EPCRA SECTION 313
DATA QUALITY INSPECTION MANUAL
&EPA
U. S. Environmental Protection Agency
Office of Compliance Monitoring
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EPCRA SECTION 313
DATA QUALITY INSPECTION MANUAL
vvEPA
U. S. Environmental Protection Agency
Office of Compliance Monitoring
-------
DISCLAIMER
This document was prepared by the United States Environmental Protection
Agency with editorial assistance from Science Applications International
Corporation (SAIC) under EPA Contract 68-C8-0066, Work Assignment C-4-84.
International Technology Corporation prepared Chapter Two and the profiles
provided with this document under EPA Contract 68-DO-0020, Work Assignment
No. 2-27/2-65/3-18, JTN 830015-5-1. Neither the U.S. Environmental
Protection Agency nor its employees makes any warranty, express or implied,
or assumes any legal liability for any third party's use of or the results of such
use of any information, product, or process discussed in this document. Mention
or illustration of company or trade names, or of commercial products, does not
constitute endorsement by the U.S. Environmental Protection Agency.
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Table of Contents
Table of Contents
Chapter One: Introduction 1-1
1.1 EPCRA Section 313 1-1
1.2 EPCRA Section 313 Enforcement and Data Quality : . . . 1-2
1.3 Purpose of This Manual 1-5
Chapter Two: EPCRA Data Quality and Nonreporters Targeting 2-1
2.1 Identification of Possible Nonreporting Facilities 2-2
2.2 Identification of Data Quality Problems ' 2-5
2.3 Common Errors - 2-12
Chapter Three: Pre-Inspection Activities 3-1
3.1 Introduction 3-1
3.2 EPCRA and Multimedia Inspections 3-2
3.3 Review of Facility and EPA Records 3-3
3.4 Providing Advance Notification 3-10
3.5 Pre-Visit Completion of the Inspection Checklist 3-12
3.6 Section 1.0 of the Inspection Checklist: Telephone Contact 3-16
3.7 . Development of an Inspection Plan ". 3-20
3.8 Collection of Inspection Documents 3-23
Chapter Four: Industrial Profiles for Section 313 Nonreporter
and Data Quality Inspections 4-1
4.1 Introduction 4-1
Chapter Five: Entry to the Facility and the Opening Conference 5-1
5.1 Introduction 5-1
5.2 Authority to Enter and to Inspect 5-1
5.3 Consent to Enter and Inspect 5-2
5.4" Opening Conference 5-8
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Table of Contents
Chapter Six: Onsite Evaluation of Data Quality 6-1
6.1 Introduction 6-1
6.2 EPCRA Section 313 Chemicals 6-1
6.3 Facility Tour Activities 6-3
6.4 Review of EPCRA Section 313 Chemicals 6-12
6.5 Reasons for Reporting Errors/Data Discrepancies 6-40
Chapter Seven: Closing Conference 7-1
7.1 Introduction .7-1
7.2 Inspection Findings 7-1
7.3 Confidentiality Claims 7-2
7.4 Compliance Outreach 7-2
Chapter Eight: Post-Inspection Activities 8-1
8.1 Introduction 8-1
8.2 Followup Activities 8-1
8.3 The Inspection Report 8-2
8.4 Submitting the Inspection Report 8-4
Industry Profiles
Appendix A: Section 313 Form R A-l
Appendix B: Section 312 Tier I and II Reports B-l
Appendix C: Sample Supplier Notification Letter C-l
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Chapter One Introduction
Chapter One
Introduction
1. Introduction 1-1
1.1 EPCRA Section 313 1-1
1.2 EPCRA Section 313 Enforcement and Data Quality 1-2
1.2.1 Headquarters-Regional Memorandum of Agreement Process and the Enforcement
Response Policy 1-4
1.3 Purpose of This Manual 1-5
List of Figures
Figure 1-1 Standard Industrial Classification Groups Subject to Section 313 1-3
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Introduction Chapter One
BLANK PAGE
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Chapter One Introduction
1. Introduction
On October 17, 1986, the Federal Superfund Amendments and Reauthorization Act (SARA) was enacted
into law. The Emergency Planning and Community Right-to-Know Act (EPCRA) is Title III of SARA.
EPCRA is designed to help communities deal safely and effectively with the numerous toxic and
hazardous chemicals used daily in our society. It contains provisions that improve emergency planning
for toxic and hazardous chemicals and require facilities to identify hazardous chemicals present onsite and
toxic chemicals released into the environment.
1.1 EPCRA Section 313
Specifically, Section 313 of EPCRA addresses reporting requirements for the release of toxic chemicals.
This section has three primary requirements:
• Covered facilities must submit annual reports to the States and the Environmental Protection
Agency (EPA) on the amounts of toxic chemicals released to the environment or transferred
offsite. Toxic chemicals are defined as any chemical on the Toxic Chemical List.
• EPA must establish an inventory of data from the facility reports.
• States and EPA must make the release information available to the public and communities
through a nationalized database and other means.
EPCRA stipulates that facilities that manufacture, process, or otherwise use certain toxic chemicals in
excess of a specified amount, or threshold quantities, must submit annual reports on the amounts of those
toxic chemicals released into the air, water, and land or transferred offsite. The original Section 313
Toxic Chemical List, comprising more than 300 chemicals and chemical categories, was based on lists
already in use by the States of Maryland and New Jersey. Through a petition process, EPA can add or
delete chemicals from the Section 313 Toxic Chemical List. Such additions or deletions occur frequently.
Currently, the reporting requirements apply to owners and/or operators of facilities that meet the
following requirements:
• Have 10 or more full-time employees (or 20,000 paid personnel hours)
• Are in Standard Industrial Classification (SIC) Codes 20XX through 39XX (i.e., facilities in the
manufacturing sector)
• Are a multi-establishment complex in which all establishments have a primary SIC code of 20
through 39 or meet other requirements as written in 40 CFR 372.22(3)(i) and (ii)
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Introduction Chapter One
• Manufacture, process, or otherwise use a listed toxic chemical in excess of the specified
threshold quantities.
For a list of SIC groups subject to Section 313, see Figure 1-1.
Threshold quantities have changed since the first year of reporting. Facilities manufacturing or
processing any Section 313 chemicals in excess of the 75,000 pound threshold for 1987 should have
submitted toxic chemical release forms (EPA Form R) by July 1, 1988. Facilities manufacturing or
processing in excess of the 50,000 pound threshold for 1988 should have reported by July 1, 1989.
Thereafter, facilities manufacturing or processing more than the 25,000 pound threshold in a year are
required to submit the forms by July 1 of the following year. Likewise, facilities otherwise using listed
toxic chemicals in quantities more than the 10,000 pound threshold in a calendar year are required to
submit toxic chemical release forms by July 1 of the following year.
Facilities must provide the required information on the Toxic Chemical Release Form (EPA Form R) and
are required to retain onsite copies of all forms submitted, along with the supporting materials used to
develop information in the report, for three years from the date of submission. These materials must also
be readily available for inspection by EPA or other authorized organizations. EPCRA Section 313 also
requires EPA to enter the data from each Form R report into the Toxic Chemical Release Inventory
System (TRIS), which is a database accessible to members of the public. The Pollution Prevention Act
of 1990 (PPA) mandated that information on past or current year source reduction or recycling activities
and future estimates be included in the Form R.
1.2 EPCRA Section 313 Enforcement and Data Quality
Numerous EPA offices use Toxic Release Inventory (TR1) data for:
• Developing regulations. TRI data can pinpoint chemicals of concern that may require more
stringent regulation based on emission estimates.
• Program planning. TRI data can provide a wealth of information on specific chemical emissions
for special initiative planning.
• Establishing benchmarks for pollution prevention/waste minimization initiatives. The emissions
data from previous years can serve as the starting point for meeting reduction goals.
Because so many offices use TRI data for their programs, it is important that the data contained within
TRIS be of the highest integrity. The Office of Compliance Monitoring (OCM) and EPA Regions,
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Chapter One
Introduction
Figure 1-1
Standard Industrial Classification Groups Subject to Section 313
SIC Code
Industry Group
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
Food and kindred products
Tobacco products
Textile mill products
Apparel and other finished products made from
fabrics and other similar materials
Lumber and wood products, except furniture
Furniture and fixtures
Paper and allied products
Printing, publishing, and allied industries
Chemicals and allied products
Petroleum refining and related industries
Rubber and miscellaneous plastic products
Leather and leather products
Stone, clay, glass, and concrete products
Primary metal industries
Fabricated metal products, except machinery and
transportation equipment
Industrial and commercial machinery and computer
equipment
Electrical and other electronic equipment and
components, except computer equipment
Transportation equipment
Measuring, analyzing, and controlling instruments;
photographic, medical and optical goods;
watches and clocks
Miscellaneous manufacturing industries
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Introduction Chapter One
through the inspection process, are obligated to help ensure that all facilities in the regulated community
are reporting and submitting accurate estimates.
Section 325(c) of EPCRA authorizes the EPA Administrator to assess administrative civil penalties for
violations of EPCRA Section 313. In the program's first years, EPA's enforcement program focused
primarily on identifying and taking action against facilities that failed to report. However, EPA is now
taking steps to make data quality a priority in its enforcement program. This guidance manual is an
essential element of that effort.
. 1.2.1 Headquarters-Regional Memorandum of Agreement Process and the Enforcement Response
Policy
The intended purpose of the Office of Prevention, Pesticides, and Toxic Substances (OPPTS)
Headquarters-Regional Memoranda of Agreement (MOAs) is to implement the pesticide and toxics
programs to achieve National program objectives while recognizing the relevant circumstances or
conditions in the different Regions. Both Regional and Headquarters management will agree on program
goals, flexibility, or discretion. The goal is to use available resources fully to address Regional and
National priorities for prevention, pesticides, and toxic substances.
The process is being implemented in the spirit of improving Headquarters-Regional teamwork and
partnerships for OPPTS programs. Headquarters and Regions recognize that the growing demand on
resources to meet an ever increasing array of priorities requires that agreements be reached on Regional
and National priorities.
The OPPTS FY 1993 MOA asked Regions to increase EPCRA Section 313 inspections by 25 percent and
target 10 percent of all Section 313 inspections on data quality. Data quality errors, as defined in the
current EPCRA Section 313 Enforcement Response Policy, are errors that cause erroneous data to be
submitted to EPA and States. Generally, these errors result from a failure to comply with the explicit
requirements of EPCRA Section 313 and are not readily detectable during EPA's data entry process. The
following list from the Enforcement Response Policy presents the range of actions that constitute data
quality errors:
• Failure to identify all appropriate categories of chemical use, which causes an error in release
or offsite transfer amounts
• Failure to identify for each wastestream the waste treatment or disposal methods employed and
an estimate of the treatment efficiency typically achieved by such methods for that wastestream
• Failure to use all information necessary to calculate releases or offsite transfers
• Failure to perform release estimation or offsite transfer calculations
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Chapter One Introduction
• Failure to provide the annual quantity of the toxic chemical that entered the environmental
medium
• Failure to provide the annual quantity of the toxic chemical transferred offsite
• Failure to provide information required by regulations promulgated under Section 7 of the PPA'
• Failure to claim the correct source reduction or recycling activities (under the requirements of
Section 7 of the PPA, past or current year source reduction or recycling activities planned, but
not yet implemented by the facility, cannot be claimed)1
• Failure to correct previous errors or omissions resulting in Notices of Noncompliance (NON),
as demonstrated by a facility's Form R reports.
It should be noted that an error made in determining a facility's toxic chemical threshold that results in
the facility erroneously concluding that a Form R report for that chemical is not required is not a data
quality error but a "failure to report in a timely manner" violation.
13 Purpose of This Manual
The purpose of this manual is to provide guidance to EPA inspectors who conduct data quality inspections
under EPCRA Section 313. While there are other EPA guidance materials pertaining to inspections in
general, this manual is intended to stand alone and provide specific guidance for Section 313 data quality
inspections. This manual is not intended to replace previous documents, but rather, to serve as a
supplement to them. Therefore, inspectors may and should refer to those other documents as necessary
when performing inspections to determine data quality.
The following chapters of this manual provide information pertaining to the various components of an
EPCRA data quality inspection. The remainder of the manual is comprised of the following chapters:
Chapter 2: Data Quality and Nonreporters Targeting
Chapter 3: Pre-Inspection Activities
Chapter 4: Industrial Profiles for Section 313 Nonreporter and Data Quality Inspections
Chapter 5: Entry to the Facility and the Opening Conference
Chapter 6: Onsite Evaluation of Data Quality
Chapter 7: Closing Conference
Chapter 8: Post-Inspection Activities
Chapter 9: Elements of a Good Data Quality Case
1 PPA inspection guidance will be developed in cooperation with OPPT as the program develops.
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Introduction Chapter One
Where appropriate, sections of the EPCRA data quality inspection checklist have been incorporated into
the text. When a checklist section appears in the manual, a discussion of the guidelines for completing
that section is also included. Additionally, at the end of this chapter, Guidelines for a Comprehensive
EPCRA.Section 313 Data Quality Inspection Process has been included. The guidelines will help the
inspector who is unfamiliar with the data quality inspection process or who wants to establish a thorough
chronology for her/his recordkeeping purposes to ensure that all inspection requirements have been met
and that, if necessary, all materials are available to develop a strong case. If, at the end of the inspection
process, questions arise concerning any phase of the process, the inspector will have documented evidence
of her/his activities.
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Chapter One
Introduction
Guidelines
for a Comprehensive EPCRA Section 313
Data Quality Inspection Process
Name of Facility
Inspector Name
Inspection Date
Pre-Inspection Phase
Was inspection targeted?
Were Form R reports reviewed?
For SIC information?
For relevant permits?
For chemical-specific information?
Were facility summary matrices created, if necessary?
Were EPA records and databases reviewed?
Has the pre-inspection checklist been completed?
Has the inspection plan been developed?
Yes
No
Date
Describe the National/Regional priority
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Introduction
Chapter One
Inspection Phase
Has the data quality inspection checklist been completed?
Facility tour?
Review of Section 313 chemicals?
Review of threshold determination?
Review of release estimates?
Have the suggested questions at the back of the industrial profiles
(if applicable) been asked and recorded?
Has the information on EPCRA Section 313 and data quality
compliance been given to the facility?
Yes
No
Date
Post-Inspection Phase
Has any needed follow-up action been initiated?
Has the inspection report been completed and filed with the case
development officer?
Yes
No
Date
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Chapter Two EPCRA Data Quality and Nonreporters Targeting
Chapter Two
EPCRA Data Quality and Nonreporters
Targeting
2. EPCRA Data Quality and Nonreporters Targeting 2-1
2.1 Identification of Possible Nonreporting Facilities 2-2
2.1.1 Select Industries 2-3
2.1.2 Compare TRI and Other Databases 2-3
2.1.3 Print Out D&B Listing of Establishments 2-4
2.1.4 Compare D&B Listing With TRI 2-4
2.1.5 Recheck TRI by Name and Location 2-4
2.1.6 Gather Sales, Employment, and RCRA Generator Information 2-4
2.1.7 Select Candidate Facilities ' 2-4
2.2 Identification of Data Quality Problems 2-5
2.2.1 Comparison of TRI Reported Releases With Other Data Sources 2-5
2.2.1.1 General Industry Data 2-5
2.2.1.2 Plant-Specific Data 2-7
2.2J.2.1 Regulatory Submittals 2-8
2.2.1.2.2 TRI Comparisons 2-8
2.2.1.2.3 Other Public Sources 2-9
2.2.2 Errors Associated With Calculation Methods 2-10
2.2.3 Other Targeting Methods 2-12
2.3 Common Errors 2-12
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EPCRA Data Quality and Nonreporters Targeting Chapter Two
References 2-16
List of Appendices
Appendix 2-A: Listing of Industrial Process Profiles for Environmental Use 2-17
Appendix 2-B: Listing of Background Documents for New Source Performance
Standards 2-18
Appendix 2-C: Listing of Section 313 Reporting Guidance Documents 2-21
Appendix 2-D: Listing of Selected Office of Air Quality Planning and Standards
Chemical-Specific Reports for Section 313 Chemicals 2-22
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Chapter Two EPCRA Data Quality and No/importers Targeting
2. EPCRA Data Quality and Nonreporters Targeting
The purpose of this guide is to assist EPA Regional Office personnel with the targeting
and conducting of SARA Title III, Section 313 inspections. This guide provides sources of
general information for a wide variety of industries that may be used to target facilities for
inspections. The sources may also be used to gather general information on an industry of
interest such as typical sizes, throughputs, or chemical releases. This guide provides
methods to identify facilities that are subject to the SARA Title III, Section 313 reporting
but who have not submitted Form Rs for their releases and offsite transfers. The guide
also provides methods to identify data quality problems for those facilities that have
reported.
Industry-specific profiles have been prepared for the following industries (See Chapter
Four for additional information on the industry-specific profiles):
• Electroplating
• Foundries
• Furniture manufacture
• Paint formulation
• Ink formulation
• Petroleum refineries
• Motor vehicle parts and accessories.
These industry-specific profiles provide targeting guidance for the six industries studied.
This document provides guidance for targeting nonreporters and data quality problems in
the TRI system as a whole. This guide presents information identified during the
preparation of industry-specific profiles and information supplied by EPA Regional Office
personnel. The guide is intended to provide EPA Regional personnel with sources of
background information to target facilities for visits and to review prior to a SARA Title
III, Section 313 inspection at a facility.
Section 2.1 of this chapter provides methods to identify nonreporting facilities. Section 2.2
provides methods that may be used to identify data quality errors and chemicals that were
not reported at facilities that submitted some Form Rs. Both industry-wide and plant-
specific data sources that may provide comparisons with TRI submitted data are
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EPCRA Data Quality and Nonreporters Targeting Chapter Two
discussed. Section 2.3 discusses common errors in TRI submittals. Appendices 2-A
through 2-D present listings of data sources that may be useful to Regional inspectors.
2.1 Identification of Possible Nonreporting Facilities
For the TRI database to be accurate, all facilities with over 10 employees that
manufacture or process over 25,000 pounds (or otherwise use over 10,000 pounds) of
listed chemicals in SIC codes 20 through 39 must submit Form Rs estimating releases and
offsite transfers of these chemicals. Therefore, it is important to identify facilities who are
required to report to TRI but who have not.
In the preparation of the six industry profiles, the number of facilities in the TRI database
was compared with the number of establishments with 10 or more employees in County
Business Patterns1 and Dunn and Bradstreet (D&B).2 Consistently, the number of
establishments with 10 or more employees in the 4-digit SIC category reported in these
published sources was about double that in the same 4-digit SIC category in the TRI
database. Within the SIC codes selected for the industry profiles, almost all facilities
manufacture, process, or otherwise use at least one Section 313 chemical in excess of
threshold quantities. Part of this difference can be accounted for by offices of the manu-
facturing establishments that would not need to report to TRI. A number of facilities,
however, apparently are subject to the reporting requirements of Section 313, but they'are
not reporting.
Identification of nonreporting facilities using public databases presents several problems
including:
• Four-digit SIC codes in many industries are not clearly understood; therefore, many
facilities are classified differently in different databases.
• Company names (corporate, subsidiary, and division names) and even addresses
(P.O. Box versus street address) differ for the same facility in different databases.
• Offices of a company where no Section 313 chemicals are used are included as
establishments on many lists.
• Some operations are embedded in a larger facility with a different SIC; and there-
fore, they are difficult to identify by SIC.
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Chapter Two EPCKA Data Quality and Nonnporters Targeting
• Because the completion dates of the databases differ, company ownership changes
are difficult to identify.
Based on International Technology's (ITs) experience from this project and discussions
with Regional Office personnel, several sources emerged as the most useful in identifying
nonreporting facilities. This assessment, however, should not exclude other sources from
consideration. The methodology proposed for identifying nonreporting facilities consists of
seven steps:
1) Select industries where nonreporting appears to be a problem and identify one or
more 4-digit SIC codes that define this industry.
2) Compare the total number establishments in TRI in the region with the number
reported with over 10 employees in County Business Patterns1 and D&B2.
3) Obtain D&B printout for geographic area of interest for those 4-digit SICs with
large differences and in which most facilities with over 10 employees would
manufacture, process, or otherwise use at least one Section 313 chemical in excess
of threshold quantities.
4) Compare D&B printout with facilities that reported in the TRI database.
5) Recheck TRI by name and location to ensure a facility has not reported under a
different SIC.
6) Gather data on sales, employment, Resource conservation and Recovery Act
(RCRA), and other information.
7) Select candidate facilities.
The EPCRA Targeting System fETSI provides automated support to the above
methodology for identifying nonreporting facilities. This system was developed by the
Office of Compliance Monitoring, with regional input, to provide Regional inspectors with
a tool to manipulate the universe of facilities that are potential nonreporters. ETS is a
hybrid PC/Mainframe computer system that provides local access to and manipulation of
facility information for the creation of prioritized inspection targeting lists. It also
supports tracking of facility contacts, tips/complaints, and can support outreach efforts.
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EPCRA Data Quality and Nonreporters Targeting Chapter Two
The ETS national facility universe is created from Dun & Bradstreet (D&B) and TRIS,
for facilities with a SIC range of 20-39 and 10 or more employees. The national universe
is partitioned into ten regional universes. Each region can then download their own data
to a PC for local use. Each Region's universe contains only facilities located in their
Region.
The crossmatched information (between D&B and TRIS) provides the inspector with
facility information, parent company corporate and demographic information and TRIS
reporting status and dates. The inspector also has fields in ETS in which information on
facility history, previous facility contact, comments, and tips/complaints can be manually
inputted. Tip/complaints and facility contact information can be used as criteria in the
development of new inspection targetting lists.
Please note that a brochure on the EPCRA Targeting System has been included in this
manual (in the front pouch).
2.1.1 Select Industries
Perhaps the most important task in effectively identifying nonreporters is the selection of
industries to be investigated. This selection should be based on the following types of
criteria:
• Likelihood of otherwise using chemicals in significant quantities. This is important
because the threshold is lower for otherwise used chemicals, releases are typically
higher, and offsite transfers may be a RCRA waste. These industries would
typically involve use of paints, inks, or degreasing solvents.
• Experience of the Regional Office with this industry. This can include things such
as the record of other environmental violations and the sophistication of the
industry in understanding environmental requirements.
• Existence of clearly defined 4-digit SICs. This is necessary because much of the
data will be gathered using a 4-digit SIC. For example, vapor degreasing as a
category would be difficult to identify by use of SIC codes.
2.1.2 Compare TRI and Other Databases
Using the 4-digit SICs, compare the total number of establishments in TKl with the
number of establishments in County Business Patterns1. County Business Patterns
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Chapter Two EPCRA Data Quality and Nonreporters Targeting
presents the number of establishments by employment size class: 1-4, 5-9, 10-19, 20-49,
50-99, 100-249, 250-499, 500-979, and 1,000 or more establishments. If, in the industry
selected, it is likely that all facilities with 10 or more employees would use at least one
Section 313 chemical in excess of the threshold, then the number of establishments with
over 10 employees should be selected for comparison with the TRI database. If only
larger facilities would be expected to exceed the -threshold on a consistent basis, then over
20 employees or over 50 employees may be used. Also obtain the number of establish-
ments in the same 4-digit SIC in D&B1. A current list of D&B is available in DIALOG
D&B File 515. The total number of facilities in the SIC over a specified employment size
may be printed out without listing the facilities. Compare the total number of
establishments in County Business Patterns and D&B with the total number in the TRI
database (by region, state, or other desired area).
2.13 Print Out D&B Listing of Establishments
For 4-digit SICs with at least twice as many establishments in the published databases
(over specified employment size) as are in the TRI database, print out a list of these
facilities from D&B. The printout may be done for the whole region or for a particular
state or area of interest. Some Regional Offices also mentioned that geographic targeting
at this stage helped to lower the ultimate costs when the sites are visited.
2.1.4 Compare D&B Listing With TRI
Remove those facilities that have reported in TRI from the D&B list. Use state manu-
facturing directories to resolve discrepancies on name, address, or SIC Code. Remove
other establishments that are obviously (by name or address) not a manufacturing facility,
such as headquarter facilities.
2.1.5 Recheck TRI by Name and Location
Because facilities may report to TRI and D&B using different SIC codes, recheck TRI to
be sure that the facility has not submitted information, under a different SIC code.
Remove those facilities found.
2.1.6 Gather Sales, Employment, and RCRA Generator Information
For each facility, gather the number of employees and the sales numbers for the facility.
This information can be obtained from the State Manufacturing Directories or from
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EPCRA Data Quality and Nonreporten Targeting Chapter Two
DIALOG D&B Files 515 and 516. If available in the region, the quantity of RCRA-
generated waste should also be added. Any other databases available to the Regional
Office that help prioritize the remaining facilities on the list (such as information from
states in the region) should also be added.
2.1.7 Select Candidate Facilities
Select facilities with high sales, employees, or RCRA volumes as the best candidate facili-
ties. Also, confirm by telephone that this location is primarily a manufacturing facility and
not an office or warehouse location.
2.2 Identification of Data Quality Problems
Section 2.0 discussed methods to identify nonreporting facilities. This section discusses
methods to identify errors at facilities that have reported to TRI. This section presents
methods to identify data quality errors in the TRI database. Data quality errors include
overestimates as well as underestimates of chemical releases or offsite transfers. Data
quality errors also include not reporting for chemicals because of calculation errors or not
understanding the reporting requirements (e.g., threshold determination or de minimis).
This section also discusses methods that may be used to identify potential errors.
Potential errors may be identified by comparison with other data sources, identifying com-
mon errors associated with different calculation methods, and other targeting methods.
2.2.1 Comparison of TRI Reported Releases With Other Data Sources
Sources of data that may be used to identify potential data quality problems in SARA
Title III, Section 313 reporting can be divided into general industry data and plant-specific
data.
2.2.1.1 General Industry Data
General information on industries comes from many sources. The following sources can
be used to estimate typical process parameters, identify potential sources of release/offsite
transfer, estimate typical releases, as sources of emission factors* and regulatory limits.
Standard sources that present this type of information include:
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Chapter Two EPCRA Data Quality and Nonreporters Targeting
. Industrial Process Profiles for Environmental Use flPPELA This source contains
detailed process flow diagrams including input materials, process conditions, and
release estimates for 29 broad industries. A separate volume addresses each
industry, and some industries (e.g., plastics and resins) contain over 20 specific
process flow sheets and 60 process descriptions. A listing of the IPPEUs is
presented in Appendix 2-A.
• Kirk-Othmer Encyclopedia of Chemical Technology3. This source contains detailed,
documented information on almost every type of chemical process. The
bibliography after each section is an excellent source of additional information.
The author of each section is an expert in the field who is typically knowledgeable
of current trends in the industry.
• Compilation of Air Pollutant Emission Factors. AP-424. This source contains
process descriptions, emission factor estimates, and control information on more
than 120 processes. Emissions factors are provided for criteria pollutants. Factors
for total particulates or Volatile Organic Compounds (VOCs) can be used with
composition information to prepare rough estimates of releases from similar
processes. Sections on the storage and transfer of organic liquids are particularly
useful in calculating releases.
• Air Pollution Engineering Manual. AP-40*. This' 'source contains process
descriptions and control information for a wide variety' of industries located in the
Los Angeles area. Some of the information (especially control information) is out
of date since the date of the publication is 1973.
• Effluent Guideline Series. This source contains information on releases of many
pollutants to wastewater for industries that represent major sources of wastewater
releases.
• New Source Performance Standards (NSPSY This source contains air release
limitations that apply to new sources in 58 industries. - Many standards involve
particulates or VOCs that may be useful in determining reasonable releases of
Section 313 constituents of the release. Background' documents prepared in
support of the NSPS are most helpful.' A listing of the NSPS is contained in
Appendix 2-B.
• SARA Title III. Section 313. Release Reporting Guidance Documents. These
reports contain brief descriptions of the industry, identify potential release points,
and model calculations for estimating releases. A 'listing' of these guidance docu-
ments is contained in Appendix 2-C.
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EPCKA Data Quality and Nonreporters Targeting _ Chapter Two
• Office of Air Quality Planning and Standards rOAOPSI Reports These sources
provide process manufacturing descriptions and release estimates and some data on
the use of specific chemicals. A listing of these reports is presented in Appendix 2-
P-
• National Institute of Occupational Safety and Health (NTOSm Health
Evaluations (HHEs) and Industry-wide 'Surveys (IWSs). ' These sources contain
well-documented occupational exposure measurements. They also contain general
process descriptions.
Industry-specific regulatory limits may be used to identify chemicals of concern. The
regulations may vary by plant size, water discharge volume, or other variables that can be
used to identify parameters common to different plant sizes: 'Finally, regulatory limits may
be used to calculate an upper limit of release for the regulated chemical. However, this is
not meant to imply that any specific plant must have this release.
Regulatory limits for an industry as a whole may be used as a reality check for high
release estimates or as an upper-bound estimate for lower release estimates. Because
industry-wide regulatory limits are upper-bound release limits, they are generally not good
indicators of actual releases at a specific facility. Also, these regulations may be for
groups of chemicals such as VOCs or participates that are difficult to relate to specific
Section 313 chemical releases.
Probably the best source of industry-wide data is the TRI database. In the industry-
specific profiles prepared by IT, an analysis of the TRI data was very important to identify
specific chemicals used and expected typical releases and offsite transfers. Although too
much time would be required for an inspector to do a similar analysis, the TRI database
may be used to produce an industry overview. To produce meaningful results, however,
any analysis must be performed at the 4-digit SIC level. The analysis may be done nation-
wide or on a regional or state basis. The most useful information is data on the number
of facilities that report use of a particular Section 313 chemical. For example, if 90
percent of the facilities report for xylene and the plant in question does not, this
difference should be investigated. The analysis for the industry-specific profiles discussed
any chemical used by more than 5 percent of the facilities; however, chemicals used by
more than a third or half may be more useful for a quick analysis. Chemicals that are
common substitutes for each other should be grouped into categories such as chlorinated
solvents, organic solvents, and metals/metal compounds. For example, the TRI data may
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Chapter Two EPCKA Data Quality and Nonreporten Targeting
indicate that chlorinated solvents are commonly used (rather than indications that 1,1,1-
trichloroethane is commonly used).
To estimate probable releases during the development of the six industry-specific guides, a
mean release/offsite transfer was calculated for the industry or industry segment. Again,
this would require too much time for an inspector- to perform.- The best method, if
possible, would be to identify similar facilities. Information in the TRI database (such as
maximum quantity onsite) should not be used, however, because it often is not reliable
and does not correlate well with releases. Similar facilities may be identified through
inspector knowledge of the facilities or through comparison of sales or number of
employees in State Manufacturer Directories. Comparisons may be made with only a few
facilities. If any statistical analysis is attempted (such as calculation of a mean release),
however, at least 10 or more facilities should be selected. Although there may be very
good reasons for differences in releases or offsite transfers between identical facilities
(such as better control or difference production rates in a given year), differences that are
of an order of magnitude should be questioned.
2.2.1.2 Plant-Specific Data
Publicly available plant-specific data is the best source of information for which to review
TRI data submittals. The types of plant-specific data that may be used to target potential
errors include regulatory submittals [e.g., RCRA, National Pollutant Discharge Elimination
System (NPDES)], TRI comparisons (e.g., year to year, Sections 6 to 8), and other public
sources. The following sources are particularly useful:
• RCRA hazardous waste generator reports
• Stack tests
• Reported VOC releases
• Wastewater monitoring data
• Year-to-year TRI comparisons
• Section 8 of TRI submittals (beginning with the 1991 submittals) for otherwise-used
chemicals.
• SRI Directory of Chemical Producers
• NIOSH HHEs.
2.2.1.2.1 Regulatory Submittals
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EPCRA Data Quality and Nonreportars Targeting Chapter Two
RCRA manifest and hazardous waste generator reports are particularly useful to estimate
offsite transfers for Section 313 chemicals because the facility that receives the waste must
analyze it prior to recycling, treatment or disposal. Some of the analyses will be Toxic
Characteristic Leachate Procedure (TCLP) measurements. TCLP measurements report
leachable contaminants, not contaminant concentration. For standard wastes, however,
the industry in question may have developed a conversion factor that is calculated based
on a concentration/TCLP ratio. The concentrations may then be estimated using this
ratio. Therefore, the facility typically will have all the information needed to accurately
calculate most offsite transfers for these wastestreams, especially solvent streams sent
offsite for fuel blending or reclamation. It should be remembered that SARA Title III,
Section 313 chemicals may be present in wastestreams that are not RCRA wastes;
however, the RCRA streams constitute a major source of data for checking TRI estimates.
Reality checks based on total reported volumes can be used to identify potential reporting
errors. For example, if offsite transfers of F001 or F002 RCRA wastes equal the reported
quantities of chlorinated degreasing solvents sent offsite, the facility probably over
reported offsite transfers and under reported air releases of chlorinated solvents. This is
because a degreasing waste should contain a sizable percentage of the contaminants being
cleaned in the waste solvent.
Stack tests performed on control equipment may be used to check the order of magnitude
of air releases for major point sources at a facility. While these results may be applicable
for particulates or VOCs, they can be used in conjunction with published chemical
speciation data to estimate releases. For example, if the quantity sent offsite for disposal
from a control device (e.g., a baghouse) and the control efficiency are known (i.e., a stack
test), the air release reported in TRI can be easily estimated and compared with the TRI
reported releases.
Some facilities must report VOC releases to state agencies as a condition of their permit.
These reported releases may be used in conjunction with speciation data to estimate air
releases of Section 313 chemicals.
Wastewater monitoring data on pH, metals, or other constituents may be used along with
wastewater release quantities to estimate releases of SARA Title m, Section 313
chemicals to water or Publicly Owned Treatment Works (POTW).
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Chapter Two EPCKA Data Quality and Nonreporten Targeting
22.122 TRI Comparisons
Year-to-year comparisons of reported releases and offsite transfers of Section 313
chemicals can detect calculation errors or errors in the methods used to calculate releases.
While year-to-year fluctuations may be explained by changes in usage (e.g., changes in
paints used), or the addition of control equipment, large changes can also indicate errors
made in one or more of the reporting years. This is especially true if no changes were
made in the type or efficiency of the reported controls for this chemical.
Discrepancies in year-to-year release estimates are not always an indication of a data
quality error. This is especially true if release estimates are declining. This may be an
indication of the use of a more sophisticated estimation methodology. For example, use
of monitoring data will typically result in a lower emission estimate than the use of an
emission factor or mass balance. Basing emission estimates on leak detection systems or
stratified factors can also result in lower reported releases. In general, more sophisticated
methodologies are more expensive and tend to be used by larger companies.
Comparison of release and offsite transfer reporting (on Form R, Sections 5 and 6) with
Source Reduction and Recycling Activity Reporting (on Form R, Section 8) for 1991 and
later reporting years can also be used to identify errors. Releases reported in Section 5
should equal 'the quantity released in Section 8 (adjusted for rounding). The Waste Treat-
ment/Disposal/Recycling/Energy Recovery Codes in Section 6 and the associated offsite
transfers should agree with the equivalent reported quantities in Section 8 (adjusted for
rounding). In conclusion, inconsistencies in reporting within a TRI submittal may indicate
errors in the calculation of releases and offsite transfers.
The value that is most useful in calculating releases and offsite transfers is the chemical
throughput. This quantity, however, was specifically excluded from reporting to TRL The
new Form R submitted for reporting year 1991, however, contains all the information
»
needed to directly calculate chemical throughput for otherwise-used chemicals that are not
recycled onsite. The sum of the quantities listed in Sections 8.1 through 8.8 of Form R
equals the throughput for otherwise-used chemicals unless the chemical is consumed or
transformed within the manufacturing process. If onsite recycling is'reported, the
estimation of throughput can become more complicated because the recycled chemical
may be reused in the same process or used for other purposes elsewhere at the facility. If
the totals reported in Section 8.1 through 8.8 do not exceed 10,000 pounds, either the
facility should not have reported the otherwise-used chemical because the threshold was
EPCRA Data Quality Inspection Manual 2-11 Interim Final, November 1992
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EPCRA Data Quality and Nonreporters Targeting Chapter Two
not exceeded, or the reported quantities are incorrect. If the throughput for otherwise-
used chemicals is known, releases to various media can be estimated based on published
emission factors or other estimation methods.
2.2.1.2.3 Other Public Sources
For chemical producers, the SRI Directory of Chemical Producers should be used to
confirm that all Section 313 chemicals reported in SRI as manufactured at that site are
reported in TRI. The directory contains information on over 1,500 facilities. The SRI
Directory's lower limit for reporting in the Directory is 5,000 pounds or $5,000, which is
below the 25,000 pounds TRI reporting threshold; however, almost all the Section 313
chemicals would be manufactured in quantities greater than- the TRI reporting threshold.
If a NIOSH HHE was performed for the facility in question, the HHE should be reviewed
to ascertain which chemicals were present at the facility. Because NIOSH measures for
chemicals that are not necessarily present at the facility, the report, not just the results,
must be reviewed.
2.2.2 Errors Associated With Calculation Methods
The quality of the release estimates is directly related to the method used by the facility to
calculate the estimate. There are specific types of errors that should be looked for with
each calculation method. One of four codes is reported on Form R as the basis of the
estimate: M, monitoring data; C, mass balance; E, published emission factor; and O,
other approaches.
Monitoring data is the best method for calculating releases or offsite transfer quantities
for an individual wastestream. These estimates always boil down to a measured
wastestream chemical concentration multiplied by the mass or volume of the wastestream.
Several errors can occur in using this method. These errors tend to cause order of mag-
nitude errors in the estimated releases or offsite transfers and can be identified by year-to-
year or industry-wide comparisons. First, use of improper units caused calculational errors
in the result. Second, an inappropriate measurement may be used. The use of TCLP
measurement will underestimate releases because these tests measure teachable metals,
not metal content, in the sample. Third, a measurement may be used of a sample that
does not represent the average concentration in the wastestream for the entire year. For
example, concentrations in wastewater will vary during low or high wastewater flow
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Chapter Two EPCRA Data Quality and Nonnporten Targeting
periods and annual average concentration must have a sufficient number of measurements
to account for this. Often the facility will have only one data point for a chemical in a
wastestream. Nonrepresentative monitoring data should not be used to calculate releases;
however, it is often the only reasonable method that the facility can use to calculate an
estimate.
Mass balance provides a means of accounting for all the inputs and outputs of process
chemicals. A mass balance is useful for estimating releases when measured release data
are not available or when other inlet and output streams are quantified. The amounts
entering or leaving a process are either measured or estimated. A mass balance can be
performed on the process as a whole or on a subprocess. Individual operations within the
process usually must be evaluated.
Mass balance calculations are the best overall method to use to account for the total
usage of the chemical for otherwise-used chemicals. Because total throughput is
accounted for, the only reporting error will be to which media the release represents. For
manufactured or processed chemicals, mass balance calculations can again account for all
releases or offsite transfers once the quantity that remains with the product is estimated.
Mass balance calculations are not appropriate when releases and offsite transfers
represent only a small percentage of the chemical throughput If mass balance
calculations are used to estimate very small releases or offsite transfers for manufactured
or processed chemicals, the results should be questioned.
A third technique for estimating releases and offsite transfer from processes involves the
use of emission factors. One type of emission factor relates a quantity of a pollutant to
some process-related parameter or measurement The amount of pollutant per quantity
of product is frequently used. Many emission factors are expressed in terms of total VOC
or particulates rather than a single chemical compound. Emission factors for VOCs are
available in VOC Emission Factors for the National Acid Precipitation Assessment
Program (NAPAP) Emission Inventory.7 These data can be used with actual process vent
measurements of volatile organics or particulates to estimate emissions of a specific
compound. The Volatile Organic Compound (VOC) Species Data Manual* also provides
information on many air emission sources. This allows the user to estimate releases of
specific toxic compounds based on the total amount of VOCs emitted from a particular
source. Similarly, the Receptor Model Source Composition Library* provides information
relating metals emissions to total paniculate emissions for different release sources.
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EPCRA Data Quality and Nonreporters Targeting Chapter Two
Another good source of information is Toxic Air Pollutant Emissions Factors - A
Compilation for Selected Air Toxic Compounds and Sources.10
Errors can result in the use of emission factors if inappropriate factors are used or if these
factors are "adjusted" by the facility using questionable rationale. If the facility reports the
use of an emission factor, the calculation should be reviewed using accepted EPA factors
for comparison.
Engineering calculations or "other approaches" can be used when parameters related to
emissions cannot be directly measured. Emissions can be estimated or inferred through
engineering calculations or measurement of other secondary parameters (i.e.,
physical/chemical properties of the materials involved, design information on the unit
operation for which the estimate is being made, or emission information from similar
processes). Engineering calculations are generally used to "fill in" information needed for
other emission estimation methods.
Physical/chemical information derived from the ideal gas law, vapor pressure, and
equilibrium relationships can frequently be applied when gaseous concentrations of a
particular compound are estimated. Some releases, such as VOC releases from storage
tanks, can be estimated by use of a combination of emission factors and engineering
calculations. For example, the EPA publication AP-42 provides equations for estimating
air emissions from organic liquid storage and handling operations.4 These equations
contain factors that depend on tank parameters and service conditions. More specific
information on storage tank emissions including example calculations for horizontal tanks
and chemical mixtures can be found in Estimating Air Toxics Emissions From Organic
Liquid Storage Tanks." The only way to identify errors in engineering calculations is to
check the rationale and the actual calculation, including units.
Finally, the methods .and data presented in Estimating Releases and Waste Treatment
Efficiencies For The Toxic Chemical Release Inventory Form are useful to check
estimates of release or offsite transfer reported by the facility."
2.2 J Other Targeting Methods
In discussions with Regional Office personnel, several additional targeting methods were
identified. They include:
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Chapter Two EPCRA Data Quality and Nonnporters Targeting
• Targeting in conjunction with other cross-program multi-media inspections [e.g.,
RCRA, Clean Water Act (CWA)]
• Targeting using tips or complaints from other media programs on questionable
submissions
• Targeting in conjunction with other Office of Compliance Monitoring (OCM)
control program inspections [e.g., Toxic Substances Control Act Sections 5 and 8 or
polychlorinated biphenyls (PCB)j
• Targeting as a follow-up or add-on to a nonreporter inspection
• Targeting a geographic area where there are a large number of facilities, thus
reducing inspection costs
• Targeting by inspecting facilities that have violations of other regulations
• Targeting using newspaper or broadcast accounts of chemical usage or release
• Targeting facilities that have received Notices of Noncompliance (NONs)
• Targeting facilities that are large emitters or emitters of specific toxic chemicals.
It should be noted that Region Vn has developed a basic formula which evaluates
chemical emission by toricity, carcinogenicity, chemical release amount, and media
released to. This method allows a Region to focus data quality inspections on chemicals
that pose the highest risk.
23 Common Errors
In targeting chemicals or processes at a facility, certain common errors should be
investigated. Based on IT experience on this project and other Section 313 projects for
Office of Pollution Prevention and Toxic (OPTS), the following general types of errors are
common enough that checks for TRI reporting errors should include these topics when
appropriate. This section also presents a list of general questions that may be helpful to
determine if reporting errors were made.
General types of errors include:
5
EPCRA Data Quality Inspection Manual 2-15 Interim Final, November 1992
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EPCRA Data Quality and Nanreparten Targeting Chapter Two
• Many facilities do not understand the difference between manufactured, processed,
or otherwise used chemicals. This can cause a facility not to report chemicals that
were otherwise used because the wrong threshold was used.
• Many facilities do not understand that the weight of metal compound is used to
determine if the threshold is exceeded while the weight of the metal only is used to
calculate releases and offsite transfers'. This can cause errors in both threshold
determination and release estimation.
• The maximum quantity reported onsite is sometimes misunderstood to be the
annual usage of the chemical.
• For metals/metal compounds, TCLP is sometimes~~used'TD estimate the metal
concentration in wastes sent offsite. This does not measure metal content, but
rather leachable metal content, and should not be used in calculations.
• Some small facilities do not understand that the threshold determination is based
on throughput, not on release quantities. Some think that they need to release
10,000 pounds before the chemical is reportable.
• Some facilities think that the total quantity of chlorinated solvents, purge solvents,
etc., sent offsite for reclamation is waste solvent and did not account for the other
constituents of the waste. This mistake causes underestimation of air releases.
• Many smaller facilities are not familiar with SIC definitions, and therefore use
incorrect SIC codes. This can cause difficulties in using TRI data to calculate
mean release quantities or to identify nonreporting facilities.
• If Material Safety Data Sheet (MSDS) information is used to estimate the quantity
of Section 313 chemical used at the facility, the supplier should be checked to see if
the percentage represented an average or a maximum concentration. Many
MSDSs report toxic materials on the high side for safety reasons.
The following questions can be helpful to determine if reporting errors were made for the
following types of releases.
Organic Solvents
• For otherwise-used solvents (Le., coatings, cleanups), did a mass balance for
solvents account for total usage at the facility?
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Chapter Two EPCRA Data Quality and Nanrtporten Targeting
• Was the otherwise-used threshold of 10,000 pounds applied for all solvents used in
coatings?
• How were releases of organic solvents other than to air estimated?
• If a paint booth and drying oven were .vended to different control devices, how was
the booth/oven split determined?
• For solvents sent offsite for fuel burning, recycling, or disposal, was a waste analysis
used to determine the quantity of the 313 chemical? Most wastes should be
RCRA wastes, which are analyzed by the waste receiver.
• How were releases of process solvents determined? What percentage of through-
put was released to air?
• For manufactured or processed chemicals, were analyses of the products used to
determine the quantity of the Section 313 chemical that remained in the product?
Chlorinated Solvents (degreasing)
• Was a mass balance accounting for all chlorinated solvent usage used to estimate
releases and offsite transfers?
• Was the percentage of chlorinated solvent in the waste accounted for?
• For vapor degreasing with water separation, were releases to water or POTW
estimated?
Metals/Metal Compounds
• Was TCLP used as a measure of metal concentration in any calculation? TCLP
does not measure metal content, but rather teachable metal, and should not be
used in calculations.
• Were wastewater monitoring data used to estimate releases to water or POTW?
What was the frequency of the monitoring?
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EPCRA Data Quality and Nonreporters Targeting Chapter Two
• Were thresholds for metal compounds determined using the weight of the
compound and not just the metal portion of the compound?
• Were thresholds determined for all metals/metal compounds processed at the
facility?
• Did the facility determine if it met the reporting thresholds from the amount
released or transferred offsite instead of the amount processed or otherwise used?
• For metals/metal compounds in paints, how was a coating transfer efficiency
determined?
Acids
• Was the pH of acid releases continuously measured to support any assumption of
neutralization? If not, what was the frequency of the monitoring?
• Was the percentage of acid in the original acid or acid solution taken into account
in the calculation of threshold?
Other Chemicals
• If chlorine releases to water or POTW were reported, the water pH should be
checked. If pH is higher than 4, there is only a very small release to water.
• Were total ammonia (NH, + NH4*) levels used to report ammonia, .releases to
water?
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Chapter Two EPCRA Data Quality and Nonnporten Targeting
References
1. U.S. Department of Commerce; Bureau of the Census. County Business Patterns,
1989. CBP-89-1, Washington, D.C 1991.
2. Dunn & Bradstreet. Dunn's Electronic Business Directory in DIALOG Database File
515. 1992.
3. Kirk-Othmer. Encyclopedia of Chemical Technology, Third Edition. John Wiley and
Sons. 1982.
4. U.S. Environmental Protection Agency. Compilation of Air Pollutant Emission
Factors. Volume I: Stationary Point and Area Sources, AP-42. Research Triangle
Park,NC. 1985.
5. U.S. Environmental Protection Agency. Air Pollution Engineering Manual. Second
Edition, AP-40. May 1973.
6. SRI International. SRI Directory of Chemical Procedures, 1992. United States of
America. 1982.
7. U.S. Environmental Protection Agency. VOC Emission Factors of a NAPAP Emission
Inventory. EPA 600/7-86-052. Research Triangle Park, NC 1986.
8. U.S. Environmental Protection Agency. Volatile Organic Compound (VOC) Species
Data Manual. Second Edition. EPA-450/4-80-015. Research Triangle Park, NC
1980.
9. Carl, J. F., et al. Receptor Model Composition Library. EPA-450/4-85-002. 1984.
10. U.S. Environmental Protection Agency. Toxic Air Pollutant Emission Factors - A
Compilation of Selected Air Toxic Compounds and Sources, EPA 450/2-88-006a.
Research Triangle Park, NC 1988.
EPCRA Data Quality Inspection Manual 2-19 Interim Final, November 1992
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EPCRA Data Quality and Nonreporters Targeting Chapter Two
11. U.S. Environmental Protection Agency. Estimating Air Toxics ^Emissions From
Organics Liquid Storage Tanks. EPA 450/4-88-004. Research Triangle Park, NC.
1988.
12. U.S. Environmental Protection Agency. Estimating Releases and Waste Treatment
Efficiencies For the Toxic Chemical Release Inventory Form. EPA 560/4-88-002.
Washington, DC. 1987.
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EPCRA Data Quality and Nonnporten Targeting Chapter Two
Appendix 2-B: Listing of Background Documents for New Source Performance Standards
4. New Source Partermancq Standard f4Q CFB 6tM
Subpart Standards of Performance for -
0 Fossil-Fuel Fired Steam Generators for Which Construction is
Commenced After August 17,1971
Da Electric Utility Steam Generating Unto for Which Construction is
Commenced After September 18.1978
Ob Irxlustrtal^ommerieal-lnstitutional Steam Qetieiaiing Unto
DC Smafl irxJustrialOxrvnenaaMnstitutional Steam Generating Unto
E Incinerators
F Portland Cement Plants
G Nitric Acid Plants
H Sulfuric Acid Plants
I Asphalt Concrete Plants
J Petroleum Refineries
K Storage Vessels for Petroleum Liquids for Which Construction, Recon-
struction, or Modification Commenced after June 11,1973 and prior to
May 19.1978
Ka Storage Vessels for Petroleum Liquids for Which Construction, Recon-
struction, or Modification
Kb Volatile Organic Liquid Storage Vessels (inducing Petroleum Liquid
Storage Vessels) for which Construction, Reconstruction, or Modification
Commenced after July 23, 1984
L Secondary Lead Smelters
M Secondary Brass and Bronze Ingot Production Plants
N Primary Emissions from Basic Oyxgen Piocess Furnaces for Which
Construction is Commenced After June 11,1973
Na Secondary Emissions From Basic Oxygen Process Steelmaking FacBties
for Which Construction Commenced After January 20,1983
O Sewage Treatment Plants
P Primary Copper Smelters
O Primary Zinc Smelters
R Primary Lead Smelters
S Primary Aluminium Reduction Plants
T Phosphate Fertilizer industry: Wet-Proeess Phosphoric Add Plants
U Phosphate Ferffizer Industry: Superphosphoric Add Plants
V Phosphate Fertifizer Industry: Diammonium Phosphate Plants
W Phosphate Fertilizer industry: Triple Superphosphate Plants
X Phosphate Fertflizer Industry: Granular Triple Superphosphate Storage
Facilities
Y Coal Preparation Plants
2 Ferroalloy Production FatiHties
AA Steel Plants: Electric Are Furnaces
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Chapter Two EPCRA Data Quality and NomreporUn Targctijig
Appendix 2-A: Listing of Industrial Process Profiles for Environmental Uw
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Chapter Two EPCRA Data Quality gad NonrtporUn Targeting
AAa Steel Plants: Electric Arc Furnaces and Argon-Oxygen Decarfaurization
Vessels Constructed After August 17, 1983
BB Kraft Pulp Mills
CC Glass Manufacturing Plants
DD Grain Elevators
EE Surface Coating of Metal Furniture
FF (Reserved)
GG Stationary Gas Turbines
HH Lime Manufacturing Plants
KK Lead-Acid Battery Manufacturing Plants
LL Metallic Mineral Processing Plants
MM Automobile and Light-Duty Truck Surface Coating Operations
NN Phosphate Rock Plants
PP Ammonium Sutfate Manufacture
OO (Reserved)
OQ Graphic Arts Industry: Publication Rotogravure Printing
RR Pressure Sensitive Tape and Label Surface Coating Operations
SS Industrial Surface Coating: Large AppJicances
TT Metal Coil Surface Coating
UU Asphalt Processing and Asphalt Roofing Manufacture
W Equipment Leaks of VOC in Synthetic Organic Chemicals Manufacturing
Industry
WW Beverage Can Surface Coating Industry
XX Bulk Gasoline Terminals
AAA New Residential Wood Heaters
BBB Rubber Tire Manufacturing Industry
CCC (Reserved)
ODD (Reserved)
EEE (Reserved)
FFF Flexible Vinyl and Urethane Coating and Printing
GGG Equipment Leaks of VOC in Petroleum Refineries
HHH Synthetic Fiber Production Facilities
III Volatile Organic Compound Emissions from the Synthetic Organic
Chemical Manufacturing Industry (SOCMI) Air Oxidation Unit Processes
JJJ Petroleum Dry Cleaners
KKK Equipment Leaks of VOC From Onshore Natural Gas Processing Plants
LLL OnShore Natural Gas Processing: SO, Emissions
MMM (Revised)
NNN Volatile Organic Compound Emissions from Synthetic Organic Chemical
Manufacturing Industry Distillation Operations
OOO NonmetaJlte Mineral Processing Plants
PPP Wool Fiberglass Insulation Manufacturing Plants
QQQ VOC Emissions from Petroleum Refinery Wastewater Systems
RRR (Reserved)
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EPCRA Data Quality and Nonnporten Targeting Chapter Two
SSS Magnetic Tape Coating Facilities
TTT Industrial Surface Coating: Surface Coating of Plastic Parts for Business
Machines
UUU (Reserved)
VW Polymeric Coating of Supporting Substrates Facilities
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Chapter Two
EPCRA Data Quality god Nonnportgn
Appendix 2-C: Lasting of Section 313 Reporting Guidance Documents
Title III Section 313 Release Reporting Guidance Estimating Releases from:
Monofilament Fiber
Manufacture
Printing Operations
Electrodeposition of
Organic Coatings
Spray Application of
Organic Coatings
Semiconductor Manufacture
Formulating Aqueous Solutions
Electroplating Operations
Textile Dyeing
Presswood and Laminated
Wood Products
Roller, Knife, and Gravure
Coating Operations
Paper and Paperboard
Production
Leather Tanning and
Finishing Processes
Wood Preserving
Rubber Production and
Compounding
Food Processors
EPA 560/4-88-0043 Jan 1988
EPA 560/4-88-004b
EPA 560/4-88-004C
EPA 560/4-88-0046
EPA 560/4-88-004f
EPA 560/4-88-004Q
EPA 560/4-88-004h
EPA 560/4-88-004J
EPA 560/4-88-004J
EPA 560/4-88-004K
EPA 560/4-88-004I
EPA 560/4-88-004p
EPA 560/4-88-004q
Jan 1988
Jan 1988
EPA 560/4-88-004d Jan 1988
Jan 1988
Mar 1988
Jan 1988
Feb1988
Mar 1988
Feb1988
Fob 1988
Feb1988
Feb1988
Mar 1988
EPA 560/4.90-014 June 1990
These reports contain brief descriptions of the industry, identify potential release
points, and model calcualtions for estimating releases.
EPCRA Data Quality Inspection Manual
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EKRA Data Quality and Nonreporten Targeting
Chapter Two
Appendix 2-D: Listing of Selected Office of Air Quality Planning and Standards Chemical-
Specific Reports for Section 313 Chemicals
Office of Air Quality Planning and Standards (OAQPS) Reports
These following reports may be useful for estimating releases for existing chemicals. They contain
information concerning chemical/physical properties, overview of production and uses, amount
consumed per end use, major industrial source categories, process descriptions and flow diagrams,
potential emission points, emission factors, number of sites and facility names, and references for
source sampling and analysis procedures. The following reports have been issued for Section 313
chemicals.
Locating **>d Estima*ing Air Emissions from Sources ofi
Acrylonitrile
Carbon tetrachloride
Chloroform
Ethylene dichloride (1,2-Dichloroethane)
Formaldehyde
Nickel
Chromium
Manganese
Phosgene
Epichlorohydrin
Vinylidene chloride
Ethylene oxide
Chlorobenzenes
Polychlorinated Biphenyl's (PCBs)
Itf^jmitf.
Chromium (supplement)
1,3-Butadiene
EPA 450/4-84-0071
EPA 450/4/84-007b
EPA 450/4-84-007C
EPA 450/4/84-007d
EPA 450/4-84-007e
EPA 450/4-84-007f
EPA 450/4-84-007g
EPA 450/4-84-007h
EPA 450/4-84-007i
EPA 450/4-84-007J
EPA 450/4-84-007k
EPA 450/4-84-0071
EPA 450/4-84-007m
EPA 450/4-84-007n
EPA 450/4-84-007q
EPA 4SO/2-89-O13
M* ^\ ^ifWI£t9f VA^
EPA 450/2-89-002
EPA 450/2-89-021
Mar 1984
Mar 1984
Mar 1984
Mar 1984
Mar 1984
Mar 1984
July 1984
Sept 1985
Sept 1985
Sept 1985
Sept 1985
Sept 1986
Sept 1986
May 1987
Mar 1988
MAT 1988
AVB.eH 47 W
Augl989
Dec 1989
Interim Final, November 1992
EPCRA Data Quality Inspection Manual
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Chapter Two EPCRA Data Quality and Nonreporten Targeting
The following reports contain industry and process descriptions, process flow diagrams, emissions
data, applicable control systems, and impact analysis. All chemicals, not just Section 313 chemicals
are presented.
6 throueh 10: Sel
Organic Chemical Manufacturing Vol. 6: Selected Processes
PB 81-220550 EPA 450/3-80-028a Dec 1980
Cyclohexane
Chlorobenzenes
Styrene
Cyclohexanol
Cyclohexanone
Maleic anhydride
Ethylbenzene
Capralacton
Adipic acid
Organic Chemical Manufacturing Vol. 7: Selected Processes
PB 81-220568 EPA 450/3-80-028b Dec 1980
Nitrobenzene
Toluene diisocyanate
Dimethyl terephthalate
Phenol
Aniline
Cumene
Crude terephthalic acid
Purified terephthalic acid
Acetone
Linear alkylbeazenes
Organic Chemical Manufacturing Vol. 8: Selected PTOCBSMS
PB 81-220576 EPA 450/3-80-028c Dec 1980
Ethylene dichloride
Perchloroethylene by hydrocarbon chlorinolysis process
Fluorocarbons
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EPCRA Data Quality and Nonrtporttn Targeting ChapUrTwo
Trichloroethylene
Chloromethanes by methane chlorination-process
Chloromethanes by metfaaool hydrochlorination and methyl chloride chlorination process
Carbon tetrachloride
1,1,1 -Trichloroethane
Perchloroethylene
Vinylidene chloride
Organic Chemical Manufacturing Vol. 9: Selected Processes
PB 81-220584 EPA 450/3-80-0284 Dec 1980
Formaldehyde
Ethylene
Acetaldehyde
Methanol
Ethanol amines
Ethylene oxide
Vinyl acetate
Ethylene glycol
Organic Chemical Manufacturing Vol. 10; Selected Processes
PB 81-220592 EPA 450/3-80-028e Dec 1980
Propylene oxide
Glycerin and intermediates (allyl chloride, epichlorohydrin, acrolein, allyl alcohol)
Chloroprene
Formic acid
Waste sulfuric acid treatment for acid recovery
Acrylonitrile
Acetic anhydride
Acetic acid .
Ethyl acetate
Methyl ethyl ketone
Interim Final, November 1992 EPCRA Data Quality Inspection Manual
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Chapter Time Pn-lnspection Preparation
Chapter Three
Pre-Inspection Preparation
Page
3. Pre-Inspection Preparation 3-1
3.1 Introduction 3-1
3.2 EPCRA and Multimedia Inspections 3-2
3.3 Review of Facility and EPA Records 3-3
3.3.1 EPCRA Section 312 Tier I and II Forms 3-8
3.3.2 Federal Database Comparison 3-9
3.3.3 Confidential Business Information Considerations 3-10
3.4 Providing Advance Notification 3-11
3.4.1 Identification of Contact Person to Notify 3-12
3.4.2 Items Addressed in Advance Notification 3-12
3.5 Pre-Visit Completion of the Inspection Checklist 3-13
3.5.1 Technical Review 3-13
3.5.2 Supplier Notification 3-14
3.5.3 Logistical Arrangements 3-16
3.6 Section 1.0 of the Inspection Checklist: Telephone Contact 3-17
3.7 Development of an Inspection Plan 3-21
3.7.1 Purpose 3-21
3.7.2 Elements of the Inspection Plan 3-21
3.8 Collection of Inspection Documents 3-24
List of Figures
EPCRA Data Quality Inspection Manual 3-i Interim Final, November 1992
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Pro-Inspection Preparation Chanter
Figure 3-1 Worksheet for Developing a Written inspection Plan 3-23
Interim Final, November 1992 3-ii EPCRA Data Quality Inspection Maaoal
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Chapterllme Pre-Inspectwn Preparatum
3. Pre-Inspection Preparation
3.1 Introduction
This chapter contains guidance on conducting pre-inspection activities pertaining to Section
313 of EPCRA. A good inspection begins with planning, which should commence well
before the inspector visits the facility to be inspected. Planning is the means by which the
inspector identifies all the required activities to be completed during the inspection process,
from obtaining records before the inspection to writing reports and follow up.
Planning includes conducting a thorough review, prior to the inspection, of EPA records and
data pertaining to the facility to be inspected (including data that may be obtained from the
facility itself). This saves time in the long run because familiarity with the operations,
history, and compliance status of the facility decreases the need for covering these areas
during the limited time typically spent onsite. In addition, planning promotes a better
relationship with the regulated community because the EPA inspector should be able to
answer questions concerning the application of EPCRA requirements to a particular facility
It also enhances the facility's confidence in the EPA inspector and aids in establishing good
relationships with facility representatives.
Another important benefit of planning is to enhance the inspector's ability to identify and
document potential violations and thus provide more time to collect necessary data to assist
Case Development Officers (CDOs) in their subsequent compliance and enforcement
activities. Ultimately, planning an inspection may actually take more time than the
inspection itself but wfll result in a more efficient and productive inspection overall.
The objectives of inspection planning are to:
• Understand the objectives of the inspection
•
• Understand EPCRA and applicable regulations
• Be familiar with the compliance history and physical site layout of the .particular
facility to be inspected
• Be well-versed in the policies and procedures governing EPCRA inspections
. • Be prepared to collect and record documents taken from the facility
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Prf Inspection Preparation Chapter Hint
• Be familiar with the safety plan for protection from potential hazards at the facility.
This chapter describes the planning process that should take place prior to any routine
EPCRA inspection. The basic elements of inspection planning are determining if an
EPCRA inspection should be included in a multi-media inspection (Section 3.1); reviewing
EPA and other records and data concerning the subject facility (Section 3.2); providing
advance notification of the inspection to the facility'(Section 33); completing the pre-visit
section of the Inspection Checklist (Section 3.4); preparing a written inspection plan to be
followed during the actual inspection (Section 3.5); and gathering inspection documents
(Section 3.6).
32 EPCRA and Multimedia Inspections
To date, most of the data quality inspections conducted have been pan of a larger
multimedia inspection. Working with a team of inspectors on a strict schedule can pose
problems for the EPCRA Section 313 data quality inspector because an onsite, thorough,
data quality review may require up to 3 days. The logistics of conducting a multimedia
inspection can also drain resources from the data quality inspection itself.
JBF
Many data quality inspectors feel there is not enough time to adequately review
emissions data during a multimedia inspection, whether announced or unannounced.
Inspectors in some Regions have eliminated this problem by scheduling data quality
reviews after other members of the multimedia team have completed their inspection.
(Taken from Study of Regional Experience Conducting EPCRA Data Quality
Inspections)
Given this problem and because Regional resources are scarce, h is important that
inspectors and their managers determine when EPCRA Section 313 data quality inspections
should be part of larger multimedia efforts. The following bullets are merely suggestions for
situations in which an EPCRA data quality inspection might benefit from being part of a
larger multimedia effort:
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Chapter Three Pre-inspection Preparation
• Single chemical initiatives
• Geographic initiatives
• Enforcement Management Council/Office of Enforcement initiatives
• Facilities manufacturing/use of explosive pj highly toxjc chemicals..
TIP
Reporting Status
Many facilities are also cited for failure to submit a Form R during a data quality
inspection. Inspectors should always examine the reporting status of a facility before
conducting a data quality inspection.
If an inspector determines that an EPCRA inspection should not occur within a multi-media
inspection, then s/he should follow the procedures outlined in the rest of this chapter.
33 Review of Facility and EPA Records
A thorough review of EPA records for the facility to be inspected is a critical component of
pre-inspection preparation. This section focuses on the review of key facility and EPA
written records and databases, which together will supply the inspector with crucial
background information pertaining to the facility to be inspected. However, the inspector
should also supplement record review activities by interviewing appropriate EPA personnel
who may have additional information or knowledge of the subject facility. The appropriate
persons to interview will be based on the., inspector's need for clarifying issues or data
discovered during the record review process and on the need for additional information.
When reviewing the available information^on a facility, the inspector should identify and
focus on the information most relevant to the purpose of the inspection.
This section discusses the purpose of pre-inspection records review; types of information to
be reviewed; sources of information; procedures for requesting information from EPA
Headquarters; and CBI considerations for the records review process.
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Pre-Inspection Preparation Chapter Three
Proper review of EPA records prior to the inspection of a subject facility is essential to the
overall success of compliance inspection efforts. The information obtained from reviews of
specific regulatory requirements that apply kto the facility, as well as site-specific background
information on compliance history and faculty operations, help the inspector to develop the
written inspection plan (Section 3.5) and gather inspection documents (Section 3.6). In
addition, facility representatives may be more responsive to an inspector who has a thorough
understanding of the facility operations and structure.
In general, the objectives of the records review include the following:
• Become familiar with facility size, operations, and physical layout
• Learn about facility compliance history
• Discover inadequacies and inconsistencies in the information on the subject facility
that the inspector may want to clarify during the inspection
• Minimize inconvenience to facility personnel by not having to ask for basic facility-
specific information that may already be in EPA records and avoid having to spend
on site time doing so
• Clarify technical and legal issues before conducting the inspection
• Make more efficient use of EPA personnel and funding by saving time once at the
inspection site.
The following list highlights examples of the types of information the inspector should search
for during the record review process. Obtaining all this information may not be possible;
however, because of its value to the inspection process, the inspector should expend
significant efforts to obtain these and other types of information on the facility.
• General Facility Information. Some of the general information on a facility the
inspector should look for during the records review process includes:
Maps and/or aerial photographs showing the location of the facility and its
relationship to the surrounding area
Names, titles, and telephone numbers of facility officials and/or representatives
Organizational structure
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Chapter Three Pre-Inspection Preparation
Special facility entry requirements
Past and present (and possibly future) operations and production levels
Safety equipment and health and safety training requirements
Water, air, and waste treatment pollutiQn.and control equipment
Descriptions of the facility's (and/or the company's or parent company's)
recordkeeping and filing systems
Physical layout of facility
Size of facility.
These types of information are particularly useful in helping the inspector plan the
details of the inspection and allocate time and resources, as well as prepare necessary
documents and equipment For example, information on personnel and
organizational structure can help the inspector determine who should be interviewed
during the inspection. Data on facility-specific entry requirements may help the
inspector determine whether it is necessary to obtain a warrant Information not
available from EPA Headquarters or from Regional EPCRA files may be available
from other program offices in the Region. Water, air, and waste permit applications
and inspection reports, for example, could have any or all of this information on a
facility.
• Previous Enforcement Information. EPCRA inspectors should also review inspection
records, compliance histories, and enforcement actions under other programs,
including the water, air, and hazardous waste programs. This information can also be
critical in planning an inspection and understanding the facility.
• Reports Prepared by the Facility. The inspector should review any reports prepared
by the facility (e.g., self-monitoring reports) that may be found in EPA files. The
inspector may review these reports to determine whether there are any discrepancies
between the self-monitoring records and the EPA records. For example, a facility
may submit a discharge monitoring report (under the NPDES permit program)
indicating the presence of a Section 313 chemical in the discharge. However in the
Form R report, the facility did not indicate any releases to receiving water. This is
a discrepancy in the data and should be reserved during the inspection.
The inspector may want to investigate further any discrepancies, either-by requesting
clarification from the facility during the advance notification or during the inspection.
Therefore, the inspector should make note of these discrepancies, as well as the
proposed method for addressing them.
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Pn-Inspection Preparation Chapter Three
TIP
The Toxic Release Inventory System (TRIS) 313 Edit Error Reports of questionable
data for 1987-88 can be reviewed. This will help the inspector spot large
discrepancies in emissions from one year' to the next by facility and by State.
Permits and Permit Applications. The idKp&ct&f should review any facility operating
permits or permit applications. Such documents may provide information on
limitations and requirements applicable to discharges, emissions, and operations;
compliance schedules; and monitoring, analytical, and reporting requirements. While
the inspector is concerned only with documenting potential EPCRA violations, EPA
is interested in encouraging comprehensive environmental compliance inspections
focusing on compliance with more than one EPA-administered law (e.g., a combined
EPCRA and Toxic Substances Control Act [TSCAJ inspection).
As noted above, programs, permits, and applications can also be useful for providing
background information. In addition, monitoring and spill data could alert an
inspector to the presence of an unexpected chemical of concern, while EPA staff in
other programs who are knowledgeable about the facility may be able to provide
insight into facility operations.
Correspondence. Correspondence between the facility and.EPA (or the State) may
provide important information on compliance issues. In addition, EPA's response to
correspondence from the facility can affect the requirements that are applicable to
the facility. Once again, the inspector should review EPCRA-related correspondence
but may also review EPA correspondence related to other program areas such as air,
water, and RCRA.
Laws and Regulations. Prior to the inspection, the inspected; must review and identify
the EPCRA regulations that apply to the facility to be inspected.
Technical Reports. The inspector should review (and, if.necessary, take to the
inspection site) copies of EPA or other publications that provide generic information
on industrial process operations. As noted elsewhere, the inspector's knowledge of
the processes and associated control equipment at a facility can be instrumental in
ensuring the success of an inspection.
Form R Report. The primary sources of information the inspector need*.to review
are the Form R chemical reports submitted by a facility to EPA. Each Form R
report contains eight types of information: facility identification data, ofisite location
data, chemical-specific data, manufacturing process data, release data, offsite transfer,
waste treatment methods, and pollution prevention data. Appendix A, contains a
blank Form R report
Interim Fatal, November 1992 3-6 EPCRA Data Quality Inspection Manual
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Table 3-1. Example of Facility Summary Matrix
Section 313
Chemical
Toluene
Hydrochloric
Acid
Lead
Compounds
Un
u
u
p
Fugitive
10.000
1-499
0
Stack
10,000
0
2,500
ReodTing
dWCtUU
0
200
50
Under-
ground
Injection
0
0
0
Omlte
Land
0
0
1,000
POTW
0
0
0
Other
OfTsite
Locations
500
0
20.000
Maximum
Amount
Onsite
5,000
2.000
10.000 '
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Pre-Inspection Preparation Chapter Thru
Inspectors should gather chemical-specific information that may be needed to make onsite
calculations or to determine where releases may occur. This information includes the
following chemical properties:
• Volatility/vapor pressure
• Solubility
• Henry's law constant (for dilute compounds)
• Specific gravity/density
• Molecular weight
• Fate of chemical in solution.
Many methods of estimating releases, such as those detailed in Estimating Releases and
Waste Treatment Efficiencies for the Tone Chemical Release Inventory Form (EPA 560/4-88-
002), also known as the "Green Book," require the use of such parameters to complete
release calculations. Some chemical properties may also dictate where an inspector should
look for releases. For example, if a particular chemical is highly volatile, the inspector
should look closely at air release estimates.
Understanding typical industrial uses and typical storage practices of a particular chemical
is also helpful. This information is contained in standard chemical dictionaries, such as The
Condensed Chemical Dictionary, published by the Van Nostrand Reinhold Company.
Inspectors should learn the treatment technologies used in the industry, and, if time and
resources allow, they should also investigate the efficiencies of different treatment units.
The inspector should then prepare a list of questions to discuss with the facility contact
during the inspection. Such questions typically seek to clarify any discrepancies in reported
information.
3 J.I EPCRA Section 312 Tier I and U Forms
Under Section 312, facilities must report information about the amounts, location, and
potential effects of hazardous chemicals to Local and State Emergency Planning Committees
(LEPC and SERQ. These reports consist of annual inventories of EPCRA chemicals kept
onsite. A two-tier approach exists for annual inventory reporting: Tier I and Tier II reports.
These inventory forms are due annually on March 1, since 1988.
Interim Final, November W2 3-8 EPCRA Date Quality Inspection Manual
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Chapter Three Pn-Inspection Preparation
Under Tier I, (See Appendix B) a facility must report the amounts and general location of
chemicals in certain hazard categories. These forms are a generalized summary of the
information collected, to complete the Tier n form. Tier I forms require development of
estimates for the amount of chemicals in each hazard category concerning the maximum
combined amount of hazardous chemicals, average daily amount present, and general
location of the chemicals in the facility.
A Tier n report (See Appendix B) contains basically the same information, but it must name
the specific chemical Tier n forms are more detailed and describe for each hazardous
chemical, the common name listed on the MSDS, maximum and average amounts of the
chemical present, storage conditions, location of the chemical, and confidential status of the
location information. Companies have the flexibility to choose whether to file Tier I or Tier
II forms, unless the SERC, LERC, or fire department request Tier n, but many companies
voluntarily provide Tier II reports.
Some Regional inspectors have requested a copy of the Tier n Inventory Report for
the facility from either the SEPC or LEPC EPCRA Section 313 chemicals or
mixtures reported at fairly high inventory levels can then be questioned during the
inspection.
Federal Database Comparison
The inspector should search the Regional files for any information obtained through
compliance monitoring activities of other Regional programs, (e.g^ NPDES permitting and
RCRA) relating to the facility to be inspected. Some Regions may have a filing system or
database from which the inspector can get information on the subject facility. In addition,
the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and the FIFRA and TSCA
Tracking System (FTTS) should be searched to determine if the company has been
inspected previously.
The inspector should also check other EPA databases, such as those listed below, for
information on the facility to be inspected.
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Pre-Inspection Preparation ___ Chapter Three
• TRIS. This database contains information on facilities subject to EPCRA Section 313
reporting. The TRIS database contains information on the facility, identification of
the toxic chemical, the amount of chemical released, and the media to which it was
released. Information on accessing this database can be obtained from the EPCRA
Section 313 Regional contact or by contacting TRI User Support at 202-260-9419.
• IDEA (Integrated Data for Enforcement, Aflalysisj Systen^. JThis is a new database
developed by the Office of Enforcement to integrate information from various
databases maintained by different program offices for enforcement targeting, case
screening, and multimedia initiatives. It is recommended that inspectors run the
facility through the IDEA database because it tracks an individual facility's compliance
records for most of the EPA statutes. A facility that has failed to report under
EPCRA may show up with a compliance record under a different statute. IDEA'S
information can be another tool to help an inspector determine whether EPCRA data
appear to be consistent across program lines. A User's Guide to the IDEA System,
dated August 2, 1991, provides instructions on how to access the system through the
EPA National Computer Center IBM mainframe.
Technical, rather than comprehensive, training for IDEA has been given in all 10
Regions to an average of about 10 people per Region. IDEA managers are currently
modifying IDEA so it will suppress confidential information when the States access
it
(Facility and Company Tracking System).i This database provides detailed
information on names, addresses, employment, sales, and SIC Codes. Facilities with
SIC Codes 28xx and 2911 or that are within a particular geographic area can be
specified. The database is available through on-line connection to the EPA National
Computer Center.
FINDS (Facility Index SvstemX This database is designed to track facilities subject
to various Federal environmental laws, including RCRA, NPDES, and the Clean Air
Act. It is available through on-line access to the EPA National Computer Center.
333 Confidential Business Information Considerations
Section 322 of EPCRA and EPA regulations (40 CFR Part 350) protect EPCRA trade
secret information from disclosure (as they apply to emergency planning, community right-to-
know, and toxic chemcial release reporting). The uncontrolled disclosure of trade secrets
including chemical identity, process, formulation, or production data could cause damage to
a facility's competitive position. In general, disclosure of legitimately trade secret
information is prohibited; however, there are certain specific and limited exceptions when
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Chapter Three Pre-Inspection Preparation
trade secret withholding is not allowed, (e.g., under EPCRA Section 304 no information may
be declared trade secret).
