United States
           Environmental Protection
           Agency
Office of Pesticides
and Toxic Substances
&EPA     Title III Section 313
           Release Reporting
           Guidance
EPA 560/4-88-004g
January 1988
           Estimating Chemical Releases From
           Electroplating Operations

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            Estimating  Chemical Releases From
                     Electroplating  Operations
   Facilities engaged in electroplating opera-
tions may be required to report annually any
releases 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
(electroplating facilities generally fall under
SIC code 3471) 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 those who perform  electroplating
operations 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 electroplating,
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
information, you must follow the steps out-
lined to handle this eventuality in the in-
structions provided with the Toxic Chemical
Release Inventory Reporting Form.
   The list presented here includes chemi-
cals typically used in electroplating opera-
tions 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.
   Degreasing solvents:  Perchloroethylene,
   trichloroethylene, methylene chloride,
   1,1,1-trichloroethane, and others
   Alkaline cleaning agents:  Sodium
   hydroxide
   Acid cleaning and pickling agents:
   Sulfuric acid, hydrochloric acid, phos-
   phoric acid, nitric acid, chromic acid

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    Chelating agents: Thiourea, nitrilo-
    triacetic acid (NTA), ethyleneimine
    (aziridine)
    Components of plating and other
    process baths: Cadmium compounds,
    chromium compounds, sodium
    hydroxide, cobalt compounds, copper
    compounds, lead compounds, nickel
    compounds, silver compounds, zinc
    compounds, cyanide compounds, sulfuric
    acid, sodium sulfate, phosphoric acid,
    ammonia, arsenic compounds, selenium
    compounds, various aldehydes
             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, metals
that are plated onto metal articles) 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:  Determining whether 1,1,1-
    trichloroethane was used in sufficient
    quantity to require reporting under
    Section 313.
       An electroplater purchased 95 percent
    1,1,1 -trichlaroethanefor use in a vapor
    degreaser.  In 1987, 3,000 pounds of this
    material was in storage at the beginning of
    the year, 18,000 pounds was purchased,
    and 6,000 pounds was in storage at the
    end of the year. The quantity of 1,1,1-
    trichloroethane used by the facility equals:
       (3,000 Ib x 0.95) (beginning
       inventory) +
       (18,000 Ib x 0.95) (purchased) -
       (6,000 Ib x 0.95) (ending inventory)
       = 14,250 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. For example,  in a  copper plating
bath, three cyanide-containing compounds
are used:  CuCN, NaCN, and KCN.  The
quantity of cyanide compounds used equals
the sum of the quantities of  CuCN,  NaCN,
and KCN used. For a substance  such as
CuCN, the amount  used must be considered
in determining whether the threshold is met
for both copper- and cyanide-containing
compounds.
    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.
AIR EMISSIONS •
    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 an example flow diagram for
 electroplating (chromium plating of zinc die
 castings).  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.
    The largest source of toxic releases at
 electroplating facilities will occur in the
 wastewater. Wastewater is generated from a
 variety of sources, including the rinsing of
 parts between process baths during metal
 cleaning, plating, and post-plating opera-
 tions; the dumping of exhausted or spent
 process baths; and  the rinsing required
 during auxiliary operations such as rack
 stripping. Wastewater usually is centrally
 collected and treated before discharge; thus,
 all of these sources are aggregated into one
 release point. Solid waste is generated
 primarily from the treatment of wastewater.
 Other sources include filter solids from
 plating baths, anode wastes, spent degreaser
 solvent and sludge, and precipitates from
 electroless nickel bath regeneration.  Two
notable air releases are solvents from metal-
degreasing operations and mists  evolved from
electrolytic cleaning solutions and cyanide
and chromium plating solutions.
AIR EMISSIONS
SPENT SOLVENTS
AND SLUDGE









