process characterization for tur · gg-04 thermal oxidizer gg-01 gg-04 . gg-04 blending /...

Process Characterization for TUR

Rich Bizzozero – OTA

Objectives

Understand why it’s important to be thoughtful in the

selection of a production unit and unit

of product

Understand why a whole-facility production unit, or

a poorly selected one, may mask progress in

tracking toxics use reduction

Understand what processing steps need to be included in the

description of a production unit

Differentiate between chemical use, product,

byproduct and emission

After this module, you will…

Key Definitions

Production unit

Chemical use

Byproduct

Emission

Unit of Product

Production Ratio

Production Unit

A process, line, method, activity, or technique, or a combination or series thereof, used to produce a product.

The production unit is where chemical tracking is performed, TUR planning performed and TUR progress is documented and reported on Form-S.

Chemical Use

• Manufacture – Create a reportable chemical • Process – Incorporated into product • Otherwise use – manufacturing aid, not part

of the product

• A + B = C • (C = Manufactured product) Manufacture

• A + B = A + B • (Mixture) Process

Byproduct

All non-product outputs of toxic or hazardous substances generated by a production unit, before handling, transfer, treatment or release. Otherwise used substances shall be counted as byproduct when they leave a production unit.

Emission

A release of a toxic or hazardous substance to the environment (on or off site) or a transfer of a toxic or hazardous substance in waste to an off-site location.

Unit of Product

• A measure that reflects the level of production or activity associated with the use of the toxic or the generation of the toxic as byproduct.

• Examples: – 1000’s square yards of coated fabric – Amp hours, pounds of product manufactured – Gallons of adhesive manufactured – Pounds of metal product clean, square feet of product

cleaned

Production Ratio / Activity Index

• Most cases - must be based on some variable other than the reportable chemical usage – Why?

• Ratios based on reportable chemical use may reflect the effects of source reduction (TUR)

• Examples: pounds of ethylene glycol used to manufacture water-based paint vs gallons of water based paint manufactured containing ethylene glycol

• Reportable chemical usage is not an appropriate activity index for “otherwise used” category of use

Facility-Wide Materials Accounting

Manufactured ____________ Processed ____________ Otherwise Used _______ Generated as Byproduct ______ _ Shipped in Product __________ Section 2: Optional Chemical was recycled on-site_________ Chemical was consumed ______ _ Chemical was held in inventory________ Chemical was a compound_________ Other (explain)__________________________________

Mass Balance

Does

Manufactured + Processed + Otherwise Used

= Byproduct + Shipped in Product ?

If not, has the optional section been filled in to explain why?

Chemical Recycled On-Site Chemical is a Compound

Chemical Held in Inventory Chemical Consumed or Transformed

Byproducts & Emissions

Byproducts should = Emissions unless you have:

• destructive treatment

• on-site recycling

• waste staying on site

BYPRODUCT

EMISSION

Byproducts & Emissions

Byproducts = Amount of the reportable chemical that leaves the production unit that is NOT consumed, chemically transformed or shipped in product

Byproducts = “Waste” BEFORE treatment

Emissions = Releases to environment (on or off site) or transfers off-site

BYPRODUCT

EMISSION

Let’s Get Started - Process Characterization Requirements - 1

Must Include For EACH Production Unit: – Production Unit Number – Unit of Product – Process Flow Diagram with:

• Each step including treatment and recycling • Movement of each reportable chemical through

process including all points of entry and exit as product, byproduct or emission

Process Characterization Requirements - 2

For EACH reportable chemical used by Production Unit: – Purpose – Total amounts & amounts per unit of product – Byproduct fate: amounts released on-site, treated on-site and off-

site, recycled on-site and off-site, and disposed of on-site and off-site

– Emissions to each media: amounts released on-site, disposed on-site, transferred off-site, and treated, recycled and disposed of off-site to air, surface water, ground water, and land

– Cost of toxics (qualitative or quantitative) • Quantitative if technically feasible options identified • Qualitative if no technically feasible options identified

Product Sodium Hydroxide Wastewater

Sodium Hydroxide

Pulper

Clean Pulp

Holding

Machine Chest

Paper

Dryer

Wastewater Treatment

Steam

Fresh Water

Cotton

Paper (product) (residual NaOH)

50,000 lbs.

Condensate

1,000 lbs

river

Off-spec paper

Paper-making Production

Unit

Fabric Coating with Solvent Adhesive Process

AA-03 BB-09

Adhesive Roll Coating

Cotton fabric

Finished Goods Storage

GG-04

Thermal Oxidizer

GG-01

GG-04

GG-04

Blending / Compounding

Adhesive storage

Drying

Toluene + MEK + Antimony Compound

Receipt & Storage Product flow

Toluene liquid phase

MEK liquid phase

Antimony

Production Operation

Fabric Coating with Solvent Adhesive – Byproducts

AA-03 BB-09

Adhesive Roll Coating

Cotton Fabric

Finished Goods Storage

GG-04

Thermal Oxidizer

GG-01

GG-04

GG-04

Blending / Compounding

Adhesive storage

Drying

Toluene + MEK + Antimony Compound

Receipt & Storage Product flow

Toluene liquid phase

MEK liquid phase

Antimony

Production Operation

Byproduct

Toluene Byproduct

MEK Byproduct

Byproduct

Byproduct

Byproduct Byproduct

Coating Byproduct (Antimony, Toluene,

MEK)

Fabric Coating Equipment Cleanup

FF-01 FF-01

Cleaning Operation

Adhesive Roll Coating

Finished Goods Storage

GG-04

Thermal Oxidizer

Blending / Compounding

Adhesive storage

Drying

MEK

Byproduct

Byproduct Byproduct Byproduct

Byproduct

MEK Byproduct

Coating Byproduct (Antimony, Toluene, MEK)

MEK

Fabric Coating with Solvent Adhesive – Process and Clean-up PFD

FF-01 FF-01

MEK

Cleaning Operation

Toluene Byproduct

MEK Byproduct

AA-03 BB-09

Adhesive Roll Coating

Cotton Fabric

Finished Goods Storage

GG-04

Thermal Oxidizer

GG-01

GG-04

GG-04

Blending / Compounding

Adhesive storage

Drying

Toluene + MEK + Antimony Compound

Receipt & Storage Product flow

Toluene liquid phase

MEK liquid phase

Antimony

Production Operation

Byproduct

Byproduct Byproduct

Coating Byproduct (Antimony, Toluene, MEK)

Byproduct

Byproduct

Byproduct

Thank you!

Questions?

Rich Bizzozero Director, OTA

rich.bizzozero@state.ma.us 617-626-1080