United States
           Environmental Protection
           Agency
Office of Pesticides
and Toxic Substances
EPA 560/4-88-004k
February 1988
wEPA     Title III Section 313
           Release Reporting
           Guidance
           Estimating Chemical Releases From
           Paper and Paperboard Production

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            Estimating Chemical Releases From
              Paper and Paperboard Production
   Facilities engaged in paper and paper-
board production 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 (paper and paperboard facilities
generally fall under SIC codes 2621 and
2631) 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
processed chemicals drops to 50,000 and
25.0OO pounds per year, respectively.
   This document has been developed to
assist those engaged in paper and/or paper-
board production 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 paper or
paperboard production, 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
outlined 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 paper and paperboard
production that are subject to reporting
under Section 313. This list does not nec-
essarily 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.
Papermaking Additives
   Sizing agents: Styrene-maleic anhydride
   copolymer (precursors), sulfuric acid,
   styrene-butadiene, acrylamide
   Wet- and dry-strength agents:
   Epichlorohydrin-based resin (precursors),
   melamine resin (precursors), urea-
   formaldehyde resin (precursors),
   formaldehyde

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    Adhesives: Aciylamide, ammonia
    Dyes and pigments: Acid Blue 9, Acid
    Green 3, Basic Red 1, Direct Blue 6,
    Direct Brown 95, Direct Black 38,
    Phthalocyanide Blue, potassium
    dichromate, lead compounds, benzidine,
    o-tolidine, cobaltic oxide, urea-
    formaldehyde resin (precursors)
    Binders:  Styrene-butadiene (precursors),
    polyvinyl acetate (precursors)
    Pigment fillers/coatings: Aluminum
    oxide, barium sulfate, styrene-butadiene
    polymer (precursors), titanium dioxide,
    zinc oxide, zinc sulfide, asbestos,
    phosphoric acid
    Humectants: Melamine-formaldehyde
    resin (precursors), urea-formaldehyde
    resin (precursors)
    Coatings:  Ammonia, diburyl phthalate,
    sodium hydroxide, potassium ferric
    cyanide,
    Oil-resistant additives: Fluorochemical
    chrome complex, ethylene glycol
    monobutyl ether (a glycol ether)
    Flame retardants:  Ammonium sulfate,
    antimony trioxide
Machine Operating Aids
    Retention aids:  Dicyano diamide,
    eplchlorohydrin copolymer (precursors),
    asbestos
    Biocides and slime control agents:
    Acrolein, phenyl mercuric acetate,
    pentachlorophenol, ethylene glycol,
    1,1,1-trichloroethane, trichlorophenol
Waste Paper Pulp Preparation Chemicals
    Deinking agents: Sodium hydroxide and
    solvents
    Bleaching chemicals: Chlorine, chlorine
    dioxide, zinc hydrosulfite, sodium
    hydroxide, sulfuric acid, methanol,
    chromic sulfate
    Chemicals imported in waste paper:
    Ink pigments, coating agents, binders,
    adhesives
    Other chemicals commonly found in
    paper mill wastes: Chloroform, phenol,
    toluene
    Many of these chemicals are polymers,
 which are not listed as toxic; however, their
 monomer precursors are. These polymers
 usually contain a small percentage of the
 unreacted or free monomer. For example,
 urea-formaldehyde resin used as wet-
 strength agent usually contains less than
 1.5 percent free formaldehyde. The toxic
 chemicals in the wastepaper your facility
 imports probably contain many of the same
 chemical additives used in your process plus
 various inks and coatings.
             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
papermaking additive) would be considered
"processed" because they become part of the
marketed finished product. Degreasing
solvents, cleaning agents, and other chemi-
cals that do not become part of the finished
product (for example, machine operating aids)
would be considered "otherwise used."

