United States
Environmental Protection
Agency
Office of Pesticides
and Toxic Substances
&EPA Title III Section 313
Release Reporting
Guidance
EPA 560/4-88-0043
January 1988
Estimating Chemical Releases From
Monojilament Fiber Manufacturing
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Estimating Chemical Releases From
i
Monofilament Filler Manufacturing
Manufacturers of monofilament fibers
may be required to report annually any re-
leases to the environment of certain chemi-
cals regulated under Section 313, Title III, of
the Superfund Amendments and Reautho-
rization Act (SARA) of 1986. If your facility is
classified under SIC codes 20 through 39
(monofilament fiber manufacturers generally
fall under SIC codes 2823 and 2824) and has
10 or more full-time employees, for calendar
year 1987 you must report all environmental
releases of any Section 313-listed chemical or
chemical category manufactured or processed
by your facility in an amount exceeding
75,000 pounds per year or otherwise used in
an amount exceeding 10,000 pounds per
year. For calendar years 1988 and 1989 (and
beyond), the threshold reporting quantity for
manufactured or processed chemicals drops
to 50,000 and 25,000 pounds per year, re-
spectively.
This document has been developed to
assist monofilament fiber manufacturers in
the completion of Part III (Chemical Specific
Information) of the Toxic Chemical Release
Inventory Reporting Form. Included herein is
general information on toxic chemicals used
and process wastes generated, along with
several examples to demonstrate the types of
data needed and various methodologies avail-
able for estimating releases. If your facility
performs other operations in addition to
monofilament fiber manufacturing, you must
also include any releases of toxic chemicals
from these operations.
Step One
Determine if your facility processes or
uses any of the chemicals subject to
reporting under Section 313.
A suggested approach for determination
of the chemicals your facility uses that could
be subject to reporting requirements is to
make a detailed review of the chemicals and
materials you have purchased. If you do not
know the specific ingredients of a chemical
formulation, consult your suppliers for this
information. If they will not provide this in-
formation, you must follow the steps outlined
to handle this eventuality in the instructions
provided with the Toxic Chemical Release
Inventory Reporting Form.
The list presented here includes chemi-
cals typically used in monofilament fiber
manufacture that are subject to reporting
under Section 313. This list does not neces-
sarily include all of the chemicals your facility
uses that are subject to reporting, and it may
include many chemicals that you do not use.
You should also determine whether any of the
listed chemicals are created during process-
ing at your facility.
Polymer constituents: Propylene,
ethylene glycol, terephthalic acid, acrylo-
nitrile, carbon disulfide, methyl acrylate,
p-phenyldiamine, ethylene, vinyl chloride,
vinyl acetate
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Solvents/precipitants: Acetone, tolu-
ene, sodium hydroxide, sulfuric acid,
methyl ethyl ketone, aqueous ZnCl2
Flame retardants: Decabromodiphenyl
oxide, vinyl bromide, hexachloropenta-
diene
Promoters/activators: Hydrazine,
hydroquinone
Pigments: Titanium dioxide
Lubricants: Ammonium salts
Step Two
Determine if your facility surpassed the
threshold quantities established for
reporting of listed chemicals last year.
You must submit a separate Toxic Chemi-
cal Release Inventory Reporting Form for
each listed chemical that is "manufactured,"
"processed," or "otherwise used" at your
facility in excess of the threshold quantities
presented earlier. Manufacture includes
materials produced as byproducts or impu-
rities. Toxic compounds that are incorpo-
rated into your products (for example, a flame
retardant applied to a fiber) would be con-
sidered "processed" because they become
part of the marketed finished product. De-
greasing solvents, cleaning agents, and other
chemicals that do not become part of the
finished product would be considered
"otherwise used."
The amount of a chemical processed or
otherwise used at your facility represents the
amount purchased during the year, adjusted
for beginning and ending inventories. To
ascertain the amount of chemical in a mixed
formulation, multiply the amount of the
mixture (in pounds) by the concentration of
the chemical (weight percent) to obtain the
amount of chemical processed.
Example: Calculating annual use of
sulfuric acid through purchases and
inventory changes.
During 1987, a plant purchased and
used 20,000 pounds of sulfuric acid at 40
percent by weight. From inventory it used
10,000 pounds of sulfuric acid at 40 per-
cent by weight. The site also used 4,000
pounds of a formulation containing 15 per-
cent sulfuric acid by weight.
