Textile Process Wastewater Permits:
An Update And Strategies
Note:-(Michael L. Leonas is affiliated with
M. R. Chasman & Assoc.. Athens. GA.)
Introduction
Over the past twenty years in-
creased attention has been directed
toward the environment. Efforts to
clean up the environment and keep it
clean have been made by government
agencies at national, state and local
levels by establishing guidances and
regulations. Industries and individuals
are also more aware of those condi-
tions that negatively impact the envi-
ronment. One of the primary concerns
is water quality. Because of the high
quantity of water and the number of
metals used in the processing of tex-
tiles, the textile industry will be signifi-
cantly impacted by the recent regula-
tions.
1990 EPA issued a technical guid-
ance document for use in water quality
control. These guidelines more than
tripled the number of toxic pollutants
of interest and include chemical con-
stituents commonly found in textile
processing. To successfully comply
with these regulations, those in the
textile industry must be knowledgeable
of permitting strategies and participate
in the process before the issuance of
the permit.
Historical perspective
The Clean Water Act (CWA) was
passed as public law in 1972 and the
National Pollutant Discharge Elimina-
tion System (NPDES) permit system
was established to ensure that indus-
tries and Publicly Owned Treatment
works (POTW) were monitoring and
complying with the stipulations of this
legislation. Since 1972 the public has
been requesting federal and state reg-
ulatory agencies to increase the scope
of environmental protection and con-
trol to provide a more pristine environ-
ment.
In response to public demand, the
Water Quality Act (WQA) was autho-
rized by Congress in 1987. The pur-
pose of the water quality act focused
26
By Karen K. Leonas, Ph.D, Michael L.
Leonas, P.E.* The Univ. of Georgia,
Athens, GA
on the control of substances toxic to
aquatic and human life. This differed
drastically from the CWA which was
primarily concerned with maintaining a
minimum dissolved oxygen level in re-
ceiving waters. The WQA was exten-
sive and the United States Environ-
mental Protection Agency (EPA) was
charged with implementing guidelines
for state and local regulatory agencies
to follow.
EPA, pursuant to its authority under
Section 304(a) of the Clean Water Act,
has published water quality criteria to
help develop permit conditions for toxic
pollutants. These criteria are intended
for national application but may be re-
placed, when appropriate by site spe-
cific criteria.
The guidance document, EPA Quali-
ty Criteria for Water issued in 1987 by
EPA, significantly altered the permit
writing process.1 The NPDES permitting
system originally introduced in 1972
still remains as the method for control
of discharges. The 1987 document
identified 129 chemical constituents to
be monitored where previously there
had been only approximately 30. In ad-
dition, thus document specified detec-
tion limits, test methods to be used
and utilized stream models for the de-
termination of discharge limits.
All states were to incorporate the
criteria into their water quality rules by
March 1990. This forced many states
to adopt the criteria without investiga-
tion or adjustment of the natural crite-
ria.2 One primary area of concern for
the textile industry is the increased
number of metals now identified by the
new criteria.
Across all industries, the cost to
comply with treatment for the metals is
overwhelming and has been estimated
at 90 to 105 billion dollars. It has been
estimated that 6000 to 8000 U.S. dis-
chargers will receive stringent metals
limitations if historical application of
EPA’s metal criteria continues. In addi-
tion, approximately 30 to 50% of the
dischargers will need to install alternate
processes (i.e. reverse osmosis and ton
exchange) to meet the new limitations.”
Impact on the Industry
Factors that make the textile indus-
try extremely susceptible to significant
changes include the high quantity of
discharge, metals used in textile pro-
cessing and metals found inherently in
the natural fibers. A number of metals
now identified the 129 chemical con-
stituents are used in textile processing,
therefore textile facilities will be particu-
larly impacted. Whether the mill oper-
ates its own treatment system or dis-
charges to a POTW facility, they will be
held accountable for their discharges
as everyone struggles to comply with
the new regulations.