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   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 insufficient
   quantity last year to require reporting
   under Section 313.
       A slime control agent used on a
   Fourdrinier paper machine contains 7.2
   percent 1,1,1-trichloroethane.  In 1987, a
   plant purchased 18,000 pounds of this
   agent, had 3,000 pounds in storage at the
   beginning of the year, and had 6,000
   pounds in storage at the end of the year.
   The quantity of 1,1,1 -trichloroethane used
   by this facility equals:
       (3,000 Ib x 0.072) (beginning
       inventory) +
       (18,OOO Ib x 0.072) (purchased) -
       (6,000 Ib x 0.072) (ending inventory)
       = 1,080 Ib             "' -
       The slime-control agent is considered
    "otherwise used," so the threshold re-
   porting quantity is 10,000 pounds per
   year. Therefore, this facility did not have
   to report emissions of 1,1,1 -trichloroethane
   for 1987 (assuming this was the only
   source of this chemical).
   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 metal compounds, base
threshold determinations on the amount of
metal compound, not the amount of parent
metal.
   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 oh the next page is an example flow
diagram for papermaking. 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 re-
sulting from the operation of each unit.
    The primary sources of wastewater at
papermaking facilities are as follows:
    •  Excess white water from savealls,
       sealing pits,  or other tank overflows
    •  Rejects from stock-cleaning devices
       (centrifugal cleaners, screens, and
       junk traps)
    •  Deinking wastewater from centrifugal
       cleaners, washers, deckers, and
       thickeners
    •  Bleaching wastewater generated
       during preparation of hypochlorite
       and chlorine dioxide and that coming
       from various washers
    •  Felt- and wire-cleaning waters
    •  Cooling-water discharges
    •  Boiler blowdown and other
       miscellaneous discharges

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               VIRGIN
                PULP
ULP       I
I     II
             DEINKED WASTEPAPER PULP
             WASTEPAPER PULP

CHEMICAL
ADDITIVES


1

fe
fe
r
STOCK
PREPARATION
*
PULP
CHEST
L
r *
REFINERS
                                                     MAIN PROCESS
                                                     SECONDARY PROCESS
                                                     PROCESS WASTE LINE
Example Flow Diagram of Paper Manufacturing Process

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   The primary sources of solid waste are as
follows:
   •   Fibers, fillers, and broke from the
       paper machine
   •   Coating residue and broke from
       finishing operations      ";
   •   Cleaner and junker rejectsTfrom
       wastepaper processing
   •   Wastewater treatment sludge
   Air emissions from papermaking facilities
are generally fugitive and they usually occur
in the following process areas:
   •   Bleach plant
   •   Paper dryers          ..„,...,.
   •   Paper machine
   •   Coating and finishing machines

   •   Mixing vats              -
   •   Wastewater treatment volatilization
   You must account for all releases in your
reporting.
             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
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.
    Direct measurements of waste streams
(sources) for most of the listed toxic chemi-
cals typically found at papermaking facilities
are not made routinely. Also, emission
factors are not generally available; however,
you may have developed some factors for
your own facility.  Mass balances can be
performed if information is available on the
quantity of chemical purchased and the
quantity retained in the paper product. The
difference between these two quantities

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represents the quantity of chemical released,
assuming none of the chemical is destroyed
during processing or treatment. This does
not provide information on the media into
which the chemical is released, however. If
this information is unknown, you will have to
use engineering calculations or assumptions
to complete the estimation.
   The following subsections present infor-
mation on the estimation of releases via
wastewater, air emissions, and solid waste.
The discussions focus primarily on mass
balances and engineering estimates. The
following table presents generalized assump-
tions regarding the fate of chemicals in paper
production. These general assumptions are
based on their point of input in the process
and their relative volatility. These assump-
tions may prove helpful during emission
estimation; however, you should approach
each reported chemical individually.  The
fates of compounds considered semivolatile or
reactive are more difficult to follow, and the
assumptions in this table may not be
applicable.
 Toxic Releases Via Wastewater
    Typically, wastewater from all parts of a
 paper-making facility are centrally collected
 and treated before they are discharged to a
 nearby body of water (direct discharge), a
 publicly owned treatment works (indirect
 discharge), or a land-application operation.
 Listed toxic compounds in the wastewater are
 considered released to water, transferred to
 an offsite facility, or released to land, de-
 pending on the method of discharge.
    Your facility probably discharges waste-
water under the authority of an NPDES per-
 mit (direct discharge) or a local pretreatment
permit (indirect discharge). These permits
likely have  discharge limits on zinc, penta-
chlorophenol  (PCP), and trichlorophenol
 (TCP), and they may also have limits on other
compounds. You can use the direct measure-
ment data collected to monitor compliance
with these permits to estimate releases of
these chemicals. You also may use any other
direct measurements of toxic compounds.
                         Chemical Fate Assumptions in Papermaking
Chemical
reporting status
Otherwise used
or imported

