United States
Environmental Protection
Agency
Office of Pesticides
and Toxic Substances
EPA 560/4-88-004h
February 1988
SEPA Title HI Section 313
Release Reporting
Guidance
Estimating Chemical Releases From
Textile Dyeing
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Estimating Chemical Releases From
Textile Dyeing
Facilities engaged in textile dyeing 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 Reauthprization
Act (SARA) of 1986. If your facility is classi-
fied under SIC codes 20 through 39 (textile
dyers generally fall under SIC code 22) and
has 10 or more full-time employees, for
calendar year 1987 you must report all envi-
ronmental releases pf any Section 313-listed
chemical or chemical category manufactured
or processed by your facility in ah amount
exceeding 75,000 pounds per year or other-
wise 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 textile dyers 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 textile dyeing,
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 textile dyeing 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 chemi-
cals that you do not use. You should also
determine whether any of the listed chemicals
are created during processing at your facility.
For example, using an alkaline sodium salt to
raise the pH of acidic solutions of sulfate will
create sodium sulfate (solution), which is a
listed substance.
Dyes specifically listed: Disperse-Yellow
3, Acid Green 3, Auramine, Basic Red 1,
Basic Violet 10, Basic Green 4, Direct
Brown 95, Direct Black 38
Cobalt-containing dyes: For example,
some neutral premetallized dyes
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Copper-containing compounds:
Including dyes and fixatives
Chromium-containing compounds:
Including dyes, oxidizing agents, and
mordants/fixatives
Oxidation bases: Catechol, p-phenylene-
dlamine, aniline black
Carriers, swelling agents: Biphenyl
Dyeing aids: Sodium hydroxide (caustic
soda), sodium sulfate (Glauber's salt),
formaldehyde, ethylene glycol, perchloro-
ethylene, tetrachloroethylene
Flame retardants: Aluminum oxide
pH adjusters: Ammonium sulfate,
phosphoric acid
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, dyes
that are incorporated into textile articles)
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
perchloroethylene through purchases
and inventory changes.
Opening stock
Plus purchases during year
Less closing stock
Total use, . ,..,
5,000 Ib
12,000 Ib
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: Calculating annual use of
chromium, compounds.
15,000 Ib chromium dye A
(containing 80% chromium
compound)
10,000 Ib chromium dye B
(containing 40% chromium
compound)
25,000 Ib chromium dye C
(containing 80% chromium
compound)
30,000 Ib sodium dichromate
(93% technical grade)
12,000 Ib
4,000 Ib
20,000 Ib
27,900 Ib
63,900 Ib
The processing threshold applies
because these compounds, including the
sodium dichromate, are incorporated into
the textile Jiber. The 1987 processing
threshold of 75,000 pounds is not
exceeded, however.
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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 textile
dyeing. 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.
SCOURING AGENTS
BLEACHES
DESIZING AGENTS
WATER
DYEING AIDS
CARRIERS .
WATER
FIXATIVES
WATER
SUBSTRATE
I
PRETREATMENT
1
DYEING UNIT
1 r
POST DYEING
DISCHARGE
TO STREAM
ORPOTW
ONSITE
-^ WASTEWATER
TREATMENT
I"
SLUDGE
TO DISPOSAL
T
DYED SUBSTRATE
Example Flow Diagram of Textile Dyeing
The primary release of any of the chemi-
cals you use is likely to occur in the waste-
water from the dyeing process. If wastewater
is treated on site, you may also have sludge
or other wastes containing the chemical.
Other releases may come from discarded
containers or samples, equipment washings,
or, in some cases, 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
facilities 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
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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
You are unlikely to have wastewater
monitoring data specific to most of the dyes
or other chemicals you process or use. In the
absence of such data for wastewater, you can
estimate the release in one of the following
ways.
1) Release from batch or continuous
dyeing
"Loss" of dye in process water can be cal-
culated as dye processed less dye exhausted
onto fiber:
Amount of dye lost to water =
amount of dye used x
(1 -fraction exhaustion)
The large number of dye baths in a year
and the variation of exhaustion with dyeing
conditions make this a complicated analysis.
An acceptable simplified approach is to apply
an estimated average percentage of exhaus-
tion for the dyes processed instead of making
individual calculations for each dye bath.
The percentage exhaustion for a dye may be
based on your own measurements, manu-
facturer's data, or published information.
If a continuous dyeing or printing process
is operated, add any amount of unused dye
or printed paste removed from the process.
