains. These chemicals are classified as proteins. Typical enzymes are protease, amylase, lipase, and cellulase. ( 11) Because anionic and cationic surfactants lower the stability of enzymes, most enzymes are used with nonionic surfactants. DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 3 7   Corrosion Inhibitors  Help protect the metal washing machine parts. Sodium silicate is the most commonly used corrosion inhibitor. ( 11)

  Fragrances  Used to mask the odors of the chemical components of the detergents.

  Hydrotopes  Prevent the individual constituents of liquid detergents from separating into phases. These chemicals promote uniformity within the detergent solution. Typical hydrotopes are ethanol, toluene sulfonates, and cumene sulfonates. ( 11)

  Preservatives  Prevent oxidation, discoloration, and bacterial growth on the fabric. ( 11) The most common preservatives are butylated hydroxytoluene and thylenediaminetetraacetic acid.

  Stabilizers and Suppressors  Work to stabilize and/ or prohibit excessive sudsing. Typical stabilizers used to keep sudsing constant are alkanolamides and alkylamine oxides. ( 11) Typical suppressors such as silicone, soap, and alkyl phosphates act to prohibit excessive detergent sudsing.

3.2.2 Bleaches Bleaches act to maintain the whiteness of laundered items, by removing stains and killing any bacteria on the textile. Bleaches eliminate the stain's color or solubilize the stain for rinse away ( 11). Laundries may use either oxidizing or reducing bleaches. Oxidizing bleaches remove electrons from the stain. Reducing bleaches add electrons to the stain. Oxidizing bleaches are often chlorine or oxygen based. Oxygen bleaches are less effective than chlorine bleaches. They require higher temperatures, alkalinity, and concentration to perform ( 11). However oxygen bleaches can achieve better whitening. The most common chlorine bleach is sodium hypochlorite. Oxygen bleaches include hydrogen peroxide, perborates, and peracids. Typical reducing bleaches are sulfur dioxide, sulfites, and bisulfites ( 13). Most detergent formulations contain small quantities of bleach, but most laundries also use a separate bleach for white cotton loads.

3.2.3 Antichlors, Sours, Softeners, and Starches These products are typically added to the washing machine immediately before or during the final rinse cycle. They do not have an effect on detergency ( dirt and oil removal), but are added to finish the textile item and neutralize harsh chemicals added to clean the item. Antichlors, sours, softeners, and starches may be added individually or as part of a finishing formulation. A brief description of each is presented below. DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 3 8   Antichlors  Remove excess bleach from laundered items by neutralizing excess chlorine ( 14,15). Antichlors are used only on chlorine bleached items and are typically added during the final rinse cycle.

  Sours ( Acids)  Lower the pH of the water during the final rinse to counteract the alkaline builders that may have been added at the beginning of the wash cycle. Sours return the pH to a proper level, preventing the item from yellowing and hardness, and to reduce skin irritation when the textile is used. Sours also remove rust and prevent iron deposition ( 14,15).

  Softeners  Control the static electricity, soften, and interfere with microbial activity on the laundered items ( 14,15). Laundries often use cationic surfactants as fabric softeners because they bind strongly to negatively charged surfaces. The softener molecules form a film on the fabric's surface, and lubricate the fabric to give it increased softness and flexibility.

  Starches  Finish laundered items by stiffening the fabric. Starches help attain a smooth crisp finishes to ironed items ( 10). Dirt and sweat also adhere to the starch rather than the fabric, and are more easily removed the next time the item is washed. Starch can be added in the final rinse cycle or sprayed onto the item prior to ironing. Spray application of starch is outside the scope of this scenario. DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 4 1 4.0 SCREENING LEVEL ESTIMATION TECHNIQUES/ METHODS This section presents calculations that can be used to estimate general facility parameters for, environmental releases of, and worker exposures to laundry cleaning products used in water washing machines at industrial and institutional laundries. The calculations are intended only for screening level estimations. Default values are provided for all parameters to allow for facility, release, and exposure estimations, even where only limited information is provided ( e. g. production volume only). Site specific information, if available, takes precedence over the defaults presented in the methodology. For example, if the number of operating days is unknown, assume 261 days/ year ( Section 4.1.1). However, if site specific information states the facility will operate 300 days/ year, that value should be used in all estimations. If the known values fall outside of the ranges presented in this scenario, judgment should be used in determining whether those known values are appropriate for the calculations or whether they should be replaced with the defaults discussed in this scenario.

4.1 General Facility Calculations The general facility calculations are based on data obtained by EPA's Office of Water during the effort to develop pretreatment standards for the industrial laundries industry. During this effort the Agency collected detailed process information in the DEQ from 82 industrial laundries ( SIC code 7218), 45 institutional laundries ( SIC codes 7213 and/ or 7219), and 46 combined industrial and institutional laundries ( SIC code 7213 and/ or 7219 and 7218). This generic scenario uses the DEQ data obtained from these facilities ( 4). Data presented in this document for " all laundries" include industrial, institutional, and combined laundries. The values for " all laundries" should be used when site specific information is not available.

4.1.1 Operating Days In the DEQ, facilities reported the number of days they conducted laundering/ drycleaning activities in 1993. Table 4 1 presents the average number of operating days ( TIMEworking_ days) for industrial, institutional, and all laundries as derived from the DEQ. The default number of operating days is 261 days/ year.

Table 4 1 Number of Operating Days Operating Days Type of Laundry Average Range Industrial 252 208 290 Institutional 277 250 365 All Laundries ( default) 261 208 365 Source: U. S. EPA, 1994 Industrial Laundries Detailed Questionnaire Database ( 4). DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 4 2 4.1.2 Throughput of Chemical of Interest Annual use rates of laundry cleaning products ( Qfacility_ yr) can be estimated from DEQ data. Respondents estimated the quantity and purpose of laundry cleaning products used in their facilities in 1993. This use rate is assumed to be the purchase rate ( in process use rate plus container residue and transfer losses). Tables 4 2 and 4 3 present annual use information for powdered laundry products and liquid laundry products, respectively. These tables show annual use rates for institutional, industrial, and all laundries by industry average, median, and upper 99% confidence interval. The daily use rate of the chemical of interest can be directly calculated from the annual product use rates.

When site specific information is not available, the steps outlined in Figure 4 1 should be followed to determine which values from Tables 4 2 and 4 3 to use in estimating calculations. Figure 4 1 includes notes providing further explanation of the outlined steps. Section 5.3 presents examples of using the diagram to determine which annual use rate value to use.

The daily use rate of the product ( Qfacility_ day) and of the chemical of interest ( Qchem_ day) can be calculated using the following equations:

ys working_ da r facility_ y ay facility_ d TIME Q Q = [ 4 1]

Where: Qfacility_ day = Daily use rate of laundry product ( kg of formulation/ siteday Qfacility_ yr = Annual use rate of laundry product ( See Tables 4 2 and 4 3; Default = 27,000 kg of formulation/ site year1)( 4) TIMEworking_ days = Operating days ( See Table 4 1; Default = 261 days/ yr)( 11)

n formulatio _ chem day _ facility day _ chem F Q Q × = [ 4 2]

Where: Qchem_ day = Daily use rate of chemical of interest ( kg of chemical of interest/ site day) Qfacility_ day = Daily use rate of laundry product ( kg of formulation/ siteday Fchem_ formulation = Weight fraction of the chemical of interest in the laundry product ( Default for detergent formulations, see Table 3 1; Default for all others = 1 kg chemical of interest/ kg of formulation)( 11)

1 The median annual use rate for powdered detergent products at " All Laundries" from Table 4 2 is used as the default value for Qfacility_ yr, based on the default assumptions presented in Figure 4 1. DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 4 3 Is the chemical received at the laundry as a solid powder or liquid solution? 1 Solid Powder ( De fault) Use Data in Table 4 2 Li quid Solution Use Data in Table 4 3 Is the chemical used at industrial or institutional laundries? 2 Unknown ( Default) Use the values in the All column of Table 4 2 or 4 3 Does the chemical arrive at the laundry as part of a detergent formulation? 3 Industrial Use the values in the Industrial column of Table 4 2 or 4 3 Institutional Use the values in the Institutional column of Table 4 2 or 4 3 Yes ( Default) Use the median4 annual use rate for Detergent If the concentr ation in the formulation is unknown5 Use the data in Table 3 1 No Use the median4 annual use rate for the respective product type If the concentration in the formulation is unknown6 Assume 100% concentration Unknown and the chemical is an Alkaline, Builder, Surfactant, or Other Additive Use the median4 annual use rate for Detergent Unknown and the chemical is an Antichlor, Bleach, Softener, Sour, or Starch Use the median4 annual use rate for the respective product type Figure 4 1. Decision Logic Diagram for Determining the Use Rate Notes for Figure 4 1 are presented on the following page. DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 4 4 Notes for Figure 4 1:

1. If the form of chemical of interest is unknown, assume that the laundry receives all chemicals in powdered form, since inhalation and dermal exposure estimates are higher for powders than liquids. Use the values in Table 4 2 as defaults.

2. If the type of laundry ( institutional or industrial) is not specified and cannot be determined, use the value for " All Laundries".

3. To determine whether to assume the laundry receives the chemical as a component of a formulated detergent or of another laundry product, refer to Table 4 4. This table lists typical types of chemicals, the form in which it is usually received ( the default), and the data source to use to determine the value.

4. Use the median annual use rate from Tables 4 2 and 4 3, as they are most likely more accurate. The average values may have been raised by a few outliers in the data; in many cases, less than 15% of the data points were above the average value. These data points may represent possible data errors, or several facilities that are significantly larger than typical facilities. Also, using the median values in calculating worker exposures will provide more conservative estimates.