Dtfntoo* (40 CFR Part 359)
A trade secret may consist of any formula, pattem».device, or compilation of
information that is used in one's business, and that gives [the employer] an
opportunity to obtain an advantage over competitors who do not know or use it
Trade secret is not intended to provide protection for chemical identities that are
readily determinable by reverse engineering.
Companies reporting under EPCRA can, under-limited conditions-request that the-identity
of specific chemicals in their reports not be disclosed to the public. No other information
required by this law in the reports filed under other Sections of EPCRA can be withheld
from the public. To protect a chemical's identity from disclosure, the company must be able
to prove among other things that the information has not been reported under other
environmental regulation, and that it is a legitimate trade secret
The inspector should keep in mind that information obtained from a facility during an
EPCRA inspection can, for the most part, be disclosed in response to a request from the
general public, or other requesting party, under the Freedom of Information Act (FOIA).
In addition, because the inspector is very likely to require access to Confidential Business
Information (CBI) before (i.eM while preparing for an inspection), during, and after an
inspection, the inspector must be knowledgeable of EPA procedures governing access to,
handling of, and disclosure of CBI. The inspector and others who may use the information
may need to have CBI access authorization under various statutes (e.g., TSCA, RCRA, and
FIFRA), since only authorized individuals may have access to CBI. An inspector may need
access to CBI data that a subject facility submitted to EPA or provides during the inspection
as well as information* that was collected during a prior inspection under other statutes.
3.4 Providing Advance Notification
EPA is not required by law to provide advance notice of inspection. In some cases, the
Agency could be subject to criticism for checking compliance after providing advance
warning and for allowing a facility the time to address any "issues" they may be aware of
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Pre-Inspection Preparation Chapter Three
before the inspector arrives. It is up to the discretion of Regional management to decide
whether or not to provide advance notification. The inspector must abide by his/her
Regional policy regarding advanced notification.
The potential advantages and disadvantages associated with providing advance notification
are as follows:
• Potential advantages
- The facility will have the necessary documents, records, or personnel accessible
to the inspector, saving valuable time onsite and requiring less time during follow
up stages of the inspection.
- The subject facility appreciates being provided advance notification so that its
regular operations are not interrupted, thereby fostering a cooperative relationship
between EPA and the regulated industry.
• Potential disadvantages
- The inspector may not have the opportunity to view the subject facility under
normal operating conditions, because the facility, with advance notification, could
tailor its operations to fit preconceived notions of what the inspector may want
to see.
- If a tip or complaint is involved, advanced notification could put an
employee's/customer's/associate's relationship with the company in jeopardy (if,
indeed, the company is suspicious of the timing of the inspection versus an
incident).
3.4.1 Identification of Contact Person to Notify
If the decision is made to provide advance notification, the inspector must determine which
individual at a particular facility is the appropriate one to arrange the inspection. This
determination can be difficult. The inspector should contact the signer of the Form R report.
A D&B report can also be used, which usually provides the name and telephone number
of the senior person in charge of a listed facility. If all else fails, the inspector should call
the general number or directory assistance for the company and ask to speak to the person
in charge.
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ChapterThne Pry-Inspection Preparation
3.42 Items Addressed in Advance Notification
If advance notification is provided, the inspector should make note of this in the inspection
report. Specific objectives of advance notification include the following:
• Scheduling the inspection.
• Determining the appropriate site(s) for the inspection, including identification of
where the necessary records, as specified in the inspection plan, are located. Records
the inspector needs to review should be described as specifically as possible.
• Ensuring that personnel are available to accompany EPA inspectors during the
inspection.
If the facility representative contacted does not cooperate, the inspector's supervisor and the
Compliance Branch Coordinator at EPA Headquarters should be consulted for instructions
on how to proceed.
When providing advance notification by telephone to the appropriate contact person at the
facility, the inspector should discuss the following items:
• Introduction. The inspector should begin the telephone contact by introducing
her/himself as an EPA inspector or other person with the authority to conduct
EPCRA Section 313 inspections. The inspector should discuss the nature and
purpose of the inspection. If the inspection is routine, as opposed to "for cause" (Le.,
based on a tip or complaint), this fact should be conveyed. If the inspection is being
conducted "for cause," the inspector should obtain guidance from her/his supervisor
and/or Regional Counsel as to the nature and amount of information that should be
conveyed during the initial telephone conversation.
• Administrative details of the inspection. The inspector should discuss several
administrative matters pertaining to the inspection. Specifically, the inspector should
establish the following:
The location of and directions to the inspection site
The date and time of the intended inspection
The name and title of the facility employee or official who wfll serve as the
designated contact person for the inspection, if such person wfll be, different from
the one contacted during this advance telephone notification
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Pre-Inspection Preparation Chapter Three
- The fact that the facility should have certain records and other data available for
review during the inspection and that certain facility personnel should be available
during the inspection for interviews
- The need to tour the manufacturing and other operational areas of the facility
- The types of safety equipment that may be needed to tour the facility
• The company's right to claim EPCRA trade secrets for any information collected
at the facility
• A follow up letter that will be sent which includes: the purpose and scope of the
inspection, the records that the facility should make available for review by the
insr ::or during the inspection (discussed below), and the name of an EPA
con :t.
3.5 Pre-Visit Completion of the Inspection Checklist
Unless the intention of the inspection program is to conduct a "no-knock" inspection, the
inspector should contact the technical representative of a facility prior to the inspection to
complete Section 1.0 of the EPCRA Section 313 Data Quality Inspection Checklist. This
checklist was derived from the OPPT Quality Assurance Audit Manual developed in
cooperation with Radian Corporation.
Section 1.0 of the inspection checklist contains three major parts: technical review, supplier
notification, and logistics. Each part has questions that should be completed during a
telephone conversation with the facility representative prior to the inspection. Although the
checklist is largely self-explanatory, this section provides brief descriptions of the information
which the inspector should collect to assist in preparing for the inspection.
3.5.1 Technical Review
During the pre-inspection telephone interview, the inspector should ask the facility contact
how many Form R chemical reports were submitted for the reporting year (Question 1.1).
This will enable the inspector to verify the number of Form R reports received by EPA from
the facility.
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ChapterThne Pn-Inspcctwn Preparation
The inspector should ask the facility contact how many EPCRA Section 313 chemicals were
identified as being at the facility during the reporting year (Question 1.2). This will help the
inspector estimate the level of effort needed to complete the inspection for this facility.
The inspector should establish whether the facility submitted revised Form R reports
(Question 1.3) and should list all chemicals-for-which chemical- reports were revised
(Question 1.4). If the facility submitted revised reports for the reporting year, the inspector
should confirm whether EPA has the most updated version. If EPA does not, the inspector
should either request the new information over the telephone or ask the facility to have the
new data available at the time of the visit The inspector should also review the amended
Form R report(s) and determine the reason for the amendment
The inspector should next ascertain the number of full-time equivalent employees at the
facility during the reporting year (Question 1.5).
Definition (40CFR3723)
Full-time equivalent employee means 2,000 hours per year of full-time equivalent
employment A facility would calculate the number of full-time employees by totaling
the hours worked during the calendar year by all employees and dividing that total by
2,000 hours. Remember, if the facility had fewer than 10 full-time employees, it was
not required to report.
Next, the inspector should inquire about the type of industrial processes performed at the
facility, as well as any significant changes in processes and treatment technologies that have
occurred since the reporting year (Questions 1.6, 1.7, 1.8, 1.9, and 1.10). The inspector
should describe the operations and any changes thoroughly in the appropriate questions
within the checklist. This information will 1) verify the data which the EPA currently has
on the facility and operations and 2) focus the inspector on the specific changes which have
occurred at the facility since they last reported.
Finally, the inspector should be sure to emphasize to the facility contact that all supporting
materials used to develop information contained within the Form R chemical reports must
be available for review. In addition, s/he should request that copies of process flow diagrams
be available at the time of the visit
EPCRA Data Quality Inspection Manual 3-15 Interim Final, November 1992
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Pre-Inspection Preparation Chapter Time
332 Supplier Notification
In accordance with 40 CFR Section 372.45, suppliers and distributors of mixtures that
include EPCRA Section 313 chemicals must notify their customers of the following:
• A statement that the mixture or trade •name .product or chemicals is subject to the
reporting requirements of EPCRA Section 313.
• The name of each toxic chemical and associated Chemical Abstracts Service (CAS)
registry number of each chemical if, applicable.
• The percentage, by weight, of each toxic chemical (or all toxic chemicals within a
listed category) contained in the mixture or trade name product.
Notifications must be sent to facilities described in 40 CFR Section 372.22 or to persons who
may in turn sell or otherwise distribute such mixtures or products to a facility described in
40 CFR Section 372.22(b). An example of a Supplier Notification form is found in
Appendix C Receipt of the Supplier Notification form means that users and/or processors
have received information on all the purchased mixtures and trade name products containing
EPCRA Section 313 chemicals.
A Supplier Notification form is a tool that facilities use to improve the accuracy and
completeness of their Form R data. This general information on supplier notification is
important because the accuracy and completeness of the data in the Supplier Notification
form will affect a faculty's ability to make threshold determinations and improve the accuracy
of their data. According to Analysis of Compliance with the Supplier Notification
Requirements under Section 313 of the Emergency Planning and Community Right-to-Know
Act fEPCRAX 65 percent of users and/or processors reported that the availability of
Supplier Notification data improved the accuracy of their estimates. In addition, inspectors
can examine it to verify whether a facility had adequate information (as found in a complete
and accurate Supplier Notification form) to correctly estimate their releases.
Suppler Notffica&m Requirements (49 CfX 37Z4S)
Interim Final, November 1992 3-16 EPCRA Data Quality Inspection Manual
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Chapter Three Pre-Inspection Preparation
Facilities must comply with supplier notification requirements if:
. Clarified in SIC Codes 20 through 39
• Manufactures, imports, or processes a listed EPCRA Section 313 chemical
• Sells or distributes a mixture or tradd"3aTm"e "product containing the EPCRA
Section 313 chemical to either a SIC Code 20-39 company or a company that
subsequently sells the mixture or trade name product to another SIC Code 20-
39 company.
The following section provides information for completingjhe Supplier Notification section
of the checklist and contains information concerning supplier notification and data quality.
General Supplier Notification. First the inspector should document whether the
facility received the appropriate notification from its supplier(s) regarding mixtures
containing EPCRA Section 313 chemicals (Question 1.11) and then list the names
and addresses of any suppliers that did not provide notification to the facility
(Question 1.12). The inspector should ascertain whether the facility distributed
mixtures containing Section 313 chemicals during the reporting year (Question 1.13).
If the facility distributed mixtures containing Section 313 chemicals, the inspector
should record whether the facility developed and distributed the appropriate
information to its customers (Question 1.14). During the inspection, the inspector
should request a copy of the information distributed.
Supplier Notification and Data Quality. The "percent by weight of the Section 313
chemical" is the critical piece of information contained in the Supplier Notification
for the purpose of release determinations. Inspectors should do the following:
- Examine the Supplier Notification form applicable to/received for each chemical
. Quiz the company on its use of Supplier Notification information to determine
release estimates
- Take note of the formulas used (if any) to determine release estimates from
Supplier Notification.
3.53 Logistical Arrangements
EPCRA Data Quality Inspection Manual 3-17 Interim Final, November 1992
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Pn-Inspection Preparation Chapter Thrte
The inspector should inquire as to the size of* the facility, including the production or
processing areas; storage facilities, and treatment areas (Question 1.15). In addition, the
inspector should document the procedures used by the facility to collect and document
information for EPCRA reporting and the number of personnel involved (Question 1.16).
This will assist the inspector in planning the resources (both time and personnel) needed to
complete the inspection. Finally, the inspector- should request that the appropriate
personnel are available during the inspection for interviews.
The inspector should clarify with the facility contact whether the facility wfll be operating
under normal conditions (Question 1.17) and whether there wfll be any problems in
arranging for a tour of the facility. In addition, the inspector should identify any personal
protective equipment needed for a tour of the facility (Question 1.18).
Interim Final, November 1992 3-18 EPCRA Data Quality Inspection Manual
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Chapter Thru _ Pn-Inspectum Preparation
3.6 Section 1.0 of the Inspection Checklist: Telephone Contact
Facility ID: __
TECHNICAL REVIEW
1.1 How many Form R chemical reports were-sttbmitted for this facility for the reporting
year?
1.2 How many 313 chemicals were identified by this facility, but not reported, for the
reporting year?
1.3 Did the facility submit any revised Form R chemical reports for the reporting year?
YES..... d NO..... 13 (If no, skip to Q. 1.5.)
1.4 List the chemicals which had revised chemical reports here.
1.5 How many full-time equivalent employees did the facility have during the reporting
year?
NOTE: If there were fewer than 10 full-time equivalent employees, this facility was not
required to report
EPCRA Data Quality Inspection Manual 3-19 Interim Final, November 1992
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Pre-Inspection Preparation Chapter Thrtt
1.6 Briefly describe the number and type of industrial processes performed at this facility
during the reporting year.
Facility ID:
1.7 Have the facility's process operations significantly changed since the reporting year
(including equipment, chemicals, feedstock, etc.)?
YES ..... NO ..... (lino, skip to Q. 1.9.)
1.8 Briefly describe any process changes.
1.9 Has the facility implemented any new treatment technologies since the reporting year?
YES n NO..... D (If no, slap to Q. 1.11.)
1.10 Briefly describe any new treatment operations.
SUPPLIER NOTIFICATION
1.11 Did the facility receive notification from chemical/material suppliers of all Section 313
chemicals in their products supplied to the facility during the reporting year?
Interim Final, November 1992 3-20 EPCRA Data Quality Inspection Manual
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Chapter Three Pit-Inspection Preparation
YES d NO..... 13 (Ifyes, skip to Q. 1.13.)
1.12 Record the name(s) and address(es) of suppliers that did not notify this facility of
Section 313 chemicals in their products.
Facility ID:
1.13 Did the facility distribute chemicals listed under Section 313 in mixtures or as trade
name products during the reporting year?
YES ..... NO ..... (If no, skip to Q. 1.15.)
1.14 Did the facility develop and distribute supplier notification information under Section
313 requirements?
YES..... NO.....
Formulas used to determine release estimates from supplier notification. (Add a question
# here???)
1.15 How large an area (# buildings, acres, etc.) do the production areas, storage facilities,
and treatment areas of the facility occupy?
(Consider Ms when planning the type and duration of tour that would be most useful)
1.16 Briefly describe the procedures used to collect and document information for EPCRA
reporting, including the number of people involved at the facility and whether they wfll
be available during the audit to answer questions.
EPCRA Data Quality Inspection Manual 3-21 Interim Final, November 1992
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Pre-Inspection Preparation Chapter Three
Interim Final, November 1992 3-22 EPCRA Data Quality Inspection Manual
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Chapter Three ___ Pry-Inspection Preparation
LOGISTICS
1.17 Will the facility be operating under normal conditions at the time of the audit?
YES..... n NO.....
1.18 What personnel protective equipment will be needed to participate in a facility tour?
Hard Hat
Safety Boots
Safety Glasses
Respirator
Other
FOR THE INSPECTOR ONLY - DO NOT ASK THIS OF FACILITY:
1.19 Coordination/logistics with other members of multimedia team, if applicable.
EPCRA Data Quality Inspection Manual 3-23 Interim Filial, November 1992
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Prt-Inspection Preparation Chapter Three
3.7 Development of an Inspection Plan
After completing Section 1.0 of the inspection checklist, the inspector should then develop
the inspection plan. An inspection plan is designed to help the inspector focus on the
important elements of the planned inspection and to provide the inspector with a pre-
planned methodology for conducting the inspection. The inspector should ensure that key
aspects of the inspection are not overlooked when developing this plan. Also, the inspector
should use the plan to brief facility officials during the opening conference on the general
approach to the inspection. However, the inspector should not provide facility officials with
a copy of this plan, because the inspector may want to deviate from the plan during the
course of inspection and wfll not want to feel locked into the details outlined in the plan.
The worksheet presented in Figure 3-2 should provide information directly relevant to the
development of the inspection plan.
3.7.1 Purpose
The main purpose of the inspection plan is to serve as a guide or blueprint to the entire
inspection process at the subject facility. The inspector should keep in mind that one of tha
most important objectives of the inspection is to collect enough documentation of potential
violations of EPCRA to determine compliance and take appropriate enforcement actions
against subject facilities. Section 3.7.2 outlines the elements of a basic inspection plan.
The investment of time required to produce a quality inspection plan can save time for the
inspector once at the inspection site. Also, the inspector can make better use of facility
officials' time if a well-prepared plan guides the inspection.
A well-developed inspection plan wfll help the inspector accomplish the following:
• Know the facility's compliance status during the inspection
• Develop a plan for evidence collection techniques should the inspection lead to
a case being issued.
3.72 Elements of the Inspection Plan
Written inspection plans may vary in length and subject matter, but should include at least
the following components:
Interim Final, November 1992 3-24 EPCRA Data Quality Inspection Manual
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Chapter Three Pry-Inspection Preparation
• Objective of the background data search and review and the inspection
• Scope and assessment topics of interest/concern
• Anticipated inspection activities and field techniques.
The following guidelines should assist the inspector in developing these components:
• Objective of Inspection and Background Data. This introductory section should
provide a brief history of factors relevant to the particular facility (e.g., previous
TRI reports, previous inspection dates and types of inspections, whether any
potential compliance issues were identified and what they were). This section
should also identify the objective or reason for the inspection. This will vary from
inspection to inspection (e.g., "for cause," random, case development, or
followup). More specific objectives may also be identified in addition to the
overall objective.
• Scope and Assessment Topics. The inspection plan should clearly establish the
scope of the inspection and the assessment topics. The scope of the inspection
is a function of the overall objective of the inspection. For example, if the
inspection is "for cause," then the scope of the inspection should include all
records, operations, and areas of the facility that will need to be inspected to
determine compliance with the provisions of EPGRA Section 313 suspected of
being violated. Some discussion of the boundaries of the inspection should be
included (i.e., if the inspection will include a tour of the facility, as well as records
review and interviews with personnel, or will only focus on a records review).
Once the scope has been identified, the inspection plan should designate the
assessment topics. Assessment topics can be roughly defined as the major
regulatory areas to be covered during the inspection. The assessment topics
should be further broken down into specific questions to be asked of facility
officials concerning the particular assessment topic and specific associated tasks.
• Inspection Activities. Once the assessment topics have been established, the
inspector must determine the most appropriate inspection activity or method of
assessing compliance and gathering evidence of potential violations (e.g.,
observation, records review, interviews, collection of samples) for each task.
Compliance and assessment and evidence collecting techniques can be organized
in an inspection plan as follows:
Facility Tour. List the activities, operations, and/or equipment to be
observed (e.g., manufacturing processes and equipment).
EPCRA Data Quality Inspection Manual 3-25 Interim ratal, November 1992
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Pre-Inspection Preparation _ Chapter Three
Records Review. List facility records that will be reviewed to determine
statutory and regulatory compliance, along with the regulatory citation(s)
applicable to each record that must be maintained, as well as a
description of the required content of each record.
Conduct of Interviews. List the titles, and names (if known) of key
personnel with whom meetings should be held to determine compliance
with specific regulatory provisions.
Interim Final, November 1992 3-26 EPCRA Data Quality Inspection Manual
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Chapter Three
Pre~Inspection Prtparat
Figure 3-1
Worksheet for Developing a Written Inspection Plan
1.0 Components of the Written Inspection Plan
Does the written toBperttaipha toctod^- .-**T<^^ ?~ **
• Objective of the background data search/review and the
inspection?
• Scope and assessment topics of interest/concern?
• Anticipated inspection activities and field techniques?
•YM
No
1.1 Objective of the Background Data Search/Review and the Inspection
fVi«a fhfa Mtnifwinmt nf fh» wrlHMt Jii< imi Itmi nl*i* fnrfiufe*
i
• Brief history of boon relevant to the facility?
• Objective or reason for the inspection?
YM
No
1.2 Scope and Assessment Topics of Interest/Concern
Does this conponeat of the written Inspection plam
• Clearly establish the scope of the inspection and the assessment
topics?
• Discuss the boundaries of the inspection?
• Designate the assessment topics?
Ye*
No
13 Anticipated Inspection Activities and Field Techniques
Does the written fatfpecttoa plan consider fee Mtowfnf acthftksr
• Facility Tour?
• Records review?
• Conduct of interviews?
Ye»
No
EPCRA Data Qualify Inspection Manual 3-27
Interim Final, November 1992
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Prt-Inspfction Prtparatiam QupttrThrt*
3.8 Collection of Inspection Documents
In addition to preparing the written inspection plan and reviewing EPA records prior to conducting the
inspection, the inspector should also gather and prepare the necessary documents and equipment to be
used during the inspection.
No single list of documents and equipment can be appropriate for all inspections. The list provided below
is intended for guidance purposes only. The inspector's experience in the field and information obtained
during pre-inspection planning should assist in preparing lists tailored to specific inspection sites and
needs.
Specific needs will be determined by the requirements of the inspection, the availability of equipment,
conditions at the facility, EPA policies, and whether or not advance notification of an inspection will be
given. Documents necessary for the inspection should be prepared in advance of me inspection,
whenever possible. The inspector should be familiar with these required documents.
Several documents that are used in facility inspections include:
• Notice of Inspection. Portions of this form can be filled out in advance, but the time of
inspection and the names of facility officials must be entered at the time of inspection.
• Receipt for Samples and Documents (See Figure 5-4). All samples and documents taken
during an inspection are listed on this form. Any documents and samples taken during an
inspection that have been claimed as trade secret information should also be noted on this
form.
• Copies of EPCRA and Specific Regulations. Some facility officials may not have copies of
EPCRA or of applicable rules and regulations. Inspectors should have these available for
distribution.
• EPA Outreach Materials. Inspectors should provide current, relevant educational information
to facility officials relating to voluntary compliance efforts. EPA has established an EPCRA
Hotline at 1-800-5J5-0202.
Iturim Ftiud, November 1992 3.28 EPCRA Data Quality Inspection Manual
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Chapter Four Industrial Profiles for Section 313 Nonreporter and Data Quality Inspections
Chapter Four
Industrial Profiles for Section 313 Nonreporter
and Data Quality Inspections
Page
4. Industrial Profiles for Section 313 Nonreporter and Data Quality Inspections 4-1
4.1 Introduction 4-1
EPCRA Data Quality Inspection Manual 4-i Interim Final, November 1992
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Industrial Profiles for Section 313 Data Quality Inspections Chapter Four
BLANK PAGE
Interim Final, November 1992 4-ii EPCRA Data Quality Inspection Manual
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Chapter Four Industrial Profiles for Section 313 Nonreporter and Data Quality Inspections
4. Industrial Profiles for Section 313 Nonreporter and Data Quality Inspections
4.1 Introduction
At the end of this manual are seven profiles for industries that have been identified by the Regions as
having a high potential for:
• Being nonreporters under EPCRA Section 313
• Having data quality problems on their Form R submissions
The industry categories that profiles have been developed for include:
• Foundries
• Electroplating
• Petroleum Refining
• Ink Formulation
• Motor Vehicle Parts and Supply Manufacturing
• Furniture Manufacturing
• Paint Formulation
It is believed that these profiles will assist inspectors with:
• Relevant permit information from other statutes
• Byproducts
• Major sources
• Throughput qualities
• Typical chemicals
• Process flow diagrams
• Common pollution prevention/control equipment
EPCRA Data Quality Inspection Manual 4-1 Interim Final, November 1992
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Industrial Profiles for Section 313 Data Quality Inspections Chapter Four
BLANK PAGE
Interim Final, November 1992 4-2 EPCRA Data Quality Inspection Manual
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Chapter Five Entry to the Facility and the Opening Conference
Chapter Five
Entry to the Facility and the Opening Conference
Page
5. Entry to the Facility and the Opening Conference 5-1
5.1 Introduction 5-1
5.2 Authority to Enter and to Inspect 5-1
5.2.1 Arrival 5-1
5.2.2 Credentials 5-2
5.2.3 Notice of Inspection 5-2
5.3 Consent to Enter and Inspect 5-2
5.3.1 Consent 5-3
5.3.2 Reluctance to Give Consent 5-5
5.3.3 Withdrawal of Consent 5-7
5.3.4 Procedures for Denial of Entry 5-7
5.3.5 Warrants 5-8
5.4 Opening Conference 5-8
5.4.1 Purpose 5-9
5.4.1.1 Explaining Inspection Activities 5-13
5.4.1.2 Understanding Facility Operations and Practices 5-13
5.4.1.3 Logistical Arrangements 5-14
List of Figures
Figure 5-1. Notice of Inspection 5-4
Figure 5-2. Types of Inspection Restrictions 5-6
Figure 5-3. Declaration of Confidential Business Information 5-11
Figure 5-4. Receipt for Samples and Documents 5-12
EPCRA Data Quality Inspection Manual 5-i Interim Final, November 1992
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Entry to the Facility and the Opening Conference Chapter Five
BLANK PAGE
Interim final, November 1992 5-ii EPCRA Data Quality Inspection Manual
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Chapter Five Entry to the Facility and the Opening Conference
5. Entry to the Facility and the Opening Conference
5.1 Introduction
This chapter discusses the required procedures for entering a facility to conduct an EPCRA inspection.
Guidance is provided to the EPCRA inspector on the preliminary aspects of an EPCRA inspection,
ranging from a discussion of the importance of facility owner/operator consent to procedures for
conducting an opening conference. Procedures for conducting the inspection to assess data quality are
covered in Chapter 6.
S3. Authority to Enter and to Inspect
EPCRA implicitly authorizes EPA to enter and to inspect any establishment or facility in which chemical
substances are manufactured, processed, stored, held, or otherwise used before or after their distribution
in commerce. This implicit authority is a function of the self-implementing Section 313 reporting
requirement and EPA's authority to assess a civil penalty against individuals who fail to report.
An inspection under EPCRA may be conducted only after the inspector has presented the following items
to the owner, operator, or agent in charge:
• Appropriate credentials
• Written Notice of Inspection.
The scope of a EPCRA inspection may include inspection of records, files, papers, processes, controls,
and facilities. EPCRA does not prohibit inspection of any certain type of data.
EPCRA inspections must be completed with reasonable promptness and at reasonable times (i.e., normal
working hours).
5.2.1 Arrival
The inspector must arrive at the facility during normal working hours and locate a facility official
immediately. After locating the appropriate facility official(s), the inspector should:
• Identify her/himself as an EPA inspector and present EPA credentials
• Introduce the inspection team (if a team is present) in a courteous manner
• Present a Notice of Inspection (NOI).
EPCRA Data Quality Inspection Manual 5-1 Interim Final, November 1992
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Entry to the Facility and the Opening Conference Chapter Five
Credentials
Upon arrival at the facility, the inspector should present her/his EPA credentials. These credentials
indicate that the inspector is a lawful representative of the EPA Administrator authorized to perform
inspections under EPCRA. Credentials must be presented whether or not identification is requested.
Business cards may be used for introductory purposes, but they do not replace official credentials.
Credentials should never leave the sight of the inspector, and the inspector should not permit
photocopying of credentials.
Approximately SO percent of EPCRA inspectors are members of the National Council of Senior Citizens
(NCSC). NCSC inspectors are issued special EPCRA credentials. These credentials are provided by
EPA Headquarters.
5.2.3 Notice of Inspection
After the inspector has presented her/his credentials, s/he should present the written NOI to corporate
officials. The NOI form (Figure 5-1) should be filled out completely. This NOI informs the owner,
operator, or agent in charge of the reason for an inspection and contains the inspector's address and
signature. It should be dated and the time of inspection should be entered as proof that entry was
requested at a reasonable hour. An NOI is not required for each entry made during the period covered
by the inspection, only the initial entry.
The inspector presents the NOI after arrival at the facility to be inspected. EPCRA does not require the
inspector to provide advance notification of the inspection to the facility, but some inspectors may choose
to provide such notice (discussed in detail in Chapter 3).
The inspector should make a note in the inspection notebook that the NOI was presented and should keep
a copy of the notice for the records.
To make certain that all steps are covered in conducting an EPCRA inspection, the inspector should refer
to the Guidelines for a Comprehensive EPCRA Section 313 Data Quality Inspection Process found in
Chapter 1.
5 J Consent to Enter and Inspect
EPA has authority to enter a facility subject to EPCRA for the purposes of conducting an inspection by
the U.S. Supreme Court's decision in Marshall, Secretary of Labor v. Barlow's, Inc. (1978), and may
do so without obtaining consent. However, facility officials sometimes withhold consent or attempt to
impose restrictions or conditions upon entry. EPA policy requires the inspector to obtain such consent
for the inspection. Therefore, the inspector must do one of the following:
Interim final, November 1992 5-2 EPCRA Data Quality Inspection Manual
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Chapter Five Entry to the Facility and the Opening Conference
• Obtain consent prior to conducting the inspection
• Or, if unable to obtain consent, followed proper procedures for when entry to a facility
is denied or when conditions or restrictions are imposed by facility officials.
Consent to enter must be given knowingly and freely. The inspector must not coerce or lie to facility
officials in order to induce consent.
Express consent is not necessary and the absence of express denial constitutes consent. Entry remains
voluntary and consensual unless there is a withdrawal of consent. Consent must be given by the person
with authority to give consent at the time of the inspection. An owner does not always have authority
to give consent. If someone with the necessary authority cannot be located, the inspector must make a
good faith effort to determine who may otherwise consent to the entry (such as the agent in charge). The
inspector should present her/his credentials to that individual and record the name and title of that person
in the inspection record book.
In most instances, if the inspector follows proper procedures upon arrival at the facility (i.e., presentation
of credentials and NOI), it will be simple to obtain consent to enter. However, special situations may
arise, as follows:
• Owner/operator reluctance to give consent
• Withdrawal of consent.
These situations and the inspector's responsibilities in each situation are discussed below.
53.1 Consent
Consent is generally needed to inspect the nonpublic portions of a facility. Entry is considered voluntary
and consensual, unless the inspector is expressly told to leave the premises. Expressed consent is not
necessary for a credentialed inspector; however, expressed consent is necessary for uncredentialed persons
accompanying an inspector.
EPCRA Data Quality Inspection Manual 5-3 Interim Final, November 1992
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Entry to the Facility and the Opening Conference
Chapter Five
Figure 5-1. Notice of Inspection
NOTICE
iKf P PZk UA. ENVDtONKD
^^ •• • •• Emergency Planning and
<
1 INVESTIGATION IDENTIFICATION 2. TIME
DATE J.NSPECTOR-N6 5A.LY SEGNO
4 INSPECTOR ADDRESS
OP INSPECTION
WAI PROTECTION AGENCY
Community Rght-to-Know Act of 1986
a*MM*nii) £r££4
3. FIRM NAME
5 FIRM ADDRESS
REASON FOR INSPECTION: This inspection is for the purpose of determining
compliance with the Emergency Planning and Community Right-to-Know Act of 1986.
Section 313 toxic chemical release reporting requirements. The scope of this inspection
may include, but is not limited to: reviewing and obtaining copies of documents and
records; interviews and taking of statements; reviewing of chemical manufacturing.
importing, processing, and/or use facilities, including waste handling and treatment
operations; taking samples and photographs; and any other inspection activities
necessary to determine compliance with the Act.
MSPECTOR SIGNATURE
•fTLE DATESIGNE
RECFIENT SIGNATURE
NAME
JD TITLE UA it SIGNED
Interim Final, November 1992
5-4 EPCRA Data Quality Inspection Manual
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Chapter Five Entry to the Facility and the Opening Conference
5.3.2 Reluctance to Give Consent
Receptiveness toward inspectors will vary from facility to facility. However, in most instances,
inspectors will be able to proceed without difficulty. In some cases, officials may be reluctant to give
entry consent because of misunderstandings of responsibilities, inconvenient scheduling, or other reasons
that may be overcome by diplomacy and discussion. Whenever the inspector encounters resistance to
enter, s/he should tactfully probe the reasons for the resistance and work with officials to overcome the
obstacles. The inspector should also explain in detail the purpose of the inspection. Care should be taken
to avoid threats of any kind, inflammatory discussions, or increased misunderstanding. The inspector
should suggest that the officials seek advice from their attorneys on the scope of EPA's inspection
authority under EPCRA and the U.S. Supreme Court's decision in Marshall, Secretary of Labor v.
Barlow's, Inc. (1978). However, it is crucial during any negotiations or discussions that an inspector not
agree to any restrictions on the scope of an inspection authorized under EPCRA. Types of restrictions
that facility officials may attempt to impose on inspectors are described in Figure 5-2.
If consent to enter still is denied, the inspector should follow denial of entry procedures described in
Section 5.3.4.
Under no circumstances should the inspector attempt to gain entry or consent to enter by coercive actions
or by making statements that suggest that the facility representatives could be fined or otherwise
"punished" unless entry is allowed.
EPCRA Data Quality Inspection Manual 5-5 Interim Final, November 1992
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Entry to the Facility and the Opening Conference Chapter five
Figure 5-2. Types of Inspection Restrictions
Types of Inspection Restrictions on Inspectors
Waivers and Other Restrictive Agreements
EPA inspectors have the right and the responsibility to refuse to sign any agreement or
waiver that promises that records or other data obtained from the facility will not be
released to any third party. Any attempt by a facility to restrict inspection activities by
requiring inspectors to sign such restrictive agreements should be viewed as a denial of
consent to inspect the facility and treated accordingly. However, during the opening
conference, inspectors must advise the facility owner, operator, or agent-in-charge of
her/his right to claim such data as CBI and of the procedures for making such claims.
Restrictions on Use of Photographic or Other Recording Equipment
EPCRA inspectors may document evidence of potential violations at the facility by means
of tape recordings, photography, recording by electronic devices with a visual taped
readout, or by other methods. Inspectors have the authority to use these recording
devices, which include aerial overflights, LIDAR (a type of radar used to detect and
measure distant air emissions of paniculate matter), and other aerial or ground
surveillance sense-enhancement devices. Facility officials often attempt to restrict the use
of any or all such devices by EPA inspectors. Any attempt by a facility to restrict the use
of such devices is considered a denial of consent and appropriate procedures governing
such denials should be followed. Facility officials should be advised that photographs
may be claimed as CBI.
Health and Safety Restrictions
The inspector should ascertain the facility safety and applicable OSHA requirements
before the inspection, if possible. The inspector should be aware that s/he is subject to
the applicable safety requirements of the facility. For example, if safety boots and glasses
are required to walk through the manufacturing area, then the inspector must wear these
items. However, EPA inspectors cannot be required to participate in the facility's safety
training program as a condition of conducting an EPCRA inspection. If facility officials
make such a demand, the inspector should refuse and should treat the situation as a denial
of consent.
Refusal to Allow Access to Certain Areas of the Facility
If, during the course of the inspections, access is denied or restricted to certain areas of
the facility, the inspector should make a notation describing such denial or restriction in
her/his notebook and identify which portion of the inspection could not be completed due
to the denied or restricted access. However, despite the access restriction, the inspector
should proceed with the remainder of the inspection. After leaving the facility, the
inspector should contact his/her supervisor to determine whether a warrant should be
obtained to complete the inspection.
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Chapter Five Entry to the Facility and the Opening Conference
533 Withdrawal of Consent
Occasionally, facility officials may initially consent to an inspection and later withdraw the consent during
the inspection. Consent to the inspection may be withdrawn at any time after entry has been made. EPA
policy concerning withdrawal of consent is to view it as an outright denial of consent. In such cases,
appropriate procedures should be followed. All activities and evidence obtained prior to the withdrawal
of consent are valid. Therefore, evidence obtained by the inspector before consent was withdrawn would
be usable in any subsequent enforcement actions and should be retained by the inspector. The inspector
should not give any evidence that has been collected before the withdrawal of consent back to the facility
if requested to do so by the facility official.
53.4 Procedures for Denial of Entry
As noted previously, the inspector should make certain that s/he has properly presented all credentials
and notices to the facility owner/operator or agent in charge. If the inspector is denied entry, s/he should
withdraw from the premises. Under no circumstances should the inspector discuss potential penalties
under EPCRA or do anything that may be construed as coercive or threatening. The inspector should
leave a copy of the written NOI with facility officials to show that proper procedures were followed.
The inspector should carefully note all observations pertaining to the denial, including the following
items, in her/his field notebook:
• Facility name and exact address
• Name and title of person(s) approached
• Time of denial and reason for denial
• Authority of person who refused entry
• Facility appearance
• Any reasonable suspicions that refusal was based on a desire to cover up regulatory
violations.
If the inspector is denied access to some parts of the facility, s/he should note the circumstances
surrounding the denial and the portion of the inspection that could not be completed and then proceed
with the rest of the inspection. After leaving the facility, the inspector should contact her/his supervisor
to determine whether a warrant should be obtained to complete the inspection.
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Entry to the Facility and the Opening Conference Chapter five
53.5 Warrants
Hie inspector, after leaving the premises, should contact her/his supervisor immediately. Once contacted,
the supervisor will confer with attorneys to discuss the desirability of obtaining an administrative warrant
and will contact OCM.
Definition
A warrant is judicial authorization for an appropriate official (EPA inspector, U.S. Marshal, or
other Federal officer) to enter a specifically described location and perform specifically described
inspection functions.
If a decision is made to obtain a warrant, the designated official should contact the U.S. Attorney of the
district in which the facility is located. EPA should assist the U.S. Attorney in the preparation of the
warrant and necessary affidavits. The application for a warrant should identify the statutes and
regulations under which EPA is seeking the warrant, as well as the name and location of the site or
establishment to be inspected and, if possible, the names of the owner and/or operator. The application
must be signed by the U.S. Attorney or her/his assistant.
An inspector may also obtain a warrant before s/he conducts an inspection. A pre-inspection warrant may
be obtained at the discretion of the EPA Regional Office. Situations in which the inspector may want
to obtain a pre-inspection warrant include the following:
• A suspected violation could be covered up during the time needed to secure a warrant
• Prior correspondence or other contact with the facility provides reason to believe that
entry will be denied when the inspector arrives
• The facility is unusually remote from the EPA Regional Office or a U.S. District Court
and obtaining a warrant would be inconvenient to the government.
5.4 Opening Conference
Once credentials and required notices have been presented, the inspector can hold the opening conference
with facility officials. During this meeting, the inspector should present an overview of the inspection
plan and attempt to gain a fuller understanding of the facility's organization, obtain current information
regarding facility operations and processes, and clarify any key issues or ambiguities identified during
the pre-inspection preparation phase (discussed in Chapter 3).
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Chapter Five Entry to the Facility and the Opening Conference
5.4.1 Purpose
The purpose of the opening conference is to establish a forum for the exchange of information between
EPA inspection personnel and facility officials. To facilitate the inspection, the inspector should attempt
to accomplish the following items during the opening conference:
• Develop a rapport with facility officials and start the inspection on a positive and
professional note
• Present and discuss any supporting information (e.g., a copy of EPCRA, Form R and
instructions booklet, or other resources)
• Acknowledge that the inspection may disrupt daily facility routines, but assert that
reasonable efforts will be made to minimize such disruption
• Listen carefully and be willing to answer questions from the facility officials
• Avoid compromising EPA policies or procedures or overstepping her/his authority to
accommodate facility representatives.
The opening conference is an appropriate time for the facility to claim any legitimate information as
confidential. The inspector should have facility officials complete a Declaration of Confidential Business
Information (Figure 5-3). The inspector should also be familiar with the fact that facilities tend to claim
information under EPCRA as trade secret and CBI under statutes such as TSCA (See Section 3.2.5).
In addition, the inspector should present to facility officials a copy of a Receipt for Samples and
Documents (Figure 5-4). This document provides EPA with a list of documents and samples of chemical
substances and/or mixtures collected during the EPCRA inspection.
A cooperative working relationship developed during the opening conference can set the tone for the
remainder of the inspection. If approached properly, the opening conference provides an ideal
opportunity for the inspector to function as a public relations liaison and educator.
From the perspective of both EPA and the regulated community, the inspector is well-positioned to serve
as a source of regulatory information. As such, the inspector should provide tactful assistance to the
facility before, during, and after the inspection.
During the conference, inspectors may want to focus on the following topics:
• Overview of EPCRA
• Specific regulation requirements
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Entry to the Facility and the Opening Conference .Chapter Five
• Importance of EPCRA Section 313 data quality
• Options for helping with facility-specific problems
• Agency outreach efforts.
In addition, the inspector is responsible for explaining inspection activities to facility officials, gaining
and understanding of facility operations and practices by asking facility officials questions, and making
logistical arrangements.
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Chapter Five
Entry to the Facility and the Opening Conference
Figure 5-3. Declaration of Confidential Business Information
vvEPA
WASHINGTON. DC IOMO
TOXIC SUBSTANCE* CONTROL ACT
DECLARATION OF CONFIDENT AL BUSINESS INFORMATION
OUt Va JO 70-400 7
fom «.jj ti
535TT
1 INVESTIGATION IDENTIFICATION
[INSPECTOR NO
DAILY sea NO
4 FIRM ADDRESS
INFORMATION OtSIONATED AS CONFIDENTIAL OUSlNESS INFORMATION.
NO
DESCRIPTION
ACKNOWLEDGEMENT BY CLAIMANT
Thi undtnuontd scknowMdooi tint Hit mformitian daeribtd ebon a dugntttd a CanfidtntMl IUSMB Infonnition undtr Section 14(c) of tht
Toxic Subnnca Control Act. Thi undmigntd Iurthir Kknonriooga tint hi/*i it wthorii* to miki weh clnmi for htt/hir firm.
Tht undmigfMd unaimandt th« chUlHioB to confidmtality dami nuy bt midt. nd ttut clnmi on not likdv to bi uphdd union tht mfor
mttion mom tht tollomng guidMiiwi (II Thi comptny hti Bkm mwurti to pronct tht confidjntWitv of tht mformition ind it mttndt to
contmut to akt uch mtourti. (2) Thi mformiun • not. tnd h» no' bttn rauntbly trttlnobli mthout tht compin>'i tenant by othtr
ponora (other than govtmrntnnl bodw) by UH of lojituntrt mam (ottitr thin dwovtry bo*d on I lowing of vtcnl (Hod in i mdciH or
outv-iudoal procMdino). (31 Tht mformition n not publicly milibli ttewhtn. ond («) Oiclouri of tht information would am wbrantiD
horm to tht compmy'icompititm poauon
NSPCCTOH SIGNATURE
CLAIMANT SIONATUMC
DATE SIGNED
Ef A ftm 7740-2 I IMS I
'ILE VELLOW FACILITY PINK - REGIONAL OFFICE GOLD • INSPECTOR'S FILE
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Interim Final, November 1992
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Entry to the Facility and the Opening Conference
Chapter Five
Figure 5-4. Receipt for Samples and Documents
&E
__ RECEIPT FOR SAMPLES AND DOCUMENTS
f~ f\ V A. BfVBOMKBfT AL PROreCTION AOBNCT
" * Envigency Planning and ConrninttyRlaMJHCnewAei 0(1966
(SUHBani) ^Tce* Page of
BATE INSPECTOR MO OA1Y SEO. NO.
4 INSPECTOR ADDRESS S. FIRM ADDRESS
77w document* tnd Mfiptos ol ehtmcMl tubtttnet* mint maamt tf Mcnb*tf tetow win eofecnd in con/MCten
with th» tOmmanton and »nlore»m»nt el th» £/n«p«nex Pltnning and Community RphMo-Know Act of 1986
RECEIPT OF THE DOCUMENT(S) AND/OR SAMPLE(S) DESCRIBED IS HEREBY ACKNOWLEDGED:
NO
NSPECTORSX
DESCRIPTION
NATURE RECPIENTSIGNATIIRE
NAME NAME
Tli DATE SIGNED TfTLE DATE SIGNED
Interim Final, November 1992
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Chapter Five Entry to the Facility and the Opening Conference
5.4.1.1 Explaining Inspection Activities
An outline of inspection objectives will inform facility officials of the purpose and scope of the
inspection, and may help avoid misunderstandings. The inspector should explain the anticipated
inspection activities in general terms and avoid providing the facility representatives with the precise focus
of the inspection for the following reasons:
• To avoid creating a situation in which facility officials use specific knowledge as advance
notification and attempt to hide violations in areas they know will be subject to scrutiny.
• To minimize the likelihood that facility officials, once having consented to the inspection,
will withdraw consent based on their perception that the inspection includes more than
they understood and agreed to. Such perceptions could contribute to misunderstandings
later during the inspection.
• To allow facility representatives to prepare the documents needed for a data quality
inspection and minimize the possibility that facility officials will limit the number of
documents for review.
5.4.1.2 Understanding Facility Operations and Practices
During the opening conference, the inspector should attempt to understand facility operations and
practices thoroughly by asking facility representatives about current operations and practices, as well as
organizational accountability and personnel, that may not have been included (or requires clarification)
in EPA records. This is an opportunity for the inspector to follow up on outstanding issues raised during
the pre-inspection preparation phase of the inspection (discussed in Chapter 3). The key areas are listed
below:
• Nature of the Operations. The inspector should determine the facility activities from an
operational standpoint, the materials used, and the management and/or disposal of wastes
that are generated. The inspector should obtain copies of manufacturing or process
diagrams to use during the inspection. The inspector should also obtain copies of plant
diagrams showing emission, or release points, such as air exhausts and sewer discharge
lines.
o Major Facility Environmental Programs. The inspector should ask which environmental
programs are part of the facility's culture, such as effluent sampling, analysis, and
reporting; inspection and maintenance of pollution control equipment; and emergency
response.
o Applicability of Environmental Regulations. The inspector should verify that facility
operations and programs have not changed in such a way as to alter the regulations or
requirements that apply to the site. Such information will permit the inspector to review
and revise the inspection plan, if necessary, by shifting the emphasis of planned activities,
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Entry to the Facility and the Opening Conference Chapter five
deleting inappropriate activities, and/or adding new activities not initially considered
relevant.
• Key Responsibilities. Authorities, and Accountabilities. The inspector should establish
which facility officials are responsible for specific environmental activities,
communicating the chain-of-command in case of emergencies, and developing
environmental performance measures. In addition, it is important to clarify what
authorities have been specifically delegated and how responsibilities are established and
maintained. A telephone directory or an organizational chart can be requested. This
information will assist the inspector in determining which individuals are knowledgeable
about specific areas and who should be interviewed.
5.4.1.3 Logistical Arrangements
The inspector should determine logistical requirements and make arrangements in the opening conference
to minimize delays and avoid misunderstandings. The following items should be addressed:
• Facility Support. It may be beneficial to identify the facility official(s) to accompany the
inspector during the inspection (or selected parts of it) who will describe the facility and
its principal operating characteristics and, where appropriate, who will indicate which
processes, records, and other materials should be claimed as CBI.
• Safety Requirements. The inspector should determine what OSHA and facility safety
regulations will be involved in the inspection and should be prepared to comply with
them. EPA typically has its representatives use the same safety equipment that is actually
used by employees. EPA has the right to and does decline to undergo the safety training
that facilities require of their employees, with the exception of site-specific mine safety
training required under EPA Order 1440.4. While onsite, the inspector should be aware
of compliance with OSHA requirements and be prepared to make a referral to OSHA if
violations are suspected.
• Order of Inspection. A discussion of the order in which operations will be inspected will
help eliminate wasted time by giving facility officials time to gather the records needed
for review.
• List of Records. A list of records to be inspected will permit facility officials to gather
and make them available for the inspector. If, however, the inspector has any reason to
believe that such advance notice will tempt facility representatives to sanitize, withhold
portions of, or destroy records, such a list should be prepared for inspector use only, not
for submission to facility officials.
• Meeting Schedule. Based on the planned inspection activities and the inspector's
understanding of facility personnel responsible for key assessment topic areas, a schedule
of meeting times can be developed for the duration of the inspection. This will allow key
personnel to plan and schedule the time needed to meet with the inspector.
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Chapter Five Entry to the Facility and the Opening Conference
Once the inspector has gained entry to the facility and conducted the opening conference, s/he is ready
to initiate the onsite phase of a data quality inspection, as discussed in Chapter Six.
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BLANK PAGE
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Chapter Six Onsite Evaluation of Data Quality
Chapter Six
Onsite Evaluation of Data Quality
Page
6. Onsite Evaluation of Data Quality 6-1
6.1 Introduction 6-1
6.2 EPCRA Section 313 Chemicals 6-1
6.3 Facility Tour Activities 6-3
6.4 Review of EPCRA Section 313 Chemicals 6-12
6.4.1 Review of Threshold Determination 6-12
6.4.2 Review of Release Estimates 6-23
6.4.3 Sources of Chemical Releases and Transfers 6-25
6.4.4 Summary of Release Estimates 6-30
6.4.5 Calculations 6-34
6.5 Reasons for Reporting Errors/Data Discrepancies 6-40
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BLANK PAGE
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Chapter Six Onsile Evaluation of Data Quality
6. Onsite Evaluation of Data Quality
6.1 Introduction
An inspection may take up to 3 days onsite to complete depending on the size and complexity of a facility
and the nature of the audit program. While onsite, inspectors should review all submitted data and
supporting materials the facility has available from its EPCRA Section 313 reporting. Inspectors should
document all calculations and assumptions on the audit checklist.
This chapter includes Sections 2.0 through 6.0 and brief guidelines for completing the sections. The
inspector should note that Section 2.0 of the checklist is completed once for each facility, Section 3.0 is
completed for every EPCRA Section 313 chemical identified at the facility by the auditor, and Sections
4.0 through 6.0 are completed for every EPCRA Section 313 chemical that meets the reporting
requirements. The inspector should make an appropriate number of copies of Sections 3.0 through 6.0
prior to the audit.
The inspection checklist which is presented throughout this Chapter is intended to document pertinent
factual information needed for preparation of the EPCRA Section 313 inspection report. All information
pertaining to the facility, its processes, and the completion of its Form R chemical reports must be
documented on the checklist or appended to the checklist as an attachment.
This chapter also discusses reasons for data discrepancies and reporting errors.
6.2 EPCRA Section 313 Chemicals
Before beginning the facility tour, the inspector should review all processes with the facility representative
and discuss any changes that have occurred in the reporting year. The inspector should ask questions
identified during the pre-inspection review of the facility's Form R reports. Detailed information on pre-
inspection review is found in Chapter 3 of this manual.
First, the inspector should complete Section 2.0 of the audit checklist (i.e., Introduction and Facility
Tour). To complete Section 2.0, the inspector must identify and list all the Section 313 chemicals both
reported (on the Form R report) and not reported which are present at the facility. This will be done
through: 1) review of the facility's Form R report and supporting documentation, 2) review of additional
information and records available at the facility, 3) discussion with facility officials, and 4) facility tour.
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Onstie Evaluation of Data Quality Chapter Six
• List of Section 313 Chemicals reported on the Form R report (Question 2.1). The inspector
should record all the EPCRA Section 313 chemicals reported by the facility. This
information can be taken directly from the facility's Form R report. If the facility reported
a chemical category, such as "lead compounds," the inspector should enter NA in the first
two boxes of the Chemical Abstract Service (CAS) number. Sections 3.0 through 6.0 of the
checklist must be completed for each chemical listed here.
If the facility reported a chemical that is not included in the Section 313 list of toxic
chemicals, the inspector should check the box indicating the chemical is not a Section 313
chemical. This would include any reported chemical that is listed with a qualifier and that
the facility does not use in the listed form. For example, isopropyl alcohol is a listed
chemical with the qualifier "manufacturing-strong acid process." Only facilities that
manufacture isopropyl alcohol by the strong acid process should report it as a Section 313
chemical.
• List of Chemicals not reported on the Form R but documented by the facility (Question 2.2).
The inspector should record all chemicals documented by the facility for Section 313
reporting that did not have Form R chemical reports submitted. This information can be
obtained from the supporting materials provided by the facility. If the chemical is not
included in the Section 313 list, the inspector should check the box indicating the chemical
is not a Section 313 chemical. The inspector should note that Section 3.0 of the checklist
must be completed for each chemical listed here.
• List of Chemicals not reported or documented, but identified by the inspector (Question 2.3).
The inspector should record all other Section 313 chemicals identified by the inspector during
the inspection. This information is obtained through review of facility records, discussions
with facility officials, and the facility tour. Section 3.0 of the checklist must be completed
for each chemical listed here.
• List of mixtures identified during the facility tour which may contain Section 313 Chemicals
(Question 2.4). Under EPCRA Section 313, toxic chemicals in mixtures, as well as trade
name products, must be factored into threshold and release calculations. The inspector should
record all mixtures identified during the inspection that may contain Section 313 chemicals
in Column a. The inspector should then investigate whether the mixtures that are identified
during the facility tour contain a Section 313 chemical. This is done by reviewing the MSDS
to verify the constituents of the mixture (recorded in column b) and to record concentrations
of any Section 313 chemical in the mixture (recorded in column c).
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Chapter Six Onsite Evaluation of Data Quality
The inspector should note that the facility is not required to consider the quantity of toxic
chemical present in a mixture if the mixture contains de minimis concentrations. De minimis
concentrations means the toxic chemical is present at less than 1 percent of a mixture, or,
if the toxic chemical is a carcinogen as defined in 29 CFR 1910.1200 (d)(4), less than 0.1
percent of the mixture.
Information on the amount of mixture and of Section 313 chemical (i.e., columns d and e)
should be completed concurrently with the threshold determination in Section 3.0.
DEFINITION (40 CFR 372.3)
A mixture is any combination of two or more chemicals, if the combination is not, in whole or in
pan, the result of a chemical reaction. However, if the combination was produced by a chemical
reaction but could have been produced without a chemical reaction, it is also treated as a mixture.
A mixture also includes any combination which consists of a chemical and associated impurities.
6.3 Facility Tour Activities
During the tour of the facility, the inspector should focus on areas in which Section 313 chemicals are
used in process lines and treatment areas. The inspector should sketch process diagram(s) in the
designated Section 2.0 checklist areas if none are available from the facility. In particular, the inspector
should identify areas where releases could occur in the facility (e.g., drains, exhaust fans, vents, and
ducts), keeping in mind the following items:
Housekeeping practices
Method(s) of receiving and unloading chemicals
Storage practices
Disposal method(s)
Use(s) of each Section 313 chemical
Waste treatment and pollution control devices.
The inspector should record descriptions and document how each Section 313 chemical is used to
determine its activity classification (i.e., manufactured, processed, and otherwise used). Finally, the
inspector should document the types of control methods that are used at the facility and make a qualitative
assessment of their efficiency by observing their operation and then record these observations in Section
2.0 of the inspection checklist. For example, a degreasing unit that is open to the atmosphere would
release a greater amount of solvent to the air than a unit with a solvent recovery system.
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Chapter Six
Section 2.0 Introduction and Facility Tour Section 313 Chemicals Present Onsite
2.1 List all chemicals reported on the facility's Form R chemical reports.
Chemical Name
CAS Number
Not
a Section 313
Chemical
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Onsite Evaluation of Data Quality
2.2 List all chemicals not reported on the facility's Form R chemical reports, but documented by the
facility.
None:
Chemical Name
CAS Number
Not'
a Section 313
Chemical
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Chapter Six
2.3 List other Section 313 chemicals not reported or documented, but identified by the inspector during
the inspection.
None:
Chemical Name
CAS Number
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Onsite Evaluation of Data Quality
2.4 List all mixtures identified during the facility tour that may contain Section 313 chemicals.
a.
Mixture Name
b.
Section 313
Chemical Present
c.
Concentration of
Chemical1
d.
Amount of
Mixture Used
in Year2
e.
Amount of
Section 313
Chemical Used1
•
If concentration of chemical is below de minimis (0.1 percent for carcinogens, 1.0 percent
for all others), do not include mixture in threshold determinations.
Complete Columns d and e during threshold determination.
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Process Diagram(s):
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Treatment Unit Operation(s):
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Facility Tour Notes:
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Facility Tour Notes (cont'd):
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Onsite Evaluation of Data Quality Chapter Six
6.4 Review of EPCRA Section 313 Chemicals
The inspector should complete Sections 3.0 through 6.0 of the audit checklist for each EPCRA Section
313 chemical manufactured, processed, or otherwise used at the facility that meets the requirements for
reporting. Section 3.0 of the checklist should be completed for every EPCRA Section 313 chemical used
by the facility. The inspector should document all calculations and assumptions on the appropriate
worksheets in Section 6.0. Calculations should be reproducible by a reviewer unfamiliar with the facility.
In addition, the inspector should collect supporting documents for responses on the checklist for use as
evidence in any potential enforcement actions.
6.4.1 Review of Threshold Determination
In completing Section 3.0 of the checklist, the inspector reviews the facility's decision to report a
chemical, including the activities of the chemical and the amount used. The inspector should ensure that
the name of the chemical being reviewed is recorded at the top of each page in Section 3.0.
• Ways the chemical is employed at the facility (Question 3.1). In this question, the inspector
is documenting all the ways the chemical is being employed (1) based on the facility's
documentation and (2) based on the inspector's own review of process diagrams, discussions
with the facility personnel, and from the plant tour. The checklist contains three activity
categories (i.e., manufacture, process, and otherwise use) as well as exempt uses. The
inspector checks the appropriate activity category based on the facility's documentation in the
left hand column, which is labeled facility.
If the chemical was present as an impurity (under the manufacture category), the inspector
must document the percent concentration. This is because the chemical is exempt from
reporting if it is only present below the de minimis concentration (0.1 percent for
carcinogens, 1.0 percent for all others). The de minimis exemption only applies to toxic
chemicals in mixtures and products. It does not apply to wastestreams from manufacturing
processes or to chemicals that undergo intentional beneficiation.
The inspector must also indicate if the chemical is employed in one of the exempt uses
(activities "n" through "s" in the checklist). These uses include the following:
Laboratories: Listed toxic chemicals that are manufactured, processed, or
otherwise used in laboratory activities at a covered facility under the direct
supervision of a technically qualified individual meet this exemption. Pilot plant
scale and specialty chemical production are not included in the laboratory
exemption.
Use exemption: The following uses are exempt - use as a structural component of
the facility, use in routine janitorial or facility grounds maintenance, personal uses
by employees or other persons, use for motor vehicle maintenance, and use of
toxic chemicals contained in intake water (used for processing or noncontact
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Chapter Six Onsite Evaluation of Data Quality
cooling water) or in the intake air (used either as compressed air or for
combustion).
Article exemption: Quantities of toxic chemicals contained in an article which is
processed or used at the facility meet this exemption.
DEFINITIONS
Manufacture means to produce, prepare, import, or compound one of the toxic chemicals on the
list. For example, if you make a dye for clothing by taking raw materials and reacting them, you
are manufacturing the dye. You also would be covered if you were a textile manufacturer who
imported a dye on the list for purposes of applying it to fabric produced at your plant.
Process, in general, is the incorporation of the toxic chemical into a product and includes making
mixtures, repackaging, or using a chemical as a feed-stock, raw material, or starting material for
making another chemical.
Examples of processing include:
• Adding a solvent as a diluent when making a paint, coating, or other mixture
• Using a chemical as reactant in the manufacture of a pesticide (e.g., using chemical A
to make chemical B).
Otherwise Use applies to any use of a toxic chemical at a covered facility that is not covered by
the terms "manufacture" or "process" and includes use of a toxic chemical contained in a mixture
or trade name product. A toxic chemical that is otherwise used by a facility is not intentionally
incorporated into a product distributed in commerce.
Examples include:
• Using a metal cutting fluid that contains diethanolamine
• Using a heat transfer fluid containing biphenyl
• Using trichloroethylene to degrease tools
• Using chlorine in waste water treatment
• Using Freon 113 as a refrigerant to cool process streams.
The inspector should not include these activities (i.e., exemptions) in threshold or release calculations.
• Was the chemical reported by the facility? (Questions 3.2 and 3.2.1). In these questions, the
inspector indicates whether the chemical was reported by the facility. If it was not, the
inspector should then record why the facility felt this chemical was not reportable. The
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Onstie Evaluation of Data Quality Chapter Six
inspector should obtain this information from the facility's documentation. If the
documentation is not available, the inspector should ask the facility official why it was not
reported and document the answer.
• Is the chemical exempt from reporting? (Question 3.3). The inspector should record whether
the chemical is exempt from reporting. The chemical is exempt if it is employed in one of
the uses or is manufactured, processed, or otherwise used at an exempt facility as described
above under question 3.1.
• Is documentation supporting the threshold determination available for review? (Question 3.4).
The inspector should determine if the facility has supporting documentation on the threshold
calculation for this chemical and obtain copies if available. If not available, the inspector
should record the most appropriate reason listed in Question 3.4.1 in the checklist why the
facility does not have the documentation. This information should be obtained through
discussion with the facility officials.
• What was the basis of the estimate of the amount of chemical manufactured, processed, or
otherwise used during the reporting year? (Question 3.5). The inspector should determine
by reviewing the facility documentation and/or discussions with facility officials, what
method the facility used to estimate the amount of chemical manufactured, processed, or
otherwise used. The inspector should record the method(s) used by the facility, keeping in
mind that possibly more than one method or approach was used.
• How much chemical did the facility manufacture, process, or otherwise use during the
reporting year? (Question 3.6). The inspector should review the facility's documentation of
the threshold determination for the chemical and record the amount for each activity
category. If the chemical was not used for a particular activity, the inspector should enter
zero into that column. The inspector should document whether the facility did not estimate
the quantities or whether there is not enough information available to estimate these
quantities.
In addition, the inspector must also do her/his own calculation of the amount of chemical
manufactured, processed, or otherwise used during the reporting year. This is done using
the threshold determination worksheet provided in Section 6.0 of the checklist.
At this point, the inspector should also complete Question 2.4 of the checklist discussed previously in this
chapter. The concentration of toxic chemical in the mixture (i.e., column c) can be retrieved from the
MSDS for the mixture. The amount of mixture used (i.e., column d) can be obtained from inventory or
purchasing records. The inspector can then calculate the amount of Section 313 chemical used (i.e.,
column e) simply by multiplying the concentration of chemical in the mixture by the amount of mixture
used.
• Was the reviewer's estimate of the amount of chemical manufactured, processed, or
otherwise used recalculated using available documentation or recreated using other facility
data? (Question 3.7). In this question, the inspector must either 1) recalculate the threshold
determination using the available facility documentation or 2) recreate the threshold
Interim Final, November 1992 6-14 EPCRA Data Quality Inspection Manual
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Chapter Six Onsite Evaluation of Data Quality
determination if the facility has no documentation or if the inspector is aware of additional,
more accurate information to use.
If the inspector recalculates the threshold value, s/he must appropriately record whether
her/his value is within a factor of 2 (box a), within a factor of 10 (box b), or not within a
factor of 10 (box c) of the facility value. Likewise, if the inspector recreates the threshold
value, s/he must appropriately record whether her/his value is within a factor of 2 (box d),
within a factor of 10 (box e), or not within a factor of 10 (box f) of the facility value.
The inspector should also record whether the facility overlooked this chemical, and therefore,
did not estimate the threshold value (box g). Finally, if the inspector is unable to perform
these calculations, s/he should document in detail the reason (box h).
• Was a threshold exceeded for this chemical in the reporting year? (Question 3.8). The
inspector should document whether the threshold value has been exceeded for this chemical.
This is done by comparing the amounts of chemicals in Question 3.6 to the threshold values
for the activity categories. If either the "manufactured" or "processed" value is greater than
25,000 pounds, or if the "otherwise used" value is greater than 10,000 pounds, a threshold
has been exceeded.
• What was the maximum amount of chemical onsite at any time? (Question 3.9).' The
inspector should review and document the maximum amount of the chemical onsite at any
time during the reporting year as indicated in the Form R report and/or in facility
documentation.
In addition, the inspector must calculate the maximum amount onsite using the worksheet
provided in Section 6.0 of the checklist. In calculating this value, the inspector should
consider the amount of chemical in all storage areas, in use at any time, and in each
wastestrearn. The inspector may need to review inventory records and tour the plant storage
areas to complete these calculations.
• Was the chemical correctly reported or not reported? (Question 3.10). In this section, the
inspector must record whether the chemical was correctly reported or not reported as
follows:
Correctly included. The chemical was reported by the facility, is not exempt, and
exceeded the applicable threshold limit. In this case, the inspector should proceed
to complete Section 4.0 of the checklist for this chemical.
Correctly omitted. The chemical was not reported by the facility and is either
exempt or did not exceed the applicable threshold limit. In this case, the inspector
should now start to complete Section 3.0 of the checklist for the next chemical.
Incorrectly included. The chemical was reported by the facility, but is either
exempt or did not exceed the applicable threshold limit. In this case, the inspector
should proceed to Question 3.11 for this chemical.
EPCRA Data Quality Inspection Manual 6-IS Interim Final, November 1992
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Onsite Evaluation of Data Quality Chapter Six
Incorrectly omitted. The chemical was not reported, but was not exempt and
exceeds the applicable threshold limit. In this case, the inspector should proceed
to question 3.12 for this chemical.
• Why was the chemical incorrectly reported? (Question 3.11). In this question, the inspector
should record the reason obtained from review of the facility's documentation and/or through
discussions with the facility officials that most closely describes why this chemical was
reported.
Although the facility was aware this chemical did not exceed the threshold limit,
it was reported anyway "to be safe."
The facility incorrectly assumed a threshold limit was exceeded (i.e., did not
complete a calculation).
The facility misclassified the chemical activity as "otherwise used," when it is
really "processed" or "manufactured."
The facility made a calculation error while determining the threshold quantity,
which resulted in the chemical exceeding a threshold limit.
The facility reported the chemical because a threshold limit was exceeded.
However, all uses of the chemical are exempt, and therefore, are nonreportable.
Any other reason not previously described. Be thorough, but brief, in your
description.
The inspector should start to complete Section 3.0 of the checklist for the next chemical.
• Why was the chemical incorrectly omitted? (Question 3.12). In this question, the inspector
should record the reason as obtained through the facility's documentation, the facility tour,
and/or discussions with facility officials that most closely describes why this chemical was
not reported.
The facility overlooked the activity of a chemical as being "manufactured,"
"processed," or "otherwise used." Examples include:
- Manufacturing byproducts
- Wastewater treatment byproducts
- Wastewater treatment chemicals
- Cleaning chemicals.
The facility misclassified the chemical activity as "processed" or "manufactured,"
when it is really "otherwise used."
The facility made a calculation error while determining the threshold quantity,
which did not exceed a threshold limit.
Any other reason not previously described. Be thorough, but brief, in your
description.
The inspector should now proceed to complete Section 4.0 of the checklist for this chemical.
Interim Final, November 1992 6-16 EPCRA Data Quality Inspection Manual
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Chapter Six Onsite Evaluation of Data Quality
Section 3.0 Review Threshold Determination
Chemical Name:
3.1 How is this chemical employed at the facility? (Check all that apply.)
Manufacture
a. Import/produce for onsite use/processing "—'
b. Import/produce for sale/distribution L-'
c. Byproduct of process I—'
d. Byproduct of waste treatment I—I
^^
e. Impurity3 (% =
Process (incorporative activity)
f. Chemical reactant (raw materials, intermediates, etc.) •—'
g. Formulation component I—I
h. Article component
i. Repackage
Other Use (nonincorporaiive activity)
j. Chemical processing aid (added to reaction mixture) LJ
k. Manufacturing aid (process lubricants, coolants, etc.) L-1
1. Ancillary use (cleaners, degreasers, lubricants) >—>
3 If impurity is present below de minimis concentrations (0.1 percent for carcinogens, 1.0 percent
for all others), it is exempt from reporting.
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Onsite Evaluation of Data Quality Chapter Six
Exempt Uses
m. Laboratory chemical LJ
n. Structural component .......................... I— '
o. Routine janitorial/facility grounds maintenance .......... LJ
p. Personal employee use ......................... LJ
q. Motor vehicle maintenance ....................... I— I
r. Intake water component ......................... I— I
s. Contained in an article ......................... I— I
3.2 Was the chemical reported by the facility?
YES ..... D NO ..... D (If yes, skip to Q. 3.3.)
3.2.1 If no, why did the facility decide this chemical was not reportable?
a. Below threshold ............................ LJ
b. Exempt use ............................... LJ
c. Overlooked chemical altogether ................... LJ
(If checked, skip to Q. 3.6)
d. Other (specify) _ ....... Cl
3.3 Is chemical exempt from reporting?
YES ..... CD NO ..... CD (If yes, skip to Q. 3.10.)
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Chapter Six Onsite Evaluation of Data Quality
3.4 Is documentation supporting the threshold determination available for review?
YES C3 NO C3 (if yes, skip to Q. 3.5.)
3.4.1 If no, why not?
a. Documentation cannot be located LJ
b. Documentation was not retained by facility LJ
c. Facility unaware that documentation is required I—'
3.5 What was the basis of estimate used by the facility for the amount manufactured, processed, or
otherwise used during the reporting year? (Check all that apply.)
a. Purchase/inventory records LJ
b. Emission factors LJ
c. Mass balance LJ
d. Assumed threshold exceeded (no calculations completed) ... LJ
e. Process recipes LJ
f. Monitoring data LJ
g. Production data LJ
h. Other (specify) D
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Onsite Evaluation of Data Quality Chapter Six
3.6 How much chemical did the facility manufacture, process, or otherwise use during the reporting
year?4
a. Manufactured Ibs
b. Processed Ibs
c. Otherwise used Ibs
d. Facility did not estimate these quantities •—'
e. Reviewer unable to estimate quantities LJ
3.7 Was the reviewer's estimate of the amount of chemical manufactured, processed, or otherwise used
recalculated using available documentation or recreated using other facility data?
a. Recalculated, within a factor of 2 L-1
b. Recalculated, within a factor of 10 Q
c. Recalculated, greater than a factor of 10 ,. . . I—'
d. Recreated, within a factor of 2 LJ
e. Recreated, within a factor of 10 LJ
f. Recreated, greater than a factor of 10 LJ
g. Facility did not estimate these quantities >—I
h. Reviewer unable to estimate quantities1 LJ
4 Record calculations and assumptions for the threshold determination on the worksheet in Section
6.0.
5 Document why you are unable to estimate chemical quantities for the reporting year on the
threshold determination worksheet in Section 6.0.
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Chapter Six
Onsite Evaluation of Data Quality
3.8 Was a threshold exceeded for this chemical in the reporting year?
YES LJ (This chemical should have been reported. Continue.)
NO LJ (This chemical should not have been reported. Skip to Q.3.10.)
Cannot be determined . .
(Skip to next chemical.)
3.9 What is the maximum amount of this chemical onsite at any time?*
a. Maximum onsite ....
Ibs
Ibs
3.10 This chemical was:
a. Correctly included .
b. Correctly omitted . .
c. Incorrectly included
d. Incorrectly omitted .
(If checked, skip to Section 4.0.)
(If checked, skip to next chemical.)
(If checked, skip to Q. 3.11.)
(If checked, skip to Q. 3.12.)
' Record calculations and assumptions for the maximum onsite quantity on the worksheet in
Section 6.0.
EPCRA Data Quality Inspection Manual 6-21
Interim Final, November 1992
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Onsite Evaluation of Data Quality Chapter Six
3.11 Why was this chemical incorrectly included?
a. Facility reported, although amount used was below threshold U
b. Facility incorrectly assumed threshold was exceeded LJ
c. Chemical activity was misclassified LJ
d. Threshold quantity was miscalculated LJ
e. Chemical was exempt LJ
f. Other (specify) d
(Skip to next chemical)
3.12 Why was this chemical incorrectly omitted?
a. Chemical activity was overlooked LJ
b. Chemical activity was misclassified LJ
c. Threshold quantity was miscalculated LJ
d. Other (specify) D
Interim.Final, November 1992 6-22 EPCRA Data Quality Inspection Manual
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Chapter Six Onsite Evaluation of Data Quality
6.4.2 Review of Release Estimates
In completing Section 4.0 of the checklist, the inspector reviews the facility's methodology and support
documentation for calculating the release estimates. This includes the review of the sources of releases
to ensure that all sources have been accounted for.
• Is documentation on release estimate available for review? (Question It. In this question,
the inspector must obtain and review the facility's supporting documentation on each release
estimate available for this chemical. If not available, the inspector must record the reason
(as determined through discussions with facility officials) which most closely describes why
the documentation is not available. If the facility overlooked this chemical, the inspector
should proceed to Section 4.1 of the checklist for this chemical.
• If monitoring data were used, are data available for review? (Question 2). The inspector
should obtain copies of any monitoring data used to develop the release estimates. The
inspector should note that the facility must use all readily available data collected to meet
other regulatory requirements or as part of routine plant operations for the toxic chemical.
However, the facility is not required to conduct additional monitoring or measurements of
the toxic chemical for the purposes of completing the Form R report.
The inspector should also document the reason if such monitoring data was used but is not
available for review.
• If a percent from stormwater estimate was reported, are the monitoring data on which the
estimate was based available for review? (Question 3). The inspector should obtain copies
of any monitoring data used by the facility to calculate the percent from stormwater estimate
(if Question S.C completed on the Form R report). The inspector should note that if the
facility has monitoring data on the toxic chemical and the flow rate, such data must be used
to calculate the percent from stormwater estimate. In addition, if the facility does not have
periodic measurements of stormwater releases of the toxic chemical, but has submitted
chemical-specific monitoring data in permit applications, then these data must be used to
calculate the percent from stormwater estimate. In this case, the inspector should obtain
copies of the data used in the permit application.
The inspector should also document the reason if such monitoring data was used but is not
available for review.
• If emission factors were used, what is the source of the factors? (Question 4). The inspector
should record and document the source of any emission factors used by the facility to
calculate the release estimate. Such factors could be facility-derived factors, EPA-published
emission factors, trade association factors, etc. The inspector should indicate NA if emission
factors were not used.
• Was each air or wastestream counted only once in the release estimate? (Question 5). The
inspector should review the facility's documentation and record whether each air stream or
wastestream that contributed to the release estimates was counted only once. Any streams
that were double counted must be documented in the release calculation worksheet in Section
EPCRA Data Quality Inspection Manual 6-23 Interim Final, November 1992
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Onsite Evaluation of Data Quality Chapter Six
6.0. An example of double counting would be reporting releases that are vented from a
spray paint booth as an air stack release as well as building fugitive emissions.
• Were all air or wastestreams containing < 1 % of the chemical included in the release
calculations? (Question 6). The inspector should review the facility's documentation and
document whether any air or wastestreams containing less than 1 percent of the chemical
were included in the release calculations. The de minimis exemption applies to ingredients
of mixtures or to impurities present in products processed or used. However, it does not
apply to wastes when chemicals in mixtures above the de minimis level are manufactured,
processed, or otherwise used, and meet the applicable activity threshold. Wastes and releases
must be reported regardless of the concentration. In addition, when the facility's operations
create (manufacture) the chemical in waste treatment, the de minimis exemption does not
apply.
The inspector should record if the facility has misinterpreted the de minimis rule and not
included wastestreams with less than 1 percent of the chemical, or the reason that most
closely describes why such wastestreams were not included.
• Was onsite treatment of this chemical included in release estimates? (Question 4.7). The
inspector should review the facility's documentation and record whether onsite treatment of
the chemical is included in the facility's release calculations. All onsite treatment processes
must be included in the release calculations. These processes would include:
Air Emissions Treatment
Biological Treatment
Chemical Treatment
Incineration/Thermal Treatment
Physical Treatment
Solidification/Stabilization.
If the facility did not include onsite treatment in its estimate, the inspector should determine
(through discussions with facility officials) and document the reason which explains most
closely why such treatment was not included.
• If sequential treatment was reported, was the efficiency based on overall treatment? (Question
£). The inspector should document if the facility used overall treatment efficiency for any
sequential treatment which was reported. Sequential treatment refers to several individual
treatment steps used in a series to treat the toxic chemical. When the facility has sequential
treatment, it should use the overall treatment efficiency in its release calculations.
TIPS
The treatment efficiency (expressed as percent removal) represents the mass or weight percentage
of chemical destroyed or removed, not merely changes in volume or concentration of the chemical
in the wastestream. The efficiency refers only to the percent destruction, degradation,
conversion, or removal of the listed toxic chemical from the wastestream, not the percent
conversion or removal of other wastewater constituents which may occur together with the listed
chemical.
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Chapter Six Onsite Evaluation of Data Quality
Were treatment efficiencies used consistent with vendor specs or EPA-published efficiencies?