Amount of sulfuric acid used -
(20,000 Ib sulfuric acid x 0.40) +
(10,000 Ib suLfuric acid x 0.40) +
(4,000 Ib suljuric acid xO.15)
= 12,600 Ib
A listed chemical may be a component of
several formulations you purchase, so you
may need to ask your supplier for informa-
tion on the concentration (percentage) of the
chemical in each. For chemical categories,
your reporting obligations are determined by
the total amounts of all chemicals in the
category.
You must complete a report for each
chemical for which a threshold is exceeded.
The thresholds apply separately; therefore, if
you both process and use a chemical and
either threshold is exceeded, you must report
for both activities. If neither threshold is
exceeded, no report is needed.
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Step Three
Identify points of release for the
chemical(s) subject to reporting.
An effective means of evaluating points of
release for listed toxic chemicals is to draw a
process flow diagram identifying the opera-
tions performed at your facility. The figure
on the right is a generalized flow diagram for
monofilament fiber manufacturing. Because
each facility is unique, you are strongly urged
to develop a flow diagram for your particular
operations that details the input of materials
and chemicals and the waste sources re-
sulting from the operation of each unit.
Air emissions of volatile chemicals will
occur during fiber spinning and processing.
Solvent recovery systems, vessel washings,
and condensate may produce water releases.
Potential sources of solid wastes include filter
cakes, distillation fractions, spent catalysts,
and vessel and tank residues. If a water
treatment plant is located on site, releases
also may occur from disposal of the sludge.
Your reporting must account for all releases.
Step Four
Estimate releases of toxic chemicals.
After all of the toxic chemicals and waste
sources have been identified, you can esti-
mate the releases of the individual chemicals.
Section 313 requires that releases to air,
water, and land and transfers to offsite facil-
ities be reported for each toxic chemical
meeting the threshold reporting values. The
usual approach entails first estimating
VOCAIR
EMISSIONS
AIR EMISSIONS
AIR EMISSIONS,
FILTER CAKE
SPINNING WASTE,
AIR EMISSIONS,
SPINNERET WASH
WATER, COOLING
TOWER SLOWDOWN
SPENT LUBRICANT,
CLEANING WASTES,
SOLVENT VAPORS
AIR EMISSIONS
Example Flow Diagram of Monofilament
Fiber Manufacturing
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releases from waste sources at your facility
(that is, wastewater, air release points, and
solid waste) and then, based on the disposal
method used, determining whether releases
from a particular waste source are to air,
water, land, or an offsite disposal facility.
In general, there are four types of release
estimation techniques:
• Direct measurement
• Mass balance
• Engineering calculations
• Emission factors
Descriptions of these techniques are provided
in the EPA general Section 313 guidance
document, Estimating Releases and Waste-
Treatment Efficiencies for the Toxic Chemical
Release Inventory Form.
Provisions of the Clean Air Act, Clean
Water Act, Resource Conservation and Re-
covery Act, and other regulations require
monitoring of certain waste streams. If
available, data gathered for these purposes
can be used to estimate releases. When only
a small amount of direct measurement data
is available, you must decide if another esti-
mation technique would give a more accurate
estimate. Mass balance techniques and
engineering assumptions and calculations
can be used in a variety of situations to
estimate toxic releases. These methods of
estimation rely heavily on process operating
parameters; thus, the techniques developed
are very site-specific. Emission factors are
available for some industries in publications
referenced in the general Section 313 guid-
ance document. Also, emission factors for
your particular facility can be developed in-
house by performing detailed measurements
of wastes at different production levels.
Toxic Releases to Air
If you have not measured air emissions
from your process, you can use one of the
following approaches to estimate releases to
air.
1) Volatile organic compounds
Releases of solvents and other volatile
organic compounds used in your process will
be primarily to air. Releases to air can be
estimated as follows:
Amount of solvents released to air =
amount used -
amount accounted/or by other wastes
destroyed in treatment
In other words, rather than directly esti-
mating air releases, you should estimate
other releases first and then subtract them
from the quantity known to be used.
Example: Estimating release of
carbon disulfide used as a fiber
constituent in fiber spinning.
Amount of carbon disulfide released
to air =
100,000 Ib used in 1987 -
10,000 Ib accounted/or in. sludges
incinerated on site -
1,000 Ib discharged in wastewater -
5,000 Ib in sludge shipped offsite -
50,000 Ib accounted for in fiber
product
= 34,000 Ib
If you use acetone, dimethylformamide
(DMF), or dimethylacetamide (DMAc) as the
solvent in dry or wet spinning processes, you
may be able to use the emission factors given
in the table at the top of the following page.