5. If site specific information does not provide the final concentration of the chemical, and the laundry receives the chemical already formulated in a detergent product, refer to Table 3 1 for a typical concentration of a detergent product. Use the higher value as a conservative estimate.

6. If site specific information does not provide the final concentration of the chemical and it is not typically a formulated detergent component ( such as an antichlor, bleach, softener, sour, or starch), use 100% concentration as the default value. DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 4 5 Table 4 2 Average Annual Use Rate of Powdered Laundry Products1 Annual Use Rate of Powdered Laundry Products ( kg/ site yr)

Institutional Laundries Industrial Laundries All Laundries Laundry Cleaning Product Median Average 99% CI Median Average 99% CI Median Average 99% CI Alkaline 15,000 14,000 26,000 1,700 15,000 45,000 3,200 14,000 27,000 Antichlor 1,500 1,500 2,000 340 440 630 500 900 1,200 Bleach 450 1,200 2,900 730 1,300 1,800 730 1,200 1,700 Builder 12,000 12,000 26,000 39,000 39,000 130,000 15,000 20,000 42,000 Detergent 28,000 35,000 50,000 28,000 45,000 68,000 27,000 40,000 52,000 Fabric Softener 590 610 940 590 830 1,500 570 690 1,000 Sour 2,300 2,700 3,800 1,000 1,600 2,300 1,800 2,100 2,600 Starch 8,000 13,000 19,000 590 1,300 2,400 1,900 7,100 11,000 Other Products 500 1,100 2,200 180 730 1,800 180 870 1,500 Source: U. S. EPA, 1994 Industrial Laundries Detailed Questionnaire Database ( 4). CI   Confidence Interval Table 4 3 Average Annual Use Rate of Liquid Laundry Products1 Source: U. S. EPA, 1994 Industrial Laundries Detailed Questionnaire Database ( 4). CI   Confidence Interval 1 Respondents to the DEQ could report usage in either pounds per year or gallons per year. It is assumed that products reported in pounds are powders and products reported in gallons are liquids. Gallons were converted to kilograms by assuming a density of 1 kg/ L ( 3.785 kg/ gal). Annual Use Rate of Liquid Laundry Products ( kg/ site yr) Institutional Laundries Industrial Laundries All Laundries Laundry Cleaning Product Median Average 99% CI Median Average 99% CI Median Average 99% CI Alkaline 27,000 50,000 120,000 50,000 220,000 660,000 35,000 35,000 310,000 Antichlor 830 2,200 5,000 790 1,200 2,000 890 6,200 17,000 Bleach 14,000 34,000 56,000 3,000 11,000 22,000 6,400 29,000 50,000 Builder 3,900 18,000 53,000 13,000 14,000 69,000 12,000 21,000 35,000 Detergent 4,900 21,000 39,000 7,900 19,000 32,000 6,800 21,000 30,000 Fabric Softener 820 2,100 4,200 950 1,700 2,500 1,200 4,900 11,000 Sour 4,000 6,900 12,000 2,400 7,800 22,000 2,600 7,000 13,000 Starch 530 1,100 2,200 230 260 440 450 1,800 4,500 Other Products 1,100 2,500 4,500 950 4,800 9,700 680 4,200 8,700 DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 4 6 Table 4 4 Defaults for the Product in which Chemicals are Typically Received Chemical Default Default Data Source Alkaline Component of formulated detergent Detergent formulation data from Tables 4 2 and 4 3 Antichlor Individually added Antichlor data from Tables 4 2 and 4 3 Bleach Individually added Bleach data from Tables 4 2 and 4 3 Builder Component of formulated detergent Detergent formulation data from Tables 4 2 and 4 3 Detergent Formulated detergent Detergent formulation data from Tables 4 2 and 4 3 Fabric Softener Individually added Softener data from Tables 4 2 and 4 3 Sour Individually added Sour data from Tables 4 2 and 4 3 Starch Individually added Starch data from Tables 4 2 and 4 3 Surfactant Component of formulated detergent Detergent formulation data from Tables 4 2 and 4 3 All Other Products Individually added Other products data from Tables 4 2 and 4 3 All Other Additives Component of formulated detergent Detergent formulation data from Tables 4 2 and 4 3 This table is based on the information presented in Section 3.2.

4.1.3 Number of Sites The daily use rate and the annual production volume of the chemical of interest can be used in the following equation to estimate the number of sites using the laundry cleaning product containing the chemical of interest. Table 4 5 presents the maximum number of sites for both laundry types not to be exceeded, based on County Business Patterns data.

ys working_ da chem_ day chem_ yr sites TIME Q Q N × = [ 4 3]

Where: Nsites 1 = Number of sites using the laundry product containing the chemical of interest ( sites) Qchem_ yr = Annual production volume of the chemical of interest ( kg of chemical of interest/ yr) Qchem_ day = Daily use rate of chemical of interest ( kg of chemical of interest/ site day) TIMEworking_ days = Operating days ( See Table 4 1; Default = 261 days/ yr)( 4)

1 The value for Nsites, calculated using equation 4 3, should be rounded up. Qchem_ day should be adjusted after Nsites is calculated to account for any rounding errors:

days _ working sites chem_ yr chem_ day TIME N Q Q × = DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 4 7 Table 4 5 Maximum Number of Sites Type of Laundry NAICS Code Total Number of Sites Industrial 812332 1,488 Institutional 812331 1,191 Total 2,679 Source: U. S. Census Bureau, 2001 County Business Patterns ( 5).

4.1.4 Annual Number of Containers Used per Facility The number of containers used annually per site can be estimated from the laundry cleaning product use rate, the container size, and the density of the formulation. Laundry cleaning products may be received at the industrial or institutional laundry in bags, cardboard boxes, or drums of various types and sizes ( 7) as a solid powder or liquid solution. However, most chemicals are received as liquids in drums or totes ( 8). In the absence of sitespecific information, use a 55 gallon drum as the default transportation container size. If the fluid density is not known, water can be used as a default ( 1 kg/ L). The annual number of containers used can be estimated through the following equation.

n formulatio container yr _ facility container RHO V Q N × = [ 4 4]

Where: Ncontainer = Annual number of containers containing chemical of interest per site ( containers/ site year) Qfacility_ yr = Annual use rate of laundry product ( See Tables 4 2 and 4 3; Default = 27,000 kg of formulation/ site year)( 4) Vcontainer = Volume of laundry product container ( Default = 208 L/ container ( for 55 gallon drum)) RHOformulation = Density of the formulation ( Default = 1 kg/ L) DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 4 8 Summary of the Relationship of Section 4.1 Parameters The values for chemical of interest throughput ( Qchem_ day), number of sites ( Nsites), and production volume of the chemical of interest ( Qchem_ yr) are all related. This scenario presents an equation to calculate the parameter for the chemical of interest throughput ( Qchem_ day) from DEQ data. The chemical of interest throughput and supplied production volume are then used to determine the number of sites.

If the number of sites is known, the chemical of interest throughput can be calculated directly without the use of DEQ data ( Qchem_ yr ÷ ( Nsites × TIMEworking_ days) = Qchem_ day). However, it is recommended to calculate the chemical of interest throughput based on the DEQ data and compare it to the throughput based on number of sites.

4.2 Environmental Release Assessments The following subsections present estimation methods for potential releases of the chemical of interest. Potential releases are shown on the process flow diagram ( Figure 3 1). Note that no releases occur from equipment cleaning because all of the production volume is assumed to already be released to water or air.

4.2.1 Transfer Operation Losses to Air from Loading Laundry Cleaning Product into Washers ( Release 1)

Most chemicals used in laundries are not volatile. For chemicals with a vapor pressure < 0.01 torr, releases to air are expected to be negligible. However, a few laundry chemicals, such as fragrances, may be volatile. If the vapor pressure of the chemical is > 0.01 torr, releases to air may occur as a worker manually scoops or pours the laundry cleaning product into the washer ( default scenario). Where automatic loaders are used, air releases are expected only when transfer lines are being connected to the transport containers. To estimate the release from either manual or automatic loading ( Elocalair_ transfers), use the EPA/ OPPT Penetration Model. While the EPA/ OAQPS AP 42 Loading Model is the standard CEB estimation model for transfer operations, it assumes containers are quickly and completely unloaded into a container of equal size, and estimates the release to air based on vapor displacement of saturated air. However, laundry cleaning product transport containers will slowly be unloaded into washers over the course of several days or weeks. The EPA/ OPPT Penetration Model estimates the volatilization of a chemical from a static pool; use of this model will provide a better estimate of the releases to air due from this transfer operation.

The model inputs and default values are listed in Table 4 6. CEB has developed a software package ( ChemSTEER) containing the EPA/ OPPT Penetration Model and all current CEB defaults. ChemSTEER should be used to calculate air releases and exposures from transfer operations. Appendix C lists the background and equations the model uses to estimate daily releases to air. Appendix D provides CEB default values for several model parameters. DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 4 9 Table 4 6 EPA/ OPPT Penetration Model Parameter Default Values During Transfers Input Parameter Default Values Diameter of Opening CEB default 2 in. ( 5.08 cm) for all containers less than 5,000 gallons ( 16)

Frequency of Use Manual loading ( default): Operating days ( default = 261 days/ yr; Table 4 1) Automatic loading: Operating days ( default = 261 days/ yr; Table 4 1) or the number of containers ( Ncontainer, calculated in Equation 4 4), whichever is fewer Molecular Weight Specific chemical parameter Number of Sites Calculated in Section 4.1.3, Equation 4 3 Operating Hours for the Activity Manual loading ( default): Operation hours/ day ( default = 11 hr/ day; Table 4 7) Automatic loading: CEB default, number of containers per site per day divided by the fill rate ( default fill rates are found in Appendix C) Vapor Pressure Specific chemical parameter Air Speed CEB defaults found in Appendix C Vapor Pressure Correction Factor Standard CEB default = 1 Note: The model also assumes standard temperature and pressure along with ideal gas interactions.