CLEAN








FILTER ^.
SOLIDS "*^






-»•











-*

V—

-_fe

1
ACID DIP
|
RINSE
I
CYANIDE
COPPER
STRIKE
1


I
ACID DIP
|
ACID
COPPER
PLATE
*
RINSE
*
NICKEL
PLATE
1
R1NSF
RINSE
^

r-»
NEUTRALIZE
AND
PRECIPITATE
AIR EMISSIONS •

FILTER SOLIDS •
                                    TREATED
                                    WATER
                                                    Example Flow Diagram of Chromium
                                                   Plating of Decorative Zinc Die Castings

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            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 facili-
ties be reported for each toxic chemical meet-
ing the threshold reporting values. The usual
approach entails first estimating 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 Via Wastewater
  ' The U.S. Environmental Protection
Agency has set effluent limitations on  electro-
plating wastewater discharges to publicly
owned treatment works (POTWs) and into ,
navigable waters.  Your facility is therefore
probably required by a local pretreatment
permit or an NPDES permit to monitor dis-
charge wastewater for toxic metals, cyanide,
and various toxic organic compounds. The
data generated from this monitoring can be
used to estimate releases of these com-
pounds.  The following example demonstrates
a wastewater release estimation based on
direct measurement.

   Example:  Using direct measurement
   to estimate releases of cyanide via
   wastewater.

      An electroplating facility discharges its
   pretreated wastewater to a POTW.  The
   municipality operating the POTW requires
   the electroplater to monitor this discharge
   once per month for various parameters,
   including total cyanide. The mass loading
   (pounds per day) of cyanide in the dis-
   charge is calculated for each sampling day
   by multiplying the daily flow by the
   measured cyanide concentration and unit
   conversionfactors:

   Amount of cyanide released to
   wastewater =
      cyanide concentration (mg/ltter) x
      wastewater flow (gal/day) x
      3.78 liters/1 gal x
       1 lb/453,000 mg

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    Cyanide andjlow data from the days
    when cyanide was monitored during 1987
    and the calculated mass loadings of
    cyanide are presented below:
Wastewater
flow,
Day gal/ day
Jan. 8
Feb. 12
Mar. 10
Apr. 15
May 9
June 13
July 1 1
Aug. 10
Sep. 8
Oct. 12
Nov. 10
Dec. 8
21,500
20,500
20,800
22,000
23,500
21,300
25,900
21,500
24,600
25,000
20,100
20,700
CN
cone.,
mg/ liter
1.5
0.8
0.6
0.5
0.7
1.9
2.1
1.0
0.9
0.8
0.6
0.2
CNmass
loading,
Ib/day
0.27
0.14
0.10
0.09
0.14
0.34
0.44
0.18
0.18
0.17
0.10
0.03
       The average daily cyanide discharge
    based on these monitoring data is 0.18
    pound per day. Assuming the plant
    operates 250 days per year, the total
    quantity of cyanide released via waste-
    water to the POTW equals:
       0.18 Ib/day x 250 days/year
       = 45 Ib
    Monitoring data may not be available for
some of the toxic chemicals present in your
wastewater. In this case, you must use
another estimation method. The following
example demonstrates the use of a mass
balance combined with an engineering
calculation.

    Example:  Using a mass balance
    combined with an engineering
    calculation to estimate releases of
    nitrilotriacetic acid (NTA) via
    wastewater.
       A facility used 12,970 pounds of NTA
    in its electroless plating operation during
    1987. Because it does not become part of
    the product, all of the NTA used becomes
    part of the facility's waste and is either
    destroyed during waste treatment or
    released from the facility. To estimate
    releases of NTA, one needs the answers to
    two questions:
    •  How much NTA is destroyed during
       treatment?
    •  In whatformfs) is NTA released from
       the facility (wastewater, solid waste,
       air emissions)?
       At this facility, NTA enters the waste-
    water stream as a chelate-metal complex
    during the rinsing of metal parts from the
    plating bath. This wastewater stream
    goes through apH adjustment/clarification
    system where lime is added to precipitate
    metals. Typically, chelating agents wiR
    not be destroyed in this process, nor will
    they precipitate along with the metals. On
    the contrary, the purpose of chelating
    agents is to keep the metal ions in solution
    in the plating bath. An engineering
    assumption can therefore be made that all
    of the NTA entering waste treatment leaves
    in the wastewater discharge.  Given that
    the wastewater is discharged to a POTW,
    the plant in this example could report
    wastewater releases of 13,000 pounds of
    NTA.
    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. If the acid or base is
transformed into a reportable substance,
however, you must estimate the quantity of
this substance manufactured to determine if
the "manufactured" threshold value has been
reached.  For example, sulfuric acid neutral-
ized by sodium hydroxide yields  sodium
sulfate, which is a listed chemical.