(Question 9). The inspector should review and document whether treatment efficiencies used
by the facility were consistent with vendor specifications or with EPA-published values. The
efficiencies reported on the facility's Form R report should be compared to literature values
before the inspection, if possible. The inspector should discuss any identified inconsistencies
with facility officials during the inspection and document the reason for such discrepancies
in Section 6.0 of the checklist. The inspector should record whether the facility did not use
treatment efficiencies in the release determination.
6.4.3 Sources of Chemical Releases and Transfers
Section 4.1 of the checklist is designed to summarize information on the sources of chemical release or
transfer considered by the facility for each release estimate. Under EPCRA Section 313, the facility is
required to account for the total aggregate releases of the toxic chemical to the environment for the
reporting year. The facility is not required to count as releases quantities of a toxic chemical lost due
to natural weathering or corrosion, normal/natural degradation of a product, or normal migration of a
chemical from a product.
Releases to media that must be included in release calculations are listed in Section 4.1 and are as
follows:
• Fugitive or Nonpoint Air Emissions. This includes all releases to air that are not released
through stacks, vents, ducts, pipes, or any other confined air stream.
• Stack or Point Air Emissions. This includes all releases to air that are released through
stacks, vents, ducts, pipes, or any other confined air stream.
• Discharges to Receiving Streams or Water Bodies. This includes releases from the facility
to each receiving stream or water body. It does not include discharges to POTWs or other
offsite wastewater treatment systems.
• Underground Injection. This includes the injection of the toxic chemical into all wells.
• Releases to Land Onsite. There are four subcategories for reporting quantities of the
chemical released to land within the boundaries of the facility. These categories include:
Landfill
Land treatment/application farming
Surface impoundment
Other disposal (such as spills or leaks of the chemical to land).
• Discharges to POTWs. This includes discharges to sewer lines which ultimately go to
wastewater treatment plants.
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Onsite Evaluation of Data Quality Chapter Six
• Offsite Transfers. The offsite transfer consists of the total quantity of chemical sent to any
offsite disposal, treatment, or storage facilities.
For each release medium listed in Section 4.1, the inspector should indicate whether the source of release
was:
• Y - Considered in the estimate
• N - Not considered in the estimate
• NA - Not present at the facility for the chemical and medium.
This section of the checklist will assist the inspector in completing Section 5.0 of the checklist. The
inspector should note that the shaded areas in Section 4.1 should not be completed.
TIPS
Errors commonly made by facilities in the preparation of the release estimate include:
• Reporting the materials being transferred offsite for recycling or reuse. Materials being
sent offsite for recycling or reuse are not considered a release under Section 313.
• Reporting zero air emissions for VOCs. VOCs are chemicals which readily evaporate at
room temperature, and therefore, will evaporate when present in an open tank or painting
or degreasing operation.
• Reporting discharges of mineral acids after neutralization. A mineral acid stream
neutralized to a pH of 6 or above is considered to be 100 percent neutralized. Such a
discharge may be reported as zero acid released.
• Incorrectly identifying/reporting fugitive and stack emissions. Fugitive and stack emissions
must be reported separately as releases to air.
Interim Final, November 1992 6-26 EPCRA Data Quality Inspection Manual
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I A
g
ff
ET
O
g
t
2?
I
o
Section 4.0 Review of Release Calculations
Code List for Section 4.0
Ql Y
Nl
N2
N3
N4
N5
= Yes
Documentation cannot be located
Documentation was not retained by facility
Facility unaware that documentation required
Facility overlooked chemical
Other
Q5 Y
N
NA
NA = Facility does not have a release for this medium
Q2 Y = Yes
Nl = Facility unable to locate data
N2 = Facility did not retain data
NA = Monitoring data not used
Q3 Y = Yes
Nl = Facility unable to locate data
N2 = Facility did not retain data
N3 = Facility did not base estimate on monitoring data
NA = Percent from stormwater estimate was not
reported
Q4 1 = Facility-derived factors
2 = EPA-published emission factors
3 = Trade association factors
4 = Other
NA = Emission factors not used
= Yes
= No
= Facility does not have a release for this medium
Q6 Y = Yes
Nl = Facility misinterpreted de minimis rule
N2 = Facility overlooked chemical
N3 = Other
NA = Facility does not have a release from this
medium
Q7 Y
N
NA
Q8 Y
N
NA
Q9 Y
N
NA
= Yes
= No, facility overlooked treatment
= No treatment of this chemical for this release
medium occurred
= Yes
= Facility incorrectly reported treatment efficiency
= Sequential treatment uses not reported
= Yes
= No
= No treatment efficiencies were used
§
i
-------
Section 4.0 Review of Release Estimates
Chemical Name
1 . Is documentation on release estimate
available for review?1
2. If monitoring data were used, are data
available for review?
3. If a percent from stormwater estimate was
reported, are the monitoring data estimate
is based on available for review?
4. If emission factors were used, what is the
source of the factors?
5. Was each air or waste stream counted
only once in release estimates?1
6. Were all air or waste streams containing
< 1 % of the chemical included in release
calculations?
7. Was onsite treatment of this chemical
included in release estimates?
8. If sequential treatment was reported, was
the efficiency based on the overall
treatment?
9. Were treatment efficiencies used
consistent with vendor specs or EPA
published efficiences?1
Fugitive
Air
Stack
Air
Receiving
Stream
Underground
Injection
Land
Onsite
POTW
Offshe
Transfer
1 If the facility overlooked this chemical, enter N4 and skip to Section 4.1.
1 If no, document all streams double counted in release calculation in Section 6.0.
1 If no. document inconsistency of treatment efficiencies used in Section 6.0.
9
-------
Section 4.1 Sources of Chemical Releases and Transfers
Document whether facility considered all releases from the following sources:1
Chemical Name
SOURCE
A Process vents/stacks
B Pumps/valves/flanges
C Volatilization from process areas
D Volatilization from treatment areas
E Indoor air releases
F Storage tank/stockpile losses
G Accidental spills/releases
H Air or waste treatment discharge
streams2
I Stormwater runoff
J Process discharge streams
K Housekeeping practices/cleanup wastes
L Container residue
M Treatment sludges
N Other
Fugitive
Air
Stack
Air
Receiving
Stream
Underground
Injection
Land
Onsite
POTW
Offsite
Transfer
not present at the facility for this chemical.
2 Includes pollution control devices, pollution equipment bypass or malfunctions, land farming, or discharges to'ponds, pits, and lagoons.
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Onsite Evaluation of Data Quality Chapter Six
6.4.4 Summary of Release Estimates
Section 5.0 is designed to summarize both the facility and inspector release estimates for each medium
and the methods used to estimate each. When entering the release estimate for a particular medium, the
inspector should sum each occurrence of the release type. For example, the facility may release a
chemical to two or more receiving streams. The amount in each stream should be added, and the total
should be recorded in the appropriate column.
• Estimate facility's release. (Question 1). The inspector should document the facility's release
estimates reported on Form R for each medium. If the facility did not report a release, the
inspector should enter zero.
• What methodfe) did the facility use to estimate their releases? (Question 2). The inspector
should document the methods that were actually used by the facility to estimate each release
using the appropriate code found in the list given prior to Section 5.0 in the checklist. This
may not necessarily be what the facility reported on the Form R chemical report. The types
of methods that can be used include:
Monitoring Data. Estimate is based on monitoring data or on measurements for the
toxic chemical as released to the environment and/or offsite facility.
Mass Balance. Estimate is based on mass balance calculations, such as a calculation
of the amount of the toxic chemical in streams entering and leaving process equipment.
Emission Factors. Estimate is based on published emission factors, such as those
relating release quantity to throughput or equipment type (e.g., air emission factors).
Engineering Judgment. Estimate is based on engineering calculations (e.g., estimating
volatilization using published mathematical formulas) or best engineering judgment.
This includes applying an estimated removal efficiency to a wastestream, even if the
composition of the stream before treatment was fully characterized by monitoring data.
• Based on data available to the facility, is this the best method? (Question 3). After reviewing
the facility's documentation for this release estimate, the inspector should record whether the
facility used the best method for determining the release, keeping in mind that the four
primary methods are monitoring data, mass balance, emission factors, and engineering
judgment. To decide whether one method is better than another, it is necessary to evaluate
the type and quality of data available to the facility at the time of reporting. For example,
if a facility used engineering judgment but had monitoring data for the toxic chemical, the
facility should have used the monitoring data. If the facility used the best method based on
available data, the inspector should proceed to Question 6.
• What methodfe) could be used to calculate a more accurate release? (Question 4V The
inspector should record the method that would be better based on data available to the
facility. The inspector should document thoroughly in Section 6.0 of the checklist why this
method is a more accurate one for this facility based on her/his evaluation.
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Chapter Six Onsite Evaluation of Data Quality
• Enter the reviewer's release estimate using the preferred methodfsV (Question SV Using the
preferred method stated in Question 3, the inspector should calculate a new release estimate
for the facility on the release estimate worksheet provided in Section 6.0 and record her/his
answer. The inspector should be sure to document all her/his calculations.
• Enter the reviewer's release estimate using the same methodfs) as the facility. (Question 6).
Using the same method as the facility, the inspector should recalculate the release estimates
on the release estimate worksheet in Section 6.0 and record her/his answer. The inspector
should be sure to calculate the estimates appropriately, avoiding the common problems noted
in Section 6.3.3 of this manual. If the facility had no documentation and the inspector is
unable to recreate the estimate, the inspector should enter "Unknown."
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Onsite Evaluation of Data Quality Chapter Six
Section 5.0 Summary of Release Estimates
Code List for Section 5.0
M = Monitoring data or direct measurements
C = Mass balance calculations
E = Published emission factors
OC = Engineering calculations
OJ = Engineering judgement
OH = Hazardous waste manifests
O = Other
NA = Facility did not estimate release
2 Y = Yes
N = No
NA = Facility did not estimate release
3 Document why this method is more accurate in Section 6.0
Document release calculations in Section 6.0
Interim Final, November 1992 6-32 EPCRA Data' Quality Inspection Manual
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Section 5.0 Summary of Release Estimates
Chemical Name
1. Enter facility's release
estimate (in Ibs).
(Check range, if
appropriate.)
2. What method(s) did
the facility use to
estimate their release?
3. Based on data
available to the
facility, is this the
best method to
determine a release
estimate?
IF YES, SKIP TO
QUESTION 6.
4. What method(s) could
be used to calculate a
more accurate release
estimate?
S. Enter the reviewer's
release estimate using
the preferred
method(s). (Check
range, if appropriate.)
6. Enter the reviewer's
release estimate using
the same method(s) as
the facility. (Check
range, if appropriate.)
Fugitive
Air
1-499 500-999
l_ll_l
1-499 500-999
l_l l_l
1-499 500-999
l_l l_l
Stack
Air
1-499 500-999
l_l l_l
1-499 500-999
l_l l_l
1-499 500-999
l_l l_l
Receiving
Stream
1-499 500-999
l_l l_l
1-499 500-999
l_l l_l
1-499 500-999
l_l l_l
Underground
Injection
1-499 500-999
l_l l_l
1-499 500-999
l_l l_l
1-499 500-999
l_l l_l
Land
On Site
1-499500-999
l_l l_l
1-499500-999
l_l l_l
1-499500-999
l_l l_l
POTW
1-499500-999
l__l l_l
1-499 500-999
l_l l_l
1-499 500-999
l_l l_l
H
Offsite
Transfer
1-499 500-999
l_l l_l
1-499 500-999
l_l l_l
1-499 500-999
l_l l_l
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Onsite Evaluation of Data Quality Chapter Six
6.4.5 Calculations
Section 6.0 contains worksheets for completing the following calculations:
• Threshold determination
• Maximum amount onsite
• Release estimates.
The completion of these worksheets has been discussed in previous sections of this chapter. In general,
the inspector should document all assumptions made during calculations on the worksheets. In addition,
the inspector should record and document the basis for any conclusions that the facility's reported release
is accurate or inaccurate. A second reviewer, not necessarily familiar with the facility, should be able
to recreate the calculations.
Interim Final, November 1992 6-34 EPCRA Data Quality Inspection Manual
-------
Chapter Six
Onsite Evaluation of Data Quality
Section 6.0 Calculations
Threshold Determination Worksheet
Chemical Name:
Description of Use
Totals
Amount
Manufactured
Amount
Processed
Amount
Otherwise Used
Calculations:
EPCRA Data Quality Inspection Manual 6-35
Interim Final, November 1992
-------
Onsite Evaluation of Data Quality
Chapter Six
Maximum Amount Onsite Worksheet
Chemical Name:
Instructions:
Calculate the maximum amount of the chemical onsite at any one time during the
reporting year. Keep in mind the following:
• All storage areas (raw materials and products) where this chemical may
be kept
• The amount of chemical being used at any time
• The amount of chemical in each wastestream.
Storage Areas:
Total:
Chemical in Use:
Total:
Chemical in Wastestreams:
Total:
Total Onsite:
Interim Final, November 1992
6-36 EPCRA Data Quality Inspection Manual
-------
Chapter Six Onsite Evaluation of Data Quality
Release Estimate Worksheet
Chemical Name:
Instructions: Record all calculations for release estimates below in the appropriate sections. Be
sure to state whether calculations use the same method as the facility or apreferred
method.
Fugitive Air
Stack Air
EPCRA Data Quality Inspection Manual 6-37 Interim Final, November 1992
-------
Onsite Evaluation of Data Quality
Chapter Six
Chemical Name:
Receiving Stream
Underground Injection
Land Onsite
Interim Final, November 1992
6-38 EPCRA Data Quality Inspection Manual
-------
Chapter Six Onsite Evaluation of Data Quality
Chemical Name:
Offsite Transfer to POTW
Offsite Transfer
EPCRA Data Quality Inspection Manual 6-39 Interim Final, November 1992
-------
OnsUe Evaluation of Data Quality Chapter Six
6.5 Reasons for Reporting Errors/Data Discrepancies
A number of items contribute to differences in the amount of reported releases and transfers from one
year to another. These changes can be attributed to: 1) reporting errors caused by a lack of
understanding of the reporting requirements, calculation errors, and personnel changes, and 2) data
discrepancies due to process modifications, production changes, product substitution, and product
elimination. In some cases, the significant reductions in releases resulted from the implementation of
pollution prevention activities.
Some reasons for potential data quality errors, which should be kept in mind as the inspector moves
through the onsite phase of the data quality inspection, are described below.
• Technical Contact. Changes in technical contact personnel have led to errors or inconsistent
reporting from year to year. Often, the new technical contact may not be familiar with the
reporting requirements, and therefore, must go through an educational process.
• Administrative Errors. The most common errors involve entry of information on the Form
R, calculation of releases, and threshold determination errors. Although data may have been
collected by a facility correctly, the data were incorrectly transferred onto the form or
entered in the wrong section of the form.
• Data/Calculation Errors. Some common errors in calculations occur when a facility includes
the entire weight of a chemical in a mixture instead of just the weight of the chemical itself
or includes the amount of a chemical purchased in a calendar year rather than the amount
used. Threshold determination errors include incorrectly interpreting the threshold
definitions for the manufactured, processed, or otherwise used activity categories.
Some reasons for significant changes in amounts of chemicals used or amounts of chemicals released are
described below.
• Process Change. Several process changes were observed during the site visits. With the
emphasis shifting from pollution control to pollution prevention, facilities are attempting to
decrease the amount of Section 313 chemicals used in their processes.
• Housekeeping. Some facilities were able to decrease the amount of Section 313 chemicals
used by incorporating simple housekeeping practices (e.g., adding cooling coils on a vapor
degreaser and keeping the cover closed when it is not in use).
• Product Substitution/Elimination. The substitution of less toxic or hazardous chemicals for
Section 313 chemicals, or total elimination of the Section 313 chemicals, can have many
economic and environmental benefits, including:
Economic benefits
— Reduction of raw material costs
- Decrease in transport, treatment, and disposal costs
— Reduction of insurance liability through a safer work environment.
Interim Final, November 1992 6-40 EPCRA Data Quality Inspection Manual
-------
Chapter Six Onsite Evaluation of Data Quality
Environmental benefits
— Reduction in potentially harmful effects to the environment and public
health
— Protection of worker health.
An example of such benefits would be a large manufacturing facility that installed a powder
paint system, thus reducing its overall usage of common paint-carrying solvents, such as
xylene, toluene, methyl ethyl ketone, and n-butyl alcohol.
• Production Changes. In the past few years, many facilities have been affected by the weakened
economy, which in turn has led to decreased production and a reduction in raw material usage.
Because of production slowdowns, some facilities did not meet the reporting thresholds.
EPCRA Data Quality Inspection Manual 6-41 Interim Final, November 1992
-------
Onsite Evaluation of Data Quality Chapter Six
BLANK PAGE
Interim Final, November 1992 6-42 EPCRA Data Quality Inspection Manual
-------
Chapter Seven Closing Conference
Chapter Seven
Closing Conference
Page
7. Closing Conference 7-1
7.1 Introduction 7-1
7.2 Inspection Findings 7-1
7.3 Confidentiality Claims 7-2
7.4 Compliance Outreach 7-2
EPCRA Data Quality Inspection Manual 7-i Interim Final, November 1992
-------
Closing Conference Chapter Seven
BLANK PAGE
Interim Final, November 1992 7-ii EPCRA Data Quality Inspection Manual
-------
Chapter Seven Closing Conference
7. Closing Conference
7.1 Introduction
The closing conference with facility officials enables the inspector to "wrap up" an inspection. The
inspector should prepare and present to the facility officials any remaining receipts for documents and
should resolve information gaps by obtaining either the necessary information or an informal agreement
that the information will be forthcoming. The inspector should clarify any final questions and provide
the facility officials with the opportunity to ask any final questions. This chapter provides guidance for
inspectors on several of the issues that may arise during the closing conference, such as the 'facility's
compliance status, facility questions, confidentiality claims, and compliance outreach.
7.2 Inspection Findings
The inspector should summarize the inspection findings in an objective and factual manner. If facility
officials ask if any violations were found, the inspector may point out various items that facility officials
might want to address. However, EPA inspectors are never authorized to say that there are or are not
violations. At most, an inspector may communicate that there were areas of possible concern or that no
major problems were "readily apparent," but should always emphasize that the decision on whether a
violation exists is not made by the inspector.
There are several reasons why the inspector should not offer conclusions, which appear to be complete
and final, regarding the facility's compliance status:
• The inspector has not had time to reflect upon and correlate all that s/he has observed and
a case development officer has not yet analyzed the inspection report. Any conclusion made
by an inspector could compromise later decisions.
• The intricacies of EPA-administered statutes and regulations do not usually lend themselves
to simple or quick assessments.
• The inspection findings may represent only a portion of a larger enforcement case.
Additionally, should the facility later be informed that the inspection did substantiate a finding of
violation, facility officials are likely to insist that the EPA inspector stated there were no violations at the
time s/he left the premises, and therefore, to question the final assessment.
EPCRA Data Quality Inspection Manual 7-1 Interim Final, November 1992
-------
Closing Conference Chapter Seven
During the closing conference, facility officials may assert that they have the right to see or copy notes
made by EPA inspection personnel. Although they may submit a Freedom of Information Act (FOIA)
request, to which EPA must respond within 10 days, EPA policy is that the inspector not permit facility
representatives to see or copy inspection notes.
7 J Confidentiality Claims
During the inspection, some information may have been declared confidential. These items should be
reviewed and confirmed with facility officials, and confidentiality claims must be completed by a facility
representative (see TSCA Inspection Guidance Manual for additional procedures). Senior Environmental
Employment (SEE) enrollees should be aware that, pending congressional legislation, they are not allowed
to see confidential business information.
Facility officials should then review the completed Receipt for Samples (if prepared) and make any
further claims. Even when no receipt is required, inspectors should be sure that facility officials
understand their right to make confidentiality claims.
7.4 Compliance Outreach
Since the inspector is often the only contact between EPA and the regulated industries, s/he should be
aware of opportunities to promote compliance with EPA regulations. The closing conference provides
an ideal opportunity to offer various kinds of help to facility officials. The inspector will have just
completed an inspection and will have first-hand knowledge of questions, problems, and possible
solutions.
However, in this role, the inspector should be careful to answer only those questions that are within
her/his ability or authority. The inspector should never recommend that a particular step be taken to
address a problem. Such advice may be wrong, and if the facility is later found to be in noncompliance,
EPA's ability to pursue an enforcement action would be jeopardized. However, the inspector can offer
or suggest resources that are available to facility officials to help solve problems (e.g., technical
publications, special services). Inspectors should refer questions and problems to other EPA personnel
as needed, and follow up with those personnel when practical to see that facility officials receive a
response.
Since the purpose of the inspection process is to promote compliance, as well as to identify violations,
it is important for the inspector to help raise the level of a facility's awareness of EPCRA Section 313.
The closing conference is an ideal opportunity for the inspector to promote compliance by disseminating
Interim Final, November 1992 7-2 EPCRA Data Quality Inspection Manual
-------
Chapter Seven Closing Conference
EPA literature to the facility. The following publications may be recommended or given to the facility
to increase their awareness of EPCRA Section 313 (especially data quality). The inspector should tell
facility officials that any information or publications on data quality given to a facility should be tailored
to their specific needs.
• General: Statute and Regulations
Toxic Chemical Release Reporting Regulations - 40 CFR Part 372
Toxic Chemical Release Inventory Reporting Package for 1990 (EPA 560/4-91 -001)
Toxic Chemical Release Inventory Questions and Answers (EPA 560/4-90-003)
Common Synonyms for Section 313 Chemicals (EPA 560/4-90-005)
Section 313 Interpretive Guidance System (ASKSAM Database)
Compilation of Air Pollution Emission Factors (AP-42, OAQPS, Sept. 1985)
Toxic Air Pollutant Emission Factors — A compilation for Selected Air Toxics
Compounds and Sources (EPA 450/2-88-006a)
Estimating Releases and Waste Treatment Efficiencies for the Toxic Chemical
Release Inventory Form (EPA 560/4-88-002)
• Industry-Specific
Toxic Chemical Release Inventory: Clarification and Guidance for the Metal
Fabrication Industry (EPA 560/4-90-012)
Title III Section 313 Release Reporting Guidance (EPA 560/4-88-004 a through 1,
p, and q), estimating chemical releases from :
a. Monofilament Fiber Manufacturing
b. Printing Operations
c. Electrodeposition of Organic Coatings
d. Spray Application of Organic Coatings
e. Semiconductor Manufacture
f. Formulating Aqueous Solutions
g. Electroplating Operations
h. Textile Dyeing
i. Presswood and Laminated Wood Products Manufacturing
j. Roller, Knife, and Gravure Coating Operations
k. Paper and Paperboard Production
I. Leather Tanning and Finishing Processes
p. Wood Processing
q. Rubber Production and Compounding
EPCRA Data Quality Inspection Manual 7-3 Interim Final, November 1992
-------
dosing Conference Chapter Seven
BLANK PAGE
Interim Final, November 1992 7-4 EPCRA Data Quality Inspection Manual
-------
Chapter Eight Post-Inspection Activities
Chapter Eight
Post-Inspection Activities
Page
8. Post-Inspection Activities 8-1
8.1 Introduction 8-1
8.2 Followup Activities 8-1
8.3 The Inspection Report 8-2
8.4 Submitting the Inspection Report 8-4
EPCRA Data Quality Inspection Manual 8-i Interim Final, November 1992
-------
Post-Inspection Activities Chapter Eight
BLANK PAGE
Interim Final, November 1992 8-ii EPCRA Data Quality Inspection Manual
-------
Chapter Eight Post-Inspection Activities
8. Post-Inspection Activities
8.1 Introduction
The effectiveness of an EPCRA data quality inspection is dependent on many factors, including the
thoroughness of the inspection, the evidence collected by the inspector, and the cooperation of the facility
being inspected. Critical to the success of the inspection process are two steps that follow the inspection
itself:
• Conducting followup activities, which help ensure that any outstanding questions or data
discrepancies are answered and resolved and contribute to a more detailed, thorough
inspection report
• Preparing the inspection report, which clearly outlines the elements for consideration prior
to making an enforcement decision.
This chapter includes discussion of followup activities and report preparation, including guidance on what
to do with the inspection report once it is completed. Followup activities are necessary to ensure that any
outstanding data pertaining to the facility and the inspection are obtained as soon as possible following
the inspection for inclusion in the inspection report. The primary function of the inspection report is to
serve as the main document upon which EPA Case Development Officers (CDOs) will base enforcement
decisions concerning the facility. These two post-inspection activities should be completed as soon as
possible, but no later than 45 days after the inspection. Each of these two steps is discussed below.
8.2 Followup Activities
Before preparing the inspection report, the inspector should review the information documented during
every phase of the EPCRA data quality inspection process, making note of data discrepancies or gaps in
knowledge, inspection processes, or timelines. The inspector should be looking for these gaps and
discrepancies when examining the following materials:
Field notebooks
Checklists
Photographs
Facility documents
Notices of Inspection, Receipts for Samples and Documents, CBI forms
Sketches of flow diagrams and process lines
Statements by facility officials.
EPCRA Data Quality Inspection Manual 8-1 Interim Final, November 1992
-------
Post-Inspection Activities Chapter Eight
If an inspector discovers gaps or discrepancies that could affect the quality of the inspection report, the
information needed may be requested from the facility via: 1) telephone call, 2) written request with a
timeframe for return attached (usually 30 days), or 3) in unusual circumstances, a followup visit.
The inspector should conduct the necessary followup to answer outstanding questions and obtain relevant
documents. The inspector should focus on obtaining information necessary to fill in gaps in material
already obtained from EPA records and/or the facility pertaining to facility operations and data quality.
The inspector should also collect information that clarifies the data already in the inspector's possession.
This additional and clarifying information should be included in the inspection report.
The inspector should keep in mind that s/he should already have requested outstanding data at the closing
conference. Therefore, the purpose of conducting followup activities is to ensure that facility
representatives respond to requests by EPA to supply missing data identified during the inspection. Other
followup can be through Headquarters (late reports, etc.), other contacts suggested on site, or other
program offices, if warranted.
83 The Inspection Report
The inspection report is the final activity and one of the most critical components of the inspection
process. It is the document that enables the CDOs to make correct enforcement decisions regarding a
facility's compliance and, if necessary, develop a case. Therefore, it is imperative that the inspection
report is complete and factual and accomplishes all of the following objectives:
• Contains all the components of the report, including copies of relevant forms and documents
as appendices, as well as the narrative component of the report referencing forms and
documents.
• Substantiates, with as much evidence as possible, each potential violation of EPCRA Section
313 cited in the report, ensuring that any documents and/or photographs are not only
appended to the report but are referenced in the narrative component of the report. (This is
necessary so that CDOs know how the data relate to the inspection.)
• Is written in clear and precise language.
• Presents factual and accurate information pertaining to all steps of the inspection process,
from opening to closing conference and followup.
• Makes only those observations that are based on firsthand knowledge of the facility since
enforcement personnel must be able to depend on the accuracy of all information.
• Includes only information that is relevant to the facility and its compliance with EPCRA
Section 313. (Irrelevant facts can interfere with enforcement decisionmaking.)
Interim Final, November 1992 8-2 EPCRA Data Quality Inspection Manual
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Chapter Eight Post-Inspection Activities
A well-developed inspection report must include several key pieces of information. This information will
enable the CDO to have all the information necessary to make the correct enforcement decision.
Therefore, it is critical that all the components of the inspection report lead the reader, in a simple and
logical progression, to the correct conclusion regarding a facility's compliance status.
The following components should be included in the inspection report:
• Title page
• Index
• Facility information
Company name, address, and telephone number
Parent company name and address
Primary SIC code and D&B number
Type of facility
Number of employees
Threshold quantities of listed EPCRA Section 313 chemicals
History of violations/receipt of Notices of Noncompliance
• Inspection information (narrative body of report)
Inspector name
Date of notification
Date, time, and type of EPCRA inspection
Responsible facility official's name, title, and phone number
Other contributing facility representatives
Reason for inspection
Physical and operational description of facility
Compliance with entry and inspection procedures
Chronology of actions during inspection
Factual observations
Deviations from inspection plan, if any
Claims of CBI, if any
• Evidence and exhibits (all evidence and exhibits must be referenced and explained in the
narrative body of the report)
Notification letter, if used
NOI
Receipt for Samples and Documents
Declaration of CBI
Inspection plan and inspection checklist
Photographs
Facility documentation supporting an estimate of releases
EPCRA Data Quality Inspection Manual 8-3 Interim Final, November 1992
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Post-Inspection Activities Chapter Eight
• Summary
Type of inspection conducted
Inspection priorities identified
Preliminary identification of potential violations (this is exempted from release
under FOIA)
While preparing the inspection report, the inspector should keep in mind that some or all of the data
gathered during the inspection may be CBI. Otherwise, the report may be released to the public in
response to a FOIA Request. Therefore, if the inspection report contains CBI, those portions of the
inspection report must be treated in accordance with CBI procedures. In addition, if the inspector takes
notes in the field logbook during the inspection and refers to CBI, s/he should treat such notes as CBI.
However, the inspector may include a reference number in the notes (referring to CBI elsewhere) so that
the notes will not have to be treated as CBI.
8.4 Submitting the Inspection Report
Once a thorough and complete inspection report has been developed, it should be reviewed by the
EPCRA Section 313 Coordinator and forwarded to the CDO. The CDO will review the inspection report
carefully, determine if a possible violation exists, draft a complaint, and begin to develop the case.
Even though the inspector's role in the investigation of a facility is technically completed once an
inspection report has been filed, the inspector should be available to the CDO to provide clarification on
technical and logistical issues and should be ready to testify if the case goes to court.
Interim Final, November 1992 8-4 EPCRA Data Quality Inspection Manual
-------
Chapter Nine Elements of a Good Data Quality Case
Chapter Nine
Elements of a Good Data Quality Case
Page
9. Elements of a Good Data Quality Case 9-1
EPCRA Data Quality Inspection Manual 9-i Interim Final, November 1992
-------
Elements of a Good Data Quality Case Chapter Nine
BLANK PAGE
Interim Final, November 1992 9-ii EPCRA Data Quality Inspection Manual
-------
Industry Profiles
-------
TRI FAaUTY PROFILE
FOUNDRIES
by
IT Corporation
11499 Chester Road
Ohio 45246
Contract No. 68-D04020
Work Assignment No. 2-27/2-65/3-18
JIN 830015-5-1
Prepared for
US. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF TOXIC SUBSTANCES
401 M Street, SW
Washington, D.C 20460
July 1992
-------
CONTENTS
Page
Section 313 Chemicals Used in Foundries 9
Iron Foundries 9
Steel Foundries 20
Aluminum Foundries 29
Copper Foundries 37
Other Foundries 42
Use of Regulations to Estimate Release of Section 313 Chemicals 48
Nonreporting Facilities 51
List of Questions S3
Bibliography 55
Appendix A Selected Information Emission Factors for Iron A-l
Foundries
11
-------
FIGURES
Number
1
2
3
Number
1
2
3
4
5
6
7
8
Simplified Process Flow Diagram for Foundries
Emission Points in a Typical Iron Foundry
Typical Flow Diagram of a Steel Foundry
TABLES
Types of Furnaces Used in Foundry Operations
Summary of Reported Releases of Metals and Metal Compounds
From Iron Foundries
Summary of Reported Releases of Chlorinated Solvents
From Iron Foundries
Summary of Reported Releases of Acids From Iron Foundries
Summary of Reported Releases of Organic Solvents
From Iron Foundries
Summary of Reported Releases of Other Chemicals From
Iron Foundries
Summary of Reported Releases of Metals and Metal
Compounds From Steel Foundries
Summary of Reported Releases of Chlorinated Solvents
From Steel Foundries
Page
4
5
21
Page
2
11
13
17
18
20
23
25
-------
TABLES (continued)
Number
9
10
11
12
13
14
15
16
17
18
19
20
21
Summary of Reported Releases of Acids From Steel
Foundries
Summary of Reported Releases of Organic Solvents
From Steel Foundries
Summary of Reported Releases of Other Chemicals
From Steel Foundries
Summary of Reported Releases of Metals and Metal
Compounds From Aluminum Foundries
Summary of Reported Releases of Chlorinated Solvents
From Aluminum Foundries
Summary of Reported Releases of Acids From Aluminum
Foundries
Summary of Reported Releases of Other Chemicals
From Aluminum Foundries
Summary of Reported Releases of Metals and Metal
Compounds From Copper Foundries
Summary of Reported Releases of Chlorinated Solvents
From Copper Foundries
Summary of Reported Releases of Acids From Copper
Foundries
Summary of Reported Releases of Metals and Metal
Compounds From Other Foundries
Summary of Reported Releases of Chlorinated Solvents
From Other Foundries
Summary of Reported Releases of Acids From Other
Foundries
Page
26
27
28
32
33
35
36
38
40
41
44
45
46
IV
-------
TABLES (continued)
Number £ig£
22' Summary of Reported Releases of Other Chemicals From
Other Foundries 47
23 Number of Facilities With More Than Ten Employees 51
-------
TRI FACILITY PROFILE
FOUNDRIES
The purpose of this profile is to assist EPA Regional Office personnel with Sec-
tion 313 inspections. The profile describes key toxic chemicals used in foundries,
describes how these chemicals are used, and identifies key release sources. All Section
313 chemicals reported to TRI by over 5 percent of the foundries in each foundry type
are presented in this profile.
Foundries are operations that melt metal to pour into molds to produce castings.
The industry is primarily defined as SIC 332 - Iron and Steel Foundries and SIC 336 -
Nonferrous Foundries (Castings). For purposes of this profile, the industry is further
divided into five categories:
• Iron foundries defined as SIC 3321 - Gray and Ductile Iron Foundries and
SIC 3322 - Malleable Iron Foundries.
Steel foundries defined as SIC 3324 - Steel Investment Foundries and SIC
3325 - Steel Foundries Not Elsewhere Classified.
• Aluminum foundries defined as SIC 3363 - Aluminum Die Castings and
SIC 3365 - Aluminum Foundries.
• Copper foundries defined as SIC 3366 - Copper Foundries.
• Other nonferrous foundries defined as SIC 3364 - Nonferrous Die Q«tifig?
Except Aluminum and SIC 3369 - Nonferrous Foundries Except Aluminum
and Copper.
Table 1 shows the various types of furnaces used to melt metal in a foundry
operation.1
Foundries use similar processes, regardless of the raw material used.1 Since iron
and steel foundries account for the vast majority of tonnages produced by all foundries in
-------
TABLE 1. TYPES OF FURNACES USED IN FOUNDRY OPERATIONS1
Metal
Aluminum
Brass/Bronze
Gray Iron
Steel
Zinc
Copper
Lead
Crucible
X
X
X
X
Electric
Induction
X
X
X
X
X
X
Furnace type
Electric Open
Reverberatory Cupola arc hearth
X
X XX
X X
X
Pot
X
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the United States, a brief description of the gray iron foundry operation is given here.
After this description, each foundry type (iron, steel, aluminum, copper, and other non-
ferrous) will be discussed separately with emphasis on differences from this overall
description and with specific emphasis on the Section 313 chemicals used in each foundry
type. As Explained in the section on nonreporting facilities, most foundries with more
than 10 employees probably are processing or otherwise using at least one Section 313
chemical in excess of threshold values. Figure 1 presents a simplified process flow dia-
gram showing major operations that occur in foundries. Figure 2 presents the emission
points in a typical iron foundry.2
The four major production steps in foundry operations include raw materials
handling and preparation, metal melting, mold and core production, and casting and
finishing.2
Raw materials handling and preparation operations include receiving, unloading,
storing and conveying of all raw materials for both furnace charging and mold and core
preparation.2 The major groups of raw materials required for furnace charging are
metallics, fluxes, and fuels. Raw material preparation may include the cleaning of scrap
metals before charging.
Metal melting is done in a variety of furnaces with the furnace charge consisting
of metallics, fluxes and fuels. As presented in Table 1, seven general furnace types are
used in foundries. The cupola, which is the major type of furnace used in iron foundries,
is a vertical cylindrical steel shell with either a refractory-lined or water-cooled inner
wall.2 Refractory linings usually consist of silica brick, dolomite, or magnesium brick.
Water cooled linings, which involve circulating water around the outer steel shell, are
used to protect the furnace wall from interior temperatures. The cupola is charged at
the top with alternate layers of coke metallics and fluxes. Cupola capacities typically
range from 1 to 30 tons per hour, with a few larger units approaching 100 tons per hour.
Electric Arc Furnaces (EAF) are large, welded-steel cylindrical vessels equipped
with a removable roof through which retractable carbon electrodes are inserted.2 The
electrodes are lowered through the roof of the furnace and are energized by three-phase
alternating current, to create arcs that melt the metallic charge with their heat
-------
Scrap Metal
Scrap Cleaning
I
Metal Ingots
Alloying Agents,
Flux, Coke, etc.
Binder
J
v/upoia rurnace
Electric Arc
Furnace
Electric
Induction
Furnace
Reverb* ratory
Furnace
Crucible
Furnace
roi rumace
Open Hearth
w
-•*•
-*»•
^—
-t*l
-•».
Ductile Iron
Innoculatlon
Canri
Preparation
t
•\JnMlvtM
MOKJing
| Molds
Pouring Metal
Into Molds
A
f Core
Core Curing
t
Pnro Maklnn
»
Binder Mix
t
Furnace
Casting
Shakeout
I
Cooling and
Cleaning
I
Finishing
I
Shipping
t
Parts
Figure 1.
Simplified process flow
diagram for foundries.1
IDRAWINO I f I
* i n
CHECKED BY
APPROVED BY
DRAWING
M 83001*
-------
0AS AN*
fAIIKUIATI
(MlttlOMS
I/I
SHIPPING
DUCTH.I MON
MMOCUIATION
CASTING
SHAKEOUT
FINISHING
Mill
COOLING AND
CLEANING
SAND
PREPARATION
Figure 2. Emission points in a typical iron foundry.3
-------
Additional heat is produced by the resistance of the metal between the arc paths. The
most common method of charging an electric arc furnace is by removing the roof and
introducing the raw materials directly. Alternative methods include introducing the
charge through a chute cut in the roof or through a side charging door in the furnace
shell. Once the melting cycle is complete, the carbon electrodes are raised, and the roof
is removed. The vessel is tilted, and the molten iron is poured into a ladle. Electric arc
furnace capacities range from 023 to 59 megagrams (0.25 to 65 tons). Nine to eleven
pounds of electrode are consumed per ton of metal melted. Electric arc furnaces are
becoming increasingly popular in the steel-making industry.
Electric induction furnaces are either cylindrical or cup-shaped refractory-lined
vessels that are surrounded by electrical coils which, when energized with high frequency
alternating current, produce a fluctuating electromagnetic field to heat the metal charge.2
For safety reasons, the scrap metal added to the furnace charge is cleaned and heated
before being introduced into the furnace. Any oil or moisture on the scrap could cause
an explosion in the furnace. Induction furnaces are kept dosed except during charging,
skimming and tapping. The molten metal is tapped by tilting the vessel and pouring the
metal through a hole in the vessel side. Induction furnaces also may be used for metal
refining in conjunction with melting in other furnaces and for holding and superheating
the molten metal before pouring (casting).
Reverberatory furnaces operate by radiating heat from a burner flame, furnace
roof, and furnace walls onto the material heated.3 The reverberatory furnace usually
consists of a shallow, generally rectangular, refractory hearth for holding the metal
charge. The furnace is enclosed by vertical side walls and covered with a low, arched,
refractory-lined roof. Fuel is combusted directly above the molten bath; the walls and
roof reserve radiant heat from the hot combustion products and, in turn, reradiate the
heat to the surface of the bath surface.3 Heat is transferred almost entirely by radiation.
Crucible furnaces used to melt metals with melting points below 2£00°F, are
usually constructed with a shell of welded steel lined with refractory materials.3 Their
covers are constructed of materials similar to the inner shell lining; a small hole over the
crucible is used for charging materials and exhausting combustion products. The
-------
crucible, which rests on a pedestal in the center of the furnace, is commonly constructed
of refractory materials such as clay-graphite mixtures or silicon carbide. Crucibles are
made in several shapes and sizes for melting from 20 to 2,000 pounds.3 Crucible
furnaces are classified as tilting, pit, or stationary furnaces.
Pot furnaces are used to melt metals with a melting temperature below 1.400T.3
These furnaces may be cylindrical or rectangular and consist of an outer shell lined with
refractory material, a combustion chamber, and a pot The pots are made of pressed
steel, cast steel, or cast iron with flanged tops.3 The flange rests on the furnace wall,
holds the pot above the furnace floor, and seals the contents of the pot from the
combustion products of the fuel used.3 The shape of the pot depends upon the
operation to be conducted. Large rectangular furnaces, generally called kettles, are used
to melt large amounts of metal for dipping operations, such as galvanizing.3 For melting
large castings, shallow, large-diameter pots are used. When ingots or other small pieces
of metal are to be melted, deep pots are used to promote better heat transfer. Pot
furnaces are usually emptied by tilting, dipping, or pumping. Combustion equipment
ranges from simple atmospheric-type burners located directly below the pot to premix-
type tangentially fired burners. The larger kettles are generally provided with many
burners along both sides of the pot
Open hearth furnaces may be charged with various types of iron-bearing materials
1) hot metal (pig iron) and molten steel, 2) cold steel scrap and cold pig iron, 3) all steel
scrap, or 4) steel scrap and molten pig iron.3 A luminous flame with excess air is passed
over the charged materials to provide heat for the process. Combustion air is alternately
preheated by regenerating units, which, in turn, are heated by the products of combus-
tion discharging from the furnace.
Mold and core production requires the use of Section 313 chemicals. Molds are
forms used to shape the exteriors of castings.2 Cores are molded sand shapes used to
make the internal voids in castings. Cores are made by mixing sand with organic
binders, molding the sand into a core, and baking the core in an oven. Molds are pre-
pared of a mixture of wet sand, day, and organic additives to make the mold shapes,
which are usually dried with hot air. Cold setting binders are being used more
-------
frequently in both core and mold production. Used sand from castings shakeout (after
metal pouring) is recycled to the sand preparation area and cleaned to remove any clay
or carbonaceous buildup. The sand is then screened and reused to make new molds.
Makeup sand is added to allow for process losses and discard of a certain .amount of
sand because of contamination.
Casting and finishing operations include molten metal pouring, mold removal and
various other operations used to finish the casting. After the melting process, molten
metal is tapped from the furnace. Molten iron produced in cupolas is tapped from the
bottom of the furnace into a trough, into a ladle. Iron produced in electric arc and
induction furnaces is poured directly into a ladle by tilting the furnace.
When castings have cooled, any unwanted appendages, such as spurs, gates, and
risers, are removed. These appendages are removed with an oxygen torch, abrasive band
saw, or friction cutting tools. In less-mechanized foundries, hand hammers may be used
to knock off the appendages. After appendage removal the castings are subjected to
abrasive blast cleaning and/or tumbling to remove any remaining mold sand or scale.
The castings may also be finished for machining or grinding, and some products are
degreased and painted before shipment.
8
-------
SECTION 313 CHEMICALS USED IN FOUNDRIES
Section 313 chemicals commonly used in foundries can be classified into five
distinct categories: metals/metal compounds, chlorinated solvents, acids, organic
solvents, and other Section 313 chemicals. Each category is discussed separately in this
report Each section contains a description of how the Section 313 chemicals are used, a
discussion of typical releases and off-site transfers, a table nimmarmng releases and off-
site transfers that were reported to the Toxic Release Inventory (TRI) in 1990, a
description of industry-specific and chemical-specific regulations, typical control practices,
and common reporting errors. Methods for identifying nonreporting facilities and a list
of questions are also presented. Appendix A presents selected information and pub-
lished emission factors for iron foundries.
IRON FOUNDRIES
Each of the five categories of Section 313 chemicals will be discussed separately.
Metals and metal compounds are processed as constituents of the iron or added
to form alloys to provide desired properties in the metal casting. Metal compounds may
also be manufactured as byproducts in the melting process. The primary metals/metal
compounds processed at iron foundries are manganese, copper, chromium, and nickel
(and their compounds). Lead, zinc, aluminum (fume or dust), and ca^miym (and their
compounds) are processed to a lesser degree. The compounds of these metals may be
manufactured as a byproduct of the process. Metal/metal compounds may also be
released during finishing of the castings during grinding and other mechanical processes.
The metals/metal compounds are in the form of fume and dust and are controlled
by a number of control devices. These controls vary so widely among foundries that
specific controls at the foundry in question should be identified.
The metals/metal compounds may also be transferred off site for treatment or
disposal or may be disposed of on site as a land release. Small quantities may be sent to
water or Publicly Owned Treatment Works (POTW). Based on Section 313 reporting
-------
for 1990, Table 2, presents a summary of Section 313 reported releases and off-site
transfers of metals/metal compounds at iron foundries.
For metals/metal compounds processed in iron foundries, stack test results
provide the best data for estimating air releases. If the stack tests are for total
particulates, then the percentage of the metal/metal compound in the control device may
be used to estimate releases of the metal/metal compound. Some plants test the cap-
tured particulates for metals for internal purposes or testing may be required if this
waste is a RCRA waste. Where no stack test data are available, emission factors Listed
in AP-42 (Section 7.4 and 7.10) by furnace and control type2 may be used. On-site land
disposal or off-site transfers can be estimated by the volume of waste and the percentage
of metal/metal compound in the waste. Releases to water or POTW may be estimated
by using monitoring data or by comparison with monitoring data for a related met-
al/metal compound. For example, EPA Effluent Guidelines may require testing for cop-
per, lead, or zinc for certain foundries.
Chlorinated solvents are otherwise used at iron foundries as a mold release
carrier, in the degreasing of metal scrap, and in degreasing of the castings prior to or
during finishing operations. Chlorinated solvents may also be present in metal cutting
fluids used at iron foundries or in products used to detect cracks in castings.
The primary chlorinated solvent used at iron foundries is 1,1,1-trichloroethane.
Dichloromethane, trichloroethylene, and Freon-113 are used to a much lesser degree.
When chlorinated solvents are used as a mold release carrier and in products
used to detect cracks in castings, all emissions are released to air without pollution
controls. Therefore, the air release is equal to solvent usage. For cutting fluids, some
emissions are released to air during usage and some are transferred off site for treatment
or disposal as waste cutting oil or in degreasing waste if the parts are cleaned with a
chlorinated solvent
Chlorinated solvents may also be used to degrease scrap or to clean castings prior
to finishing. They may be used as a solvent wipe, in a cold degreaser, or in a vapor
degreaser.
10
-------
TABLE 2. SUMMARY OF REPORTED RELEASES OF METALS AND METAL COMPOUNDS
FROM IRON FOUNDRIES
Section 313
Chemical
Manganese
Manganese compounds
Copper
Coppor compounds
Chromium
Cnronluni compounds
Nickel
Nickel compounds
Load
'Load compounds
Zinc (fume or
dust)
Zinc compounds
Aluminum (fun or
dUBt)T
Cadmium
Molybdenum trloxldo
Cobalt
Hunter of facilities
reporting usage
(X reporting usage)
96 (49)
23 (12)
76 (39)
10 (5)
58 (29)
19 (10)
54 (27)
11 (6)
14 (7)
13 (7)
6 (3)
13 (7)
12(6)
6(3)
3 (1)
2 (1)
1 (0.5)
Mean release. Ib (X reporting to each media)
Fugitive
665 (58)
571 (52)
1,996 (55)
182 (60)
1.053 (48)
1.113 (53)
192 (52)
34 (45)
190 (50)
473 (46)
812 (67)
678 (46)
784 (33)
5(50)
250 (33)
5(50)
21 (100)
Stack
6.567 (50)
2,199 (61)
184 (53)
529 (70)
267 (50)
593 (79)
129 (SO)
139 (63)
1197 (71)
860 (77)
e(50)
1.306 (69)
1.676 (67)
53 (83)
0 (0)
5 (SO)
SB (100)
Water
303 (13)
729 (26)
48 (16)
24 (40)
77 (16)
69 (26)
62 (9)
132 (18)
96 (21)
70 (38)
0 (0)
586 (31)
500 (8)
1 (17)
250 (33)
0(0)
0 (0)
Land
116.972 (25)
385.550 (26)
4.161 (20)
12.000 (10)
19.893 (17)
280.000 (11)
1.830 (15)
3.700 (9)
e (50)
34.700 (31)
0(50)
152.790 (23)
48.046 (25)
o(67)
0(0)
0(0)
0 (0)
rorec
587 (15)
100 (13)
162 (17)
34 (40)
150 (19)
49 (32)
164 (15)
52 (27)
135 (14)
93 (23)
750 (17)
1.200 (8)
250 (17)
250 (17)
0(0)
250 (50)
29 (100)
Off -site transfer
47,410 (51)
182.395 (65)
3.026 (S3)
7.124 (80)
30,599 (43)
46.876 (79)
3.985 (44)
4.922 (73)
• (71)
44,678 (85)
o (17)
117.031 (69)
192.811 (8)
67 (83)
0(0)
1056 (50)
9.418 (100)
Total"
63.173 (91)
242.454 (91)
4,024 (91)
7.402 (100)
20.685 (83)
71.324 (95)
2,744 (81)
4,463 (91)
o (100)
49.410 (100)
o (100)
139.183 (85)
35.450 (83)
e (100)
250 (67)
658 (100)
9.526 (100)
BA total of 197 facilities In SICs 3321 and 3322 reported usage of at least one Section 313 chemical above the threshold limits.
Mean release In pounds per year In 1990 for firms reporting releases of this chemical, and percentage of firms reporting usage of this chemical
and releases to this Madia. Releases to other media were Insignificant.
° PDTV • Publicly owned treatment works.
d
The total Includes all releases and off-site transfers, not just categories summarized In this table.
Mean value Is not representative because of e very large value at one facility and the small number of facilities.
These chemicals are produced as by-products.
-------
In a solvent wipe, a rag or other wiper is dipped in the chlorinated solvent and
wiped across the part to remove the contaminant from the casting. Cold degreasers
usually consist of a tank, basket, and cover, and may employ spraying, brushing, agitation,
flushing, or immersion. The solvent is usually kept near room temperature. Cold units
vary greatly in size and design. The size of the degreaser is directly related to the size
and number of the castings being cleaned.
A vapor degreaser consisting of a tank and heating system to boil the solvent, may
be operated manually or it may be conveyorized. In this process, parts are lowered into
a solvent vapor produced for cleaning. Vapors condense on the parts until the tempera-
ture of the part approaches that of the vapor, at which time the parts are removed.
Most vapor degreasers are equipped with condenser coils located on the upper sidewalls
of the degreaser to control the vapor level in the tank. They may also be equipped with
water separators, which are simple containers in which solvent and water that condenses
from the ambient air are separated. Lids are commonly closed when the degreaser is
not in use.
Degreasing operations primarily produce fugitive and point-source air releases and
off-site transfers for solvent recovery or disposal. In vapor degreasing, moisture from air
condensing on the cooling coils of the degreaser may result in minimal releases to water
or POTWs. Based on Section 313 reporting for 1990, Table 3 presents a summary of
Section 313 reported releases and off-site transfers from use of chlorinated solvents at
foundries.
Various controls may be used to reduce releases and off-site transfers of Section
313 chemicals from foundries. Air releases from the use of chlorinated solvents in vapor
degreasing operations may be reduced by application of the following engineering con-
trols and operation and maintenance (O&M) procedures:
Engineering controls
Lowering the temperature of cooling water.
• Increasing freeboard height (distance between top of vapor phase and top
of degreaser).
Adding low-solvent-level detector.
12
-------
TABLE 3. SUMMARY OF REPORTED RELEASES OF CHLORINATED SOLVENTS
FROM IRON FOUNDRIES
Rioter of facility
reporting usage
Section 313 Chemical (X reporting usage
1.1, 1-Trlchloroethane
Olchloromthane
Tr 1 chl oraethylene
Freon-113
51 (26)
7 (4)
6(3)
5 (3)
*
) Fugitive
97,746 (92)
14.924 (100)
39.553 (83)
1.312 (100)
Mean release. Ib [X reporting
Stack
103.790 (37)
6.984 (14)
39.078 (67)
36.168 (40)
POTW°
4,207 (12)
250 (29)
19 (50)
414 (80)
to each media)6
Off -site transfer*
802 (20)
6.028 (14)
7.866 (67)
1.077 (20)
Total6
129.423 (100)
16.855 (100)
64.265 (100)
16.326 (100)
A total of 197 facilities In SICa 3321 and 3322 reported usage of at least one Section 313 chemical above the threshold limits.
Mean release In pounds per year In 1990 for firms reporting releases of this chemical and percentage of firms reporting usage of
this chemical and releases to this media. Releases to other media were Insignificant.
POTV • Publicly owned treatment works.
Off-elte transfer for recycling was not report able In 1990; transfer for recycling would be significant for chlorinated
solvents used In degreaalng operations.
The total Includes all releases and off-site transfers, not just categories suimrlied In this table.
-------
' Using optimum pans-handling speeds (automatic hoists).
• Adding automatic lid closure.
Adding extra cooling coils on inlets and outlets.
O&M procedures
• Qosing the cover when possible.
• Minimizing drafts.
Positioning work to minimize dragout (solvent on part when removed from
the degreaser).
• Spraying only below the vapor level.
Avoiding excessively large loads.
Maintaining equipment
Waste solvent evaporation can be a major source of air release from cold
cleaning. This release occurs when spent solvent is stored in open containers prior to
disposal and/or from evaporation at the disposal site. This release can be minimized by
covering spent solvent containers and by reclaiming solvent Another release source,
solvent bath evaporation, can be reduced through use of a cover whenever parts are not
being cleaned and through adjustment of room and exhaust ventilation rates to minimize
drafts. A third release source, solvent canyout, is dependent on the use of a drainage
rack. Internal or external racks can be used, depending on the size of the cleaning unit.
Also, drainage time must be of adequate duration to ensure that the racks are effective
in reducing carryout
Resource Conservation and Recovery Act (RCRA) wastes are those that are
defined in § 261 of RCRA. Specific chlorinated solvents are identified in § 26131 as
wastes from non-specific sources or "F" wastes. F001 and F002 generic wastes as defined
by the RCRA are spent solvent wastes that before use contained over 10 percent listed
chlorinated solvents (including tetrachloroethylene, trichloroethylene, methylene chloride,
1,1,1-trichloroethane, carbon tetrachloride, chlorobenzene, orthodichlorobenzene,
trichlorofluoromethane, and 1,1,2-trichloroethane). Off-site transfers of waste
chlorinated solvents (RCRA F001 and F002 wastes) can be reduced through use of on-
site solvent recovery.
14
-------
For two of the chlorinated solvents used in foundries (1,1,1-trichloroethane and
Freon-113), use is expected to drop significantly as a result of EPA environmental regu-
lations to reduce ozone depletion. These regulations will eventually phase out the use of
these solvents entirely and will result in increased control of air releases, substitution,
and use of solvent recovery due to rising solvent costs. -Although terpenes, aqueous
cleaning and semi-aqueous cleaning are being substituted in may uses for chlorinated
solvents, the probable substitutes in the foundry industry are not well defined.
For chlorinated solvents used in degreasing, a mass balance (addressing primarily
air release and off-site transfer of waste solvent) that accounts for the total throughput of
the solvent is the best methodology for estimating release and off-site transfer. Prior to
the 1991 reporting year (to be submitted by July 1,1992), this approach was difficult
using the Section 313 reporting quantities because off-site transfer for recycling of the
chlorinated solvents was not reportable. Beginning with the submittals for the 1991
reporting year, a mass balance will be possible for all reportable quantities once the
throughput has been obtained from the facility as all releases and off-site transfers are
now reportable. A common error in reporting has been the use of the total quantity of
waste solvent sent off site (i.e., that reportable under RCRA as F001 and F002 wastes)
as the quantity of chlorinated solvent sent off site. Since the chlorinated solvent repre-
sents only a portion of the waste, the mass balance underestimates the air release of the
chlorinated solvent Although Section 313 reporting does not require the facility to take
any measurements, the facility usually can contact the solvent reclaimer to obtain the
percentage of chlorinated solvent in the waste solvent If the percentage of chlorinated
solvent represents only a portion of the waste, it is the appropriate quantity to use in a
mass balance.
Acids are otherwise used in a wide variety of ways at foundries. Sulfuric and
phosphoric acids are the primary acids used at iron foundries with hydrochloric and nitric
used to a much lesser extent Sulfuric acid may be used in wastewater treatment and as
a constituent of scrubber water. Phosphoric acid may be present in mold or refractory
materials or used in phosphating of parts during finishing processes. Hydrochloric acid
may be used to clean the cupola shell or in metal precipitation during wastewater
15
-------
treatment. Acids are primarily released through off-site transfer of spent acid. Some of
the more volatile acids are released to air and some are released to water if the stream
is not neutralized. Table 4 presents a summary of reported releases and off-site transfers
of acids from iron foundries. Acid releases are primarily controlled through neutrali-
zation. For acid use, a release to water is not reportable if the pH is 6 or higher;
however, a facility cannot just assume neutralization. Typically, pH monitoring data for
other regulations is (and should be) retained by the facility. This data can be used to
calculate water releases if excursions below pH 6.
Organic solvents are primarily otherwise used as solvents in paints and coatings in
the finishing of parts formed at iron foundries. For all organic solvents virtually all
release occurs to air. Minor quantities may be transferred off site in paint wastes or to
POTW if a water curtain is used as a control/collection measure for spray mist A mass
balance may be calculated with almost all of the usage released as an air waste. Table 5
presents a summary of reported releases and off-site transfers of organic solvents from
iron foundries.
Other Section 313 chemicals have three primary uses at iron foundries.
Phenol, methylenebis (phenylisocyanate) formaldehyde, and ammonium nitrate
(solution) are otherwise used in core making at iron foundries. They are constituents in
the binder used to form the molds. Both organic binders and cross-linked organic poly-
mers may be used as core binders.4 The cross-linked organic polymers undergo thermal
decomposition when exposed to the very high temperatures of casting (typically 1400°C
for iron casting).4 At these temperatures it is likely that pyrolysis of the chemical binder
will produce a complex of free radicals which may recombine to form a wide range of
chemical compounds.4 Each chemical binder system gives rise to a number of different
thermal decomposition products.4
Releases to air can occur during the core making process. Releases to land or
off-site transfers can occur during disposal of molding materials. Minor quantities may
be released to water or a POTW.
Ethylene glycol is otherwise used in hydraulic fluids in iron foundries. Releases
and off-site transfers of this chemical can occur when the hydraulic fluid is changed or
16
-------
TABLE 4. SUMMARY OF REPORTED RELEASES OF ACIDS
FROM IRON FOUNDRIES
Section 313 Chemical
Sulfurlc acid
Phosphoric acid
Hydrochloric acid
Nitric acid
Number of facilities
reporting usage
(X reporting usage)
30 (IS)
23 (12)
7 (4)
1 (0.5)
Mean release. 1b (X reporting to each media)
Fugitive
e (28)
1.385 (35)
3.300 (4)
0 (0)
Stack
e (20)
5 (9)
188 (57)
0 (0)
Hater
0(0)
0 (0)
0(0)
0 (0)
Land
0 (0)
20.133 (13)
0 (0)
0 (0)
POTVC
5 (3)
202 (22)
0(0)
0 (0)
Off -site transfer
34,034 (27)
46.330 (22)
36.000 (14)
14.688 (100)
Total"
17.290 (57)
21.725 (61)
10.013 (57)
14.688 (100)
* A total of 197 facilities In SICs 3321 and 3322 reported usage of at least one Section 313 chemical above the threshold limits.
Mean release In pounds par year In 1990 for firm reporting releases of this chemical, and percentage of firms reporting usage of
this ehemlcel and releases to this media. Releases to other media were Insignificant.
C POTW • Publicly owned treatment works.
The total Includes all releases end off-site transfers, not just categories summarized In this table.
Mean value Is not representative because of one high value that may be In error. Air releases Mould be low because of low vapor pressure
of sulfurlc acid (VP <0.001 nmNg).
-------
TABLE 5. SUMMARY OF REPORTED RELEASES OF ORGANIC SOLVENTS
FROM IRON FOUNDRIES
Section 313 Chemical
Methanol
Xylene (mixed
1 sonars)
Toluene
61yeol ethers
Nethyl ethyl ketone
(hater of facilities
reporting usage
(X reporting usage)
30 (15)
25 (13)
12 (6)
8(4)
2 (1)
Mean release. Ib (X
Fugitive
33.735 (90)
35,843 (96)
20.847 (100)
3.410 (63)
1.776 (100)
Stack
46.288 (30)
22.422 (44)
23.072 (42)
8.672 (63)
0 (0)
Water
6 (13)
0(0)
0(0)
128 (SO)
0 (0)
reporting to each media)
POTWC
167 (10)
17(4)
0(0)
294 (50)
0 (0)
Off-site transfer
1.458 (30)
2.397 (12)
925 (25)
f (25)
8.117 (50)
Total*
46.244 (97)
44.563 (100)
30.691 (100)
f (100)
5.834 (100)
" A total of 197 facilities In SICs 3321 and 3322 reported usage of at least one Section 313 chemical above the threshold limits.
b
_ Mean release In pounds per year In 1990 for firms reporting releases of this chemical and percentage of firms reporting usage of
00 this chemical reporting releases to this media. Releases to other media were Insignificant.
° POTW • Publicly owned treatment works.
Off-site transfer for recycling or fuel blending was not report able In 1990: transfer off site of purge or cleanup solvent for
these purposes will be reportable In 1991.
* The total Includes all releases to and off-site transfers, not Just categories sonar 1 zed In this table.
Mean value la not representative because of one high value.
-------
when equipment leaks. If the leak is not cleaned up, then release may be to air. If
leaks are flushed down the sewer, then releases may be to water or a POTW. Beginning
in reporting year 1991, ethylene glycol in hydraulic fluid transferred offsite for fuel blend-
ing will be reportable under Section 313 and off-site transfers may increase from previ-
ous years.
Diethanolamine is otherwise used as a product constituent to detect cracks in
castings at some iron foundries. Reported releases include fugitive air POTW and off-
site transfers. No controls are typically used for any of these otherwise used chemicals.
Table 6 presents a summary of reported releases and off-site transfers of other
chemicals at iron foundries. It should be noted that some foundries reported the use of
isopropyl alcohol. Since this chemical is only reportable if it is manufactured at a facility
using a strong acid process, it should not have been reported by the iron foundries and
therefore is a mistake. Also, some facilities reported aluminum oxide (fibrous form). It
is unlikely but possible that over 25,000 Ib of aluminum oxide (fibrous form) would have
been processed or otherwise used. Aluminum oxide is used on grinding wheels, sanding
cones and in refractory bricks but not in the fibrous form.
19
-------
TABLE 6. SUMMARY OF REPORTED RELEASES OF OTHER CHEMICALS
FROM IRON FOUNDRIES
Section 313
Chemical
tJJimnnl
rnQTiOl
Nethylenebls
(phenyllsocyanate)
Formaldehyde
Ammonium nitrate
(solution)
Ethylene glycol
Dt et Hanoi ami ne
Use
Core-making
Core-making
Core-taking
Core-making
Hydraulic
fluid
Casting
finishing
Nutter of facilities
reporting usage
(X reporting usage)
60 (30)
32 (16)
21 (ID
6(3)
8(4)
4(2)
Mean release. 1b (X reporting to each media)
Fugitive
20,064 (77)
3.931 (72)
5.523 (95)
e(33)
5.865 (50)
300 (25)
Stack
5.912 (53)
5.530 (44)
10.166 (38)
e (33)
1.225 (25)
0(0)
Water
136 (23)
15(3)
1 (5)
34.000 (17)
854 (25)
0(0)
Land
5.762 (15)
36.046 (IB)
29,200 (10)
24.000 (17)
11.000 (13)
0(0)
POTWC
172 (20)
1.503 (B)
1.381 (24)
1.780 (33)
3.954 (36)
5.971 (75)
Off -site transfer
5.914 (62)
14.456 (53)
2.509 (48)
16.967 (66)
7.821 (50)
41,019 (25)
Total*1
23.505 (98)
20.416 (97)
13.437 (100)
26.339 (83)
11.692 (88)
14.808 (100)
A total of 197 facilities In SICs 3321 and 3322 reported usage of at least one Section 313 chemical above the threshold limits.
Mean release In pounds per year In 1990 for firms reporting releases of this chemical and percentage of firms reporting usage of this chemical and releases
to this media. Releases to other media were Insignificant.
C POTO • Publicly owned treatment works.
The total Includes all releases and off-site transfers, not just categories summarized In this table.
* Although two firms reported air releases of ammonium nitrate (solution), air releases for this chemical should be zero.
-------
STEEL FOUNDRIES
Steel foundries produce steel castings through melting, alloying, and molding of
pig iron and steel scrap. The process flow diagram of a typical steel foundry is presented
in Figure 3. The major processing operations of a typical steel foundry are raw materials
handling, metal melting, mold and core production, and casting and finishing.^
Raw materials used by steel foundries include pig iron, iron and steel scrap,
foundry returns, metal turnings, alloys, carbon additives, fluxes (limestone, soda ash,
fluorspar, calcium carbide), sand, sand additives, and binders. These raw materials are
received in ships, railcars, trucks, and containers and are transferred by trucks, loaders,
and conveyors to both open pile and enclosed storage areas.2
Generally, the first step in the metal melting operations is scrap preparation.
Since scrap is normally purchased in the proper size for furnace feed, preparation
primarily consists of scrap degreasing. This step is very important for electric induction
furnaces, as organics on scrap can be explosive. Scrap may be degreased with solvents,
by centrifugation, or by incinerator or preheater combustion. After preparation, the
scrap, metal, alloy, and flux are weighed and charged to the furnace.2
Electric arc furnaces (EAFs) are used almost exclusively in the steel foundry for
melting and formulating steel. EAFs are charged with raw materials by removal of the
lid, through a chute opening in the lid, or through a door in the side. The molten metal
is tapped by tilting the furnace and pouring the contents through a hole in the side.
Melting capacity ranges up to 10 megagrams (11 tons) per hour.2 EAFs generate a dust
of metallic oxides containing the volatile metals present in the charge (e.g., Zn, Pb, Cd,
Cr, and Mn).
A second, less common, furnace used in steel foundries is the open hearth
furnace-a very large, shallow refractory-lined vessel operated in a batch manner. The
open hearth furnace is fired at alternate ends by using heat from the waste combustion
gases to heat incoming combustion air.2 Aluminum oxide is used in refractory bricks but
not in the fibrous form.
20-/)
-------
is
If
Raw Materials
Unloading. Storage.
Transfer
•Flux
• Metalhcs
• Carbon Sources
•Sand
• Binder
Fugitive
Dust
Sand
Preparation
Fumes and
Fughive -
Dust
Scrap
Preparation
_ Hydrocarbons
and Smoke
Furnace
Vent
Furnace
> Electric Arc
• Induction
•Other
^ Fugitive
Dust
Mold Making
I
Fugitive
Oust
Mixing
'Sand
• Binder
Tapping.
Treating
Mold Pounng.
Cooling
Sand
i
Fugitve
• Fumes
and Dust
Fugitve
• Fumes
and Dust
^ Fugitive
•" " " Dust
Core Making
fc Oven
" " " Vent
Core Baking
Casting
Shakeout
Cooling
Cleaning.
Finishing
1
Fugitive
Dust
Fumes and
- Fugitive
Dust
Fugitive
Dust
Shipping
Figure 3
Typical flow diagram of a
steel foundry.2
21
-------
A third furnace used in the steel foundry is the induction furnace. Induction
furnaces are vertical, refractory-lined cylinders surrounded by electrical coils energized
with alternating current. The resulting fluctuating magnetic field heats the metal.
Induction furnaces are kept closed except when charging, skimming, and tapping. The
molten metal is tapped by tilting the container and pouring the metal through a hole in
the side of the container.2
The basic melting process operations are 1) furnace charging, in which metal,
scrap, alloys, carbon, and flux are added to the furnace; 2) melting, during which the
furnace remains closed; 3) backcharging, which is the addition of more metal and
possible alloys; 4) refining, during which the carbon content is adjusted; 5) oxygen
lancing, which is the injection of oxygen into molten steel to dislodge slag and to adjust
the chemistry of the metal; 6) slag removal; and 7) tapping the molten metal into a ladle
or directly into molds.2
Sand containing organic binders is molded into a core and baked in an oven.
When the melting process is complete, molten metal is tapped and poured into a ladle.
At this time, molten metal may be treated by adding alloys and/or other chemicals.
Treated metal is then poured into a mold and allowed to partially cool under carefully
controlled conditions.2 When partially cooled, the castings are placed on a vibrating grid,
and the sand in the mold and core are shaken away from the casting.2
The same five categories of Section 313 chemicals are used as were used for iron
foundries.
Metals and metal compounds are processed as constituents of the steel or added
to form alloys to provide desired properties in the metal casting. Metal compounds may
be manufactured as a byproduct of the process. The metal/metal compounds are pro-
cessed in different proportions than for iron; chromium, nickel, manganese, and copper
are processed most often, but cobalt and molybdenum trioxide also processed.
Aluminum (fume or dust) is manufactured as a byproduct Lead and zinc are processed
at a few steel foundries.
Table 7 presents a summary of Section 313 reported releases and off-site transfers
of metals/metal compounds at steel foundries. Releases may be calculated by similar
22
-------
TABLE 7. SUMMARY OF REPORTED RELEASES OF METALS AND METAL COMPOUNDS
FROM STEEL FOUNDRIES
Section 313
Chemical
Chronlus
i*nroni UN coRepouim
Nickel
Nickel tmyoumte
rwnQAnese
VtanQftnese conpounov
Copper
Copper compounds
Cobalt
Molybdenum trloxlde
Aluminum (fun or
dust)'
Lead
Lead compounds
Zinc (fume or
dust)
Zinc ccnpounds
Number of facilities
reporting usage
(X reporting usage)
92 (69)
30 (22)
77 (57)
19 (14)
67 (SO)
18 (13)
SO (22)
6(4)
12 (9)
6(6)
13 (»)
13 (10)
3 (2)
4 (3)
4(3)
2(1)
Mean release. 1b (X reporting to each media)
Fugitive
455 (93)
318 (63)
224 (69)
62 (63)
• (71)
1.021 (72)
131 (73)
e(67)
61 (75)
48 (75)
67 (62)
94 (46)
168 (100)
1700 (25)
87 (25)
1 (SO)
Stack
230 (68)
291 (63)
171 (57)
126 (63)
575 (75)
254 (72)
87 (53)
• (67)
39 (58)
196 (50)
145 (8)
995 (54)
128 (67)
250 (25)
103 (50)
0 (0)
Water
275 (10)
58 (17)
66 (5)
88 (16)
155 (10)
360 (17)
176 (10)
1 (17)
250 (8)
0(0)
168 (23)
0(0)
5 (33)
250 (25)
0(0)
0 (0)
Land
38.598 (14)
100.696 (20)
3.219 (12)
0(0)
403,969 (19)
90 (6)
260(7)
0(0)
0(0)
0(0)
750(8)
19.618 (15)
0(0)
0(0)
0(0)
0 (0)
POTWC
159 (16)
100 (20)
122 (19)
22 (16)
100 (16)
39 (22)
91 (40)
250 (17)
87 (67)
29 (13)
128 (15)
78 (31)
128 (67)
25 (50)
250 (25)
1 (50)
Off-site transfer
28.129 (64)
40.730 (53)
8.018 (66)
3.721 (58)
82.297 (67)
200.754 (72)
6,329 (57)
1.088 (50)
10,814 (83)
3.488 (38)
1,196 (71)
7,931 (62)
875 (67)
• (75)
2,947 (50)
0 (0)
Total*
25.109 (96)
43.735 (97)
6.293 (95)
2.418 (95)
114,852 (94)
164.231 (89)
3.931 (97)
2.260 (100)
9,158 (100)
1.652 (88)
1.288 (92)
8.480 (100)
923 (100)
e (75)
1.609 (100)
2 (50)
A total of 134 facilities In SICs 3324 and 3325 reported usage of at least one Section 313 chemical above the threshold limits.
Mean release In pounds per year In 1990 for firms reporting releases of this chemical, and percentage of firms reporting usage of this
chemical and releases to this media. Releases to other media Mere Insignificant.
' POTV • Publicly owned treatment works.
The total Includes ell releases and off-site transfers, not just categories sumnarlzed In this table.
Mean value Is not representative because of a very large value at one facility and the small number of facilities.
These chemicals art produced •• by-products.
-------
methods described for iron foundries with the exception that AP-42 Section 7.13 should
be used to determine emission factors.
Chlorinated solvents have the same uses as the ones described in iron foundries.
Table 8 presents a summary of Section 313 reported releases and off-site transfers of
chlorinated solvents at steel foundries.
Acids are otherwise used for the same uses described in iron foundries. Table 9
presents a summary of reported releases and off-site transfers of acids from steel
foundries.
Organic solvents are otherwise used for the same uses described in iron foundries.
Table 10 presents a summary of reported releases and off-site transfers of other solvents
from steel foundries.
Other chemicals have two uses at steel foundries: core making and hydraulic
fluid. These uses are described in the iron foundries section. Table 11 presents a
summary of reported releases and off-site transfers of other chemicals from steel
foundries. If heating is done with other than electric or natural gas, any TRI chemicals
in the fuels should also be considered in threshold and release calculations.
24
-------
TABLE 8. SUMMARY OF REPORTED RELEASES OF CHLORINATED SOLVENTS
FRON STEEL FOUNDRIES
Section 313 Chemical
Freon-113
Dlcnloromethana
Tr 1 chl oroethyl era
Tetrachloroetnylera
Number of facilities
reporting usage
(X reporting usage)
24 (18)
14 (10)
3 (2)
2 (2)
2 (2)
Mean release. Ib (X reporting to each media)
Fugitive
29,886 (96)
21.669 (86)
40,550 (100)
39 (50)
13.848 (100)
Stack
20.736 (29)
36.910 (29)
24.514 (33)
113.335 (50)
0 (0)
Water
11 (6)
0(0)
0(0)
0 (0)
0 (0)
POTM°
0(0)
1.154 (7)
0 (0)
1 (50)
0 (0)
Off -site transfer*1
9.249 (25)
2.249 (29)
0 (0)
29,179 (50)
1.502 (50)
Total"
37.001 (100)
32,140 (93)
48,721 (100)
127,947 (100)
14.598 (100)
* A total of 134 facilities In SICe 3324 and 3325 reported usage of at least one Section 313 chemical above the threshold Units.
Mean release In pounds par year In 1990 for firms reporting releases of this chemical, and percentage of firms reporting usage of
this chemical and releases to this media. Releases to other media were Insignificant.
C POTW • Publicly owned treatment works.
Off-site transfer for recycling was not reportable In 1990; transfer for recycling would be significant for chlorinated
solvents used In degreaslng operations.
The total Includes all releases and off-site transfers, not Just categories sumnarlzed In this table.
-------
TABLE 9. SUMMARY OF REPORTED RELEASES OF ACIDS
FROM STEEL FOUNDRIES
Section 313 Chemical
Sulfurlc acid
Hydrochloric acid
Phosphoric acid
Nitric acid
* A total of 134
MBBH pal MM In
Number of facilities
reporting usage
(X reporting usage)
12 (9)
6(4)
S (4)
2 (1)
facilities In SICs 3324 and
i anumfa Mr v««r In 1990 fai
Mean release. Ib (X reporting to each media)
Fugitive
128 (17)
87 (SO)
128 (40)
5 (SO)
3325 reported
• firm r«Bortl
Stack
128 (17)
128 (33)
553 (40)
5 (50)
usage of at least
Ina T«IMBM af Mil
Water
0(0)
0(0)
S (25)
0 (0)
one Section
)• ehmleal.
Land
0 (0)
0 (0)
5 (20)
0 (0)
POTWC
0(0)
0(0)
250 (20)
5 (50)
313 chemical above
•ml MremtBM of 1
Off -site transfer
21.665 (17)
72.751 (33)
21.914 (60)
16.844 (100)
the threshold limits.
Firms mart Ira UMM af
Totald
7.373 (50)
36.505 (67)
22.452 (60)
16.852 (100)
this chemical and releases to this media. Releases to other media Mere Insignificant.
C POTV • Publicly owned treatment works.
The total Includes all releases and off-site transfers, not Just categories suimarlied In this table.