The CEB default for operating hours for this activity is equal to the number of containers used per site per day divided by a constant fill rate. Default fill rates are found in Appendix C. This is a reasonable assumption for automatic loaders, because releases are expected only when transfer lines are being connected. For manual loading, laundry cleaning products are unloaded from transport containers and loaded into washers throughout the working day. Table 4 7 presents the operating hours per day taken from DEQ data. Assume this release occurs over 11 hours/ site day, if the laundry type is unknown. Note that while the release is over 11 hours/ day, the number of hours an individual worker may be exposed would only be 8 hours/ day.

Table 4 7 Hours of Operation per Day Hours of Operation per Day Type of Laundry Average Range Industrial 12 7 24 Institutional 11 6 18 All 11 5 24 Source: U. S. EPA, 1994 Industrial Laundries Detailed Questionnaire Database ( 4).

4.2.2 Container Residue ( Release 2)

The amount of laundry cleaning product remaining in the transportation containers depends on the size of the transport container and the physical form of the laundry product. A 55 gallon drum should be used as the default transportation container size in the DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 4 10 absence of site specific information. For liquids in the default transport container size, assume 3% remains as residue ( Fcontainer_ residue) in the empty drums ( 17). Per Section 261.7 ( b) ( 1) ( ii) of the Resource Conservation and Recovery Act ( RCRA), a container or an inner liner removed from a container that has held any hazardous wastes, except waste that is a compressed gas or that is identified as an acute hazardous waste listed in § 261.31, 261.32, or 261.33( e) of the act is empty if no more than 2.5 centimeters ( 1 inch) remain on the bottom of the container or liner ( 18). Section 261.7 ( b) ( 1) ( iii) ( A) states that no more than 3% by weight of the total capacity of the container remains in the container or inner liner if the container is equal to or less than 110 gallons in size ( 18). The default for larger containers, 3%, is supported by a pilot scale research project investigating the effect of four parameters on residue quantities in drums ( 19). The parameters include the design configuration of the container, the viscosity of the chemical, the method of unloading the chemical, and the container construction or lining material.

If liquid laundry cleaning products are transported in small containers, assume 0.6% of the chemical remains as residue ( Fcontainer_ residue) ( 20). Using 0.6% results in a conservative estimate, as it represents the high end value of a study regarding container residue for small containers. For powdered laundry cleaning products, assume that 1% by weight ( Fcontainer_ residue) remains in the container as residue ( 20).

Empty containers are typically sent to drum recycler/ reconditioner ( 8). Current CEB policy assesses the release of container reside at the use site and not at a separate drum recycler/ reconditioner site; therefore, assume all containers are rinsed on site and the residual is released to POTW. Drum recyclers/ reconditioners may also incinerate or landfill the container residue. Assessing the release at the use site instead of the drum recycler/ reconditioner will yield the same total volume of release; however, the days of release, the number of release sites, and the quantity released per site per day will differ.

The information presented for this release is based on the following standard EPA/ OPPT models, which are included in ChemSTEER:

  EPA/ OPPT Drum Residual Model should be used for drums containing liquids;

  EPA/ OPPT Small Container Residual Model should be used for small liquid containers; and   EPA/ OPPT Solid Residuals in Transport Containers Model should be used for containers of all sizes containing solids.

The release estimates are based on the current version of the models ( as of the date of this generic scenario). Standard EPA/ OPPT models are subject to change; therefore, the current version of the standard EPA/ OPPT model should be used. DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 4 11 If the number of containers used per site per year ( Ncontainer) is fewer than the days of operation, the days of release equal the number of containers and the daily release is calculated based on the following equation:

day site container residue _ container n formulatio _ chem n formulatio container disp _ residue _ container 1 F F RHO V Elocal   × × × × = [ 4 5]

Where: Elocalcontainer_ residue_ disp = Daily release of chemical of interest from container residue ( kg chemical of interest/ site day) Vcontainer = Volume of laundry product container ( Default = 208 L/ container ( for 55 gallon drum)) RHOformulation = Density of formulation ( Default = 1 kg/ L ) Fchem_ formulation = Weight fraction of the chemical of interest in the laundry product ( Default for detergent formulations, see Table 3 1; Default for all others = 1 kg chemical of interest/ kg of formulation)( 11) Fcontainer_ residue = Fraction of chemical remaining in the container as residue ( Default for larger liquid containers = 0.03 kg container residue/ kg in container; smaller liquid containers = 0.006; all powder containers = 0.01)( 17, 20)

If the number of containers used per site per year ( Ncontainer) is greater than the days of operation, the days of release equal the days of operation, and the average daily release is calculated based on the following equation. Note that most sites should use less than one container per day. Also use this equation if a container size is not assumed in Equation 4 4 and the number of containers used per site per year is unknown.

residue _ container day _ chem disp _ residue _ container F Q Elocal × = [ 4 6]

Where: Elocalcontainer_ residue_ disp = Daily release of chemical of interest from container residue ( kg chemical of interest/ site day) Qchem_ day = Daily use rate of chemical of interest ( kg chemical of interest/ site day) Fcontainer_ residue = Fraction of chemical remaining in the container as residue ( Default for larger liquid containers = 0.03 kg container residue/ kg in container; smaller liquid containers = 0.006; all powder containers = 0.01)( 17, 20) DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 4 12 4.2.3 Open Surface Losses to Air During Container Cleaning ( Release 3)

Most chemicals used in laundries are not volatile. For chemicals with a vapor pressure < 0.01 torr, releases to air are expected to be negligible. However, a few laundry chemicals, such as fragrances, may be volatile. If the vapor pressure of the chemical is > 0.01 torr, chemicals may volatilize while empty containers are being rinsed and cleaned ( Elocalair_ cleaning). While containers are typically cleaned off site by a drum recycler/ reconditioner, current CEB policy assesses the release to air during container cleaning at the use site and not at a separate drum recycler/ reconditioner site. Therefore, assume all containers are cleaned on site. Assessing the release at the use site instead of the drum recycler/ reconditioner will yield the same total volume of release; however, the days of release, the number of release sites, and the quantity released per site per day will differ. The CEB standard model for estimating releases to air from containers cleaned inside ( EPA/ OPPT Penetration Model as of the date of this scenario) should be used. The model inputs and default values are listed in Table 4 8. The models and all current CEB defaults have been programmed into ChemSTEER, and the software should be used to calculate open surface losses to air during container cleaning. Appendix C lists the background and equations the model uses to estimate daily releases to air. Appendix D provides CEB default values for several model parameters.

Table 4 8 EPA/ OPPT Penetration Model Parameter Default Values During Container Cleaning Input Parameter Default Values Diameter of Opening CEB default 2 in. ( 5.08 cm) for all containers less than 5,000 gallons ( 16)

Frequency of Use Equal to operating days ( default = 261 days/ yr; Table 4 1) or the number of containers ( Ncontainer, calculated in Equation 4 4), whichever is fewer Molecular Weight Specific chemical parameter Number of Sites Calculated in Section 4.1.3, Equation 4 3 Operating Hours for the Activity Number of containers per site per day divided by the fill rate ( default fill rates are found in Appendix C) Vapor Pressure Specific chemical parameter Air Speed CEB defaults found in Appendix C Vapor Pressure Correction Factor Standard CEB default = 1 Note: The model also assumes standard temperature and pressure along with ideal gas interactions.

4.2.4 Release from the Water Washing Process ( Release 4)

Industrial and institutional laundries use an estimated 72,000 gallons of water/ site day, based on an average of 2.74 gallons of water used to produce one pound of dry, clean laundry ( 2) and the average amount of laundry processed per site shown in Table 2 1. Laundry is typically rinsed to remove the majority of laundry chemicals, since they may cause skin irritation. Only minimal quantities of laundry cleaning products may remain on the laundered item after washing. While many facilities may have on site wastewater treatment, DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 4 13 most of these treatment technologies are designed to remove dirt, oil, and other materials that were lifted from the textile during laundering. On site treatment technologies are generally not designed to remove laundry cleaning products. Section 6.2 discusses the treatment technologies in more detail. All of the facilities responding in the DEQ reported discharging to a POTW.

To calculate the daily release to POTW of non volatile components, assume the entire production volume of the chemical of interest except the container residue is discharged directly to a POTW from the washing process.

) F 1 ( Q Elocal residue _ container day _ chem washing   × = [ 4 7]

Where: Elocalwashing = Daily release of chemical of interest to POTW from the washing process ( kg chemical of interest/ site day) Qchem_ day = Daily use rate of chemical of interest ( kg chemical of interest/ site day) Fcontainer_ residue = Fraction of chemical remaining in the container as residue ( Default for larger liquid containers = 0.03 kg container residue/ kg in container; smaller liquid containers = 0.006; all powder containers = 0.01)( 17, 20)

Volatile components may be released to a POTW in wastewater after the washing cycle. They may also evaporate and be released to air during the washing process, especially if a hot water washing cycle is used. Any residual volatile components that are not removed during the washing process will evaporate during the transfer, steaming, pressing, or drying of the laundered textile. For volatile components, assume the entire production volume of the chemical of interest, except for container residue and releases to air during transfers and container cleaning, is released to POTW or vented to air. The following equation can be used to calculate the daily release to POTW or air of volatile components from the water washing process:

transfers _ air cleaning _ air residue _ container day _ chem washing Elocal Elocal ) F 1 ( Q Elocal       × = [ 4 8]

Where: Elocalwashing = Daily release of chemical of interest to POTW or air from the washing process ( kg chemical of interest/ site day) Qchem_ day = Daily use rate of chemical of interest ( kg chemical of interest/ site day) Fcontainer_ residue = Fraction of chemical remaining in the container as residue ( Default for larger liquid containers = 0.03 kg container residue/ kg in container; smaller liquid containers = 0.006; all powder containers = 0.01)( 17, 20) Elocalair_ cleaning = Daily release to air of volatile chemicals during container cleaning ( kg of chemical of interest/ site day) DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 4 14 Elocalair_ transfers = Daily release to air of volatile chemicals during transfers ( kg of chemical of interest/ site day)

The quantity of volatile chemicals released to water versus released to air is unknown and may be dependent on several factors such as wash water temperature, agitation, washer venting, and the vapor pressure of the chemical of interest. Fragrances may be released to air at a higher fraction than other volatile components in laundry cleaning products. Fragrances are generally designed for the consumer or worker to help mask less pleasant chemical odors. They are more likely to remain on clothing after the washing process. However, they are generally not designed to stay on the textile after drying, and will volatilize during the drying cycle ( 21).

