United States
Environmental Protection
Agency
Office of Pesticides
and Toxic Substances
&EPA Title III Section 313
Release Reporting
Guidance
EPA 560/4-88-004d
January 1988
Estimating Chemical Releases From
Spray Application of Organic Coatings
-------
-------
Estimating Chemical Releases From
Spray Application of Organic Coatings
Spray applicators of organic coatings may
be required to report annually any releases to
the environment of certain chemicals regu-
lated under Section 313, Title III, of the
Superfund Amendments and Reauthorization
Act (SARA) of 1986. If your facility is classi-
fied 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 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 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 spray
application of organic coatings, 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 the spray application of
organic coatings 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.
Solvents: Approximately 50 solvents are
on the Section 313 list; these include,
among others, methanol, n-butyl alcohol,
methylene bromide, methyl ethyl ketone,
2-nitropropane, xylene, and toluene
-------
Pigments: Primarily metal-containing
compounds such as titanium dioxide,
zinc chromate, zinc dust, lead flake, lead
chromate, red lead, barium chromate,
barium sulfate, and nickel titanate
Additives: Curing agents, flow control
agents, surfactants, defoamers, film-
building agents, and film-control agents
(for example, melamine, MOCA, dibutyl
phthalate, and diethanolamine)
Resin precursors (residues/impurities):
Ethyl acrylate, formaldehyde, vinyl chlo-
ride, methyl methacrylate, and toluene-
2,3-diisocyanate
Step Two
Determine if your facility surpassed the
threshold quantities established for
reporting of listed chemicals last year.
^ - ^f
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.
Degreasing 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 12,000 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
5,000 gallons of a clear topcoat containing
15 percent NBA by volume. The plant also
purchased and used 15,000 gallons of a
color topcoat containing 7 percent NBA by
volume.. In addition, it purchased 300
gallons of a formulation containing 95 per-
cent NBA by volume, which was used for
thinning and cleaning. Total annual usage
of NBA was asfoUows:
Annual usage of NBA =
(5,000 gal x 0.15) +
(15,000 gal x 0.07) +
(300 gal x 0.95)
= 2,085 gal
-------
The density of NBA is 0.810 kg/liter;
therefore, the annual usage in gallons can
be converted to pounds as follows:
Annual usage of NBA =
2,085 gal x
3.785 liters /I gal x
0.810 kg/I liter x
2.205 lb/1 kg
= 14,095 Ib
The use threshold applies because the
NBA is not incorporated into the final
coated aticle. 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 .spray
application 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 chemicals and the waste sources result-
ing from the operation of each unit.
The primary release of any of the chemi-
cals you process is likely to occur during the
spraying of the coating formulations. If your
spraying operations take place in a spray
booth, paint enclosure, or paint room in
which controls are in operation, the
overspray is probably collected in these
STORAGE:
FORMULATIONS
SOLVENTS
DRUMS/BAGS
RESIDUES
fc-
fe
^-
PREMIX/
THINNING
PREMIX/
THINNING
PREMIX/
THINNING
fc*
fc.
^
SUBSTRATE
SPRAYING
PRIMER
1
r
SPRAYING
COLOR COAT
1
r
SPRAYING
CLEAR TOP
COAT
1
r
FLASH-OFF
(AIR CURING)
1
r
HEAT CURING
*»~~~^
WASTEWATER
TOPOTW
t
ONSITE
TREATMENT
1
SLUDGE TO
DISPOSAL
>. SOLVENT EMISi
TO CONTROL D
5IONS
EVICE
T
MAINTENANCE/CLEANUP RESIDUES
Example Flow Diagram of Spray Application of Organic Coatings
-------
controls. If you have onsite wastewater
treatment, you also might have wastewater
sludge containing the chemical. Other re-
leases may come from discarded shipping
containers (drums, bags) or occur during
cleanup operations. 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
Recovery 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 arid
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.
For spray coating operations, the amount
of material oversprayed plays a major role in
estimating releases. You can estimate this
amount by considering the spraying method
and the type of sprayed surface. The per-
centage of overspray will be needed in most
types of release estimations. If data specific
to your operations are not available, the fol-
lowing table provides some information you
may use.
-------
Percentage of Overspray Resulting From Three Spraying Methods
Percentage of overspray
Spraying method
Air-atomized
Airless
Electrostatic
Disc
Airless
Air-atomized
Flat
surfaces
50
20-25
5
20
25
Table leg
surfaces
85
90
5-10
30
35
Bird cage
surfaces
90
90
5-10
30
35
When the amount of coating applied, the
concentration of the chemical in the formu-
lation, the type of substrate, and spraying
method are known, the amount of over-
sprayed material can be estimated as follows:
Amount of chemical oversprayed =
amount of formulation applied x
weight percent of chemical x
percent overspray
Toxic Releases Via Wastewater
If you have monitoring data specific to the
chemicals you process or use, you can use
these data for reporting purposes. For
example, if wastewater has been monitored
prior to discharge, the amount of chemical
released in wastewater can be calculated as
follows:
Amount of chemical released to
wastewater =
concentration in wastewater x
daily volume of wastewater x
days /yearfor which data apply
Review all available monitoring data to
determine a representative concentration to
use in this calculation. In the absence of
such data, the following approaches can be
used to estimate releases.