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Solvent Usage and Emission Factors for Several Types
of Monofilament Fiber Manufacturing Processes
Plant
Emission factors, kg/1000 kg of fiber produced
Solvent Solvent
Makeup residual losses
Solvent solvent in fiber to water Emissions
Wet spin*
Dry spin*
Dry spin
Filter-tow dry spin
Filament yam dry spin
DMAc
DMF
Acetone
Acetone
Acetone
70
70
155
130
175
5
5
5
Negligible
10
25
20
10
10
20
40
45
140
120
145
*These plants have a filament washing stage that extracts residual solvent and monomer
from the fiber.
In the following example, these factors are
used to calculate air releases.
Example: Using emission factors to
estimate VOC releases
A plant produced 120,000 kilograms of
modacrylic in 1987. Acetone was used as
the solvent Based on the VOC estimate
for acetone from the preceding table,
Amount of acetone released to air =
120,000 kg ffoerx
140 kg acetone/1,000 kg fiber x
2.2 lb/1 kg
= 36,960 Ib
Using this approach, the plant in this
example could report air emissions of
37,000 pounds of acetone.
2) Particulates
Two methods can be used to estimate the
particulates released to air. The first entails
the use of available emission factors for gen-
eral monofilament, polypropylenes, or poly-
vinyl chloride manufacturing. The table
shown at the bottom of this page presents
selected air emission factors. In the following
example, these factors are used to estimate
the release of particulates to air during the
manufacture of polypropylene.
Air Emission Factors for General Monofilament,
Polyvinyl Chloride, and Polypropylene Manufacturing
Particulate
Type
General
Polyvinyl chloride
Polypropylene
Ib/ton
Pigment
5-10
35
3
kg/MT
Pigment
2.5-5
17.5
1.5
Gases
Ib/ton
Product
17
0.7
kg/MT
Product
8.5
0.35
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Example: Using emission factors to
estimate particulate emissions to air.
A plant produced 500,000 pounds of
polypropylene in 1987. The pigment con-
tent of this fiber was 8 percent. Based on
the emission factors provided in the pre-
ceding table, the particulate releases can
be calculated as follows:
Amount of pigment released =
500,000 Ib fiber x
0.08 Ib pigment/1 Ib fiber x
1 ton/2,000 Ib x
3 Ib particulate/1 ton pigment
= 60Zb
The second method entails back-
calculating the particulate emissions from the
weight of the particulate collected in the
baghouse with design efficiencies provided by
the baghouse manufacturer. If reported
values are not available, an efficiency of 98 to
99 percent should be assumed.
Most of the particulate matter released to
air will become airborne during the dope
preparation or blending operation. Based on
the weight percent of the chemical of interest
that enters the blender, the amount of spe-
cific chemical released to air in the form of
particulates can be estimated as follows:
Amount of chemical released to air =
amount of particulate released to air x
weight percent of chemical entering the
blender
Example: Using baghouse efficiency
to estimate particulate emissions to
air.
A polyester textile fiber manufacturing
plant collected 250,000 pounds of
parttculates in the baghouse filters from
the blending operations in 1987. The
baghouse manufacturer claims a 99.3
percent efficiency for these filters. If the
weight percent of titanium dioxide (TiOJ in
the fiber is 8 percent, the amount of this
chemical released to the air can be calcu-
lated as follows:
Amount ofTiO2 released =
250,000 Ib particulate collected x
(0.007/0.993) x
0.08 Ib TiO2/l Ib particulate
= 140 Ib
Toxic Releases Via Wastewater
The solvent recovery system, equipment
cleaning effluent, condensate, and washing
stage effluent are all potential sources for
water release. If plant monitoring data for
the water releases are available for the chemi-
cals of interest, the water releases can be
calculated directly.
Data on solvent emissions to water are
available for some dry and wet spinning
processes, as shown in the table of solvent
usage and emission factors on page 5. The
estimates in the table giving losses to water
include losses from the solvent recovery
system, any washing stage, and equipment
cleaning. The following example shows the
use of these factors to estimate water re-
leases.
Example: Using emission factors to
estimate water releases.
A plant produced 120,000 kilograms of
modacrylic in 1987 by dry spinning.
Acetone was used as the solvent. Emis-
sion factors can be used to calculate
acetone losses asfoUows:
Amount of acetone released to water =
120,000 kg fiber x
10kg acetone/1,000 kg fiber x
2.2 lb/1 kg
= 2,640 Ib
Using this approach, the plant in this
example could report water releases of
2,600 pounds of acetone.
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v If your facility uses a listed mineral acid
or base but this acid or base is effectively
neutralized in use or during wastewater
treatment (to pH 6 to 9, as required by most
effluent standards), no release quantities
should be reported for these substances.