4.2.5 Mass Balance The following equation provides a balance for the use of laundry cleaning products at industrial and institutional laundry sites.

days _ working sites washing cleaning _ air residue _ container day _ chem transfers _ air yr _ chem Time N ) Elocal Elocal F Q Elocal ( Q × × + + × + = [ 4 9]

Where: Qchem_ yr = Annual production volume of the chemical of interest ( kg of chemical of interest/ yr) Elocalair_ transfers = Daily release to air of volatile chemicals during transfers ( kg of chemical of interest/ site day) Qchem_ day = Daily use rate of chemical of interest ( kg chemical of interest/ site day) Fcontainer_ residue = Fraction of chemical remaining in the container as residue ( Default for larger liquid containers = 0.03 kg container residue/ kg in container; smaller liquid containers = 0.006; all powder containers = 0.01)( 17, 20) Elocalair_ cleaning = Daily release to air of volatile chemicals during container cleaning ( kg of chemical of interest/ site day) Elocalwashing = Daily release of chemical of interest to POTW or air from the washing process ( kg chemical of interest/ site day) Nsites = Number of sites using the laundry product containing the chemical of interest ( sites) TIMEworking_ days = Operating days ( See Table 4 1; Default = 261 days/ yr)( 4) DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 4 15 Summary of Relationship Between Release Estimates of Section 4.2 Chemical of interest release estimates ( Releases 1 through 4) are all related. If less than one container is used per site per day ( typically true), the release from container residue will not occur over the number of operating days, while other releases will occur over the number of operating days. Equations 4 7, 4 8, and 4 9 rely on the alternate method for calculating the release from container residue shown in Equation 4 6, because the water discharge release, fugitive air release, and mass balance are based on daily releases occurring over the number of operating days. Due to rounding errors when determining the number of containers per site per year, Elocalcontainer_ residue_ disp may not be equal to the terms used in Equation 4 9 ( e. g., calculating the release based on five full containers per site per year, when only four and a half will be used). However, this rounding error is automatically corrected when using standard EPA/ OPPT container residual models in ChemSTEER.

4.3 Occupational Exposure Assessments The following section present estimation methods for worker exposures to the chemical of interest. Figure 3 1 presents possible worker exposures. Workers are expected to have inhalation and dermal exposures to laundry chemicals during the transfer of the chemicals into the washing machine. Common personal protective equipment use in laundries include:

  Skin and eye protection when handling corrosive substances;

  Respirator protection when handling substances which produce dusts or vapors that can be inhaled; and   Skin protection if worker's hands are constantly immersed in water or wash solutions containing detergents and other chemicals. ( 22)

However, these situations are not typical for most operations at industrial and commercial laundries. Therefore, the use of PPE or engineering controls to reduce occupational exposures is not expected.

4.3.1 Number of Workers Washer/ dryer operators and maintenance supply personnel are the laundry workers with the greatest potential to be exposed to laundry chemicals. Figure 3 1 shows these production activities, designated as worker activities A, B, and C. Table 4 9 presents the average number of workers exposed per laundry site, generated using the following data sources:

  2001 County Business Patterns data on the US Census Bureau website  Extracted total number of workers and sites data the for institutional ( NAICS code 812331) and industrial ( NAICS code 812332) laundries. DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 4 16   DEQ database  Pulled the average number of workers per site and exposed workers per site: specifically, the total number of workers per site, the number of management workers, and the number of workers engaging in non laundry activities. If it is assumed that all management employees and non laundry employees are not exposed, the remaining 80% of the employees can be classified as production workers, potentially exposed to the chemicals of interest.

Table 4 9 Number of Total Workers and Production Workers per Site Type of Laundry NAICS Code Total Number of Workers* Total Number of Sites* Average Number of Workers per Site Exposed Workers per Site** Industrial 812332 77,724 1,488 52 42 Institutional 812331 56,582 1,191 48 38 Average 134,306 2,679 50 40 * Source: U. S. Census Bureau, 2001 County Business Patterns ( 5). ** Based on 80% of workers potentially exposed ( see above)

However, this estimate of the number of exposed workers per site may also include dry cleaning operators, folders, pressers, and delivery drivers who may not be exposed ( or may be minimally exposed) to chemicals in the laundry cleaning products. Based on sitevisit experience, approximately 1 2 workers are exposed per washer ( 23). Using DEQ data and observed activities, Table 4 10 presents the number of water based washers per site and number of exposed workers per site. This estimate is still very conservative as a number of laundries have automated chemical loading systems. Note that the same workers exposed to the chemical of interest during washer loading ( Exposure A) are also likely to be exposed to any vaporized chemical during steaming, drying, or transfer operations ( Exposure C).

Table 4 10 Number of Exposed Workers per Site Number of Washers per Site* Type of Laundry Average Range Number of Workers Exposed per Site** Industrial 5.9 2 20 6 12 Institutional 8.8 2 17 9 18 All 7.3 1 28 8 16 * Source: U. S. EPA, 1994 Industrial Laundries Detailed Questionnaire Database ( 4). ** Based on the average number of washers per site and 1 2 workers per washers ( 23).

One additional worker per site ( CEB default for container cleaning, as of the date of this scenario) should be assumed exposed to the chemical of interest during container cleaning ( Exposure B). While this worker may not be exposed at the industrial or institutional laundry site, he may be exposed to the laundry chemical at a drum recycler/ reconditioner. Because current CEB policy assesses exposure to the chemical of interest during container cleaning at the DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 4 17 use site and not at a separate drum recycler/ reconditioner site, this additional worker per laundry site should be factored in to account for workers at the recycler/ reconditioner sites.

4.3.2 Exposure from Loading Laundry Cleaning Products into Washers ( Exposure A)

Laundry cleaning products may be added automatically or manually to the washing machine. Automatic loaders limit worker exposure during the washing process, but workers may still be exposed when connecting transfer lines or transferring the liquid chemicals from the transport container to storage tanks. If automatic loaders are not used, workers manually scoop or pour solid or liquid detergent chemicals into the washing machine ( default scenario). If site specific information is not available, assume that the laundry cleaning product is manually loaded as a conservative exposure estimate. In the case of automatic loading, the number of days of exposure is equal to the number of containers used per year if the number of containers is less than the days of operation. Assume 8  16 workers per site are exposed to the cleaning product during this activity, if site specific information is not available.

Inhalation Exposure:

Liquids: The method used to calculate inhalation exposure depends on the volatility and the physical state of the chemical of interest. Inhalation exposure to liquids is negligible for nonvolatile liquids ( vapor pressure < 0.001 torr standard CEB estimate ( 24)). Using the vapor generation rate calculated in Release 1, the EPA/ OPPT Mass Balance Model can be used to calculate worker inhalation exposure due to volatilization during transfer operations. The model estimates that the airborne concentration of the chemical is a function of the source vapor generation rate and the volumetric ventilation rate within a given space. The model also includes simplifying assumptions of steady state ( constant generation rate and constant ventilation rate) and a mixing factor ( for non ideal mixing of air) ( 25). The default ventilation rates and mixing factors provide a typical and worst case estimate of exposure. The airborne concentration of the chemical cannot exceed the level of saturation for the chemical. The model and all current CEB defaults have been programmed into ChemSTEER, and the software should be used to calculate inhalation exposures from transfer operations. Appendix C lists the background and equations the model uses to estimate daily releases to air. Appendix D provides CEB default values for several model parameters.

Table 4 11 lists the model inputs and default values. Note that while the release and vapor generation for manual loading is over 11 hours/ day, the individual worker exposure would be only the CEB default of 8 hours/ day. Similarly, while facilities may operate an average of 261days/ year, workers are likely to be exposed only the CEB maximum default of 250 days/ yr. This estimate is equivalent to full time employment and considers an individual worker's vacation, sick, and weekend time ( 17). DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 4 18 Table 4 11 EPA/ OPPT Mass Balance Model Parameter Default Values During Transfers Input Parameter Default Values Inhalation Rate Default = 1.25 m3/ hr ( 26)

Exposure Days Manual loading ( default): CEB maximum default = 250 days/ yr ( 17) Automatic loading: CEB maximum default = 250 days/ yr ( 17) or the number of containers ( Ncontainer, calculated in Equation 4 4), whichever is fewer Vapor Generation Rate Calculated by the EPA/ OPPT Penetration Model ( Section 4.2.1)

Exposure Duration Manual loading ( default): CEB default = 8 hr/ day Automatic loading: Number of containers per site per day divided by the fill rate ( default fill rates are found in Appendix C) Mixing Factor Use CEB defaults ( Appendix C)

Molecular Weight Specific chemical parameter Number of Sites Calculated in Section 4.1.3, Equation 4 3 Ventilation Rate Use CEB defaults ( Appendix C)

Vapor Pressure Specific chemical parameter Vapor Pressure Correction Factor Standard CEB default = 1 Note: The model also assumes standard temperature and pressure along with ideal gas interactions.