Prior to 1990 NPDES permits con-
trolled items such as pH. temperature,
sulfides, chromium, etc. for the textile
industries. With the implementation of
the WQA via the 1987 criteria, textile
facilities will particularly be Impacted
due to the high quantity of discharge,
the metals used in typical textile
processes and metals inherent in nat-
ural fibers.
Quantity of Discharge
In North Carolina the textile industry
is the largest water user and waste-
water producer.4 The historical data of
water usage and discharge has been
presented and discussed by Smith.’ A
large mill could produce over two mil-
lion gallons of wastewater per day,
which is discharged into treatment
systems then to the environment.
Use of Metals
Metals are used in a variety of pro-
cessing techniques throughout the
textile industry, Including oxidizers for
vat and sulfur dyes, aftertreatment of
direct dyes, metal catalyst used for
American Dyestuff Reporter c March 1994
curing resins, finishes (i.e., flame retar- Table I: Average metal content of selected dyes (ppm).
dant, soil release, and water repellent),
dye stripping agents, and various Dye Class
classes of dyes.5 Metal Acid Basic Direct
Of the six common dye classes, Arsenic <1 <1 <1
acid, basic, direct, disperse, fiber re- Cadmium <1 <1 <1
active and vat all contain metals in- Chromium 9 2.5 3.0
cluding chromium, arsenic, cadmium, Cobalt 3.2 <1 <1
mercury, copper, lead and zinc, all of Copper 79 33 35
Lead 37 6 28
which are now targeted by the new <1 0.5 0.5
Mercury
criteria. Prior to 1990 these chemicals Zinc <13 32 8 3
may have been subcategory specific,
however today they are equally applied
to all subcategories. Table I lists vari-
ous dye categories which contain met-
als that are controlled via the new wa- plicants to modify their approach and
ter quality criteria.6 strategies to the application process. It
is necessary to become familiar with
Metals Inherent in natura/ fibers the permitting process and the tech-
In some cases the greige goods niques being used by the permitting
also contain metals; this is from metals agency in response to the Water Quali-
inherent in the fibers (Table II).4 Of the ty Act and the criteria created by the
36 elements found in cotton, half are Act. In May 1992, EPA issued the doc-
targeted by the new water quality cri- ument “Interim Guidance on Interpre-
teria. Although it is not a metal, chlo- tation and Implementation of Aquatic
rine was also detected and is con- Life Criteria for Metals”. In this docu-
trolled by the NPDES permits. ment EPA attempts to clarify Its posi-
Given the potential for substantial tion on implementation of water quality
impacts to textile facilities from the pa- criteria for metals.2 Even with this guid-
rameters controlled in the NPDES per- ance, many facilities can still be affect-
mits, it is important for permit appli- /ed by the complicated NPDES permit
Fiber
Disperse Reactive Vat
<1 1.4 <1
<1 <1 <1
3.0 24 83
<1 <1 <1
45 71 110
37 52 6
<1 0.5 1.0
4 4
conditions.
Given the complexities of determin-
ing the permit limits and the potential
financial and operatlonal impacts on
the facility, it is necessary to give more
time and thought to the application
process. This article provides informa-
tion which may be helpful as industries
revise their current permitting applica-
tion processes.
Permitting processes
Initially, a review of the Water Quali-
ty Standards that pertain to your in-
dustrial subcategory as defined In the
Code of Federal Regulations (CFR)
(Table III) is necessary.‘ Also, an un-
derstanding of the techniques used by
the regulatory agency to determine
limits, is helpful. One technique which
has seen increased usage is stream
modeling.
Use of Strem modeling
The evolution of mathematical mod-
eling techniques has resulted in signifi-
cant advancements in water quality-
based permitting. Statistical modeling
has eliminated the need to make as-
sumptions regarding the likelihood of
remote events occurring simultaneous-
y. Permit limitations established using
mathematical modeling techniques do
not include multiple and duplicate con-
servative assumptions. These models
include the necessary safety factors
built into the permit process such as a
facility to perform at a fraction of its
permit limit. They produce both cost-
effective and realistic permit limitations
while adequately protecting the envi-
ronment.
