United States
Environmental Protection
Agency
Office of Pesticides
and Toxic Substances
EPA 560/4-88-0041
March 1988
vvEPA Title HI Section 313
Release Reporting
Guidance
Estimating Chemical Releases From
Presswood and Laminated Wood
Products Manufacturing
Emergency Planning and
Community Right-to-Know Act of 1986
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Estimating Chemical Releases From Presswood
and Laminated Wood Products Manufacturing
Facilities engaged in the manufacture of
presswood and laminated wood products 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 (press-
wood and laminated wood facilities generally
fall under SIC codes 2435, 2436, 2492, and
2499) and has 10 or more full-time employ-
ees, 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 pro-
cessed chemicals drops to 50,000 arid 25,000
pounds per year, respectively.
This document has been developed to
assist those who manufacture presswood and
laminated wood products 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 the manu-
facture of presswood and laminated wood
products, 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 manufacture of
presswood and laminated wood products 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.
Phenol-formaldehyde resins: Phenol,
formaldehyde
Urea-formaldehyde resin: Formaldehyde
Melamine-formaldehyde resins: Mela-
mine, formaldehyde
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Dispersion agent (during glue formu-
lation): Sodium hydroxide
Resin catalysts: Ammonium sulfate,
various acids
Chemicals used in finishing operations:
Miscellaneous chemicals found in coat-
ings, stains and dyes, fillers, inks, fire
retardants, and overlay materials
Formaldehyde scavengers: Ammonia,
ammonium sulfate
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 incorpor-
ated into your products (for example, the free
formaldehyde present in glue mixtures
applied to the wood) would be considered
"processed" because they become part of the
marketed finished product. Dispersion
agents, resin catalysts, 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: Determining whether
formaldehyde was used in sufficient
quantities to require reporting under
Section 313.
Trace quantities of free formaldehyde
and phenol are contained in phenol-
formaldehyde resin purchased to formu-
late plywood glue. According to the
supplier's Material Safety Data Sheet
(MSDS), this particular resin contains
0.2 percent free formaldehyde and
0.03 percent free phenol by weight. Under
Section 313 reporting, amounts of chemi-
cals present in purchased mixtures that
are below the de minimis level of 1 percent
(0.1 percentfor carcinogens) do not have to
be considered in threshold and release
calculations. Therefore, no reporting is
required for phenol With regard to
formaldehyde, however, because OSHA
classifies it as a carcinogen and its
concentration exceeds 0.1 percent, this
amount must be counted toward deter-
mination of threshold. If 15,000,000
pounds of this resin was purchased in
1987, 1,300,000 pounds was in storage at
the beginning of the year, and 700,000
pounds was in storage at the end of the
year, the amount of resin processed would
equal:
1,300,000 Ib (beginning inventory) +
15,000,000 Ib (purchased) -
700,000 Ib (ending inventory)
= 15,600,000 Ib
The amount of formaldehyde processed
equals:
15,600,000 Ib x 0.2%
= 31,200lb
Therefore, for the reporting year 1987,
formaldehyde was not processed in
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sufficient quantity to require reporting.
Reporting also would not be required in
1988. In 1989 and beyond, however, this
quantity of formaldehyde would trigger the
reporting requirement.
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
shown below is an example flow diagram of
veneer and plywood production. 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.
Air emissions at presswood and laminated
wood production facilities are primarily from
pressing and drying operations. Other
sources include emissions from sanding and
cutting and fugitive emissions from wood-
finishing operations. Wastewater is typically
generated as a result of process equipment
LIQUID WASTE
GLUE WASH
WATER
AIR EMISSIONS
+
I
GLUE! "'
GLUE
LINE
•« —
RE
CYCLE
— *!
SANDING
AND
CUTTING
SOLID WASTE IS BURNED IN BOILER,
CHIPPED FOR REUSE, OR SOLD
Example Flow Diagram of Veneer and Plywood Production
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cleaning (glue wash water), fire protection,
and the overflow from log storage. Solid
wastes usually consist of wood scraps and
dust, which are often used as fuel for onsite
boilers. Solid wastes also may be generated
in finishing 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
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
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.