Solids: The transfer of non volatile powdered laundry cleaning products from containers to washing machines generates particulates. The degree of inhalation exposure to particulates depends on the concentration of the chemical of interest in the laundry cleaning product ( Fchem_ formulation), the potential concentration of the laundry cleaning product in the worker's breathing zone ( Cparticulate), and the total amount of laundry cleaning product the worker is exposed to per day ( Qfacility_ day). Note that the trigger for using equation 4 10 versus 4 11 is based on the amount of laundry cleaning product the worker is exposed to per day ( Qfacility_ day), not the amount of chemical of interest the worker is exposed to per day ( Qchem_ day).

If the transfer rate of the solid powder laundry cleaning product containing the chemical of interest ( Qfacility_ day ) is greater than 54 kg of formulation/ site day use the OSHA Total PNOR PEL Limiting Model:

lation chem_ formu exposure breathing e particulat inhalation F TIME RATE C EXP × × × = [ 4 10]

Where: EXPinhalation = Inhalation exposure from the chemical of interest per day ( mg chemical of interest/ day) Cparticulate = Concentration of particulate in the workers breathing zone ( Default = 15 mg/ m3; based on OSHA PEL ( 8 hr TWA*) for nuisance dusts, not otherwise regulated 29 CFR 1910.1000)( 25) DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 4 19 RATEbreathing = Typical worker breathing rate ( Default = 1.25 m3/ hr) ( 26) TIMEexposure = Duration of exposure ( Default = 8 hr/ day, the default values for Cparticulate are 8 hr TWA*; therefore, 8 hr/ day must be used) Fchem_ formulation = Weight fraction of the chemical of interest in the laundry product ( Default for detergent formulations, see Table 3 1; Default for all others = 1 kg chemical of interest/ kg of formulation)( 11) * TWA = Time weighted average The accuracy of solid component inhalation estimates are limited by the estimated airborne concentration of the chemical of interest and the assumed breathing rate.

If the transfer rate of the solid powder laundry cleaning product containing the chemical of interest ( Qfacility_ day ) is less than or equal to 54 kg of formulation/ site day use the EPA/ OPPT Small Volume Solids Handling Inhalation Model:

exposure lation chem_ formu ay facility_ d inhalation F F Q EXP × × = [ 4 11]

Where: EXPinhalation = Inhalation exposure from the chemical of interest per day ( mg chemical of interest/ day) Qfacility_ day = Daily use rate of laundry product ( kg of formulation/ siteday Fchem_ formulation = Weight fraction of the chemical of interest in the laundry product ( Default for detergent formulations, see Table 3 1; Default for all others = 1 kg chemical of interest/ kg of formulation)( 11) Fexposure = Weight fraction of the total solid in the workers breathing zone ( Default = 0.0477 ( typical) to 0.161 ( worst) mgsite kg of formulation) ( 27)

Data collected in a textile dye weighing monitoring study were used to calculate the default values for concentration of the total solid in the workers breathing zone used in Equation 4 11. During this study, two personal monitoring devices measured on dye weighers measured exposure levels at 24 facilities ( 27). CEB uses this monitoring data to estimate inhalation exposures to solids transferred at a rate less than 54 kg/ site day in any industry, when industry specific information is unavailable.

Dermal Exposure:

Dermal exposure is expected for both automatic and manual loading. Automatic loaders limit worker exposure during the washing process, but workers may still be exposed when connecting transfer lines or transferring the liquid chemicals from the transport container to storage tanks. If automatic loaders are not used, workers manually scoop or pour solid or DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 4 20 liquid detergent chemicals into the washing machine. No dermal monitoring data on the transfer of laundry cleaning products were found. In the absence of data, the EPA/ OPPT standard models for estimating dermal exposures from industrial activities can be used. Similar models can be used to estimate exposure to detergent chemicals for both automatic and manual loading. To estimate dermal exposure to the chemical of interest in a liquid formulation during these activities, the EPA/ OPPT routine two hand contact with liquids model ( EPA/ OPPT 2 Hand Dermal Contact with Liquid Model in ChemSTEER) should be used ( 28). This model is based on experimental data with liquids of varying viscosity. The amount of exposure to hands was measured for various types of contact, then judgments were made as to the types of common industrial activities that could be associated with the experimental data. Similar assessments were made based on experimental data from exposure to solids. To estimate dermal exposure to the chemical of interest in a solid powder formulation, the EPA/ OPPT routine two hand direct handling of solids model ( EPA/ OPPT Direct 2 Hand Dermal Contact with Solids Model in ChemSTEER) should be used ( 28). Appendix E presents a table of dermal assessment factors, derived from several sources, including available data on pesticide exposures collected by EPA's Office of Pesticide Programs ( 28). Another key assumption and limitation of the dermal model is that a single contact with a chemical results in an exposure assessment for the entire day. These factors provide an assessment of potential exposure and do not take into account any protection from the use of protective gloves; however, protective gloves are not expected to be worn in industrial and institutional laundries.

The information presented for standard EPA/ OPPT models is based on the current version of the models ( as of the date of this generic scenario). Standard EPA/ OPPT models are subject to change; therefore, the current version of the standard EPA/ OPPT models should be used.

Liquids: To estimate the potential worker exposure to the chemical of interest in a liquid laundry cleaning product for this activity, use the following equation:

lation chem_ formu nt exp_ incide surface n liquid_ ski dermal F N AREA Q EXP × × × = [ 4 12]

Where: EXPdermal = Potential dermal exposure to the chemical of interest per day ( mg chemical of interest/ day) Qliquid_ skin = Quantity of liquid remaining on skin ( Defaults = 2.1 mg/ cm2 incident ( high end) and 0.7 mg/ cm2 incident ( lowend ( 28) AREAsurface = Surface area of contact ( Default = 840 cm2, 2 hands) ( 28) Nexp_ incident = Number of exposure incidents per day ( Default = 1 incident/ day) DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 4 21 Fchem_ formulation = Weight fraction of the chemical of interest in the laundry product ( Default for detergent formulations, see Table 3 1; Default for all others = 1 kg chemical of interest/ kg of formulation)( 11)

Only one contact per day is assumed because the quantity of liquid remaining on skin, with few exceptions, is not expected to be significantly affected either by wiping excess from skin or by repeated contact( s) with additional chemical ( i. e., wiping excess from the skin does not remove a significant fraction of the small layer of chemical adhering to the skin and additional contacts with the chemical do not add a significant fraction to the layer). Exceptions to this assumption may be considered for chemicals with high volatility and/ or with very high rates of absorption into the skin.

Solids: To estimate the potential worker exposure to the chemical of interest in a solid laundry cleaning product for this activity, use the following equation:

n formulatio _ chem dermal F mg/ day 3,100 to p u EXP × = [ 4 13]

Where: EXPdermal = Potential dermal exposure to the chemical of interest per day ( mg chemical of interest/ day) Fchem_ formulation = Weight fraction of the chemical of interest in the laundry product ( Default for detergent formulations, see Table 3 1; Default for all others = 1 kg chemical of interest/ kg of formulation)( 11)

4.3.3 Exposure During Transport Container Cleaning ( Exposure B)

Workers may be exposed to the chemical of interest during container cleaning. While this activity may not occur at the industrial or institutional laundry facility, workers are likely to be exposed to the laundry chemical during cleaning operations at a drum recycler/ reconditioner. Current CEB policy assesses exposure to the chemical of interest during container cleaning at the use site and not at a separate drum recycler/ reconditioner site. Assessing the exposure at the use site instead of the drum recycler/ reconditioner will yield the same daily exposure; however, the days of exposure and the total number of exposed workers may differ. The exposures presented for this activity are similar to those presented for Exposure A. See Section 4.3.2 for the derivation and explanation of these models.

Inhalation Exposure:

Liquids: Using the vapor generation rate calculated in Release 3, the EPA/ OPPT Mass Balance Model can be used to calculate worker inhalation exposure due to volatilization during cleaning operations. The default ventilation rates and mixing factors provide a typical and worst DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 4 22 case estimate of exposure. The model and all current CEB defaults have been programmed into ChemSTEER, and the software should be used to calculate inhalation exposures from transfer operations. Table 4 12 lists the model inputs and default values. Note that while facilities may operate an average of 261days/ year, workers are likely to be exposed only the CEB maximum default of 250 days/ yr. This estimate is equivalent to full time employment and considers an individual worker's vacation, sick, and weekend time ( 17). The models and all current CEB defaults have been programmed into ChemSTEER, and the software should be used to calculate inhalation exposure to volatile chemicals during container cleaning. Appendix C lists the background and equations the model uses to estimate daily releases to air. Appendix D provides CEB default values for several model parameters.

Table 4 12 EPA/ OPPT Mass Balance Model Parameter Default Values During Container Cleaning Input Parameter Default Values Inhalation Rate Default = 1.25 m3/ hr ( 26)

Exposure Days Equal to CEB maximum exposure days ( 250 days/ yr)( 17), or the number of containers ( Ncontainer, calculated in Equation 4 4), whichever is fewer Vapor Generation Rate Calculated by the EPA/ OPPT Penetration Model ( Section 4.2.3)

Exposure Duration Number of containers per site per day divided by the fill rate ( default fill rates are found in Appendix C) Mixing Factor Use CEB defaults ( Appendix C)

Molecular Weight Specific chemical parameter Number of Sites Calculated in Section 4.1.3, Equation 4 3 Ventilation Rate Use CEB defaults ( Appendix C)

Vapor Pressure Specific chemical parameter Vapor Pressure Correction Factor Standard CEB default = 1 Note: The model also assumes standard temperature and pressure along with ideal gas interactions.