The advantages to the permittee of
such a model are the more complex
modeling procedures often produce
effluent limitations higher than steady
state procedures. Applicants may
avoid the higher costs of facilities de-
signed to meet steady state-model.8
Applicants should review the water-
quality model used by the permit writer
to derive permit limitations. Considera-
American Dyestuff Reporter c March 1994
 tion should be given to whether the
model assumptions reflect expected
conditions in the receiving stream.
The use of probablistic modeling in
its new water quality criteria has been
promoted by EPA. However, appli-
cants must ensure that these proce-
dures are allowed in state rules and
used in calculating the permit limita-
tions.
Designated use also influences the
determination of permit limits. Desig-
nated use classifications include drink-
ing water, wild and scenic, recreation,
and fish reserves, which have varying
water quality criteria.

Characterization of discharge water

Identifying the sources in the plant
that produce discharge waters and de-
termining the approximate quantity
discharged from each source is criti-
cal. Identifying those chemicals that
are used in various processes is criti-
cal in evaluating the discharge.

Effluent monitoring
Data collected up to 18 months pri-
or to the permit application can be
submitted with the application. It is
typical to submit only one data point
and then the permit is prepared based
on that information. However, with the
more stringent limitations it is advanta-
geous to provide a mean value from
which the permit limit is established.
The location of sample collection
should be reviewed to ensure that it
reflects what is being discharged after
all treatment processes. Sometimes it
may also be appropriate to collect the
sample downstream of the mixing
zone but within the established regula-
tory guidelines.
Sample analysis
It is critical to use approved analyti-
cal methods and laboratory (some-
times referred to as a contract lab) as
specified by the regulatory agency. In
some cases the test methods do not
accurately simulate site conditions,
therefore, it is advantageous to pro-
vide additional data to correct skew-
ness inherent in the methods by the
permitting agency.
Review results
Test results should be reviewed for
accuracy prior to submission to the
permitting agency. Evaluation to deter-
mine if additional testing is necessary
can be completed, and it may be ap-
propriate to apply for a site specific
discharge request.
Site Specific standards
Where one or more assumptions
underlying the standard are not applic-
able to the receiving stream, applica-
tion for site specific standards may be
appropriate. EPA has issued guidance
on how to derive site-specific stan-
dards.g Using one of the three method-
ologies approved in that guidance
should be acceptable to the regulatory
agency.
In developing site-specific stan-
dards, it is first necessary to review
the receiving stream’s designated use,
which defines the receiving stream’s
actual and potential beneficial uses.
Water-quality criteria and standards
are intended to protect the uses identi-
fied. Applicants may find that the
state’s designated use is outdated or
otherwise inadequate. The applicant
should then consider providing addi-
tional information.
This information could include iden-
tification of current uses, causes of
use impairment, and potential uses
given the chemical, physical and bio-
logical characteristics of the stream.
EPA then recommends the important
chemical, physical, and biologlcal fac-
tors that should be considered when
establishing site-speclfic standards.
The Water Quality Standards Hand-
book identifies three alternate ap-
proaches for developing site-specific
water-quality standards. The appropri-
ate approach will depend on whether it
is the biological, chemical, or physical
assumptions of the state-wide stan-
dards that should not apply to the re-
ceiving stream.
An example presented by Hall,
Raider and Grafton is a situation where
elevated hardness or TOC are present,
the pH and temperature vary signifi-
cantly from the EPA laboratory condi-
tions used to develop the water-quality
criteria.g In this situation, the receiving
and effluent stream may be allowed as
use as the test water.
Another concern is whether the test
species could reasonably inhabit the
receiving stream. Temperature, pH, or
other chemical and physical limitations
of the receiving stream may be such
that the test species is not likely to
populate the stream. In this case, the
applicant should use a substitute
species that probably populate the re-

30 American Dyestuff Reporter c March 1994

 ceiving stream.