-------
TABLE 10. SUMMARY OF REPORTED RELEASES OF ORGANIC SOLVENTS
FROM STEEL FOUNDRIES
Section 313 Chemical
Itethanol
Xylene (mixed
learners)
Toluene
Methyl ethyl Intone
Number of facilities
reporting usage
(X reporting usage)
9(7)
4(3)
3 (2)
2 (1)
Mean release. 1b (X
Fugitive
66,688 (100)
67,277 (100)
1.822 (100)
27.705 (100)
Stack
128 (22)
15.230 (50)
3.498 (67)
5.698 (50)
Water
0(0)
250 (33)
250 (50)
0(0)
b
reporting to each media)
POTWC
0(0)
250 (25)
250 (33)
0 (0)
Off-site transfer*
15.836 (11)
250 (25)
625 (67)
0 (0)
Total"
70.236 (100)
75.142 (100)
4.737 (100)
30.554 (100)
* A total of 134 facilities In SICs 3324 and 3325 reported usage of at least one Section 313 chemical above the threshold limits.
Mean release In pounds per year In 1990 for firms reporting releases of this chemical, and percentage of firms reporting usage of
this chemical releases to this media. Releases to other media were Insignificant.
C POTW - Publicly owned treatment works.
Off-site transfer for recycling or fuel blending was not report able In 1990; transfer off site of purge or cleaning solvent for
these purposes will be reported In 1991.
* The total Includes all releases and off-site transfers, not just categories summrlied In this table.
-------
TABLE 11. SUMMARY OF REPORTED RELEASES OF OTHER CHEMICALS
FROM STEEL FOUNDRIES
Section 313
Chanlcal
Phenol
Nethylerablt
(phenyl Isocyanate)
Formaldehyde
Ethylene glycol
Use
Core-making
Core-Mklng
Core-making
Hydraulic
fluid
Hunter of facilities
reporting usage
(X reporting usage)
23 (17)
7 (5)
4 (3)
7 (5)
Mean release. Ib (X reporting to each media)
Fugitive
9.115 (91)
10,185 (86)
15.983 (75)
9.703 (71)
Stack
2.134 (52)
250 (14)
2.735 (75)
0(0)
Water
214 (IB)
0 (0)
0 (0)
0(0)
Land
3.407 (22)
0 (0)
2.800 (25)
0 (0)
POTWC
250 (9)
0(0)
750 (25)
60.000 (14)
Off -site transfer
4.940 (91)
963 (57)
1.000 (25)
19.000 (14)
Total d
12.803 (100)
19.868 (86)
15.176 (100)
21.553 (86)
A total of 134 facilities In SICs 3324 and 3325 reported usage of at least one Section 313 chemical above the threshold Units.
Mean release In pounds per year In 1990 for firms reporting releases of this chemical, and percentage of firms reporting usage of this
chemical releases to this media. Releases to other media were Insignificant.
' POTV • Publicly owned treatment works.
The total Includes all releases and off-site transfers, not just categories summarized In this table.
-------
ALUMINUM FOUNDRIES
Secondary aluminum melting is essentially the process of remelting aluminum, but
the term encompasses the following additional practices.3
Fluxing. This term is applied to any process in which materials are added
to the melt to aid in removal of gases, oxides, or other impurities, but
which do not remain in the final product
Alloying. This term is applied to any process in which materials are added
to give desired properties to the product and which become part of the
final product
Degassing. This includes any process used to reduce or eliminate dissolved
gases.
"Demagging." This includes any process used to reduce the magnesium
content of the alloy.
These terms are often used vaguely and overlap to a great extent. For example,
degassing and demagging are usually accomplished by means of fluxes. The use of zinc
chloride and zinc fluoride fluxes increases the zinc content of aluminum aLoys.3
Aluminum for secondary melting comes from three main sources:
• Aluminum pigs. These may be primary metal but may also be secondary
aluminum produced by a large secondary smelter to meet standard alloy
specifications.
Foundry returns. These include gates, risers, runners, spruces, and rejected
castings. In foundries producing sand mold castings, foundry returns may
amount to 40 to 60 percent of the metal poured.
• Scrap. This category includes aluminum contaminated with oil, grease,
paint, rubber, plastics, and other metals such as iron, magnesium, zinc, and
brass.
The melting of dean aluminum pigs and foundry returns without the use of fluxes does
not result in the discharge of significant quantities of air contaminants. The melting of
aluminum scrap, however, frequently requires air pollution control equipment to prevent
the discharge of excessive air contaminants.3
29
-------
Crucible or pot-type furnaces are used extensively to melt small quantities (up to
1,000 pounds) of aluminum. Almost all crucibles are made of sib'con carbide or similar
refractory material. Small crucibles are lifted out of the furnace and used as ladles to
pour molds. The larger crucibles are usually used with tilting-type furnaces. For die
casting, molten metal is ladled out with a small hand ladle or it can be fed automatically
to the die-casting machine.3
The reverberatory furnace is commonly used for medium- and large-capacity
heating operations. Small reverberatory furnaces up to approximately 3,000-pound
capacity may be of the tilting type. Sometimes a double-hearth construction is
employed in furnaces of 1,000- to 3,000-pound holding capacity.3
Reverberatory furnaces of 20- to 50-ton holding capacity are common. Usually
one heat is produced in a 24-hour period; however, the time required per heat in
different shops varies from 4 hours to as much as 72 hours.3
Electric induction furnaces are becoming increasingly common for both melting
and holding aluminum in spite of higher installation and operating costs. Some of the
advantages they offer over other furnaces are higher efficiency, closer temperature con-
trol, no contaminants from products of combustion, less oxidation, and improved homo-
geneity of metal. Electric resistance heating is sometimes used for holding but rarely for
melting furnaces. Most electric furnaces for aluminum melting are relatively small,
although some holding furnaces have capacities up to about 15 tons.3
The types of fluxing generally fall into four main categories:
Cover fluxes. These fluxes are used to cover a metal surface to prevent
further oxidation and are usually liquid at the melting point of aluminum.
Some of these are also effective in preventing gas absorption.
• Solvent fluxes. These fluxes generally cause impurities and oxides to float
on top of the melt in the form of a dross that can be easily skimmed off.
• Degassing fluxes. These fluxes are used to purge the melt of dissolvent
gases. The dissolved gas is assumed to be hydrogen, but other gases are
also highly soluble in aluminum. The solubility of gases in molten
aluminum increases with temperature. The gases most soluble in molten
aluminum, in decreasing order of solubility, are hydrogen, methane, carbon
30
-------
dioxide, sulfur dioxide, oxygen, air, and carbon monoxide. The solubility of
hydrogen is 6 to 7 times as great as that of methane and over 10 times that
of carbon dioxide. Elimination of hydrogen gas in aluminum is a major
problem.
• Magnesium-reducing fluxes. These fluxes are used to reduce magnesium
content of the alloy (known as demagging).
The quantity and type of fluxing depend on the type of furnace, materials being
melted, and specifications of the final product. Chlorine gas, used for reducing the
magnesium content of the alloy (demagging) is easier to regulate than fluxes used for
that purpose.3
Only four of the five categories of Section 313 chemicals that were used for iron
foundries are used at aluminum foundries. No organic solvents are used at aluminum
foundries because aluminum castings are not typically painted or coated.
Metals and metal compounds are processed as constituents of the aluminum or
added to form alloys to provide desired properties in aluminum casting. Metal
"compounds and aluminum (fume or dust) may be formed as a by-product of the process.
The metal/metal compounds processed are different than those at iron and steel
foundries. Copper, zinc, and nickel are the primary metals processed with manganese,
lead, and chromium processed to a lesser extent.
TRI reported releases to air are similar to those for iron and steel foundries;
however, TRI reported releases to land and off-site transfers are lower for aluminum
foundries than for iron and steel foundries. Table 12 presents a summary of Section 313
reported releases of metal/ metal compounds at aluminum foundries. Releases may be
calculated by similar methods described for iron foundries with the exception that AP-42
Section 7.8 should be used for emission factors.
Chlorinated solvents are otherwise used for the same uses described in iron foun-
dries. Table 13 presents a summary of Section 313 reported releases and off-site trans-
fers of chlorinated solvents at aluminum foundries.
31
-------
TABLE 12. SUMMARY OF REPORTED RELEASES OF METALS AND METAL COMPOUNDS
FROM ALUMINUM FOUNDRIES
Section 313
Chemical
Copper
Copper compounds
Aluminum (fume or
dust)"
Zinc (fume or
dust)*
Nickel
Nickel compounds
Manganese
Manganese compounds
Lead
Chromium
Chromium compounds
Number of facilities
reporting usage
(X reporting usage)
93 (62)
IS (10)
46 (31)
18 (12)
15 (10)
20 (13)
3(2)
13(9)
3(2)
11 (7)
5(3)
3(2)
Mean release, 1b (X reporting to each media)
Fugitive
856 (56)
162 (33)
4.462 (56)
662 (56)
110 (47)
171 (60)
5(33)
450 (62)
250 (33)
479 (64)
18 (60)
1225 (66)
Stack
341 (59)
722 (53)
9,403 (78)
1.316 (78)
345 (67)
228 (45)
168 (100)
131 (62)
250 (67)
254 (73)
128 (40)
2.200 (33)
Water
137 (6)
5(7)
1,226 (11)
0(0)
69 (27)
250 (5)
250 (1)
50(8)
0(0)
0(0)
26 (40)
0(0)
Land
308 (8)
5(7)
7,308 (17)
250 (6)
5(7)
250 (5)
0(0)
625 (15)
0(0)
0(0)
0(0)
f (33)
WTWe
92 (18)
569 (40)
254 (22)
4(17)
302 (60)
64 (20)
0(0)
123 (15)
489 (33)
250(9)
7(20)
126 (33)
Off -site transfer
1.070 (38)
899 (47)
59,542 (43)
4,739 (28)
380 (73)
825 (35)
750 (33)
649 (38)
398 (67)
544 (45)
135 (40)
45 (33)
Total d
1.305 (87)
1,165 (93)
38.921 (96)
2.883 (94)
760 (100)
591 (90)
503 (100)
726 (100)
845 (100)
836 (91)
127 (100)
f (100)
*A total of 149 facilities In SICs 3363 and 3365 reported usage of at least one Section 313 chemical above the threshold limits.
Mean release In pounds per year In 1990 for firm reporting releases of this chemical, and percentage of firms reporting usage of this
chemical and releases to this media. Releases to other media were Insignificant.
C POTV • Publicly owned treatment works.
The total Includes all releases and off-site transfers, not Just categories suraurlzed In this table.
* These chemicals are produced as by-products.
Mean value Is not representative because of a very large value at one facility and the small number of facilities.
-------
TABLE 13. SUMMARY OF REPORTED RELEASES OF CHLORINATED SOLVENTS
FROM ALUMINUM FOUNDRIES
Mean release. 1b (X reporting to each media)
reporting usage
Section 313 Chemical (X reporting usage) Fugitive
1,1.1-THchloroethane
Trlchloroethylene
Freon-113
Tetrachloroethylene
13 (9)
8 (4)
5 (3)
4 (3)
3 (2)
14.950 (92)
9.431 (83)
9.611 (100)
13.559 (100)
2.875 (87)
Stack
17.375 (31)
35.782 (83)
16.680 (40)
16.142 (25)
25.667 (100)
Water
0(0)
223 (25)
0(0)
0 (0)
0 (0)
POTW0 Off-site transfer*1
5 (8)
5(17)
0 (0)
0 (0)
0 (0)
250 (8)
7.976 (83)
3.775 (60)
1.680 (50)
0 (0)
Total*
19.166 (100)
44.362 (100)
18.548 (100)
18.435 (100)
27.583 (100)
* A total of 149 facilities In SICs 3363 and 3365 reported usage of at least one Section 313 chemical above the threshold limits.
Mean release In pounds per year In 1990 for firms reporting releases of this chemical, and percentage of firms reporting usage of
this chemical and releases to this media. Releases to other media Mere Insignificant.
6 POTV • Publicly owned treatment works.
Off-site transfer for recycling was not reportable In 1990; transfer for recycling would be significant for chlorinated
solvents used In degreaslng operations.
* The total Includes all releases and off-site transfers, not just categories summarized In this table.
-------
Acids are otherwise used for the uses described in iron foundries. Table 14
presents a summary of reported releases and off-site transfers of acids from aluminum
foundries.
Other chemicals are also used at aluminum foundries. As in iron steel foundry
use, phenol and methylenebis (phenylisocyanate) are used in core making, diethano-
lamine is used in a product to detect cracks in castings, and ethylene glycol is used as a
hydraulic fluid. Unlike iron and steel, foundry use, chlorine is used in degassing at
aluminum foundries. Table 15 presents a summary of reported releases and off-site
transfers of other chemicals at aluminum foundries.
34
-------
TABLE 14. SUMMARY OF REPORTED RELEASES OF ACIDS
FROM ALUMINUM FOUNDRIES
Section 313 Chemical
SulfuHc acid
Hydrochloric acid
Nitric acid
Umber of facilities
reporting usage
(X reporting usage)
20 (13)
11 (7)
4 (3)
Mean release.
Fugitive
270 (SO)
314 (73)
338 (75)
Stack
159 (40)
8.500 (9)
376 (75)
Water
250
(8)
5(14)
5 (33)
1b (X reporting to each «ed1a)b
Land
0(0)
750 (18)
0 (0)
pom"
500 (10)
0(0)
0 (0)
Off-site transfer
28.048 (10)
0(0)
12.329 (25)
Totald
4.717 (65
1.391 (82)
3.619 (100)
a A total of 149 facilities In SICs 3363 and 3365 reported usage of at least one Section 313 chemical above the threshold limits.
Mean release In pounds per year In 1990 for firms reporting releases of this chemical, and percentage of firms reporting usage of
this chemical and releases to this media. Releases to other media were Insignificant. A pH release above 6 la not reportable
under Section 313.
C POIV • Publicly owned treatment works.
The total Includes ell releases and off-site transfers, not just categories sunsarlzed In this table.
-------
TABLE 15. SUMMARY OF REPORTED RELEASES OF OTHER CHEMICALS
FROM ALUMINUM FOUNDRIES
Section 313
Chemical
Ethyl era glycol
Chlorine
•M «J
rnaflOl
Nethylenebls
(phenyl Isoeyante)
Dtethanolamlne
Use
Hydraulic
fluid
Degassing
Core-making
Core-making
Coating
flnlaher
Hunter of facilities
reporting uaage
(X reporting usage)
21 («)
14 (9)
8(4)
5(3)
2(1)
Nean release, Ib (X reporting to each media)
Fugitive
2,222 (38)
327 (93)
1.827 (100)
625 (80)
0(0)
Stack
250 (5)
394 (50)
2.213 (67)
750 (60)
0(0)
Water
5.125 (10)
385 (14)
250 (17)
0(0)
250 (50)
Land
17.085 (15)
0(0)
1.052 (33)
0 (0)
8.759 (50)
POTV.C
20.020 (38)
250 (7)
5 (17)
0(0)
16.464 (50)
Off-site transfer
17.709 (57)
e(14)
2.096 (33)
61,467 (60)
8.759 (50)
Total*1
22.610 (95)
e (100)
4.394 (100)
47.268 (80)
17.117 (100)
A total of 149 facilities In SICs 3363 and 3365 reported usage of at least one Section 313 chemical above the threshold limits.
D
Mean release In pounds per year In 1990 for firms reporting releases of this chemical, and percentage of firms reporting usage of this chemical
5\ and releases to this media. Releases to other media Here Insignificant.
C POTW • Publicly owned treatment works.
The total Includes ell releases and off-site transfers, not just categories sumarlied In this table.
"Although two firms reported large off-site transfers of chlorine (mean 14,000 Ib), this would not be typical and may be an error.
-------
COPPER FOUNDRIES
This section discusses copper foundries (SIC 3366). Brass and bronze foundries
should also report under SIC 3366. However, it is clear from many company names that
many brass and bronze foundries report to TRI under SIC 3669 and processes such as
the lost wax process used at these foundries are discussed in the next section on Other
Foundries. Copper die casting is contained in SIC 3364. Only three of the five cate-
gories of Section 313 chemicals used at iron foundries are used at copper foundries.
Although coatings may be applied to copper, brass, or bronze to prevent oxidation, only
2 facilities of the 80 facilities (25%) who reported to TRI in SIC 3366 reported use of
methyl ethyl ketone and toluene. No other solvents were reported in TRI in SIC 3366.
If coatings are applied, then it is probable that the threshold limit for otherwise used
chemicals (10,000 Ib) would be exceeded for at least one solvent Also no "other chemi-
cals" including core making chemicals, were reported under SIC 3366 in the TRI data-
base.
Brass and bronze may be cast at precision investment foundries. This process is
discussed in the next section on Other Foundries.
Metals and metal compounds are processed as constituents of the copper or are
added to form alloys. Because of the high boiling temperature of copper (2S67°C), lower
boiling metals (BP Mn 1,962°C, Pb 1,740°C, Zn 907°C) will be released in greater per-
centages than their concentration in the melt The metal/metal compounds processed in
copper foundries are different from those in iron and steel; copper, lead, nickel, and
manganese are the primary metals/metal compounds, but zinc (fume or dust) and zinc
compounds are also processed.
Releases to air are similar to those for iron and steel foundries; however, off-site
transfers are much lower for copper foundries than for iron and steel foundries. Table
16 presents a summary of Section 313 reported releases of metals/metal compounds at
copper foundries. Releases may be calculated by similar methods described for iron
foundries with the exception that AP-42 Section 7.9 should be used for emission factors.
37
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TABLE 16. SUMMARY OF REPORTED RELEASES OF METALS AND METAL COMPOUNDS
FROM COPPER FOUNDRIES
Section 313
Chemical
Copper
Copper
Lead
Nickel
Nickel
Manganese
Manganese
Zinc (fume or
dust)
£inC lUneJJUUIIU*
Number of facilities
reporting usage
(X reporting usage)
75 (94)
8(7)
26 (33)
4(5)
IB (23)
3(4)
9(11)
3 (4)
7 (9)
5(6)
Mean release. Ib (X reporting to each media)
Fugitive
1.311 (67)
1.567 (50)
282 (77)
0(0)
145 (61)
0(0)
271 (67)
250 (33)
152 (86)
500 (40)
Stack
649 (56)
10.321 (83)
1.290 (65)
765 (50)
180 (39)
183 (67)
152 (56)
5(67)
984 (71)
2.681 (100)
Water
250 (4)
250 (17)
250 (12)
0(0)
5(6)
250 (33)
250 (11)
250 (33)
750 (14)
250 (20)
Land
17.231 (12)
0 (0)
38.165 (4)
0(0)
128 (11)
0(0)
5 (11)
0 (0)
114.494 (14)
1.400 (20)
WTW6
161 (17)
625 (50)
250 (8)
67 (75)
65 (22)
620 (33)
84 (33)
0(0)
0 (0)
225 (60)
Off-site transfer
3.565 (49)
• (67)
3.378 (50)
• (75)
513 (56)
27.754 (67)
H (44)
875 (67)
6.878 (28)
81,167 (100)
Total**
5.627 (91)
e (83)
4.435 (96)
• (75)
567 (83)
28.372 (67)
367 (89)
753 (100)
e (100)
84,514
(100)
*A total of 80 facilities In SICs 3366 reported usage of at least one Section 313 chemical above the threshold limits.
Mean release In pounds per year In 1990 for firms reporting releases of this chemical, and percentage of firms reporting usage of
this chemical and releases to this media. Releases to other media were Insignificant.
C POTV • Publicly owned treatment works.
The total Includes all releases and off-site transfers, not just categories sumrarlzed In this table.
8 Mean value Is not representative because of a very large value at one facility and the small number of facilities.
These chemicals are produced as by-products.
-------
Chlorinated solvents are used for some of the same purposes as in iron foundries,
but to a much lower degree. Most copper foundries do not use chlorinated solvents
above the threshold quantities. Table 17 presents a summary of reported releases and
off-site transfers of chlorinated solvents from copper foundries.
Acids are otherwise used for the uses described in iron foundries. In addition,
bronze that will not be exposed to extremes of weather can be protected from corrosion
by warming it to slightly over 212°F (KXTC) in an oxygen atmosphere. A thin layer of
oxide or patina forms to prevent further oxidation. A patina may be formed on art ob-
jects by exposure first to acid fumes and then drying as above. While still warm, the
object can be further protected by a spray of wax in a solvent Table 18 presents a sum-
mary of releases and off-site transfer of acids at copper foundries.
39
-------
TABLE 17. SUMMARY OF REPORTED RELEASES OF CHLORINATED SOLVENTS
FROM COPPER FOUNDRIES
Number of faclllt,
reporting usage
Section 313 Chemical (X reporting usagi
1.1.1-THehloroethane
Freon-113
6(8)
2(3)
es
t) Fugitive
153.447 (100)
15.319 (100)
Mean release. 1b (X reporting to
Stack
19.238 (33)
0(0)
Water
5(13)
0(0)
POTWC
108 (33)
0(0)
each media)
Off -site transfer11
400 (33)
16.20 (100)
Total*
160.029 (100)
16.99 (100)
A total of 80 facilities In SIC 3366 reported usage of at least one Section 313 chemical above the threshold limits.
Mean release In pounds per year In 1990 for firms reporting releases of this chemical, and percentage of firms reporting usage of
this chemical and releases to this media. Releases to other media Mere Insignificant.
POTW • Publicly owned treatment works.
Off-site transfer for recycling was not reportable In 1990; transfer for recycling would be significant for chlorinated
solvents used In degreaslng operations.
The total Includes all releases and off-site transfers, not just categories summarized In this table.
-------
TABLE 18. SUMMARY OF REPORTED RELEASES OF ACIDS
FROM COPPER FOUNDRIES
Section 313 Chemical
Sul f uric acid
Phosphoric acid
Hydrochloric acid
Nitric acid
Nutter of facilities
reporting usage
(X reporting usage)
7 (9)
3 (4)
1 (1)
1 (1)
Mean release. 1b (X reporting to each media)
Fugitive
351 (57)
87 (100)
0(0)
0 (0)
Stack
250 (14)
168 (100)
0(0)
0 (0)
Water
11.920 (11)
5(50)
0(0)
0 (0)
Land
42.750 (14)
5 (33)
0 (0)
0 (0)
POTWC
11.920 (14)
0(0)
28.000 (100)
0 (0)
Off -site transfer
21.693 (57)
40.366 (67)
0(0)
0 (0)
Total*1
28.619 (71)
27.167 (100)
28.000 (100)
0 (0)
* A total of 80 facilities In SIC 3366 reported usage of at least one Section 313 chemical above the threshold Knits.
Mean release In pounds per year In 1990 for firms reporting releases of this chemical, and percentage of firms reporting usage of
this chemical and releases to this media. Releases to other media Mere Insignificant. pH release above 6 Is not reportable
under Section 313.
POTV • Publicly owned treatment works; sulfurlc acid release Is to water.
The total Includes all releases and off-site transfers, not just categories sunmarlted In this table.
-------
OTHER FOUNDRIES
This category includes nonferrous foundries except copper, aluminum, and all
die-castings. It's clear from company name, however, that many brass and bronze foun-
dries report using SIC 3369. Four of the five categories of Section 313 chemicals used
for iron foundries are used for other foundries. Although coatings may be applied to
silver, brass or bronze castings to prevent oxidation, only one facility per solvent of the
128 facUities, who, reported to TRI in the other foundries category reported the use of
MEK, MIBK, toluene or xylene. If coatings are applied then it is probable that the
threshold limit for otherwise used chemicals (10,000 Ib) would be exceeded for at least
one solvent
Investment foundries may cast bronze, stainless steel and precious metals such as
silver using the lost wax process. Products include sculptures, commemorative medals,
trophies and plaques. Precision investment casting, also known as the are perdue or lost
wax process, is a special process for making castings to very close dimensional tolerances.
The process consists of making a pattern of such materials as wax, plastics, fusible alloy
or frozen mercury. A Suitable molding or investment compound such as ethyl silicate is
cast around the pattern, cured, and the invested pattern melted out to form the finished
mold. After the metal is cast, usually under pressure, the mold is broken and removed
to free the castings, which usually only require the removal of gates for finishing. The
investment casting method has been used to mass produce parts weighing between 5 and
4500 g.
An older but similar process used in statuary founding involves modeling in wax
over a core, and then covering with plaster. The wax is removed by melting, and a metal
shell is cast in its place between the core and the plaster mold. The main advantage of
this procedure is the ability to make intricate shapes without machining while attaining
close dimensional tolerances. Size is a limitation and may range up to 8.cm maximum
dimension with a marinmm 4 cm section in thickness-
Metals and metal compounds are processed as constituents of the metal castings
or are added to form alloys. The metals/metal compounds reported in TRI in
42
-------
descending order of reporting are copper, zinc (fume or dust), lead, nickel, chromium,
aluminum (fume or dust), cobalt, and manganese. The metal compounds, zinc (fume or
dust), and aluminum (fume or dust) may be manufactured as a by-product in the process.
Releases to air are difficult to estimate unless process specifics are known.
Releases are similar to those for aluminum and copper foundries in that off-site transfers
are lower than for iron and steel foundries. Table 19 presents a summary of Section 313
reported releases of metal/metal compounds at other foundries.
Chlorinated solvents are used for the same purposes as in iron foundries. Table
20 presents a summary of Section 313 reported releases of chlorinated solvents at other
foundries.
Acids are otherwise used for the uses described in iron foundries except
phosphoric acid is not used. Table 21 presents a summary of releases and off-site
transfer of acids at other foundries.
Other chemicals are otherwise used at other foundries. Phenol and formaldehyde
are otherwise used as binders in core making, ethylene glycol is otherwise used in
hydraulic fluid, and chlorine is otherwise used in degassing. Table 22 presents a
summary of releases and off-site transfers of other chemicals at other foundries.
43
-------
TABLE 19. SUMMARY OF REPORTED RELEASES OF METALS AND METAL COMPOUNDS
FROM OTHER FOUNDRIES
Section 313
Chemical
Copper
Copper compounds
Zinc Ifume or
dust)*
Zinc compounds
Lead
Lead compounds
Nickel
Nickel compounds
Chromium
Chromium
compounds
Aluminum^ fume
or dust)
Cobalt
-Manganese
Manganese
Number of facilities
reporting usage
(X reporting usage)
74(58)
13 (10)
25 (20)
16 (13)
31 (24)
4(3)
26 (20)
5(4)
15 (12)
4(3)
18 (14)
10(8)
8(6)
1(1)
Mean release. 1b (X reporting to each
Fugitive
349 (65)
230 (62)
1.217 (52)
346 (69)
137 (61)
500 (50)
187 (69)
168 (60)
224 (67)
107 (75)
1,168 (56)
343 (60)
145 (88)
5(100)
Stack
1.172 (64)
472 (100)
f (76)
2.750 (75)
510 (61)
176 (75)
135 (57)
127 (80)
142 (67)
265 (75)
2.006 (78)
183 (50)
75(88)
250 (100)
Water
209(8)
152 (38)
87 (12)
297 (43)
87 (10)
1 (25)
8(8)
188 (80)
1 (7)
5(25)
128 (11)
1(10)
0(0)
0(0)
Land
12.450 (7)
250 (8)
0(0)
250 (13)
11.000 (3)
5(25)
2.162 (4)
0(0)
854 (13)
0(0)
18.845
(11)
1,785 (10)
375 (25)
0(0)
POTW"
152 (26)
66 (46)
250 (16)
116 (38)
136 (19)
5(25)
173 (38)
5(20)
149 (40)
148 (SO)
201 (28)
78 (40)
128 (25)
250 (100)
medta)b
Off-alto transfer
9.512 (34)
5.211 (54)
10.072 (28)
12.208 (50)
1.242 (32)
269 (50)
3.016 (65)
14.537 (80)
3.220 (67)
7.337 (100)
5.841 (33)
4,909 (80)
449 (SO)
255 (100)
Total*1
5.372 (95)
3,536 (100)
f (92)
8,594 (100)
1,472 (81)
519 (100)
2,524 (92)
11.983
(100)
2,747 (93)
7.691 (100)
6,320 (100)
4,927 (90)
542 (100)
760 (100)
aA total of 128 facilities In SICa 3364 and 3369 reported usage of at least one Section 313 chemical above the threshold limits.
Mean release In pounds per year In 1990 for firms reporting releases of this chemical, and percentage of firms reporting usage of this
chemical and releases to this media. Releases to other media were Insignificant.
c POTO • Publicly owned treatment works.
The total Includes all releases and off-site transfers not just categories summarized In this table.
* These chemicals are produced as by-products.
Mean valiwuls not representative because of a very large value at one facility and the small number of facilities.
-------
TABLE 20. SUMMARY OF REPORTED RELEASES OF CHLORINATED SOLVENTS
FROM OTHER FOUNDRIES
Section 313 Chemical
1.1.1-Trlchloroetham
Freon-113
Trlehloroathylene
Tetrachloroethylene
Olchloromethane
•.inter of facilities
reporting usage
(X reporting usage)
16 (13)
• (6)
8 (6)
6 (5)
2 (2)
Mean release. Ib (X reporting
Fugitive
17.280 (81)
20.435 (100)
11.848 (75)
f (50)
753 (100)
Stack
28.137 (69)
4.783 (25)
25.903 (75)
28.672 (83)
8.700 (100)
Water
0 (0)
0(0)
0(0)
0 (0)
0(0)
POTW*
87 (19)
0(0)
0(0)
4« (17)
0 (0)
to each nedta)b
Off-site transfer*
2.317 (25)
1.680 (25)
7.908 (25)
1.903 (17)
9.400 (50)
Total*
33.979 (100)
22.051 (100)
30.290 (100)
51.932 (100)
14.153 (100)
A total of 128 facilities In SICs 3364 and 3369 reported usage of at least one Section 313 chemical above the threshold limits.
b
Mean release In pounds per year In 1990 for firms reporting releases of this chemical, and percentage of firms reporting usage of
this chemical and releases to this media. Releases to other media were Insignificant.
6 POTW • Publicly owned treatment works.
Off-site transfer for recycling was not reportable In 1990; transfer for recycling would be significant for chlorinated
solvents used In degreaslng operations.
8 Ttw total Includes all releases and off-site transfers, not just categories sumarlzed In this table.
. Mean value Is not representative because of a very large value at one facility and the small number of facilities.
-------
TABLE 21. SUMMARY OF REPORTED RELEASES OF ACIDS
FROM OTHER FOUNDRIES
Section 313 Chemical
Sulfurle acid
Hydrochloric acid
Nitric acid
Phosphoric AC id
Number of fadings
reporting usage
(X reporting usage)
19 (IS)
13 (10)
12 (9)
1 (1)
Mean release. Ib (X reporting to each
Fugitive
1« (74)
133 (77)
530 (75)
250 (100)
Stack
118 (63)
316 (85)
1.030 (58)
250 (100)
Hater
0(0)
5(10)
0(0)
0 (0)
Land
0(0)
0 (0)
4.200 (8)
0 (0)
POTVC
5(5)
1.937 (23)
378 (16)
5 (100)
media)"
Off-site transfer
21.574 (16)
13.000 (8)
15.098 (42)
7.600 (100)
Total*1
4,010 (89)
1.968 (92)
7.702 (100)
8.105 (100)
* A total of 128 facilities In SICs 3364 and 3369 reported usage of at least one Section 313 chemical above the threshold limits.
b
Mean release In pounds per year In 1990 for firms reporting releases of this chemical, and percentage of firms reporting usage of
this chemical and releases to this media. Releases to other media Mere Insignificant.
C POTV • Publicly owned treatment works.
0
The total Includes all releases and off-site transfers, not just categories sumac tied In this table.
-------
TABLE 22. SUMMARY OF REPORTED RELEASES OF OTHER CHEMICALS
FROM OTHER FOUNDRIES
Section 313
Chemical
Ethyl me glycol
Chlorine
Phenol
Fonnl OBriyoB
Use
Hydraulic
fluid
Degassing
Core*«akliig
Core-asking
Number of facilities
reporting usage
(X reporting usage)
9(7)
5(4)
2 (2)
1 (1)
Mean release. 16 (X reporting to each ndla)
Fugitive
1.301 (44)
4.337 (100)
945 (100)
2.350 (100)
Stack
168 (33)
557 (60)
0 (0)
0(0)
Water
0(0)
5(20)
0 (0)
0 (0)
Land
0(0)
0(0)
250 (50)
0 (0)
POTV°
16.921 (67)
0(0)
5 (50)
0 (0)
Off -site transfer
12.590 (56)
750 (20)
0 (0)
0 (0)
Total*1
21.274 (89)
4.822 (100)
1.073 (100)
2.350 (100)
A total of 128 facilities In SICa 3364 and 3369 reported usage of at least one Section 313 chemical above the threshold limits.
Nean release In pounds per year In 1990 for firms reporting releases of this chemical and percentage of firms reporting usage of this chemical
and releases to this media. Releases to other media were Insignificant.
Publicly owned treatment works.
The total Includes ell releases end off-site transfers, not Just categories summarlied In this table.
-------
USE OF REGULATIONS TO ESTIMATE RELEASE OF SECTION 313 CHEMICALS
Two regulations that may assist in emission estimations of Section 313 chemicals
are the effluent guidelines and standards governing water releases and the paniculate
emission standards governing air releases. Because the Section 313 chemical
concentration is highly variable between facilities, neither set of regulations is directly
applicable. The regulations may require monitoring or other testing, however, that may
be used to estimate releases of the Section 313 chemicals.
Water Releases
The EPA Effluent Guidelines and Standards for Metal Molding and Casting (40
CFR 464; SO FR 45247, October 30, 1985; corrected by 51 FR 21760, June 16, 1986)
provide effluent limits for foundries. The guidelines are detailed and specific to the type
and size of foundry, process, and type of discharge. The specific guideline for the
foundry type in question should be consulted to estimate the maximum allowable dis-
charge. The guidelines are applicable to aluminum casting, copper casting, ferrous cast-
ing, and zinc casting. There are limits for discharged copper, lead, zinc, total phenols, oil
and grease, total suspended solids, and pH. The limits are separately applied by process
including 1) casting cleaning operations, 2) casting quench operations, 3) dust collection
scrubber operations, 4) grinding scrubber operations, 5) investment casting,
6) melting furnace scrubber operations, 7) mold cooling operations, 8) slag quench
operations and 9) wet sand reclamation operations. Separate standards are established
for best available technology economically achievable, best practicable control technology
currently available, new source performance standards, and pretreatment standards for
new sources. Standards are also different based on the size of the foundry (based on
tons of metal poured) and the type of discharge (continuous or noncontinuous).
Although these standards cannot be used directly to estimate releases of Section
313 chemicals, they can be used as a pointer as to what to look for in permit or monitor-
ing records. The pH of the wastewater discharge can be used to determine releases for
acids used at the facility if only one acid is present in the discharge. Also, regulatory
48
-------
standards for copper, lead, and zinc can be used as the upper limits of the waste dis-
charge. Measurements of these metals in the wastewater made by the facility to comply
with the standards can be used along with the discharge quantities to calculate water
releases of metals/metal compounds.
Air Releases
State and local air regulations requiring installation and operation of pollution
controls on ferrous foundries vary widely both from state to state and within states. The
enactment of an emission limit at a foundry is influenced by factors such as foundry
location, type of process, foundry size, date of startup, available legal structure, and
previous experience with the public, the foundry industry, and the court systems.6
The four general types of air regulations enacted to control foundry process emis-
sions are mass emission, visible emission, fugitive emission, and nuisance-related regula-
tions. Other important regulations are the malfunction regulation operation and main-
tenance (O&M) regulations, and operating permit regulations. These regulations may be
used individually or in combination to ensure appropriate control of foundry emissions.6
Three major types of mass emissions regulations are: process weight regulation
which limits the total mass of hourly emissions based on the hourly raw material input;
concentration regulation, which limits the mass of paniculate in a specified volume of
undiluted gas; and removal efficiency regulation which specifies the efficiency that must
be attained by the control device on a foundry process.6
Visible emissions (VE) regulations generally limit the opacity of the emissions
plume. (Opacity is the degree to which the plume limits an observer's view of the
background.) Unlike mass emissions regulations, VE regulations cannot be used to limit
precisely the quantities of particulate emitted to the atmosphere.6
Fugitive emissions regulations involve no specific, quantitative standards; rather,
they invite the discretion of the responsible agency official to determine the levels of
49
-------
Nuisance-related regulations include: a general proscription against emissions
that harm persons or property; a proscription against air pollution that causes a nuisance;
and regulations that proscribe air-pollution-causing odors.6
Although air regulations may be used in conjunction with a paniculate concentra-
tion estimate of a Section 313 metal/metal compound in order to estimate releases, this
approach may not necessarily provide the best estimate. The amount of particulates cap-
tured by control devices and control efficiency may also be used to estimate paniculate
release. Concentration of Section 313 chemicals in captured paniculate must be ad-
justed, however, to account for low-boiling metals that may be released in higher con-
centrations.
SO
-------
NONREPORTING FACILITIES
Nonreporting facilities may be identified by comparing lists of facilities in the
following Standard Industrial Classifications (SICs) having more than 10 employees with
those facilities that have reported under Section 313.
Iron foundries - SICs 3321 and 3322
Steel foundries - SICs 3324 and 3325
Aluminum foundries • SICs 3363 and 3365
Copper foundries - SIC 3366
Other foundries - SICs 3364 and 3369
Most foundries with more than 10 employees probably are processing or otherwise using
at least one Section 313 chemical in excess of threshold values. For example, iron and
steel foundries likely are processing a Section 313 metal in iron or steel that is in excess
of 25,000 Ib per year. Most nonferrous foundries probably are also processing more than
25,000 Ib per year of a Section 313 metal. Foundries may also otherwise use an acid or
core binder in excess of the 10,000-lb threshold.
Sources of information on facilities in the various foundry SICs presented by
employment class are included in County Business Patterns (for number of facilities),
published by the U.S. Department of Commerce.7 Another source of information is
Dunn and Bradstreet (D&B), which provides lists of companies by SIC and employment
size category.8 Table 22 presents data on the number of facilities employing more than
10 employees, as reported in County Business Patterns, D&B, and TRI database in 1990.
TABLE 23. NUMBER OF FACILITIES WITH MORE THAN TEN EMPLOYEES
Foundry type
SICs
TRI 1990
County Business
Patterns7 (1989)
D&B 1992
Iron
Steel
Aluminum
Copper
Other
3321,3322
3324,3325
3363,3365
3366
3364.3369
197
134
149
80
128
584
326
612
203
243
464
252
617
196
397
51
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A review of TRI data in 1990 pointed out apparent errors in reporting of whether
the chemical was manufactured, processed, or otherwise used. All metals are processed
at foundries with the exception of aluminum (fume or dust) and zinc (fume or dust).
The fume or dust is manufactured at the foundry. Foundries manufacture or process
metals/metal compounds by changing the metal to a metal compound or visa versa (i.e.t
oxide of the metal). All metals/metal compounds are subject to the 25,000-lb threshold.
All chlorinated solvents, acids, organic solvents, and other chemicals are otherwise used
and subject to the 10,000-lb threshold.
Another error made by a number of foundries was to report the use of isopropyl
alcohol (IPA) and aluminum oxide. IPA is reportable only for facilities who manu-
facture IPA by the strong acid process, and aluminum oxide is reportable only if it is in
the fibrous form. No foundries should report either of these Section 313 chemicals.
52
-------
LIST OF QUESTIONS
The following questions may be helpful in determining if errors were made in
Section 313 reporting for foundries.
Metal/Metal Compounds
Were threshold determinations made for all metals/metal compounds
processed at the facility?
Did the facility determine if it met the reporting thresholds from the
amount released or transferred instead of the amount processed or other-
wise used?
• Were threshold determinations for metal compounds made using the
weight of the compound and not just the metal portion of the compound?
How was air release calculated? Were emission factors or monitoring data
used? What were these factors?
Was Toxicity Characteristic Leaching Procedure (TCLP) used as a measure
of metal concentration in any of the calculations? TCLP measures
leachable metal, not metal content, and thereby should not be used in
calculations.
Chlorinated Solvents
Was a mass balance accounting for all chlorinated solvent usage used to
estimate releases and off-site transfers? (Mass balance is especially useful
for chlorinated solvents because total usage is usually released or trans-
ferred off-site.)
• Was the percentage of chlorinated solvent in the waste solvent accounted
for?
Acids
For vapor degreasing with water separation, was release to water or POTW
estimated?
Was the pH of the release continuously measured as a means of verifying
neutralization? (Monitoring of pH may be required by EPA Effluent
Guidelines)
53
-------
• Was the percentage of acid in the original acid or solution taken into
account in the threshold calculations?
• For brass and bronze foundries, were any acids used to form patinas count-
ed in threshold and release calculations.
Organic Solvents
• How were solvents otherwise used?
How were releases for solvents other than to air estimated?
Did mass balance for solvents account for total usage calculated?
• For brass and bronze foundries, was any coating applied to the casting?
Did these coatings contain TRI solvents in excess of 10,000 Ibs?
Other Chemicals
• Was a threshold determination made for Section 313 chemicals in core
binders such as phenol, methylenebis (phenylisocyanate), formaldehyde, or
ammonium nitrate (solution).
• Was a threshold determination made for usage of ethylene glycol in
hydraulic fluid.
Was a threshold determination made for Section 313 chemicals used for
mold-making, shelling?
54
-------
BIBLIOGRAPHY
1. U.S. Environmental Protection Agency. Technical Guidance for Control of
Industrial Process Fugitive Paniculate Emissions. EPA-450/3-77-010, Research
Triangle Park, N.C. March 1979.
2. U.S. Environmental Protection Agency. Compilation of Air Pollutant Emission
Factors. AP-42. Volume 1 Stationary and Point Source. September 1985 plus
supplements.
3. U.S. Environmental Protection Agency. Air Pollution Engineering Manual,
Second Edition. AP-40. May 1983.
4. U.S. Environmental Protection Agency, Control Technology Center. Emissions
for Iron Foundries - Criteria and Toxic Pollutants. EPA 600/2-90-044. Research
Triangle Park, N.C. August 1990.
5. Kirk Othmer Encyclopedia of Chemical Technology. Third edition. Volume 7
Copper Alloys. John Wiley and Sons. 1979
6. U.S. Environmental Protection Agency. Summary of Factors Affecting
Compliance by Ferrous Foundries, Volume L EPA 340/1-80-020. January 1981.
7. U.S. Department of Commerce, Bureau of Census, County Business Patterns
1989, CBP-89-1 Washington, D.C 1991.
8. Dunn & Bradstreet. International Dunn's Market Identifier in DIALOG data
base File 518. 1992.
9. U.S. Environmental Protection Agency. Electric Arc Furnaces in Ferrous
Foundries - Background Information for Proposed Standards - Draft EIS.
EPA-450/3-88-020a. May 1980.
10. U.S. Environmental Protection Agency. Development Document for Effluent
Limitations Guidelines and Standards for the Metal Molding and Casting
(Foundries) Point Source Category, Volumes I and n, EPA 440/l-82/070b.
November 1982.
11. 40 CFR 464. U.S. Environmental Protection Agency Effluent Guidelines and
Standards for Metal Molding and Casting. Revised June 16,1986.
12. United States Steel The Making, Shaping and Treating of Steel. Tenth Edition.
1985.
55
-------
13. PEDCo Environmental, Inc. International Technology for the Nonferrous
Smelting Industry. Noyes Data Corporatioa 1982.
14. U.S. Environmental Protection Agency. Emission Factors for Iron and Steel
Jouries - Criteria and Toxic Pollutants. EPA 600/2-90-024. Research Triangle
Park, N.C June 1990.
IS. U.S. Environmental Protection Agency. Organic Emissions form Ferrous Metal-
lurgical Industries: Compilation of Emission Factors and Control Technologies.
EPA 600/2-84-003. Research Triangle Park, N.C. January 1984.
16. Baldwin V.H. Jr. Environmental Assessment of Iron Casting. EPA 600/2-80-021.
U.S. Environmental Protection Agency. 1980.
17. Baldwin V.H. Environmental Assessment of Melting, Inoculation, and Pouring.
American Foundrymen's Society. 153: 65-72, 1982.
18. Ambidge, PJ. and PDJE. Biggins. Environmental Problems Arising From the
Use of Chemicals in Molding Materials. BORA Report, 1984.
56
-------
APPENDIX A
SELECTED INFORMATION AND EMISSION FACTORS
FOR IRON FOUNDRIES1
• All information in this section is from Reference 4. Original sources of data are
provided in this reference.
A-l
-------
TABLE Al. SOME FOUNDRY-ATOHOSPHERE CONTANINANTS EVOLVED DURING MOLD AND CORE MAKING, CASTING.
AND COOLING AT IRON FOUNDRIES4
PROCESS
BINDER INGREDIENTS
POTENTIAL EMISSIONS
Shell
Ammonia
Phenol
Hexamethylene tetramlne
Stearates
Fatty adds
Ammonia
Aromatic hydrocarbons (benzene, toluene, xylene, etc.)
Phenol and homologues (phenol, cresol, xylenol, etc.)
Hexamethylene tetramfne
Other amines (e.g. trlmethylamlne)
Hydrogen cyanide
Hot-box
Formaldehyde
Phenol
Urea
Furfuryl alcohol
Aromatic hydrocarbons
Phenol and homologues
Ammonia
Chlorinated hydrocarbons
Hydrogen cyanide
Cold-set
Formaldehyde
Furfuryl alcohol
Phenol
Benzene )
Toluene j depends on catalyst
Xylene )
Sulphur dioxide
Hydrogen sulphide
Nercaptans (e.g. methyl, ethyl mercaptan)
Aromatic hydrocarbons
Phenol and homologues
Furan and homologues (furan, methyl furan, etc.)
Carbonyl sulphide
Carbon d1sulphide
Aromatic sulphur compounds
(Methyl ethyl ketone)
(Acetone - from S02 - gassed system only)
Cold-box
(amlne-
gassed)
Carbon dioxide
Trlethyl amlne
Dimethyl ethyl amlne
MOI
Phenol
Resin solvents (e.g. trlmethyl
benzene, Isophorone)
Naphthalene and homo!ogues
Hydrogen cynlde
Phenol and homologues
Aromatic hydrocarbons
Aniline and homologues (aniline, toluldlne, etc.)
Aliphatic amines
Resin solvents (e.g. trlmethyl benzene, Isophorone)
Isocyanates (e.g. methyl, phenyl Isocyanate)
BenzoquInclines
-------
TABLE A2. INTRODUCTION FURNACE EMISSIONS AT IRON FOUNDRIES4
5
ZnO
A120,
Cr20,
MnO
N10
PbO
CuO
CoO
BaO
Malleable Iron
mg/Mg
5.2 x 10*
2.6 x 10*
1.3 x 10s
1.3 x 10s
1.3 x 102
1.3 x 101
1.3
2.6
2.6
Ductile Iron
mg/Mg
7.8 x 10s
5.2 x 10*
2.0 x 10s
1.3 x 10s
1.3 x 102
1.3 x 101
2.6
2.6
2.6
-------
TABLE A3. ORGANIC EMISSIONS FROM IRON FOUNDRIES, ng/Hg IRON PRODUCED4
Aliphatic Hydrocarbons
Hal operated Hydrocarbons
Aromatic Hydrocarbons
Fused Aranattcs
(>216 MO
Halogens ted Aronatlcs
Heterocycllc N Compounds
Heterocycllc S Conpounds
Alcohols
Phenols
Ketones
Anlnes
Slllcones
Heterocycllc 0 Conpounds
Nitroaromattcs
Ethers
Aldehydes
Phosphates
Nltrlles
Alkyl S Conpounds
Sulfonlc Acids
Sulf oxides
Amides
Carboxyllc Acids
Esters
Haloallphatlcs
Electric Arc
Furnaces
4.94
4.94
3.41
3.41
0.12
0.12
0.40
0.12
0.84
0.40
0.37
1.63
0.00
0.02
0.00
0.82
0.00
0.12
0.12
0.12
0.12
0.40
0.12
Cupola
1.92
1.92
1.70
1.70
0.16
0.16
0.14
0.14
1.51
0.14
0.43
1.01
0.11
1.10
0.11
0.16
0.11
0.14
0.14
0.14
0.14
0.14
0.89
Inoculation
0.08
0.08
0.19
0.05
0.01
0.01
0.01
0.06
0.01
0.01
0.18
0.00
0.05
0.01
0.01
0.00
0.01
0.01
0.01
0.01
0.01
0.01
0.02
Pouring
0.78
0.78
0.56
0.56
0.14
0.14
0.26
0.05
0.42
0.31
0.07
0.47
0.03
0.20
0.03
0.06
0.03
0.08
0.06
0.05
0.09
0.26
0.22
Green
Sand
Shakeout
0.39
1'.34
0.13
0.56
0.05
0.31
0.31
0.05
0.31
0.05
0.01
0.05
0.05
0.01
0.03
0.03
0.23
0.25
0.15
0.12
A-4
-------
TABLE A4. INORGANIC EHISSIONS FROM IRON FOUNDRIES, mg/Hg IRON PRODUCED4
Element
Ag
Al
As
Ba
Be
Cd
Co
Cr
Cu
Hg
fc *
Nn
N1
Pb
Se
Th
Zn
Electric Arc
Cupola Furnaces Inoculation
8.7
55
26.1 7.3 - 26.8
55
0.02
1,654 1.5
0.1
97 4.0
850 11.7
36 22
56
125,000 65 35
0.31
5 x 10* - 323 56
5.5 x 10'
2.6 x 10*
5.8
56
Pouring
1.0
>66
0.1
65
0.04
0.8
0.35
>66
14.7
11
>66
>66
25
11
0.1
1.1
>66
-------
TABLE AS. TOXIC POLLUTANT EMISSION FACTORS FOR IRON FOUNDRIES4
Type of Furnace
Pollutant
Emission Factor, mg/Hg
Cupola
Electlrc Arc Furnace
halogenated hydrocarbons
aromatic hydrocarbons
halogenated aromatlcs-
$111cones
heterocycllc N compounds
amines
arsenic
lead
manganese
copper
halogenated hydrocarbons
aromatic hydrocarbons
halogenated aromatlcs
amines
tin
antimony
silver
lead
mercury
boron
flourlne
chromium
maganese
1.92
1.70
1.70
0.43
0.16
0.14
26.1
5 x 10* - 5.5 x 105
1.25 x 10s
8.5 x 102
4.94
3.41
3.41
0.40
1,654
3
36
323
35
81
6,614
97
65
A-6
-------
TRI FACILITY PROFILE,
ELECTROPLATING
by
IT Corporation
11499 Chester Road
Cincinnati, Ohio 45246
Contract No. 68-DO-0020
Work Assignment No. 2-27/2-65/3-18
JTN 830015-5-1
Prepared for
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF TOXIC SUBSTANCES
401 M Street, SW
Washington, D.C. 20460
June 1992
-------
CONTENTS
Page
Figures jjj
Tables iii
Section 313 Electroplating Chemicals 1
Chlorinated Solvents 4
Acids 8
Metals/Metal Compounds 11
Other Section 313 Chemicals 20
Nonreporting Facilities 24
List of Questions 25
Bibliography 27
-------
FIGURES
Number Page
1 Process Row Diagram of Chromium Plating of Decorative Zinc Die
Castings 2
TABLES
Number Page
1 Summary of Reported Releases of Chlorinated Solvents From
Electroplating Facilities 5
2 Summary of Reported Releases of Acids From Electroplating Facilities 9
3 Summary of Reported Releases of Metal Compounds From Electro-
plating Facilities 12
4 Summary of Pretreatment Standards for the Electroplating Point
Source Category 15
5 Summary of Effluent Limitation for Metal Finishing 16
6 Summary of Emission Factors from XATEF Database 18
7 Summary of Reported Releases of Other Chemicals From Electro-
plating Facilities 22
in
-------
TRI FACILITY PROFILE,
ELECTROPLATING
The purpose of this profile is to assist U.S. Environmental Protection Agency
(EPA) personnel with Section 313 inspections. The profile describes key toxic chemi-
cals used in electroplating, describes how these chemicals are used, and identifies key
release sources. All Section 313 chemicals reported to TRI by more than 5 percent of
the electroplating facilities are presented in this profile.
Electroplating is the electrodeposition of an adherent metallic coating on an
electrode in order to form a surface with properties or dimensions different from those
of the base metal. The Section 313 metals that are commonly electroplated include
nickel, copper, chromium, and zinc, and to a lesser degree, cadmium and lead. The
electroplating process includes cleaning, rinsing, plating, and postplating treatments:
such operations can be performed manually or with varying degrees of automation.1
The primary cleaning processes performed prior to electroplating include solvent
cleaning, alkaline cleaning, and acid cleaning. Alkaline cleaners do not typically con-
tain Section 313 chemicals in high enough concentrations such that use would be
above the threshold limits. Parts to be plated may be hung in the plating tank on
wires or racks, contained in wire baskets, or, more commonly placed in barrels that
rotate in the plating tank.1 Movement from one operation to the next may be by hand
or by machine. Figure 1 presents a process flow diagram showing chromium plating
of decorative zinc die castings in a plating operation of several Section 313 metals.
SECTION 313 ELECTROPLATING CHEMICALS
Section 313 chemicals commonly used in electroplating can be classified into
four distinct categories: chlorinated solvents, acids, metals/metal compounds, and
other Section 313 chemicals. Each category is discussed separately in this report.
1
-------
Air Emissions •*-
Metal Parts
*
Degreasing
1
Alkaline
Clean
Air Emissions •*-
Filter Solids •*-
Chromium
Plate
i
Rinse and Dry
*
Spent Solvent
and Sludge
p1
Clean
Water
Filter Solids W
— ^
— *•
— »•
\__
_-»
ninsa
*
Acid Dip
*
Rinse
*
Cyanide
Copper Strike
i
Dine A
4
Acid Dip
*
Acid
Copper Plate
4
Rinse
*
Nickel Plate
*
Rinse
Neutralize
and Precipitate
Oxidize
Cyanide
*
Precipitate
Copper
•*- Filter Solids
V,
s
u
S«ttle
Sludge
Precipitate Ntake
and Copper
Reduce
Chromium
1
Precipitate
Chromium
i
Is
o
Treated
Water
Rntehed Pan
Figure 1 . Process flow diagram of chromium plating of decorative zinc die castings.
-------
Each section contains a description of how the Section 313 chemicals are used, a
discussion of typical releases and off-site transfers, a table summarizing releases and
off-site transfers that were reported to TRI in 1990, a description of industry-specific
and chemical-specific regulations, typical control practices, and common reporting
errors. Methods for identifying nonreporting facilities and a list of questions are also
presented.
-------
CHLORINATED SOLVENTS
The primary chlorinated solvents used in degreasing prior to electroplating are
1,1,1-trichloroethane and trichloroethylene; CFC-113, tetrachloroethylene, and
dichloromethane (methylene chloride) are used to a lesser degree. No Section 313
byproducts are formed during the use of chlorinated solvents in degreasing.
Chlorinated solvents are otherwise used in electroplating to remove unpigment-
ed oil/grease and metal chips/cutting fluid. They may be used as a solvent wipe, in a
cold degreaser, or in a vapor degreaser.
In a solvent wipe, a rag or other wiper is dipped in the chlorinated solvent and
wiped across the part to remove the contaminant. Cold degreasers usually consist of
a tank, basket, and cover, and may employ spraying, brushing, agitation, flushing, or
immersion. The solvent is usually kept near room temperature. Cold units vary
greatly in size and design.
A vapor degreaser which consists of a tank and heating system to boil the
solvent, may be operated manually or it may be conveyorized. In this process, a
solvent vapor phase is produced and parts to be cleaned are lowered into the vapor
phase. Vapors condense on the parts until the temperature of the part approaches
that of the vapor, at which time the parts are removed. Most vapor degreasers are
equipped with condenser coils located on the upper sidewalls of the degreaser to con-
trol the vapor level in the tank. They may also be equipped with water separators,
which are simple containers in which solvent and water that condenses from the am-
bient air are separated. Lids are commonly closed when the degreaser is not in use.
Degreasing operations primarily produce fugitive and point-source air releases
and off-site transfers for solvent recovery or disposal. In vapor degreasing, moisture
from air condensing on the cooling coils of the degreaser may result in minimal
releases to water or publicly owned treatment works (POTWs). Based on Section 313
reporting for 1990, Table 1 presents a summary of Section 313 reported releases and
off-site transfers from solvent degreasing at electroplating facilities.
Various controls may be used to reduce releases and off-site transfers of Sec-
tion 313 chemicals from electroplating operations. Air releases from the use of
-------
TABLE 1. SUMMARY OF REPORTED RELEASES OF CHLORINATED SOLVENTS
FROM ELECTROPLATING FACILITIES
Mean release, Ib (% reporting to each med1a)b
Section 313 chemical
1,1,1-Trlchloro-
ethane
Trlchloroethylene
CFC-113
Tetrachl oroethy 1 ene
Dlchloromethane
Number of facil-
ities reporting
usage3 (% re-
porting usage)
184 (19)
97 (10)
55 (5)
35 (4)
29 (3)
Fugitive
19,159
21,430
23,767
24,180
8,127
(85)
(82)
(96)
(86)
(93)
33
35
16
31
39
Stack
,550
,316
,704
,444
,187
(50)
(61)
(25)
(57)
(69)
POTWC
125
69
4
110
177
(18)
(20)
(5)
(14)
(28)
Off-site
transfer**
7,401 (34)
5,652 (49)
3,711 (40)
12,465 (31)
8,367 (45)
Total6
35,877
42,946
28,639
43,881
38,515
(99)
(98)
(100)
(97)
(100)
c
d
e
A total of 994 facilities in SIC 3471 reported usage of at least one Section 313 chemical above
threshold limits in 1990.
Mean release In pounds per year In 1990 for firms reporting release of this chemical and
percentage of firms reporting usage of this chemical that reported release to this media.
Releases to other media were Insignificant.
POTW = Publicly owned treatment works.
Off-site transfer for recycling was not reportable In 1990; transfer for recycling would be
significant for chlorinated solvents. The mean release to off-site transfer would be expected to
increase significantly in the 1991 reporting year.
The total Includes all releases and off-site transfers not just categories summarized 1n this
table.
-------
chlorinated solvents in vapor degreasing may be reduced by application of the
following engineering controls and operation and maintenance (O&M) procedures:
Engineering controls
Lowering the temperature of cooling water.
Increasing freeboard height (distance between top of vapor phase
and top of degreaser).
Adding low-solvent-level detector.
Using optimum parts-handling speeds (automatic hoists).
Adding automatic lid closure.
Adding extra cooling coils on inlets and outlets.
O&M procedures
Closing the cover when possible.
Minimizing drafts.
Positioning work to minimize dragout (solvent on part when re-
moved from the degreaser).
Spraying only below the vapor level.
Avoiding excessively large loads.
Maintaining equipment.
Waste solvent evaporation can be a major source of air release from cold
cleaning. This release occurs when spent solvent is stored in open containers prior to
disposal and/or from evaporation at the disposal site. This release can be minimized
by covering spent solvent containers and by reclaiming solvent. Another release
source, solvent bath evaporation, can be reduced through use of a cover whenever
parts are not being cleaned and through adjustment of room and exhaust ventilation
rates to minimize drafts. A third release source, solvent carryout, is dependent on the
use of a drainage rack. Internal or external racks can be used, depending on the size
of the cleaning unit. Also, drainage time must be of adequate duration to ensure that
the racks are effective in reducing carryout.
F001 and F002 Generic RCRA* wastes are spent solvent wastes that before
use contained over 10 percent listed chlorinated solvents. Off-site transfers of waste
chlorinated solvents (RCRA F001 and F002 wastes) can be reduced through use of
' Resource Conservation and Recovery Act.
6
-------
on-sfte solvent recovery. For two of the chlorinated solvents used in degreasing
(1,1,1-trichloroethane and CFC-113), use is expected to drop significantly because of
environmental regulation by EPA to reduce ozone depletion. These regulations will
eventually phase out the use of these solvents entirely and will cause increased control
of air releases, substitution, and use of solvent recovery as a result of rising costs
solvent costs.
For chlorinated solvents used in degreasing, a mass balance (addressing pri-
marily air release and off-site transfer of waste solvent) which accounts for the total
throughput of the solvent (at least 10,000 pounds) is the best methodology to estimate
release and off-site transfer. Prior to the 1991 reporting year, this approach is difficult
using the Section 313 reported quantities because off-site transfer for recycling of the
chlorinated solvents is common and this quantity was not reportable. Beginning with
the submittals for the 1991 reporting year, the new pollution prevention reportable
quantities will enable a mass balance to be performed if the throughput has been ob-
tained from the facility. A common error in reporting has been the use of the total
quantity of waste solvent sent off site (i.e., that reportable under RCRA as F001 and
F002 wastes) as the quantity of chlorinated solvent sent off site. Since this overesti-
mates the quantity of chlorinated solvent sent off site, use of this amount in mass bal-
ance calculations underestimates the air release of the chlorinated solvent. Although
Section 313 reporting does not require the facility to take any measurements, the facili-
ty usually can contact the solvent reclaimer to obtain the percentage of chlorinated
solvent in the waste solvent.
-------
ACIDS
Sulfuric and hydrochloric acids are the primary acids used as components in
electroplating solutions, with nitric and phosphoric acids used to a lesser degree.
Acids are otherwise used in electroplating to control the pH of the plating baths, to
clean surfaces before and between plating steps, and as postplating treatments (e.g.,
phosphate treatments). Although acids in electroplating solutions are used to control
the pH of the solution to promote the formation of desired ionic metal compounds,
there is no net formation of Section 313 byproducts during the use of acids in elec-
troplating. Because hydrogen cyanide gas can form if acid and cyanide solutions are
mixed, great care is taken when cyanide is used in the plating bath to avoid mixing the
cyanide solution with acids either through dragout or disposal. The primary release of
acids is through off-site transfer of spent acid or plating solution and release to water
or POTW through dragout to the rinse water. As described in the Metals/Metal Com-
pounds section of this profile, a mist is formed over plating baths as a result of the
evolution of gases during the electroplating process. This mist will contain acids from
the plating bath. Controls designed to capture metals and cyanides in the bath will
also capture the acids in the mist. Although these systems will be pH controlled to
limit corrosion problems and to eliminate the possible formation of hydrogen cyanide
gas, the pH of any discharges (e.g., scrubber water) should be checked to determine
if any acids are released. Based on Section 313 reporting for 1990, Table 2 presents
a summary of the reported releases and off-site transfers of acids from the electroplat-
ing process.
Neutralization is the primary control used for acid releases. For acid use, a
release to surface waters is not reportable under TRI if the pH is 6 or higher. The pH
value of wastewater discharged should not be assumed by the facility, but should be
verified. Typically, pH monitoring for other regulations is (and should be) retained by
the facility. Most electroplating facilities are required to monitor the pH of discharges
continuously. These data can be used to calculate water releases if excursions below
pH 6 occurred and only one acid is present in the wastewater. The U.S. EPA Pretreat-
ment Standards for Electroplating Facilities2 requires that facilities with a discharge of
8
-------
TABLE 2. SUMMARY OF REPORTED RELEASES OF ACIDS FROM ELECTROPLATING FACILITIES
CD
Mean release, Ib (%
Section 313
chemical
Sulfuric acid
Hydrochloric
acid
Nitric acid
Phosphoric
acid
Number
ties
usage3
ing
676
514
372
123
of facili-
reporting
(% report-
usage)
(68)
(52)
(37)
(12)
Fugitive
496 (55)
670 (67)
357 (63)
277 (57)
Stack
605
911
1469
1055
(45)
(48)
(58)
(50)
Water
1386
211
2779
750
(5)
(4)
(3)
(1)
reporting to
POTWC
7,557
15,006
3,984
9,714
(26)
(26)
(28)
(24)
each media)0
Off-site
transfer
56,987 (14)
34,884 (12)
13,425 (19)
9,765 (14)
Totald
14,127 (74)
11,102 (82)
5,726 (84)
5,645 (78)
A total of 994 facilities in SIC 3471 reported usage of at least one Section 313 chemical above
threshold limits.
Mean release in pounds per year in 1990 for firms reporting release of this chemical and
percentage of firms reporting usage of this chemical reporting release to this media. Releases
to other media were insignificant. pH release above 6 is not reportable under Section 313.
POTW = Publicly owned treatment works.
The total includes all releases and off-site transfers not just categories summarized 1n this
table.
-------
more than 38,000 L/day to maintain the pH of the discharge between 7.5 and 10. The
U.S. EPA Effluent Limitations for Metal Finishing Facilities requires certain facilities to
maintain the pH of the discharges between 6 and 9.
10
-------
METALS/MEtAL COMPOUNDS
Metals/metal compounds are processed in electroplating operations. While
conversions between metal and metal compounds do occur there are no Section 313
byproducts formed during the use of the metal/metal compounds in electroplating.
The purpose of electroplating is to deposit the metal on the surface of the part being
plated. Plating baths for the Section 313 chemicals are almost always aqueous
solutions.1 The part being plated is made the cathode, and the metal salts in the
aqueous solution are reduced and electroplated onto the part. The thickness of the
metal deposit applied by electroplating can vary from 0.025 //m to 1 mm or more in
electroforming, with a standard nickel-chromium plate on exterior automotive hardware
from 25 to 50 //m.
The major types of electroplating include immersion plating, barrel plating, and
brush plating. In immersion plating, the metallic coating is deposited on the base
4
metal from a solution containing the coating metal. Immersion baths are usually in-
4
expensive and permit plating on different surfaces, such as the insides of tubing. In
barrel plating, a bulk workload is tumbled in a rotating vessel incorporating electrical
4
contacts to attract metals out of solution onto the parts. The major advantage of bar-
4
rel plating is high efficiency. Available barrel-plating equipment varies widely, but
generally conforms to two major configurations: horizontal and oblique barrels.4
Brush plating is a process performed with a hand-held or portable plating tool, rather
than a tank of solution; it is also called contact plating, selective plating, or swab
4
plating. Half of the time brush plating is used because it is a better way to apply an
electroplate and the other half because it is a better repair method for work on
4
mismachined parts.
The anode is the positive electrode in a plating bath; it conducts the current into
the solution and, by its shape and position relative to the cathode, influences the distri-
bution of current over the cathode surface. Anodes may be soluble or insoluble, or
both may be used in combination.5 In most plating operations, a soluble anode sup-
plies the metal that is deposited on the cathode; the solution is merely the means by
which the metal is carried from anode to cathode. Insoluble electrodes are used
11
-------
either as cathodes or anodes in electrocleaning, as cathodes in electropolishing, and
as anodes in certain plating operations, the most important of which is chromium plat-
ing.5
An ideal soluble anode has the following desirable characteristics:5
1) Corrodes smoothly and evenly under the influence of the current.
2) Produces, in corroding, a minimum quantity of sludge and metallic parti-
cles.
3) Corrodes with a high anode efficiency under normal operating conditions.
4) Has a high limiting current density.
5) Has a low rate of solution in the bath (without current).
6) Introduces no objectionable amount of impurities into the bath.
The sole function of an insoluble electrode is to complete the electrical circuit to
the solution; hence, it is merely necessary for it to be a good conductor and to be
unattacked by the bath with or without current flowing.5 Insoluble electrodes are used
as anodes in plating, as cathodes in electropolishing and anodizing, and as either
anodes or cathodes in electrolytic treatments in acid or alkaline solutions, In all such
operations there will be strong gassing at the electrode, usually liberating hydrogen at
the cathode and oxygen at the anode; however, an insoluble anode in a chloride-
bearing electrolyte will release chlorine. In this case, chloride should be reported as
manufactured as a byproduct of the process. An insoluble anode will tend to oxidize
certain bath constituents as organic addition agents and cyanide. The irreversible
reactions occurring at insoluble anodes will materially increase the cell voltage over
that required for soluble anodes operating under the same conditions.
Steel, nickel, alloyed lead, and carbon (graphite) serve as insoluble anodes.5
Release of metals and metal compounds from electroplating is primarily through
off-site transfer of spent plating bath solutions. Significant quantities of metals and
metal compounds are also released to water and POTW through dragout from the
plating bath to the rinse water and from release of scrubber water used to control air
release. Finally, small quantities of metals and metal compounds are released to air
(both fugitive and stack) through misting during electroplating. Based on Section 313
12
-------
reporting for 1990, Table 3 presents a summary of the reported releases and off-site
transfers of metals and metal compounds from the electroplating baths.
Releases of several chemicals are strictly regulated for electroplating operations.
A summary of the U.S. EPA Pretreatment Standards for the Electroplating Point
Source Category is presented in Table 4. For full explanation of these guidelines, see
40 CFR 413. The Pretreatment Standards presented in Table 4 are basically the stan-
dards for those facilities discharging into POTWs. A summary of the U.S. EPA Effluent
Limitations for the Metal Rnishing Point Source Category are presented in Table 5.
For full explanation of these guidelines, see 40 CFR 433. The Effluent Limitations pre-
sented in Table 5 are the standards for direct discharges to navigable waterways or
rivers. The concentrations in Tables 4 and 5 may be used as a guideline to estimate
releases; however, local regulations may be more stringent and actual concentrations
may be below the allowable levels. The facility would likely be required to monitor for
these pollutants. These monitoring data represent the best release estimates, and
releases reported should be checked on Form R as calculated using monitoring data.
Releases and off-site transfers of metals and metal compounds are strictly regu-
lated. Because of the effluent guidelines summarized in Table 4 limiting release of cya-
nide and metals to water, pretreatment of the wastewater may generate a RCRA F006
waste (wastewater treatment sludges from electroplating operations). F006 wastes
result primarily from wastewater treatment operations in the electroplating or metal-
g
finishing operations. The leading technology used to remove metals from plating
wastewaters include 1) a chromium reduction step to treat hexavalent chromium, 2) a
chemical precipitation step to precipitate metals out of solution (using lime or sulfides),
e
and 3) a sludge dewatering step to remove the precipitated residues from solution.
Waste volumes determined from RCRA reporting and estimates or measure-
ment of the concentrations of metals or metal compounds may be used to estimate
off-site transfers.
Individual states may have regulations that are more stringent than RCRA. For
example, California regulates any spent plating bath that does not fit into one of the
other RCRA categories as a hazardous waste under the generic category of spent
13
-------
TABLE 3. SUMMARY OF REPORTED RELEASES OF METALS AND HETAL COMPOUNDS FROH ELECTROPLATING FACILITIES
Mean release, 1b (X reporting to each med1a)b
Number of facil-
ities reporting
Section 313 usage3 (% re-
chemical porting usage) Fugitive
Nickel
Nickel compounds
Copper
Copper compounds
Chromium
Chromium
compounds
Zinc (fume or
dust)
Zinc compounds
Lead
Lead compounds
Cadmium
Cadmium
compounds
118
105
125
61
76
96
37
108
35
8
23
15
(12)
(11)
(13)
(6)
(8)
(10)
(4)
(11)
(4)
(1)
(2)
(2)
113
129
133
97
169
106
347
168
127
4
128
66
(48)
(50)
(36)
(39)
(63)
(57)
(54)
(46)
(43)
(50)
(43)
(27)
Stack
122
133
210
633
187
197
655
664
535
5
152
128
(31)
(41)
(39)
(48)
(72)
(59)
(35)
(40)
(40)
(50)
(43)
(27)
Water
351 (14)
264 (11)
263 (19)
205 (21)
104 (14)
136 (8)
72 (22)
203 (16)
259 (11)
5 (13)
260 (4)
0 (0)
POTWC
273 (77)
402 (87)
208 (68)
295 (80)
239 (62)
272 (79)
278 (73)
285 (81)
117 (60)
102 (63)
166 (91)
184 (93)
Off- site
transfer
12,477
32,571
8,885
19,161
14,242
16,054
12,402
32,019
8,494
52,423
8,057
7,162
(64)
(69)
(66)
(72)
(75)
(83)
(70)
(84)
(74)
(38)
(74)
(87)
Total d
8,969 (92)
23,754 (96)
6,488 (96)
15,192 (95)
11,936 (95)
13,928 (99)
9,887 (95)
28,655 (96)
6,875 (97)
22,550 (88)
6,848 (91)
6,431 (100)
c
d
A total of 994 facilities In SIC 3471 reported usage of at least one Section 313 chemical above
threshold limits.
Mean release in pounds per year in 1990 for firms reporting release of this chemical and
percentage of firms reporting usage of this chemical reporting release to this media. Releases
to other media were insignificant.
POTW « Publicly owned treatment works.
The total Includes all releases and off-site trnasfers not just categories summarized in this
table.
-------
TABLE 4. SUMMARY OP PRETREATMENT STANDARDS FOR THE ELECTROPLATING POXNTSOURCE CATEOORT
[Daily average in mg/L (mg/m* operation)****
01
Lees than 38,000-L (10,000-gal/day)
diecharge
Hore than 38,000-L (10,000-gal/day)
discharge
Pollutant
Cyanide
Cyanide, total
Copper
Nickel
Chromium
Zinc
Lead
Cadmium
Total metals
pH
TTO
TSSf
Ag
Electro-
plating
common
metals
2.7
0.4
0.7
4.57
Electro-
plating
precious
metals Anodizing
2.7 2.7
0.4 0.4
0.7 0.7
4.57 4.57
Electro-
plating
common
metals
1.0 (39)
2.7 (105)
2.6 (100)
4.0 (156)
2.6 (102)
0.4 (16)
0.7 (29)
6.8 (267)
7.5-10
2.13
13.4
Electro-
plating
precious
metals
1.0 (39)
2.7 (105)
2.6 (100)
4.0 (156)
2.6 (102)
0.4 (16)
0.7 (29)
6.8 (267)
7.5-10
2.13
13.4
0.7 (29)
Anodizing
1.0 (39)
2.7 (105)
2.6 (100)
4.0 (156)
2.6 (102)
0.4 (16)
0.7 (29)
6.8 (267)
7.5-10
2.13
13.4
a
b
c
d
40 CFR 413 (Electroplating Point Source Category also presents pretreatment standards Subpart E -
Coatings Subcategory, Subpart P - Chemical Etching and Milling Subcategory, Subpart G - Electrol-
ess Plating Subcategory, and Subpart H - Printed Circuit Board Subcategory.
Values presented are average daily values for 4 consecutive monitoring days. Daily maximum limi-
tations are also presented in 40 CFR 413.
Cyanide amenable to chlorination.
Total copper, nickel, zinc, and chromium.
Total toxic organics listed in 40 CFR 413.02(1).
Total suspended solids. Value presented is a 1-day maximum.
-------
TABLE 5. SUMMARY OF EFFLUENT LIMITATION FOR METAL FINISHING
(Monthly average in mg/L)a
Pollutant
Cadmium, total
Chromium, total
Copper, total
Lead, total
Nickel, total
Silver, total
Zinc, total
Cyanide9
Cyanide, total
TTOh
Oil and grease
TSS1
PH
BPTb
0.26
1.71
2.07
0.43
2.38
0.24
1.48
0.32
0.65
2.13
26
31
6-9
BATC
0.26
1.71
2.07
0.43
2.38
0.24
1.48
0.32
0.65
2.13
PSESd
0.26
1.71
2.07
0.43
2.38
0.24
1.48
0.32
0.65
2.13
NSPSe
0.26
1.71
2.07
0.43
2.38
0.24
1.48
0.32
0.65
2.13
26
31
6-9
PSNSf
0.26
1.71
2.07
0.43
2.38
0.24
1.48
0.32
0.65
2.13
a 40 CFR 433 Metal Finishing Point Source Subcategory. Maximums for any one
day are also presented.
BPT = Best practicable control technology currently available.
c BAT = Best available control technology economically achievable.
PSES = Pretreatment standards for existing sources (except job shops and
Independent printed circuit board manufacturers.
e NSPS = New source performance standards.
PSNS = Pretreatment standards for new sources.
9 Cyanide amenable to chlorlnatlon.
Total toxic organlcs listed In 40 CFR 433.11(e). Value presented Is a
1-day maximum.
1 TSS = Total suspended solids.
16
-------
plating bath. Plating solutions containing nickel, for example, are not regulated as
hazardous wastes under RCRA (if the pH is greater than 2.0) but are regulated in Cali-
fornia. Therefore, records maintained for manifests and reporting requirements could
be used as a source for estimating off-site transfers of nickel compounds.
A mist is formed over plating baths due to the evolution of gases during the
electroplating process. For example, in a hexavalent chromium plating process only
about 10 to 20 percent of the current applied is used to deposit chromium on the item
plated. Eighty to ninety percent of the current is consumed by the evolution of
hydrogen gas at the cathode with the resultant liberation of gas bubbles. Additional
bubbles are formed at the anode due to the evolution of oxygen. As the bubbles
burst at the surface of the plating solution, a fine mist of plating bath droplets is
formed.
