United States:,- f ....
Envifbnrriental Protection '
Agency "' : ' , ' :
. Prevention, Pesticide's,
And Toxic Substances
(7101) / :-, '
EPA902-R-977003 ;.
August 1997 / .
vxEPA Multimedia Pollution Prevention
Pfpject Report
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gresultsoF permit consolidation at Schering-Plough's^KeriilNyorthtacihty.
while permits it replaces are shown in file Gatgiriets.
ScHering-Plough Corporation ancTNarClymer, PhotograptJeT
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Acknowledgments
The U.S. Environmental Protection Agency's Pollution Prevention Policy Staff and its
Region 2 Office gratefully acknowledge and thank the participating states for their commitment
and support received under this project. Without their experience, generosity, expertise, and
willingness to explore new opportunities for environmental protection, this report could not have
been produced. Also, we wish to acknowledge the broad support and important input received
from all peer reviewers, within and without the Agency, who helped in the preparation of this
report.
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CONTENTS
Section
I.
INTRODUCTION
II. STATE MULTIMEDIA PERMITTING EFFORTS
New Jersey
Arizona
Massachusetts
Other States
IE. PROJECT FINDINGS
Environmental Results
Other Benefits and Costs
Multimedia Permitting and Pollution Prevention
Incentives Used in M2P2 Programs/Projects
Issues/Barriers
IV. RECOMMENDATIONS
ATTACHMENT A
ATTACHMENT B
Page
1
5
5
8
10
10
13
13
16
18
20
22
25
ATTACHMENT C
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I. INTRODUCTION
This report presents the findings of a study conducted by the U.S. Environmental Protection
Agency (EPA) to evaluate the results of a pilot project on multimedia environmental permitting,
with a focus on pollution prevention. The project was part of President Clinton's Regulatory
Reinvention Initiative.
President's Regulatory Reinvention Initiative
In March 1995, President Clinton unveiled a major initiative aimed at finding "cleaner,
cheaper and smarter" ways of reaching our nation's environmental goals. The Regulatory
Reinvention Initiative is designed to build greater fairness and common sense into the regulatory
system while ensuring that environmental progress will continue.
The focal point of the initiative is a set of 25 pilot projects that are testing innovative
regulatory approaches through partnerships with states, communities and private industry. EPA has
formed a Regulatory Reinvention Team to coordinate these projects and has proposed a
reorganization that would include an Office of Reinvention within EPA's Office of the
Administrator.
Multimedia Pollution Prevention Permitting Project
As one of the reinvention projects, EPA is working with several states to examine the
feasibility of developing multimedia pollution prevention-based permits for industrial facilities.
A multimedia permit, broadly defined, is a single enforceable agreement that controls releases to
multiple environmental media with permitted releases to each media determined in a coordinated
manner, as distinct from the usual practice of writing separate permits for each medium (air, water
and soil/land).
Advocates of multimedia permitting say the approach will lead to more effective
environmental management, while reducing delay and duplication, advancing pollution prevention
and, over time, reducing costs. Through the pilot project on multimedia pollution prevention-based
permitting (M2P2 Project), EPA hopes to gain experience and information that will be useful in
evaluating such claims.
EPA's Pollution Prevention Policy Staff (PPPS) and its Region II office are managing the
M2P2 project in cooperation with states and industry. The mission of PPPS is to coordinate EPA's
pollution prevention activities across media programs. Region II oversees the implementation of
EPA programs in the States of New York and New Jersey, the Commonwealth of Puerto Rico and
the territory of the U.S. Virgin Islands.
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States Lead the Way
The M2P2 Project ties together a number of efforts initiated by states to develop multimedia
permits and related environmental management tools. EPA's role in the project is to provide
technical and administrative assistance, facilitate information sharing, help clarify key issues, and
coordinate a peer review of the project results. States do the actual permitting.
This report focuses primarily on efforts underway in New Jersey, Arizona, and
Massachusetts. These states began their efforts relatively early and have made significant progress
toward their goals.
Project Background and Development
The M2P2 Project began with a meeting and conference call, held in August 1995, to define,
the scope and overall parameters of the project. Participants reached agreement on a workplan and
schedule, as well as a division of responsibility for further action.
The initial meeting was followed by a conference and training session on multimedia
permitting, held November 1995 in Baltimore, MD. Representatives of states, EPA, industry and
environmental organizations were in attendance. The conference included a presentation on the
M2P2 Project. Several workgroups met during the conference to discuss key issues and to develop
a framework for data collection and peer review of the project results.
In December, the EPA lead offices contacted states that had attended the conference to find
out which were planning to take part in the M2P2 Project. The states that decided to participate were
asked to make a commitment to develop one or more multimedia permits (or suitable interim work
products) within the project timeframe and to join in the peer review process. States were also asked
to identify facilities that were interested in obtaining a multimedia permit.
The next phase of the project focused on development of the multimedia permits. After
collecting baseline data, the states began working with cooperating facilities to define the terms of
the individual permits and to develop actual permit language (several states had already begun this
process). States also provided updated information to EPA.
EPA then proceeded with the analysis of project data and began work on the project report.
After completing a draft of the report, EPA circulated the document first for internal Agency review
and then for a broader peer review. This report reflects both sets of comments.
This report contains preliminary recommendations that are based on early and still
inconclusive findings that tend to show there are potential environmental and economic benefits to
be realized with multimedia permitting, but that there are significant barriers to broad
implementation.
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Environmental Permitting Today
Environmental permitting plays a key role in society's efforts to control industrial pollution.