For each of the three protocols,
EPA has provided guidelines to identify
when each is appropriate and the im-
plementation of that protocol. Each
approach requires the permittee to as-
semble sitespecific data and to recal-
culate a water-quality standard. Once
the standard is recalculated and ap-
proved, the regulatory agency must
apply the permitting rules to translate
the water-quality standard into effluent
limitations.
The site specific discharge request
must include data sufficient to calcu-
late a reasonable alternate limit and in-
formation showing the requested limit
will result in no degradation of the wa-
ter quality. This effort should be coor-
dinated with the permitting agency pri-
or to the submission to prevent delays
and misunderstandings.
The implementation of the water
quality criteria has been difficult for
various reasons. Some of those in-
clude inadequacies in test methods,
calculation of limits, inadequacy of
technology to monitor and control. The
methodologies commonly used by per-
-nit writers drastically overstate the
bioavailable fraction of heavy metals in
effluent and receiving waters. As a re-
32
Table III: Industrial Subcategory as in
40CFR 410 Textile Mills Point Source
Category
a. Wool scouring
b. Wool finishing
c. Low water use
processing
d. Woven fabric finishing
e. Knit fabric finishing
f. Carpet finishing
g, Stock and yarn finishing
i. Felted fabric processing
suit, the permit restricts the discharge
of metals that could pose no threat to
he environment. The permit limitations
are intended to regulate only bioavail-
able metals. However, many state per-
mitting authorities and EPA regions do
not reflect this.
Due to increased public awareness
of environmental issues and public de-
mand for a cleaner environment, future
environmental regulations are in-
evitable. One example would be issues
pertaining to the reauthorization of the
clean Water Act.g.1O There continues to
be advocates in the U.S. Senate and
U.S. House of Representatives as
demonstrated by the Senate Bill enti-
tled “Water Pollution Prevention and
Control Act of 1993” introduced in
June, 1993.11 In November 1992, the
EPA proposed the National Toxics
Rule that would implement water quali-
ty criteria for states which have not
adopted such criteria.1 This could re-
sult in the imposition of further limita-
tions and conditions on NPDES Per-
mits. Recently, legislation was intro-
duced, H.R. 2199, that proposes a tax
ranging from 6 cents to $63 per pound
on discharges of 307 different chemi-
cals.
The cost is based on the toxicity of
the chemical. Industrial and commer-
cial consumers would pay a tax of
1.95 cents for each 1000 gallons of
water used. 12
All taxes collected would be con-
tributed to a clean water trust fund
Major areas of concern include water
pollution prevention, water quality sci
ence, toxic water pollutant control, ac-
curate assessment of compliance and
water pollution control funding.
EPA continues to set water en-
forcement records in convictions, ad-
ministrative orders, and civil and crimi-
nal penalties. This includes company
officials serving prison sentences and
monetary assessments in the millions
of dollars. The enforcement office has
stepped up its efforts to crack down
on polluters earlier in the enforcemenl
cycle and are developing a criminal en-
forcement program that will include a
larger staff of criminal investigators
who will be better trained in investiga-
ive techniques.
According to LaJuana Wilcher of
EPA “the states tell us that 75% of
heir waters meet water quality stan-
dards. That is not enough. This year
we’re going after the remaining 25%
using all of our tools.“’
Summary
EPA has recently recognized prob-
ems with the implementation of the
toxic criteria. Many states have not
adopted the toxic criteria which EPA
imposed. Some states have adopted
toxic criteria but are not fully imple-
nenting them. This has created an un-
level playing field in which industries
literally face closure and relocation to
other states and in which municipali-
ies have been issued NPDES permits
with limits that are unattainable and
innecessary for toxicity control.
The EPA-imposed toxic criteria for
metals are an ineffective and detrimen-
al tool for eliminating toxicity. There
are three fundamental problems with
these criteria:
American Dyestuff Reporler c March 1994

1. Many of the criteria are below
laboratory detection limits and con-
sequently states cannot determine
if rivers are in compliance with stan-
dards. Also, NPDES permit effluent
limitations resulting from the stan-
dards are below detection limits
and are unenforceable.