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Toxic Releases Via Solid Waste
   Some solid wastes at electroplating facili-
ties are listed as hazardous under RCRA
regulations.  Others may be deemed hazard-
ous based on the extraction procedure tox-
icity characteristic (EP toxicity). Generation,
transportation, and disposal of certain solid
wastes from electroplating may therefore be
regulated under RCRA. The RCRA manifest-
ing procedure for hazardous waste shipped
offsite requires documentation of quantities
shipped. Detailed chemical and physical
analyses may be performed on the wastes by
treatment, storage, and disposal facilities.
The electroplater also may perform analyses
on the waste.  Release estimates for some
compounds can therefore be made by direct
measurement.
   Example: Using direct measurement
   to estimate releases of toxic metals
   via solid waste.
       Wastewater treatment sludge from an
   electroplating operation is shipped to an
   offsite secure chemical landfill for disposal.
   Shipping manifests for the past year con-
   tain detailed information on the quantity of
   sludge sent to the landfill Shipments of
   sludge were made on a monthly basis.
   The landfill performed detailed chemical
   analysis for nickel on representative
   portions of each shipment before final
   disposal  As shown in the following table,
   the information from the manifests and
   landfill can be combined to estimate
   releases of toxic metals and cyanide in the
   wastewater treatment sludge.
Month
Jan.
Feb.
Mar.
Apr.
May
June
July
Aug.
Sep.
Oct.
Nov.
Dec.
Sludge
shipped,
Ib
6,000
5,400
4,700
5,500
6,100
6,800
7,200
6,400
5,900
4,500
5,200
5,300
Nickel
cone.,
ppm
50,600
51,900
48,500
37,000
30,000
75,000
84,000
55,500
50,000
105,500
69,000
20,000
Nickel in
sludge,
Ib
304
280
228
204
183
510
605
355
295
475
359
106
       It should be noted that this example
   only addresses nickel releases in waste-
   water sludge.  Nickel may also be present
   in other wastes in the facility. Also, the
   landfill probably would have analytical
   data for other metals in this sludge that
   could be used to calculate releases of
   those compounds.
   When direct measurement data are not
available, another method of estimating
releases is needed. The following example
demonstrates the use of an engineering
calculation to estimate toxic metal releases
via solid waste.
   Example:  Using an engineering
   calculation to estimate toxic releases
   of copper in wastewater treatment
   sludge.
       In an electroplating facility, rinse water
   from a copper-plating unit is treated sep-
   arately from other process wastewater.
   The rinse water is first treated with
   chlorine to oxidize cyanide.  Sodium
   hydroxide is then added to react with the
   Cu in the wastewater. The precipitate
   formedfrom this reaction is removed as
   sludge from the facility's central clari-
   fication unit.

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    The reaction of NaOH and Cu++ in the rinse
    water proceeds as follows:
Cu++
              2NaOH
CufOHL + 2NO++
    For each mole of Cu present in the rinse
    water, two moles ofNaOH must be added
    to precipitate the Cu. Purchasing and
    inventory records indicate that 1,984
    pounds ofNaOH was used for precipi-
    tating Cu last year. The quantity ofCu
    precipitated (and thus the quantity ofCu
    releasedfrom this source of solid waste)
    can be estimated by performing the
   following calculations:

    Molecular weight ofCu= 63.5 Ib/lb-mole
    Molecular weight ofNaOH = 40 Ib/lb-mole
    Amount ofCu released in sludge =
       !,9841bNaOHx
       lib-mole NaOH/40 Ib NaOHx
       1 Ib-mole Cu/2 Ib-mole NaOH x
       63.51bCu/l Ib-mole Cu
       = 1,575 Ib
    The plant in this example could therefore
    report the release of 1,600 pounds of Cu in
    the wastewater treatment sludge.
    It should be noted that the NaOH in this
example only reacted with the Cu present in
the wastewater. If other metal ions are
present, they may also react with the NaOH,
which would make this estimation method
ineffective.  In some instances, however, this
approach can result in a rough approxima-
tion of the quantity of releases.

Toxic Releases to Air
    Typical emissions to air from electro-
plating facilities are fugitive in nature and are
not monitored. Alternative techniques must
therefore be used to estimate air releases.
Releases of toxic compounds contained in
mists evolved from plating and  cleaning baths
can be estimated by mass balance (provided
sufficient information is available on the
quantity of chemical entering and leaving the
process) or engineering calculations.  Sol-
vents emitted to air during metal cleaning
operations can usually be estimated by mass
balance or emission factors as shown in the
following example.
   Example:  Using a mass balance to
   estimate air emissions of 1,1,1-
   trichloroethanefrom a degreasing
   operation.
       In the example presented earlier in this
   pamphlet, an electroplating facility op-
   erating a vapor degreaser used 14,250
   pounds of 1,1,1 -trichloroethane during the
   past year.  The vapor degreaser contains a
   built-in local exhaust ventilation system to
   reduce worker exposure to the solvent.
   This system collects spray solventfum.es
   and exhausts them to the atmosphere
   through the roof of the facility. Spent
   solvent and sludge that accumulate on the
   bottom of the degreaser are collected in 55-
   gallon drums for shipment to an offsite
   solvent reclaimer. Last year, 13 drums of
   spent solvent were sent to the reclaimer.
   Because 1,1,1-trichloroethane is only
   "used" in the process (i.e., it does not
   become part of the product) and it is not
   destroyed during the process or treatment,
   the entire 14,250 pounds of the solvent is
   releasedfrom the facility either as an air
   emission or as solid waste. Thus, if the
   quantity of spent solvent shipped to the
   reclaimer is known, the quantity emitted to
   air can be calculated by mass balance, as
   shown in the following equations:
   Volume of 1,1,1 -TCE to reclaimer =
       13 drums x 55 gal/drum
       = 715 gal
   Mass of 1,1,1 -TCE to reclaimer =
       715 gal x 11.05 Ib/gal
       = 7,900 Ib

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   Amount of 1,1,1 -TCE released to air =
   14,250 tb (purchased) -
       7,900 Ib (to reclaimer)
       ~ 6,350 Ib
   The plant in this example could therefore
   report the release of 6,400 pounds of
   1,1,1-TCE to air and 7,900 pounds
   shipped ojfsite as solid waste.
   Emission factors for estimating releases of
solvents from different types of degreasing
units are presented in the EPA publication,
Compilation of Air Pollutant Emission Factors
(AP-42). To apply these factors properly, you
should carefully read the text that
accompanies them.

Other Toxic Releases
   Electroplating 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
reduces 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
   arid Community
   Right-to-Know
   Hotline
                        (800) 535-0202
                              or
                        (202) 479-2449
                      (In Washington, D.C.
                          and Alaska)
Small Business
   Ombudsman
   Hotline
                        (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 Electroplating
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.
Development Document for Existing Source
Pretreatment Standards for the Electroplating
Point Source Category. EPA 440/1-79/003.
NTIS PB80-196488.  Washington, D. C.
August 1979.
U.S. Environmental Protection Agency.
Assessment of Industrial Hazardous Waste
Practices - Electroplating and Metal Finishing
Industries - Job Shops. NTIS PB-264349.
Washington, D. C. September 1976.
                        B-U.S. Government Printing Office : 1988 - 516-002/80172

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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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