Processed

Process
• input
point
Wet end
Dry end
Wet end
Dry end
Relative
volatility
Nonvolatile
Volatile
Nonvolatile
Volatile
Nonvolatile
Volatile
Nonvolatile
Volatile
Probable fate in process
Wastewater, solid waste
Air emissions
Solid waste
Air emissions
Paper product, wastewater, solid waste
Air emissions
Paper product, solid waste
* Air emissions
                                            6

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   When direct measurement data are not
available, an alternative method of estimation
is needed. Mass balances can be made if
sufficient information is available on the
quantity of chemicals purchased and the
quantity of chemicals retained in the product.
An engineering assumption can then be used
to determine what fraction of the waste
chemical is released to wastewater, air, or
solid waste.
   This method of estimation lends itself well
to those chemicals that are considered
"otherwise used" (that is, they do not become
part of the product), such as deinking agents,
bleaching chemicals, chemicals imported in
the wastepaper, and slime-control  agents.
Because these chemicals do not become part
of the paper product, the quantity as waste
equals the amount used or imported (except
for compounds that undergo chemical
transformation during processing or waste
treatment).
   Example: Using a mass balance and
   engineering assumption to estimate
   releases ofethylene glycol via
   wastewater.
       In 1987, a papermaking facility used
    12,200 pounds ofethylene glycol (EG) in a
   biacide formulation applied on the wet end
   of its paper machine. To estimate releases
   of this compound, it can be assumed that
   EG does not become part of the paper
   product, because its mLscibility  in water
   causes it to be removed almost  completely
   from the paper web during the forming and
   pressing functions. It can further be
   assumed thatfugitwe air emissions of EG
   are unlikely because of its low volatility
    (vapor pressure = 0.1 mmHg at 18°C).
       After forming and pressing functions
    are completed,, the white water in the
    system carries the EG through a saveall.
   A portion of the filtered white water is
    discharged as wastewater, and the rest is
    recirculated. Assuming that none is
    retained in the product or emitted to air, on
    a mass balance basis, all of the EG will
    eventually end up in the wastewater.  All
    12,200 pounds of EG was therefore
    contained in this facility's wastewater.
       If the facility discharged the waste-
    water to a POTW, a transfer of 12,200
    pounds of EG to an offsite disposal facUtty
    would be reported. If the wastewater was
    pretreated before discharge, the amount of
    EG removed from the wastewater would
    be subtracted from the 12,200 pounds.
    Mass balance estimation is more difficult
and less accurate for papermaking additives
that become part of the paper product. In
this case, engineering calculations and
assumptions can be used alone.  For non-
volatile paper additives that enter the process
before the forming section, the concentration
of chemicals in the white water discharged as
wastewater can be set (by engineering
assumption) to be equal to their solubility in
water. The engineering assumption is
developed as follows. The finished solution
entering the paper machine is saturated with
the paper additive because it is retained as a
solid in the paper as the web is formed. The
white water generated from the forming
section is also saturated because more solids
are removed from solution at the saveall. The
wastewater discharged from the saveall or
reused in the sealing pits or cooling water
and subsequently discharged can thus be
assumed to be saturated. The solubility of a
chemical in water is thus an approximation
of the concentration of that chemical in the
wastewater discharged from this section of
the plant. Solubility data for many of the
Section 313 chemicals can be found in
Appendix B of the Section 313 general guid-
ance document.
    Example: Using an engineering
    assumption to estimate releases of
    zinc oxide via wastewater.
       During 1987, a papermaking facility
    discharged an average of 200,000 gallons
    of treated wastewater per day to a nearby
    river. Zinc oxide, which was used as a
    paper filler, was added to the refiner. An
    estimated 45 percent (or 90,000 gallons
    per day) of the wastewater from the entire