Solids: The cleaning of solid powders from transport containers may generate dust particulate. The degree of inhalation exposure to particulates depends on the concentration of the chemical of interest in the formulation ( Fchem_ formulation), the potential concentration of the laundry chemical in the worker's breathing zone ( Cparticulate), and the total amount of laundry cleaning product the worker is exposed to per day ( Qfacility_ day). Note that the trigger for using equation 4 14 versus 4 15 is based on the amount of laundry cleaning product the worker is exposed to per day ( Qfacility_ day), not the amount of chemical of interest the worker is exposed to per day ( Qchem_ day).

If the transfer rate of the solid powder laundry cleaning product containing the chemical of interest ( Qfacility_ day ) is greater than 54 kg of formulation/ site day use the OSHA Total PNOR PEL Limiting Model: DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 4 23 lation chem_ formu exposure breathing e particulat inhalation F TIME RATE C EXP × × × = [ 4 14]

Where: EXPinhalation = Inhalation exposure from the chemical of interest per day ( mg chemical of interest/ day) Cparticulate = Concentration of particulate in the workers breathing zone ( Default = 15 mg/ m3; based on OSHA PEL ( 8 hr TWA*) for nuisance dusts, not otherwise regulated 29 CFR 1910.1000)( 25) RATEbreathing = Typical worker breathing rate ( Default = 1.25 m3/ hr) ( 26) TIMEexposure = Duration of exposure ( Default = 8 hr/ day, the default values for Cparticulate are 8 hr TWA*; therefore, 8 hr/ day must be used) Fchem_ formulation = Weight fraction of the chemical of interest in the laundry product ( Default for detergent formulations, see Table 3 1; Default for all others = 1 kg chemical of interest/ kg of formulation)( 11) * TWA = Time weighted average The accuracy of solid component inhalation estimates are limited by the estimated airborne concentration of the chemical of interest and the assumed breathing rate.

If the transfer rate of the solid powder laundry cleaning product containing the chemical of interest ( Qfacility_ day ) is less than or equal to 54 kg of formulation/ site day use the EPA/ OPPT Small Volume Solids Handling Inhalation Model:

exposure lation chem_ formu ay facility_ d inhalation F F Q EXP × × = [ 4 15]

Where: EXPinhalation = Inhalation exposure from the chemical of interest per day ( mg chemical of interest/ day) Qfacility_ day = Daily use rate of laundry product ( kg of formulation/ siteday Fchem_ formulation = Weight fraction of the chemical of interest in the laundry product ( Default for detergent formulations, see Table 3 1; Default for all others = 1 kg chemical of interest/ kg of formulation)( 11) Fexposure = Weight fraction of the total solid in the workers breathing zone ( Default = 0.0477 ( typical) to 0.161 ( worst) mgsite kg of formulation) ( 27)

Data collected in a textile dye weighing monitoring study were used to calculate the default values for concentration of the total solid in the workers breathing zone used in Equation 4 11. During this study, two personal monitoring devices measured on dye weighers DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 4 24 measured exposure levels at 24 facilities ( 27). CEB uses this monitoring data to estimate inhalation exposures to solids transferred at a rate less than 54 kg/ site day in any industry, when industry specific information is unavailable.

Dermal Exposure:

Dermal exposure is expected during the cleaning of transport containers. No dermal monitoring data on the cleaning of laundry cleaning products transport containers were found. In the absence of data, the EPA/ OPPT standard models for estimating dermal exposures from industrial activities can be used. To estimate dermal exposure to the chemical of interest in a liquid formulation during these activities, the EPA/ OPPT routine two hand contact with liquids model ( EPA/ OPPT 2 Hand Dermal Contact with Liquid Model in ChemSTEER) should be used ( 28). To estimate dermal exposure to the chemical of interest in a solid powder formulation during these activities, the EPA/ OPPT routine two hand direct handling of solids model ( EPA/ OPPT Direct 2 Hand Dermal Contact with Solids Model in ChemSTEER) should be used ( 28). The rationale for these models is further explained in Section 4.3.2 and Appendix E. These factors provide an assessment of potential exposure and do not take into account any protection from the use of protective gloves; however, protective gloves are not expected to be worn in industrial and institutional laundries but may be worn at a drum recycler/ reconditioner.

The information presented for standard EPA/ OPPT models is based on the current version of the models ( as of the date of this generic scenario). Standard EPA/ OPPT models are subject to change; therefore, the current version of the standard EPA/ OPPT models should be used.

Liquids: To estimate the potential worker exposure to the chemical of interest in a liquid laundry cleaning product for this activity, use the following equation:

lation chem_ formu nt exp_ incide surface n liquid_ ski dermal F N AREA Q EXP × × × = [ 4 16]

Where: EXPdermal = Potential dermal exposure to the chemical of interest per day ( mg chemical of interest/ day) Qliquid_ skin = Quantity of liquid remaining on skin ( Defaults = 2.1 mg/ cm2 incident ( high end) and 0.7 mg/ cm2 incident ( lowend ( 28) AREAsurface = Surface area of contact ( Default = 840 cm2, 2 hands) ( 28) Nexp_ incident = Number of exposure incidents per day ( Default = 1 incident/ day) DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 4 25 Fchem_ formulation = Weight fraction of the chemical of interest in the laundry product ( Default for detergent formulations, see Table 3 1; Default for all others = 1 kg chemical of interest/ kg of formulation)( 11)

Only one contact per day is assumed because the quantity of liquid remaining on skin, with few exceptions, is not expected to be significantly affected either by wiping excess from skin or by repeated contact( s) with additional chemical ( i. e., wiping excess from the skin does not remove a significant fraction of the small layer of chemical adhering to the skin and additional contacts with the chemical do not add a significant fraction to the layer). Exceptions to this assumption may be considered for chemicals with high volatility and/ or with very high rates of absorption into the skin.

Solids: To estimate the potential worker exposure to the chemical of interest in a solid laundry cleaning product for this activity, use the following equation:

n formulatio _ chem dermal F mg/ day 3,100 to p u EXP × = [ 4 17]

Where: EXPdermal = Potential dermal exposure to the chemical of interest per day ( mg chemical of interest/ day) Fchem_ formulation = Weight fraction of the chemical of interest in the laundry product ( Default for detergent formulations, see Table 3 1; Default for all others = 1 kg chemical of interest/ kg of formulation)( 11)

4.3.4 Exposure to Vaporized Chemicals During Operations ( Exposure C)

The quantity of volatile chemicals released to water versus released to air is unknown and may be dependent on several factors such as wash water temperature, agitation, washer venting, and the vapor pressure of the chemical of interest. Fragrances may be released to air at a higher fraction than other volatile components in laundry cleaning products. Fragrances are generally designed for the consumer or worker to help mask less pleasant chemical odors. They are more likely to remain on clothing after the washing process. However, they are generally not designed to stay on the textile after drying, and will volatilize during the drying cycle ( 21). While most of the evaporated volatile chemical of interest from the washing and drying processes will be vented to the atmosphere, the chemical may enter in the workers' breathing zone when workers open the washer or dryer, transfer the laundered items, or steam or press the item.

For non volatile components ( vapor pressure < 0.001 torr standard CEB estimate ( 24)) inhalation exposure is negligible. Assume as a conservative estimate for volatile chemicals, assume ten percent ( Fbreathing_ zone) of Release 4 ( Elocalwashing) volatilizes in the DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 4 26 workers' breathing zone. Based on the amount of the chemical likely discharged to POTW or vented to air during the washing process, this estimate is conservative and may be adjusted based on engineering judgment. The EPA/ OPPT Mass Balance Model can be used to calculate this worker inhalation exposure. Note the model precludes the concentration of the chemical of interest in air from exceeding the saturation level of the chemical in air. Table 4 13 lists the model inputs and default values. The model and all current CEB defaults have been programmed into ChemSTEER, and the software should be used to calculate inhalation exposure from this activity. Appendix C lists the equations the model uses to estimate inhalation exposure. Appendix D provides a detailed description of input variables, along with the corresponding CEB default values for the model.

Assuming a fraction of the Release 4 volatilizes in the workers' breathing zone, Equation 4 18 should first be used to estimate the average vapor generation rate. Note that while Release 4 and vapor generation occur over 11 hours/ day, the individual worker exposure would only occur over the CEB default of 8 hours/ day.

3.6 TIME F Elocal Q urs working_ ho zone breathing_ washing ration vapor_ gene × × = [ 4 18]

Where: Qvapor_ generation = Average vapor generation rate ( g of chemical of interest/ sec) Elocalwashing = Daily release of chemical of interest to POTW or air from washing operation ( kg chemical of interest/ site day) Fbreathing_ zone = Fraction of the chemical of interest volatizing in the workers' breathing zone ( kg of chemical of interest/ kg released during washing operation; Default = 0.1) TIMEworking_ hours = Hours of operation per day ( hr/ site day; See Table 4 7; Default = 11 hr/ site day)( 4) Note: The factor 3.6 in Equation 4 18 accounts for unit conversions. DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 4 27 Table 4 13 EPA/ OPPT Mass Balance Model Parameter Default Values During Operations Input Parameter Default Values Inhalation Rate Default = 1.25 m3/ hr ( 26)

Exposure Days CEB maximum default = 250 days/ yr ( 17)

Vapor Generation Rate Calculated in Equation 4 18 Exposure Duration CEB default = 8 hr/ day Mixing Factor Use CEB defaults ( Appendix C)

Molecular Weight Specific chemical parameter Number of Sites Calculated in Section 4.1.3, Equation 4 3 Ventilation Rate Use CEB defaults ( Appendix C)

Vapor Pressure Specific chemical parameter Vapor Pressure Correction Factor Standard CEB default = 1 Note: The model also assumes standard temperature and pressure along with ideal gas interactions.