Releases to air from the mist generated from plating baths depend on the sur-
face area of the bath, the applied current, the hours of operation of the bath, the con-
centration of the metal in the solution, and the controls on the system. Table 6 pre-
sents emission factors from the Crosswalk/Air Toxic Emission Factor (XATEF) Data-
base.7
Mist generated during electroplating operations can cause threshold limit values
(TLVs) for cyanide and some metals to be exceeded in the workplace air. Local ex-
haust ventilation (LEV) may be used to reduce potential worker exposures. Because
LEV creates a point-source release for these toxics, controls may be used such as
mist eliminators (usually using impaction of droplets onto a stationary set of blades or
mesh pad) or wet scrubbers (typically single and double packed-bed) that are
operated at a relatively low pressure drop.8 Because of the corrosive properties of
many of the electroplating baths, the control devices may be constructed of polyvinyl
chloride (PVC) or fiberglass.8
Since metal discharges are regulated under Effluent Limitations and Pre-
treatment Standards, most facilities should have monitoring data as required by their
permits. Regulatory limits and the wastewater flow rates may be used to estimate
maximum release. The metal content of the pretreatment sludge is typically not
17
-------
TABLE 6. SUMMARY OF EMISSION FACTORS FROM XATEF DATABASE
Process
Metal
Emission factor
Conditions
Cadmiun electroplating
Chrone plating, hard
Chrome plating, hard
Nickel electrodeposition
Chrone plating, decorative
Chrome plating, hard
Cadmiun 0.00005 g/h/anp
Chroniun VI 0.00191 Ib/h/ft* tank area
Chromium 1.64 x 10" lb/h/fta tank
area
Nickel 4.95 x 10'' Ib/h/amp
Chroniun VI 1.0 x 10* Ib/anp hour
Chromium VI 3.08 x 10' Ib/amp hour
Entire process, uncontrolled
Chromic acid anodizing tank,
uncontrolled
Plating tank, uncontrolled
Value is for striking, can be
used for plating
Plating tank controlled by foam
blanket fume suppressant with
wetting agent
Plating bath controlled by
double packed-bed scrubber fol-
lowed by chevron blades
Chrome
Chrome
Chrome
Chrome
Chrome
Chrome
Chrome
Chrome
Chrome
Chrome
Chrome
Chrome
Chrome
Chrome
plating,
plating.
plating.
plating,
plating,
plating.
plating.
plating.
plating.
plating,
plating.
plating.
plating.
plating,
hard
hard
hard
hard
hard
decorative
hard
decorative
anodizing
decorative
hard
hard
decorative
decorative
Chromium VI
Chromium VI
Chromium VI
Chromium VI
Chromium VI
Chromium VI
Chromium VI
Chromium
Chromium
Chromium
Chromium
Chromium
Chromium
Chromium
3.08 x 10' Ib/amp hour
1.23 x 10* Ib/amp hour
1.76 x 10' Ib/amp hour
3.96 x 10' Ib/amp hour
5.9 x 10 7 to
1.2 x 10* Ib/amp hour
3.6 x 10* Ib/amp hour
2.02 x 10* Ib/amp hour
0.00012 lb/h/ft2 surface
area
6 mg/amp hour
20 mg/amp hour
0.7 mg/amp hour
0.04 mg/amp hour
12 mg/amp hour
0.001 mg/amp hour
Plating tank controlled by
single packed-bed scrubber
Plating tank controlled by
double packed-bed scrubber
Plating tank controlled by mesh
pad mist eliminator with two
sets of chevron blades followed
by two pads
, 'Plating tank
mesh pad mist
controlled by one
eliminator
Plating tank controlled by
chevron-blade mist eliminators
Plating tank.
Plating tank.
Chromic acid
uncontrolled
Plating tank
additives
Plating tank.
Plating tank
scrubber
Plating tank
polyball
Plating tank.
Plating tank
additives
uncontrolled
uncontrolled
anodizing tank
controlled by
uncontrolled
controlled by
controlled by
uncontrolled
controlled by
•
foam
foam
18
-------
available and may be difficult to relate to F006 disposal quantities. The best method to
use to estimate this quantity is to estimate the quantity based on the quantity released
to water and the control efficiency of the pretreatment. Mass balance calculations for
total metal usage are not useful, as most of the metal and metal compounds are dep-
osited on the product. However, a mass balance using measured values of influent
and effluent to the wastewater treatment plant may be used when available. The qua-
ntities of metal and metal compounds in the spent plating bath may be estimated from
disposal quantities and the concentration maintained in the baths during operation.
19
-------
OTHER SECTION 313 CHEMICALS
Six other Section 313 chemicals are otherwise used at electroplating facilities.
The use of these chemicals does not typically form any Section 313 byproducts during
use in electroplating. Three are solvents: methyl ethyl ketone (MEK), toluene, and xy-
lene (mixed isomers). These solvents are widely used, and although they may be
used at some facilities for cleaning, they are probably used in coatings that are applied
elsewhere in the facility and are not directly related to the electroplating process. The
other three Section 313 chemicals used at electroplating facilities are ammonia, chlo-
rine, and cyanide compounds. Ammonia may be used to adjust the pH of the plating
bath or wastewater treatment operations. Chlorine is used in wastewater treatment
and for cyanide destruction. Chlorine gas or hypochlorrtes are used to break down
cyanides in the following reaction:1
CAT + C/2 - CNCI + Cr
CNCI + 2OH- - CA/O- + cr + H2o
2CNO- + AON' + 3C/2 -* 6C/' + 2C02 + 2H2O + A/2
Cyanide compounds are otherwise used in alkaline plating baths. Cyanide
compounds consist of both compounds of the metals being plated (e.g., Cu, Zn, Cd)
and compounds of alkali metals (e.g., Na, K). Solutions of these compounds are al-
ways basic. When the compound consists of a Section 313 metal and cyanide, two
Form Rs are required. One Form R is required to report the metal portion of the metal
compound, and a separate Form R is required to report the cyanide portion of the
cyanide compound. While the weight of the entire compound is used for the threshold
evaluation, only the cyanide portion is used to estimate releases and off-site transfers.
While the metal compound is subject to the 25,000-pound threshold because it is
processed, the cyanide compound is subject to the 10,000-pound threshold because it
is otherwise used.
Great care is taken to avoid mixing the cyanide compounds with any acids
because this would cause formation of cyanide gas. The primary release of cyanide
compounds results from the off-site transfer of spent plating bath solutions. The plat-
20
-------
ing baths containing cyanides are RCRA hazardous wastes. Spent cyanide plating
bath solutions from electroplating operations are classified as F007 wastes. F008
wastes are plating sludges from the bottom of plating baths in electroplating opera-
tions using cyanide. F009 wastes are spent stripping and cleaning bath solutions from
electroplating operations using cyanides. Waste volumes determined from RCRA
reporting and estimates or measurement of the concentrations of cyanide may be
used to estimate off-site transfers. Cyanide releases to water, POTW, or off-site trans-
fer may be estimated by using cyanide measurements made for other regulations and
the volume of the waste stream.
Cyanide compounds are also released to water or POTW from dragout to rins-
ing operations and from scrubber water used to control air releases. Minor releases
of cyanide compounds to air (both stack and fugitive) also result from misting during
plating operations. The Best Demonstrated Available Technology (BOAT) for treatment
for cyanides in F006 wastewaters is alkaline chlorination. Based on Section 313 re-
porting for 1990, Table 7 presents a summary of the reported releases and off-site
transfers for six "other chemicals" used at electroplating facilities.
Chlorine and ammonia releases are minimal. Chlorine reacts with water to form
HOCI, CI', and HT. Although this is an equilibrium reaction, at pH above 4, the equilib-
rium is shifted almost completely to the right. Therefore, essentially zero releases of
chlorine to water will occur under normal circumstances. Small fugitive releases of
chlorine to air from tank changeover should be reported.
Because ammonia is a listed Section 313 chemical, all gaseous and aqueous
forms must be considered for reporting. Aqueous solutions of ammonia contain both
nonionized ammonia (NH3) and ionized ammonia (NH/). As the following chemical
equation shows, an equilibrium exists between the two forms of ammonia in the pres-
ence of water.
NH3 + 2H2O — » A/H/ + OhT + H2O
The term "total ammonia" refers to the sum of these species (i.e., NH3 + NH4+).
The relative amounts of NH3 and NH4* depend upon several factors (e.g.,
21
-------
TABLE 7. SUMMARY OF REPORTED RELEASES OF OTHER CHEMICALS FROM ELECTROPLATING FACILITIES
Section 313
chemical
NEK
To! uene
Xylene
Aimonla
Chlorine
Cyanide
compounds
Use
Sol vent
Solvent
Solvent
Wastewater/
bath pH
Wastewater/
cyanide
treatment
Plating bath
Number of
facilities
reporting
usage8
(X reporting
usage)
69 (7)
51 (5)
«7 (5)
54 (5)
57 (6)
137 (14)
Mean release, Ib (X reporting to each media)'1
Fugitive
7984
7166
2891
1137
184
178
(86)
(88)
(85)
(74)
(61)
(54)
Stack
35.465 (74)
35.585 (92)
20,603 (89)
3.621 (46)
518 (42)
527 (41)
Water
5 (3)
5 (6)
87 (6)
151 (4)
265 (19)
181 (11)
POTW0
8 (6)
7 (4)
110 (4)
7774 (35)
1710 (49)
198 (85)
Off -site
transfer
8,334
13,963
11,638
6,756
253
1,951
(«)
(39)
(40)
(15)
(5)
(78)
A total of 994 facilities In SIC 3471 reported usage of at least one Section 313 chemical above threshold limits.
b
Mean release In pounds per year In 1990 for firms reporting release of this chemical and percentage of firms reporting
chemical that reported release to this media. Releases to other media Mere Insignificant.
POTW = Publicly owned treatment works.
Total d
36,906
44,593
25,587
7,044
1,409
2.069
(100)
(100)
(100)
(89)
(87)
(97)
usage of this
The total Includes all releases and off-site transfers not just categories summarized In this table.
-------
temperature, pH, ionic strength, and other chemical reactions). To account for all
forms that are present, estimates of releases for Section 313 should be made for total
ammonia.
Ammonia hydroxide solutions should also be considered ammonia because
ammonium hydroxide is aqueous ammonia. The commercial products "aqua ammo-
nia" and •ammonium hydroxide" are approximately equivalent to 30 percent solutions
of ammonia in water. These products are mixtures of ammonia and water, and there-
fore should be reported as ammonia.
23
-------
NONREPORTING FACILITIES
Nonreporting facilities may be identified by comparing lists of facilities in Stan-
dard Industrial Classification (SIC) 3471 having more than 10 employees with those
facilities that have reported under Section 313. Most facilities that perform electroplat-
ing operations and have more than 10 employees should be using at least one Sec-
tion 313 chemical in excess of the threshold value. Exceptions include facilities that
only polish, anodize, or color the products or who electroplate metals that are not
reportable under Section 313 [primarily tin, precious metals (gold or platinum), or rare
metals (e.g., rhodium)]. Frequently, these cases can be identified by the name of the
company. For some facilities, the electroplating operation may be a very small part of
a large operation, and SIC 3471 may not be used to identify the facility. Sources of
information on facilities in SIC 3471 by employment size class include County Business
Patterns (for number of facilities), published by the U.S. Department of Commerce.9
Another source is Dunn and Bradstreet (D&B), which provides lists of companies by
SIC and employment size category.10 D&B reported 2181 facilities with more than
10 employees in SIC 3471 in 1992. County Business Patterns reported 1760 facili-
ties with more than 10 employees as SIC 3471 in 1989.9 In 1990, 944 facilities report-
ed under Section 313 using SIC 3471.
A review of the facilities in SIC 3471 in 1990 seemed to indicate some misre-
porting of whether a chemical was manufactured, processed or otherwise used. This
misinterpretation for otherwise used chemicals could cause the facility to use the
wrong threshold and not report for some of the otherwise used chemicals.
24
-------
LIST OF QUESTIONS
The following questions can be helpful to determine if errors were made in
Section 313 reporting for electroplating facilities.
Chlorinated Solvents
• Was a mass balance accounting for all chlorinated solvent usage used to
estimate releases and off-site transfers?
• Was the percentage of chlorinated solvent in the waste solvent
accounted for?
Acids
For vapor degreasing with water separation, was release to water or
POTW accounted for?
• Was pH of releases continuously measured to support any assumption
of neutralization?
• Was the percentage of acid in the original acid or solution taken into
account in the calculations of threshold?
Metals/Metal Compounds
• Was TCLP used as a measure of metal concentration in any of the
calculations? TCLP does not measure metal content but rather teachable
metal and should not be used in calculations.
• Were wastewater monitoring data used to estimate release to water or
POTW? What was frequency of monitoring?
• Were emission factors used to calculate air releases from plating baths?
What is the source of these emission factors?
Other Section 313 Chemicals
• How were other solvents used?
• How were releases for other solvents other than to air estimated?
• Was mass balance for other solvents accounting for total usage
calculated?
25
-------
• If chlorine release to water or POTW was reported, check pH of water. If
pH is higher than 4, there is only a very small release to water.
• Was total ammonia used to report ammonia release to water?
• Was cyanide compound release estimated using RCRA reported release
quantities?
26
-------
BIBLIOGRAPHY
1. Kirk-Othmer Encyclopedia of Chemical Technology. Volume 8, Electroplating,
pp. 826-868.
2. U.S. Environmental Protection Agency. Effluent Guidelines and Standards for
Electroplating. 40 CFR 413 • Electroplating Point Source Category.
3. U.S. Environmental Protection Agency. Effluent Guidelines and Standards for
Metal Finishing. 40 CFR 433 - Metal Finishing Point Source Category.
4. Metal Finishing Guidebook and Directory Issue '92, Plating Procedures, pp. 289-
371. 1992.
5. Durney, L J. (ed). Electroplating Engineering Handbook. 4th Edition. 1984.
Van Nostrand Reinhold Co.
6. U.S. Environmental Protection Agency. Proposed Best Demonstrated Available
Technology (BOAT) Background Document for F006 (Addendum). Volume 12.
PB90-166232. Washington, D.C. November 1989.
7. U.S. Environmental Protection Agency. Crosswalk/Air Toxic Emission Factor
(XATEF) Database Management System and User's Manual, Version 1.2. U.S.
EPA Office of Air Quality Planning and Standards. October 1991. EPA 450/4-
91-028.
8. U.S. Environmental Protection Agency. Locating and Estimating Air Emissions
From Sources of Chromium (Supplement). EPA/450-2-89-002. PB90-103243.
Research Triangle Park, North Carolina. August 1989.
9. U.S. Department of Commerce, Bureau of the Census. County Business Pat-
terns 1989. CBP-89-1. Washington, D.C. 1991.
10. Dunn & Bradstreet. International Dunn's Market Identifier in DIALOG data base
File 518, 1992.
27
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11. The Hazardous Waste Consultant. Volume 10, Issue 1. RDB Memos - EPA's
Unpublished Regulatory Interpretations, Part II - Electroplating Wastes p 4.6-4.7.
McCoy and Associates Inc. January/February 1992.
12. U.S. Environmental Protection Agency. Development Document for Effluent
Limitations Guidelines and New Source Performances Standards for the
Copper, Nickel, Chromium, and Zinc Segment of the Electroplating Point
Source Category. EPA 440/1-74-003A. Washington DC. March 1974.
13. U.S. Environmental Protection Agency. Locating and Estimating Air Emissions
From Sources of Chromium. EPA/450-2-89-002. August 1989.
14. U.S. Environmental Protection Agency. Development Document for Effluent
Limitations Guidelines and Standards for the Metal Rnishing Point Source Cate-
gory. June 1983. EPA 440/1 -83-091.
15. U.S. Environmental Protection Agency. Estimating Releases for Mineral Acid
Discharges Using pH Measurements. June 1991. U.S. EPA Office of Toxic
Substances, Economics Technology Division.
16. U.S. Environmental Protection Agency. Waste Minimization in Metal Parts
Cleaning. August 1989. U.S. EPA Office of Solid Waste and Emergency Re-
sponse. EPA/530-SW-89-049.
17. U.S. Environmental Protection Agency. Guides to Pollution Prevention - The
Fabricated Metal Products Industry. July 1990. EPA 625/7-90-006.
18. U.S. Environmental Protection Agency. Locating and Estimating Air Emissions
From Sources of Nickel. EPA 450/4-84-007F. March 1984.
19. U.S. Environmental Protection Agency. Chromium Emissions From Chromium
Electroplating and Chromic Acid Anodizing Operations - Background Informa-
tion for Proposed Standards for NESHAP (National Emission Standards for
Hazardous Air Pollutants). December 1990. Preliminary Draft. Vol. I and II.
28
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TRI FACILITY PROFILE,
PETROLEUM REFINERIES
by
IT Corporation
11499 Chester Road
Cincinnati, Ohio 45246
Contract No. 68-DO-0020
Work Assignment No. 2-27/2-65/3-18
JTN 830015-5-1
Prepared for
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF TOXIC SUBSTANCES
40-i M Street, SW
Washington, D.C. 20460
September 1992
-------
CONTENTS
Page
Figure iii
Tables iii
Typical Refinery Processes 4
Section 313 Petroleum Refining Chemicals 12
Constituents of Crude Oil 13
Manufactured Products 17
Processed and Otherwise Used Chemicals 19
Metals/Metal Compounds 22
Acids 25
Use of Regulations to Estimate Release of Section 313 Chemicals 27
Nonreporting Facilities 29
List of Questions 30
Bibliography 32
Appendix A Selected Information and Emission Factors A-1
-------
FIGURE
Number
1 Simplified Process Flow Diagram for Petroleum
Refineries
Page
3
TABLES
Number
1
2
3
4
5
Summary of Reported Releases of Constituents of
Crude Oil From Petroleum Refineries
Summary of Reported Releases of Manufactured
Products From Petroleum Refineries
Summary of Reported Releases of Processed and
Otherwise Used Chemicals From Petroleum Refineries
Summary of Reported Releases of Metals and Metal
Compounds From Petroleum Refineries
Summary of Reported Releases of Acids From Petroleum
Refineries
Page
14
18
20
23
26
iii
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TRI FACILITY PROFILE,
PETROLEUM REFINERIES
The purpose of this profile is to assist U.S. Environmental Protection Agency
(EPA) Regional Office personnel in conducting SARA Title III, Section 313, inspections.
The profile describes key toxic chemicals manufactured, processed, or otherwise used
in petroleum refining, describes how these chemicals are used, and identifies key
release sources. All Section 313 chemicals reported to the Toxic Release Inventory
(TRI) by more than 5 percent of the petroleum refineries are presented in this profile.
For the purposes of this profile, the petroleum refining industry is defined as:
• SIC 2911 - Petroleum Refining
This Standard Industrial Classification (SIC) includes establishments primarily engaged
in producing gasoline, kerosene, distillate fuel oils, residual fuel oils, and lubricants
through fractionation or straight distillation of crude oil, redistillation of unfinished
petroleum derivatives, cracking, or other processes. Establishments in this industry
also produce aliphatic and aromatic chemicals as by-products.1 Major products are
aromatic chemicals (including benzene), asphalt, butadiene, butylene, coke, diesel
fuel, ethylene, gasoline, greases, jet fuels, kerosene, mineral oils/waxes, naphtha, oils
(fuel and lubricating), propylene, solvents, and tar.1
Petroleum refineries convert crude oil into products such as liquified petroleum
gas, gasoline, kerosene, jet fuel, diesel fuel, fuel oils (home heating oils, etc.), and
feedstocks for the petrochemical industry. The petroleum refining industry begins with
the storage of crude oil and terminates with the storage of refined products. Crude
oil production, distribution of refined products, and production of petrochemicals are
generally considered part of other industries.2
Crude oil typically contains a wide range of hydrocarbons: paraffins, cyclo-
paraffins (naphthenes), and aromatic compounds. Crude oil also contains some sulfur
1
-------
compounds, a small amount of nitrogen compounds, and small amounts of oxygen
compounds or olefins.3
Because of the wide range of hydrocarbons found in crude oil, many processes
are used at petroleum refineries to yield the desired type and quantity of products.
These processes can be grouped into the following classes: separation, conversion,
treatment, feedstock and product handling, and auxiliary facilities.
Crude oil is transported to the refinery by either pipeline or tanker and stored in
large tanks. The crude oil is washed with water to remove salt and suspended
particles before being introduced into the process system.
Figure 1 illustrates a simplified process flow diagram used by refineries in the
United States. A more detailed process flow diagram is presented in Appendix A.
Distillation is the first process that the crude oil is subjected to at a typical refinery.
The distillation process takes place at atmospheric pressure and is used typically to
separate numerous fractions boiling below approximately 370 *C.
The distillate fractions are then further processed to upgrade the quality of, and
remove sulfur and other contaminants from, the distillate to produce a salable product.
The following are examples of these processes:
• Naphtha is typically upgraded to increase its octane number and
aromatic content by noble-metal catalysts in a fixed-bed reactor;
• Light gas oil is subjected to hydroprocessing, which removes sulfur,
nitrogen, oxygen, and metals. Also, hydroprocessing converts
unsaturated compounds to saturated compounds to improve burning
properties;
• Heavier gas oil is usually processed further by catalytic cracking to yield
high-octane gasoline.
The bottoms from the atmospheric distillation are further distilled under vacuum.
These distillate fractions are fed to the process stream of heavier gas above and
subjected to catalytic cracking.
Vacuum distillation bottoms can be used as fuel or road asphalt or processed
further in coking. Coking is a thermal process that cracks heavy oil into a range of
lighter products and a solid coke product. The lighter products produced are
hydrotreated to yield a salable fuel oil.
-------
Storage
Tanks
DosBltfng
0>
Atmospheric
Distillation
Extraction
and/or
Alkylation
and/or
Catalytic
Reforming
Fuel Gas
LPG. Butane. Petrochemicals
Motor Gasoline
Aromatics
Cracking
Hydrotreating
Diesel and Jet Fuel.
Heating Oil
Lubricants and Waxes
Fuel Oils
Figure 1.
Petroleum Refinery Process
Flow Diagram.
I DRAWING r
" I
CHECKED BY
.APPROVED BY
DRAWING NO
M-BX015-S-1-MM
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TYPICAL REFINERY PROCESSES
Refineries will differ from facility to facility; however, the following categories of
processes and associated operations will typically be found at a refinery:
Separation
Conversion
Treatment
Feedstock and product handling
Auxiliary facilities
These operations are described in the following sections. The arrangement of the
processes varies among refineries, and few will contain all of the processes described
in this report.
SEPARATION PROCESSES
The first step in petroleum refining is the separation of crude oil into its major
constituents by two separation processes:
• Distillation
• Extraction
Distillation is a unit operation that is used to separate the components of a
liquid solution based on the distribution of these various components between a vapor
and liquid phase. All components are present in both phases. The liquid mixture is
fed to a point along the length of the distillation column. The column contains packing
or trays to promote vapor-liquid contact. The liquid at the bottom is heated. As the
vapor rises up the column, the vapor is washed of the heavier components by the
liquid feed and returned to the liquid phase. This washed vapor fraction is a product
stream taken from the process. The fraction may be taken from a variety of heights in
the column depending upon the weight of the fraction required. The typical locations
are top, middle, and bottom. This type of distillation is called continuous fractionation
plate distillation.
The initial distillation of the raw crude oil, also known as primary distillation or
atmospheric distillation, is performed under atmospheric pressure and at a bottom
-------
temperature of 370 *C to 400 *C. The main products of primary distillation are
naphtha, light and heavy gas oil, and a bottoms fraction that is usually further pro-
cessed. The lightest fraction, naphtha, is taken from the top of the tower. The middle
fraction contains diesel, jet fuel, and home heating oil. The bottom fraction containing
the heaviest components of crude oil is usually processed further by vacuum distil-
lation to yield several valuable products.3
Vacuum distillation is the same type of process as the primary distillation, with
one distinct change: the column is operated under vacuum pressure instead of at
atmospheric pressure. Primary distillation bottoms are subjected to vacuum distillation
to increase the yield of high-value distillate oil.
Extraction is a separation process that separates by chemical type in the liquid
phase rather than by boiling point differences as is done in distillation. An extraction
solvent is introduced to the oil and the chemical species separate from the oil into the
solvent. Because of the high cost of extraction compared with distillation, extraction is
used only when distillation is not suitable. Extraction is primarily used to remove
aromatic compounds, including recovery of benzene, toluene, and xylene from
naphtha fractions. Extraction is also used to upgrade the middle distillates: kerosene,
diesel, and jet fuel, and to prepare high-quality lubricating oils from the light fraction
from vacuum distillation.3
CONVERSION PROCESSES
Conversion processes transform crude oil components such as residual oil, fuel
oil, and light ends to highly demanded high-octane gasoline. The conversion pro-
cesses used at refineries are:
Hydrocracking
Catalytic cracking
Coking
Visbreaking
Stream cracking
Alkylation
-------
Hydrocracking is a high-severity process in which high molecular weight
compounds are cracked to lower molecular weight, lower boiling compounds. The
process operates at high hydrogen pressure of approximately 1500 psig inside the
reactor and uses over 1000 cubic feet of hydrogen per barrel of crude oil. This
process is typically applied to high-quality kerosene, diesel, and jet fuels low in sulfur
and nitrogen in order to produce a naphtha product.3
Catalytic cracking was initially in use as a cyclic fixed-bed process; however,
current use is almost exclusively as a fluidized process. In the fluidized process, small
particles (20 to 200 micron) of catalyst are suspended in upflowing gas and circulated
through pipes and valves between reaction and regeneration vessels.3 This allows for
a continuous process and a transfer of heat from the regeneration to the reactor
vessel where the heat is needed by the recirculation of the catalyst. The coke burned
in the regenerator produces and releases this large amount of heat. The recirculating
catalyst is stripped with steam before regeneration to recover hydrocarbons. Tem-
peratures range from 480 "C to 510° C in the reactor to 620 "C in the regeneration
vessel.3
The catalysts typically used are a synthetic silica gel activated with 15% to 60%
AI2O3 or a more active zeolite catalyst. The zeolite catalyst can withstand higher
temperatures and is usually regenerated at 700*0 to allow for more complete oxida-
tion of carbon monoxide to carbon dioxide. To assure complete combustion of
carbon monoxide, a noble metal or other combustion catalyst is added at a parts-per-
million level in the regeneration vessel.3
The conversion of the fresh feed ranges from 50% to 90% with the use of the
zeolite catalyst yielding the higher percent conversion. Part of the feed to the process
is refractory and recycled. The typical range of the recycle flow rate is 20% to 50% of
the fresh feed.3
Catalytic cracking is used at refineries to convert heavy distillates to compounds
of lower molecular weight in the boiling range of gasoline and middle distillates. The
main objective of catalytic cracking is to increase the yield of gasoline and raise the
octane number.
-------
Coking 8s a high-severity thermal cracking distillation. Two types of coking
operations are typically used: delayed coking and fluid coking.
Delayed coking is a cyclic batch operation in which several drums of hot
vacuum distillation bottoms are held at approximately 450 'C and 5 to 10 psi to deposit
coke, while cracked vapors are taken in an overhead stream. Once the coking
process is complete in the drum, the drum must be steamed out and the coke
removed by a hydraulic cutter nozzle using water at 2030 psi.3
Fluid coking is a continuous process in which the hot vacuum distillation
bottoms are sprayed into a fluidized bed of hot coke particles. The process is
operated at 22 to 36 psi and 510'C or higher by recirculating the coke particles to a
burner vessel. The feed vaporizes in the reactor and cracks, which forms a liquid film
on the coke particle surfaces. This deposition of the liquid film on the coke particles
avoids deposition on the reactor walls and thus avoids high-maintenance costs of
delayed coking. Product coke, however, still must be removed from the system in
order to keep the average particle size in the range of 100 to 600 microns.3 Part of
the product coke removed from the system is ground and recycled to maintain the
desired particle size range in the system.
Gas, naphtha, gas oils, and coke are products from either delayed or fluid
coking. The naphtha fraction is hydrotreated and the other light olefins are used in
alkylation, both to obtain motor gasoline. The coke produced can be utilized as fuel if
SOX controls are provided in the combustion system, since the coke usually contains
as much as 50% higher sulfur content than the feed. Other special coke produced is
used in graphite production.3
Visbreaking is a thermal cracking process used to decrease the viscosity of the
heavy fuel oil to permit handling at lower temperatures. In visbreaking, the primary
distillation bottoms are heated in a furnace to approximately 480 'C and held at that
temperature for sufficient time to yield the desired amount of cracking.3 Visbreaking
yields typically 1% to 2% gas, 5% to 10% naphtha, and 20% to 30% distillate gas oil.
The bottoms of the process are usually vacuum distilled to yield a pitch that can be
used in asphalt or roofing tar.3
-------
steam cracking is a thermal cracking process operated at 800 °C to 850 °C and
slightly above atmospheric pressure. The hydrocarbon partial pressure is reduced by
adding the steam with the feed, thus yielding more olefins. The quantity of steam is
usually equal to the weight of the oil feed.3 This process is typically used to produce
olefinic raw materials for petrochemicals manufacture from feed stocks ranging from
ethane to vacuum gas oil. The typical feeds are ethane, butane, and naphtha.
Alkylation is a process that reacts olefins of 3, 4, and 5 carbon atoms with
isobutane in the presence of a catalyst to yield higher molecular weight products of
high octane. Sulfuric acid or hydrofluoric acid is used as the catalyst.
Sulfuric acid alkylation is typically operated at a temperature range of 4*C to
15 "C and at a pressure slightly greater than atmospheric. Isobutane is allowed to boil
from the reactor to control the heat of reaction; however, -chilling of the reactor is
required. The feed consisting of olefins and isobutane is injected into the reaction
emulsion via high-velocity nozzles. The mixture in the reactor is agitated with mechan-
ical stirrers. The vapor is compressed, condensed, and recycled to the reactor. A
large amount of the isobutane is also recycled to the reactor to minimize the undesir-
able side reactions that produce products of lower octane. Recycled isobutane is
obtained by fractionation of the hydrocarbon phase withdrawn from the reactor. Acid
is settled out of the liquid hydrocarbon and recycled to the reactor. Some of the acid
is replaced with fresh acid on a continuous basis. Fresh acid requirements typically
are 90 grams per kilogram of alkylation product.3
The hydrofluoric acid alkylation is operated in the same fashion as the sulfuric
system with the exception of the operation temperature and pressure. The process
temperature ranges from 25'C to 45 *C, while the pressure ranges from 101 to 145
psi to keep the hydrofluoric acid in the liquid phase.3
TREATMENT PROCESSES
Treatment processes separate petroleum products from less-desirable products
and remove objectionable elements such as sulfur, nitrogen, and oxygen. The four
upgrading treatment processes used at refineries are:
8
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• Desalting
• Hydroprocessing
• Catalytic reforming
• Chemical sweetening
Desalting is used to remove salt, clay, and other suspended solids that are
introduced into the crude oil as a result of contamination in the ground or in the tanker
during transportation. Crude oil salt concentration averages approximately 280 grams
per 100 cubic meters of crude oil. These contaminants are removed from the crude
oil by washing the crude oil with water at a temperature range of 65* C to 90° C to
decrease viscosity. Electrostatic precipitation is used to separate the wash water from
the crude oil. The desalting process may remove 95% or more of these contaminants
with no significant amount of crude oil lost.3
Hvdrotreatinq improves oil quality by removing contaminants such as sulfur,
nitrogen, oxygen, and metals. Also, unsaturated hydrocarbons are converted to
saturated hydrocarbons. The operating conditions depend on the severity of the
contamination. Under mild conditions, a fixed bed is used and operated at 200 to 300
psi and 350 °C to 400 'C without catalyst regeneration. On the other hand, severe
.conditions require 1000 to 3000 psi and 350'C to 500'C with catalyst regeneration.
The typical catalysts used are cobalt/molybdenum or nickel/tungsten of 3- to 6-
millimeter size.3
During operation, hydrogen gas is recirculated at a high rate to hold the
hydrogen sulfide content to only a few percent within the reactor. The recycle stream
typically contains 65% hydrogen. The hydrogen sulfide is removed from the gas
stream by scrubbing with a solution. Nitrogen compounds are removed from the gas
by forming ammonia, and oxygen is removed by forming water.3
Net consumption of hydrogen can range from 100 to 1000 cubic feet of
hydrogen per barrel of feed.3 The lower end of the range is the typical range for
hydrotreating. The hydrogen needed historically was provided as a by-product from
catalytic reforming, but recently the demand for hydrogen has significantly increased
9
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because of its use in sulfur controls and upgrading of heavier stocks. Therefore,
hydrogen manufacture has become an essential part of the refinery-
Mild hydrotreating removes sulfur, nitrogen, oxygen, and metals and converts
olefins to saturated compounds. Moderate-severity hydrotreating is applied to lube
stocks to remove wax or to jet and diesel fuel to saturate the aromatic compounds.
Hydrotreating is typically applied to the feed or products of catalytic cracking or on the
products of coking or thermal cracking.
Catalytic reforming is a fixed-bed process typically operated at 430'C to 520 *C
and 145 to 870 psi. A number of fixed-bed reactors typically are used in series and
the reactant streams are heated, since the reactions are endothermic. The reactions
that occur within the reactors are: dehydrogenation of cycloparaffins, hydrocracking of
paraffins, and removal of sulfur, olefins, nitrogen, and oxygen (if present). The
reactions yield hydrogen, typically 140 to 180 cubic meters per cubic meter of feed,
and Cs and greater hydrocarbons at approximately 80 to 85% by volume. The
hydrogen produced is recycled to minimize carbon deposits within the reactors.3
The catalyst typically used may be 0.5% platinum on alumina, which may also
contain rhenium or another metal. Chlorine is also added to the catalyst as a
promoter and to keep the platinum well dispersed over the catalyst surface. The
catalyst is typically replenished at a rate of 25 to 50 kilograms of feed per gram of
catalyst. Once spent, the catalyst is regenerated by burning in a low-oxygen
atmosphere.3
Catalytic reforming is applied to naphtha fractions boiling in the range of 80°C
to 230 'C to increase the octane for use in motor gasoline. Octane rating is improved
in catalytic reforming by removal of low-octane paraffins from the gasoline boiling
range. Catalytic reforming is also a source of isobutane for use in gasoline blending
or alkylation and a source of benzene, toluene, and xylene for chemicals manufacture.
Chemical sweetening processes remove mercaptans, hydrogen sulfide, and
elementary sulfur from light distillates.3 Sweetening is accomplished in three major
ways: oxidation of mercaptans to disulfides, removal of mercaptans, and destruction
and removal of elemental sulfur and sulfur compounds (desulfurization).
10
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Oxidation processes use copper chloride solutions with a low pH and air or
oxygen to wash the light distillate, typically gasoline. The process involves the
oxidation of mercaptans to bisulfides and the reduction of cupric chloride to cuprous
chloride. The cuprous chloride is then oxidized in the presence of hydrochloric acid
and oxygen or air back to the cupric state. Hydrogen sulfide and other sulfur com-
pounds are removed by a preliminary caustic wash.4
Mercaptan removal processes typically employ a caustic solution to wash the
product. The product is contacted with sodium, calcium, or magnesium hydroxide
solution of 5% to 15%. An organic agent may also be used to increase the solubility
of mercaptans in the caustic solution.4
Desulfurization is obtained by two processes: hydrotreating and solvent
extraction. Hydrotreating was previously described. Solvent extraction typically uses
sulfuric or hydrofluoric acids.4
FEEDSTOCK AND PRODUCT HANDLING
These operations include storage tanks and loading/unloading of transportation
vessels. Storage tanks come in five basic designs for feedstock and product storage:
fixed roof, external floating roof, internal floating roof, variable vapor space, and
pressure (low and high).4 Transportation vessels include tankers, barges, rail tank
cars, tank trucks, and pipelines.
AUXILIARY FACILITIES
Several processes and equipment not directly involved in the refining of crude
oil are used at a refinery. Examples of these are boilers, wastewater treatment
facilities, hydrogen plants, cooling towers, and sulfur recovery units. Products from
these are required by several process units throughout the refinery.
11
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SECTION 313 PETROLEUM REFINING CHEMICALS
Section 313 chemicals commonly used in petroleum refining can be classified
into five general categories: constituents of crude oil, manufactured products,
processed and otherwise used chemicals, metals/metal compounds, and acids. Each
category is discussed separately in this report. Each section contains a description of
how the Section 313 chemicals are used, a table summarizing releases and off-site
releases that were reported to TRI in 1990, a discussion of typical releases and off-site
transfers, and typical control practices. Also presented are methods for identifying
nonreporting facilities, a description of industry-specific and chemical-specific regula-
tions, common reporting errors, and a list of questions.
12
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CONSTITUENTS OF CRUDE OIL
Crude oil contains a wide range of saturated and unsaturated hydrocarbons,
sulfur compounds, nitrogen compounds, oxygen compounds, and metals/metal
compounds. The metals/metal compounds are described in a later section. This
section discusses the releases of hydrocarbons and ammonia-constituents of crude
oil and Section 313 listed chemicals. Table 1 presents a summary of Section 313
reported releases and off-site transfers of crude oil constituents from petroleum
refineries.
The type of crude used at a refinery will determine which of the chemicals listed
in Table 1 will be reported. In most crude oils, ammonia will be below de minimis
concentrations. These levels may be concentrated during processing or formed
during hydrotreating, however, and therefore surpass the de minimis concentration;
therefore, reporting would be required.
Crude oil is the main feed stock to a petroleum refinery. Releases of Section
313 listed constituents from crude oil can occur in the following areas.
Loading/unloading transportation vessels
Storage tanks
Leaking compressors, pumps, valves, and flanges
Flares
Catalyst regeneration
Process drains/wastewater
Tank bottoms/sludges
Wastewater treatment
These releases are primarily fugitive and point-source air releases with smaller
releases to water, land, publicly owned treatment works (POTW), and off-site transfers.
Fugitive emission sources include valves, flanges, pump seals, compressor
seals, process drains, pressure vessel relief valves, cooling towers, and oil/water
separators. Controls to minimize fugitive releases of crude oil constituents include
good operation and maintenance (O&M) procedures for the facility. Some of these
O&M procedures include: 1) regular inspection of storage tanks, process vessels,
piping, pumps, and valves to maintain structural integrity and proper operation,
13
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TABLE 1. SUMMARY OF REPORTED RELEASES OF CONSTITUENTS
OF CRUDE OIL FROM PETROLEUM REFINERIES
Section 313 chemical
Benzene
Toluene
Xylene (mixed Isoner)
Ethyl benzene
Cyelohexane
1 , 2 . 4-Tr 1 methyl benzene •
Annonla
o-Xylene
p-Xylene
m-Xylene
Number of fact 11 tie
reporting usage8
(X reporting usage!
196 (100)
189 (96)
169 (86)
163 (83)
149 (76)
125 (64)
116 (59)
25 (13)
23 (12)
22 (11)
!S
) Fugitive
19,636 (98)
38.552 (98)
26.119 (98)
6,588 (98)
8,985 (98)
9.208 (94)
26.899 (73)
13.375 (100)
22.868 (100)
20.135 (100)
Stack
13.825 (94)
23.739 (93)
14.263 (93)
3.543 (94)
5.861 (92)
3.373 (95)
106.548 (44)
8.743 (96)
20.717 (96)
10.398 (95)
Mean release,
Water
118 (41)
142 (39)
142 (36)
102 (40)
68 (33)
85 (34)
40.444 (72)
69 (40)
67 (43)
83 (45)
Ib (X reporting to each media)b
Land
10.657 (34)
2.383 (34)
6.433 (33)
1.092 (31)
436 (22)
294 (22)
17.069 (16)
292 (28)
228 (30)
196 (32)
-POTW6 Off -site transfer
4.865 (19)
5.548 (19)
3.513 (17)
774 (19)
1,621 (10)
703 (10)
82.746 (16)
896 (16)
85 (13)
253 (14)
1.548 (50)
2.778 (49)
5.646 (51)
1.251 (51)
974 (30)
4.318 (34)
2.841 (16)
1.215 (48)
773 (48)
1.732 (45)
Total**
38.501 (100)
63.874 (99)
44.803 (100)
11.021 (100)
14.787 (100)
13.738 (100)
426.024 (98)
22.604 (100)
43,164 (100)
30.981 (100)
A total of 196 facilities In SIC 2911 reported usage of at least one Section 313 chemical above threshold limits In 1990.
Mean release In pounds per year In 1990 for firms reporting releases of this chemical and percentage of firms reporting usage of this chemical that
reported release to this media. Releases to other media Mere Insignificant.
POTV • Publicly owned treatment works.
The total Includes all releases and off-site transfers, not just categories sunmarlzed In this table.
-------
2) regular equipment changes to prevent leaks, 3) off-loading of crude oil from, and
loading of products onto, transportation vessels in a manner that minimizes spills and
releases, 4) proper maintenance of heat exchangers and condensers to minimize
contamination of cooling water (thus minimizing emissions from cooling towers), and
5) covering wastewater systems such as oil/water separators and settling basins.
These fugitive releases can be estimated by utilizing established emissions factors
such as those presented in Appendix A.
Releases from storage tanks depend upon the tank type. Five basic tank
designs are used for material storage at refineries: fixed roof, external floating roof,
internal floating roof, variable vapor space, and pressure (low and high).5
Fixed roof tanks, the minimum acceptable equipment for storage of organic
liquids, are typically equipped with a pressure/vacuum vent that allows for operation at
a slight internal pressure/vacuum to prevent the release of vapors during slight
changes in temperature, pressure, and/or liquid level. This vent is the emission point
of the vapors to the atmosphere. These emissions can be controlled by the instal-
lation of an internal floating roof and seals to minimize vaporization of the contained
product, use of a vapor recovery system to collect vapors and convert them to liquids,
or thermal oxidation (incineration) of the vapors.5
External and internal floating roof tanks consist of a cylindrical steel shell with a
movable roof that floats on the surface of the contained liquid. The internal floating
roof tank, however, has a permanent fixed roof outside of the floating roof. The liquid
surface is completely covered with the exception of a small annular space between the
floating roof and the tank wall. A seal attached to the roof fills this annular space and
contacts the tank wall. This seal is the release point of emissions from external and
internal floating roof tanks. These emissions can be controlled by regular replacement
of the seals and use of multiple seals to minimize emissions.5
Variable vapor space tanks have expandable vapor reservoirs to accommodate
vapor volume fluctuations caused by temperature and barometric changes. The two
common types of variable vapor space tanks are: lifter roof and flexible diaphragm
tanks. Lifter roof tanks have a telescoping roof with a space between the roof and
15
-------
tank wall that is a trough filled with liquid or filled with a flexible coated fabric. Flexible
diaphragm tanks have flexible membranes that provide the expandable volume.
Emissions occur when the vapor storage capacity is displaced with liquid during filling
operations. These emissions can be controlled by regular replacement of the seals
and by not surpassing tank vapor capacity.
Pressure tanks are typically used for storing organic liquids and gases with high
vapor pressures. There are high and low operating pressure classes of tanks. Both
classes have a pressure/vacuum vent set to release pressure only as a safety feature.
High-pressure tanks can be operated with virtually no emissions. On the other hand,
low-pressure tanks can produce emissions by atmospheric venting during filling opera-
tions. Typical controls on low-pressure tanks are vapor recovery systems to contain
releases.
Flares can be an emission source at a refinery. Typically, flares are considered
to be 98% efficient.5 Thus, some estimation or monitoring data is required to estimate
flare releases. The refinery's process control equipment usually records process
upsets. Temperature and pressure data recorded at the time of the upset can be
used to perform mass balances to estimate the quantity of material sent to the flare.
Oil/water separators and process drains/wastewater are sources of air emis-
sions. Typically, emissions factors are used to estimate total VOC emissions from
these operations. These emissions factors are presented in Appendix A.
Catalyst regeneration can be a source of air emissions. Emissions can include
hydrocarbons, ammonia, and acids. Catalyst regeneration processes are described in
the Section titled "Metals/Metal Compounds." Controls used to minimize these
emissions are incineration of flue gases and use of high-efficiency cyclones.
Process wastewater and oil/water separators are a source of releases to water
or POTWs. Plant effluent monitoring can supply data needed to calculate these
releases. Typical controls to minimize releases include high-efficiency oil/water
separators.
Off-site transfers of crude oil constituents typically include tank bottoms and
other unusable sludges from processing and cleaning of process equipment. These
transfers are typically sent to recyclers, fuel blenders, or landfills.
16
-------
MANUFACTURED PRODUCTS
Several Section 313 chemicals are manufactured at petroleum refineries. These
chemicals are hydrocarbons produced for use as chemical feedstocks or blended into
petroleum products. Table 2 presents a summary of Section 313 reported releases
and off-site transfers of manufactured products from petroleum refineries.
The chemicals listed in Table 2 are typically manufactured in cracking proc-
esses, in coking, and in catalytic reforming. Once the feed is cracked in hydro-
cracking, steam cracking, and/or catalytic cracking, chemicals are formed into product
streams that are fed directly to storage tanks or to other processes, including chemical
sweetening and catalytic reforming. The products are then fed to storage tanks prior
to use in gasoline blending or petrochemical refining.
Releases of the products manufactured thus can occur from the conversion
processes on through product storage. These releases can occur from the following:
Loading products into transportation vessels
Product storage tanks
Leaking compressors, pumps, valves, and flanges
Flares
Catalyst regeneration
Process drains/wastewater
Tank bottoms/sludges
Wastewater treatment
These release sources are discussed in the previous section on releases of constit-
uents of crude oil. The difference between this section and the previous one, how-
ever, is that the chemicals in this section are manufactured during the process and are
not present in the feedstock crude oil. Therefore, these chemicals pass through fewer
pumps, valves, flanges, etc., than do the chemicals present in the crude oil.
17
-------
TABLE 2. SUMMARY OF REPORTED RELEASES OF MANUFACTURED
PRODUCTS FROM PETROLEUM REFINERIES
oo
Section 313 chemical
Propylene
Ethyl ene
Naphthalene
1.3-butadlene
Phenol
Cumene
Cresol (mixed Isomer)
Methyl tert-butyl ether
[MTBE]
Styrene
Blphenyl
Methanol
Number of fact 11 tic
reporting usage*
(X reporting usage
123 (63)
108 (55)
92 (47)
74 (38)
60 (31)
54 (28)
28 (14)
23 (12)f
12 (6)
10 (5)
7 (4)ft9
!S
) Fugitive
34,598 (76)
16.222 (93)
4.658 (86)
3.412 (96)
9.838 (48)
15.382 (89)
2.522 (61)
6.213 (91)
910 (92)
2.281 (80)
4.355 (100)
Mean release. Ib (X reporting to each medla)b
Stack
38.555 (61)
30.522 (51)
1.316 (77)
3.171 (49)
16.748 (35)
15.163 (76)
35 (39)
24.813 (96)
323 (67)
635 (50)
12.971 (71)
Water
192 (3)
271 (3)
96 (37)
87 (9)
3.161 (77)
59 (30)
166 (36)
1.561 (17)
65 (58)
19 (40)
5 (14)
Land
41 (1)
5(1)
3.997 (29)
1 (1)
474 (23)
272 (13)
310 (25)
430 (4)
14 (17)
0 (0)
0 (0)
POTV6 Off-site transfer
0(0)
0(0)
154 (8)
0(0)
89.481 (30)
128 (4)
6.814 (14)
35.470 (9)
10 (8)
0(0)
236.342 (29)
33 (2)
62 (2)
3.231 (55)
89(4)
e
766 (26)
1.321 (25)
191 (9)
8(25)
2.134 (50)
36 (14)
Totald
56.708 (100)
31.149 (98)
8.505 (96)
4.985 (97)
79.622 (98)
26.073 (98)
3.483 (86)
38.834 (96)
1.092 (100)
3.574 (90)
81.152 (100)
A total of 196 facilities In SIC 2911 reported usage of at least one Section 313 chemical above threshold limits In 1990.
b
Mean release In pounds per year In 1990 for firms reporting releases of this chemical and percentage of firms reporting usage of this
chemical that reported release to this media. Releases to other media were Insignificant.
POTW • Publicly owned treatment works.
The total Includes all releases and off-site transfers, not just categories summarized In this table.
Mean value Is not representative because of a very large value at one facility and the small number of facilities.
The number of facilities reporting usage as manufactured. Facilities that do not report as manufactured are not Included.
n
The total reported usage of manufactured, processed, and otherwise used Is greater than 5X of the number of facilities reporting usage.
-------
PROCESSED AND OTHERWISE USED CHEMICALS
Several chemicals are processed and/or otherwise used at petroleum refineries.
Chemicals that are processed are typically blending additives added to a product. On
the other hand, otherwise used chemicals are used at refineries in a variety of ways
including to clean and maintain process equipment. Metals/metal compounds or
acids that are processed or otherwise used are discussed in separate sections. Table
3 presents a summary of processed and otherwise used chemical releases from
petroleum refineries.
Processed chemicals are hydrocarbon compounds added as an aid in product
formulation. The following are chemical additives and their uses:
• Methano! is blended with gasoline as a gas-line antifreeze.
• Methyl tert-butyl ether, 1,2-dichloroethane, and 1,2-dibromoethane are
blended with gasoline as anti-knock agents or to increase octane levels.
• 2-methoxyethanol is blended with military jet fuel as a deicer component.
These chemicals are typically introduced in storage tanks and blended within the tank.
Thus, releases can occur from tanks, product loading/unloading of transportation
vessels, and process fittings (valves, flanges, etc.). Process controls are discussed in
the previous section titled "Constituents of Crude Oil."
Otherwise used chemicals aid in the operation and maintenance of the
petroleum refinery. Chlorine is added to process cooling water systems to control
biological fouling in the system. Chlorine is also added to maintain the platinum
dispersion over the catalyst surface of platinum-based catalysts used in catalytic
reforming. Chlorine may be released to air as a result of the handling and storage of
chlorine gas. Diethanolamine, 1,1,1-trichloroethylene, carbon tetrachloride, methyl
ethyl ketone, acetone, and glycol ethers are used as refinery cleaners. These cleaners
are used to clean tanks, reactors, and other process equipment of sludges and other
fouling materials. Diethanol amine (DEA) is also otherwise used as a scrubbing agent
in the refinery's light-ends recovery system. Uncondensed gases of five carbon
19
-------
TABLE 3. SUMMARY OF REPORTED RELEASES OF PROCESSED AND
OTHERWISE USED CHEMICALS FROM PETROLEUM REFINERIES
Section 313 chemical
Chlorine
Nethanol
Diet Hanoi ami ne
Methyl tert-butyl ether
1.1, 1-THchloroethylem
Carbon tetrachlorlde
1 . 2-D1 chl oroethane
Ethyl ene glycol
1.2-Dlbromethane
2-Hethoxyethanol
Methyl ethyl ketone
Acetone
Glycol ethers
Number of facllttU
reporting usage'
(X reporting usage
109 (56)
68 (35)C
54 (2B)
47 (24)"
37 (19)
31 (16)
25 (13)
25 (13)
23 (12)
23 (12)
21 (ID
11 (6)
11 (6)
>3
) Fugitive
1.018 (69)
5.375 (84)
2.378 (44)
9.744 (77)
6.226 (84)
1.605 (94)
513 (64)
2.635 (48)
120 (65)
644 (78)
185.803 (90)
43.011 (100)
f
Stack
4.881 (35)
2.323 (65)
103 (9)
14.810 (91)
90 (19)
226 (29)
126 (16)
f
201 (22)
350 (57)
25.388 (48)
58.880 (55)
129 (45)
Mean release.
Water
1.292 (14)
56.610 (18)
f
1.037 (28)
72 (24)
49 (13)
87 (4)
f
0 (0)
27 (13)
591 (38)
4.400 (IB)
0 (0)
Ib (X reporting to each media)6
Land
393 (2)
5.440 (7)
47 (11)
266 (9)
250 (3)
128 (6)
100 (4)
f
63 (7)
66 (17)
344 (14)
1.767 (18)
331 (18)
POTVC Off-site transfer
841 (4)
124.673 (9)
f
f
7.219 (8)
0(0)
167 (12)
22.732 (8)
250 (4)
5 (4)
0(0)
87.875 (18)
34.000 (9)
0(0)
160 (7)
117 (13)
5(2)
2.781 (14)
1.133 (10)
53 (8)
175 (8)
45(7)
0(0)
1.533 (14)
928 (18)
0(0)
•Totald
3.135 (83)
33.308 (96)
63.263 (72)
22.600 (100)
6.574 (95)
1.808 (94)
570 (68)
20.020 (68)
206 (74)
825 (87)
189.725 (95)
98.349 (100)
6.843 (64)
A total of 196 facilities In SIC 2911 reported usage of at least one Section 313 chemical above threshold limits.
Mean release In pounds per year In 1990 for firms reporting releases of this chemical and percentage of firms reporting usage of this
chemical that reported release to this media. Releases to other media Mere Insignificant.
° POTV - Publicly owned treatment works.
The total Includes all releases and off-site transfers, not just categories sumnarlzed In this table.
The number of facilities reporting usage as processed and/or otherwise used. Facilities that have reported as manufactured are not Included.
Mean value Is not representative because of a very large value at one facility and the small number of facilities.
-------
atoms or less are compressed, scrubbed with an amine to remove H2S, and then
used for liquified petroleum gas (LPG) or as fuel in refinery furnaces. Air releases of
DEA may occur through scrubber stacks or from material handling and storage.
Wastestreams containing DEA from the scrubber may be released to water or
transferred off site to a POTW. Methyl ethyl ketone (MEK) is otherwise used in solvent
separation extractions. Many refineries use MEK in azeotrophic distillation processes
to produce high quality toluene. MEK is also used to purify lubricating oils by remov-
ing wax from waxy distillates. MEK releases to air occur during distillation and from
the filtration process to remove waxes from lubricating oils.
Glycol ethers are processed as detergent additives in gasoline. Ethylene glycol
is typically used in closed refrigeration systems with a lesser amount used in fire foam
systems.
Releases of these otherwise used chemicals can occur from many pathways.
Releases of chlorine may occur from storage tanks, process water, and cooling
towers. Process water typically is discharged to water and/or POTWs, and cooling
tower emissions are released directly to the air. Releases from process equipment
cleaning chemicals are mostly fugitive emissions from evaporation of the solvents
during cleaning operations. The cleaners may also be mixed into the sludge material
cleaned from the equipment that is transferred off site. Some of the higher boiling
solvents may remain in the rinse water and be released to water and/or POTWs
through process drains and wastewater treatment activities.
Controls typically used to minimize the releases of otherwise used chemicals
include: using solvent cleaners in an enclosed environment and venting of the
hydrocarbon vapors from cleaning to a vapor collection system.
21
-------
METALS/METAL COMPOUNDS
Metals/metal compounds are processed and otherwise used in petroleum
refinery operations. Metals/metal compounds are introduced into the refinery by metal
contamination in the crude oil, as a metal catalyst used in catalytic processes, from
catalyst regeneration on site, as metal compound additives to the petroleum products,
and as metal compound additives to other process streams. Table 4 presents a sum-
mary of reported releases of metal/metal compounds from petroleum refineries.
Metal contamination in crude oil is typically from nickel and nickel compounds.
When crude oil is introduced to the refinery, the typical concentration of the nickel is a
few hundred parts per million (ppm)-well below the de minimis level. The nickel tends
to concentrate in the residuum and other heavy bottoms, however, and may become
concentrated enough to exceed the de minimis level.
Several metal/metal compound catalysts are used at a refinery. Section 313
metal catalysts include cobalt/molybdenum, nickel/tungsten, and copper chloride
solution. Cobalt/molybdenum and nickel/tungsten catalysts are used in hydretreating.
These catalysts are regenerated by burning deposits off the surface in a low-oxygen
atmosphere at 500 °C to 600 °C.3 This regeneration process can be a source of air
emissions. The regeneration off-gases typically pass through a CO boiler and
paniculate control system before being emitted. The copper chloride solution catalyst
is used in chemical sweetening to remove sulfur compounds. The off-gases from this
process typically pass through a sulfur scrubber, thus removing any entrained copper
compound. This scrubber solution, however, can be released to water and/or POTW.
Several metal compound additives are used at petroleum refineries. These
additives include barium compounds, lead/lead compounds, and manganese com-
pounds. Barium compounds (barium sulfonates or phenates) are typically detergent
additives added to lubricant products.4 Lead/lead compounds (tetraethyllead) and
manganese compounds are octane-boosting additives that may be added to motor
gasoline. These additives are typically blended with the products after the main
22
-------
TABLE 4. SUMMARY OF REPORTED RELEASES OF METALS AND
METAL COMPOUNDS FROM PETROLEUM REFINERIES
Section 313 chemical
Lead
Lead compounds
Chromium
Chromium compounds
Nickel
Nickel compounds
Zinc compounds
Molybdenum trl oxide
Manganese compounds
i*ooa 1 i compounua
Copper compounds
• Number of facilities
reporting usage'
(X reporting usage)
17 (9)
SB (30)
17 (9)
44 (22)
11 (ID
33 (17)
38 (19)
36 (IB)
23 (12)
17 (9)
13 (7)
9 (5)
Fugitive
152 (47)
197 (43)
250 (18)
2.214 (39)
110 (45)
1.044 (12)
1.068 (21)
115 (17)
137 (35)
87 (18)
e
0 (0)
Stack
223 (24)
168 (31)
3.437 (29)
6.332 (50)
1.221 (54)
415 (36)
1.319 (39)
86 (8)
953 (26)
23 (12)
67 (8)
e
Mean release,
Water
152 (29)
390 (36)
252 (76)
780 (68)
191 (50)
555 (52)
1.205 (55)
1.078 (8)
772 (35)
395 (24)
373 (62)
2.146 (56)
. Ib (X reporting to each med1a)D
Land
115 (24)
4.715 (40)
e
5.281 (55)
7.045 (27)
4.409 (39)
3.722 (39)
1.128 (17)
e
6 (35)
1.819 (38)
6.433 (33)
POTV0
153 (12)
629 (14)
2.232 (18)
2.217 (20)
338 (9)
189 (15)
3.725 (21)
0 (0)
0 (0)
0 (0)
500 (15)
0(0)
Off-site transfer
286 (76)
8.434 (59)
6.849 (71)
7.224 (75)
17.641 (77)
8.292 (70)
11.695 (55)
20.880 (22)
605 (17)
883 (53)
2.400 (46)
1.473 (56)
Total d
432 (100)
7.861 (91)
20,604 (100)
13.306 (100)
16.395 (100)
9.331 (88)
11.319 (89)
9.888 (50)
5.239 (78)
947 (76)
5.069 (85)
12.335 (78)
* A total of 196 facilities In SIC 2911 reported usage of at least one Section 313 chemical above threshold limits In 1990.
Mean release In pounds per year In 1990 for firms reporting releases of this chemical and percentage of firms reporting usage of this
chemical that reported release to this media. Releases to other media were Insignificant.
POTW - Publicly owned treatment works.
The total Includes all releases and off-site transfers, not just categories sunmarlzed In this table.
e Mean value Is not representative because of a very large value at one facility and the small number of facilities.
-------
petroleum processing units and before product storage. Thus, releases are limited to
blending tanks through product storage tanks and transportation vessels. Controls
typically used are those discussed previously for storage tank controls. Off-site
transfers are usually limited to off-spec products and spills/leaks of liquid materials.
Several metal compound additives are added to other process streams
including chromium/chromium compounds and zinc compounds. These compounds
are added to cooling water to inhibit corrosion within the system. These metals can
be released by the cooling tower and as discharges to water or POTWs. Controls
used to minimize these releases include ion exchange and precipitation processes.
These control processes can result in off-site transfers of regeneration liquids and
precipitate sludges.
24
-------
ACIDS
Several acids are used at petroleum refineries. These acids are used as
catalysts or for pH control, desulfurization, and resin regeneration. The four acids
reported to TRI in 1990 are: sulfuric, hydrofluoric, phosphoric, and hydrochloric acids.
Table 5 presents a summary of reported releases of acids from petroleum refineries.
Sulfuric acid may be used in many processes. Sulfuric acid is used as a
catalyst in alkylation, for pH control in cooling towers, and to regenerate resin beds in
boiler feed water systems. Releases can occur from these processes by leaks in
process piping, pumps, valves, etc. Spent acid streams typically are treated in the
wastewater treatment system and/or transferred off site.
Hydrofluoric acid can be used as an alternative catalyst in alkylation. Releases
and off-site transfers of hydrofluoric acid can occur in the same pathways as sulfuric
acid in alkylation.
Phosphoric acid is used in the wastewater treatment facilities. The acid is used
to adjust the pH of the water and to supply phosphorus to the biological organisms
within the system. Air releases can occur from open-top tanks, and liquid releases
can occur in the piping, valves, etc. and from spills. Off-site transfers are typically
from spills and spent acid.
Hydrochloric acid is used in chemical sweetening processes to keep the pH of
the copper chloride solution low so that the cuprous chloride will oxidize back to the
cupric state in the presence of air/oxygen. These releases are typically limited to the
sweetening process and wastewater treatment areas with potential releases to water
and POTWs. Neutralization is used to control water and POTW releases and off-site
transfers.
25
-------
TABLE 5. SUMMARY OF REPORTED RELEASES OF ACIDS
FROM PETROLEUM REFINERIES
Section 313 chemical
Sulfurlc acid
Hydrofluoric acid
Phosphoric acid
Hydrochloric acid
Number of facilities
reporting usage*
(X reporting usage)
137 (65)
60 (31)
57 (29)
38 (19)
Mean release. 1b (X reporting to each media )b
Fugitive
207 (32)
3.929 (90)
148 (19)
2.650 (37)
Stack
6.059 (22)
7.495 (40)
103 (9)
17.155 (39)
Water
164 (4)
5 (2)
363 (4)
5 (3)
Land
1.065 (9)
697 (2)
e
2.336 (5)
POTW=
940 (3)
84 (2)
0(0)
0(0)
Off-site transfer
1.171 (6)
1.264 (8)
e
1.825 (5)
Total d
3.415 (47)
7.257 (92)
44.227 (39)
12.664 (66)
A total of 196 facilities In SIC 2911 reported usage of at least one Section 313 chemical above threshold limits In 1990.
Nean release In pounds per year In 1990 for firms reporting releases of this chemical and percentage of firms reporting usage of this
chemical that reported release to this media. Releases to other media were Insignificant.
POTV • Publicly owned treatment works.
The total Includes all releases and off-site transfers, not just categories summarized In this table.
Mean value Is not representative because of a very large value at one facility and the small number of facilities.
-------
USE OF REGULATIONS TO ESTIMATE RELEASE OF SECTION 313 CHEMICALS
Two regulations that may provide assistance in estimating emissions of Section
313 chemicals are the effluent guidelines and standards governing water releases and
the standards of performance for new stationary air sources. Because the Section
313 chemical concentration is highly variable between facilities, neither set of regula-
tions is directly applicable. The regulations may require monitoring or other testing,
however, and may be used to estimate releases of the Section 313 chemicals.
WATER RELEASES
The EPA Effluent Guidelines and Standards for Petroleum and Petroleum
Refining (40 CFR 419; 47 FR 46446, October 18, 1982) provide effluent limits for
petroleum refineries. The guidelines are detailed and specific to the refinery process,
size, and type of discharge. The specific guideline for the refinery process should be
consulted to estimate the maximum allowable discharge. The guidelines are applic-
able to topping/catalytic reforming processes, cracking processes, petrochemical
operations, and lube oil operations. These guidelines apply individually and as a
separate subcategory for an integrated facility containing part or all of the above
processes. Limits have been established for discharged biological oxygen demand
(BOD), total suspended solids (TSS), chemical oxygen demand (COD), oil and grease,
phenolic compounds, ammonia as nitrogen, sulfide, total chromium, hexavalent
chromium, and pH. Separate standards are established for best practicable control
technology currently available (BPT), best available technology economically achiev-
able (BAT), best conventional pollutant control technology (BCT), pretreatment
standards for existing sources (PSES), standards of performance for new sources
(NSPS), and pretreatment standards for new sources (PSNS). The standards are also
different based on the size of the refinery (based on 1,000 bbl of feedstock
processed).
Although these standards cannot be used directly to estimate releases of
Section 313 chemicals, they can be used as a guide in permit or monitoring records.
The pH of the wastewater discharge can be used to determine releases for acids used
27
-------
at the facility if only one acid is present in the discharge. Also, oil and grease,
phenolic compounds, ammonia, and chromium regulatory standards can be used to
estimate the upper limits of the wastewater discharge. Measurements of the chem-
icals in the wastewater made by the facility to comply with the standards can be used
along with the discharge quantities to calculate water releases of these chemicals.
AIR RELEASES
State and local air regulations requiring installation and operation of pollution
controls on petroleum refineries vary widely both from state to state and within states.
Thus, the plant-specific regulation should be consulted.
The EPA Regulations on Standards of Performance for New Stationary Sources
(40 CFR 60; 57 FR 24550, June 10,1992) provide emission limits for petroleum
refineries. The guidelines are detailed and specific to the refinery process. The
specific guideline for the refinery process may be consulted to estimate the maximum
allowable emission. The guidelines are applicable to the fluid catalytic cracking unit,
catalyst regenerators, fuel gas combustion devices, all Claus sulfur recovery plants
(except Claus plants of 20 long tons per day or less), petroleum liquids storage
vessels (larger than 40,000 gallons), equipment (valves, pumps, pressure relief device,
sampling connection system, open-ended valve or line, compressors, flange, or other
connector in VOC service), and wastewater systems (process drains, oil-water
separators, and wastewater treatment facilities). There are limits for emitted paniculate
matter, carbon monoxide, sulfur oxides, and VOCs. VOC standards are established
for petroleum liquid storage vessels, equipment, and wastewater systems only.
As with the effluent standards, the emission standards cannot be used directly
to estimate releases of Section 313 chemicals. Both standards, however, can be used
as a guide to indicate possible permit or monitoring records. Also, regulatory emis-
sion monitoring for paniculate matter and VOCs can be used as the upper limits of the
waste discharge and can aid in the calculation of quantities released to the air.
28
-------
NONREPORTING FACILITIES
Nonreporting facilities may be identified by comparing lists of facilities in the
Standard Industrial Classification (SIC) 2911 having more than 10 employees with
those facilities that have reported under Section 313. Most petroleum refineries with
more than 10 employees probably are manufacturing, processing, or otherwise using
at least one Section 313 chemical in excess of threshold values. For example,
benzene, toluene, or xylene is likely manufactured or processed in excess of 25,000
pounds per year. Refineries may also otherwise use an acid in excess of the 10,000-
pound-per-year threshold.
A source of information on the number of facilities in SIC 2911 presented by
employment class is County Business Patterns published by the U.S. Department of
Commerce.6 Another source of information is Dunn and Bradstreet (D&B), which
provides lists of companies by SIC and employment size category.7 The 1990 TRI
database indicates 196 facilities reported, while County Business Patterns -1989
reports 326 facilities in SIC 2911 employing more than 10 employees and D&B -1992
reports 688 facilities in SIC 2911 employing more than 10 employees.
29
-------
LIST OF QUESTIONS
The following questions may be helpful in determining if errors were made in
Section 313 reporting for petroleum refineries.
Constituents of Crude oil
• What were the constituents of the crude oil processed at the
facility? (Compare with Table 1)
• How were the concentrations of these constituents determined?
Manufactured Chemicals
• What Section 313 chemicals were produced at the facility? (Compare
with the SRI Directory of Chemical Products List)
Are any analyses of the products available?
• What type of storage tanks and controls were in place on the storage
tanks at the facility?
Processed and Otherwise Used Chemicals
How is biological fouling controlled in the cooling towers?
• How are these chemicals processed or otherwise used?
Does the facility add de-icer or anti-knock agents to the products?
• How are releases determined for these chemicals?
Metals/Metal Compounds
• What metals/metal compounds were added to petroleum products?
• What metals/metal compounds were used as process catalysts at the
facility?
Were metals included in the threshold analysis that were not-added to
the system (i.e., fixed-bed catalysts)?
30
-------
Acids
Were acid releases to POTW and/or off-site transfers determined
by pH measurements?
• How were air releases determined for acids?
General Facility
How were the total number of process fittings determined?
Which emission factors were used to estimate releases?
How were the percent leakers of process fittings determined if SOCMI
emission factors were used?
What constituents are measured in wastewater discharged to POTW?
What chemicals does the facility manufacture, process, or otherwise use
that the facility calculated to be exempt from reporting to TRI?
What process units or storage tanks have air permit limits and what is
the total allowable VOC releases from them?
How were chemical analysis of effluents determined? (TCLP cannot be
used to determine chemical composition.)
Was monitoring data used to calculate emissions when possible?
Were hazardous and nonhazardous wastes reviewed for Section 313
chemicals?
Was the current definition of de minimis applied? (1991 and after).
Were air releases estimated from wastewater treatment? (oil/water
separators, biological treatments, etc.)
• Were air releases estimated for flares?
Were vapors from storage tanks vented to flares accounted for?
Were all accidents reported?
Were any materials (hazardous or nonhazardous) transferred off site for
treatment, recycling, or disposal?
31
-------
BIBLIOGRAPHY
1. Office of Management and Budget. Standard Industrial Classification
Manual. Washington, DC. 1987.
2. U.S. Department of Commerce. Industrial Process Profiles for
Environmental Use. Industrial Environmental Research Lab, Research
Triangle Park, NC. January 1977.
3. Kirk-Othmer Encyclopedia of Chemical Technology. Third Edition. Volume 17.
Petroleum (Refinery Processes, Survey. Wiley & Sons. 1982.
4. Nelson, W. L Petroleum Refinery Engineering. Fourth Edition.
McGraw-Hill. 1958.
5. U.S. Environmental Protection Agency. Compilation of Air Pollutant
Emission Factors. AP-42. Volume 1 Stationary and Point Source.
September 1985 plus supplements.
6. U.S. Department of Commerce, Bureau of Census, County Business
Patterns 1989, CBP-89-1 Washington, DC. 1991.
7. Dunn & Bradstreet. Dunn's Electronic Business Directory in DIALOG
database File 515. 1992.
8. Lafargue, E. and C. Barker. Effect of Water Washing on Crude Oil
Compositions. The American Association of Petroleum Geologists
Bulletin. Volume 72. Number 3. March 1988. Pages 263-276.
9. Park, S. J. and G. A. Mansoori. Aggregation and Deposition of Heavy
Organics in Petroleum Crudes. Energy Sources. Volume 10. Pages 109-
125.
32
-------
APPENDIX A
SELECTED INFORMATION AND EMISSION FACTORS
A-1
-------
10 M«M
STORMI I MWMO
Figure A-1.
Detailed Petroleum Refinery
Schematic from AP-42.5"
I DRAWING |_
** I
CHECKED BY
APPROVED BY
I DRAWING NO
M.8W015-4-I VK-3
-------
Proem
Bolwft intf proem hvAlvri,
PertlculMee
Sulfur
0* Idee
(•• SOjl
Cirbon
monoilde
Toll)
hydro*
cerbone*
Nitrogen
oildei
(•• NOj )
Altfvhydn
Ammonle
Emlulon
lietar
rating
Fuel On Sm SKllon 1 3 • Fuel Oil Combuillen
Nitunl Q|( Se* Section 1 1 - Ndurii 0« Combustion
Fluid eeleryne cracking unlit b
Uncontrolled
Ib/IOtibl Ireih leed
kg/lO> Hurt freth feed
Clecln
Millie preelplletor
end CO boiler
lb/10* bbl freth led
ko/iO» men Ireih feed
Moving-bed cetetyilc
crecklng unlti *
lb/10> bW Irnh leed
kg/IP Wort Irethfaed
FtuU CORMQ unlli
h
lb/10' bW Imh loed
ko/lo> nteri freth feed
EMclrotlellc preelplletor
end CO boner
ib/iO> bbl Irnh feed
kg/10" inert fmh leed
Oiliyvd coking unlli
Compretnr englnei '
lb/101 II' git burned
kg/10> m> get burned
On turbines
Ib/I0> H> get bumed
kg/101
||^D TEC^So*
LUCORPOIL
m> get bumed
TION
242
(93 10 340) e
0895
(0 267 to 0 978)
4S<
(7 to ISO)
0128
(0020100428)
17
0049
523
ISO
885
00196
NA
Neg
Neg
Neg
Neg
493
(100 10 525)
1 413
(0 2BB lo 1 SOS)
493
(100 to 525)
1413
(0 288 lo 1 SOS)
80
0171
NAl
NA
NA
NA
NA
2l»
321
J,
321
13.700
392
Neg>
Neg
3.800
108
NA
NA
Neg
Neg
NA
043
702
012
194
220
0630
Nig
Nig
87
0250
NA
NA
Neg
Neg
NA
1 4
216
002
028
710
137 1 to 1450)
0204
(01071004161
710'
(37 1 lo 14501
0204
(0 107 lo 0 416)
5
0014
NA
NA
NA
NA
NA
34
554
03
4 7
19
0054
Neg
Neg
12
0034
NA
NA
Neg
Neg
NA
01
161
NA
NA
54
0155
Neg
Nig
a
0017
NA
NA
Neg
Neg
NA
02
32
NA
NA
B
B
B
B
B
a
C
C
C
C
B
B
a
B
Table A- 1.
>**• Emission Factors for Petroleum
moM Refineries from Section 9. 1 of AP-42. 5
I DRAWING 1
BY |
«S* \ CHECKED BY | ?4/O 1 9/rf/ft. \ DRAWING NO
*/* 1 APPROVED BY 1 1 IMW V9M
-------
P'OCIM
Slowdown irtiinifi
Unco ftti o 1 lf)d
lb/10' bbl raiinary
few*
kg/101 Hlart rrfmary load
Viper recovery lyitam
and Hiring
Ib/lO" bbl ralinary l«td
kg/101 INari refinery laad
Vacuum dlemiilion"1
column condaniari
Uncontrolled
lb/101 bbl relinery iMd
kg/10' Mtri relinary Ittd
lb/101 bbl .aeuiirn IMd
kg/10' Mart neuum IMd
Conlronid
Claua plant ind tail gaa Iraalmanl
Particuiatai
Nag
Nag
Nig
Nag
Nag
Nag
Nag
Nag
Nag
Sullur
o»da«
(II SO; )
Nag
Nag
»9
0077
Nag
Nag
Nag
Nag
Nag
Saa lacllon S IS
Carbon
mononda
Nag
Nag
43
001}
Nag
Nag
Nag
Nag
Nag
Tolll
hydro-
Clrbonl
580
ieaz
01
0001
11
OOM
50(0-130)
0144
Nag
Nilrogan
oiidai
(II NO! I
Nag
Nag
119
OOS4
Nag
Nag
Nag
Nag
Nag
Nag
Nag
Nog
Nag
Nag
Nag
Nag
Nag
Nog
Ammonia
Nag
Nag
Nag
Nag
Nag
Nag
Nag
Nag
Nag
Err.lMion
(actor
riling
C
C
C
C
C
C
C
C
C
* Overall, tail mm 1 parcani by walghl ol lha total hydrocarbon amniloni ara malhana
b Befarencee 2 through I
c Numbari m pirantnaili Indieita ringa ol «aiuai obtarvad
d Undar Iht Naw Sourea Parlorminca Slindardl conlroNad FCC raganaralori will hiva pirlieulila tmlitioni lower Ihm U lb/101 bbl Iraih lead
Nagiigibit amnnon
May ba higher dua 10 lha eombuition ol ammonia
B Relerance 2
h Mafaranca S
I
N« NotAvlillbll
Relarancn* 10
I • Ralinary git fulfur conlenl (lb/1000 n>) Factori bnad on 100 pareani combuillon ol luilur to SO;
MalaraneM 2 11
"Ralarancai 2 12. 1]
CORPORATION
Table A-1 (Continued).
Emission Factors for Petroleum
Refineries from Section 9.1 of AP-42.'
I DRAWING I
" r
CHECKED BY
APPROVED BY
I DRAWING NO
M-8300t5-S-1-ftf92-4
-------
Emission Process Emission
Source Slr**C Factor
Tvoe Units
Pipeline valves' II o«. Ik/hr-aource
' -kg/day-source
111 ' '
•t
Open ajnde.0 valves '* 1 "
Pw»p oeala* III *
IV "
Compressor aealt It "
V
Process drains' 1
•
Pressure vessel 11 "
relief valves. . "
(gaa service)"1'
Cooling lowers - Ik/10* gal cooling
water
kg/10'' liters cool In*
water
lb/101 bbl refinery
feed*
kg/101 liters
kg/101 liter waste
water
lb/101 bbl refinery
feed
kg/101 liters refiner
feed
Storage See Section 4.)
loading See Section 4 4
*0aia from References 2. 4. 12 and 1) eicept at not
b«* - Hot Available.