For the latter, include estimates of losses in
screen washing. Your estimate should be
based on knowledge of the volume of unused
bath and the concentration of chemicals in
the bath.
2) Release of nonvolatile and nonsub-
stantive dyeing aids
Most dye bath chemicals other than the
dyes themselves are not retained in the fibers
and most materials used in "wet processes"
will be lost to water. Water releases can be
calculated as the amount used less any other
known losses. For example, if "empty" drums
still containing 1 percent of a dye carrier are
landfilled and the only other release is in the
process water, 99 percent of the dye carrier
would be lost to water.
3) Release of metal-containing com-
pounds ;
When compounds contain chromium,
copper, cobalt, or other metals, releases
should be reported for the metal only. If
monitoring data are available for any of these
metals, you can calculate the release as:
Amount of metal released to water =
- " concentration in wastewater x
daily volume of wastewater x
days/year for which data apply
Review all monitoring data for the metal
to determine an average representative con-
centration to use in this calculation. If no
monitoring data exist, calculate releases
based on exhaustion data, but adjust for the
metal content. For example, in the case of a
chromium-complex dye;
Amount of chromium, released to water =
weight of dye x
weight percent of chromium x .
(1 -fraction exhaustion)
Your estimate of the release of each metal
to water must take into consideration each
compound containing that metal.
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4) Releases of acids and bases
If a listed mineral acid or base is used at
your facility but is effectively neutralized in
use or during wastewater treatment (to pH
6 to 9, as required by the effluent guidelines
for most textile dyers), no release quantities
should be reported for the acid or base.
Sodium sulfate solution, a listed sub-
stance, is used as a processing aid, whether
its source is as a diluent in the purchased
dyes or as sodium sulfate purchased sep-
arately. Sodium sulfate also may be manu-
factured during the neutralization of sulfuric
acid. Because the threshold for reporting is
lower for used substances than for
manufactured substances, in nearly all cases
you should focus on the amount of sodium
sulfate you use when determining whether a
threshold is exceeded.
Total release equals the sum of sodium
sulfate content in each dye or other formu-
lations and the sodium sulfate produced by
neutralization of sulfuric acid. The quantity
of the latter can be calculated as:
Amount of sodium sulfate =
amount of sulfuric acid usedx
142 (the molecular weight of sodium
sulfate) -s-
98 (the molecular weight of sulfuric
acid)
5) Release after treatment
If wastewater treatment occurs on site,
you should adjust the total losses to yield
"release" for purposes of reporting. If avail-
able, use actual plant operating data on
removal efficiency. Published data also may
be used if available for the dye or other
chemical treated by the method used at your
plant (for example, biological wastewater
treatment). The amount of chemical released
to water after treatment can thus be cal-
culated as:
Amount of chemical released to water =
amount lost in process water x
(1 - treatment efficiency)
If no data are available, assume that the
treatment does not remove the chemicals
(that is, the treatment efficiency is zero).
Toxic Releases Via Solid Waste
During wastewater treatment, a listed
chemical may be transferred to sludge. For
the listed metals, loss in the sludge may be
calculated as:
Amount of metal in sludge =
amount lost from process-
amount lost til water .
Alternatively, you may calculate the quantity
directly if you have data on the concentration
of metals in your sludge.
For organic chemicals in general, some
degradation may occur during treatment,
which means that all of the chemical removed
from water is not transferred to the sludge.
The amount of organic compounds in the
sludge may be estimated by using measured
data or by subtracting the amount degraded
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.
Toxic Releases to Air
Some of the chemicals you use are vola-
tile enough so that air releases will occur
either during process steps or during waste
treatment. Air releases are most easily
estimated by subtracting all other known
releases from the amount used.
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Example: Estimating perchloro-
ethylene air releases from dry
cleaning.
In 1987, a plant used 20,000 pounds
ofperc to dry clean samples. Manifests
show that 5,000 pounds of spent perc was
sent offsite for disposal. Therefore, air
releases were:
Amount ofperc released to air -
20,000 Ib used -
5,000 Ib to offsite disposal
= 15,000 Ib
Other Toxic Releases
Other wastes in textile dyeing from which
toxic chemicals may be released 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.
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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, Emergency Planning
and Community Right-to-Know Act, Section
313 Release Reporting Requirements (EPA
560/4-88-001) 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 reporting requirements, and what
must be reported. It also contains a complete
listing of the chemicals and chemical cate-
gories 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 informa-
tion on general release estimation techniques
than is included in this document.
Government Printing Office : 1988 -516-002/80165
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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
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