United States
Environmental Protection
Agency
Office of Pesticides
and Toxic Substances
EPA 560/4-88-004C
January 1988
v>EPA Title III Section 313
Release Reporting
Guidance
Estimating Chemical Releases From
Electrodeposition of Organic Coatings
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Estimating Chemical Releases From
Electrodeposition of Organic Coatings
Appllers of organic coatings via electro-
deposition (EDP) may be required to report
annually 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 and has 10 or more full-time
employees, for calendar year 1987 you must
report all environmental releases of any Sec-
tion 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 pro-
cessed chemicals drops to 50,000 and 25,000
pounds per year, respectively.
This document has been developed to
assist appliers of organic coatings in the com-
pletion of Part III (Chemical Specific Informa-
tion) 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 estimating releases. If your facility per-
forms other operations in addition to EDP,
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 In-
ventory Reporting Form.
The list presented here includes chemi-
cals typically used in EDP of organic coatings
that are subject to reporting under Section
313. This list does not necessarily 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 processing at
your facility.
Solvents: Approximately 50 solvents are
on the Section 313 list; these include,
among others, 1,1,2-trichloroethane,
n-butyl alcohol, ethylene glycol,
2-ethoxyethanol, xylene, and toluene
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Pigments: Primarily metal-containing
compounds, such as titanium dioxide.
zinc oxide, white lead, barium sulfate,
chromium oxide, and nickel titanate
Additives: Curing agents, surfactants.
defoamers, thickeners, film-control
agents, and plasticizers (for example,
dibutyl phthalate, dimethyl phthalate.
ammonia, and diethanolamine)
Resin precursors (residues/impurities):
Ethyl acrylate, formaldehyde, vinyl
chloride, methyl acrylate. acrylic acid.
acrylonitrile, ethylene glycol, melamine,
vinylidene chloride, styrene, 1,3-buta-
diene, and phenol
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
pigment coated onto a metal part) would be
considered "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
toluene through purchases and
inventory changes.
Opening stock 5,000 Ib
Plus purchases during year J 2,000 Ib
Less closing stock
Total use
17,000 Ib
6,000 Ib
11,000 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.
Example: Estimating usage ofn-butyl
alcohol (NBA) in coating formulations.
In 1987, a plant used from inventory
10,000 gallons of a coating formulation
containing 15 percent NBA by volume. It
also purchased 350 gallons of a formu-
lation containing 98.4 percent NBA by
volume, which was used for thinning.
Total annual usage of NBA was as follows:
Annual usage of NBA =
(10,000 gal x 0.15) +
(350 gal x 0.984)
= 1,844 gal
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The density of NBA is 0.810 kg/liter. The
annual usage in gallons can therefore be
converted to pounds as follows:
Annual usage of NBA =
1.844 gal x
3.785 liters/I gal x
0.81 Okg/I liter x
2.205 lb/1kg
= 12,465 lb
The use threshold applies because the
NBA is not incorporated into the final
article. Because the plant uses more than
10,000 pounds per year of NBA, it must
complete a Toxic Chemical Release
Inventory Reporting Form.
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
below is an example flow diagram for EDP of
organic coatings. 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 chemi-
cals and the waste sources resulting from the
operation of each unit.
The major releases in EDP coating opera-
tions consist of the coating components that
are not transferred to the coated substrate.
These are likely to be discharged from the
EDP tank. If you have onsite wastewater
treatment, you might also have wastewater
sludge containing the chemical. Other
PRETREATED/DRY RECYCLED
METAL SUBSTRATE COATING/WATER
STORAGE:
FORMULATIONS -
WATER
EDP DIP TANK
DE1ONIZED_
WATER
1
ULTRAFILTER
SERIES OF
WATER
RINSES
STORAGE
CLEANUP
RESIDUES
I
RECYCLED
RINSATE
PERMEATE
AIR/FORCED
DRYING
WASTEWATER
TOPOTW
t
ONSITE
WASTEWATER
TREATMENT
T
SLUDGE TO
DISPOSAL
MAINTENANCE/CLEANUP RESIDUES
Example Flow Diagram of Electrodeposition of Organic Coatings
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releases may come from discarded shipping
containers, cleanup operations, or (in the
case of some substances) volatilization to the
air. 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 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
estimation technique would give a more
accurate estimate. Mass balance techniques
and engineering assumptions and calcula-
tions 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.
For EDP coating operations, the transfer
efficiency will be a major determinant of the
amount of material released. This efficiency
will vary significantly among systems. If
specific data for your system are not avail-
able, a transfer efficiency of 97 percent may
be assumed for estimation purposes (that is,
97 percent of the coating solids are trans-
ferred to the substrate).
Toxic Releases Via Wastewater
If you have monitoring data specific to the
chemicals you process or use, you should use
these data for reporting purposes. For exam-
ple, if wastewater has been monitored prior to
discharge, the amount of chemical released in
wastewater can be calculated as follows:
Amount of chemical released =
concentration in wastewater x
i
daily volume of wastewater x
days/year/or which data apply
Review all available monitoring data to de-
termine a representative concentration to use
in this calculation. In the absence of such
data, the following approaches can be used to
estimate releases.