The stream Identification nuocrala and group names
Streaej
Identification Slreao
Humeral Name
1 A] 1 si reaos
II Cat streams
III Light liquid and
IV Heavy liquid stream!
V Hydrogen slrejmt
Suobert in parentheses are the upper and lower bow
Jjeta fiorn Reference 17.
Title downstream aide of these valves la open 10 the
FBISSIOK Factors. _ _ rn,,,,nn
Uncontrolled Controlled Applicable Control TirhnoloRv fi.-i. r
0.059 (0.0)0 - 0. 110) HA Monitoring and maintenance prnRi.iw ,\
0.64 (0.12 - 1.19)
0 024 (0.017 - 0.0)6) HA A
0.26 (0.18 . 0.19)
0 0005 (O.OO02- 0.0015) HA *
0.005 (0.002 - 0.016)
0.018 (0.007 - 0.045) HA A
0.20 (0.08 - 0.49)
0.005 (0.0016- 0.016) HA Installation nf rap nr plug on npin end A
0.05 (0.017 - 0.17) of valve/ line
0.0005n (0.0002- 0.0025) NA Monitoring and maintenance program. A
0.0061 (0.002 - 0.027)
0.25 (0.16 - 0.17) HA Mechanical «eal>. dual Heals. puraiJ A
2.7 (1.7 - 4 0) »eal*. monitoring and malnieninn
program^, runtrollcd iltRaihini. vrni*
0.046 (0.019 - 0. II) HA A
0.50 (0.21 - 1.2)
1 4 (0.66 - 2.9) 1A hchaniral w.il-. dull KC.iU. p«ri...l \
0.11 (0 05 - 0 2)) NA »
1 2 (0.5 - 2.5)
0.070 (0 02) - 0 20) KA Traps and co.crv >
0.76 (0.25 - 2 2)
0.16 (0.10 -1.1) McRllglble Rupture dmki upvirram ol rel irf A
1.9 (1.1 - 14) valves and/or vent inn to a flare
6 0.70 Hlnimliation of hydrocarbon leak* n
inln cooling water system Hnniinring
0 7 0.01)
10 1.2
Systems
0 6 0.024
200 10
r
06 00)
id. Ovtrall, leas than 1Z by weight of the total VOX emission* are methane.
and descriptions arc
Strean Croup Urftcription
All tt reams
Hydrocarbon gas/vapor at process condition* (containing let* than W hydriigin. hi
volume)
Liquid or Rat/liquid llream with a vapor pressure ireater than that nf
kerosene (- 0 1 p»la f 100'F or 68V Pa • IB'C). based in the most vnlaiil.- >ljs<
prcaeni at * 20Z by volume
Liquid stream with a vapor pressure equal 10 or less than ihai of kerosene (-01.
ptia e lOO'F or 689 Pa (> )8*C). bated on the must volalfli cl.m prcxent at " 70.
b> vnluae
Ca« streams containing tt^re than 5U* hydlugen by volume
wit of the 95> confidence Interval for the emlitlon factor
atmosphert. Emissions are Ikrough the valve seat of the closed valve.
Table A-2.
Fugitive Emission Factors for Petroleum
Refineries9 from Section 9.1 of AP-42.5
ii
z +
jji
o
rJ
Or 1 CHECKED BY
>/tv 1 APPROVED BY
* t
>
' 1
LJ
-------
TRI FACILITY PROFILE
INK FORMULATION
by
IT Corporation
11499 Chester Road
Cincinnati, Ohio 45246
Contract No. 68-00-0020
Work Assignment No. 2-27/2-65/3-18
JTN 830015-5-1
Prepared for
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF TOXIC SUBSTANCES
401 M Street, SW
Washington, D.C. 20460
August 1992
-------
CONTENTS
Page
Figures iii
Tables iii
Section 313 Chemicals Used in Ink Formulation 12
Solvents 13
Metals and Metal Compounds 19
Other Chemicals 21
Use of Regulations To Estimate Release of Section 313 Chemicals 23
Nonreporting Facilities 24
List of Questions 26
Bibliography 27
-------
FIGURES
Number
Simplified Process Flow Diagram for Ink Formulation
Page
7
TABLES
Number
1 Estimated Raw Material Consumption in Printing Ink
Formulation, 1981
2 Estimated Solvent Consumption in Printing Ink Formulation,
1981
3 Estimated Resin Consumption in Printing Ink Formulation,
1981
4 Relationship Between Ink Type, Premixer, and Mill Type
5 Summary of Reported Releases of Solvents From Ink
Formulation
6 Uses of Typical Ink Solvents
7 Summary of Reported Releases of Metals and Metal
Compounds From Ink Formulation
8 Summary of Reported Releases of Other Chemicals From
Ink Formulation
9 Number of Establishments in SIC 2893
Page
3
3
5
9
16
17
20
22
24
in
-------
TRI FACILITY PROFILE,
INK FORMULATION
The purpose of this profile is to assist U.S. Environmental Protection Agency
(EPA) Regional Office personnel with Section 313 inspections. The profile describes
key toxic chemicals processed or otherwise used in ink formulation, describes how the
chemicals are used, and identifies key release sources. All Section 313 chemicals
reported to the Toxic Release Inventory (TRI) by more than 5 percent of the paint
formulators are presented in this profile.
For the purposes of this profile, the ink formulation industry is defined as:
SIC 2893 - Printing Ink
This Standard Industrial Classification (SIC) includes establishments primarily engaged
in manufacturing printing ink, including gravure ink, screen process ink, and litho-
graphic ink.1 Establishments primarily engaged in manufacturing writing ink and draw-
ing ink are not included. The following types of ink are specifically included:
Bronze and gold
Flexographic
Gravure
Duplicating
Letterpress
Lithographic
Offset
Printing
Screen process
The U.S. printing ink industry services two much larger industries: graphic arts
(printing and publishing) and packaging.2 The complexity and size of the graphics arts
and packaging industries have a strong bearing on the makeup and structure of the
1
-------
ink formulation industry.2 Thus, the size and distribution of printing ink formulators
follow the industry it serves. The ink formulation industry consists of about 500
establishments. This does not include about 170 blending stations operated by larger
producers at facilities of major customers or about 100 captive ink formulation opera-
tions owned by printing companies.2 Ink formulators are as geographically dispersed
as their customers, with packets of concentration around major metropolitan areas.2
The diversity of end-use markets has created a need for inks with a wide variety
of characteristics. More than 1 million individual ink formulations are developed each
year to satisfy the specific needs of the U.S. printing and packaging industries.2 An
estimated 5 million formulations are in active use at any given time, with the majority
being customized inks for specific needs.2
Printing ink is a mixture of coloring matter dispersed or dissolved in a vehicle or
carrier that forms a fluid or paste which can be printed on a substrate and dried.3
Printing inks can generally be described as mixtures of pigments dispersed in various
oils, resins, organic solvents, water, and chemical additives.2 Ingredients in inks fall
into three main categories: fluid ingredients or vehicles (also known as varnishes),
solid ingredients or pigments, and additives.2 Most inks reportedly contain at least 10
or more ingredients.2 Table 1 presents estimated raw material consumption in ink
formulation in 1981.
In the formulation of printing inks, solvents dissolve vehicle components, control
vehicle viscosity, and aid in the blending of vehicles and pigment.2 In addition,
solvents are used in printing to reduce the viscosity of flexographic and gravure inks.
The concentration of solvents in gravure flexographic and screen printing inks is much
higher than that used in letterpress and lithographic inks.2
Ink solvents fall into two general categories: hydrocarbon and oxygenated
types. Hydrocarbon solvents are aliphatic, naphthenic, or aromatic. Oxygenated
solvents include monohydric alcohols, glycols, glycol ethers, ketones, and esters.
Solvents are selected based on drying speed, printability, cost, odor, color, flam-
mability, and toxicity. Table 2 presents the estimated amounts of different solvents
-------
TABLE 1. ESTIMATED RAW MATERIAL CONSUMPTION IN
PRINTING INK FORMULATION, 19812
Type
Solvents, total
Hydrocarbon
Oxygenated
Water
Resins
Oils '(mineral, drying)
Pigments0
Additives
Total
Millions of pounds
489
298
120
68
325
295
255
35
1399
Percent of total
35b
23b
21b
18
3
100
These estimates represent the use of solvents in ink manufacture only.
Inks employing hydrocarbon solvents (except Ink oils) and oxygenated
solvents (i.e., flexographlc and gravure Inks) are sold in concentrated
form and require dilution (thinning) at press side. For the combined
total of solvent dilution at press side, an additional 75-100% of solvent
1s required.
Components of the vehicle.
c Includes carbon black, organic and Inorganic pigments, and extenders.
TABLE 2. ESTIMATED SOLVENT CONSUMPTION IN
PRINTING INK FORMULATION, 19812
Millions of pounds Percent of total
Oxygenated solvents
(alcohols, acetates, ketones, 120 24
glycols, and glycol ethers)
Hydrocarbon solvents, total
Ink oils
Mineral spirits (lacteal spirits)
Aromatlcs h
Allphatics0
Water
301
115
130
51
5
68
62
24
27
10
1
14
Total 489 100
a Almost exclusively toluene; only minor amounts of xylene are used.
Toluene is used mostly In publication gravure Inks.
b Mainly n-heptane.
-------
processed in the formulation of printing inks. These estimates do not include solvents
used at press side for thinning.2
An additional 75 to 100 percent of hydrocarbon and oxygenated solvents are
used in press side to dilute flexographic and gravure inks concentrates prior to use.
Of the oxygenated solvents, alcohols account for the greatest share followed by
acetates, ketones, and then glycols and glycol ethers. Ethyl, n-propyl and isopropyl
acetates are the main esters used in inks. MEK is the predominant ketone with
acetone, MIBK, and isophorone used to lesser extents. Ethanol is the major alcohol,
but n-propanol and isopropanol are also used.2
Resins used in printing inks influence hardness, gloss, adhesion, and flexibility.
Both natural and synthetic resins are used in ink vehicles and varnishes. Table 3
presents the estimated amounts of resins processed in the formulation of printing
inks.2
Pigments are used not only for color but also to produce other physical proper-
ties such as bulk, opacity, specific gravity, and viscosity.3 The most common
pigments used in ink formulation are:3
Black pigments - primarily carbon black.
White pigments - including titanium dioxide, zinc sulfide, and zinc oxide
(extenders).
Transparent pigments (extenders) - including alumina hydrate,
magnesium carbonate, calcium carbonate, barium sulfate, and clay.
Inorganic color pigments • including lead chromate, chrome orange,
molybdate orange, cadmium yellow/orange/red, cadmium-mercury red,
and iron blue (a complex cyanide).
Organic color pigments - including yellow Lakes (dyes deposited on
• alumina hydrate), Hansa yellows (from ozo dyes), orange pigments
(dianisidine orange, benzidine orange, and Persian orange), and red
pigments.
Blue pigments - including peacock blue, victoria blue, alkali blues.
-------
TABLE 3. ESTIMATED RESIN CONSUMPTION IN
PRINTING INK FORMULATION. I9812
General type
Rosin ester adductsa
Metallized ros1nsb
(metal res 1 nates)
Hydrocarbon resins0
Alkyds
Acryl ics
Nitrocellulose
Poly amides
Miscellaneous
Total
Millions of pounds
90
55
47
37
28
10
10
48
325
Percent of total
27
17
15
11
9
3
3
15
100
a In general, rosin esters are Important components of rapidly drying
heatset Inks.
Zinc and calcium resinates are mainly used In gravure Inks for
publication printing.
c In news Inks, hydrocarbon resins are replacing rosin-based compounds.
Hydrocarbon resins are used extensively in lithographic and letterpress
vehicles and a little in publication gravure Inks.
-------
Purple pigments • including methyl violet.
Green pigments • including phythalocyanine and green lake.
Additives such as driers, waxes, lubricants, reducing oils, antioxidants, gums,
starches, and surface-active agents are used in printing inks to impart special char-
acteristics.2 Driers are soaps of cobalt, manganese, and lead formed with organic
acids such as linolenic, naphthenic, and octanoic acids.3 Some additives are incor-
porated directly into the vehicle during cooking, some may be added during com-
pounding in the ink, while others can be added to the finished ink in the pressroom.2
Figure 1 presents a simplified process flow diagram of ink formulation. The
basic raw materials, such as mineral oil and solvents, are supplied in tanker loads and
are unloaded into bulk storage tanks adjacent to the ink manufacturing facility.2 The
oils or solvents are then pumped and metered into mixing tanks where other liquid
ingredients are added in a similar manner.2 Resins may also be added. Vehicle
preparation can involve polymerization of resins or involve only cold dissolving of
vehicle solids in appropriate solvents.3 Therefore, vehicle preparation equipment may
include autoclaves for polymerization reactions or high-speed mixers for simple
dissolving.3
Varnish or vehicle preparation by heating is by far the largest source of ink
manufacturing VOC emissions.4 The ink "varnish* or vehicle is generally cooked in
large kettles at 200* to 600 *F for 8 to 12 hours in much the same way that regular
varnish is made.4 Cooling the varnish components (resins, drying oils, petroleum oils,
and solvents) produces odorous emissions. At about 350 'F, the products begin to
decompose, resulting in the emission of decomposition products from the cooking
vessel.4 Emissions continue throughout the cooking process with maximum emissions
occurring just after maximum temperature is reached.4 Emissions of VOCs from
vehicle cooking can be reduced by more than 90 percent with the use of scrubbers or
condensers followed by afterburners.4 Compounds emitted from the cooking of oleo-
resinous vamish (resin plus varnish) include water vapor, fatty acids, glycerine,
acrolein, phenols, aldehydes, ketones, terpene oils, terpenes, and carbon dioxide.4
-------
Resins—
I —
} —
! —
I
vt
St
i
•
•
Vehicle
Preparation
Vehicle
Pre-Mix
Storage
Ink
Storage
n
-»•
Pre-Mix
Milling
Resins —
Additives —
Packaging/
Shipping
. Final
Product
Figure 1. Simplified process flow diagram for ink formulation.
I DRAWING I
" r
CHECKED BY
APPROVED BY
I DRAWING NO
S-83001B-S-I-MZ-4
-------
Emissions of thinning solvents used in flexographic and rotogravure inks may also
occur.4 The quantity, composition, and rate of emissions from ink manufacturing
depend upon cooking temperature and time, ingredients, method of introducing addi-
tives, degree of stirring, and extent of air or inert gas blowing.4
Once these operations are complete, the vehicle may be pumped to a premix
tank where solid materials such as pigments or resins are added. The solid materials
are generally purchased in bags or other containers, and formulations correspond to a
number of full bags to avoid problems with solids weighing and handling.2
The unground ink is then pumped or gravity fed into the mixture or milling
equipment. During the transfer, the premix may be filtered. Although printing inks
vary greatly in composition and properties, only two mechanical means produce
dispersions-mixing and milling. Mixing is a mechanical blending of pigment and
vehicle that is continued until no dry pigment is visible.2 Milling is a mechanical
process that reduces particle size by cleavage or fracture of the particle.
The process of dispersion occurs in three stages, but in practice these stages
may overlap.2 The primary stage is the wetting of the pigment by the vehicle. The
efficiency of this operation depends on the nature of the pigment and vehicle and the
mechanical equipment used. During the second stage, the easily broken aggregates
are reduced. Thus, stage two requires the application of considerable mechanical
force. A notable increase in viscosity occurs during stage two because the break-
down of pigment agglomerates leads to an increase in pigment surface area that
absorbs more vehicle. The third stage is the completion of wetting and separation of
particles so that no flocculation or reassemblage occurs.2
Table 4 presents a simplified relationship between ink type, premixer char-
acteristics, and mill type. Dispersion equipment is classified as follows:
Low-shear equipment including pug mill, planetary mixers, and two-blade
mixers.
High-shear dispersers including cavitation mixers, Kady mill, and high-tip-
speed impellers or rotors.
8
-------
Ball mills - including sand mills, Perle mills, and attrtors.
Roll mills - including single or multiple roll mills.
TABLE 4. RELATIONSHIP BETWEEN INK TYPE,
PREMIXER, AND NILL TYPE2
Ink product
characteristic
Viscous paste Ink
Medium-viscous paste Ink
Low- viscous paste Ink
Liquid Inks
Pigmented
Dye-based
Premixer characteristic
Low shear
High shear
High shear
High-shear
High-speed stlrrer
Mill type
Roll mill
Roll mill,
Bead mill
Ball mill
Bead mill,
bead mill
micromill
Pigment aggregates are broken down by three types of mechanical forces:
impact, pressure, or shearing. Application of pressure crushes aggregates, while
impact shatters them on collision. Shearing action results when parallel layers of
material are flowing at different speeds. Each of these effects is strongly dependent
on viscosity.
The various types of mixers and mills used in ink production include:8
Premixer-The use of lower viscosity inks and more easily dispersed pigments
has lead to the increased use of the vertical mixer over the horizontal blade mixer.
Low-Viscosrtv-Mixer-Low-viscositv inks, such as those for the high-speed web
process and pre-mixes for liquid inks for shot mills, are generally handled by mixers
that consist of an impeller in a cylindrical mixing tank. The ratio of impeller to tank
diameter and to depth of the tank are important to ensure optimum results. The
design of the impellers varies from the simplest form, which is a disk, to the most
widely used impeller, which is the saw tooth design. These mixers cannot handle hard
aggregates and are most efficient with medium-viscosity systems using easy
dispersing pigments. Most of the energy is applied by forming viscous shear between
fluid near the impeller and fluid in the outer areas of the tank.2
9
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Medium viscosity mixer-Medium-viscositv mixers rely on high shear produced
by a rapid stirring action. The same basic machines used for low-viscosity mixing may
be used with some modifications. The low flow properties of the medium-viscosity
products may result in dead zones in regions of the mixing vessel. In a twin-shaft
disperser, a slow-speed agitator clears the sides and bottom and feeds the mix into
one or more high-speed rotors operating off center. Other types of medium viscosity
mixers have two counter-rotating shafts with projections mounted down their length to
provide shearing action.2
High-Viscostty-Mixer-Twin-blade Z-arm mixers are the most common premixers
in the paste ink industry. In operation, two gear-driven Z-shaped blades rotate in op-
posite directions, usually at different speeds, and almost scrape the bottom and sides
of the mixer. This type of mixer is capable of mixing extremely viscous materials and
relies on high viscosity for its shearing action. The mix is kneaded as the blades
rotate resulting in strong internal shear forces. A buss kneader is another example of
heavy-duty mixing equipment. These machines work on the same principle as the
worm drive. A series of projections along the chamber provide a kneading action as
the mix is forced along the chamber length. Machines with twin screws running
parallel are also available.8
Ball Mills-The ball mill was the principal machine for dispersing pigment in the
news inks, photogravure inks, flexographic inks, and roller coatings. With the develop-
ment of easy-disperse pigments and advances in the dispersion machine, however,
ball mills have declined in use. A ball mill is a hollow cylinder that rotates on a hori-
zontal axis. This cylinder is partly filled with the material to be mixed and .steel or
ceramic balls. The balls roll and cascade over each other during cylinder rotation,
thereby crushing and shearing the ink components. Several advantages of ball mills
are the simplicity of design and operation, easy loading of raw materials in a single
charge, tow labor requirements, easy discharge, and uniformity of product. These
mills are often noisy, large and difficult to dean, however, and have low production
rates.
10
-------
The pigment/vehicle mixture significantly affects the performance of the ball mill
because milling efficiency is strongly dependent on the mixture viscosity. Several
modifications have been made to deal with the slow dispersing speed of the ball mill.
These modified ball mills use a stationary vessel and move the mixture and balls,
pebbles, or sand by agitation. These mills are advantageous because the smaller size
grinding media lead to better dispersing efficiency. Also, these mills can operate con-
tinuously. The high-speed agitator bead mill is the predominant method for manufac-
turing newspaper ink, which is generally a dispersion of carbon black in a mineral oil
vehicle system.
Roller Mills-The main function of the roll mill is to complete and refine the total
dispersion process begun at the premix stage. Roller mill dispersion is produced by
the differential speeds of the roller surfaces, together with the pressure exerted
between the rolls. Multiroll mills are more effective with viscous products because the
shearing forces increase proportionally with an increase in viscosity. Modern roll mills
use three rollers. The three-roll mill is the basic machine for letterpress and offset ink
production.
When the milling operation is complete, inks of moderate to low viscosity may
undergo a finer filtration step. The finished ink is then pumped or gravity fed into
storage tanks for transfer to tanker truck or rail car for delivery. Small batches of ink
may be transferred to totes, drums, pails, or smaller containers for labeling and ship-
ment.
11
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SECTION 313 CHEMICALS USED IN INK FORMULATION
Section 313 chemicals commonly processed or otherwise used in ink
formulation can be classified into three distinct categories: solvents (chlorinated and
organic), metals and metal compounds, and other constituents. Each category is
discussed separately in this report Each contains a description of how the Section
313 chemicals are used, a discussion of typical releases and off-site transfers, a table
summarizing releases and off-site transfers that were reported to the Toxic Release
Inventory (TRI) in 1990, a description of industry-specific and chemical-specific regula-
tions, typical control practices, and common reporting errors. Methods for identifying
nonreporting facilities and a list of questions are also presented.
12
-------
SOLVENTS
Solvents are both processed and otherwise used by ink formulators. Solvents
are primarily processed as a constituent of the ink. Solvents are also otherwise used
as cleanup solvents throughout the formulation process. Solvents may be organic or
chlorinated and are received by drum, tote, tanker truck, or rail car.
For solvents processed in ink formulation, solvents may be released during
vehicle preparation or during mixing/milling/packaging operations. For those ink
formulators that have vehicle cooking, AP-42 presents the following uncontrolled VOC
emission factors for vehicle cooking: general (6%), oils (2%), oleoresinous (7.5%), and
alkyds (8%).4 The uncontrolled emission factors are a percent of vehicle produced.
The VOC emissions from vehicle cooking are a mix of volatilized vehicle components,
cooking decomposition products and ink solvent.4 No breakdown was found to
indicate that emissions other than solvent emissions are Section 313 chemicals.
No emission factor was found to estimate the solvent releases from mixing,
milling, or packaging operations. Because the process is similar to paint formulation,
however, AP-42 was used to estimate a 1 to 2 percent release to air even under well-
controlled conditions.4 The primary factors affecting solvent air emissions from ink for-
mulation are the vapor pressure of the solvent, care in handling, enclosure of the for-
mulation equipment, mixing temperature, and air movement near open tanks or pack-
aging equipment. Air releases may be either fugitive or stack depending if local ex-
haust ventilation is used to reduce potential worker exposure to solvents. Fugitive air
releases can also occur from spills that are allowed to evaporate. The manufacture of
water-based inks containing solvents (e.g., glycol ethers, methanol) may result in
releases to water or POTW when equipment is washed with water and then sewered.
Off-site transfers occur from ink residues in cleaning solvent and disposal of off-spec
ink. Land releases are not common, but can occur through spills. Small quantities of
solvents may also be contained in dirty filters or ink sludge generated during cleaning
operations.
13
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Some of the solvent otherwise used to dean equipment is lost to air during
cleaning while the remainder is typically transferred off site for recycling, use as a fuel,
or for treatment and disposal. Releases of solvents otherwise used as a cleaning sol-
vent may be best determined through mass balance calculations with almost all of the
usage either released to air or transferred off site. The quantity transferred off site for
recycling or fuel burning was not reportable under Section 313 until 1991 (estimates
due Jury 1.1992).
When solvent-based cleaning solvents are transferred off site, they may be
classified as a RCRA waste based upon one of the following criteria:
K086 - Contain solvent washes and sludges, caustic washes and sludges,
or water washes and sludges from cleaning tubs and equipment
used in the formulation of ink from pigments, driers, soaps, and
stabilizers containing chromium and lead.
F002 - Contain a total of 10 percent or more (by volume) prior to use of
one or more of the following solvents: tetrachloroethylene,
methylene chloride, trichloroethylene, 1,1,1-trichloroethane, chloro-
benzene, 1,1,2-trichloro-1,2,2-trifluoroethane, orthodichloro-
benzene, trichlorofluoromethane, and 1,1,2-trichloroethane.
F003 - Contain a total of 10 percent or more (by volume) prior to use of
one or more of the following solvents: xylene, acetone, ethyl
acetate, ethylbenzene, ethyl ether, MIBK, n-butyl alcohol, cyclo-
hexanone, and methanol.
F005 - Contain a total of 10 percent or more (by volume) prior to use of
one or more of the following solvents: toluene, MEK, carbon
disulfide, isobutanol, pyridine, benzene, 2-ethoxyethanol, and 2-
nitropropane.
Off-site transfers of RCRA-classified waste can best be calculated from RCRA
manifests and analysis by the company receiving the waste.
K086 wastes include solvent washes and sludges, caustic washes and sludges,
or water washes and sludges from cleaning tubs and equipment used in the formula-
tion of ink from pigments, driers, soaps, and stabilizers containing chromium and
lead.5'6 Best Demonstrated Available Technology (BOAT) is defined for two sub-
14
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categories: wastewater (caustic/water washes) and nonwastewater (solvent washes).
BOAT standards for the regulated organics and cyanides in K086 nonwastewaters are
based on incineration.5-6 BOAT treatment standards for the regulated metals in all
K086 wastes are based on hexavalent chromium reduction to trivalent chromium
followed by lime precipitation and sludge filtration with sludge stabilization.
BOAT standards for cyanide in wastewaters is based on cyanide oxidation.
BOAT for organic wastewater K086 wastes is incineration, wet air oxidation, or chem-
ical oxidation followed by carbon adsorption, biological treatment, or steam stripping.5-6
Table 5 presents a summary of Section 313 reported releases and off-site
transfers of solvents at ink formulators, based on Section 313 reporting for 1990. As
expected, solvents such as toluene, MEK, and xylene that are both processed as paint
solvents and otherwise used in cleaning solvents are the most widely reported
solvents.
Table 6 presents a description of the specific uses of ink solvents in ink for-
mulation.2 The solvents are presented in order of their reported usage in the TRI data-
base in 1990.
Air releases of solvents can be reduced by enclosure of the mixing, packaging,
and cleaning operations and through management practices that minimize spills or the
quantity of cleanup solvent necessary.
Equipment cleaning wastes can be reduced through source reduction by reduc-
ing the frequency of required cleaning or reducing the quantity of cleaning solvent.
Scheduling for long production runs, use of dedicated equipment, or scheduling
batches from light color inks to dark color inks can also reduce the need for cleaning.
Recycling and reuse of cleaning waste can substantially reduce waste volumes.
Cleaning wastes may be: 1) collected and used in the next compatible batch as part
of the formulation, 2) collected and recycled on or off site, or 3) collected and reused
as a cleaning solvent by filtering or other means of solids removal.
15
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O)
TABLE 5. SUMMARY OF REPORTED RELEASES OF SOLVENTS
FROM INK FORMULATION
Mean release. 1b (X reporting to each nedla)b
Section 313 chemical
Toluene
Glycol ethers
Methyl ethyl ketone
Nethanol
Xylene (mixed Isomer)
Acetone
1.1,1-Trlchloroethylene
Ethyl ene glycol
Dlchloronethane
Methyl Isobutyl ketone
Number of
facilities
reporting usage*
(X reporting
usage)
74 (94)
49 (62)
30 (38)
29 (37)
27 (34)
13 (16)
13 (16)
10 (13)
6(8)
5 (6)
Fugitive
10.547 (92)
509 (80)
e
1071 (90)
675 (96)
e
e
114 (90)
1556 (100)
24.215 (100)
Stack
14.780 (82)
952 (67)
13.902 (80)
1681 (90)
1452 (85)
e
e
87 (30)
2748 (67)
e
Water
0(0)
15(2)
0(0)
0(0)
15(4)
0(0)
0(0)
0 (0)
0(0)
0 (0)
Land
33(4)
13(4)
20(3)
20(3)
20(4)
20 (8)
20(8)
0(0)
0(0)
0(0)
POTtr5
148 (3)
286 (24)
0(0)
875 (7)
5(7)
0(0)
0(0)
370 (20)
0(0)
0(0)
Off-site
transfer
14.957
1809 (65)
11.658 (70)
1871 (62)
2802 (44)
6442 (23)
e
417 (30)
393 (33)
9.020 (60)
Total*1
30.370 (100)
2347 (98)
e
3690 (100)
3135 (100)
14.892 (92)
22.907 (100)
364 (90)
3519 (100)
38.971 (100)
A total of 79 facilities In SIC 2893 reported usage of at least one Section 313 chemical above threshold limits.
Mean release In pounds per year In 1990 for firms reporting releases of this chemical and percentage of firms reporting usage of this chemical
that release to this media. Releases to other media Mere Insignificant.
° POTW • Publicly owned treatment works.
The total Includes all releases and off-site transfers, not just categories summarized In this table.
Mean value Is not representative because of a very large value at one facility and the small number of facilities.
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TABLE 6. USES OF TYPICAL INK SOLVENTS2
Solvent
Main resin types for which solvent Is useful
Other remarks
Toluene
Slycol Ethers
Ethylene Glycol Nonomethyl Ether
(Methyl Glyeol. Methyl Cellosolve)
Ethylene Glyeol Nonoethyl Ether
(Ethyl Glycol. Cellosolve)
Ethylene Glyeol Nonobutyl Ether
(Butyl Glycol. Butyl Cellosolve)
Dlethylene Glyeol Nonoethyl Ether
(Hydroxyethoxyethyl Ether. Carbltol).
Dlethylene Glycol Monobutyl Ether
(Butyl Olgol. Butyl Carbltol)
Methyl Ethyl Ketone (MEK)
Methanol
Rubber, chlorinated rubber melamlne. urea
formaldehyde, phenolIcs. ethyl cellulose.
res1nates, ester gum, polyvlnyl acetate, and
polystyrene.
Nitrocellulose, cellulose, acetate, vinyl
acetate. CAP, shellac, rein, spirit soluble
rolelc resins and various rosin derivatives.
Same as for methyl cellosolve except for
cellulose acetate and proplonate.
Nitrocellulose, ethyl cellulose, epoxy resins,
alkyds, phenolIcs. malelcs. shellac, ester gum.
and chlorinated rubber.
Shellac, nitrocellulose, epoxy resins, and
PVAC.
Nitrocellulose. PVAC. Only partly dissolves
shellac and ester gum.
Similar to acetone except for cellulose acetate
for which NEK Is not a very good solvent.
No Information found but probably water-based
Inks.
Used extensively In gravure Inks (for which
special low-odor grades are available).
Mlsclble with water, aromatic hydrocarbons, and
some aliphatic hydrocarbons. Viewed as a slow
evaporating solvent for flexographlc and
gravure Inks, but as fast solvent for air-
drying screen Inks.
Mlsclble with water, hydrocarbons, and castor
oil. Used as a main solvent In screen Inks and
as a retarder In liquid Inks.
Mlsclble with water, linseed oil. and hydro-
carbons. Used In screen and letterset Inks.
Mlsclble with water. Used In letterpress, dry
off-set, and screen Inks. Also used In textile
printing.
Mlsclble with water and hydrocarbons. Inks
containing this solvent are slower setting but
have better press stability than those based on
carbltol.
Completely mlsclble with linseed and castor
oils, and with most organic solvents. Main use
Is In gravure Inks. Often used as a substitute
for ethyl acetate In nitrocellulose lacquers.
Mlsclble with water.
(continued)
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TABLE 6 (CONTINUED)
Solvent
Main resin types for which solvent la useful
Other
rks
Xyli
09
Acetone
l.l.l-Trlchloroethylene
Ethylem glyeol
Dlchloromethane
Methyl Isobutyl Ketone (NIBK)
Solvency It similar to toluene, except that It
Is a poor solvent for polyvtnyl acetate. It
«11I penetrate treated polythene and PVC.
Cellulose acetate, nitrocellulose, ethyl cellu-
lose, CAB. CAP, PVAC. PVC, ester gum. and many
other natural and synthetic resins. (It also
penetrates methyl mthacryate and polythene.)
No Information found.
Gelatin, dextrin. ie1n, and ml etc or fumarlc
resins of high acid value.
No Information found.
Nitrocellulose, ethyl cellulose. CAB. PVC.
PVAC. vinyl copolymers. acrylics, chlorinated
rubber, polyurethane, phenol Ic,\ and epoxy
resins.
A mixture of the ortho- mea- and para-learners.
Its slow evaporation rate (half that of
toluene) limits Its use to gravure proofing and
sheet-fed gravure Inks. Its excellent
solubllltlng ability for many resins makes It a
useful solvent for the removal of dried Ink
films.
Mtsclble with water, hydrocarbons, and natural
oils. Occasionally used In flexographlc and
gravure Inks as a rapid evaporating solvent.
Can also be used In lacquers. Too volatile for
most applications, though.
May be In Ink formulation but primarily used In
products for Ink cleanups.
Very hygroscopic: la mlsclble with water.
alcohol and some ketone solvents. Used In
moisture-set Inks and water-reducible letter-
press Inks. (The relatively rapid evaporation
rate leads to poor press stability.)
May be used In Inks formulation, but primarily
used In products for Ink cleanup (e.g., blanket
wash sold to printers.)
Mlsclble with most solvents and ells (not
water). Used In gravure and screen Inks.
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METALS AND METAL COMPOUNDS
Metals and metal compounds are processed by ink formulators as solid consti-
tuents in inks. The metal/metal compounds are primarily processed as pigments but
may also be part of metallized rosins (e.g., zinc resinate). Metal/metal compounds
reported by more than 5 percent of ink formulators in 1990 include barium, copper,
lead, chromium, and zinc. Table 7 presents a summary of Section 313 reported re-
leases arid off-site transfers of metals/metal compounds at ink formulators, based on
Section 313 reporting for 1990.
Metals and metal compounds are typically received in dry form. According to
AP-42 estimates, 1 percent of pigments handled in dry form during uncontrolled opera-
tions will be lost to air during transfer. Air releases may be easily controlled with a
baghouse when local exhaust ventilation is used to reduce worker exposure to the
pigments.
The primary releases are off-site transfers of pigments in the cleanup solvent,
filter disposal, and disposal of off-spec ink.
The next largest release is to POTW. Most of this release is comprised of pig-
ments contained in wash water from cleaning equipment used to make water-based
inks. Some POTW releases could also result from spills that are sewered. The use of
dedicated equipment and reuse of wash solvent in the next ink batch can all reduce
the POTW release of pigments during cleaning.
Air releases during the transfer of dry pigments can be fugitive or stack, based
on whether local exhaust ventilation is used to reduce worker exposure to the
pigments.
19
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TABLE 7. SUMMARY OF REPORTED RELEASES OF METALS AND METAL COMPOUNDS
FRON INK FORMULATION
Mean release. Ib (X reporting to each media)1*
Section 313 chemical
Barium
Copper
Lead
cnroMi UM coMpounos
Chromium
Zinc compounds
Zinc (fume or dust)
Number of facilities
reporting usage8
(X reporting
usage)
52 (66)
7(9)
33 (42)
7(9)
17 (22)
3(4)
14 (18)
3(4)
13 (16)
5(6)
Fugitive
103 (31)
82 (57)
5(30)
250 (14)
432 (35)
145 (67)
155 (36)
180 (100)
167 (23)
250 (20)
Stack
31 (35)
3(57)
68(24)
26 (66)
304 (47)
250 (33)
64 (29)
250 (33)
65 (31)
64 (100)
Water
0(0)
250 (14)
0(0)
250 (14)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
Land
378 (4)
0(0)
5(3)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
0(0)
POTtf*
56 (15)
2280 (14)
128 (21)
1850 (14)
5(6)
0(0)
0(0)
0(0)
0(0)
0 (0)
Off -site
transfer
633 (52)
2153 (88)
407 (30)
730 (71)
870 (76)
255 (67)
547 (79)
380 (67)
1029 (85)
603 (80)
Tota1d
554 (71)
2255 (100)
372 (45)
1026 (86)
1021 (94)
350 (100)
542 (93)
517 (100)
1006 (92)
597 (100)
A total of 79 facilities In SIC 2893 reported usage of at least one Section 313 chemical above threshold Units.
Mean release In pounds per year In 1990 for firm reporting releases of this chemical and percentage of firms reporting usage of this
chemical that release to this Media. Releases to other media were Insignificant.
POTV • Publicly owned treatment works.
The total Includes all releases and off-site transfers, not Just categories swnarlzed In this table.
-------
OTHER CHEMICALS
Table 8 presents a summary of Section 313 reported releases and off-site trans-
fers of other chemicals, based on Section 313 reporting for 1990. Dibutyl phthalate is
used as a plasticizer in liquid inks and lacquers.2 The purpose of the plasticizer is to
make the dried print more flexible and pliable.2 Release or off-site transfer of dibutyl
phthalate was reported by 13 percent of ink formulators; off-site transfer was most
commonly reported. Air releases, both fugitive and stack, were also commonly
reported.
Although no information was found on the use of ammonia in ink formulation,
ammonia likely is an additive in water-based inks. Use was reported by 13 percent of
ink formulators.
If ammonia is received in gaseous form, air releases can result from storage
and transfer. Ammonia in aqueous form or in water-based ink is released to air from
open tanks and packaging. Off-site transfers and releases to water, POTW, or land
result from cleaning or spills. These releases/transfers can be determined by the
percentage of ammonia listed on the MSDS for the ink.
Because ammonia is a listed Section 313 chemical, all gaseous and aqueous
forms must be considered for reporting. Aqueous solutions of ammonia contain both
nonionized ammonia (NKy and ionized ammonia (NH4+). As the following chemical
equation shows, the two forms of ammonia are in equilibrium in the presence of water.
NH3 + 2H2o - NH; + OH- + H2o
The term "total ammonia' refers to the sum of these species (Le., NH3 + NH4*).
The relative amounts of NH3 and NH4* depend upon several factors (e.g., tempera-
ture, pH, tonic strength, and other chemical reactions). To account for all forms that
are present, Section 313 releases should be estimated for total ammonia.
21
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TABLE 8. SUMMARY OF REPORTED RELEASES OF OTHER'CHEMICALS
FROM INK FORMULATION
Section 313 chemical
Otbutyl phthalate
Ammonia
Number of
facilities
reporting usage8
(X reporting
usage)
10 (13)
10 (13)
Fugitive
138
594
(60)
(100)
Stack
390 (30)
940 (90)
Mean release,
Water
0(0)
0(0)
Ib (X
reporting
land
0
0
(0)
(0)
to each media)0
POTV6
0(0)
280 (50)
Off -site
transfer
586 (90)
462 (50)
Total
727
1811
d
(100)
000)
A total of 79 facilities In SIC 2893 reported usage of at least one Section 313 chemical above threshold limits.
Mean release In pounds per year In 1990 for firm reporting releases of this chemical and percentage of firm reporting usage of this
chemical that release to this media. Releases to other media were Insignificant.
POTW • Publicly owned treatment works.
I
The total Includes all releases and off-site transfers, not Just categories summarized In this table.
-------
USE OF REGULATIONS TO ESTIMATE RELEASE OF SECTION 313 CHEMICALS
Regulations pertaining to ink formulators do not provide direct assistance in
estimating emissions of Section 313 chemicals.
WATER RELEASES
The EPA Effluent Limitations Guidelines for Ink Formulation (40 CFR 447) define
the best available technology economically achievable for oil-based solvent wash as
no discharge of process wastewater pollutants to navigable waters. New source per-
formance standards are the same. Pretreatment standards for the same source are
no discharge of process water pollutants to a POTW. These standards apply only to
facilities in which tanks are used to formulate oil-based inks. These regulations are not
particularly useful for estimating water releases because the most likely water/POTW
discharge of solvents and metal/metal compounds is from water washing of equip-
ment used to make water-based inks and most ink formulators formulate both solvent-
based and water-based inks. Monitoring of discharges may be required by the POTW
for TTO (total organics listed in 40 CFR 413.02(i)) or metals.
AIR RELEASES
No national regulations directly limit air releases of VOCs or other pollutants
from ink formulation. The State Implementation Plans for some noncompliance areas
may have plant-specific VOC limits that apply to large facilities. Regulations governing
the printing industry have caused some ink formulators to reformulate coatings to
reduce the VOC content in the ink they produce. Because VOC regulations are not
particularly useful in helping to predict releases of Section 313 chemicals from ink
formulators, each plant must be assessed individually based on the products they
produce.
23
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NONREPORTING FACILITIES
Nonreporting facilities may be identified by comparing lists of facilities in
Standard Industrial Classification (SIC) 2893 having more than 10 employees with
those facilities that have reported under Section 313. Most if not all ink formulators
with more than 10 employees would process in excess of 25,000 pounds of at least
one solvent or metal/metal compound (approximately 55-60 drums of the chemical).
This would be true even for water-based ink formulators.
Sources of information on number of establishments in SIC 2893 presented by
employment class include County Business Patterns, published by the U.S. Depart-
ment of Commerce,7 and Dunn and Bradstreet (D&B).8
Table 9 presents a comparison of the number of facilities listed in various
sources with the number of facilities reporting to TRI in 1990.
TABLE 9. NUMBER OF ESTABLISHMENTS IN SIC 2893
Source
TRI, 1990
County Business Patterns
19897
D&B 19928
Basis
SIC 2893
SIC 2893,
SIC 2893,
>10 employees
>10 employees
Number of
establishments
reported
79
332
379
There apparently are a number of nonreporting facilities, based on the number
of facilities reported in County Business Patterns and D&B and the probability that
almost all ink formulators with over 10 employees would process at least one Section
313 chemical in excess of 25,000 pounds.
A review of the TRI data in 1990 pointed out few apparent errors. There did
appear to be a possible underreporting of solvents that are typically used as cleanup
solvents as otherwise used. Because of the lower threshold for these uses, this could
also cause nonreporting for some cleanup solvents if the higher processed threshold
(25,000) were used. There was also one Section 313 chemical (n-butyl alcohol) that in
24
-------
the literature appeared to be used in sufficient quantities that more than 5 percent of
the ink formulators should nave reported. However, only 3 percent of the ink
fbrmulators reported releases or off-site transfers of this solvent.
25
-------
LIST OF QUESTIONS
The following list of questions may be helpful in determining if errors were made
in Section 313 reporting for ink formulators:
Solvents
• Which solvents were processed (just formulated into inks) and which
were also otherwise used (also used as a cleanup solvent)?
• Was vehicle cooking performed at the facility? Were-any Section 313
solvents used in the process?
• For processed solvents, how was air release calculated?
• For otherwise used solvents, was a mass balance performed on the total
quantity used?
For solvents sent off site for fuel burning, recycling, or disposal, was
waste analysis used to determine the quality of the 313 chemical? Most
wastes should be RCRA wastes which are analyzed by the waste
receiver.
Was a 10,000-pound threshold used for all otherwise used solvents
(cleanup solvents)?
How was the quantity of solvent in water-based inks released to water
determined (e.g., glycol ethers, methanol)?
Metals/Metal Compounds
Were thresholds for metal compounds determined using the weight of
the compound and not just the weight of the metal portion of the
compound?
• Was Toxicity Characteristic Leaching Procedure (TCLP) used as a
measure of metal concentration in any of the calculations? TCLP
measures teachable metal, not metal content, and therefore should not
be used in any release calculations.
Other Chemicals
• Was total ammonia used to report ammonia releases to water?
26
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BIBLIOGRAPHY
1. Office of Management and Budget. Standard Industrial Classification Manual.
1987. Washington, D.C. 1987.
2. U.S. Environmental Protection Agency. Industrial Process Profiles to Support
PMN Review: Printing Inks. Office of Pesticides and Toxic Substances,
Washington, D.C. February 1983.
3. Wrk-Othmer. Encyclopedia of Chemical Technology. 3rd Edition, Volume 13.
Inks. John Wiley and Sons, 1981.
4. U.S. Environmental Protection Agency. Compilation of Air Pollution Emission
Factors, 3rd Edition, AP-42. Research Triangle Park, N.C. 1983.
5. U.S. Environmental Protection Agency. Best Demonstrated Available
Technology (BOAT) Background Document for K086 (Ink Formulation Equip-
ment Cleaning Wastes.) Washington, D.C., May 1990.
6. U.S. Environmental Protection Agency. Proposed Best Demonstrated Available
Technology (BOAT) Background Document for K086 (Ink Formulation Equip-
ment Cleaning Wastes) (Addendum) Volume 6. Washington, D.C., November
1989.
7. U.S. Department of Commerce, Bureau of Census, County Business Patterns,
1989, CBP-89-1, Washington, D.C. 1991.
8. Dunn & Bradstreet, Dunn's Electronic Business Directory in DIALOG database
file 515.1992.
27
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TRI FACILITY PROFILE,
MOTOR VEHICLE PARTS AND
ACCESSORIES
by
FT Corporation
11499 Chester Road
Cincinnati, Ohio
Contract No. 68-00-0020
Work Assignment No. 2-27/2-65/3-18
JTN 830015-5-1
Prepared for
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF TOXIC SUBSTANCES
401 M Street, S.W.
Washington, D.C. 20460
September 1992
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CONTENTS
Page
Tables iii
Typical Operations Used 4
Section 313 Chemicals Used in the Manufacture of Motor Vehicle
Parts and Accessories 18
Organic Solvents 19
Chlorinated Solvents 21
Polymer Chemicals 24
Metals and Metal Compounds 26
Acids 29
Other Chemicals 31
Regulations Useful for Estimating Releases of Section 313 Chemicals 34
Nonreporting Facilities 36
List of Questions 37
Bibliography 39
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TABLES
Number Page
1 Summary of Reported Releases of Organic Solvents From Motor
Vehicle Parts and Accessory Manufacturing 20
2 Summary of Reported Releases of Chlorinated Solvents From
Motor Vehicle Parts and Accessory Manufacturing 22
3 Summary of Reported Releases of Polymer Chemicals From
Motor Vehicle Parts and Accessory Manufacturing 25
4 Summary of Reported Releases of Metals and Metal Compounds
From Motor Vehicle Parts and Accessory Manufacturing 27
5 Summary of Reported Releases of Acids From Motor
Vehicle Parts and Accessory Manufacturing 30
6 Summary of Reported Releases of Other Chemicals From
Motor Vehicle Parts and Accessory Manufacturing -32
iii
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TRI FACILITY PROFILE,
MOTOR VEHICLE PARTS AND ACCESSORIES
The purpose of this profile is to assist U.S. Environmental Protection Agency
(EPA) Regional Office personnel in conducting Superfund Amendments and Reauthori-
zation Act (SARA) Title III, Section 313, inspections. The profile describes key toxic
chemicals manufactured, processed, or otherwise used in the manufacture of motor
vehicle parts and accessories, describes how these chemicals are used, and identifies
key release sources. All Section 313 chemicals reported to the Toxic Release
Inventory (TRI) by more than 5 percent of the motor vehicle parts and accessories
manufacturers are presented in this profile.
For the purposes of this profile, the motor vehicle parts and accessories
industry is defined as:
• SIC 3714 - Motor Vehicle Parts and Accessories
This Standard Industrial Classification (SIC) includes establishments primarily engaged
in manufacturing motor vehicle parts and accessories, but not engaged in
manufacturing complete motor vehicles or passenger car bodies. Establishments
primarily engaged in manufacturing or assembling complete automobiles and trucks
are classified in SIC 3711; those manufacturing tires and tubes are in SIC 3011; those
manufacturing automobile glass are in Major Group 32; those manufacturing auto-
mobile stampings are classified in SIC 3465; those manufacturing vehicular lighting
equipment are classified in SIC 3647; those manufacturing ignition systems are
classified in SIC 3694; those manufacturing storage batteries are classified in SIC
3691; and those manufacturing carburetors, pistons, piston rings, and engine intake
and exhaust valves are classified in SIC 3592.1
SIC 3714 does include the manufacture of brakes and brake parts, wiring
harnesses (except ignition), axles, axle housings and shafts, ball joints, bearings,
1
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bumpers, bumperettes, camshafts, air cleaners, connecting rods, control equipment,
crankshaft assemblies, cylinder heads, defrosters, differentials, directional signals,
drive shafts, dump truck lifting mechanisms, engines and engine parts, exhaust
systems, fifth wheels, filters (oil, fuel, and air), frames, fuel pumps, fuel systems, gas
tanks, gears, heaters, horns, power steering pumps, instrument board assemblies,
lubrication systems, manifolds, engine rebuilding, mufflers, PVC valves, transmissions,
pumps (oil, water, and fuel), radiators, wheel rims, shock absorbers, steering mechani-
sms, thermostats, suspension parts, universal joints, and windshield frames and wiper
systems.1 While this list contains most of the parts and accessories in SIC 3714, it is
not an all-inclusive list.
The manufacture of motor vehicle parts and accessories utilizes the following
types of operations:
Foundries
Metal fabrication
Plastics processing
Parts coating
Electroplating
Electronics manufacturing
The first three operations (foundries, metal fabrication, and plastics forming) are the
initial processes for parts such as engines, suspension parts, body parts, interior
parts, and other metal and plastic parts. Foundries are operations that melt metal to
pour into molds to produce castings. Metal fabrication includes operations such as
stamping, welding, or soldering. Plastics forming operations utilize resins or liquid
organic compounds to produce a solid polymerized chemical in the desired shape.
Once the basic part is formed, it is usually further processed by one or more of the
finishing processes.
Parts coating and electroplating operations are finishing processes that apply a
decorative and/or protective layer on the metal and plastic parts such as trim parts,
bumpers, exterior parts, and wheel rims. Parts coating operations deposit a coating
on the part, typically by either dipping, spray coating, or electrodeposition. Electro-
plating operations deposit metal on the surface of the part by electrochemical reaction.
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Electronics manufacture utilizes similar operations to produce finished accessory
products such as radios, electronic instrument panels, and other electronic acces-
sories.
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TYPICAL OPERATIONS USED
Motor vehicle parts and accessories manufacturing facilities differ widely from
facility to facility. The following operations are typically used to manufacture motor
vehicle parts and accessories:
Foundries
Metal fabrication
Plastics processing
Parts coating
Electroplating
Electronics manufacturing
Each of these operations is described separately. Few of the motor vehicle parts and
accessories manufacturing facilities will contain all of these operations.
FOUNDRY PROCESSES
This section summarizes information presented in the TRI Facility Profile, Found-
ries.2 For more detailed information on foundry operations, please consult this profile.
Five metals/metal alloys are utilized in motor vehicle parts and accessories manu-
facturing. These include iron, steel, aluminum, magnesium, and lead. Typical iron
castings include engine blocks, crank shafts, and other engine components. Steel
castings are used in chassis components, suspension components, and wheel rims.
Aluminum castings include engine heads, blocks, and intake parts. Magnesium is
typically alloyed with other metals for use in wheel rims. Lead castings are typically
limited to ingots used for balancing purposes on parts and in applications bearings.
The four major production steps in foundry operations include raw materials
handling and preparation, metal melting, mold and core production, and casting and
finishing.2
Raw materials handling and preparation operations include receiving, unloading,
storing, and conveying of all raw materials for both furnace charging and mold and
core preparation. The major groups of raw materials required for furnace charging are
metallics, fluxes, and fuels. Raw material preparation may include the cleaning of
scrap metals before charging.
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foetal melting is performed in a variety of furnaces with the furnace charge
consisting of metallics, fluxes, and fuels. Seven general furnace types are used in
foundries.
Cupola
Electric arc furnace
Electric induction furnaces
Reverberatory furnaces
Crucible furnaces
Pot furnaces
Open hearth furnaces
The cupola, which is the major type of furnace used in iron foundries, is a
vertical cylindrical steel shell with either a refractory-lined or water-cooled inner wall.2
Refractory linings usually consist of silica brick, dolomite, or magnesium brick. Water-
cooled linings, which involve circulating water around the outer steel shell, are used to
protect the furnace wall from interior temperatures. The cupola is charged at the top
with alternate layers of coke metallics and fluxes. Cupola capacities typically range
from 1 to 30 tons per hour, with a few larger units approaching 100 tons per hour.
Electric Arc Furnaces (EAF) are large, welded-steel cylindrical vessels equipped
with a removable roof through which retractable carbon electrodes are inserted. The
electrodes are lowered through the roof of the furnace and are energized by three-
phase alternating current to create arcs that melt the metallic charge with their heat.2
Additional heat is produced by the resistance of the metal between the arc paths. The
most common method of charging an electric arc furnace is by removing the roof and
introducing the raw materials directly. Alternative methods include introducing the
charge through a chute cut in the roof or through a side charging door in the furnace
shell. Once the melting cycle is complete, the carbon electrodes are raised, and the
roof is removed. The vessel is tilted, and the molten iron is poured into a ladle.
Electric arc furnace capacities range from 0.23 to 59 megagrams (0.25 to 65 tons).
Nine to eleven pounds of electrode are consumed per ton of metal melted. Electric
arc furnaces are becoming increasingly popular in the steel-making industry.
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Electric induction furnaces are either cylindrical or cup-shaped refractory-lined
vessels that are surrounded by electrical coils that, when energized with high-frequen-
cy alternating current, produce a fluctuating electromagnetic field to heat the metal
charge.2 For safety reasons, the scrap metal added to the furnace charge is cleaned
and heated before being introduced into the furnace. Induction furnaces are kept
closed except during charging, skimming, and tapping. The molten metal is tapped by
tilting the vessel and pouring the metal through a hole in the vessel side. Induction
furnaces also may be used for metal refining in conjunction with melting in other
furnaces and for holding and superheating the molten metal before pouring (casting).
Reverberatory furnaces operate by radiating heat from a burner flame, furnace
roof, and furnace walls onto the material heated. The reverberatory furnace usually
consists of a shallow, generally rectangular, refractory hearth for holding the metal
charge. The furnace is enclosed by vertical side walls and covered with a low, arched,
refractory-lined roof. Fuel is combusted directly above the molten bath; the walls and
roof reserve radiant heat from the hot combustion products and, in turn, reradiate the
heat to the surface of the bath surface. Heat is transferred almost entirely by
radiation.2
Crucible furnaces used to melt metals with melting points below 2,500'F are
usually constructed with a shell of welded steel lined with refractory materials. Their
covers are constructed of materials similar to the inner shell lining; a small hole over
the crucible is used for charging materials and exhausting combustion products. The
crucible, which rests on a pedestal in the center of the furnace, is commonly con-
structed of refractory materials such as clay-graphite mixtures or silicon carbide.
Crucibles are made in several shapes and sizes for melting from 20 to 2,000 pounds.
Crucible furnaces are classified as tilting, pit, or stationary furnaces.2
Pot furnaces are used to melt metals with a melting temperature below
1,400'F.3 These furnaces may be cylindrical or rectangular and consist of an outer
shell lined with refractory material, a combustion chamber, and a pot. The .pots are
made of pressed steel, cast steel, or cast iron with flanged tops. The flange rests on
the furnace wall, holds the pot above the furnace floor, and seals the contents of the
6
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pot from the combustion products of the fuel used. The shape of the pot depends
upon the operation to be conducted. Large rectangular furnaces, generally called
kettles, are used to melt large amounts of metal for dipping operations, such as
galvanizing. For melting large castings, shallow, large-diameter pots are used. When
ingots or other small pieces of metal are to be melted, deep pots are used to promote
better heat transfer. Pot furnaces are usually emptied by tilting, dipping, or pumping.
Combustion equipment ranges from simple atmospheric-type burners located directly
below the pot to premix-type tangentially fired burners. The larger kettles are generally
provided with many burners along both sides of the pot.2
Open hearth furnaces may be charged with various types of iron-bearing
materials 1) hot metal (pig iron) and molten steel, 2) cold steel scrap and cold pig iron,
3) all steel scrap, or 4) steel scrap and molten pig iron. A luminous flame with excess
air is passed over the charged materials to provide heat for the process-. Combustion
air is alternately preheated by regenerating units, which, in turn, are heated by the
products of combustion discharging from the furnace.2
Mold and core production requires the use of Section 313 chemicals. Molds
are forms used to shape the exteriors of castings. Cores are molded sand shapes
used to make the internal voids in castings. Cores are made by mixing sand with
organic binders, molding the sand into a core, and baking the core in an oven. Molds
are prepared of a mixture of wet sand, clay, and organic additives to make the mold
shapes, which are usually dried with hot air. Cold setting binders are being used
more frequently in both core and mold production. Used sand from castings shakeout
(after metal pouring) is recycled to the sand preparation area and cleaned to remove
any day or carbonaceous buildup. The sand is then screened and reused to make
new molds. Makeup sand is added to allow for process losses and discard of a
certain amount of sand because of contamination.2
Casting and finishing operations include molten metal pouring, mold removal,
and various other operations used to finish the casting. After the melting-process,
molten metal is tapped from the furnace. Molten iron produced in cupolas is tapped
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from the bottom of the furnace into a trough, into a ladle. Iron produced in electric arc
and induction furnaces is poured directly into a ladle by tilting the furnace.
When castings have cooled, any unwanted appendages, such as spurs, gates,
and risers, are removed. These appendages are removed with an oxygen torch,
abrasive band saw, or friction cutting tools. In less-mechanized foundries, hand
hammers may be used to knock off the appendages. After appendage removal, the
castings are subjected to abrasive blast cleaning and/or tumbling to remove any
remaining mold sand or scale. The castings may also be finished for machining or
grinding, and some products are degreased and coated or electroplated before
shipment.
METAL FABRICATION
Body parts, frame parts, and system parts such as radiators or air conditioners
may be fabricated from purchased metal at motor vehicle parts and accessory
manufacturers. These processes can use operations such as stamping, welding,
cutting, grinding, or soldering. Releases can include releases of metal from cutting or
grinding or metal vapors from welding or soldering. The fabricated parts may then be
coated prior to shipment. Coating operations are described later in the section called
Parts Coating.
PLASTIC PROCESSING
At least 17 types of plastic resins and compounds are used in the manufacture
of motor vehicle parts and accessories. These materials include:
• Acetals • Polyetherimides
• Acrylics • lonomer
• Cellulosics • Thermoplastic polyimides
• Ketone-based resins • Polyphenylene ethers
• Nylon • Polypropylene
• Polyamide-imide • Styrenic resins
• Polyarylate • Thermoplastic elastomers
• Polycarbonate • Polyurethane
• Polybutylene terephthalate
8
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These materials are used to make a wide variety of plastic parts and accessories. A
description of each of these plastics follows.
Aeetals are engineering thermoplastics that are characterized by their high load-
bearing capabilities and low coefficient of friction. Aeetals, also known technically as
polyoxymethylenes (POM), are polymers of formaldehyde with the linear polymer
structure of (-CH20-) units repeating in their backbone. Typical applications of POM
are molded window lift mechanisms; ball sockets for track rod ends; fasteners for
interior and exterior trim, cables, etc.; functional parts in heating, ventilation, and air
conditioning systems; steering column/gear shift mechanisms; and door handles.3
Acrylics are used by the motor vehicle parts and accessory industry for their
sparkling crystal clarity, outstanding surface hardness, superior weatherability, and
good chemical resistance. Acrylic is used as a monomer for coating resins and
casting sheet, rods, and tubes and as polymer beads or pellets for extrusion or
injection molding. Acrylics typically start with methyl methacrylate (MMA) monomer.
MMA is polymerized by a free radical process in the presence of peroxides to form
poly-MMA (PMMA). Typical PMMA applications are taillights, side markers,
escutcheons, pillar posts, instrument covers, nameplates, trim, and dials.3
Cellulosics are plastics produced by the chemical modification of cellulose.
Cellulose is the cell wall substance of many trees and plants that is produced by
photosynthesis. Cellulosics are characterized by their toughness, surface gloss,
clarity, and ability to be processed by a variety of methods. Typical Cellulosics
applications include steering wheels in luxury and special-purpose vehicles and
coated-over foil strips for trim parts.3
Ketone-based resins are characterized by their chemical resistance, toughness,
strength, rigidity, radiation resistance, and easy melting process. These resins are
partially crystalline aromatic materials composed of aryl repeating units linked by
oxygen and carbonyl groups. Typical application of these resins are bearing cages,
seals, housings, and printed circuit boards.3
Nylons are notable for their resistance to oils and greases, repeated impacts,
fatigue, and abrasion. Nylons contain an amide group (-CONH-) as the recurring
9
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part of the chain. Typical applications of nylons are electrical connectors, wire jackets,
emission canisters, light-duty gears for windshield wipers and speedometers, trim
dips, engine fans, radiator headers, brake and power steering reservoirs, valve covers,
mirror housings, and fender extensions.3
Potyamide-imides (PAI) are amorphous, high-temperature engineering thermo-
plastics. PAI is produced by the reaction of trimellttic anhydride and aromatic diamines
followed by condensation to form the imide group. After molding, the parts must be
thermally treated by a program of increasing temperatures that increases the molec-
ular weight and improves the properties of the material. Typical applications of PAIs
are thrust washers and seal rings in transmissions, universal joints, and power-
assisted devices.3
Polyarylates are noted for their tough, durable, and heat-resistance properties.
These polymers are aromatic polymers with an amorphous molecular structure.
Polyarylate parts provide excellent surfaces for painting, plating, hot stamping, and
printing. Typical applications of polyarylates are headlight housings, brakelight
reflectors, door handles, mirror housings, window trim, brackets, fasteners, and
windshield wipers.3
Polycarbonates (PC) are characterized by high clarity, heat- and flame-resis-
tance, dimensional stability, and exceptional high impact strength over a wide range of
temperatures. PC is a polyester of carbonic acid generally produced by using a
reaction between di- or polyhydric phenols and a suitable carbonate precursor such
as dichlorocarbonate. Typical applications of PCs are instrument panels, light pipes,
glazing, seat backs, headlights, taillight lenses, and side markers.3
Polybutylene terephthalates (PBT) are thermoplastic polyesters that are char-
acterized by good chemical resistance and good electrical properties. PBTs are
produced by the transesterrfication of dimethyl terephthalate with butanediol. Typical
applications of PBT are grilles, body panels, fenders, bumper covers, wheel covers,
distributor caps, rotors, head lamp system parts, windshield wiper assemblies, water
pump parts, brake system parts, and components for doors, windows, and mirrors.3
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pptyetherimides are thermoplastics characterized by high strength and rigidity at
elevated temperatures, long-term heat resistance, highly stable dimensional and
electrical properties, and broad chemical resistance. Polyetherimide has an
amorphous chemical structure with recurring aromatic imide and ether units. Typical
applications of polyetherimides are under-the-hood temperature sensors, fuel system
components, lamp sockets, and metallized reflectors; and high-strength transmission
components.3
lonomers are noted for their UV resistance, transparency, colorability, low-
temperature toughness, and adhesion to other materials, lonomers, a generic term for
polymers containing interchain ionic bonding, are based on metal salts (usually
sodium or zinc) of ethylene/methacrylic acid copolymers. Typical applications of
ionomers are air dams, exterior trim parts, bumper pads, and bumper guards.3
Thermoplastic polyimides are linear polymers with the imide group (-CONGO-)
incorporated in the polymer main chain. The key properties include outstanding high-
temperature resistance, toughness, and high resistance to deformation under load at
elevated temperatures. Thermoplastic polyimides are typically used for the manu-
facture of rotary seal rings in heavy-duty transmissions.3
Polyphenylene ethers (PPE) are produced by the oxidative coupling of sub-
stituted phenols. The two main materials are the homopolymer based on 2,6 dimethyl
phenol and the copolymer, which contains primarily 2,6 dimethyl phenol and a lower
concentration of 2,3,6 trimethyl phenol. PPE is typically alloyed with polystyrene to
provide excellent melt flow characteristics. Polyblends are typically applied to instru-
ment panels, seat backs, rear spoilers, wheel covers, mirror housings, electrical
connectors, and fuse blocks.3
Polypropylenes (PP) are noted for their low specific gravity and good resistance
to chemicals and fatigue. Typical PP is a stereo-specific polymer with propylene units
attached in a head-to-tail fashion and with methyl groups aligned on the same side of
the backbone. PP is produced by the polymerization of polypropylene with organo-
metallic stereo-specific catalysts. Typical applications of PP are interior trim parts and
air ducts.3
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styrenlc resins are a family of thermoplastics that include acrylonitrile-butadiene-
styrene (ABS), acrylic-styrene-acrylonitrile (ASA), styrene-acrylonitrile (SAN), and
styrene-maleic anhydride (SMA). These listed are the typically used thermoplastics in
motor vehicle parts and accessories manufacturing. ABS is a mixture of SAN co-
polymer with SAN-grafted potybutadiene typically used in interior moldings, consoles,
quarter trim panels, map pockets, grilles, mirror housings, wheelcovers, and headlamp
bezels. ASA is an outdoor weatherable and UV-resistant material that is produced by
a terpolymer system. ASA is typically used in body side moldings and trim, mirror
housings, bumper parts, and interior trim parts. SAN is a copolymer system that
possesses transparency, high gloss, and chemical resistance and is typically applied
to instrument lenses and dash board components. SMA is a thermoplastic produced
by the copolymerization of styrene and maleic anhydride that are typically used in
electrical connectors, consoles, top pads, instrument panels and supports, interior trim
parts, headliners, heater ducts, and consoles.3
Thermoplastic elastomers fTPE) are a category of polymers that are a combina-
tion of the mechanical properties of thermoset rubber with the processing ease of
thermoplastics. TPEs are resistant to high loads and chemicals and have a broad
service temperature range. Applications of TPEs include hose jacketing, seals,
grommets, air ducts, convoluted boots, weather-stripping, o-rings, bumper covers, air
dams, and gear shift knobs.3
Polyurethanes (PUR) are produced by combining two primary ingredients, a
polyisocyanate and a polyol, during processing. Two types of foams are typically
produced by motor vehicle parts and accessories manufacturers: integral skin loams
and semi-rigid foams. Integral skin foams have a thin tough skin on a lightweight
foam core that are typically used to produce armrests and steering wheels. Semi-rigid
foams are open-celled foams that are harder and do not form a skin during forming as
integral skin foams. Semi-rigid foams have a moderate amount of resiliency and
excellent sound and energy absorbency properties that are used in armrests, door
panels, and instruments panels.3
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Four major processed typically are used by motor vehicle parts and accessories
manufacturing facilities to process these plastics into useable parts. These processes
are:
• Blow molding
• Extrusion
• Injection molding
• Thermoforming
Blow molding may be used on several thermoplastic materials. The materials
typically used by motor vehicle parts and accessory manufacturers are polyarylates,
polycarbonates, ionomers, styrenic resins, and polyurethanes. Blow molding follows a
six-step process that is typically totally automated. The first step is extrusion from the
molten plastic of a round hollow tube, called a parison. This parison is then entrapped
between two halves of the mold. The parison within the mold is expanded by air pres-
sure (usually 100 psi) against the cavity of the mold to form the part. The part is
allowed to cool within the mold. Once cooled, the part is removed from the mold and
the excess is trimmed.3
Extrusion may be used for the following thermoplastic materials typically used
by motor vehicle parts and accessory manufacturers: acetals, cellulosics, nylons,
polyarylates, polycarbonates, ionomers, and styrenic resins. Extrusion follows a four-
step process. First, the plastic powder or granules are heated to a continuous uniform
melt. This melt is then forced through a die of the desired part shape. The part is
held in the desired shape until it cools back into a solid state. Extruded parts can be
in the form of custom profiles, fiat sheets, piping and tubing, and fibers.
injection molding involves a three-step process to manufacture a molded pan
Palletized granular or powdered plastic is fed to a heating cylinder where heat and
pressure are applied to the plastic to obtain a melt. The melt is then injected under
high pressure into a metal mold. The pressure is maintained in the mold until the
plastic is hard enough to be removed from the mold. Typical materials processed by
injection molding by motor vehicle parts and accessory manufacturers are acetals,
acryfics, ketone-based resins, nylons, polyamide-imides, polyarylates, polycarbonates,
13
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polybutylene terephthalates, polyetherimides, ionomers, polyimides, polyphenylene
ethers, polypropylenes, styrenic resins, and thermoplastic elastomers.
Thermoforming involves a simple two-step process of elevating the temperature
of a thermoplastic material to a workable level and forming the material into the
desired shape by one of nine techniques: straight vacuum forming, drape forming,
matched mold forming, pressure bubble-plug assist vacuum forming, plug assist
forming, vacuum snapback forming, pressure bubble vacuum snapback forming,
trapped sheet contact heat pressure forming, and air-slip forming. Typical materials
processed by thermoforming are cellulosics, potyarylates, polyetherimides, and
styrenic resins.
PARTS COATING
Coatings are applied to motor vehicle parts and accessories for appearance,
durability, and corrosion protection. Typically three steps are used in coating parts:
pretreatment, primer coat, and top coat.
The coating process begins with a pretreatment process. Pretreatment can
consist of phosphate coating or degreasing. For phosphate coating, metal parts are
bathed or sprayed with a hot phosphoric acid solution containing dissolved zinc and
other metals. The part is then rinsed with dilute chromic acid and water. Once dried,
the surface of the part will contain a conversion coating of zinc or iron phosphate.
An alternate pretreatment is to degrease the part using a chlorinated solvent or
other cleaning solution. In a solvent wipe, a rag or other wiper is dipped in the
chlorinated solvent and wiped across the part to remove the contaminant from the
part. Cold degreasers usually consist of a tank, basket, and cover, and may employ
spraying, brushing, agitation, flushing, or immersion. The solvent is usually kept near
room temperature. Cold units vary greatly in size and design. The size of the
degreaser is directly related to the size and number of the parts being cleaned.
A vapor degreaser consisting of a tank and heating system to boil the solvent
may be operated manually or it may be conveyorized. In this process, parts are
lowered into a solvent vapor produced for cleaning. Vapors condense on the parts
14
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until the temperature of the part approaches that of the vapor, at which time the parts
are removed. Most vapor degreasers are equipped with condenser coils located on
the upper sidewalls of the degreaser to control the vapor level in the tank. They may
also be equipped with water separators, which are simple containers in which solvent
and water that condenses from the ambient air are separated. Lids are commonly
dosed when the degreaser is not in use.
Once the surface of the part is pretreated, a primer coating is applied. The
main function of the primer is corrosion protection and, to a lesser degree, to smooth
out small imperfections in the surface. Primer is usually applied to auto parts by one
of three methods: dipping, spray coating, or electrodeposition. Dipping and spray
coating primers may use a binder of alkyd and epoxy resins dissolved in an organic
solvent. Electrodeposition coating may be used to provide an adequate coating to
recessed areas where dipping and spraying coatings do not. Electrodeposition
typically uses polybutadiene- or epoxy-based binders. The typical range of thickness
of the primer coating is 7.5 to 25 microns. The primer coating may be air dried or
baked dried.
The topcoat is the final coating and is placed on top of the primer coating.
Typical topcoats used by motor vehicle parts and accessories manufacturers for
visible exterior body parts are lacquers and enamels. Lacquer binders consist mainly
of poly(methyl methacrylate) and also contain cellulose acetate butyrate, a small
amount of alkyd plasticizer, and a copolymer of methyl methacrylate with an acrylate
dispersed in an organic solvent. Enamel topcoats are composed of a mixture of an
acrylic resin and a melamine-formaldehyde resin usually dispersed in an organic
solvent. To achieve a metallic finish for exterior visible parts, a concentration of
aluminum pigment of about 2 percent is added to the coating material before appli-
cation.
Plastic parts may also be coated. They are typically coated with a lacquer-type
primer consisting of a polyether urethane. Topcoats are typically enamels made with
binders of hydroxy-functional polyester urethanes that are cross-linked with a
melamine-formaldehyde resin, while other topcoats are acrylic resins cross-linked with
15
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melamine-formaldehyde resin and contain a plastitizer. No conversion coating is
applied; however, the parts may be degreased prior to coating.
ELECTROPLATING
This section summarizes information presented in the TRI Facility Profile,
Electroplating.5 For more detailed information on electroplating operations, please
consult this profile.
Electroplating is the electrodepos'rtion of an adherent metallic coating on an
electrode in order to form a surface with properties or dimensions different from those
of the base metal. The Section 313 metals that are commonly electroplated in auto
parts manufacture include chromium, nickel, and zinc. The electroplating process
includes cleaning, rinsing, plating, and postdating treatments; such operations can be
performed manually or with varying degrees of automation. The primary cleaning
processes performed prior to electroplating include solvent cleaning, alkaline cleaning,
and acid cleaning. The processes associated with chlorinated solvent degreasing
were previously described in the section on parts coating. Alkaline cleaners do not
typically contain Section 313 chemicals in high enough concentrations such that use
would be above the threshold limits. Parts to be plated may be hung in the plating
tank on wires or racks, contained in wire baskets, or, more commonly placed in •
barrels thai rotate in the plating tank. Movement from one operation to the next may
be by hand or by machine.9
ELECTRONICS
Electronic parts manufacturing includes printed circuit board assembly and
wiring, enclosure fabrication, and entire part assembly. Electronics manufacturing may
also include integrated circuit silicon chip fabrication; however, it is assumed that this
part of the electronic component is fabricated at another facility.
Printed circuit board assembly involves the degreasing of the printed circuit
boards, application of solder flux, wiring and soldering connections, and removal of
the solder flux. Chlorinated solvents are used for the degreasing and flux removal
16
-------
operations because of the extreme requirements for cleanliness and purity of the
products. Solvent degreasing in the electronics manufacturing process consists of
seven steps: degreasing with a chlorinated solvent, cleaning with an abrasive, soaking
in alkaline or acid, rinsing, dipping in hydrochloric acid, final rinsing, and drying. Once
dry, the flux is applied to the components to be joined to dean the surfaces and
promote the fusion of the solder with the surfaces. Typical solder used is tin-lead
solder to join the connections and wiring components.
The flux that remains on the circuit board after soldering is removed by either
chlorinated solvent or aqueous-based systems. The choice of flux removal system is
determined by the type of flux used. There are three types of solder flux: rosin,
organic acid, and synthetic-activated resin. Both systems may be used to remove
rosin fluxes, organic acids fluxes are removed exclusively with aqueous systems, and
synthetic-activated resin fluxes require halogenated solvent removal.
Enclosure fabrication and product assembly include some of the processes
discussed previously such as electroplating, plastics forming, and parts coating.
Examples of these include electroplating metal contacts with gold or other conductive
metal, plastic forming enclosure shells, and coating metal or plastic parts and enclo-
sures.
17
-------
SECTION 313 CHEMICALS USED IN THE MANUFACTURE OF MOTOR VEHICLE
PARTS AND ACCESSORIES
Section 313 chemicals commonly used in the manufacture of motor vehicle
parts and accessories can be classified into six general categories: organic solvents,
chlorinated solvents, polymer chemicals, metals/metal compounds, acids, and other
chemicals. Each category is discussed separately in this report. Each section
contains a description of how the Section 313 chemicals are used, a table summariz-
ing the releases and off-site transfers that were reported to TRI in 1990, and a
discussion of typical releases, off-site transfers, and typical control practices. Also-
presented are methods for identifying nonreporting facilities and a list of questions.
18
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ORGANIC SOLVENTS
Eight organic solvents are otherwise used at motor vehicle parts and accessory
facilities. The use of these chemicals does not typically form any Section 313 chemical
by-products during use. These solvents are widely used, and although they may be
used at some facilities for cleaning, they are typically used in coatings that are applied
to the parts. For all organic solvents, virtually all releases occur to air. Minor quan-
tities may be transferred off site in paint wastes or to POTWs if a water curtain is used
as a control/collection measure for spray mist. Because glycol ethers are soluble in
water, significant release to water or POTW is to be expected for this chemical.
Organic solvents that are used as purge solvents such as xylene, toluene, or
MEK can be expected to be transferred off site for recycling, fuel blending, or disposal.
Because off-site transfer for recycling or fuel blending was not reportable prior to the
1991 reporting year, significant increases in the off-site transfers of these organic
solvents can be expected in 1991 and subsequent years. These quantities will also be
reported in Sections 8.3 and 8.5 of the Form R. Table 1 presents a summary of
reported releases and off-site transfers of organic solvents from the manufacture of
motor vehicle parts and accessories.
Controls of organic solvent releases include add-on pollution control equipment
such as thermal or catalytic incinerators or carbon adsorbers. The most prevalent
control to reduce Volatile Organic Compound (VOC) emissions involves process
changes such as use of high solids paint, powder coatings, and water-bome coatings.
Process changes such as new spray guns are also used to increase transfer efficien-
cies and therefore reduce solvent consumption.
19
-------
TABLE 1. SUMMARY OF REPORTED RELEASES OF ORGANIC SOLVENTS FROM
MOTOR VEHICLE PARTS AND ACCESSORY MANUFACTURING
Nean release.
