United States
Environmental Protection
Agency
Office of Pesticides
and Toxic Substances
xvEPA Title III Section 313
Release Reporting
Guidance
EPA 560/4-88-004b
January 1988
Estimating Chemical Releases From
Printing Operations
-------
-------
Estimating Chemical Releases
From Printing Operations
Printers may be required to report an-
nually any releases to the environment of
certain chemicals regulated under Section
313, Title III, of the Superfund Amendments
and Reauthorization Act (SARA) of 1986. If
your facility is classified under SIC codes 20
through 39 (facilities that apply printing inks
generally fall under SIC code 27) and has 10
or more full-time employees, for calendar year
1987 you must report all environmental re-
leases 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,
respectively.
This document has been developed to
assist printers 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 available for esti-
mating releases. If your facility performs
other operations in addition to printing, you
must also include any releases of toxic chem-
icals 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 In-
ventory Reporting Form.
The list presented here includes chemi-
cals typically used in printing that are sub-
ject to reporting under Section 313: This list
does not necessarily include all of the chemi-
cals your facility uses that are subject to
reporting, and it may include many chemicals
that you do not use. You should also deter-
mine whether any of the listed chemicals are
created during processing at your facility.
Solvents: Acetone, methyl ethyl ketone,
methyl isobutyl ketorie, xylene, toluene,
ethylbenzene, Michler's ketone,
n-butanol, ethylene glycol, glycol ethers,
methyl chloroform, methanol
-------
Resins: Resins containing formaldehyde,
zinc resinates
Antioxidants: Hydroquinone, catechol
Plastlcizers: Dibutyl phthalate
Driers: Metallic soaps containing cobalt,
lead, manganese, copper, or zinc
Pigments: Titanium dioxide, zinc sulfide,
barium sulfate, lead chromates, hydrated
alumina (pigment extender), aluminum
powder
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, inks
applied to substrates) would be considered
"processed" because they become part of the
marketed finished product. Degreasing
solvents, cleaning agents, and other chemi-
cals 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
acetone through purchases and
inventory changes.
Opening stock 5,000 Ib
Plus purchases during year 12,000 Ib
Less closing stock
Total use
17,000lb
6,000 Ib
ll.OOOlb
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.
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 next page is an example flow diagram
of printing operations. 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 resulting
from the operation of each unit.
-------
SOLVENTS
RESINS
PIGMENTS
ADDITIVES
PRINTED PAPER
- AIR EMISSIONS
• AIR EMISSIONS
• CLEANING WASTE
• AIR EMISSIONS
• CLEANING WASTE
AIR EMISSIONS
UNCONTROLLED AIR EMISSIONS
AIR EMISSIONS
STEAM
HOT
AIR
AIR EMISSIONS
RECYCLE
SOLVENT
CONDENSATE WATER
WATER
RECYCLE
TO BOILER
ANICS
PPER
1
BIOLOGICAL
WASTEWATER
TREATMENT
»-
DISCHARGE
WATER
Example Flow Diagram of Printing Operations
-------
Solvents present in the ink are likely to be
emitted to the air. Ink solids, such as pig-
ments and driers, may end up as solid waste.
Other potential sources of release include
waste printed items, "empty" containers, and
wastes from pollution control devices. 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 fa-
cilities be reported for each toxic chemical
meeting the threshold reporting values. The
usual approach entails first estimating re-
leases 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
1) Uncontrolled Emissions
Most, if not all of the organic solvents
used in inks will be emitted to the air as a
result of evaporation in the ink application
area, the press, the dryer, and the chill rolls.
Therefore, if there are no control devices to
reduce emissions, the simplest approach may
be to use a mass balance to estimate total
uncontrolled emissions rather than measur-
ing or estimating the emissions from each
source.