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 facility was generatedfrom the area in
 which the zinc oxide was used. Assuming
 that the zinc oxide concentration in the
 wastewater is equal to its solubility in
 water (0.00042 pound per 100 pounds
 H2O), the quantity of zinc in the raw
 wastewater can be calculated asfoUows:
 Amount ofZn in raw wastewater =
    0.00042 Ib ZnO/100 Ib H2O x
    8.34 Ib H2O/1 gal H2O x
    90,000 gal H20/l day x
    0.802 IbZn/l IbZnO
    « 2.52 Ib
 If the plant operated 350 days during the
 year, the total amount of zinc released
from the process into the wastewater
 would therefore be 882 pounds.
    The preceding calculations were used
 to estimate the quantity of zinc in the raw
 wastewater. The operators of this facility
 developed a treatment factor to consider
 the treatment before discharge for various
 toxic compounds. They reviewed the
 literature on waste treatment in paper-
 making facilities (see the reference section
 at the end of this pamphlet), focusing on
 information applicable to the production
process and treatment system at their
facility. They found that 80 percent of the
zinc is removedfrom the facility waste-
 water. Because zinc cannot be destroyed
during treatment, the amount removed
was actually transferred to the  waste-
water sludge, which was subsequently
landfilled on site. Thus, this zinc must be
considered as having been released as
solid waste. The remaining 20 percent of
the zinc (176 pounds) passed through
treatment and was released to water; 80
percent (706 pounds) was partitioned to
the wastewater sludge, which is sub-
sequently landfilled on site.  Using this
approach, the plant in this example could
therefore report a release to land of 710
pounds of zinc.
    The waste treatment efficiency in the
 preceding example was derived from the
 literature.  The best method of estimating
 treatment efficiency is by direct measurement
 of the treatment process influent and efflu-
 ent. A treatment efficiency can be developed
 for any number of chemicals by conducting a
 direct measurement test program (monitoring
 the influent and effluent throughout the year
 is not necessary). In lieu of direct measure-
 ment, the use of literature sources is prob-
 ably the best method of estimating treatment
 efficiency.
    If your facility uses a listed mineral acid
 or base, but that 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 for these substances. If
 the acid or base is transformed into a re-
 portable substance, however, the quantity of
 this substance manufactured must be esti-
 mated to determine if the "manufactured"
 threshold value has been reached. For exam-
 ple, sulfuric acid neutralized by sodium
 hydroxide yields sodium sulfate, which is a
 listed chemical.

 Toxic Releases Via Solid Waste
    Solid wastes are rarely measured directly
 for most of the listed toxic compounds, and
 emission factors are not generally available.
 Mass balances can be performed to determine
 toxic releases, provided sufficient data are
 available on the quantity of chemicals in the
 product and/or wastewater. Engineering
 calculations that assume the chemical con-
 centration in the solid waste is the same as
that in the paper product can also be used.
In the case of wastewater sludge,  however,
 direct measurement would be required or an
estimate would have to be based on the
treatment of the raw wastewater.
    Example:  Using a mass balance and
    an engineering assumption to estimate
    releases of titanium dioxide.
      During 1987, a papermdking facility
   produced 150,000 reams (1 ream = 3,300
                                         8

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    square feet) of a fine paper with a coating
    weight of 45 pounds per ream. The
    coating was applied, by air knife at the dry
    end of the facility. According to operating
    records, the coating contained 4.3 percent
    titanium dioxide CnOJ on a dry basis. EPA
    has proposed to remove TiO2from the
    Section 313 list; however, this example is
    also representative of the use of a mass
    balance and an engineering assumption to
    estimate releases of other similar com-
    pounds. The quantity ofTiO2 leaving the
   facility in the product can thus be
    calculated as follows:
    Amount of TiO2 =
       150,000 reams x
       45 Ib dry coating/I reamx
       0.043 Ib TiO2/l  Ib dry coating
       = 290,250 Ib
    A review of purchasing and storage
    records at the facility shows that 300,000
    pounds ofTiO2 was processed last year.
    By mass balance, the quantity ofTiO2 lost
    to waste is calculated, by determining the
    difference between the amount processed
    and the amount in the product.
    Amount ofTiO2 released as solid, waste =
       300,000 Ib processed -
       290,250 Ib in product
       = 9,750 Ib
    Because TiO2 is nonvolatile, no air emis-
    sions would, be expected, and all of the
    TiO2 waste is assumed to be released as a
    solid, waste (coating residue and broke
   from finishing). Using this approach, the
    plant in this example could, therefore report
    releases via. solid, waste of 9,800 pounds
    QfTi02.