Assume the same 8 16 workers per site exposed during the loading of laundry cleaning products into the washer are exposed to the chemical of interest during this activity, if site specific information is not available. Dermal exposure is not estimated for this activity, because any exposure is insignificant compared to the dermal exposure from loading the chemical of interest into the washer. DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 5 1 5.0 SUMMARY OF EQUATIONS AND SAMPLE CALCULATIONS Section 5.1 presents a summary of all the equations introduced in Section 4 of this document. Section 5.2 shows how all of these equations are related and provides sample calculations, while Section 5.3 provides additional examples of estimating the throughput of the chemical of interest using the methodology presented in Figure 4 1.

5.1 Summary of Release and Exposure Estimation Equations Table 5 1 summarizes the equations introduced in Section 4 of this document. These equations may be used in evaluating releases of and exposures to components of detergent chemicals used in water based washing operations at industrial and institutional laundries. A description of each equation is also presented in the table and supporting nomenclature is provided after the table.

Table 5 1 Summary of Release and Exposures Calculation General Facility Estimates Daily Use Rate of Formulation per Facility:

ys working_ da r facility_ y ay facility_ d TIME Q Q = [ 4 1]

Daily Use Rate of Chemical of Interest per Facility:

n formulatio _ chem day _ facility day _ chem F Q Q × = [ 4 2]

Days of Operation per Year: TIMEworking_ days = 261 days/ year ( Default from Table 4 1)

Number of Sites:

ys working_ da chem_ day chem_ yr sites TIME Q Q N × = [ 4 3]

Annual Number of Containers per Facility:

n formulatio container yr _ facility container RHO V Q N × = [ 4 4] DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 5 2 Table 5 1( Continued)

Release Calculations Source Media of Release Calculations Release 1 Fugitive Air Release During Transfer Air Non volatile chemicals ( VP < 0.01):

Elocalair_ transfers = negligible Volatile chemicals ( VP > 0.01):

Calculate Elocalair_ transfers using the EPA/ OPPT Penetration Model in ChemSTEER. In the absence of site specific information, use standard CEB defaults for all parameters ( Table 4 6), except the number of hours of operation per working day ( Default = 11 hr/ site day; see Table 4 7).

Release 2 Container Residue POTW Estimate if number of containers is fewer than days of operation ( kg/ siteday

day site container residue container_ lation chem_ formu n formulatio container sp residue_ di container_

1 F F RHO V Elocal   × × × × =

[ 4 5]

Estimate if number of containers is greater than days of operation ( kg/ siteday

residue _ container day _ chem disp _ residue _ container F Q Elocal × = [ 4 6]

Release 3 Fugitive Air Release During Container Cleaning Air Non volatile chemicals ( VP < 0.01):

Elocalair_ cleaning = negligible Volatile chemicals ( VP > 0.01):

Calculate Elocalair_ cleaning using the EPA/ OPPT Penetration Model in ChemSTEER. In the absence of site specific information, use standard CEB defaults for all parameters ( Table 4 8). DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 5 3 Table 5 1( Continued)

Release Calculations Source Media of Release Calculations Release 4 Release from Water Washing Process Non volatiles: POTW Volatiles: POTW or Air Non volatile chemicals ( VP < 0.01):

) F 1 ( Q Elocal residue _ container day _ chem washing   × = [ 4 7]

Volatile chemicals ( VP > 0.01):

ers air_ transf ng air_ cleani residue container_ chem_ day washing Elocal Elocal ) F ( 1 Q Elocal       × = [ 4 8]

Mass Balance:

days _ working sites washing cleaning _ air residue _ container transfers _ air yr _ chem TIME N ) Elocal Elocal F Elocal ( Q × × + + + = [ 4 9]

Occupational Exposure Number of Exposed Workers per Site ( Table 4 8 ( 3,22)):

All Laundries ( Default): 8  16 workers/ site Industrial Laundries: 6  12 workers/ site Institutional Laundries: 9  18 workers/ site Note: An additional 1 worker/ site may be exposed during on or off site transport container cleaning ( Exposure B) DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 5 4 Table 5 1( Continued)

Occupational Exposure Exposure from Loading Laundry Cleaning Products into Washer ( Exposure A)

Default Number of Exposed Workers: 8 16 workers/ site Inhalation:

Liquids:

If non volatile ( VP < 0.001 torr): Negligible EXP inhalation =

If volatile ( VP > 0.001 torr): Calculate EXPinhalation using the EPA/ OPPT Mass Balance Model in ChemSTEER, using the vapor generation rate from Release 1. See Table 4 11 for model inputs and defaults.

Solids:

If Qfacility_ day > 54 kg of formulation/ site day:

lation chem_ formu exposure breathing e particulat inhalation F TIME RATE C EXP × × × = [ 4 10]

If Qfacility_ day < 54 kg of formulation/ site day:

exposure lation chem_ formu ay facility_ d inhalation F F Q EXP × × = [ 4 11]

Dermal:

Liquids:

n formulatio _ chem incident exp_ surface skin _ liquid dermal F N AREA Q EXP × × × = [ 4 12]

Solids:

n formulatio _ chem dermal F day / mg 100 , 3 to up EXP × = [ 4 13] DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 5 5 Table 5 1( Continued)

Occupational Exposure Exposure During Transport Container Cleaning ( Exposure B)

Default Number of Exposed Workers: 1 workers/ site Inhalation:

Liquids:

If non volatile ( VP < 0.001 torr): Negligible EXP inhalation =

If volatile ( VP > 0.001 torr): Calculate EXPinhalation using the EPA/ OPPT Mass Balance Model in ChemSTEER, using the vapor generation rate from Release 3. See Table 4 12 for model inputs and defaults.

Solids:

If Qfacility_ day > 54 kg of formulation/ site day:

lation chem_ formu exposure breathing e particulat inhalation F TIME RATE C EXP × × × = [ 4 14]

If Qfacility_ day < 54 kg of formulation/ site day:

exposure lation chem_ formu ay facility_ d inhalation F F Q EXP × × = [ 4 15]

Dermal:

Liquids:

n formulatio _ chem incident exp_ surface skin _ liquid dermal F N AREA Q EXP × × × = [ 4 16]

Solids:

n formulatio _ chem dermal F day / mg 100 , 3 to up EXP × = [ 4 17] DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 5 6 Table 5 1( Continued)

Occupational Exposure Inhalation Exposure to Vaporized Chemicals During Operations ( Exposure C)

Default Number of Exposed Workers: 8 16 workers/ site Note: These are the same workers exposed during the loading of laundry cleaning products into washers ( Exposure A).

Inhalation:

If non volatile ( VP < 0.001 torr): Negligible EXP inhalation =

If volatile ( VP > 0.001 torr): Calculate EXPinhalation using the EPA/ OPPT Mass Balance Model in ChemSTEER, using the vapor generation rate calculated from Equation 4 18. In the absence of site specific information, use standard CEB defaults for all other parameters ( Table 4 13).

3.6 TIME F Elocal Q urs working_ ho zone breathing_ washing ration vapor_ gene × × = [ 4 18] DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 5 7 Table 5 2 Default Value Declaration and Documentation Variable Variable Description Default Value Data Source AREAsurface Surface area of contact ( cm2) 840 cm2, 2 hands ( 28)

Cparticulate Concentration of particulate in the workers breathing zone ( mg/ m3) 15mg/ m3; based on OSHA PEL ( 8 hr TWA) for nuisance dusts, not otherwise regulated ( 25)

Fbreathing_ zone Fraction of the chemical of interest volatizing in the workers' breathing zone ( kg of chemical of interest/ kg released during washing operation) 0.1 ( eng. judgment)

Fchem_ formulation Weight fraction of the chemical of interest in the laundry product ( kg of chemical of interest/ kg of formulation) See Table 3 1 for detergent formulations; all others, 1 kg chemical of interest/ kg of formulation ( 11)

Fcontainer_ residue Fraction of chemical remaining in the container as residue ( kg container residue/ kg in container) larger liquid containers = 0.03; smaller liquid containers = 0.006; all powder containers = 0.01 ( 17, 20)

Fexposure Weight fraction of the total solid in the workers breathing zone ( mg particulate/ kg weighed) 0.0477 ( typical) to 0.161 ( worst) mgsite kg of formulation ( 27)

Nexp_ incident Number of exposure incidents per day ( incidents/ day) 1 incident/ day ( CEB assumption)

Qfacility_ yr Annual use rate of laundry product ( kg of formulation/ site yr) See Tables 4 2 and 4 3; Default = 27,000 kg/ site year ( 4)

Qliquid_ skin Quantity of liquid remaining on skin ( mg/ cm2 incident) 2.1 mg/ cm2 incident ( high end) and 0.7 mg/ cm2 incident ( lowend ( 28)

RATEbreathing Typical worker breathing rate ( m3/ hr) 1.25 m3/ hr ( 26)

RHOformulation Density of the formulation ( kg of formulation/ L) 1 kg/ L ( CEB assumption) DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 5 8 Table 5 2( continued)

Variable Variable Description Default Value Data Source TIMEexposure Duration of exposure ( hr/ day) 8 hr/ day, the default value for Cparticulate is an 8 hr TWA TIMEworking_ days Operating days ( days/ yr) See Table 4 1; Default = 261 days/ yr ( 4)

TIMEworking_ hours Hours of operation per day ( hr/ site day) See Table 4 6; Default = 11 hr/ site day ( 4)

Vcontainer Volume of laundry product container ( L/ container) 208 L/ container ( for 55 gallon drum) ( CEB assumption)

5.2 Chemical Release and Exposure Examples This section presents a hypothetical operating scenario and displays how the equations in Section 4 might be used to estimate releases of and exposures to laundry cleaning products at industrial and institutional laundries. The default values used in these calculations should be used only in the absence of site specific information. The following chemical information is assumed:

  The chemical of interest is a surfactant;   The chemical of interest is non volatile ( VP < 0.001 torr); and   The chemical of interest production volume ( Qchem_ yr) is 250,000 kg/ year.