If wastewater treatment occurs on site,
you should adjust the total losses to yield the
release. If available, use plant operating data
on removal efficiency for this purpose. Pub-
lished data also may be used, if such data are
available for the specific chemical treated by
the method used at your plant (for example,
biological wastewater treatment). The amount
of chemical released to water after waste-
water treatment can thus be calculated as:
Amount of chemical released to water =
amount lost in process water x
(1 - removal efficiency)
If no data are available, assume treatment
does not remove the chemical.
Toxic Releases Via Solid Waste
The possible sources of nonaqueous
waste to be landfilled or otherwise disposed of
include filter cakes, distillation fractions,
spent catalyst, vessel and tank residues, and
drums. Assuming that the monomer weight
percent in the dope is known, the loss in the
filter cake will be:
Amount of monomer in filter cake =
amount offUter cake x
weight percent of monomer
When a wastewater treatment plant is
located on site, some chemicals will also be
transferred from thej^uid to sludge and
some will be chemicfly or biologically
destroyed or neutralized. Loss to the sludge
will be:
Amount of chemical in sludge =
amount lost from process -
amount lost in water
Alternatively, you may have data on the con-
centration of chemicals in the sludge.
For organic chemicals in general, some
degradation may occur during treatment so
that all of the chemical is not transferred to
the sludge. The amount of organic com-
pounds in the sludge may be estimated by
using measured data or by subtracting the
amount biodegraded from the total amount
removed in treatment. Removal may be
determined from operating data, and the
extent of biodegradation may be obtained
from published studies. If the biodegrad-
ability of the chemical cannot be measured or
is not known, you should assume that all
removal is due to adsorption of sludge.
Other Toxic Releases
Monofilament fiber manufacturing pro-
duces other wastes from which toxic chemi-
cals may be released. These include:
• Residues from pollution control
devices
• Wash water from equipment
cleaning
• Product rejects
• Used equipment
• Empty chemical containers
Releases from these sources may already
have been accounted for, depending on the
release estimation methods used. These
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items (and any other of a similar nature)
should be included in your development of a
process flow diagram.
The contribution of sources of wastes
such as cleaning out vessels or discarding
containers should be small compared with
process losses. If you do not have data on
such sources (or any monitoring data on
overall water releases), assume up to 1 per-
cent of vessel content may be lost during
each cleaning occurrence. For example, if
you discard (to landfill) "empty" drums that
have not been cleaned, calculate the release
as 1 percent of normal drum content. If the
drums are washed before disposal, this may
contribute 1 percent of the content to your
wastewater loading.
Step Five
Complete the Toxic Chemical Release
Inventory Reporting Form.
After estimating the quantity of each
chemical released via wastewater, solid
waste, and air emissions, you must deter-
mine the amount of each chemical released to
water, land, or air or transferred to an offsite
disposal facility. This determination will be
based on the disposal method you use for
each of your waste streams. Enter the re-
lease estimates for each chemical or .chemical
category in Part III of the Toxic Chemical Re-
lease Inventory Reporting Form. Also enter
the code for each treatment method used, the
weight percent by which the treatment re-
duces the chemical in the treated waste
stream, and the concentration of the chemi-
cal in the influent to treatment (see instruc-
tions). Report treatment methods that do not
affect the chemical by entering "0" for re-
moval efficiency.
8
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For More Information
Emergency Planning
and Community
Right-to-Know
Hotline
Small Business
Ombudsman
Hotline
(800) 535-0202
or
(202) 479-2449
(in Washington, D.C.
and Alaska)
(800) 368-5888
or
(703) 557-1938
(in Washington, D.C.
and Virginia)
The EPA brochure, Title III Section 313
Release Reporting Requirements (EPA 560/4-
87-001) presents an overview of the new law.
It identifies the types of facilities that come
under the provisions of Section 313, the
threshold chemical volumes that trigger re-
porting requirements, and what must be
reported. It also contains a complete listing
of the chemicals and chemical categories
subject to Section 313 reporting. The EPA
publication, Estimating Releases and Waste-
Treatment Efficiencies for the Toxic Chemical
Release Inventory Form (EPA 560/4-88-002),
presents more detailed information on gen-
eral release estimation techniques than is
included in this document.
9
*U.S. Government Printing Office : 1988 - 516-002/80167
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United States
Environmental Protection
Agency
Office of Pesticides and
Toxic Substances, WH-562A
Washington, D.C. 20460
Official Business
Penalty for Private Use
$300
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