Section 313 chemical
Xylene (mixed Isomer)
Toluene
Methyl ethyl ketone
61yco1 ethers
Nethanol
Acetone
n-Butyl alcohol
Methyl Isobutyl ketone
Number of facil-
ities Deporting
usage (X re-
porting usage)
94 (28)
86 (26)
n in]
62 (19)
SO (15)
49 (15)
35 (11)
27 (8)
Fugitive
13.561 (79)
16.084 (74)
9.953 (89)
6.071 (76)
3.923 (84)
28.874 (86)
4.080 (86)
7.764 (89)
Stack
84.067 (91)
52.219 (88)
68.590 (84)
44.327 (84)
27.423 (64)
67.938 (61)
37.785 (86)
39.580 (89)
Water
66(4)
10 (2)
87 (4)
e
0(0)
0 (0)
5(3)
0 (0)
lb (X reporting to each media)
Land
0(0)
135 (2)
0(0)
0 (0)
0(0)
0(0)
0(0)
0 (0)
roTwe
265 (15)
241 (17)
1.201 (10)
23.710 (SO)
e
500(12)
973 (11)
551 (19)
Off -site
Transfer
5.233 (49)
9.425 (48)
14.603 (58)
7.168 (47)
3.603 (26)
1.977 (37)
1.232 (51)
4.297 (56)
Total*1
90,191 (100)
82.655 (100)
74.698 (100)
59.139 (97)
24.943 (90)
68.530 (98)
36.629 (100)
44.573 (100)
8 A total of 331 facilities In SIC 3714 reported usage of at least one Section 313 chemical above threshold limits.
Mean releases In pounds per year In 1990 for facilities reporting releases of this chemical and percentage of facilities reporting usage
of this chemical that release to this media. Releases to other media were Insignificant.
C POTV • Publicly Owned Treatment Works.
The total Includes all releases and off-site transfers, not Just categories sumwrlzed In this table.
Mean value Is not representative because of a very large value at one facility and the small number of facilities.
-------
CHLORINATED SOLVENTS
Chlorinated solvents are otherwise used at auto parts and accessory manufac-
turing facilities in foundry, parts coating, electroplating, and electronics operations.
These solvents are typically used as cleaning and degreasing agents at all of the
above-listed operations. At foundry operations, however, chlorinated solvents may
also be contained in metal cutting fluids, used as mold release carriers, and contained
in products used to detect cracks in casting. Table 2 presents a summary of 1990
reported releases and off-site transfers of chlorinated solvents from motor vehicle parts
and accessories manufacturing.
During use of chlorinated solvents contained in mold release carriers and in
products used to detect cracks in castings at foundry operations, all emissions are
released to air and no pollution controls are typically used. Therefore, the air release
is equal to the solvent usage. For cutting fluids, some emissions are released to air
during usage and some are transferred off site for treatment or disposal as waste
cutting oil.
Chlorinated solvents may also be used to degrease or clean metal castings,
metal parts before electroplating, or parts coating. Chlorinated solvents are also used
to clean electronic circuit boards. The solvents may be used in a solvent wipe, cold
degreaser, or vapor degreaser, all of which have been previously described.
Degreasing operations primarily produce fugitive and point-source air releases
and off-site transfers for solvent recovery or disposal. In vapor degreasing, moisture
from air condensing on the cooling coils of the degreaser may result in minimal
releases to water or POTWs.
Numerous controls may be used to reduce releases and off-site transfers of
chlorinated solvents from motor vehicle parts and accessories manufacturing. Air
releases from vapor degreasing operations may be reduced by application of the
following engineering controls and operation and maintenance (O&M) procedures:
21
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TABLE 2. SUMMARY OF REPORTED RELEASES OF CHLORINATED SOLVENTS FROM MOTOR VEHICLE PARTS
AND ACCESSORY MANUFACTURING
Section 313 chemical
1.1,1-THchloroethane
Freon 113
Trlchloroethylene
Dlchloromethane
Tetrachloroethylene
Number of facilities
reporting usage
(X reporting usage)
129 (39)
56(17)
34 (10)
27 (8)
IB (5)
Fugitive
27.929 (91)
36.352 (100)
49.655 (91)
16.920 (89)
45.413 (83)
Mean
Stack
42.673 (70)
35.372 (41)
60.791 (74)
27,858 (63)
32.774 (83)
release, Ib
Water
8(2)
250 (2)
98(9)
0(0)
111 (11)
(X reporting, to each media)
Land
20(1)
0(0)
0(0)
0(0)
0 (0)
POTW6
100 (13)
128 (4)
204 (18)
189 (15)
29(17)
Off -site
Transfer
12,816 (39)
4,021 (29)
12.698 (44)
9.533 (52)
5.175 (28)
Total*
60.084 (100)
52.038 (100)
95.619 (100)
37,551 (100)
66.610 (100)
A total of 331 facilities In SIC 3714 reported usage of at least one Section 313 chemical above threshold limits/
Mean releases In pounds per year In 1990 for facilities reporting releases of this chemical and percentage of facilities reporting usage of
this chemical that release to this media. Releases to other media were Insignificant.
POTV • Publicly Owned Treatment works.
The total Includes all releases and off-site transfers, not just categories summarized In this table.
-------
Engineering controls
Lowering the temperature of cooling water
Increasing freeboard height (distance between top of vapor
phase and top of degreaser)
Adding low-solvent detector
Using optimum part-handling speeds (automatic hoists)
Adding automatic lid closure
Adding extra cooling coils on inlets and outlets
O&M procedures
Closing the cover when possible
Minimizing drafts
Positioning work to minimize dragout
Spraying only below the vapor level
Avoiding excessively large loads
Maintaining equipment
Waste solvent evaporation can be a major source of air releases from cold
cleaning. This release occurs when spent solvent is stored in open containers prior to
disposal and/or from evaporation at the disposal site. This release can be minimized
by covering spent solvent containers and by reclaiming solvent. Another release
source, solvent bath evaporation, can be reduced through use of a cover whenever
parts are not being cleaned and through adjustment of room and exhaust ventilation
rates to minimize drafts. A third release source, solvent carryout, is dependent on the
use of a drainage rack. Internal or external racks can be used, depending on the size
of the cleaning unit. Also, drainage time must be of adequate duration to ensure that
the racks are effective in reducing carryout.
A common error in reporting has been the use of the total quantity of waste
solvent sent off site Q.e., that reportable under the Resource Conservation and
Recovery Act as F001 and F002 waste mixtures) as the quantity of chlorinated solvent
sent off site. Using this overestimation of the quantity of chlorinated solvent sent off
site in mass balance calculations underestimates the air releases of the solvent. The
facility usually may contact the solvent reclaimer to obtain the percentage of chlori-
nated solvent in the waste mixture.
23
-------
POLYMER CHEMICALS
Polymer chemicals are processed in plastics forming operations. Two polymer
chemicals were reported to TRI in 1990: methylenebis(phenyl isocyanate) and styrene.
Table 3 presents a summary of reported releases and off-site transfers of polymer
chemicals from motor vehicle parts and accessories manufacturing. Many other
Section 313 chemicals may be used as polymer chemicals; however, they may be
present at below the de minimis levels. These other polymer chemicals include form-
aldehyde, methyl acrylate, ethylene, acrylon'rtrile, butadiene, and maleic anhydride.
The majority of the Section 313 listed polymer chemicals are released to air.
Solvent recovery systems, vessel washings, and condensate may produce water or
POTW releases. Off-site transfers are typically waste polymer and off-spec product
and parts. Controls of polymer chemical releases include add-on pollution control
equipment such as thermal or catalytic incinerators or carbon adsorbers.
24
-------
TABLE 3. SUMMARY OF REPORTED RELEASES OF POLYMER CHEMICALS FRO* ROTOR VEHICLE PARTS
AND ACCESSORY MANUFACTURING
Mean release. 1b (X reporting to each media)
Section 313 chemical
Methyl enebls (pnenyl
1 socyanate)
Styrene
Number of faclll^es
reporting usage
(X reporting usage)
29 (9)
24 (7)
Fugitive
2.435 (48)
e
Stack
1.346 (38)
20.176 (54)
Water
0(0)
0 (0)
Land
0(0)
0(0)
POTW6
128 (7)
0(0)
Off-site
Transfer
e
10.556 (29)
Totald
14.423 (69 r
95,783 (96)
A total of 331 facilities In SIC 3714 reported usage of at least one Section 313 chemical above threshold limits.
Mean releases In pounds per year In 1990 for facilities reporting releases of this chemical and percentage of facilities reporting usage of
fO this chemical that release to this media. Releases to other media were Insignificant.
° POTV - Publicly Owned Treatment Works.
The total Includes all releases and off-site transfers, not Just categories sunnarlzed In this table.
Mean value Is not representative because of a very large value at one facility and the small number of facilities.
-------
METALS AND METAL COMPOUNDS
Metals and metal compounds are processed at motor vehicle parts and
accessories manufacturing facilities that utilize foundry, coating, electroplating, and
electronic manufacturing operations. While conversions between metal and metal
compounds may occur, there are no Section 313 metal by-products formed during the
use of metal/metal compounds in coating, electroplating, and electronics operations.
However, metal compounds may be manufactured as by-products in the melting
process in foundry operations. Table 4 presents a summary of reported releases, and
off-site transfers of metals and metal compounds from the manufacture of motor
vehicle parts and accessories.
The primary metals/metal compounds processed at foundry operations are
aluminum (fume or dust), chromium, copper, lead, manganese, nickel, and zinc (and
their compounds). The compounds of these metals may be manufactured as a by-
product of the process. Metal/metal compounds may also be released during
finishing of the castings during grinding and other mechanical processes.
The metals/metal compound releases to air at foundries are in the form of fume
or dust and are controlled by a number of control devices. These controls vary so
widely among foundry operations that specific controls at the foundry in question
should be identified.
The metal/metal compounds may also be transferred off site at foundries for
treatment or disposal or may be disposed of on site as a land release from foundry
operations. Small quantities may be sent to water or Publicly Owned Treatment Works
(POTWs).
Metals/metal compounds are solid constituents of coatings processed by
coating operations. The metals/metal compounds are primarily processed as
pigments, but may also be constituents of other additives. Major pigments that are
Section 313 chemicals include barium compounds, zinc oxide and other zinc com-
pounds, and chromium compounds. Lead and lead compounds are still used, but
their use is on the decline due to toxicity concerns. Most of the metal/metal
26
-------
TABLE 4. SUMMARY OF REPORTED RELEASES OF METALS AND METAL COMPOUNDS FROM
MOTOR VEHICLE PARTS AND ACCESSORY MANUFACTURING
Mean release. 1b (X reporting to each media)
Section 313 chemical
Copper
Copper compounds
Nickel
Nickel compounds
Manganese
L i nc compounds
Chromium
Lead
Leao con^jounos
Barium compounds
Aluminum (fume or
dust)
Number of facil-
ities Reporting
usage (X re-
porting usage)
116 (35)
20 (6)
70 (21)
28 (8)
69 (21)
24 (7)
65 (20)
64 (19)
36 (11)
48 (15)
30 (9)
36 (11)
18 (5)
Fugitive
128 (42)
145 (35)
181 (33)
148 (43)
217 (39)
244 (50)
e
326 (36)
175 (36)
113 (44)
211 (50)
1.791 (25)
339 (72)
Stack
60S (42)
329 (70)
224 (30)
118 (43)
209 (43)
203 (42)
1.223 (51)
178 (38)
223 (47)
359 (75)
166 (50)
484 (36)
e
Water
91 (12)
125 (30)
65 (10)
203 (18)
220 (4)
155 (13)
352 (25)
117 (8)
104 (17)
226 (10)
118 (33)
98 (11)
83 (11)
Land
250 (1)
250 (1)
1.675 (3)
0 (0)
3.183 (4)
0 (0)
10.072 (5)
378 (3)
0 (0)
0 (0)
11 (3)
e
0 (0)
POTWC
159 (44)
369 (60)
341 (40)
2.219 (79)
144 (20)
8.101 (54)
820 (77)
283 (39)
1.635 (56)
93 (50)
177 (60)
e
6.143 (28)
Off-alt*
Transfer
•
19.421 (65)
10.357 (69)
•
4.631 (58)
14.503 (75)
33.462 (82)
8.021 (73)
e
3.282 (63)
12.009 (77)
39.967 (81)
4.560 (28)
Total4
26.101 (85)
16.470 (80)
7.992 (93)
75.442 (100)
3.275 (93)
15.492 (100)
30.349 (97)
5.053 (94)
65.923 (97)
2.546 (96)
10.601 (90)
140.554 (89)
6.173 (83)
* A total of 331 facilities In SIC 3714 reported usage of at least one Section 313 chemical above threshold limits.
Mean releases In pounds per year In 1990 for facilities reporting releases of this chemical and percentage of facilities reporting usage of
this chemical that release to this media. Releases to other media were Insignificant.
C POTtf - Publicly Owned Treatment Works.
The total Includes all releases and off-site transfers, not just categories summarized In this table.
Mean value Is not representative because of a very large value at one facility and the small number of facilities.
-------
compound pigment typically is applied to the manufactured part; however, some
metals/metal compounds may be transferred off site in coating wastes or to POTWs if
a water curtain is used as a control/collection measure for spray mist.
Releases of metals/metal compounds from electroplating operations are
primarily through off-site transfer of spent plating solutions. Also, significant quantities
of metals/metal compounds are released to water and POTW through dragout from
the plating bath to the rinse water and from releases of scrubber water used to control
air releases. Other small quantities of metal/metal compounds are released to air
through misting during electroplating.
A mist is formed over plating baths due to the evolution of gases during the
electroplating process. As the bubbles burst at the surface of the plating solution, a
fine mist of plating solution droplets is formed. Emission factors from the
Crosswalk/Air Toxic Emission Factor (XATEF) Database may be used to determine
the air releases from the plating bath.
Metals/metal compounds released during electronic manufacturing processes
may be minimal. Solder is the main metal/metal compound used in electronic manu-
facturing and .almost all of the material is applied to the parts. Some solid metal/metal
compound material may be generated and transferred off site or released to land on
site.
Fumes of metals contained in the solder, welding rod, or metal being joined will
be released to air as metal/metal compounds if these operations are present at the
facility.
Stack test results provide the best data for estimating air releases from these
operations. Where no stack test data is available, emissions factors listed in AP-42
may be used. On-site land disposal or off-site transfers can be estimated by using the
volume of the waste and the percentage of metal/metal compound contained in the
waste. Releases to water or POTW may be estimated by using monitoring data as
required by EPA Effluent Guidelines.
28
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ACIDS
Acids are otherwise used in a wide variety of ways in foundry, coating, electro-
plating, and electronics operations. Sulfuric, hydrochloric, nitric, and phosphoric acids
were reported to TRI in 1990 for motor vehicle parts and accessories manufacturing.
Table 5 presents a summary of reported releases and off-site transfers of acids from
motor vehicle parts and accessories manufacturing.
Foundry operations use acids as cleaners, in finishing processes, and as a
constituent of scrubber water. Hydrochloric acid may be used to dean the cupola
shell. Phosphoric acid may be used in the phosphating of parts during finishing
processes. Sulfuric acid may be used as a constituent of scrubber water.
Coating operations utilize phosphoric acid in a pretreatment process. A hot
phosphoric acid bath is used to apply a conversion coating of zinc or iron phosphate
onto metal parts.
Electroplating operations utilize acids to control pH of plating baths, to clean
surfaces before and between plating steps, and as post-plating treatments (e.g.,
phosphate treatments). As described in the Metals and Metal Compounds section of
s
this profile, a mist is formed over the plating baths as a result of evolution of gases
during the electroplating process. This mist may contain acids from the plating bath
and subsequently released to the air.
Electronic operations utilize acids in a solvent degreasing process. Hydro-
chloric acid dip is used in the process before final rinsing and drying.
These acids from all of the operations are primarily released through off-site
transfer of spent acid. Some of the more volatile acids are released to air and some
are released to water if the stream is not neutralized to a pH greater than 6. Neutrali-
zation is the primary control used for acid releases. For acid use, releases to surface
waters and POTWs are not reportable under TRI if the pH is 6 or higher. Typically, pH
monitoring for other regulations, such as EPA Pretreatment Standards and Effluent
Limitations, is retained by the facility. These data may be used to calculate water or
POTW releases if excursions below pH of 6 occurred and only one acid is present in
the water.
29
-------
TABLE 5. SUMMARY OF REPORTED RELEASES OF ACIDS FROM MOTOR VEHICLE PARTS AND ACCESSORY MANUFACTURING
Mean release, 1b (X reporting to each media)
Section 313 chemical
Sulfurlc acid
Hydrochloric ftclo
Nitric acid
Phosphoric acid
NiMber of faclliyes
reporting usage
(X reporting usage)
155 (47)
64 (19)
SB (IB)
57 (17)
Fugitive
154 (31)
525 (58)
321 (43)
149 (30)
Stack
614 (40)
1.479 (52)
987 (50)
418 (37)
Water
e
5(2)
5 (3)
5 (2)
Land
0(0)
0(0)
0(0)
0 (0)
WTWC
e
e
e
e
Off-site
Transfer
e
e
6.360 (19)
11.753 (23)
Total'
36.442 (54)
23.804 (78)
3.339 (60)
7.993 (54)
* A total of 331 facilities In SIC 3714 reported usage of at least one Section 313 chemical above threshold limits.
b
Mean releases In pounds per year In 1990 for facilities reporting releases of this chemical and percentage of facilities reporting usage of
this chemical that release to this media. Releases to other media were Insignificant.
C POTW - Publicly Owned Treatment Works.
The total Includes all releases and off-site transfers, not just categories suimartzed In this table.
Mean value Is not representative because of a very large value at one facility and the small number of facilities.
-------
OTHER CHEMICALS
Three other chemicals are used in electroplating and coating operations. These
other chemicals are ammonia, ethylene glycol, and diethanolamine. All three of these
chemicals are used by only a small percentage of motor vehicle parts and accessories
manufacturers: ammonia, 13 percent; ethylene glycol, 9 percent; and diethanolamine
6 percent Table 6 presents a summary of reported releases and off-she transfers of
other chemicals from motor vehicle parts and accessories manufacturing.
Because of the wide variety of uses of these chemicals and the small percent-
age of the facilities that use them, IT could not determine specific uses at motor
vehicle parts and accessories manufacturers. The following are probable uses of
these chemicals.
Ammonia may be used in wastewater treatment or for pH adjustment of electro-
plating baths. Ammonia is also used as a constituent of some coatings. Because
ammonia is a listed Section 313 chemical, all gaseous and aqueous forms must be
considered for reporting. Aqueous solutions of ammonia contain both nonionized
ammonia (NHg) and ionized ammonia (NH/). As the following chemical equation
shows, an equilibrium exists between the two forms of ammonia in the presence of
water.
+ 2H2O ~ AW4* + OH' * H2O
The term total ammonia" refers to the sum of these species (i«e., NH3 + NH4*).
The relative amounts of NH3 and NH4* depend upon several factors (e.g., tempera-
ture, pH, bnic strength, and other chemical reactions). To account for all forms that
are present, estimates of releases for Section 313 should be made for total ammonia.
Ammonia hydroxide solutions should also be considered ammonia because
ammonium hydroxide is aqueous ammonia. The commercial products 'aqua ammo-
nia" and •ammonium hydroxide" are approximately equivalent to 30 percent solutions
31
-------
TABLE 6. SUMMARY OF REPORTED RELEASES OF OTHER CHEMICALS FROM MOTOR VEHICLE PARTS
AND ACCESSORY MANUFACTURING
Mean release. 1b (X reporting to each media)
Section 313 chemical
Affmonla
Ethylene glycol
Olethanolamlne
Number of faclliyes
reporting usage
(X reporting usage)
42 (13)
30(9)
21 (6)
Fugitive
836 (62)
382 (57)
2.395 (52)
Stack
2.643 (57)
7.820 (33)
1.148 (33)
Water
942 (7)
6.400 (3)
8.183 (10)
Land
0(0)
5(7)
0(0)
POTW"
.
17.628 (53)
40.092 (57)
Off -Site
Transfer
775 (5)
•
5.490 (29)
Totald
7,032 (79)
26.609 (100)
33.223 (81)
A total of 331 facilities In SIC 3714 reported usage of at least one Section 313 chemical above threshold limits.
Mean releases In pounds per year In 1990 for facilities reporting releases of this chemical and percentage of facilities reporting usage of
this chemical that release to this media. Releases to other media Mere Insignificant.
POTW - Publicly Owned Treatment Works.
The total Includes all releases and off-site transfers, not Just categories sumarlzed In this table.
Mean value Is not representative because of a very large value at one facility and the small number of facilities.
-------
of ammonia in water. These products are mixtures of ammonia and water, and there-
fore should be reported as ammonia. Ammonia is released to air and to water.
Ethylene glycol may be used in hydraulic fluid, as antifreeze, and as a residual
constituent in some resins. Release is primarily to water or POTW, probably through
teaks or spills.
No information was found on how diethanolamine is used in motor vehicle parts
and accessories manufacture. The largest release is to water or POTW with some
release to air or off-site transfer. Diethanolamine may be used as a corrosion inhibiter,
as a polyurethane crosslinker, or in coatings.
33
-------
REGULATIONS USEFUL FOR ESTIMATING RELEASES OF SECTION 313
CHEMICALS
No regulations are directly applicable to motor vehicle parts and accessory
manufacture. This is because SIC 3714 covers such a broad range of processes that
where regulations are applicable they are specific to a process type that is repre-
sented by only a small portion of the facilities in these industry categories. The EPA
Effluent Guidelines and Pretreatment Standards for Foundries and Electroplating are
the primary examples. The regulations for these categories are explained in the
individual Industry Profiles for these industries.23 For even these regulatory limits to
be useful, however, the inspector must have considerable knowledge of the processes
at the facility. This detailed knowledge of the plant processes is unlikely to be easily
available from public sources. Therefore, the more efficient way to determine the air
and water release regulatory limits for the plant in question is to go directly to the
Regional, State, or local files for the individual facility in question.
RCRA* reported wastes at motor vehicle parts and accessory manufacturers
can be extremely useful in estimating off-site transfers of Section 313 chemicals at
these facilities. The following RCRA generic wastes can be used to determine what
processes are at a facility and what quantities of these wastes are generated.
Waste No. Description
F001 Specified halogenated solvents used in degreasing
F002 Specified halogenated solvents
F003 Specified nonhalogenated solvents
F004 Specified nonhalogenated solvents
F005 Specified nonhalogenated solvents
F006 Wastewater treatment sludges from electroplating
F007 Spent cyanide plating bath sludges
F008 Spent cyanide plating bath sludges
Resource Conservation and Recovery Act.
34
-------
Waste No. Description
F009 Spent stripping and cleaning bath solutions at
electroplating operations where cyanides are used
F010 Quenching bath residues from oil baths from heat
treating metals where cyanides are used
F011 Spent cyanide solutions from salt bath pot cleaning
from metal heat treating operations
F012 Quenching wastewater treatment sludges from
metal heat treating where cyanides are used
35
-------
NONREPORTING FACILITIES
Nonreporting facilities may be identified by comparing lists of facilities in the
Standard Industrial Classification (SIC) 3714 having more than 10 employees with
those facilities that have .reported under Section 313. Most motor vehicle parts and
accessories manufacturers with more than 10 employees probably are manufacturing,
processing, or otherwise using at least one Section 313 chemical in excess of
threshold values.
A source of information on the number of facilities in SIC 3714 presented by
\
employment class is County Business Patterns published by the U.S. Department of
Commerce.6 Another source of information is Dunn and Bradstreet (D&B), which
provides lists of companies by SIC and employment size category.7 The 1990 TRI
database indicates 331 facilities reported, while County Business Patterns -1989
reports 1,817 facilities in SIC 3714 employing more than 10 employees and D&B •
1992 reports 2,384 facilities in SIC 3714 employing more than 10 employees.
36
-------
UST OF QUESTIONS
The following questions may be helpful in determining if errors were made in
Section 313 reporting for motor vehicle parts and accessory manufacturers. Since this
industry category is composed of a wide variety of facilities, general facility questions
to determine what the facility does are presented first.
General Facility
What products are produced at this facility?
Are foundry electroplating or electronics manufacturing operations done
at this facility?
Are metal or plastic products produced?
What metals are processed?
Are coatings applied to any parts?
Orpanic Solvents
Was a mass balance for organic solvents calculated that accounted for
total usage?
How were releases of organic solvents other than to air calculated?
If a solvent is reported as processed on Form R, what threshold was
used for all other organic solvents? The 10,000-pound threshold for
otherwise-used chemicals should be used.
Chlorinated Solvents
How were chlorinated solvents used?
Was the percentage of chlorinated solvent in any waste solvent
accounted for?
Was a mass balance accounting for all chlorinated solvent usage used to
estimate releases and off-site transfers?
For vapor degreasing with water separation, was release to water or
POTW estimated?
37
-------
Polvmer Chemicals
Was MSDS information used to estimate the quantity of unreacted
monomer in polymers used at the facility?
Were any polymers manufactured (polymerized) at the facility? What
were the reactants?
Metals/Metal Compounds
Were threshold determinations made for all metals/metal compounds
processed at the facility?
Did the facility determine if ft met the reporting thresholds from the
amount released or transferred instead of the amount processed or
otherwise used?
Were threshold determinations for metal compounds made using the
weight of the compound and not just the metal portion of the compound?
How was air release calculated? Were emission factors or monitoring
data used? What were these factors?
Was Toxicity Characteristic Leaching Procedure (TCLP) used as a
measure of metal concentration in any of the calculations? TCLP mea-
sures teachable metal, not metal content, and thereby should not be
used in calculations.
Acids
• Was the pH of the release measured or was neutralization just assumed?
What was the frequency of monitoring?
Was the percentage of acid in the original acid or solution taken into
account in the threshold calculations?
Other Chemicals
How were other chemicals used at the facility?
• Was total ammonia used to report ammonia release to water?'
38
-------
BIBLIOGRAPHY
1. Office of Management and Budget. Standard Industrial Classification Manual.
Washington, DC. 1987.
2. IT Corporation. TRI Facility Profile, Foundries. Prepared for U.S. Environmental
Protection Agency under Contract No. 68-DO-0020. Cincinnati, Ohio. July
1992.
3. Modem Plastics Encyclopedia. Vol. 65, No. 11. McGraw-Hill. October 1988.
4. Kirk-Othmer Encyclopedia of Chemical Technology. Third Edition. Volume 6.
Coatings, Industrial. Wiley & Sons. 1982.
5. IT Corporation. TRI Facility Profile, Electroplating. Prepared for U.S. Envi-
ronmental Protection Agency under Contract 68-DO-0020. Cincinnati, Ohio.
June 1992.
6. U.S. Department of Commerce, Bureau of Census, County Business Patterns
1989, CBP-89-1 Washington, DC. 1991.
7. Dunn & Bradstreet. International Dunn's Electronic Business Directory in
DIALOG Database File 515. 1992.
39
-------
TRI FACILITY PROFILE
FURNITURE MANUFACTURE
by
IT Corporation
11499 Chester Road
Cincinnati, Ohio
Contract No. 68-DO-0020
Work Assignment No. 2-27/2-65/3-18
JTN 830015-5-1
Prepared for
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF TOXIC SUBSTANCES
401 M Street, S.W.
Washington, D.C 20460
September 1992
-------
CONTENTS
Page
Section 313 Chemicals Used in Furniture Manufacture 6
Wood Furniture, With Coatings 6
Wood Furniture, Lower Coating Use 17
Metal Furniture 21
Other Furniture 30
Regulations Useful for Estimating Releases of Section 313 Chemicals 36
Nonreporting Facilities 40
List of Questions 42
Bibliography 44
Appendix A Selected Information on the Furniture Industry A-l
11
-------
TABLES
Number Page
1 Selected Information on Furniture Spray Coating 4
2 Typical Wood Furniture Finishing Schedule 8
3 Summary of Reported Releases of Organic Solvents From the
Manufacture of Wood Furniture With Coatings 10
4 Summary of Reported Releases of Chlorinated Solvent From the
Manufacture of Wood Furniture With Coatings 12
5 Summary of Reported Releases of Metals and Metals Compounds
From the Manufacture of Wood Furniture With Coatings 14
6 Summary of Reported Releases of Other Chemicals From the
Manufacture of Wood Furniture With Coatings 16
7 Summary of Reported Releases of Organic Solvents From the
Manufacture of Wood Furniture, Lower Coating Use 18
8 Summary of Reported Releases of Chlorinated Solvents From
the Manufacture of Wood Furniture, Lower Coating Use 20
9 Typical Operating Parameters for Coating Operations 21
10 VOC Emission Factors for VOC Surface Coating Operations 24
11 Summary of Reported Releases of Organic Solvents From the
Manufacture of Metal Furniture 25
12 Summary of Reported Releases of Chlorinated Solvents From the
Manufacture of Metal Furniture 26
13 Transfer Efficiencies for Metal Furniture Coating 28
111
-------
TABLES (continued)
Number Table
14 Summary of Reported Releases of Metals and Metal Compounds
From the Manufacture of Metal Furniture 29
15 Summary of Reported Releases of Organic Solvents From the
Manufacture of Other Furniture 31
16 Summary of Reported Releases of Chlorinated Solvents From the
Manufacture of Other Furniture 32
17 Summary of Reported Releases of Metals and Metal Compounds
From the Manufacture of Other Furniture 34
18 Summary of Reported Releases of Other Chemicals From the
Manufacture of Other Furniture 35
19 Summary of Effluent Limitations for Metal Finishing 37
20 Number of Facilities With More Than 10 Employees 41
rv
-------
TRI FACILITY PROFILE
FURNITURE MANUFACTURE
The purpose of this profile is to assist U.S. Environmental Protection Agency
r
(EPA) Regional Office personnel in conducting Superfund Amendments and Reauthori-
zation Act (SARA) Title ID, Section 313, inspections. The profile describes key toxic
chemicals manufactured, processed, or otherwise used in furniture manufacture, de-
scribes how these chemicals are used, and identifies key release sources. All Section 313
chemicals reported to the Toxic Release Inventory (TRI) by more than 5 percent of the
furniture manufacturers are presented in this profile.
The furniture manufacturing industry is defined by SIC 25, Furniture and Fixtures.
For purposes of this profile, the industry is divided into four categories:
.Wood Furniture With Coatings defined under'SIC 2511 - Wood Household
Furniture, Except Upholstered; SIC 2517 - Wood Television, Radio,
Phonograph, and Sewing Machine Cabinets; and SIC 2521 - Wood Office
Furniture.
• Wood Furniture. Lower Coatings Use, defined under SIC 2512 - Wood
Household Furniture, Upholstered, and SIC 2541-Wood Office and Store
Fixtures, Partitions, Shelving, and Lockers.
• Metal Furniture defined under SIC 2514 - Metal Household Furniture.
• Other Furniture defined under SIC 2515 - Mattresses, Formulations, and
Convertible Beds; SIC 2519 - Household Furniture, not Elsewhere
Classified; SIC 2525 • Office Furniture, Except Wood; SIC 2531 • Public
Building and Related Furniture; SIC 2542 - Office and Store Fixtures,
Partitions, Shelving, and Lockers, except Wood; SIC 2591 - Drapery
Hardware and Window Blinds and Shades; and SIC 2599 - Furniture and
Fixtures, Not Elsewhere Classified.
-------
Figure 1.presents a simplified process flow diagram of the furniture manufacturing
process. The flow diagram includes both wood and metal furniture manufacture.
Woodworking associated with the manufacture of wood furniture parts can
include mechanical manipulations of wood or wood by-products including sawing,
planing, chipping, shaping, lathing, and sanding. Although these operations generate
wood waste particles such as shavings, sanderdust, or sawdust, they do not generally
release Section 313 chemicals.
The fabrication of metal furniture consists of cutting, bending, and possibly
grinding of the metal. Section 313 metals (e.g. Cr, Mn) may be present in the metal
used, however, in most cases the quantity processed will be below the 25,000 pound
threshold.
Adhesives may be used for several purposes in furniture manufacture. They may
be used to glue wood veneer on wood furniture products, to glue laminates on wood or
metal furniture products, or to glue wood furniture pans together. Some adhesives
contain chlorinated solvents or organic solvents that are released to air upon application.
The furniture coating application (including stains) uses the largest quantity of
Section 313 chemicals in both wood and metal furniture manufacture. A wide variety of
solvents are otherwise used to apply the coatings. Metals/metal compounds and polymers
are processed as pan of the coatings. The coatings are applied by a variety of methods
including spray coating, dip coating, flow coating and manual coating. Table 1 presents
selected information on both wood and metal furniture spray coating operations. After
the coating dries a manual touch-up repairs any imperfections.
Other operations that do not involve use of Section 313 chemicals include
upholstery application, mounting of metal hardware, and final assembly.
-------
Adhesive*
Veneer or
Laminate
Application
Wood Parts
Manufacture
Manufacture
Shipment
Figure 1.
Simplified Process Flow Diagram of
Furniture Manufacture.
I DRAWING I JU I
BY F *•
CHECKED BY
APPROVED BY
*- fr.
I '*> I
DRA«'
NO
122
-------
TABLE 1. SELECTED INFORMATION ON FURNITURE SPRAY COATING
1
Wood
Metal
Coating components
Resins: Urea formaldehyde, catalyzed
urethane, nitrocellulose, acrylic,
oil-based.
Solvents: Acetates, acetone, alco-
hols, aromatic hydrocarbons, ethers,
glycol ethers, ketones, mineral
spirits.
Pigments: Silica, calcium carbonate,
Iron oxide, titanium dioxide, talc.
Coating classifications Mostly low-solids, solvent-based.
Coating compositions
(% Weight as applied)
Overspray
Body stain: 1% solids.
Washcoat: 8 to 10% solids.
Filler: 40% solids.
Sealed (barrier coat): 14 to 23%
solids.
Glaze: 21 to 24% solids.
Clear lacquer (topcoat): 14 to 15%
percent solids
Air atomized: More than 50%.
Airless: Less than 50%.
Resins: acrylics, amines, vinyls,
celluloslcs.
Solvents: Allphatlcs, xylene, tolu-
ene, other aromatlcs.
Pigments: Titanium dioxide, Iron,
barium compounds, talc, calcium car-
bonate, chromium compounds.
Waterborne; solvent-borne (conven-
tional and high solids).
Solvent-based (conventional): 15 to
25% solids.
Solvent-based (high-solids): 40 to
60% solids.
Waterborne (15 to 25% solids).
Air-atomized: 50% to 75%.
Airless: 75%
(continued)
-------
TABLE 1 (continued)
Wood
Metal
Overspray (continued)
Electrostatic:
Manual - 40%
Nonrelational automatic - 30%
Rotational (manual/automatic)
to 20%.
- 5
Solvent discharge
Exposure/release controls
Appllcatlon/Flash-off - 80 to 90%.
Oven drying 10 to 20%.
Spray booths with disposable filters
and turning vanes. Filters are
changed at the end of a shift.
Makeup air Is provided.
Particle removal efficiencies could
range from 94 to 96%.
AppHcatlon/Flash-off - 80% (air-atom-
ized), 65 to 70% (electrostatic.
Oven drying: 20% (air-atomized), 30
to 35% (electrostatic).
Filter bank with makeup air supplied
from opposite the exhaust filter, bank,
and fram-f11tered-a1r Inlets In each
conveyor exit. Mater-washed spray
booths are also used. Thick mesh pre-
fliters are sometimes fitted over the
water curtains (side draft) to reduce
booth cleanup time/frequency.
These prefliters are changed period-
ically (some shifts may not apply
enough paint to clog filters).
Particle-removal efficiencies of
water-washed booths could range from
95 to 99%.
(continued)
-------
SECTION 313 CHEMICALS USED IN FURNITURE MANUFACTURE
Section 313 chemicals commonly used in furniture manufacture can be classified
into four distinct categories: organic solvents, chlorinated solvents, metals/metal
compounds, and other Section 313 chemicals. Each category is discussed separately in
this report. Each section includes a description of how the Section 313 chemicals are
used, a discussion of typical releases and off-site transfers, a table summarizing releases
and off-site transfers that were reported to TRI in 1990, a description of pertinent
regulations, typical control practices, and common reporting errors. Methods for
identifying nonreporting facilities and a list of questions are also presented.
WOOD FURNITURE, WITH COATINGS
This category includes wood furniture that would likely have stains and coatings
applied to the finished product. Most of the releases and off-site transfers of Section 313
chemicals are associated with the application of these coatings or with the use of
adhesives. Wood furniture coating is characterized by many manual operations. A great
variety of procedures and formulas are used in furniture coating. The decorative effect
of finishes often relies on the appearance of the fibrous structure of the wood itself.
This appearance is enhanced by the addition of transparent coatings that penetrate pores
and the addition of pigments that fill the pores and also improve the color uniformity of
the wood. Nitrocellulose has advantages over other treatments in its ease of application
and drying and in the degree to which it highlights natural wood patterns.2
In general, the wood is stained to a uniform desired color (bleaching may be a
necessary first step); stains may be applied using water or solvent A typical stain would
contain about 1% of a dye mixture in methanol and might contain a small amount of
less-volatile solvent2
A sealer coat is then applied and sanded. The sealer might be a 15%
nitrocellulose-based vehicle ; 1% colloidal silica (for filling, flatting, and transparency);
1% zinc stearate (for easy sanding); and mixtures of alcohol, ester, and hydrocarbon
solvents appropriate for the spray system and ambient temperature in the factory.2
-------
A wiping stain may be applied instead of the separate stain and sealer. When this
stain is applied, the excess must be wiped off.
Shellac-type sealers may contain 10% binder (50% shellac and 50% other film
formers such as nitrocellulose or poly(vinyl butyryl) and 90% solvent. Transparent
pigments such as silica or zinc stearate can be added to improve sanding properties.2
The finish coat is usually nitrocellulose based. The binder may contain about
35% nitrocellulose and 65% of a mixture of nitrocellulose and plasticizers, which may
include simple esters, polyesters, and esters of rosin.2
Urea-formaldehyde resins, acid catalyzed to permit low-temperature drying, are
second to nitrocellulose in the furniture market. A typical formulation would consist of
45% butylated urea-formaldehyde resin and 55% plasticizers dissolved in aromatic
hydrocarbon, alcohol, and ketone solvents.
Table 2 presents a process schedule for a typical wood furniture finishing
operation.1
Each of the four categories of Section 313 chemicals will be discussed separately.
Organic solvents are otherwise used as constituents of stains, coatings, or
adhesives applied at the facilities. SARA, Section 313 organic solvents used in coatings
include toluene, methanol, xylene, glycol ethers and ethylbenzene. SARA, Section 313
organic solvents used in adhesives include MEK, MIBK, xylene, and toluene. Most of
the organic solvent emissions are released to the air when the coating is dried. If a
water curtain is used to capture paniculate releases during spray coating operations,
some organic solvents may be transferred to water to public owned treatment works
(POTW).
Organic purge solvents for cleaning spray equipment or for other cleanup pur-
poses may be transferred off site for recycling, fuel burning, or disposal. SARA, Section
313 organic solvents used in purge and cleanup solvents include acetone, toluene, and
methanol.
Two major sources of spent solvent in wood furniture finishing are from furniture
stripping or "wash-off and from finishing equipment and spray booth cleanup. In the
-------
TABLE 2. TYPICAL WOOD FURNITURE FINISHING SCHEDULE
i
Operation
No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Operation name
Load
Spray uniform stain
Dry
Spray stain
Dry
Spray wash coat
Dry
Sand lightly
Spray filler
Flash-off filler
Wipe filler
Dry
Spray sealer
Dry
Sand
Spray sealer
Dry
Sand
Spray glaze
Wipe and brush
Dry
Distress
Spray lacquer
Dry
Spray lacquer
Dry
Unload
Return to load
TOTAL
Operation
time allowed,
minutes
5
1.5
15
1.5
20
1.5
20
1.5
1.5
2
4
45
1.5
30
3
1.5
30
3
1.5
5
60
2
1.5
45
1.5
75
5
15
399
No. of persons
per operation
1
2
2
2
4
2
8
2
7
2
7
2
13
4
2
2
1
63
8
-------
"wash-off process, improperly finished furniture is stripped of the defective finish by
means of a lacquer thinner or "stripper" which is reused until too dirty for further use.
Spray guns, feed lines, and spray booths are regularly cleaned with lacquer thinner which
goes into the waste stream after being used for cleanup. Some spent solvent also comes
from an occasional batch of defective finishing materials. Virgin stripper is usually a
mixture of toluene, xylene, acetone, ethanol, butanol, isopropyl alcohol, naphtha, methyl
ethyl ketone and esters.3
Spent solvents from wash-off and spray booth cleanup are usually contaminated
with stains, fillers, glazes and nitrocellulose. Since the solvents used are normally non-
halogenated and have high BTU values, spent solvents from the furniture industry are
much easier to dispose of than from industries which use halogenated solvents or pro-
duce low BTU wastes. Because of the high BTU value and the absence of halogens in
their waste streams, some companies have been incinerating their spent solvents or burn-
ing them for fuel. As the price of petroleum products and solvents increases, more and
more furniture plants are recycling their spent solvents either in-house or through an
outside recycler.3
Transfers off site for recycling or fuel burning were not reportable under Section
313 until 1991 (estimates due July 1, 1992). Table A-l in Appendix A presents more
information on wastes generated in the furniture industry.
Paniculate control equipment may consist of fabric filters or a water wash.
Releases of volatile organic carbon (VOC) at large facilities may be controlled by in-
cineration or other pollution equipment.
The best method of verifying release estimates is to calculate a mass balance
based on total usage of organic solvents with almost all of the emission released to air or
sent to an air control device (e.g., an incinerator).
Table 3 presents a summary of reported releases and off-site transfers of organic
solvents resulting from wood furniture manufacture with coatings.
Chlorinated solvents are otherwise used in wood furniture manufacture as a
solvent in adhesives and as a coating stripper. Adhesives are used in wood furniture
manufacture to apply veneer or laminates to a wood or wood composite base or to glue
-------
TABLE 3. SUMMARY OF REPORTED RELEASES OF ORGANIC SOLVENTS FRON
THE MANUFACTURE OF WOOD FURNITURE WITH COATINGS
Hean release. 1b (X reporting to each media)6
No. of facilities
reporting usage
Section 313
chemical*
Toluene
Methanol
Xylene
(mixed
Isomers)
NEK
Acetone
n-Butyl
alcohol
NIBK
Glycol
ethers
Ethyl ben-
zene
(X reporting
usage)
257 (100)
196 (76)
195 (76)
151 (59)
125 (49)
96 (37)
59 (23)
31 (12)
8 (3)
Fugitive
8,391 (70)
6,256 (67)
8,180 (66)
3,529 (69)
6,648 (69)
1,955 (66)
5,906 (78)
3,344 (54)
1,781 (100)
Stack
4,913 (96)
44,831 (96)
32,219 (96)
28,380 (97)
28,825 (96)
23,423 (99)
28,901 (98)
22,836 (94)
19,860 (100)
ROTH*
1,231 (5)
291 (6)
1,067 (6)
292 (6)
251 (6)
922 (8)
521 (5)
g
325 (25)
Off -site
transfer*
4,757 (30)
3,719 (27)
2,961 (30)
6,644 (28)
5,754 (26)
1,545 (33)
4,235 (39)
5,770 (35)
1,969 (25)
Total*
52,608 (100)
48,433 (100)
37,796 (100)
32,406 (99)
33,787 (100)
25,054 (100)
35,307 (98)
26,992 (100)
23,078 (100)
Isopropyl alcohol (IPA) MM reported by 20 facilities, since IPA Is only reporteble by manufacturer* of IP*, I PA Is not repor table In the
furniture Manufacture Industry.
A total of 257 facilities In SIC* 2511. 2517. and 2521 reported usage of at least one Section 313 chemical above the threshold Units.
Neon release In pounds per year In 1990 for fires reporting release of this chemical and percentage of firms reporting usage of this chemical and
releaae to this media. Releases to other media were Insignificant.
POTU • Publicly Owned Treatment Works.
Off-site transfer for recycling or fuel blending was not reportable In 1990; transfer off site of purge or cleanup solvent'for these purposes will
be reporteble In 1991.
The total Includes all releases and off-alto transfers, not just categories turner1zed In this table.
Mean value la not representative because of one high-value.
-------
wood parts together. 1,1,1-Trichloroethane is the primary chlorinated solvent used in
adhesives at furniture manufacturers. If plastic parts are used as part of the furniture,
chlorinated solvents can be used as a plastic adhesive or as a mold release carrier in the
process.
Methylene chloride may be used to strip coatings from defective products, from
the walls of the spray booth, from brushes, spray guns, or from other equipment. Meth-
ylene chloride may also be used to refinish furniture.
Chlorinated solvent used by wood furniture manufacturers is primarily released to
air. Some dichloromethane used to strip furniture, spray booths, or equipment may be
transferred off site for disposal.
No controls are typically used to reduce the release or off-site transfer of
chlorinated solvents at furniture manufacturing facilities. Also, off-site transfers would
not typically be recycled. Therefore, the best method for estimating releases is a mass
balance based on total usage of chlorinated solvent The quantity of chlorinated solvent
transferred off site may be estimated by determining the quantity and concentration of
waste generated at the facility under guidelines established by the Resource
Conservation and Recovery Act (RCRA).
RCRA wastes are defined in § 261 of RCRA. Specific chlorinated solvents are
identified in § 26131 as wastes from nonspecific sources or T" waste. F002 generic
RCRA wastes are spent solvent wastes that prior to use contained over 10 percent of
the listed chlorinated solvents. Table A-l in Appendix A presents more information on
wastes generated in the furniture industry. Use of 1,1,1-trichloroethane is expected to
drop significantly because of EPA environmental regulation to reduce ozone depletion.
These regulations will eventually phase out the use of this solvent entirely.
Table 4 presents a summary of Section 313 reported releases and off-site transfers
from use of chlorinated solvents at wood furniture manufacturers applying coatings.
Metals/metal compounds are processed at wood furniture manufacturers as
constituents of coatings because they remain as pan of the furniture and are therefore
subject to the 25,000-pound threshold. Very few furniture manufacturers will exceed this
threshold for any individual metal or metal compound. Even if the threshold is
11
-------
TABLE 4. SUMMARY OF REPORTED RELEASES OF CHLORINATED SOLVENT FROM THE MANUFACTURE
OF HOOD FURNITURE NITH COATINGS
Hean release. Ib (X reporting to each media)*
a
b
e
d
e
No. of facilities
reporting usage*
Section 313 (X reporting
chemical usage)
1.1,1-Trl- 36 (14)
chloroethane
Dlchloro- 9 (4)
methane
Fugitive Stack
15.967 (78) 36.042 (81)
13.804 (100) 18.340 (44)
A total of 257 of facilities In SICs 2511. 2517. and 2521 reported usage of
Mean release In pounds par year In 1990
and release to this media. Releases to
POTO • Publicly toned Treatment Works.
Off -site transfer for recycling was not
•»•_._ «L._.A_.I • * — • — ,^1 • _».t AAAAB. &&J KjTaY_
for firms reporting release of this
other media were Insignificant.
report abl* In 1990.
Water
or Off -site
Land POTW transfer' Total*
13.300 (3) 250 (6) 5.965 (17) 42.830 (100)
12.095 (78) 31.362 (100)
at least one Section 313 chemical above the threshold limits.
chemical and percentage of firms reporting usage of this chem
«^«__l*_J
-------
exceeded, releases and off-site transfers will be small. Table 5 presents a summary of
Section 313 reported releases and off-site transfers of metals/metal compounds at wood
furniture manufacturers applying coatings.
If a facility is large enough to exceed the threshold for metals/metal compounds,
it is likely that the spray booth will be controlled with a water wash to capture
particulates and send them to a settling basin. Most of the metals/metal compounds are
removed from the settling basin periodically and transferred off site for disposal. Some
of the metals/metal compounds will be released to water or POTW. A small quantity of
metals/metal compounds not captured in the water wash will be released to air through
a stack.
Other Section 313 chemicals are processed at wood furniture manufacturers as
constituents of the coatings. Di-(2-ethylhexyl)phthalate (DEHP), formaldehyde, and
styrene may be present in resins used as coatings on wood furniture. Formaldehyde may
also be present in glues used during furniture manufacture. Although most of these Sec-
tion 313 chemicals are reacted to form the resin, some will remain unreacted and there-
fore will be released on site or transferred off site. The percentage of unreacted
chemical should be available on the Material Safety Data Sheet (MSDS) pertaining to a
specific coating.
Table 6 presents a summary of reported releases and off-site transfers of these
other Section 313 chemicals from wood furniture manufacture with coatings. The
primary release is to air with some off-site transfer possible if waste resin or coating is
sent off site for disposal. Releases and off-site transfers are best estimated based on
information contained on the MSDS specifying the quantity of unreacted'chemical in the
13
-------
TABLE 5. SUMMARY OF REPORTED RELEASES OF METALS AND METALS COMPOUNDS FROM
THE MANUFACTURE OF WOOD FURNITURE WITH COATINGS
Section 313
chemical
Barium
Barium compounds
Zinc (fume or
dust)
Zinc compounds
Chromium
Chromium com-
pounds
Nickel
Nickel compounds
Manganese
Manganese
compounds
Copper
Copper compounds
Cobalt compounds
No. of facilities
reporting usage"
(% reporting
usage)
1 (0.4)
7 (3)
1 (0.4)
4 (2)
2 (1)
3 (1)
2 (1)
2 (1)
2 (1)
1 (0.4)
1 (0.4)
2 (1)
1 (0.4)
Mean
Fugitive
250 (100) 5
250 (14)
1 (100)
378 (50)
250 (50)
-
250 (50)
-
126 (100)
-
3 (100)
-
-
release, Ib
Stack
,933 (100)
635 (43)
10 (100)
250 (50) 2
1 (50)
-
250 (50)
-
32 (50)
-
54 (100)
-
-
(X reporting to each media)*
Off-site
POTW* transfer*
6,
375 (29) 5,741 (100) 6,
-
,560 (25) 1,983 (75) 3
-
418 (100)
250 (50) 4,945 (50) 2,
250 (50) 383 (100)
-
2 (100)
-
500 (100)
6 (100)
Total*
183 (100)
156 (100)
11 (100)
,254 (75)
126 (la)
418 (100)
848 (100)
508 (100)
142 (100)
2 (100)
57 (100)
500 (100)
6 (100)
(continued)
-------
TABLE 5 (continued)
No. of facilities
reporting usage"
Section 313 (X reporting
chemical usage)
Lead compounds 1 (0.4)
Antimony com- 1 (0.4)
pounds
a A total of 257 facilities 1n SICs 2511,
leal above the threshold limits.
Mean release,
Fugitive Stack
- -
2517, and 2521 reported
Ib (X reporting
POTW
-
to each media)..
Off -site
transfer" Total"
750 (100) 750 (100)
750 (100) 750 (100)
usage of at least one Section 313 chem-
firms reporting usage of this chemical and release to this media. Releases to other media were
Insignificant.
c POTW - Publicly Owned Treatment Works.
The total Includes all releases and off-site transfers, not just categories summarized In this table.
-------
TABLE 6. SUMMARY OF REPORTED RELEASES OF OTHER CHEMICALS FROH THE MANUFACTURE OF
WOOD FURNITURE WITH COATINGS
Section 313
chemical
DEHP
Formaldehyde
Styrene
No. of facilities
reporting usage"
(% reporting
usage)
22 (9)
13 (5)
5 (2)
Mean release, Ib (X reporting to each med1a)b
Off-site
Fugitive Stack POTVf transfer Total*
2,103 (59) 12,714 (86) - 8,434 (23) 15,553 (91)
2,633 (77) 2,870 (77) 250 (15) 622 (38) 4,549 (100)
833 (40) 14,363 (100) - - 14,969 (100)
a A total of 257 facilities In SICs 2511, 2517, and 2521 reported usage of at least one Section 313 chem-
ical above the threshold limits.
Mean release In pounds per year In 1990 for firms reporting release of this chemical and percentage of
firms reporting usage of this chemical and release to this media. Releases to other media were
Insignificant.
c POTW - Publicly Owned Treatment Works.
d The total Includes all releases and off-site transfers, not just categories summarized 1n this table.
-------
WOOD FURNITURE, LOWER COATING USE
This category includes wood furniture that would tend to use less coatings.
Coating use would be lower because either upholstery covers a wood frame or laminates
are used to cover the wood. Although, parts of the furniture may be stained or coated,
coating use generally would be lower than for the wood furniture with coatings category.
Only two of the four categories described in wood furniture with coatings would
typically be used in this category. These categories are organic solvents and chlorinated
solvents. Metals/metal compounds and other chemicals (containing the constituents of
resins) typically are not used above threshold limits.
Organic solvents are otherwise used as constituents of stains, coatings, or
adhesives. The percentage of facilities reporting use of organic solvents above threshold
limits is lower than for wood furniture with coatings, and the releases and off-site trans-
fers reported are lower for those facilities that do report usage of organic solvents. The
same organic solvents are reported as were reported for wood furniture with coatings,
and the same controls would be used.
The best method for checking release estimates is to calculate a mass balance
based on total usage of the organic solvents with almost all of the usage released to air
or sent to an air control device (e.g., incinerator).
Table 7 presents a summary of reported releases and off-site transfers of organic
solvents from wood furniture manufacture, lower coating use.
Chlorinated solvents are otherwise used in wood furniture manufacture as a
solvent in adhesives and to a lesser extent as a coating stripper. Adhesives are used in
wood furniture manufacture to apply veneer or laminates to a wood or wood component
base or to glue wood parts together. If plastic parts are used as pan of the furniture,
chlorinated solvents can be used as a plastic adhesive or as a mold release carrier in the
process. Dichloromethane may be used to strip coatings from defective products, from
the walls of the spray booth, or from other equipment. Usage of 1,1,1-trichloroethane is
higher in this category than for wood furniture with coatings, and reported releases for
those facilities that did report usage is also higher. Dichloromethane use is similar to
17
-------
TABLE 7. SUMMARY OF REPORTED RELEASES OF ORGANIC SOLVENTS FROM THE MANUFACTURE OF MOOD
FURNITURE, LOWER COATING USE
No. of facilities
reporting usage"
Section 313 (% reporting
chemical" usage)
Toluene
Methanol
Xylene (mixed
Isomers)
MEK
Acetone
n- Butyl
alcohol
MIBK
Glycol ethers
58 (88)
23 (35)
23 (35)
23 (35)
19 (29)
10 (15)
10 (15)
5 (8)
Mean
Fugitive
7,359 (62)
3,653 (70)
2,162 (61)
5,069 (57)
6,174 (74)
993 (90)
2,188 (60)
1,733 (80)
release, Ib (% reporting to each media)0
Stack
22,660 (90)
16,351 (87)
50,980 (100)
16,016 (87)
11,028 (89)
18,612 (100)
10,043 (90)
41.925 (60)
Off-s1teH
transfer*1
2,624 (38)
1,945 (35)
4,552 (39)
1,518 (26)
12,394 (26)
2,156 (40)
2,785 (40)
800 (20)
Total*
25,918 (100)
17,435 (100)
54,007 (100)
17,188 (100)
17,678 (100)
20,368 (100)
11,465 (100)
26,701 (100)
a Isopropyl alcohol (IPA) was reported by three facilities. Since IPA Is only reportable by manufacturers
of IPA, this Is not reportable In the furniture manufacture Industry.
b A total of 66 facilities In SICs 2512 and 2541 reported usage of at least one Section 313 chemical above
the threshold limits.
c Nean release 1n pounds per year 1n 1990 for firms reporting release of this chemical and percentage of
firms reporting usage of this chemical and percentage of firms regulating usage of this chemical and
release to th.1s media. Releases to other media were Insignificant.
d Off-site transfer for recycling or fuel blending was not reportable 1n 1990; transfer offsite of purge or
cleanup solvent for these purposes will be reportable 1n 1991.
e The total Includes for all releases and off-site transfers, not Just categories summarized In this table.
-------
that for wood furniture manufacture with coatings. No controls are typically used and
off-site transfer would typically not be for recycling. Therefore, the best method for
estimating releases is a mass balance based on total usage of the chlorinated solvent.
The quantity of chlorinated solvent transferred off site may be estimated based on the
quantity and concentration of RCRA waste (F002) generated as described previously.
Table 8 presents a summary of Section 313 reported releases and off-site transfers
from use of chlorinated solvents at wood furniture manufacturers with lower coating use.
19
-------
TABLE 8. SUMMARY OF REPORTED RELEASES OF CHLORINATED SOLVENTS FROM THE MANUFACTURE OF WOOD
FURNITURE. LOWER COATING USE
Mean release, 1b (X reporting to each med1a)b
Section 313
chemical
1,1,1-TH-
chloroethane
Dlchloro-
methane
Trlchloro-
8 ethyl ene
No. of facilities
reporting usage"
(% reporting
usage)
15 (23)
* (6)
1 (2)
Fugitive Stack POTH°
22,054 (60) 54,321 (80) 5 (7)
11,203 (100) 12,342 (75)
6,645 (100)
Off-site
transfer"
1,634 (27)
5,042 (25)
Total9
57,125 (100)
21,720 (100)
6,645 (100)
a A total of 66 facilities In SICs 2512 and 2541 reported usage of at least one Section 313 chemical above
the threshold limits.
Mean release In pounds per year 1n 1990 for firms reporting release of this chemical and percentage of
firms reporting usage of this chemical and percentage of firms regulating usage of this chemical and
release to this media. Releases to other media were Insignificant.
c POTH - Publicly Owned Treatment Works.
Offsite transfer for recycling was not reportable In 1990.
e The total Includes all releases and off-site transfers, not just categories summarized In this table.
-------
METAL FURNITURE
This category includes metal household furniture. Some metal furniture is also
produced in some of the SICs classified in this report as "other furniture." The
definitions of these other categories were redefined from "metal" to "except wood" in the
SIC categories. To avoid confusion, therefore, the metal furniture category will include
SICs that remain exclusively metal.
Table 9 presents typical operating parameters for metal furniture coating for three
plant sizes.4 Metal furniture pieces are loaded onto an overhead conveyor moving at
speeds of 25 to 7 meters per minute.5 Coating of metal furniture is usually preceded by
a three or five stage washer. A five-stage cleaning process contains the following steps:
1. Alkaline cleaner wash
2. Iron phosphate
3. Hot-water rinse
4. Chromic wash
5. Cold-water rinse
TABLE 9. TYPICAL OPERATING PARAMETERS FOR COATING OPERATIONS4
Plant
size
Small
Medium
Large
Operating
schedule
h/yr
2,000
2,000
2,000
No. of lines
1
(spray booth)
2
(3 booths/line)
10
(3 booths/line)
Line speed"
m/min
2.5
2.4
4.6
Surface
area
coated
nr/yr
45,000
780,000
4,000,000
Coating
used, lb
5,000
87,100
446,600
a Line speed is not used to calculate emissions, only to characterize plant
operations.
Based on 35 volume percent solids coating, applied by electrostatic spray
at 65 percent transfer efficiency.
21
-------
Alkaline cleaning removes oil and grease, and phosphate treatment improves the ad-
hesion characteristics of the surface.5 Most metal furniture coating operations only use a
3-stage cleaning process (Steps 1, 2, and 3). After washing, the furniture or furniture
parts pass through a dry-off oven and then into the coating operation. Coating
application methods include spray coating, dip coating, and flow coating. Electrostatic
spray coating is the most common application method.5 After coating, the solvent is
allowed, to flash-off and the paint is then dried in an oven.
Transfer efficiency for paint solids varies from 60 to 95% depending on the type
of application equipment and the configuration of the item being painted. Because of
the length of time that the item is in the booth and flash-off area, approximately 70% of
the solvent evaporates prior to the oven.5
Dip coating is the second most commonly used method of paint application.1
Items to be coated are loaded onto an overhead conveyor that lowers them (manually or
automatically) into the paint dip tank.6 They are then raised from the tank and
suspended in the flash-off area over a drain board. Approximately 40 percent of the
solvent emissions are released during application and flash-off. Transfer efficiency is
approximately 90%.6
Flow coating is the least-used application method.6 For topcoat application,
furniture items are carried by an overhead conveyor into a flow-coating chamber.4 In the
chamber, paint is directed at the object from many angles through as many as 100
nozzles.6 The nozzles effectively form a curtain of paint through which the furniture
items must pass.
After application, the coated objects are held over a drain board in a flash-off
area and then are moved to a curing oven. Approximately 80% of all solvent emissions
are released in the application and flash-off areas.6 Transfer efficiency is estimated at 90
percent with no significant differences with varying object shapes.6
Three of the four categories described in wood furniture with coatings would
typically be used in the metal furniture category. The "other chemicals" categories
containing constituents of resins are not typically used.
22
-------
Organic solvents are otherwise used as constituents of paints for coating metal
furniture. Solvent emissions in the metal furniture coating industry are directly related
to the types of coating materials used and the technique used to apply the coating.1
Controls of organic solvent release include add-on air pollution control equipment such
as thermal or catalytic incinerators or carbon adsorbers. The most prevalent control
involves process changes such as the use of high solids paint, powder coatings, water-
borne coatings, or increased transfer efficiencies. Additional information on methods
that may be used to control VOCs from metal furniture coating is found in the EPA
Control Techniques Guideline (CTG) document6 or AP-42.4
Table 10 presents AP-42 emission factors for determining total VOC releases
from metal furniture coating operations.4 The best method for calculating releases and
off-site transfers of VOC in metal furniture coating is a mass balance taking into account
using total annual chemical usage. Most releases are to air with some transfer offsite for
disposal of purge solvent or waste paint.
Table 11 presents a summary of Section 313 reported releases and off-site transfer
of organic solvents from the manufacture of metal furniture.
Chlorinated solvents are otherwise used in adhesives and as a coating stripper in
metal furniture manufacture. Adhesives may be used in metal furniture manufacture to
apply laminates. Chlorinated solvents may also be used as a metal degreasing solvent at
some facilities. Dichloromethane may be used to strip coatings from defective products, •
from the walls of the spray booth, or from other equipment.
For all chlorinated solvent usage, the primary release is to air. Dichloromethane
used to strip furniture, spray booths, or equipment, may be transferred offsite for
disposal No controls are typically used to reduce releases or off-site transfers of
chlorinated solvents at metal furniture manufacturing facilities. Off-site transfers may be
F002 RCRA wastes.
Table 12 presents a summary of Section 313 reported releases and off-site
transfers from use of chlorinated solvents by metal furniture manufacturers.
23
-------
TABLE 10. VOC EMISSION FACTORS FOR VOC SURFACE COATING OPERATIONS4
VOC emissions8
Plant size and control technique
kg/m2 coated kg/yr
kg/h
Small
Uncontrolled emissions
65 Volume X high solids
Waterborne coating
Medium
Uncontrolled emissions
65 volume X high solids
Waterborne coating
Large
Uncontrolled emissions
65 volume X high solids
Waterborne coating
coating
coating
coating
0
0
0
0
0
0
0
0
0
.064
.019
.012
.064
.019
.012
.064
.019
.012
2
49
14
8
255
74
46
,875
835
520
,815
,445
,970
,450
,080
,000
1.44
0.42
0.26
24.90
7.22
4.48
127.74
37.04
23.00
a Calculated using the parameters given in Table 9 and the following
equation. Values have been rounded off.
where E
A
T
V
D
S
Te
r 0.02S4 A T V D
1 " S Te
Mass of VOC emitted per hour (kg)
Surface area coated per hour (nr)
Dry film thickness of coating applied (mils)
VOC content of coating; Including dilution solvents added at the
plant (fraction by volume)
VOC density (assumed to be 0.88 kg/L)
Solids content of coating (fraction by volume)
Transfer efficiency (fraction)
The constant 0.0254 converts the volume of dry film applied per m2 to liters.
Nominal values of T, V, S, and Te are:
T
V
S
Te
1 mil
0.65
0.35
0.65
(for all cases)
uncontrolled), 0.35 (65 volume X solids), 0.117 (waterborne)
uncontrolled), 0.65 (65 volume X solids), 0.35 (waterborne)
for all cases)
24
-------
TABLE 11. SUMMARY OF REPORTED RELEASES OF ORGANIC SOLVENTS FROM THE MANUFACTURE OF METAL FURNITURE
Mean release, Ib (X reporting to each media)"
Section 313
chemical
Xylene (mixed
Isomers)
Toluene
Glycol ethers
Acetone
n- Butyl
alcohol
MEK
No. of facilities
reporting usage"
(% reporting
usage)
11 (65)
6 (35)
3 (18)
3 (18)
2 (12)
2 (12)
Fugitive
4,688 (91)
2,635 (100)
2,292 (100)
606 (100)
9,820 (100)
7,567 (100)
Stack
26,651 (91)
40,030 (100)
18,835 (100)
26,248 (100)
7,933 (50)
31,738 (100)
Off-site
transfer*
7,756 (45)
3,333 (50)
-
6,926 (33)
2,273 (50)
1,000 (50)
Total"
32,016 (100)
44,332 (100)
21,127 (100)
29,166 (100)
14,923 (100)
39,805 (100)
a A total of 17 facilities 1n SIC 2514 reported usage of at least one Section 313 chemical above the thres-
hold limits.
Mean release In pounds per year In 1990 for firms reporting release of this chemical and percentage of
firms reporting usage of this chemical and percentage of firms regulating usage of this chemical and
release to this media. Releases to other media were Insignificant.
c Off-site transfer for recycling or fuel blending was not reportable In 1990; transfer off site of purge
or cleanup solvent for these purposes will be reportable In 1991.
The Total Includes all releases and off-site transfers, not just categories summarized In this table.
-------
TABLE 12. SUMMARY OF REPORTED RELEASES OF CHLORINATED SOLVENTS FROM THE MANUFACTURE OF HETAL FURNITURE
Mean release, Ib (X reporting to each med1a)b
Section 313
chemical
1,1,1-TH-
chloroethane
Dlchloro-
methane
No. of facilities
reporting usage"
(% reporting
usage)
4 (24)
2 (12)
Fugitive
28,645 (75)
53,333 (100)
Stack
27,392 (75)
8,341 (100)
Off-site
transfer"
750 (25)
4,446 (100)
Total"
42,216 (100)
66,126 (100)
a A total of 17 facilities In SIC 2514 reported usage of at least one Section 313 chemical above the thres-
hold limits.
b Mean release In pounds per year In 1990 for firms reporting release of this chemical and percentage of
firms reporting usage of this chemical and release to this media. Releases to other media were
Insignificant.
c Off-site transfer for recycling was not reportable 1n 1990; transfer for recycling could be significant
for chlorinated solvents used In degreaslng operations.
d The total Includes all releases and off-site transfers, not just categories summarized In this table.
-------
Metals/metal compounds are processed at metal furniture manufacturers as
constituents of the metal or as constituents of the coating. Table 13 presents typical
transfer efficiencies for various methods of coating application. The best method for
estimating releases of metals/metal compounds is to multiply the total quantity of
metals/metal compound times (1 - transfer efficiency). This quantity will be released or
transferred off site for disposal. Depending on the paniculate controls present, a small
quantity may be released to air. If a water wash is used, a small release to water is also
likely. The remaining metals/metal compounds in the overspray are typically transferred
off site for disposal.
If grinding operations are performed on the metal, a small quantity of alloy metal
in the steel may be released to air or transferred offsite for disposal. Table 14 presents
a summary of Section 313 reported releases and off-site transfers of metals/metal
compounds at metal furniture manufacturers. Fewer metals/metal compounds and lower
air releases than expected were reported. It is not known if this is due to high transfer
efficiency through use of dip tanks or flow coats, the use of water walls to control air
releases, under-reporting of these compounds, or a combination of these reasons.
27
-------
TABLE 13. TRANSFER EFFICIENCIES FOR
METAL FURNITURE COATING*
Application method Transfer efficiency
Air-atomized spray 0.25
Airless spray 0.25
Manual electrostatic spray 0.60
Nonrelational automatic electrostatic 0.70
spray
Rotating head electrostatic spray 0.80
(manual and automatic)
Dip coat and flow coat 0.90
Electrodepositlon 0.95
28
-------
TABLE 14. SUMMARY OF REPORTED RELEASES OF METALS AND METAL COMPOUNDS
FROM THE MANUFACTURE OF METAL FURNITURE
Section 313
chemical
Nickel
Nickel compounds
Copper
No. of facilities
reporting usage8
(% reporting
usage)
2 (12)
3/19)
2 (12)
Mean
Stack
250 (50)
5 (100)
release, Ib (X reporting to each med1a)b
POTM0
250 (50)
250 (67)
Off-site
transfer
5,548 (100)
1,720 (100)
128 (100)
Total"
5,798 (100)
1,887 (100)
133 (100)
a A total of 17 facilities In SIC 2514 reported usage of at least one Section 313 chemical above the
threshold limits.
Mean release In pounds per year In 1990 for firms reporting release of this chemical and percentage of
firms reporting usage of this chemical and release to this media. Releases to other media were
Insignificant.
c POTW - Publicly Owned Treatment Works.
d The total Includes all releases and off-site transfers, not just categories summarized In this table.
-------
OTHER FURNITURE
This category includes all furniture not included in the categories previously
discussed. It includes the types of facilities previously discussed as well as furniture
made from polymers. Releases and off-site transfers for all four categories of Section
313 chemicals were reported in 1990. Each category will be discussed separately.
Organic solvents are otherwise used as constituents of stains, coatings, adhesives,
and polymers. Most solvents are released to air, but some are released to water if a
water curtain is used. Organic purge solvents used to clean spray equipment or for other
cleaning purposes may be transferred offsite for recycling, fuel burning, or disposal.
The best method for calculating releases is a mass balance based on total usage of
organic solvents with almost all of the emissions released to air or sent to an air control
device.
Table IS presents a summary of reported releases and off-site transfers of organic
solvents from the manufacture of other furniture.
Chlorinated solvents are otherwise used in other furniture manufacture as a
solvent in adhesives and as a coating stripper. Adhesives may be used to apply
laminates. Chlorinated solvents may also be used as a metal degreasing solvent at some
faculties. Dichloromethane may be used to strip coatings from defective products, from
the walls of the spray booth, or from other equipment.
Chlorinated solvents are primarily released to air. A significant amount of
dichloromethane used as a stripper as well as and other chlorinated solvents used as a
degreaser may be transferred offsite. No controls are typically used to reduce releases or
off-site transfers of chlorinated solvents at other furniture manufacturing-facilities. Off-
site transfers may be F002 RCRA wastes.
Table 16 presents a summary of Section 313 reported releases and off-site
transfers from otherwise uses of chlorinated solvents in other furniture manufacture.
Metals/metal compounds are processed at other furniture manufacturers as con-
stituents of the coatings. The best method for estimating releases of metals/metal
30
-------
TABLE 15. SUMMARY OF REPORTED RELEASES OF ORGANIC SOLVENTS FROM THE MANUFACTURE OF OTHER FURNITURE
Mean release, Ib (X reporting to each media)6
No. of facilities
reporting usage
Section 313 (X reporting
chemical* usage)
Xylene
(mixed Iso-
mers)
Toluene
Acetone
MEK
n- Butyl
alcohol
Hethanol
MIBK
Glycol
ethers
Ethyl benzene
92 (54)
83 (49)
40 (24)
29 (17)
23 (14)
18 (11)
18 (11)
7 (4)
7 (4)
Fugitive
8,387 (72)
4,892 (67)
8,224 (83)
5,398 (79)
2,782 (70)
5,940 (50)
2,629 (61)
10,648 (67)
4,772 (71)
Stack
39,886 (96)
27,481 (89)
14,788 (83)
20,484 (86)
14,839 (100)
16,047 (83)
12,691 (100)
47,018 (87)
21,246 (100)
POTW"
169 (7)
78 (5)
3,753 (5)
5,252 (10)
5 (9)
-
-
12,067 (40)
-
Off-site
transfer*
18,728 (34)
23,486 (45)
10,761 (38)
11,434 (41)
1,192 (43)
14,936 (22)
7,291 (44)
9,040 (27)
7,643 (43)
Total*
51,697 (99)
38,745 (99)
23,209 (100)
27,215 (100)
17,295 (100)
20,820 (94)
17,539 (100)
55,174 (100)
27,932 (100)
Isopropyl alcohol was reported by five facilities. Since IPA Is only reportable by manufacturers of IPA,
this 1s not reportable In the furniture manufacture Industry.
A total of 169 facilities In SICs 2515, 2519, 2522, 2531, 2542, 2591, and 2599 reported usage of at
one Section 313 chemical above the threshold limits.
c Mean release- In pounds per year In 1990 for firms reporting release of this chemical and percentage of
firms reporting usage of this chemical and release to this media. Releases to other media were
Insignificant.
d POTM • Publicly Owned Treatment Works.
e Off-site transfer for recycling or fuel blending was not reportable In 1990; transfer off site of purge
or cleanup solvent for these purposes will be reportable In 1991.
The total Includes all releases and off-site transfers, not just categories summarized In this table.
-------
TABLE 16. SUMMARY OF REPORTED RELEASES OF CHLOR1MATED SOLVENTS FROM THE MANUFACTURE OF OTHER FURNITURE
Mean release, Ib (X reporting to each med1a)b
Section 313
chemical
No. of facili-
ties reporting
usage"
(X reporting
usage)
Fugitive
Stack
Off-site
transfer*
TotaV
1,1,1-Trl-
chloroethane
45 (27)
16,775 (76) 37,067 (78)
6,639 (24) 43,139 (100)
Dlchloromethane
THchloroethvlene
7 (4)
3 (2)
1,755 (71)
38,154 (100)
2,633 (86)
12,499 (33)
32,582 (71)
37,211 (33)
53,560 (100)
54,724 (100)
c
d
A total of 169 facilities In SICs 2515, 2519, 2522, 2531, 2542, 2591, and 2599 reported usage of at
least one Section 313 chemical above the threshold limits.
Mean release 1n pounds per year In 1990 for firms reporting release of this chemical and percentage of
firms reporting usage of this chemical and release to this media. Releases to other media were
Insignificant.
Off-site transfer for recycling was not reportable In 1990.
The total Includes all releases and off-site transfers, not just categories summarized In this table.
-------
compounds is to multiply the total quantity of metal/metal compound times (1 - transfer
efficiency). This quantity will be released or transferred off site for disposal. Depending
on the paniculate controls present, a small quantity may be released to air. If a water
wash is used, a small release to water is also likely. The remaining metal/metal
compounds in the overspray are typically transferred off site for disposal.
Table 17 presents a summary of Section 313 reported releases and off-site
transfers of metals/metal compounds at other furniture manufacturers.
Other chemicals are both processed and otherwise used above the threshold limits
by a small number of facilities in other furniture manufacture. Sulfuric and hydrochloric
acids may be otherwise used in wastewater treatment or in metal cleaning. For these
uses, releases to POTW is typically between pH 6 to 9 and therefore not reportable
under Section 313. A facility cannot just assume a neutral pH, however, and should have
monitoring data to support this assumption. If pH is below 6, then releases to POTW
can be calculated based on the pH and volume of water if only one acid is present.
Small air releases of more volatile acids can also be expected from transfer loses.
Neutralization is the primary method used to control acids/
Phosphoric acid may be processed at some facilities in the 3- or S-step wash of
metal furniture or furniture parts. Phosphate treatment improves the adhesion
characteristics of the metal surface for subsequent coating application. Neutralization is
the primary method used to control phosphoric acid.
Methylenebis (phenylisocyanate) (MBI) is processed as a constituent of urethane
and other resins. Although most of the MBI is reacted to form the resin, some small
quantity of unreacted MBI may be released to air or transferred off site in waste resin.
Table 18 presents a summary of Section 313 reported releases and off-site
transfers of other chemicals at other furniture manufacturers.
33
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TABLE 17. SUMMARY OF REPORTED RELEASES OF METALS AND METAL COMPOUNDS
FROM THE MANUFACTURE OF OTHER FURNITURE
Mean release,
Section 313
chemical
Nickel
Nickel compounds
Manganese
Chromium
Chromium compounds
Zinc compounds
No. of facilities
reporting usage"
(X reporting
usage)
12 (7)
4 (2)
9 (5)
4 (2)
2 (1)
4 (2)
Fugitive
451 (42)
87 (75)
209 (67)
250 (50)
5 (50)
253 (100)
Stack
250 (25)
5 (50)
250 (33)
250 (25)
-
189 (100)
Ib (X report Inq to each media),.