Total uncontrolled emissions can be
calculated as follows:
Amount of chemical released =
amount of fresh and recycled chemical
used per year -
chemical remaining in product -
chemical disposed of in solid/liquid
waste
-------
Emissions from the dryer would be con-
sidered stack emissions. If possible, you
should estimate these separately, based
either on measurements or estimated dryer
capture efficiencies:
Amount of chemical released through dryer
stack =
total emissions x
(1 - capture efficiency)
the EPA publication, Compilation of Air
Pollutant Emission Factors:
Press type
Dryer
capture
efficiency
as:
Publication rotogravure 85%
Packaging rotogravure 75%
Flexographic 70%
Fugitive emissions can then be calculated
Amount of fugitive emissions =
total emissions -
stack emissions
2) Controlled Emissions
The amount of stack emissions from con-
trolled dryers (or other equipment) can be
calculated by multiplying the air flow rate
from the control device (condenser, carbon
adsorber, or incinerator) by the average
chemical concentration, if known. Alter-
natively, these "uncontrolled" emissions can
be estimated by applying a control device
efficiency:
Amount of device emissions =
dryer stack emissions x
(1 *^ control device efficiency)
Report these emissions as stack emissions on
the form. If you do not have data on the
effectiveness of your control device, use the
following information, which was taken from
Control
Cooler/condenser
Carbon adsorber
Incinerator
Control
device
efficiency
85-90%
90-95%
95%
Example: Estimating air releases
from a dryer with carbon absorption.
In 1987, a plant released 10,000
pounds of'toluene from a dryer equipped
with carbon absorption. The total emis-
sions were as follows:
Amount of toluene released to air =
10,000 Ib x (1 - 0.95)
= 500 Ib
The material captured by a carbon adsorber
must be accounted for in release estimates;
for example, it could be part of the "solid
waste" sent offsite for treatment or disposal.
Toxic Releases Via Wastewater
Releases of solvent to water can occur
when the carbon beds are regenerated by
steam stripping followed by condensation and
decantation of the solvent and water. To
estimate the amount of a solvent released to
water, multiply the flow rate of water from the
decanter times the concentration of chemical
in the water. This loss is usually less than
1 percent of all the solvent used at the print-
ing press. If the concentration is unknown,
you can estimate it by using the water solu-
bility of the chemical at the proper water
temperature. For publication rotogravure
printing, the solvent content of the con-
densate is typically 130 to 200 ppm, but it
could be as much as 1900 ppm. The actual
concentration will depend on the specific
-------
chemical used and its solubility. You should
keep in mind that the water solubility of most
organic liquids increases with temperature.
If hot air is used to strip condensate, the
solvent concentration in the water will be
considerably lower (usually less than 5 ppm
organic content). In this case, water solu-
bility should not be used as a measure of
concentration.
If the organic-contaminated condensate is
treated biologically to meet local and State
effluent limitations (for example, by use of
activated sludge or a trickle filter), the
amount released to water should reflect the
percentage removal of the chemical from the
wastewater, and the wastewater treatment
efficiency should be reported on the Toxic
Release Inventory Reporting Form.
Toxic Releases Via Solid Waste
Cleaning wastes and ink batches that fail
to meet specifications may be sources of
liquid/solid waste that your facility disposes
of or incinerates on site. Whether disposal is
on or offsite, you can estimate the amount of
chemical released by multiplying the quantity
of waste generated by the concentration of
the chemical in the waste. Hazardous waste
quantities may be available from shipping
manifests or RCRA Biennial Reports.
If the solid waste is treated or incinerated
on site, you should report the amount of
chemical leaving the treatment under the
appropriate media (air, water, solid waste)
into which final disposal of the chemical is
made. Solvent recovered from carbon
adsorption systems and recycled is not
considered a "release" and should not be
reported as such.
Other Toxic Releases
Printing operations produce other wastes
from which toxic chemicals 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
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
Release 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
removal efficiency.
7
-------
For More Information
Emergency Planning
and Community
Right-to-Know
Hotline
Small Business
Ombudsman
Hotline
(800) 535-0202
or
(202) 47.9-2449
(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.
Additional Sources of Information
on Releases From Printing
Operations
U.S. Environmental Protection Agency. Com-
pilation of Air Pollutant Emission Factors,
Fourth Edition. AP-42. Research Triangle
Park, North Carolina. September 1985.
U.S. Environmental Protection Agency.
Publication Rotogravure Printing—Back-
ground Information for Proposed Standards.
EPA 450/3-80-03 la. NTIS PB 81 -117145.
Research Triangle Park, North Carolina.
October 1980.
U.S. Environmental Protection Agency.
Control of Volatile Organic Emissions From
Existing Stationary Sources—Volume VII:
Graphics Arts—Rotogravure and Flexo-
graphy. EPA 450/2-78-033. NTIS PB
292490. Research Triangle Park, North
Carolina. December 1978.
8
*U.S. Government Printing Office : 1988 - 516-002/80170
------- |