If a water curtain is installed as a control
in your spray booth, most of the material lost
through overspray will be collected in this
water. Particulate collection efficiencies for
water curtains vary among manufacturers
and coating application facilities. If you have
no data on your particular system, you can
assume an efficiency of 95 percent, as water
curtain system efficiencies are generally
higher than 95 percent (that is, the water
curtain will collect 95 percent of the over-
sprayed material). The amount of chemical
collected by the water curtain can thus be
calculated as:
Amount of chemical collected =
amount of overspray x
water curtain efficiency
If wastewater treatment occurs on site,
the amount of chemical "lost" must be ad-
justed to yield the actual release. Use either
actual plant operating data on removal
efficiency or published data for treatment
methods similar to those used at your site. If
no data are available, assume the treatment
does not remove the chemicals. The amount
of chemical released in the wastewater can
thus be calculated as:
Amount of chemical released in
wastewater =
amount "lost" in wastewater x
(1 - removal efficiency)
-------
Toxic Releases Via Solid Waste
If "solids" are removed from the water
before it leaves the water curtain tanks (for
example, by settling with or without the aid of
chemical treatment), estimate the amount of
chemical in these solids based on their vol-
ume and the concentration of the chemical.
The amount of chemical collected in these
solid wastes can thus be calculated as:
.Amount of chemical collected =
amount of solid x
weight percent of chemical
Alternatively, the amount of chemical in
the sludge may be estimated as the difference
between overspray and the amount in dis-
charged water, if the latter has been mea-
sured or can be estimated based on water
solubility. Report the amount of chemical in
the sludge in accordance with its disposal (for
example, transfer to landfill).
If your spray booth, paint enclosure, or
paint room is equipped with a dry particulate
collection filter, you will need to estimate the
amount of chemical captured in the filter
medium. If collection efficiency data are not
available, you may use the following infor-
mation.
Collection Efficiencies for Several Types
of Dry Particulate Collection Filters
Collection
Filter type efficiency, %
Metal panels and
corrugated filters 90
, Pleated kraft filters 93-95
Fiberglass filters 97-99
Expanded kraft,
nonwoven cloth, and
baffle-strainer
combinations 98-99.8
The amount of chemical collected in the dry
filter medium can thus be calculated as:
Amount of chemical collected =
amount oversprayed x
collection efficiency
This material is expected to be disposed of
with the dry filter medium or removed from
the filter during cleaning operations. These
wastes are probably landfilled or incinerated,
but they could be released to water if the
filters are washed. Report the release under
the appropriate category on the form.
During wastewater treatment the chemi-
cals can be transferred to the sludge. Avail-
able data on the chemicals should be used
for estimation purposes. For organic chemi-
cals, some degradation usually occurs during
treatment, so all of the chemical removed
from the water does not end up in the sludge.
You can estimate the amount of organic
compounds in the sludge 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 extent of biode-
gradation may be obtained from published
studies. If the biodegradability of the chemi-
cal cannot be measured or is unknown, you
should assume that all removal is due to
adsorption to the sludge.
Toxic Releases to Air
Any overspray material not collected by
spray booth controls (water curtains or dry
filter media) will be released to the air unless
some additional controls are in place for this
section of your finishing operations. The
amount of chemical released to air can thus
be calculated as:
Amount of chemical released to air =
amount oversprayed x
(1 - collection efficiency)
-------
Apply measured control efficiencies for con-
trol devices (for example, fabric filters) If they
are used to reduce emissions of nonvolatile
substances. The amount of chemical re-
leased to air after the overspray passes
through the control device can thus be
calculated as:
Amount of chemical released to air =
amount to the control device x
(1 - collection efficiency)
Volatile materials (such as solvents) in
your coating systems are designed to facil-
itate the coating application and then to
volatilize after the coating reaches the sub-
strate. Approximately 70 percent of these
materials are expected to volatilize during the
actual spraying, 10 percent during the flash-
off, and 20 percent during curing. You can
assume all volatiles will be lost to air; there-
fore, to estimate amounts actually released,
you only have to account for the effectiveness
of any control device used.
Your facility probably has control devices
for volatiles at the spraying stations, the
flash-off stations, or the oven. When this is
the case, you need to adjust your estimated
"losses" to "releases." You should use re-
moval efficiency data for your control device if
available. By using the figures on volatiliza-
tion from the preceding paragraph, you can
estimate the actual release from each of the
control devices as follows:
Amount of volatiles released to air =
(amount of volatiles x 0.7 x spray
control efficiency) +
(amount of volatiles x 0.2 x flash-off
control efficiency) +
(amount of volatiles xO.l x drying
control efficiency)
Of course, if a control device transfers the
chemical to another waste that is then
released, that release must be reported.
Other Toxic Releases
Spray application 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.
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 iri 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
1 affect the chemical by entering "0" for
removal efficiency.
8
-------
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, B.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.
S-U.S. Government Printing Office : 1988 - 516-002/80171
-------
vvEPA
United States
Environmental Protection
Agency
Office of Pesticides and
Toxic Substances, WH-562A
Washington, D.C. 20460
Official Business
Penalty for Private Use
$300
------- |