Daily Throughput of Formulation per Facility:

Following the decision logic diagram ( Figure 4 1):

  It is unknown if the chemical is received at laundries in liquid or powder form; therefore, assume the chemical is received as a solid powder. Use data in Table 4 2.

  It is unknown if the chemical is used at industrial or institutional laundries; therefore, median values from the " All" column in Table 4 2 should be used.

  It is unknown if the chemical is received at the laundry as part of a detergent formulation; since it is a surfactant, it is assumed that the additive is a component of a detergent formulation and the median annual use rate for detergent at all laundries from Table 4 2 should be used ( 27,000 kg/ yr). DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 5 9   The concentration of the chemical in the formulation is unknown; therefore, the value for surfactant from Table 3 1 should be used. Use the higher concentration ( 36%).

day n/ site formulatio of kg 103 Q days/ yr 261 yr  kg/ site 27,000 TIME Q Q ay facility_ d ys working_ da r facility_ y ay facility_ d   = = =

Daily Throughput of Chemical of Interest per Facility:

day  ite interest/ s of chemical of kg 1 . 37 Q 36 . 0 day  n/ site formulatio of kg 103 F Q Q day _ chem n formulatio _ chem day _ facility day _ chem = × = × =

Number of Sites:

sites 26 N days/ yr 261 day kg/ site 1 37 kg/ yr 250,000 TIME Q Q N sites ys working_ da chem_ day chem_ yr sites = ×   = × = .

Annual Number of Containers per Facility:

yr / site containers 130 N kg/ L 1 r L/ containe 208 yr kg/ site 27,000 RHO V Q N container n formulatio container r facility_ y container   = ×   = × =

Transfer Operation Losses to Air from Loading Laundry Cleaning Products in Washers ( Release 1):

Elocalair_ transfers = Negligible ( VP < 0.01 torr)

Container Residue ( Release 2):

The number of containers is less than the days of operation; therefore, use Equation 4 5. Fcontainer_ residue = 0.01 because the chemical is assumed to be received as a solid powder.

days/ yr 130 over day kg/ site 0.75 Elocal 0.01 0.36 kg/ L 1 r L/ containe 208 Elocal F F RHO V Elocal sp residue_ di container_ sp residue_ di container_ residue container_ lation chem_ formu n formulatio container sp residue_ di container_

  = × × × = × × × = DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 5 10 Open Surface Losses to Air During Container Cleaning ( Release 3):

Elocalair_ transfers = Negligible ( VP < 0.01 torr)

Release from Water Washing Process ( Release 4):

Since the chemical is non volatile ( VP < 0.01 torr) use Equation 4 7.

day kg/ site 36.7 Elocal 0.01) ( 1 day kg/ site 37.1 ) F ( 1 Q Elocal harge water_ disc residue container_ chem_ day harge water_ disc   =   ×   =   × =

Mass Balance:

kg/ yr 250,000 Q days/ yr 261 sites 26 day) kg/ site 0 day kg/ site 36.7 0.01 day kg/ site 37.1 day kg/ site ( 0 Q Time N ) Elocal Elocal F Q ( Elocal Q chem_ yr chem_ yr ys working_ da sites washing ng air_ cleani residue container_ chem_ day ers air_ transf chem_ yr = × ×   +   + ×   +   = × × + + × + =

Total Number of Exposed Workers:

Nworkers = 8  16 workers/ site ( see Table 4 8)

Note: An additional 1 worker/ site may be exposed during on or off site transport container cleaning ( Exposure B)

Exposure from Loading Laundry Cleaning Products into Washer ( Exposure A):

Chemical of interest is assumed to be a component of a powdered detergent formulation ( See Figure 4 1).

Inhalation:

Qfacility_ day > 54 kg of formulation/ site day:

mg/ day 54 EXP 0.36 hr/ day 8 / hr m 1.25 mg/ m 15 EXP F TIME RATE C EXP inhalation 3 3 inhalation lation chem_ formu exposure breathing e particulat inhalation = × × × = × × × = DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 5 11 Dermal:

mg/ day 1,100 to up EXP 0.36 mg/ day 3,100 to up F mg/ day 3,100 to up EXP dermal lation chem_ formu dermal = × = × =

Exposure During Transport Container Cleaning ( Exposure B):

Inhalation:

Qfacility_ day > 54 kg of formulation/ site day:

mg/ day 54 EXP 0.36 hr/ day 8 / hr m 1.25 mg/ m 15 EXP F TIME RATE C EXP inhalation 3 3 inhalation lation chem_ formu exposure breathing e particulat inhalation = × × × = × × × =

Dermal:

mg/ day 1,100 to up EXP 0.36 mg/ day 3,100 to up F mg/ day 3,100 to up EXP dermal lation chem_ formu dermal = × = × =

Exposure to Vaporized Chemicals During Steaming and Drying ( Exposure C)

EXPinhalation = Negligible ( VP < 0.001 torr)

5.3 Additional Examples of Determining the Throughput of the Chemical of Interest For additional guidance on determining the daily throughput ( Qchem_ day), three additional examples are provided below.

Example 1:

Company A manufactures 15,000 lbs of a chemical. The use description in the submission states " additive used in laundry detergents." No other information is provided, and the submitter could not be contacted. Following the decision logic diagram:

  It is unknown if the chemical is received at laundries in liquid or powder form; therefore, assume the chemical is received as a solid powder. Use data in Table 4 2.

  It is unknown if the chemical is used at industrial or institutional laundries; use the " All" column in Table 4 2. DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 5 12   It is unknown if the chemical is received at the laundry as part of a detergent formulation and the chemical is an " other additive"; therefore, it is assumed that the additive is a component of a detergent formulation. Use the median annual use rate for detergent at all laundries from Table 4 2. ( 27,000 kg/ yr)

  The concentration of the chemical in the formulation is unknown; therefore, the value for " other" from Table 1 should be used. Use the higher concentration ( 4%).

Throughput Calculations:

day  ite interest/ s of chemical of kg 12 . 4 Q 04 . 0 day  n/ site formulatio of kg 103 F Q Q day n/ site formulatio of kg 103 days/ yr 261 yr kg/ site 000 , 27 TIME Q Q day _ chem n formulatio _ chem day _ facility day _ chem yr _ facility day _ facility days _ working = × = × =   =   = =

Example 2:

Company B manufactures a builder specially designed to assist in the removal of oil and grease from shop rags ( industrial laundries). The submission states that the builder is formulated into a liquid at 25% concentration. Following the decision logic diagram:

  Since the submission states that chemical is sent to laundries in liquid form. Use the data in Table 4 3.

  The chemical is specially designed to be used in industrial laundries; therefore, use values from the " Industrial" column in Table 4 3.

  It is unknown if the chemical is received at the laundry as part of a detergent formulation. Since the chemical is a " builder"; it is assumed that it is a component of a detergent formulation. Use the median annual use rate for detergent at industrial laundries from Table 4 3 ( 7,900 kg/ yr).

  The concentration of the chemical in the formulation is 25%, as stated in the submission. DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 5 13 Throughput Calculations:

day  ite interest/ s of chemical of kg 83 . 7 Q 25 . 0 day  n/ site formulatio of kg 3 . 31 F Q Q day n/ site formulatio of kg 3 . 31 days/ yr 252 yr kg/ site 900 , 7 TIME Q Q day _ chem n formulatio _ chem day _ facility day _ chem days _ working yr _ facility day _ facility = × = × =   =   = =

Example 3:

Company C manufactures a bleach chemical. The submission states that the chemical is shipped to the institutional laundries in liquid form, but does not include the concentration of the chemical in the bleach. Following the decision logic diagram:

  The submission states that the chemical is sent to the laundry in liquid form. Use the data in Table 4 3.

  The submission states that the chemical is used at institutional laundries; therefore, use values from the " Institutional" column in Table 4 3.

  It is unknown if the chemical is received at the laundry as part of a detergent formulation. Since the chemical is a bleach, it is assumed that it is used as a separate additive. Use the median annual use rate for bleach at institutional laundries from Table 4 3 ( 14,000 kg/ yr).

  The concentration of the chemical in the bleach is unknown; therefore, assume 100% concentration.

Throughput Calculations:

day  ite interest/ s of chemical of kg 5 . 50 Q 1 day  n/ site formulatio of kg 5 . 50 F Q Q day n/ site formulatio of kg 5 . 50 days/ yr 277 yr kg/ site 000 , 14 TIME Q Q day _ chem n formulatio _ chem day _ facility day _ chem days _ working yr _ facility day _ facility = × = × =   =   = = DRAFT GENERIC SCENARIO CHEMICALS USED IN WATER BASED WASHING OPERATIONS AT INDUSTRIAL AND INSTITUTIONAL LAUNDRIES August 2004 6 1 6.0 DATA GAPS/ UNCERTAINTIES AND FUTURE WORK/ CONTROL TECHNOLOGIES 6.1 Data Gaps   The percentage of facilities using automatic versus manual detergent chemical loading was not found. As a conservative estimate, all facilities were assumed to use manual chemical loading into the washing machine.

  The fraction of detergent chemical remaining on the textile item after washing was not found. These data would enhance the estimation of Release 4 and Exposure C.

  The method for calculating the number of exposed workers is partially based on site visit experience of ERG staff members. Industry worker breakdowns could not be found.