2. Achievement of the standards
and resulting effluent limitations are
unattainable in many instances. The
metals in municipal effluent come
from plumbing (primarily copper,
zinc and lead). Technology is not
available to reduce the concentra-
tions to meet the effluent limits re-
sulting from the water quality stan-
dards
3. The criteria are over-protec-
tive. There are many streams in the
Southeast which have natural metal
concentrations (especially zinc)
which far exceed EPA’s criteria, yet
always support a healthy and bal
a n c e d f i s h p o p u l a t i o n . Also
streams below municipalities and
industries with calculated exe
ceedances of toxic criteria also
support fish life. Finally, many of the
supposedly toxic effluents routinely
pass acute and chronic bioassays.
Fortunately, the Interim Guidance
on lntrepretation and lmplementatior
of Aquatic Life Criteria for Metals is
providing some assistance to all par
ties in the permitting process. In fact
the interim guidance recognized that
current procedures may result in over
estimating toxicity.
One solution recommended by EPA
is the water-effect ratio. This involve!
measuring a pollutant’s water-effect
ratio into the receiving water coverer
by the water quality standard. As a re
sult of the complexity of metal chem-
istry, there is not one chemical analyti-
cal method that can accurately deter-
mine the metals that are bioavailable
and toxic. Therefore, EPA’s guidance
allows an adjustment in the numeric
metals criteria. The water-effect ratio
compares the toxicity of a pollutant in
actual site water to its toxicity in labo-
ratory water for two or more aquatic
species. Since the metal’s toxicity in
laboratory water is the basis of a
states numeric criteria, the water-ef-
fect ratio could be used to derive a
site-specific criteria.
In the 1987 Clean Water Amend-
ments, Congress anticipated that nu-
meric criteria will not be applicable for
all streams. Paragraph 303(C)(2)(B)
provides that States shall adopt nu-
meric criteria for pollutants “the dis-
charge or presence of which in the af-
fected waters could reasonably be ex-
pected to interfere with those desig-
nated uses adopted the state.”
To date many state permitting
agencies have not addressed this con-
gressional directive in its water quality
standards. c c c
References
(1) Nichols, A.B. “EPA Firm but Flexible on
Toxics”. Water Environment & Technology,
Vol. 5, No. 1, January 1993, 60.
(2) Hall, J.C. and Raider, R.L. “A Reflection
on Metals Criteria” Water Environment &
Technology, Vol. 5. No. 6. June 1993, 63.
(3) Nichols, A.B. “1991: A Banner Year for
Water Enforcement”. Water Environment &
Technology, Vol. 4. No. 3, March 1992, 14.
(4) Smith, C.B. “Reducing Pollution in Warp
Sizing and Desizing”. Textile Chemist & Col-
orist, Vol. 24, No. 6, June 1992. 30.
(5) Smith, C.B. Identification and Reduction
of Pollution Sources in Textile Wet Proces-
sing, Pollution Prevention Program, North
Carolina Department of Environment, Health,
and Natural Resources, 1986.
(6) Smith, B. “Pollutant Source Reduction:
Part II -Chemical Handling”. American Dye-
stuff Reporter, April, 1989, 26.
(7) Title 40, Code of Federal Regulations,
Part 410.
(8) Hall, J.C., Raider, R.L. and Grafton, J.A.
“EPA’s Heavy Metal Criteria”, Water Environ-
ment & Technology, Vol. 4, No. 3, March
1992, 60-63.
(9) Bagwell, S. “Clean Water Act Reauth-
orization Bill Introduced in Senate”. Water
Environment & Technology, Vol. 3. No. 8,
August 1991, 18-20.
(10) Nichols, A.B. “CWA Reauthorization
Schedule”, Water Environment & Technol-
ogy, Vol. 3, No. 8, August 1991, 19.
(11) “Regulatory Update”, Water Environ-
ment & Technology, Vol. 5, No. 8, August
1993, 11.
(12) ‘Polluter Pays” The National Environ-
mental Journal. Vol. 3. No. 5, September/ Oc-
tober 11.
American Dyestuff Reporter c March 1994