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Ultrafiltration is commonly used as part
of electrodeposition coating systems. The
permeate or ultrafiltrate that results from
this operation probably will be transferred to
onsite wastewater treatment. Although most
of the organic chemicals in your coating are
expected to be recycled into the EDP tank, a
certain fraction of them could be present in
the permeate or ultrafiltrate.
Chemicals that are suspended in the for-
mulation (for example, pigments, resin pre-
cursors, and some additives, which can also
be thought of as solids) are not soluble in
water. If you have monitoring data for the
chemical concentration in the permeate
stream, use it to estimate releases. If no data
are available, you may estimate the amount
of chemical lost by assuming that 0.5 percent
of the total solids in the coating applied are
released with the permeate and calculate the
amount in the permeate as follows:
Amount of chemical lost in permeate =
amount of coating applied x
(weight percent of chemical in coating x
0.005)
Water-soluble species include the various
solvents in the coating formulation, along
with some other organics that may be part of
the resin system or of the additives. If mon-
itoring data are available for the specific
chemical concentration in the permeate
stream, you should use these data for report-
ing purposes. If such data are not available,
the amount of chemical lost in this stream
can be estimated as follows, based on the
water solubility of the chemical and the per-
meate stream flow rate:
Amount of chemical lost in permeate =
amount of permeate released/year x
water solubility of chemical
If the permeate stream is sent to waste-
water treatment on site, you should adjust
"losses" to yield "release." You may base your
estimate of the amount released on treatment
efficiencies. Use actual operating data on
removal efficiency or published data for a
treatment similar to that used at your site, as
follows:
Amount of chemical released after
wastewater treatment =
amount lost in permeate x
(1 - removal efficiency)
Toxic Releases Via Solid Waste
The major source of release for "solids" is
expected to be the EDP tank residues. These
solids build up as a result of EDP process
inefficiencies and are periodically collected
when the tank contents are "dumped" for
cleanup purposes. To obtain the quantity of
chemical released, simply multiply the weight
of sludge removed by the known concen-
tration of the chemical. If such data are not
available, you can base your estimate of the
amount of chemical in the sludge on the EDP
transfer efficiency and the amount lost in the
permeate:
Amount of chemical lost in sludge =
amount of chemical applied x
(1 - transfer efficiency) -
amount lost in permeate
Example: Estimating releases in EDP
tank sludge.
A plant used 60,000 pounds of a pig-
ment in 1987. Of this amount, 97 percent
is estimated to have been transferred to
the coated substrate and 0.5 percent is
estimated to have been lost to water.
Amount of pigment in sludge =
60.000 Ib pigment x
(1-0.97)-
(60,000 Ib x 0.005)
= 1.500 Ib
This release should be reported under the
appropriate category of disposal. If hazard-
ous waste regulations apply to your sludge,
report this release according to any special
handling procedures that may apply.
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A fraction of the water-soluble species is
expected to be removed with the coating
sludge. Use any specific data on the sludge's
concentration and its disposal rate, as dis-
cussed for the release of solids. If no moni-
toring data for the sludge are available, you
may estimate the amount of a water-soluble
substance in the sludge based on its solu-
bility in water and the percentage of water in
the removed sludge:
.Amount of chemical in sludge =
amount of sludge x
weight percent water in sludge x
water solubility of chemical
Toxic Releases to Air
Volatile species (mainly solvents) pro-
cessed or used at your site could be released
to air because of their relatively high vapor
pressures. If they have not been measured,
air releases can be estimated as the differ-
ence between total chemical applied and
chemical lost in water and solid wastes. This
mass balance will be as follows:
Amount of chemical released to air =
amount applied -
amount lost in permeate -
amount lost in sludge -
amount lost in process-related releases
Example: Using a mass balance to
estimate air releases.
In 1987 a plant used 150,000 pounds
of a 55 percent water-soluble solvent This
solvent was used for 50 days, during
which 210,000 pounds of permeate was
drainedfrom the system and 55,000
pounds of water was removed with the
system's sludge during cleanup opera-
tions.
Amount of solvent released to air =
150,000 Ib used -
(210,000 Ibx 0.55)-
(55,000 Ib x 0.55)
= 4,250 Ib
Using this approach, the plant in this
example could report air emissions of
4,300 pounds of solvent.
If volatile emissions are controlled (for
example, by carbon adsorption or incinera-
tion), apply the measured or estimated con-
trol efficiency to obtain actual releases to air.
Account for any of the chemical transferred to
other wastes (for example, spent carbon), and
report it in the appropriate portion of the
form.
Other Toxic Releases
Electrodeposition of organic coatings
produces 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 the development of
your process flow diagram.
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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
removal efficiency.
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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, B.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.
8
S-U.S. Government Printing Office : 1988 - 516-002/80164"
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