At many presswood and laminated wood
production facilities, the primary sources of
listed toxic compounds are glue resins and
adhesives. These materials contain small
quantities of the toxic resin precursors in a
free or unpolymerized state. During process-
ing,, the small quantities of free phenols,
formaldehyde, or melamine in the glue resins
may follow any of the paths listed below:
• Release to air during glue preparation,
glue application, and pressing
• Polymerization during pressing
• Retention in the product
• Retention in scrap and subsequent
combustion as fuel on site
• Release in wastewater during washing
of glue tanks and lines
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The primary difficulty in estimating releases
of these chemicals is determining what
happens to them during pressing. A mass
balance combined with engineering assump-
tions can be used for this purpose:
Amount of chemical in purchased resin =
amount released to air +
amount polymerized during pressing +
amount retained in product +
amount retained in scrap and burned
for fuel +
amount discharged as wastewater
during cleanup of glue tanks and
lines
Toxic Releases to Air
The simplest technique for estimating
releases to the air is to assume that all the
trace quantities of free chemical are vola-
tilized during pressing and are released.
Although this will result in an overestimation
of emissions, it will give a rough idea of the
magnitude of the release.
The mass balance approach can be used
if enough detailed information is available on
the fate of the chemical in various pathways.
Almost all facilities recycle glue-equipment
wash water in the preparation of new batches
of glue. If this is the practice at your plant,
no release of toxic chemicals should occur via
wastewater. Perforator test data on boards,
acknowledged to be a good indicator of the
free formaldehyde content in pressed panels,
can be used to estimate the quantity of
formaldehyde retained in the product and in
the scrap wood. The quantities of free
formaldehyde that react during board
manufacture are generally not known, but
most of the free formaldehyde is believed to
be taken up during the crosslinking reaction.
The press area is the largest contributor to
total plant formaldehyde emissions. Note:
the overall mass balance does not take into
account the use of formaldehyde scavengers,
which could have a significant effect on air
emissions depending on the point in the
process where they are used.
In a survey of formaldehyde emissions
from particleboard plants, the National
Council for Air and Steam Improvement
(NCASI) determined average formaldehyde
emission rates related to percentage of excess
formaldehyde in the resin. The processing
parameters that were found to have an
impact on formaldehyde emission rates were
1) excess formaldehyde in the resin, 2) press
temperature, 3) press cycle time, 4) amount
of adhesive used, and 5) the use of formal-
dehyde scavengers. Results of the survey are
shown below:
Formaldehyde Emissions Survey Data
Parameter
Average Range
Emitted formaldehyde:
lb/1000ft2 0.51 0.22-0.84
(3/4-inch board)
As % of excess HCHO 4.7 1.9-12
in resin
Conditions:
Press temperature (° F) 339 315-385
Ib resin/1000 ft2 216 150-290
(3/4-inch board)
% excess HCHO in
resin (dry basis)
5.9 3.2 - 7.7
Many plants use resins that contain less
than 1 percent free formaldehyde. In lieu of
more detailed data needed to estimate air
emissions via a mass balance, however, the
average percentage of excess formaldehyde in
resin emitted could be used to estimate
releases.
Example: Using an average emission
factor to estimate air releases of
formaldehyde.
In its gluing operations, a particle-
board manufacturing facility used 36,000
pounds per day of a urea-formaldehyde
resin containing 1.0 percent free formal-
dehyde. This facility produced an average
of 300 tons of particleboard per day.
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Amount of excess formaldehyde in resin =
36,000 Ib/dayx 0.01
= 360 Ib/day
Assuming an average of 4.7 percent of the
excess formaldehyde is emitted:
Amount of formaldehyde released to air =
360 lb/day x 0.047
= 17lb/day
These emissions would be reported as
stack emissions if exhausted through the
building ventilation system.
Toxic Releases Via Wastewater
Wastewater is usually not measured di-
rectly for specific toxic chemicals. In lieu of
this information, mass balances and/or engi-
neering calculations can be used to estimate
wastewater releases from individual process-
es. Equipment washdowns generate most of
the wastewater containing toxic compounds.
One method of estimating releases is to
calculate how much material is lost during
each washdown and then to multiply that
amount by the number of washdowns per
year. Multiplying this result by the percent-
age of a toxic chemical in the material will
then yield the quantity released via waste-
water. The quantity of material lost per
washdown can be determined by in-house
measurements, or it can be assumed (for
vessels) that the weight of material lost is
equal to 1 percent of the total weight capacity
of the vessel or tank. The following is an
example of the use of this procedure.