Toxic Releases to Air
    Because of the fugitive aspect of most air
releases, these emissions are not often
measured directly, and emission factors are
generally not available for most compounds.
For bleach plant air releases of chlorine and
chlorine dioxide, however, the following
emission factors (taken from the EPA publi-
cation, Environmental Pollution Control in
the Pulp and Paper Industry) can be used.
    •   When vacuum rotary drum washers
       are used, total uncontrolled chlorine
       emissions from the bleach tower vent
       and from the hood vent of the suc-
       ceeding washing stage amount to
       about 1.0 pound of C12 per ton of
       pulp.
    •   If a bleach plant has two chlorine
       dioxide stages, C1O2 is emitted from
       both the washer hood vents after the
       bleach towers and from the C1O2
       manufacturing process. If vacuum
       rotary drum washers are used, total
      . C1O2 emissions amount to about 0.6
       pound of C1O2 per ton of pulp.

    •   Plants that use pressure washers or
       continuous diffusers will have lower
       emissions for both C12 and C1O2.
   Air emissions of paper additives and
machine operating aids can occur from
numerous locations in the process (for exam-
ple, mixing and formulation, paper forming,
drying, coating, finishing). As a result, all
emissions of highly volatile compounds are
likely to be to air. The release estimate will
thus consist of simply determining how much
of the chemical was introduced in the process
and then assuming that all of it is emitted to
air.
   Estimating the release of other com-
pounds that are only semivolatile or that
chemically react during the process is not as
simple.  You must first evaluate the physical
properties of the chemicals (for example,
solubility and vapor pressure) and then use
simplifying engineering assumptions and
calculations based on operating conditions of
the process to estimate emissions.

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 Example: Using a mass balance with
 an engineering assumption to estimate
 air releases of formaldehyde.
    During 1987, a papermaking facility
 used 100 tons of urea-formaldehyde resin
 as a wet-strength agent in the wet end of
 its process and 200 tons as a coating
 component in the dry end. The urea-
formaldehyde resin contained ap-
 proximately 1.5 percent of the free-
formaldehyde precursor.  Thus, 3,000 and
 6,000 pounds of free formaldehyde were
 processed as part of the resin. An ad-
 ditional 17,000 pounds of formaldehyde
 was used as a wet-strength additive.
 Altogether, a total of 26,000 pounds of
formaldehyde was processed at the
facility.
 '   Formaldehyde is volatile, but it is also
 highly soluble in water. Formaldehyde
 releases can be estimated for both the wet
 end and the dry end of the process. In the
 dry end, the free formaldehyde is con-
 tained in the coating formulation. After the
 coating is added, the paper is transported
 through a dryer, where all of the formal-
 dehyde can be assumed to be released to
 air (6,000 pounds).
    In the wet end of the process, the free
formaldehyde is contained in the finish
 that enters the paper machine.  During
paper forming, a portion of the formal-
 dehyde will volatilize as the web forms on
 the paper machine, a portion will leave in
 the white water during pressing, and
 another portion will remain in the web and
 volatilize as the web passes through the
dryer. One portion of the white water is
 recovered in the saveall and returned to
 the process; another portion is released to
 the facility sewer or recycled as sealing
water or cooling water for subsequent
    release to the sewer. In either case, it is
    probably safe to assume that all of the
    formaldehyde will be volatilized either in
    the process or during wastewater
    treatment.  Determining which portions of
    less-volatile chemicals are released to
    water or air would require an assumption
    based on the specific layout of the facility.

 Other Toxic Releases
    Other wastes in the paper and paper-
 board production industry 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 the 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.
                                         10

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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.
                                           11

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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.
Additional Sources of Information
on Releases From. Paper and
Paperboard Production
U.S. Environmental Protection Agency. Fate
of Toxic and Nonconventional Pollutants in
Wastewater Treatment Systems Within the
Pulp, Paper, and Paperboard Industry. EPA-
600/2-81 /158. NTIS PBS 1 -247405.
Cincinnati, Ohio.  August 1981.
U.S. Environmental Protection Agency. De-
velopment Document for Effluent Limitations
Guidelines and Standards for the Pulp,
Paper, and Paperboard Point Source Cate-
gory. EPA-440/1-82/025.  NTIS PB83-
163949. Washington, D.C.
U.S. Environmental Protection Agency. Paper
Production and Processing - Occupational
Exposure and Environmental Release Study.
EPA-600-2-84-120. NTIS PB84-215730.
Cincinnati, Ohio.  July 1984.
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.
Environmental Pollution Control in the Pulp
and Paper Industry - Part I/Air. EPA-625/7-
76-001. NTIS PB-261708. Cincinnati, Ohio.
                                         12
                        *U.S. Governoent Printing Office : 1981 - 516-002/80160

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