POTH*
146 (58)
128 (50)
5 (11)
-
236 (50)
1,405 (50)
Off -site
transfer*
1,459 (83)
7,854 (100)
160 (22)
250 (50)
6,658 (100)
2,945 (50)
Totald
1,697 (92)
8,035 (100)
333 (78)
417 (75)
6,818 (100)
2,616 (100)
a A total of 169 facilities In SICs 2515, 2519, 2522, 2531, 2542, 2591, and 2599 reported usage of at least
one Section 313 chemical above the threshold limits.
Mean release 1n pounds per year 1n 1990 for firms reporting release of this chemical and percentage of
firms reporting usage of this chemical and release to this media. Releases to other media were
Insignificant.
c POTH • Publicly Owned Treatment Works.
d The total Includes all releases and off-site transfers, not just categories summarized In this table.
-------
TABLE 18. SUMMARY OF REPORTED RELEASES OF OTHER CHEH1CALS FROH THE MANUFACTURE OF OTHER FURNITURE
Mean release, 1b (% reporting to each media)1*
Section 313 chemical
Sulfurlc acid
Hydrochloric acid
Phosphoric acid
Nethylene bis (phenyl
Isocyanate)
No. of facilities
reporting usage"
(X reporting
usage)
21 (12)
14 (8)
9 (5)
9 (5)
Fugitive
154 (48)
459 (43)
714 (56)
478 (56)
Stack
406 (24)
578 (29
599 (44)
1,984 (44)
POTW*
e
e
13,921
-
Off-site
transfer
-
-
21,941 (22)
1,953 (33)
Total"
e
e
15,079 (78)
2,698 (67)
a A total of 169 facilities In SIC 2514 reported usage of at least one Section 313 chemical above the
tt threshold limits.
k Mean release In pounds per year In 1990 for firms reporting release of this chemical and percentage of
firms reporting usage of this chemical and reporting release to this media. Releases to other media were
Insignificant.
c POTW - Publicly Operated Treatment Works.
* The total Includes all releases and off-site transfers, not just categories summarized In this table.
e Most releases to POTW are zero; however, two facilities reported very large releases to POTW. Therefore,
mean releases are not representative of the Industry.
-------
REGULATIONS USEFUL FOR ESTIMATING RELEASES OF SECTION 313
CHEMICALS
Two regulations that may provide assistance in estimating emissions of Section
313 chemicals are effluent guidelines and standards governing water releases and VOC
standards governing air releases. Because the concentration of Section 313 chemicals
varies greatly between facilities, neither set of regulations is directly applicable. The
regulations may require monitoring or other testing, however, that may be used to
estimate releases of Section 313 chemicals.
Water Releases
Effluent limitations pertaining to Wood Furniture and Fixture Production are
presented in Code of Federal Regulations (CFR) §429 Subparts O and P. Subpart O
presents the standards applicable to for Wood Furniture Production Without Water
Wash Spray Booth(s) or Without Laundry Facilities. Best practicable control technology
for this subcategory currently available (BPT) and Best Available Technology (BAT)
economically available for this subcategory is no discharge of process wastewater into
navigable waterways.
Subpart P presents the standards for Wood Furniture and Fixture Production
With Water Wash Spray Booth(s) or With Laundry Facilities. Best practicable control
technology currently available (BPT) for this subcategory is settleable solids less than or
equal to 02 ml/1 with a pH between 6.0 and 9.0 at all times. Best Available Technology
(BAT) economically available calls for no discharge of process wastewater pollutants into
navigable waterways. The New Source Performance Standard (NSPS) governing new
sources calls for no discharge of process wastewater pollutants.
Metal furniture manufacturers which use electroplating, electroless plating, anodi-
zing, or coating (chromating, phosphating, and coloring) are subject to the effluent
limitations pertaining to the Metal Finishing Subcategory (433.10 Subpart A). These
limitations are summarized in Table 19.
Discharges into a POTW must comply with 40 CFR 403 General Pretreatment
Regulations for Existing and New Sources of Pollution. The general Pretreatment
36
-------
TABLE 19. SUMMARY OF EFFLUENT LIMITATION FOR METAL FINISHING
(Monthly average In mg/L)a
Pollutant
BPT1
BAT1
PSES1
NSPS1
PSNS1
Cadmium, total
Chromium, total
Copper, total
Lead, total
Nickel, total
Silver, total
Zinc, total
Cyanide9
Cyanide, total
TTOh
Oil and grease
TSS1
PH
0.26
1.71
2.07
0.43
2.38
0.24
1.48
0.32
0.65
2.13
26
31
6-9
0.26
1.71
2.07
0.43
2.38
0.24
1.48
0.32
0.65
2.13
0.26
1.71
2.07
0.43
2.38
0.24
1.48
0.32
0.65
2.13
0.26
1.71
2.07
0.43
2.38
0.24
1.48
0.32
0.65
2.13
26
31
6-9
0.26
1.71
2.07
0.43
2.38
0.24
1.48
0.32
0.65
2.13
40 CFR 433 Metal Finishing Point Source Subcategory. Maximums for any one
day are also presented.
BPT - Best practicable control technology currently available.
BAT » Best available control technology economically achievable.
PSES - Pretreatment standards for existing sources (except job shops and
Independent printed circuit board manufacturers.
NSPS « New source performance standards.
PSNS • Pretreatment standards for new sources.
Cyanide amenable to chlorination.
Total toxic organic* listed in 40 CFR 433.11(e).
1-day maximum.
TSS - Total suspended solids.
Value presented is a
37
-------
Regulations establish discharge standards and categorical pretreatment standards to con-
trol pollutant discharges into the POTW. Discharge standards apply to all industrial and
commercial discharges connected to POTWs. Categorical pretreatment standards apply
to industrial and commercial discharges in 25 specific industrial categories. The furni-
ture industry is not among these 25 industries.
Discharge standards applicable to the furniture industry prohibits discharge of
pollutants that:
Create a fire or explosion hazard in sewers or treatment works;
• Are corrosive (with a pH lower than 5.0);
• Obstruct flow in the sewer system or interfere with operation;
• Upset the treatment process or cause a violations of the POTW's permit;
or
• Increase the temperature of wastewater entering the treatment plant above
104°F (40°C).
The furniture industry is subject to the above discharge standards as well as any
permit requirements of the local POTW.
Air Releases
Air releases of VOCs in metal furniture coating are regulated in 19 states. The
regulations are based on pounds of VOC content as applied (less water) (i.e., 3.0 Ib
VOC/gallon), specified transfer efficiencies, or other means used to reduce VOC
releases. Permit conditions applicable to the specific plant should be consulted.
Two states (Indiana and New Jersey) regulate VOC releases from wood furniture
surface coating operations. The standards are dependent on the type of operation and
are stated in Ib VOC/gallon.
New Source Performance Standards (NSPS) governing Surface Coating of Metal
Furniture are presented in Subpart EE (§ 60310 to § 60315). The NSPS exempt
sources that use less than 3,842 liters of coating per year. Sources subject to NSPS must
limit VOC emissions to 0.90 kg VOC per liter of coating solids applied. Procedures are
38
-------
provided to calculate VOC releases by month. Recordkeeping of coatings used is
required as are estimates of the proportion of VOC that enters a control device.
Although these data do not present information on Section 313 chemicals, the usage
reports, collection efficiencies, and control efficiencies can be used to calculate releases
of Section 313 solvents that are used in the coatings.
Off-Site Transfers
RCRA wastes reported by generators can be a good source of information on off-
site transfers from furniture manufacturers. A waste solvent may be determined hazard-
ous by two methods.3 Either the waste is "listed" or the solvent exhibits a hazardous
"characteristic."
A waste is "listed" in the regulations because it has already been determined to
exhibit a hazardous characteristic or it has been determined to be toxic to humans.
There are over 700 chemicals listed in the regulations. Most waste solvents used in the
furniture industry are solvent blends containing methyl ethyl ketone, acetone, toluene,
etc. which are usually toxic or ignitible and have the EPA Waste Numbers F001 through
F005.
If a waste exhibits one or more of the following characteristics, it is considered a
hazardous waste.
• Ignitibility
Corrosivity
• Reactivity, and
EP Toxic.
Results from standard tests specified by the EPA will determine if the waste is deemed
hazardous by the characteristic test The furniture industry works with solvent blends
that frequently will exhibit the ignitibility characteristic. If the waste solvent is not listed
in the F001-F005 wastes and is "ignitible" it has the EPA Hazardous Waste Number
D001.
39
-------
NONREPORTING FACILITIES
Nonreporting facilities may be identified by comparing lists of facilities in the
following Standard Industrial Classifications (SICs) having more than 10 employees with
those facilities that have reported under Section 313.
Wood furniture with coatings - SICs 2511 and 2517
Wood furniture, lower coating use - SICs 2512 and 2541
Metal furniture - SIC 2514
Other furniture - SICs 2515, 2519. 2522, 2531, 2542, 2591, and 2599
Most larger furniture manufacturers that coat furniture probably are using at least
one Section 313 chemical in excess of threshold values. A significant number of medium
to large faculties that apply coatings most likely otherwise use more than 10,000 pounds
of at least one organic solvent
Sources of information on furniture manufacture facilities presented by SIC and
employment size class include County Business Patterns (for number of facilities),
published by the U.S. Department of Commerce.7 Another source is Dunn and
Bradstreet (D&B), which provides lists of companies by SIC and employment size
category.8
Table 20 presents the number of facilities with over 10 employees as reported in
County Business Patterns (1989) and D&B compared with the number of facilities in the
TRI database in 1990. Because most small furniture manufacturers would not exceed
the threshold for any Section 313 chemical, facilities with more than 50 (or 100)
employees are the most likely to be required to report.
Significant nonrepoiting may be occurring in the furniture manufacturing industry,
based on the number of facilities reporting in the TRI database and the number of
faculties listed in County Business Patterns with over 50 employees (Table 20). Some of
the difference may be accounted for by facilities manufacturing furniture that is not
coated or which use high solids coatings; however, larger facilities that do perform
coating should be checked to determine if they exceed the threshold for any of the
coating solvents.
40
-------
TABLE 20. NUMBER OF FACILITIES
WITH MORE THAN 10 EMPLOYEES
Furniture type
Wood, costings
Wood, tower coatings
Metal
Other
SIC*
2511, 2S17
2512,2541
2514
2515 2519,2522,2531,
2542,2591,2599
TRI1990
257
66
17
169
County Business
Patterns8
1,199 (491)
1,630(562)
248(117)
2^69(883)
D&B1992
1£24
2,433
376
3,681
* The numbers in parentheses are the number of facilities with over SO employees.
A review of the 1990 TRI data seems to indicate some errors in reporting whether
a chemical was manufactured, processed, or otherwise used. All organic solvents,
chlorinated solvents, and some other chemicals are otherwise used at furniture manu-
facturers and are therefore subject to the 10,000-pound threshold. All metals/
metal compounds and some other chemicals are processed at furniture manufacturers.
No chemicals are manufactured or manufactured as a by-product. Many firms reported
that organic solvents were processed. This misunderstanding of the definitions of
processed and otherwise used may cause nonreporting if the wrong threshold is used for
the threshold determination.
Another error made by a number of furniture manufacturers was to report the use
of isopropyl alcohol (IPA). IP A is reportable only for facilities who manufacture IPA by
the strong acid process. No IPA should be reported by furniture manufacturers.
41
-------
LIST OF QUESTIONS
The following questions may be helpful in determining whether furniture manu-
facturers made errors in Section 313 reporting.
Organic solvents
• If a solvent is reported as processed on Form R, ask what threshold was
used for all organic solvents. The 10,000-pound threshold for otherwise
used chemicals should be used.
How were releases of organic solvents other than to air estimated?
Was a mass balance for organic solvents that accounted for total usage
calculated?
If a control such as incineration was used on the drying oven, how were
releases in the booth versus releases in the oven estimated?
Chlorinated solvents
How were chlorinated solvents otherwise used (adhesives, cleaning,
stripping)?
• Was the percentage of chlorinated solvent in any waste solvent accounted
for?
Was a mass balance accounting for all chlorinated solvent usage used to
estimate releases and off-site transfers.
Metals/metal compounds
• Were threshold determinations made for all metals/metal compounds
processed at the facility?
• Were threshold determinations made using the total quantity of Section
313 metal/metal compound processed and not the quantity of metal/metal
compound released or transferred off site?
• Were threshold determinations for metal compounds made using the
weight of the compound and not just the metal portion of the compound?
42
-------
Was TCLP used as a measure of metal concentration in any of the calcula-
tions? TCLP measures teachable metal (not metal content) and should not
be used in calculations.
Other Chemicals
How was the release of chemicals that are present in resins such as
formaldehyde or styrene estimated?
How were any acids estimated that were reported otherwise used at the
facility? Is there monitoring data to support any neutralization
assumptions?
43
-------
BIBLIOGRAPHY
1. U.S. Environmental Protection Agency. Summary of Technical Information for
Selected Volatile Organic Compound Source Categories. EPA 450/3-81-007.
1981 (Original source technical paper, Society of Manufacturing Engineers, MS-
75-251).
2. Kirk-Othmer Encyclopedia of Chemical Technology. Volume 6, Coatings
Industrial, pp. 443,444.
3. North Carolina State University. Managing and Recycling Solvents in the Furni-
ture Industry. Raleigh, NC. May 1986.
4. U.S. Environmental Protection Agency. Compilation of Air Pollutant Emission
Factors. AP-42. Volume 1. Stationary and Point Source. Section 42.2.2 Other
Metal Coating. September 1985 plus supplements.
5. U.S. Environmental Protection Agency. Surface Coating of Metal Furniture -
Background Information for Proposed Standards. EPA-450/3-80-007a.
September 1980.
6. U.S. Environmental Protection Agency. Control of Volatile Organic Emissions
from Existing Stationary Sources, Volume HI Surface Coating of Metal Furniture.
EPA-450/2-77-032. December 1977.
7. U.S. Department of Commerce, Bureau of Census, County Business Patterns.
1989. CBP-89-1. Washington, D.C. 1991.
8. Dunn & Bradstreet. Dunn's Electronic Business Directory in DIALOG data base
File 515. 1992.
9. U.S. Environmental Protection Agency. Pollution Prevention Options In Wood
Furniture Manufacture, A Bibliographic Report. EPA/560/8-92/001c. February
1992.
10. U.S. Environmental Protection Agency. Summary of State VOC Regulations.
EPA-450/2-85-003. April 1985.
11. U.S. Environmental Protection Agency. Air Pollution Engineering Manual,
Second Edition AP-40. May 1973.
44
-------
12. U.S. Environmental Protection Agency. Generic Engineering Assessment, Spray
Coating, Occupational Exposure and Environmental Release. Chemical
Engineering Branch, October 1987 (unpublished).
13. U.S. Environmental Protection Agency. Title III Section 313 Release Reporting
Guidance, Estimating Chemical Releases From Electrodeposition of Organic
Coatings. EPA/560/4-88-004C. January 1988.
14. U.S. Environmental Protection Agency. Title III Section 313 Release Reporting
Guidance, Estimating Chemical Releases From Spray Application of Organic
Coatings. EPA/560/4-88/004d January 1988.
45
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APPENDIX A
SELECTED INFORMATION OF
THE FURNITURE INDUSTRY
A-l
-------
TABLE A-l. TYPICAL FURNITURE MANUFACTURING OPERATIONS
USING MATERIALS WHICH NAY GENERATE HAZARDOUS HASTES
Typical
process/pperat1on
Typical materials used
Typical nterial
Ingredients
General types of wastes
generated
Wood cleaning and wax
val
RefInlshlng/str1pplng
Staining
Painting
Finishing
Cleaning brushes, spray gun
and spray equipment, and
overspray from spray booths
Gluing, cleaning adhesive
application equipment
petroleu
•pints
distillates, white
paint removers, varnish
removers, enamel removers.
shellac removers, paint
solvents, turpentine
stains
enamels, lacquers, epoxy.
alkyds. acrylics
varnish, shellac.
polyurethane. lacquers with
residues
paint thinners. enamel
reducers, varnish removers.
shellac removers, white
spirits
adhesives
petroleum distillates.
mineral spirits
acetone, toluene, petroleum
distillates, nethanol.
•ethylene chloride.
alcohols, ketones.
oxygenated solvents
mineral spirits, alcohol
pigments
toluene, pigments, titanium
dioxide, epoxyester resins.
aromatic hydrocarbons.
glycol ether, nalogenated
hydrocarbons, vinylacetate
acrylic
denatured alcohols, resins.
shellac, petroleum
distillates, toluene.
di1socyanate
acetone, toluene, petroleum
distillates, nethanol.
•ethylene chloride.
isopropanol. mineral
spirits, alcohols
•ethyl Isobutyl ketone.
methyl ethyl ketone.
xylene. toluene. 1.1.1-
trichloroethane
ignitable wastes, spent
solvents, volatile emissions
ignitable wastes, ignitable
paint wastes, solvent still
bottoms, volatile emissions
ignitable wastes, spent
solvents, solvent still
bottoms, volatile emissions
ignitable paint wastes.
ignitable wastes, solvent
still bottoms, paint waste
containing heavy metals.
volatile emissions
ignitable wastes, spent
solvents, solvent still
bottoms, volatile emissions
ignitable paint wastes.
ignitable wastes, spent
solvents, solvent still
bottoms, volatile emissions
volatile emissions
Source: Tennessee Hazardous Waste Minimization Program as cited in Reference 9.
A-2
-------
TABLE A-2. PHYSICAL CHARACTERISTICS OF
SOLVENTS USED IN THE FURNITURE INDUSTRY5
PRODUCT
Alcohols
Methanol (L)
Ethanol. Prop. Anhy. (C)
Ethanol. Spec. Ind. Anhydrous (C)
Isopropanol. Anhydrous (C)
Isobutanol (L)
n-Butanol (L)
Ketones
Acetone (L)
Methyl Ethyl Ketone (L)
Methyl Isobutyl Ketone (L)
Methyl I seamy 1 Ketone (C)
01 acetone Alcohol. F. (C)
Methyl Amyl Ketone (C)
Ester Solvents
Ethyl Acetate 99X (L)
Isopropyl Acetate 99X (C)
n-Propyl Acetate (C)
Isobutyl Acetate (C)
n-Butyl Acetate 99X (C)
Isobutyl Isobutyrate (C)
Glycol Ether EE Acetate (C)
Glycol Ether EB Acetate (HH)
PRODUCT
filvcols
Prapylete Slycol (HH)
Ethylene Glycol (NH)
DtethyUne GVycol .(HH)
Glvcol Ethers
Glycol Ether EM (C)
«lycol Ether EE (C)
Glycol Ether Eb (C)
LB./6AL.
20'C
6.60
6.75
6.59
6.55
6. 66
6.75
6.59
6.71
6.67
6.78
7.82
6.81
7.51
7.27
7.40
7.24
7.34
7.13
8.10
7.83
LB./GAL.
20'C
8.64
9.28
9.31
6.04
7.74
7.51
SP. 6R.
20V20'C
0.792
0.809
0.790
0.786
0.803
0.811
0.792
0.806
0.802
0.812
0.937
0.818
0.900
0.871
0.887
0.870
0.879
0.855
0.973
0.938
SP. GR.
20V20-C
1.038
1.115
1.119
0.966
0.930
0.903
BOILING
•c
64-65
74-80
75-81
82-83
107-109
116-118
55.5-56.5
78-80
114-117
141-148
145-172
147-154
75.5-78
86-90 .
99-103
112-119
118-128
144-151
150-160
186-194
BOILING
•c
185-190
193-202
242-250
123-125
134-136
169-173
RANGE
•F
147-149
165-176
167-178
180-182
225-228
241-245
131-133
172-176
237-243
286-298
293-342
297-309
168-172
187-194
210-217
234-246
244-262
291-304
302-320
367-381
RANGE
•F
367-374
379-396
468-482
253-257
273-277
336-343
FL. PTC
•F TCC
54
51
50
53
86
96
-4
24
61
96
120
102
26
47
55
63
81
101
130
160
FL. PTb
•F COC
225
240
290
97
110
140
EVAPd
RATE
5.2
6.8
6.8
7.7
16.3
20.0
1.9
2.7
5.6
17.0
60.0
22.0
2.7
3.0
4.8.
5.8
8.2
15.0
32.0
137.0
A-3
-------
TABLE A-2 (continued)
L6./6AL. SP
PRODUCT 20'C 20'
Aliphatic Solvents
Hexane (C) 5.61 0
Heptane (C) S.76 0
Nlneral Spirits (C) 6.55 0
LB./6AL.
PRODUCT 20'C
Aroma t 1 c Sol vents
Toluene (L) 7.26
Xylene (L) 7.23
. LB./GAL
PRODUCT 20'C
A_l
amines
Nonoethanolanlne (NH) 8.48
Trletnanolaailne (NH) 9.37
PRODUCT
Chlorinated Solvents
Hethylene Chloride (L)
1.1.1-Trichloroethane (L)
Trichloroethylene (L)
Perch] oroethylene (L)
. 6R.
/20'C
.675
.704
.787
SP. 6R
20' /20'
0.870
0.866
BOILING RANGE
'C 'F
65-70 150-158
94-98 202-209
157-196 315-385
BOILING RANGE
C 'C 'F
FL. PT. . ANILINE
•F TCC KB PT 'F
<0 28 151
25 32 146
105 31 155
FL. PT.
•F TCC KB
110-111 230-233 45 105
138-142 280-288 80 98
BOILING
SP. 6R.
20'/20'C 'C
1
1
LB.GAL
25V25'
11.0
10.8
12.1
13.5
.016 166-174
.126 App 360
SP. 6R.
C 25V25-C
1.320
1.300
1.449
1.618
RANGE
FL. PT.
•F 'F TCC
331-345 200
App 680 375
BOILING RANGE
'C 'F
39.4-40.4 103-105
72-86 162-191
86-86 167-190
120-122 248-252
X f
ARO
0.1
0 1
HAP
50
52
EVAPd
RATE
1.9
2 9
70.0
EVAPd
RATE
4.5
9.5
FREEZING
POINT 'C
10
21
C¥APd
RATE
1.8
2.6
3.9
6 0
(C) - Characteristic
(LJ - Listed
(NH) - Nonhazardous
" Selected solvents from a chart provided by Industrial Chemicals t Solvents Division. Ashland Chemical Company. Box 2219.
Colwfeus. ON 43216.
b Cleveland Open-Cup Test (flashpoint).
C TA6 Closed Cup Test (flashpoint).
d Ethyl Ether • 1.
" Kauri-Butanol Value (relative solvent power).
f Aromatlclty
A-4
-------
TRI FACILITY PROFILE,
PAINT FORMULATION
by
IT Corporation
11499 Chester Road
Cincinnati, Ohio 45246
Contract No. 68-DO-0020
Work Assignment No. 2-27/2-65/3-18
JTN 830015-5-1
Prepared tor
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF TOXIC SUBSTANCES
401 M Street, SW
Washington, D.C. 20460
August 1992
-------
CONTENTS
Page
Figures iii
Tables iii
Section 313 Chemicals Used in Paint Formulation 11
Solvents 12
Metals and Metal Compounds 15
Resin Constituents 18
Other Chemicals 20
Use of Regulations to Estimate Releases of Section 313 Chemicals 23
Nonreportihg Facilities 25
List of Questions 27
Bibliography .29
-------
FIGURES
Number
1
2
3
Simplified Process Row Diagram for Solvent-Based Paint
Formulation
Simplified Process Flow Diagram for Water-Based Paint
Formulation
Simplified Process Flow Diagram for Varnish Manufacture
Pape
5
8
10
TABLES
Number
1
2
3
5
6
7
Paint Products and Use Distributions in 1986
Raw Materials Used by the Paint Formation Industry in 1982
Summary of Reported Releases of Solvents (Chlorinated
and Organic) From Paint Formulation
Summary of Reported Releases of Metals and Metal Compounds
From Paint Formulation
Summary of Reported Releases of Resin Constituents From
Paint Formulation
Summary of Reported Releases of Other Chemicals From
Paint Formulation
Number of Establishments in SIC 2851
3
4
14
16
19
21
25
iii
-------
TRI FACILITY PROFILE,
PAINT FORMULATION
The purpose of this profile is to assist U.S. Environmental Protection Agency
(EPA) Regional Office personnel with Section 313 inspections. The profile describes
key toxic chemicals processed or otherwise used in paint formulation, describes how
these chemicals are used, and identifies key release sources. All Section 313 chem-
icals reported to the Toxic Release Inventory (TRI) by more than 5 percent of the paint
formulators are presented in this profile.
For purposes of this profile, the paint formulation industry is defined as:
SIC 2851 - Paints, Varnishes, Lacquers, Enamels, and Allied Products
This Standard Industrial Classification (SIC) includes establishments primarily
engaged in the manufacture of paints (in paste and ready mixed form), vamishesr
lacquers, enamels, shelters, putties, wood fillers and sealers, paint and varnish re-
movers, paint brush cleaners, and allied paint products.1 Establishments engaged in
the manufacture of pigments, resins, printing inks, adhesives and sealants, or artist
materials are not included.1
The industry is comprised of roughly 1,375 establishments nationwide.8
Approximately 44 percent of all paint manufacturing plant sites are located in five
states (California, New Jersey, New York, Illinois, and Ohio).2 Most of the plants are
located near major population centers.2
Most small plants produce paint in 10- to 500-gallon batches.2 Plants with more
•than 20 employees produce paint in 200- to 3000-gallon batches.2 For an average
paint plant located in the United States, 60 percent of its total annual production would
be solvent-based paint, 35 percent would be water-based paint, and 5 percent would
be allied products.2 Although more than 70 percent of architectural coatings are
water-based, solvent-based paint is still predominantly used for product and special-
1
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purpose coatings.8 Table 1 presents the volumes and distribution of products formu-
lated by the paint industry in 1986.
The major raw materials used to formulate paint include resins, solvents, pig-
ments, extenders, and drying oils.2 Table 2 presents annual consumption of these
materials in the paint formulation industry in 1982.
Paint is a mixture of pigments or combination of pigments and a liquid vehicle
that is composed of binders and thinner. The formulation of paint is a highly
developed combination of science, art, and technology.7 Since paints are required to.
meet a wide diversity of end uses, the formulations vary widely. The type and relative
quantities of vehicles, pigments, extenders, additives, and volatile thinners determine
the final film properties.7
In paint manufacture, pigment is mixed with a portion of the vehicle to form a
paste that is then milled to disperse the pigment into the vehicle. After the pigment is
dispersed into finely divided particles, the balance of the vehicle and additives are
added to produce the paint product. Tinting may be required to produce the proper
color, and the paint may be filtered to remove foreign material or large particles. Paint
formulation facilities usually take advantage of gravity flow.7
In paint formulation, only physical processes such as weighing, mixing,
grinding, dispersion, thinning, filtering, and packaging take place. No chemical
reactions are involved. The processes take place in large mixing tanks at room
temperature.8 At a typical plant, both solvent-based and water-based paints are
formulated.2
Figure 1 presents a simplified process flow diagram of solvent-based paint for-
mulation. The production of solvent-based paint begins by weighing and then mixing
resins, dry pigment, and pigment extenders in a high-speed mixer. Solvents and plas-
ticizers are also added during this operation. Following the mixing operation, the
batch frequently is transferred to a mill for additional grinding and mixing.2
The type of mill is dependent on the types of pigments being handled; no one
style is universal.2 Mills break up the agglomerates by 'smashing,' 'smearing,' or a
combination of the two actions.7 The types of mills include:
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TABLE 1. PAINT PRODUCTS AND USE DISTRIBUTIONS IN 19862'5
Product
Volume, million
gallons
Use and distribution (X)
Architectural coatings
525
Product coatings
371
Special-purpose coatings
250
Interior solvent-based (11)
Interior water-based (43)
Exterior solvent-based (16)
Exterior water-based (23)
Lacquers (2)
Other and not specified (5)
Metal containers (19)
Automotive (16)
Machinery (6)
Sheet, strip & coll (6)
Metal furniture (5)
Other (48)
High-performance maintenance
(31)
Automotive and machinery
refinishing (29)
Traffic paint (14)
Other (26)
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TABLE 2. RAW MATERIALS USED BY
FORMATION INDUSTRY IN
PAINT
Material
Usage,
million Ib/yr
Type and distribution (%)
Resins
Solvents
1844
3774
Pigments
Extenders
Miscellaneous
1062
1162
220
Alkyd (33)
Acrylic (19)
Vinyl (19)
Other (29)
Aromatic (30)
Aliphatic (27)
Ketones (17)
Alcohols (12)
Other (14)
Titanium dioxide (65)
Inorganic3 (33)
Organic (2)
Calcium carbonate (31)
Talc (25)
Clay (23)
Other (21)
Drying oils (41)
Plastlclzers (18)
Other (41)
a
Approximately 60 percent of Inorganic pigments used consisted of
Iron oxide, zinc oxide, zinc dust, and aluminum paste; 27 percent
consisted of lead and chrome compounds; and 13 percent consisted of
other compounds.
-------
Resins
Pigments
Extenders
Mixing
Grinding/
Dispersion
Tints — 1
Solvents —
Thinning
Filtering
Packaging
.^ Final
Product
Solvents-
Plasticizers-
Rgure 1. Simplified process flow diagram for solvent-based paint formulation.
CGSFCRAnOK
I DRAWING I
°Y r
CHECKED BY
APPROVED BY
DRAWING NO
S-W0015-M-W9? 1
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Stone and colloid mills
Roller mills
Ball and pebble mills
• Sand mills
High-speed dispensers
Horizontal mills
Kinetic dispersion mills
Stone and colloid mills contain a rotor (rotates) and stator (stationary) that can
be made of stone or metal. A premix is fed by gravity into the mill, and residence time
is short. Vehicle solids can be as tow as 20 percent or as high as 75 percent.7 As the
paste reaches the rapidly revolving rotor, it is impelled to the outer edge by centrifugal
force through a narrow adjustable gap. The material is subjected to high stress
(smearing) as it passes between the rotor and the stator. Stone and colloid mills are
usually used for architectural paints, but are not good for pigments that are difficult to
disperse.
Roller mills in the paint industry typically consist of three rollers, but one, two,
four, and five roller mills are also used.7 The mills are of the smearer type with each
roll rotating in the opposite direction at increasing revolutions per minute. The paste
must be tacky so it adheres to the surface of the rotating rolls. The vehicle portion
must be high in resin solids.7 Clearances between the rolls are adjustable. Roller mills
can be used for difficult-to-disperse pigments.7
Ball and pebble mills are hardened steel shells with closed ends that use steel
balls as the grinding medium. Pebble mills have steel shells, but are lined with stone
and use natural or porcelain balls as the grinding media.7 The cascading action of the
grinding media causes the pigment to be both impacted and sheared by the tumbling
balls.
Sand mills consist of a water-jacketed cylindrical shell containing discs mounted
on a centrally located shaft. A screen allows the paste to flow through the mill while
retaining the media in the mill. The mill is typically operated in the temperature range
of 120 to 150* F, but may be as high as 300* F. In addition to sand, many media such
as glass beads, ceramics, AI209, and steel may be used; therefore, the sand mill may
6
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be considered a small media mill.7 Sand mills disperse by shearing and some
impingement.7
High-speed dispensers consist of a disc that rotates at high speed in the center
of a vertical tank. The disc (impeller), the key feature of a high-speed disperses
typically consists of a saw tooth disc. The teeth are formed by bending the edges of
the disc alternately up and down.7 With a high-speed disperser, a batch can be for-
mulated and milled in the same tank.7
Horizontal mills have a horizontal grinding chamber. Suitable types of media
include glass, ceramic, or steel. Unlike the sand mill, the horizontal mill does not work
against gravity. The premix is subjected to both impact and shear by the grinding
media.7 A cooling system allows use of heat-sensitive products.
Kinetic dispersion mills use a high-speed impeller. The paste is of low viscosity,
and the mill gives little or no shearing action and depends primarily on impact for
dispersion. No premix is needed, and the time required varies from 15 to 45 minutes.7
After milling, the paint base or concentrate is transferred to an agitated tank
where tints and thinner (usually volatile naphtha or a blend of solvents) and the -
balance of the resin are added. Upon reaching the proper consistency, the paint is
filtered to remove any nondispersed pigment and then transferred to a loading hopper.
From the hopper, the paint is poured into cans, drums, or totes. The product is then
labeled/packed and moved to storage.
Figure 2 presents a simplified process flow diagram of water-based paint
formulation. The water-based paint process is very similar to the solvent-based pro-
cess previously described. The major difference is the substitution of water for solvent
and the sequencing of material additions.2 Water-based paint is prepared by first mix-
ing water, ammonia, and a dispersant in a mixer. Dry pigment and pigment extender
•are then added. After mixing, the material is ground in a mill and then transferred to
an agitated mix tank.2
Next, plasticizers and resin are added to the agitated mix tank. The polymer in
a latex should be of high molecular weight. The viscosity of a high molecular weight
-------
Ammonia—
Water—
Dispersant—
Weighing
Mixing
Extenders-
Pigment-
Grinding/
Dispersion
P
-».
PMM
Resins —
asticizer —
1
Mixing/
Thinning
Eoruatiua —
Antifoam —
PVA Emulsion -
Water •—'
Filtering
Packaging
_^ Final
Product
Figure 2. Simplified process flow diagram for water-based paint formulation.
(ON
DRAWING
BY
CHECKED BY
t/nfit
APPROVED BY
DRAWING NO
s-B3
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polymer is such, however, that coalescence at ambient temperatures is difficult.
Therefore, temporary plasticizers are used to facilitate coalescence. They are usually
water-miscible solvents (e.g., ethers or mixed ether esters of ethylene glycol) that are
adsorbed by the latex particles, which soften the polymer.8
The next step is the addition of preservatives and an antifoaming agent. Then,
a polyvinyl acetate emulsion is added followed by water to thin the paint. At many
facilities, the grinding and mixing operations may all be carried out in a single high-
speed mixer. Finally, the paint is filtered and sent for packaging.
Unlike paint formulation, varnish manufacture involves chemical reactions that
are initiated by heating.8 Figure 3 presents a simplified process flow diagram of
varnish manufacture. Varnish is cooked in both portable kettles and large reactors.
Kettles are used primarily by smaller manufacturers. The manufacture of varnish con-
sists of heating oil and resins together to make them compatible, dissolving the mix-
ture in solvent, and forming high molecular weight polymers.10 Varnishes are cooked
for periods of 4 to 16 hours at temperatures of 200' to 650 *F.8 A large variety of
synthetic resins are produced for use in surface coatings, and operating variables dif-
fer with each resin. Viscosity adjustment (thinning), or the addition of dryers or
unreacted monomers, usually does not take place in the reaction kettle.11 Instead, the
contents are pumped to other vessels designed for these purposes. These thinning
vessels are typically closed and equipped with agitators.11 After the thinning, the
varnish is packaged for shipment.
9
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Oils—i
Natural Resins -
Synthetic Resins—
Solvents-
Kettles
Solvents-
Dryers-
Monomers-
Reactors
Thinning
Packaging
Final
Product
Figure 3. Simplified process flow diagram for varnish manufacture.
DRAWING
BY
CHECKED BY
APPROVED BY
DRAWING NO
S-e*' < OTJ-3
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SECTION 313 CHEMICALS USED IN PAINT FORMULATION
Section 313 chemicals commonly used in paint formulation can be classified
into four distinct categories: solvents (chlorinated and organic), metals and metal
compounds, resin constituents, and other chemicals. Each category is discussed
separately in this report. Each contains a description of how the Section 313
chemicals are used, a discussion of typical releases and off-site transfers, a table
summarizing releases and off-site transfers that were reported to the Toxic Release
Inventory (TRI) in 1990, a description of industry-specific and chemical-specific regula-
tions, typical control practices, and common reporting errors. Methods for identifying
nonreporting facilities and a list of questions are also presented.
11
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SOLVENTS
Solvents are both processed and otherwise used by paint formulators. Solvents
are primarily processed as a constituent of the paint or varnish. Solvents are also
otherwise used as cleanup solvents throughout the formulation process. Solvents may
be organic or chlorinated and are received by drum, tote, tanker truck or rail car.
Even under well-controlled conditions, about 1 to 2 percent of solvents pro-
cessed in paint formulation are lost to the air (per AP-42 estimates).9 The primary
factors affecting air emissions from paint manufacture are the vapor pressure of the
solvent, care in handling, enclosure of formulation equipment, mixing temperature, and
air movement near open tanks or packaging equipment. Air releases may be either
fugitive or stack, depending if local exhaust ventilation is used to reduce potential
worker exposure to the solvents. Fugitive air releases can also occur frpm spills that
are allowed to evaporate. Releases to water or POTW can occur when equipment
used in the preparation of water-based paints containing solvents (e.g., glycol ethers)
is washed with water and then sewered. Off-site transfers occur from paint residues in
cleaning solvent and the disposal of off-spec paint. Land release is not common, but
j*
can occur through spills. Dirty filters or paint sludge generated during cleaning opera-
tions may also contain small quantities of solvents.
Some of the solvent otherwise used to clean equipment is lost to air during
cleaning while the remainder is typically transferred off site for recycling, fuel use, or
treatment prior to disposal. Releases may be best determined through mass balance
calculations; all releases are either released to air or transferred off site. The quantity
transferred off site for recycling or fuel burning was not reportable under Section 313
until 1991 (estimates due July 1,1992).
When solvent-based cleaning solvents are transferred off site, they may be
classified as a RCRA waste based upon one of the following waste criteria:
F002 Contain a total of 10 percent or more (by volume) prior to Use of one or
more of the following solvents: tetrachloroethylene, methylene chloride,
trichloroethylene, 1,1,1-trichloroethane, chlorobenzene, 1,1,2-triehloro-
12
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1,2,2-trffluoroethane, orthodichlorobenzene, trichlorofluoromethane, and
1J ,2-trichloroethane.
F003 Contain a total of 10 percent or more (by volume) prior to use of one or
more of the following solvents: xylene, acetone, ethyl acetate, ethyl-
benzene, ethyl ether, MIBK, n-butyl alcohol, cyclohexanone, and
methanol.
F005 Contain a total of 10 percent or more (by volume) prior to use of one or
more of the following solvents: toluene, MEK, carbon disulfide, iso-
butanol, pyridine, benzene, 2-ethoxyethanol, and 2-nitropropane.
Off-site transfers of RCRA-classified waste can best be determined from RCRA
manifests and analysis by the company receiving the waste.
Table 3 presents a summary of Section 313 reported releases and off-site trans-
fers of solvents at paint formulators, based on Section 313 reporting for 1990. As
expected, the most widely reported solvents include xylene, toluene, and MEK, which
are both processed as paint solvents and otherwise used in cleaning solvents.
Air releases of solvents can be reduced by enclosing the mixing, packaging,
and cleaning operations and through management practices that minimize spills or the
quantity of cleanup solvent necessary.
Equipment cleaning waste accounts for over 80 percent of the paint industry's
waste.5 Equipment cleaning wastes can be reduced through source reduction by
reducing the frequency of required cleaning or reducing the quantity of cleaning sol-
vent. Scheduling for long production runs, use of dedicated equipment, or scheduling
batches from light colors to dark colors can also reduce the need for cleaning.
Recycling and reuse of cleaning waste can substantially reduce waste volumes.
Cleaning wastes may be: 1) collected and used in the next compatible batch as part
of the formulation, 2) collected and recycled on or off site, or 3) collected and reused
as a cleaning solvent by filtering or other means of solids removal.
13
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TABLE 3. SUMMARY OF REPORTED RELEASES OF SOLVENTS (CHLORINATED AND ORGANIC)
FROM PAINT FORMULATION
Mean release. 1b (X reporting to each media)1*
Section 313 chemical
Xylene (mixed Isomer)
Toluene
Methyl ethyl ketoiw
Glycol ethers
Methyl Isobutyl ketone
n-butyl alcohol
Acetone
Ethylene glycol
Methanol
Ethyl bentene
1 . 1 . 1-Trlchloroethylene
Olchloranethane
Naphthalene
Sec-butyl alcohol
Number of
facilities
reporting usage*
(X reporting
usage) Fugitive
485
465
348
262
249
237
214
194
171
145
116
79
25
18
(90)
(84)
(64)
(49)
(46)
(44)
(40)
(36)
(32)
(27)
(21)
(15)
(5)
(3)
4042
3555
3867
1813
1635
1693
5098
624
1987
1267
3600
4344
807
472
(92)
(92)
(91)
(92)
(90)
(92)
(94)
(78)
(94)
(96)
(94)
(92)
(96)
(94)
Start
11.443 (74)
13.981 (76)
10.883 (78)
3519 (77)
2465 (81)
7171 (79)
14.124 (73)
856 (70)
1727 (74)
5804 (89)
3520 (60)
5144 (67)
2378 (72)
200 (89)
Water
83 (2)
108 (2)
27(2)
195 (2)
50(1)
455 (1)
133 (1)
103 (4)
572 (2)
4 (1)
0(0)
255 (5)
0(0)
0(0)
Land
188 (3)
3648 (4)
163 (3)
2966 (4)
63(2)
109 (3)
98(2)
1925 (4)
90 (4)
103 (3)
20(1)
18(4)
0(0)
0(0)
POTw*
777 (11)
749 (10)
9242 (9)
2169 (19)
7612 (9)
2223 (11)
162 (9)
4922 (34)
e
265 (21)
4(5)
236 (14)
19 (12)
5(6)
Off -site
transfer
26.071
22.710
15.135
6914
8906
7499
15.069
4403
(48)
(42)
(45)
(58)
(48)
(49)
(43)
(42)
15.508 (42)
4691
7523
5380
2314
(52)
(28)
(34)
(28)
984 (61)
Total*
25.107 (99)
23.768 (99)
19.730 (99)
9006 (99)
8429 (100)
11.303 (99)
21.683 (99)
4909 (95)
13.713 (99)
8895 (100)
7715 (98)
9470 (99)
3136 (100)
1225 (100)
a A total of 540 facilities In SIC 2851 reported usage of at least one Section 313 chemical above threshold limits.
Mean release In pounds per year In 1990 for firms reporting releases of this chemical and percentage of firms reporting usage of this
chemical that release to this media. Releases to other media were Insignificant.
C POTV • Publicly owned treatment works.
The total Includes all releases and off-site transfers, not Just categories similar 1 zed In this table.
e Mean value Is not representative because of a very large value at one facility and the small number of facilities.
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METALS AND METAL COMPOUNDS
Metals and metal compounds are processed by paint formulators as solid
constituents in the paints. The metal/metal compounds are primarily processed as
pigments, but may also be constituents of other additives. A pigment is 'a finely divid-
ed, insoluble powder which imparts color, including black or white, to the paint. Pig-
ments also can impart flatness, rheology, corrosion resistance, hardness, etc."8 Major
pigments that are Section 313 chemicals include barium compounds, zinc oxide and
other zinc compounds, and chromium compounds.8'10 Lead and lead compounds are
still used, but their use is declining because of toxicity concerns. Use of copper
compounds, cobalt compounds, and antimony were also reported in the TRI data-
base.
Metals and metal compounds may be received dry, as a paste, or in slurry
form. Because most pigments are produced by precipitation in water or are washed
with water at the pigment manufacturer, shipment in slurry form may reduce the cost
of the pigment if it is to be used in a water-based paint. Shipment in paste or slurry
form also reduces losses to air during transfer of dry pigment as well as reducing
disposal costs associated with bags or other packages.5 Empty containers of liquid
raw materials may be cleaned or returned to the supplier to be recycled.5
According to AP-42 estimates, 0.5 to 1 percent of pigments handled in dry form
during uncontrolled operations will be lost to air during transfer.9 Air releases may be
easily controlled with a baghouse when focal exhaust is used to reduce worker ex-
posure to the pigments.
Table 4 presents a summary of Section 313 reported releases and off-site trans-
fers of metals/metal compounds at paint formulators, based on Section 313 reporting
for 1990. The primary releases are off-site transfers of pigments in the cleanup
solvent, filter disposal, and disposal of off-spec paint. Air releases are also reported
for transfer of dry pigments. The air release is fugitive or stack depending on whether
local exhaust ventilation is used to reduce worker exposure to the pigments.
15
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o>
TABLE 4. SUMMARY OF REPORTED RELEI
COMPOUNDS FROM PAINT
Section 313 chemical
Barium compounds
Zinc (fume or dust)
Zinc compounds
Lead
Copper compounds
Cobalt compounds
Antimony
Number of facilities
reporting usage*
(X reporting usage)
152 (28)
36(7)
131 (24)
111 (21)
17 (3)
102 (19)
39 (7)
26 (5)
25(5)
WES OF METALS AND METAL
FORMULATION
Mean release, Ib (X reporting to each media)11
Fugitive
460 (61)
451 (53)
244 (64)
247 (55)
196 (53)
286 (55)
225 (44)
188 (35)
281 (52)
Stack
1310 (57)
896 (56)
298 (53)
123 (57)
557 (29)
235 (66)
106 (49)
85 (42)
82 (52)
Water
140 (2)
115 (3)
10 (3)
7 (5)
0(0)
30 (4)
5 (8)
0 (0)
250 (4)
Land
640 (5)
250 (3)
385 (6)
60(5)
0(0)
135 (5)
126 (5)
5 (8)
1 (4)
pour5
822 (27)
113 (11)
169 (26)
73 (23)
5(6)
267 (23)
121 (33)
107 (27)
109 (32)
Off-site transfer
3649 (71)
1161 (56)
1945 (74)
1154 (72)
521 (35)
1853 (72)
2110 (87)
289 (92)
436 (66)
Total"
4124 (94)
I486 (94)
1926 (95)
1161 (91)
512 (88)
1812 (94)
2089 (97)
398 (100)
600 (100)
A total of 540 facilities In SIC 2851 reported usage of at least one Section 313 chemical above threshold limits.
Mean release In pounds per year In 1990 for firms reporting releases of this chemical and percentage of firms reporting usage of
chemical that release to this media. Releases to other media Mere Insignificant.
POTV • Publicly owned treatment works.
The total Includes all releases and off-site transfers, not just categories sunmarlzed In this table.
this
-------
The next largest release is to water or POTW. This release primarily involves
pigments contained in wash water from cleaning equipment used to make water-based
paints. Some water/POTW releases could also result from spills that are sewered.
The water/POTW release of pigments during cleaning can also be reduced by the use
of dedicated equipment, manual cleaning with spatulas or rubber wipers, or use of
tanks with nonstick surfaces such as Teflon.*
17
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RESIN CONSTITUENTS
Resin constituents that are Section 313 reportable chemicals are processed in
paints as unreacted monomers in resin systems, as monomers added to the paint that
react when the paint dries, as plasticizers added to the paint, or as two-part systems
that react when paint is applied. These chemicals may be present in alkyd, polyester,
urea-formaldehyde, acrylic, phenolic, or other resin systems. The best way to deter-
mine their presence is by reviewing MSDSs for the resins as received and the paints
as shipped by the formulator.
Table 5 presents a summary of Section 313 reported releases and off-site trans-
fers of resin constituents at paint formulators, based on Section 313 reporting for
1990. Air releases of these chemicals are difficult to determine as some are solids and
some are liquids. The chemicals mainly are present in a complicated resin system
that does not easily permit engineering calculations to predict volatilization. Off-site
transfers and releases to water, POTW, or land may be estimated the same way as for
solvents and pigments by using the chemical percentage from the MSDS.
18
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CO
TABLE 5. SUMMARY OF REPORTED RELEASES OF RESIN CONSTITUENTS
FROM PAINT FORMULATION
Number of facllltti
reporting usage*
Section 313 chemical (X reporting usage
Styrene
1.2.4-Trlnethylbetifene
Phthallc anhydride
Methyl methacrylate
Butyl acrylate
Butyl bentyl phthalate
01 -(2-ethylhexyl ) phthalate
(DEHP)
Formaldehyde
4.4' - Isopropyl Idenedl phenol
Nalelc anhydride
Ethyl aerylate
Vinyl acetate
Acrylic acid
D1 butyl phthalate
Nethyenebls (phenyllsocyante)
[HBI]
Cumene
Phenol
Toluene dllsocyante
79 (15)
60 111)
55 (10)
51 (9)
44 (8)
29 (5)
29(5)
28 (5)
28 (5)
25 (5)
23 (4)
22 (4)
21 (4)
21 (4)
21 (4)
20 (4)
16 (3)
15 (3)
•s
) Fugitive
9093 (69)
1160 (95)
1499 (67)
1235 (92)
312 (69)
313 (72)
406 (72)
797 (86)
216 (50)
129 (56)
179 (78)
1208 (100)
45 (62)
1295 (62)
94 (52)
547 (95)
1134 (75)
64 (87)
Mean release.
Stack
4368 (82)
1039 (88)
1212 (69)
2154 (90)
402 (89)
289 (72)
211 (66)
464 (86)
372 (71)
116 (56)
361 (91)
2328 (77)
192 (71)
302 (52)
86 (43)
426 (100)
458 (81)
52 (73)
Water
1065 (1)
5 (2)
135 (41
1 (2)
e
0(0)
0(0)
167 (11)
0(0)
0(0)
0 (0)
0 (0)
0(0)
0(0)
0 (0)
0 (0)
1500 (6)
0(0)
1b (X reporting to each media )b
land
5(1)
134 (3)
5700 (2)
5 (2)
5(2)
1900 (3)
250 (3)
42 (4)
0 (0)
0 (0)
5(4)
5(5)
0 (0)
0 (0)
5(5)
0 (0)
0 (0)
0 (0)
POTW6 Off-site transfer
118 (19)
1794 (IZ)
4962 (15)
614 (20)
338 (14)
978 (21)
84 (10)
591 (32)
470 (7)
87 (12)
353 (22)
168 (14)
22 (10)
1865 (10)
1 (5)
1204 (IS)
752 (19)
1(7)
3720 (47)
2451 (43)
3171 (62)
1749 (37)
844 (27)
7356 (52)
1174 (38)
1166 (43)
2348 (75)
590 (68)
691 (48)
775 (9)
616 (67)
379 (43)
339 (33)
309 (50)
13.137 (44)
74(2)
Total1*
13.778 (97)
3352 (98)
4812 (96)
3853 (100)
1505 (100)
4844 (93)
1057 (83)
1927 (93)
2168 (100)
623 (88)
877 (100)
3100 (100)
607 (95)
1365 (95)
262 (76)
1281 (100)
7685 (94)
109 (100)
* A total of 540 facilities In SIC 2B51 reported usage of at least one Section 313 chemical above threshold limits.
b Mean release In pounds per year In 1990 for firms reporting releases of this chemical and percentage of firms reporting usage of this
chemical that release to this media. Releases to other media were Insignificant.
C POTW - Publicly owned treatment works.
The total Includes all releases and off-site transfers, not just categories summarized In this table.
* Mean value Is not representative because of a very large'value at one facility and the small number of facilities.
-------
OTHER CHEMICALS
Table 6 presents a summary of Section 313 reported releases and off-site trans-
fers of other chemicals based on Section 313 reporting for 1990. Ammonia is pro-
cessed as a constituent of water-based paints.5 If the ammonia is received in gaseous
form, air releases can result during storage and transfer. When in aqueous form or
when in water-based paint, air releases result from open tanks and packaging. Off-site
transfers and releases to water, POTW, or land can result during cleaning or from
spills. These releases/transfers can be determined in the same way as for solvents
and pigments, based on the percentage of ammonia from the MSDS.
Because ammonia is a listed Section 313 chemical, all gaseous and aqueous
forms must be considered for reporting. Aqueous solutions of ammonia contain both
nonionized ammonia (NHg) and ionized ammonia (NH4+). As the following chemical
equation shows, the two forms of ammonia are in equilibrium in the presence of water.
NH9 «• 2H2O «* A/H; + OH' + H20
The term total ammonia* refers to the sum of these species (i.e., NH3 + NH/).
The relative amounts of NH3 and NH44 depend upon several factors (e.g., tempera-
ture, pH, ionic strength, and other chemical reactions). To account for all forms that
are present, estimates of Section 313 releases should be made for total ammonia.
Acids (hydrochloric, sulfuric, and phosphoric) are used by a small percentage
(5% or less) of paint formulators. No information was obtained on the use of these
acids. Phosphoric acid may be processed as a phosphate coating product to treat
metal prior to painting. Acids may also be processed as part of a pH adjustment in
some electrocoated paints.
Hydrochloric acid or sulfuric acid may be used to regenerate water deionizers at
water-based paint manufacturers. Sulfuric acid may also be used as a water treatment
chemical at some facilities. Acids may also be otherwise used to neutralize caustic
solutions from dean equipment used to make water-based paints.
20
-------
TABLE 6. SUHMART OF REPORTED RELEASES OF OTHER CHEMICALS
FROM PAINT FORMULATION
Section 313 chemical
Ammonia
Hydrochloric acid
Sulfurlc acid
•M • • — •ktf»i«i>
rnospnoric flcia
Number of facilities
reporting usage*
(X reporting usage)
34 (6)
27 (5)
18(3)
15 (3)
Hean release. 1b (X reporting to each
Fugitive
540 (82)
392 (61)
280 (61)
25« (6)
Stack
588 (62)
615 (56)
209 (33)
168 (2)
Water
e
0 (0)
0 (0)
0 (0)
land
375 (6)
5(4)
250 (6)
0 (0)
POTW5
e
1579 (15)
168 (17)
0 (0)
media)*
Off-site transfer
1361 (41)
•
5 (6)
507 (13)
Total*
7499 (100)
13.966 (69)
424 (67)
345 (73)
" A total of 540 facilities In SIC 2851 reported usage of at least one Section 313 chemical above threshold limits.
Mean release In pounds per year In 1990 for firms reporting releases of this chemical and percentage of firms reporting usage of this
chemical that release to this media. Releases to other media were Insignificant.
-*• c POTV • Publicly owned treatment works.
The total Includes all releases and off-site transfers, not just categories summarized In this table.
Hean value Is not representative because of a very large value at one facility and the small number of facilities.
-------
Acids may be released to air during storage and transfer and released to water
or POTW during water treatment or equipment cleanup of paint products that could
contain acids. Acid releases are primarily controlled through neutralization. For acid
use, a release to water or POTW is not reportable if the pH is 6 or higher; however, a
facility cannot just assume neutralization.
22
-------
USE OF REGULATIONS TO ESTIMATE RELEASES OF SECTION 313 CHEMICALS
Regulations pertaining to paint formulators do not provide direct assistance in
estimating emissions of Section 313 chemicals.
WATER RELEASES
The EPA Effluent Limitations Guidelines for Paint Formulation (40 CFR 466)
define the best available technology economically achievable for oil-based solvent
wash (tank cleaning performed with solvents) as no discharge of process wastewater
pollutants to navigable waters. New source performance standards are the same.
Pretreatment standards for the same source are no discharge of process water pollu-
tants to a POTW. These standards apply only to facilities in which tanks used to
formulate oil-based paint are cleaned by solvents. These regulations are not partic-
ularly useful for estimating water releases because the most likely water/POTW dis-
charge of solvents, metal/metal compounds, and resin constituents is from water
washing of equipment used to make water-based paints. Some facilities may be
required by the POTW to monitor for TTO (total organics listed in 40 CFR 413.02(i)) or
metals.
AIR RELEASES
No national regulations directly limit air releases of VOCs or other pollutants
from paint formulation. The State Implementation Plans for some noncompliance
areas may have plant-specific VOC limits that apply to large facilities. Numerous
regulations governing the industries that apply the paints and coatings, however, have
caused paint formulators to reformulate coatings to reduce the VOC content in the
paint they produce. One source reported that the production of conventional solvent-
based coatings has dropped from about 100 million dry gallons in 1983 to 65 million
dry gallons in 1987 and is expected to drop to 40 million dry gallons by 1993.5 The
same source reported the production of high-solids solvent-based coatings increasing
from 18 million dry gallons in 1983 to 35 million gallons in 1987.9
23
-------
State regulations, especially those in California, may require that the VOC
content of paint sold in the state be below a specified level (e.g., 250 g VOC per liter
of paint). These regulations have also forced paint formulators to reduce the VOC
content in the paints they produce.
These regulations are not particularly useful for predicting releases of Section
313 chemicals from paint formulators. Each plant must be assessed individually based
on the products ft produces.
24
-------
NONREPORTING FACILITIES
Nonreporting facilities may be identified by comparing lists of facilities in
Standard Industrial Classification (SIC) 2851 having more than 10 employees with
those facilities that have reported under Section 313. In addition, an annual publica-
tion-The Paint Red Book-by the publishers of Modem Paint and Coatings lists paint
formulators.12 Dealers and repackages are not listed, however. In 1989, The Paint
Red Book contained listings of 1,202 plants representing 764 companies. The listing
provides the name, location, phone number, total company employees, type of coat-
ings formulated, and other information. Almost all the companies listed employ more
than 10 employees.
Most if not all paint formulators with more than 10 employees would process in
excess of 25,000 pounds of at least one solvent or metal/metal compound (approxi-
mately 55-60 drums of the chemical). This would be true even for water-based paint
formulators.
In addition to the Paint Red Book, sources of information on SIC 2851 present-
ed by employment class include County Business Patterns published by the U.S."
Department of Commerce,13 and Dunn and Bradstreet (D&B).14
Table 7 presents a comparison of the number of facilities listed in various
sources with the number of facilities reporting to TRI in 1990.
TABLE 7. NUMBER OF ESTABLISHMENTS IN SIC 2851
Number of establlsh-
Sonrce Basis merits reported
TRI, 1990 SIC 2851 540
Countv Business Patterns SIC 2851, >10 employees 899
1989"
D&B 1992 SIC 2851 >10 employees 984
Paint Red Book, 1989 Number.of formulation 1209
plants8
* Total 11st, but very few listed were below 10 employees.
25
-------
There apparently are a number of nonreporting facilities, based on the number
of facilities reported in County Business Patterns, D&B, and the Paint Red Book and
the probability that almost all paint formulators would process at least one Section 313
chemical in excess of 25,000 pounds.
A review of the TRI data in 1990 pointed out apparent errors in reporting
whether a chemical was manufactured, processed, or otherwise used. Many facilities
reported chemicals as manufactured when they were clearly processed or otherwise
used (e.g., solvents). There also appeared to be a possible underreporting of solvents
that are typically used as cleanup solvents as otherwise used. Because of the lower
threshold for these uses, this could also cause nonreporting for some cleanup
solvents if the higher processed threshold (25,000 pounds) were used.
26
-------
UST OF QUESTIONS
The following list of questions may be helpful in determining if errors were made
in Section 313 reporting for paint formulators:
Solvents
Which solvents were processed Qust formulated into paint) and which
were also otherwise used (also used as a cleanup solvent)?
For processed solvents, how was air release calculated? Air release
should equal about 1 to 2 percent of throughput for most formulators
(AP-42).
• For otherwise used solvents, was a mass balance performed on the total
quantity used?
For solvents sent off site for fuel burning, recycling, or disposal, was
waste analysis used to determine the quality of the 313 chemical? Most
wastes should be RCRA wastes, which are analyzed.
Was a 10,000-pound threshold used for all otherwise used solvents
(cleanup solvents)?
. How was the quantity of solvent in water-based paints released to water
determined (e.g., glycol ethers)?
Metals/Metal Compounds
Were thresholds for metal compounds determined using the weight of
the compound and not just the weight of the metal portion of the
compound?
Was Toxicity Characteristic Leaching Procedure (TCLP) used as a
measure of metal concentration in any of the calculations? TCLP
measures teachable metal, not metal content, and therefore should not
be used in any release calculations.
Resin Constituents
Were the resin constituents received as an unreacted portion of a resin?
Was the percentage of the 313 chemical on the MSDS as received used
as the basis for release estimates?
27
-------
Were any monomers purchased and added to the formulations?
Were any resins manufactured (polymerized) at the facility? What were
the reactants?
Other Chemicals
Was total ammonia used to report ammonia releases to water?
Was the pH of the water or POTW release used to determine acid
releases? (pH above 6 is not reportable.)
28
-------
BIBLIOGRAPHY
1. Office of Management and Budget. Standard Industrial Classification Manual.
1987. Washington, D.C. 1987.
2. U.S. Environmental Protection Agency. Guides to Pollution Prevention. The
Paint Manufacturing Industry. EPA/625/7-90/005. June 1990.
3. Webber, D. Coating Industry Heading for Record Year. Chem. Eng. News
61(4):51. 1984.
4. Winton, J. M. Coatings 1987. Chemical Week. 141 (15):30. 1987.
5. Lorton, G. A. Waste Minimization in the Paint and Allied Products Industry.
Journal of the Air Pollution Control Association, 38(4)422. April 1988.
6. SRI Chemical Economics Handbook, 1981, as cited in Reference 2.
7. American Chemical Society. Applied Polymer Science. ACS Symposium Series
285, Second Edition. Paint Manufacture, Washington, D.C. 1985. p. 1297-
1314.
8. Kirk-Othmer. Encyclopedia of Chemical Technology. 3rd Edition, Vol. 16.
Paint. John Wiley & Sons, 1981.
9. U.S. Environmental Protection Agency. Compilation of Air Pollution Emission
Factors, 3rd Edition, AP-42. Research Triangle Park, N.C. 1983.
10. U.S. Environmental Protection Agency. Air Pollution Control Engineering and
Cost Study of the Paint and Varnish Industry. EPA 450/3-74-031, June 1974.
11. U.S. Environmental Protection Agency. Air Pollution Engineering Manual. AP-
40, 2nd Edition. Research Triangle Park, N.C. May 1973.
12. Communication Channels Inc. 1989 Paint Red Book, 21st Edition, Atlanta, GA.
1989.
13. U.S. Department of Commerce, Bureau of Census, County Business Patterns
1989, CBP-89-1, Washington, D.C. 1991.
14. Dunn & Bradstreet, Dunn's Electronic Business Directory in DIALOG database
file 515.1992.
29
-------
Appendix A
-------
<&EPA
United States
Environmental Protection
Agency
FC
SecfenX
ate know
\DIV/I D TOXIC CHEMICAL RELEASE
/niVI n INVENTORY REPORTING FORM
3 of the Emergency Planning and Community Right-MOnw Act of 1986.
n at Tldt HI of the Supttfund Amendment and Raautarization Ad
WHERE TO SEND
COMPLETED FORMS
1. EPCRA Reporting Center i APPROPRIATE STATE OFFICE
P.O. Box 23779 (S*» MBudnm n Appendb F)
Washington. DC 200264779
ATTN: TOXIC CHEMICAL RELEASE INVENTORY
IMPORTANT: See instructions to determine when "Not
Applicable (NA)n boxes should be checked.
TRiMCVTVOIIUtlBfP
TacCtanm CMgonf. or Gmrc Hum
Enter -X* here!
thia la a revision
MrlMtMMy
•
PART 1. FACILITY IDENTIFICATION INFORMATION
SECTION 1.
REPORTING
YEAR
19
SECTION 2. TRADE SECRET INFORMATION
2.1
2.2
Are you claiming the toxic chemical identified on page 3 trade secret?
DYes (Answer question 2.2: ("~~"| No (Do not answer 2.2:
Attach substantiation forms) 1— J Go to Section 3)
If yes in 2.1 , is this copy: | | Sanitized | | Unsanitized
SECTION 3. CERTIFICATION (Important: Read and sign-after completing all form sections.)
I hereby certify that 1 have reviewed the attached documents and that, to the best of my knowledge and belief, the
submitted information is true and complete and that the amounts and values in this report are accurate based on
treasonable estimates using data available to the preparers of this report.
Name and official We of owner/operator or senior management official |
Signature |
Dato Signed ]
.
SECTION 4. FACILITY IDENTIFICATION
4.1
!
»
Facility tx Establishment Name J TRI Facility ID Number)
Sfreet Address I
City I
Stale I
MafBng Address (Hd^rert from steet address) |
CJJLJ
State I ZipCods I
County |
Zip Code |
PUT LABEL HERE
•PA Form 9350-1 (Rev 5/14/92) • Previous edffions are obsotoft.
-------
Peee2of 9
** CDA EPA FORM R
ESSSSLi**** PARTI. FACILITY IDENTIFICATION
tSST" re . INFORMATION (CONTINUED)
| T«c Ctmncm. r mtm ,. er O»wc Hm
SECTION 4. FACILITY IDENTIFICATION (Continued)
4.2
4.3
4.4
4.5
4.6
4.7
4.8
4.9
4.10
This report contains information tar, m r— i . _. .^..^
(Important: check only one) a" LJ An entire facillty
Name I
Technical Contact '
Name I
Public Contact '
SIC Code
f«wo .. b. c. d.
umuav Degree* Ilintrtw Seconda Degrees
Longitude)
Dun ft Bradstreet Number(a) (9 digits) a
b.
EPA Identification Numbers) (RCRA LD. No.) a-
(12 characters) b
Facility NPDES Permit Numbers) a-
(9 characters) .
• . D.
Underground Injection Well Code (UIC) I.Q. a.
Number(s) (12 digits)
b.
b. | | Part of a facility
Tebphont Number (taboi area coot)
Telephone Number (ndudt area cote)
t. f.
Longitude
MhMdat Seconds
-"
SECTION 5. PARENT COMPANY INFORMATION
5.1
5.2
Name el Parent Company |
DNA
Pawn Compenyn Dun a Budtteet Number j
n NA (9 digits)
sPA Form 9350-1 (Rev. VI 4*2). Primus wftons am abMlM.
-------
rag* J « S
EPA
Unittd States
Environmental Protection
Agoncy
EPA FORM R
PART II. CHEMICAL-SPECIFIC
INFORMATION
SECTION 1 TOXIC CHEMICAL IDENTITY (Important: DO NOT complttf this
SECTION 1 . TOAii* unewiK, AL lUtlM HIT ^^ H yo|| comp|tta s^fon 2 btlow.)
1.1
1.2
1.3
CASNumbar (Important: Ent»r only on* numetf«arty»sltipptaf» on l» Section 313 1st. EmtrattgofycodiHrapartingaeiwmBileaiBgory)
Tone Chtmeal or ChamealCatagory Nam* (Important Em«onlyon«umtaxadryasttappMnanlh«S«aton313ksl)
Ganarfc Chtmial Nam*
(Important: Comptot* only if Pan 1. Section 2.1 > chackad >*!* Gtntrlc Nairn must bt structurally descnptrvt )
SECTION 2. MIXTURE COMPONENT IDENTITY
2.1
Gcntrfc Chtmfcal Nam* Provfotd by SuppBar (Important Manmum of 70 crtaracttn. hdudng numbmjtBan. apaoas. and punctuation.)
SECTION 3. ACTIVITIES AND USES OF THE TOXIC CHEMICAL AT THE FACILITY
(Important: Cheek all that apply.)
3.1
Manufacture
the toxic
chemical:
a. 1 — 1 Produce
b. 1 1 Import
If produce or import:
c. 1 1 For on-site use/processir.g
d. 1 1 For sale/distribution
e. I I As a byproduct
f. | | As an impurity
3.2
Process
the toxic
chemical?
a. LJ As a reactant c. 1 1 As an article component
b. 1 1 As a formulation component d. [~| Repackaging
3.3
Otherwise us*
the toxic
chemical:
a. 1 1 As a chemical processing aid c. 1 1 Ancillary or other use
b. [""] As a manufacturing aid
SECTION 4. MAXIMUM AMOUNT OF THE TOXIC CHEMICAL ON-SITE AT ANY TIME
DURING THE CALENDAR YEAR
4.1
(Enter two-digit code from instruction package.)
EPA Form 9350-1(R«v. 5/14*2) • Pnvtous adUons am obaolata
-------
EPA
Unit*d States
Environmental Protection
Agency
EPA FORM R
PART II. CHEMICAL-SPECIFIC
INFORMATION (CONTINUED)
Pag* 4 ot 9
THI E«ca.rr> o KUMBEa
SECTION 5. RELEASES OF THE TOXIC CHEMICAL TO THE ENVIRONMENT ON-SITE
A. Total RflMM (pounds/
yB8r) (win QDQB cod6 from
instructions or estirnttB)
5.1
5.2
Fugitive or non-point air
•missions
Stack or point all
•missions
DNA
DNA
Discharges to receiving
streams or water bodies
(enter one name per box)
5.3.1 Stream or Water Body Name
B. Basis of
Estimate
{•nttrcode)
C.%From
Stormwattr
5.3.2 Stream or Water Body Name
5.3.3 Stream or Water Body Name
5.4
5.5
5.5.1
5.5.2
5.5.3
5.5.4
Underground Injections
on-slte
Releases to land on-slta
Landfill
Land treatment/ .
application terming
Surface Impoundment
Other disposal
| | Check here only If additional Section 5.3 Information Is provided on page 5 of this form.
IPA Form 9350-1 (Rtv. 5/UftZ) • Pnvious cdtioM an abtoMi
RangtCodn. A-1-10pounds: B>n-499pounds;
C« 500 -999 pounds.
-------
«-EPA
United States
Environmental Protection
Agency
EPA FORM R
PART II. CHEMICAL-SPECIFIC
INFORMATION (CONTINUED)
Pag* 5 of 9
SECTION 5.3 ADDITIONAL INFORMATION ON RELEASES OF THE TOXIC CHEMICAL TO THE
ENVIRONMENT ON-SITE
Discharges to receiving A. Total Release (pounds/
5.3 Streams or water bodies year) (enter range code from
(enter one name per box) instructions or estimate)
5.3. Stream or Water Body Name
5.3._ Stream or Water Body Name
5.3. .Stream or Water Body Name
B. Basis of C.%From
Estimate Stormwater
(enter code)
SECTION 6. TRANSFERS OF THE TOXIC CHEMICAL IN WASTES TO OFF-SITE LOCATIONS
6.1 DISCHARGES TO PUBLICLY OWNED TREATMENT WORKS (POTW)
' 6.1 .A Total Quantity Transferred to POTWs and Basis of Estimate
6.1JL1 Total Transfers (pounds/year)
(enter range code or estimate)
6.1. B POTW Name and Location Information
POTW Name J
C.1.D. —
Street Addreta J
Cifr I '
Sate |
Cotnty j
ZbCodH
6.1JL2 Basis of Estimate
(enter code)
-
n i n I TOTWNim»
Street Address |
Q» 1 Ooarty 1
Stt» \ Zip Code |
If additional pages of Part II, Sections 5.3 and/or 6.1 are attached. Indicate the total number of
and Indicate which Part If, Sections 5.3/6.1 page this Is, here.} |
(example: t, 2,3, etc.)
pages In this box
ePA Form 9350-1 (Rev. 5n«92) • Previous eeftons we obsoM.
Range Codes: A.1-10poun
-------
EPA
EPA FORM R
PART II. CHEMICAL-SPECIFIC
INFORMATION (CONTINUED)
rag* o at»
SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATIONS
Oitate EPA MMMcaton lumbar (RCMjDNajl
Off-Sin location Name ]
SfrMt Address j
Crty 1
a*"*..]
Stilt | apCodt | to location under control of reporting r— i — i
~~~"^ faculty or parent company? I | YM | | Ne
(tram rang* cod* or estinala}
1.
2.
3.
4.
•.BHtoerEittMli
(an* «to)
1.
2.
3.
4.
-------
EPA FORM R
PART II. CHEMICAL-SPECIFIC
INFORMATION (CONTINUED)
Pag«7of9
If additional eoplas of page 7 are attached, indicate the total number of pages In this
box | [ and Indicate which page 7 this Is, here. | | (example: i, 2,3, ate.)
.PA Form 9350-1 (Rw. S14/92) • Pravious *Kor* an obsoMr
-------
EPA
EPA FORM R
PART II. CHEMICAL-SPECIFIC
INFORMATION (CONTINUED)
Pag* 6*9
SECTION 7B. ON-SITE ENERGY RECOVERY PROCESSES
Not Applicable (NA) - Check here If up. on-slte energy recovery Is applied to any waste
stream containing the toxic chemical or chemical category.
Eiwrgy Itocovwy Itothodt [wittr
eod«(t)]
SECTION 7C. ON-SITE RECYCLING PROCESSES
Not Applicable (NA) - Check here If ntt on-slte recycling Is applied to any waste
stream containing the toxic chemical or chemical category.
Raeycllng Itathods [«ntw tehwutor eodi(t]|
UForm93SO-1 (Rev V14^2).Pi«vious«ft)ansanab»Mi.
-------
Page9of»
^ERA EPA FORM R
%££&****« PART II. CHEMICAL-SPECIF
SSy nttl Pretictl° . INFORMATION (CONTINUEI
»» «ACI TV o mu8E<> r
'If CnmeiLCwooir.wGm"cNm
3)
SECTION 8. SOURCE REDUCTION AND RECYCLING ACTIVITIES
All quantity istlmatfs can ft* nportod
using up to two significant figures.
8.1
8.2
8.3
8.4
8.5
8.6
8.7
4.8
8.9
Quantity released*
Quantity used for energy
recovery on-slte
Quantity used for energy
recovery off-site
Quantity recycled on-slte
Quantity recycled off-site
Quantity treated on-sfte
Quantity treated off-site
Column A
1990
(pounds/year)
•
Column B
1991
(pourufc/yeir)
Column C
1992
(pounds/y«ar)
Column 0
1993
(pounds/yev)
-
Quantity released to the environment as a result of '.--
remedial actions, catastrophic events, or one-time events
not associated with production processes (pounds/year)
Production ratio or activity Index
8.10
8.10.1
8.10.2
8.10.3
8.10.4
8.11
Did your facility engage In any source reduction activities for this chemical during '
the reporting year? If not, enter "NA" In Section 8.10.1 and answer Section 8.11.
Source Reduction Activities
[enter code(e)]
Methods to Identify Activity (enter codes)
a.
a.
a.
a.
b. c.
b. c.
b. c.
b. c.
Is additional optional Information on source reduction* recycling, or
pollution control activities Included with this report? (Check one box)
YES NO
a a
Report releases pursuant to EPCRA Section 329(8) including 'any spilling, leaking, pumping, pounng. emitting, emptying, discnargng.
injecting, escaping, leaching, dumping, or disposing into the environment.* Do not include any quantity treated on-site or off-site.
EPA Form 9350 • 1 (Rev 5/1402) • Previous edhms are obsotts
-------
Appendix B
-------
1990
1 ... ^ EMERGENCY AND HAZARDOUS
Tier One CHEMICAL INVENTORY
AOOC*4 CMS SC X '
£25.. [
More completing form
(Crranc)
tMflftMMVOV
«0«T«<
9.999
99.999
01 0
oa too
0$ 1000
04 10.000
09 100.000
09 1.000.000 9.999.909
07 10.000.000 40.999.999
09 90.000.000 99.999.999
09 100.000.000 499999999
10 900.000.000 999 999 999
-------
Tier Two
EMERGENCY
CHEMCAL
MVEHTORV
i i i
MHi
11*.
-,*•>»,•- 5,< -•»
' * * ? <.
^i i i i i i-imn £±
CP»S«.
8tor«o* Codtt and Uevtfont
i i i i nmn ai
EH8
uai i i i i nmn £±
- u u u u u u
EHSI
^^W^^k ^^^ 1^^^ %
-------
Tier Two
HAM
MVCNfORV
r
MM
Confidential Location Information Sheet
iii
^•Jw^^^^^P^P ^I^T^^^^^^ V^Mv vMrV^VMV^W^P
"••MM IJLJ
'»! M I I ULUU
"••Ml I I Mi_LJLJ
-------
Appendix C
-------
Sample Notification Letter
Mr. Edward Burke
Furniture Company of Ruritania
1000 Main Street
Sellers, Ruritania
Dear Mr. Burke:
The purpose of this letter is to inform you that a product that we sell to you, Furniture Lacquer KXZ-
1390, contains 20 percent toluene (Chemical Abstracts Service (CAS) number 108-88-3). We are
required to notify you of the presence of toluene in the product under Section 313 of the Emergency
Planning and Community Right-to-Know Act of 1986. This law requires certain manuafcturers to
report on annual emissions of specified toxic chemicals and chemical categories.
If you are unsure if you are subject to the reporting requirements of Section 313, or need more
information, call the EPA Emergency Planning and Community Right-to-Know Information Hotline:
(800) 535-0202 or (202) 479-2449 (in Washington, DC or Alaska). Your other suppliers should also
be notifying you if Section 313 chemicals are in the mixtures and trade name products they sell to
you.
Please also note that if they repackage or otherwise redistribute this product to industrial customers, a
notice similar to this one should be sent to those customers.
Sincerely,
Axel Leaf
Sales Manager
Furniture Products
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Sample Notification on an MSDS
Section 3D Supplier Notification
This product
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