Example: Using an engineering cal-
culation to estimate releases of
formaldehyde in wastewater.
A veneer/plywood facility discharged
glue equipment wash water to a publicly
owned wastewater treatment plant (direct
discharge to streams or other bodies of
water is forbidden). The plant has 3
mixing tanks, each with a capacity of
4,000 gallons. The piping associated with
each tank has a capacity of 6.5 gallons.
The total capacity of these vessels is
therefore:
(3 tanks x 4,000 gal) +
(3 tanks x 6.5 gal/associated piping)
= 12,020 gal
If the glue density is known to be 9.17
pounds per gallon and the amount of glue
residual left on the sides of the mixing
tank and associated piping is assumed to
be 1 percent of the capacity of the tank
and piping, the quantity of glue lost per
washdown is:
12,020 gal (capacity) x
9.17 lb glue/gal x
0.01 lb glue/weight capacity of vessel
= 1,102 lb glue
The plant performed one washdown per
day and operated 250 days per year.
Thus, the total quantity of glue lost per
year is:
1,102 Ibx 250 days
= 275,550 lb glue
On average, the glue formulation used at
this facility contained 50 percent raw resin
solution containing 0.2 percent formal-
dehyde. Thus, the total quantity of
formaldehyde released in wastewater per
year is:
275,550 lb x 0.50 x 0.002
= 276 lb formaldehyde
Using this approach, the plant in this
example could report releases of 280
pounds of formaldehyde to wastewater.
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
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the "manufactured" threshold value has been
reached. For example, sulfuric acid neutral-
ized by sodium hydroxide yields sodium
sulfate, which is a listed chemical.
Toxic Releases Via Solid Waste
Solid wastes from presswood and lam-
inated wood production facilities consist
primarily of wood scraps and dust from
trimming operations. If this material is used
as fuel in an onsite boiler, it may be assumed
that no toxic chemicals are released in this
form. If the scrap wood contains compounds
that are not completely destroyed during
combustion, however, you must account for
the release of these compounds. If the wood
scraps are shipped offsite or landfilled, any
toxic compounds that have been incorporated
into the wood are considered transferred to
an offsite facility or released to land,
respectively.
Example: Using measured process
data to estimate solid waste releases
of formaldehyde.
A particleboard facility produces an
average of 300 tons of particleboard per
day and estimates that the wood trim and
dust wastes generated amount to 10 per-
cent of total particleboard production. The
wood waste is generated 250 days per
year and is shipped offsite. Perforator
tests routinely performed on samples of
particleboard average 30 milligrams of
formaldehyde per 100 grams of particle-
board (30 pounds formaldehyde per 50
tons of product).
The quantity of free formaldehyde
retained in the wood waste can be
calculated as follows:
' Amount of formaldehyde transferred
offsite in solid waste =
300 tons/day x 0.1 x
30 Ib formaldehyde/50 tons board x
250 days/year
= 4,500 Ib
Other Toxic Releases
Other wastes in the presswood and lam-
inated wood products industry from which
toxic chemicals may be released include:
• Residues from pollution control
devices
• 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 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 percent 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.
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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
removal efficiency.
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For More Information
Emergency Planning
and 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, 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.
Additional Sources of Information
on Releases From Presswood and
Laminated Wood Products
Manufacturing
U.S. Environmental Protection Agency.
Compilation of Air Pollutant Emission
Factors, AP-42. Research Triangle Park,
North Carolina. September 1985.
U.S. Environmental Protection Agency.
Control Techniques for Organic Emissions
From Plywood Veneer Dryers. EPA-450/3-
83-012. NTIS No. PB83-228247. May 1983.
U.S. Environmental Protection Agency.
Multimedia Pollution Assessment of the Wood
Products Industries. EPA-600/2-81-008.
NTIS No. PB84-160266. February 1984.
U.S. Department of the Interior, Federal
Water Pollution Control Association. Plywood
Plant Glue Wastes Disposal. Technical
Projects Report No. FR-5. NTIS No. PB-
217183. January 1969.
U.S. Environmental Protection Agency. Eval-
uation of Emission Factors for Formaldehyde
From Certain Wood Processing. Operations.
EPA 450/3-87-023. October 1987.
*U.S. Government Printing Office : 1988 - 516-002/80166
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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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