For most regulated facilities, the permit serves as the instrument by which environmental regulations
are applied to individual sources. The typical individual permit is issued to a single facility, setting
limits on the release of specific pollutants (or pollutant parameters) to a single environmental
medium.
Most environmental permitting programs are organized by environmental media, reflecting
the structure of the underlying laws and regulations. The U.S. Congress has created separate
permitting programs under the Clean Air Act, Clean Water Act, and the Resource Conservation and
Recovery Act (RCRA), which control releases to the air, water, soil and groundwater (see Figure 1).
The Clean Water Act establishes the National Pollutant Discharge Elimination System (NPDES)
permit program, RCRA as amended by the Hazardous and Solid Waste Amendments (HSWA)
establishes the hazardous waste permit program under Subtitle C, and the Clean Air Act establishes
the Title V operating permit program. Generally, if a state has adopted regulations at least as
stringent as the federal requirements, EPA may authorize it to administer them in lieu of the federal
program. However, EPA still retains oversight responsibilities. Currently, the three primary states
participating in the M2P2 project (New Jersey, Arizona and Massachusetts) have approved interim
operating permit programs pursuant to Title V of the C AA. With respect to the hazardous waste
program, only New Jersey and Massachusetts have final approval of the RCRA base program.
Under the NPDES program, only New Jersey has been authorized.
The current permitting system has the advantages of being firmly established and familiar
to a broad range of stakeholders, but it is often characterized as an obstacle to effective program
integration, a barrier to pollution prevention, and a source of duplication and inefficiency. As single-
medium permits multiply in number, it is argued, companies are forced to devote an increasing share
of resources to permit applications, renewals and modifications. Critics maintain that this diverts
scarce resources from more productive activities.
Most companies respond to permitting requirements by creating a specialized environmental
function, distinct from core business functions such as product design and production management,
or by hiring environmental consultants. These responses work to the disadvantage of pollution
prevention, which requires a greater integration of environmental considerations into core business
decisions. For example, a company that is required to have separate permits to control releases to
the air, water and soil (as hazardous waste), may respond by developing three different end-of-pipe
strategies, instead of determining whether it could reduce its use of hazardous substances through
cost-effective design and process innovations.
Multimedia Permitting Approaches
The perceived weaknesses of single-medium permitting have stimulated interest in proposals
to reorganize the permitting function on an integrated multimedia basis. In broad terms as noted
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earlier, a multimedia permit is a single enforceable agreement that is designed to control releases
to multiple regulated environmental media in a coordinated manner.
There are many possible variations on this basic model. The following section describes the
specific approaches being taken by states involved in the M2P2 Project. These range from full-scale
consolidation of permits across media to a streamlined multimedia self-certification form designed
for small companies.
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FIGURE 1
Current EPA Permitting Programs
I. The Clean Air Act
The goal of the Clean Air Act (CAA) is to control and abate air pollution through
regulation of air emissions from mobile and stationary sources.
Sources located in attainment areas are subject to the prevention of significant
deterioration (PSD) permit program. The PSD program applies to sources that have the
potential to emit over 250 tons per year (tpy) of a regulated pollutant, or over 100 tpy of a
regulated pollutant if the source falls within one of 28 listed source categories. Under the
PSD program, a permit must be obtained before one can construct a major new source, or
undertake a major modification of an existing major source, in a national ambient air
quality standard (NAAQS) attainment area.
Sources in nonattainment areas may be subject to the nonattainment major new source
permit program. The nonattainment program applies to sources that have the potential to
emit at least 10 - 100 tpy of the nonattainment pollutant.
All sources, whether located in an attainment or non-attainment area, are required to
obtain a minor new source review permit for any activity which may increase emissions
of a regulated pollutant.
Title V of the 1990 CAA Amendments requires a state to develop and implement a
detailed and extensive operating source permit program for all sources of significant air
emissions, including stationary and mobile sources. The CAA permits must contain
emission limitations, monitoring and reporting requirements, and any other conditions
that are applicable to the source. This new operating permit program facilitates source
compliance and enforcement activities by consolidating all the federal and state
regulations into a single document.
II. The Clean Water Act (CWA)
The goal of the Clean Water Act (CWA), enacted in' 1977 and amended by the Water
Quality Act of 1987, is to restore and maintain the quality and integrity of the nation's
waters.
The CWA required the establishment of effluent limitation guidelines, pretreatment
standards, and new source performance standards for industrial discharges based
principally on the degree of effluent reduction attainable through the application of
control technologies.
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Section 402 of the CWA provides for the issuance of permits to direct point source
dischargers under National Pollutant Discharge Elimination System (NPDES). These
permits are issued either by EPA or by a state agency approved to administer the NPDES
program. Individual NPDES permits must incorporate applicable technology-based
limitations contained in guidelines and standards for the industrial category. In situations
where more stringent site specific limits than technology-based effluent guidelines must
be developed in order to protect the water quality of the receiving waters, water quality-
based limitations must be used in a permit. Where EPA has not promulgated applicable
technology-based effluent guidelines for an industry, the permit must utilize best
professional judgement to establish limitations for discharges.
The CWA also established national pretreatment standards under the pretreatment
program to regulate pollutants from industrial users discharging into the sanitary sewer
system that may interfere with the operation of a publicly owned treatment works
(POTWs). Under the pretreatment program, limitations are imposed on industrial users
of a POTW through a permit issued by the POTW or by the state or EPA. Indirect
discharges are regulated by the general pretreatment regulations and categorical
pretreatment standards for new and existing sources (PSNS and PSES) covering specific
industrial categories determined to be the most significant sources of toxic pollutants.
III. The Resource Conservation and Recovery Act (RCRA)
The Resource Conservation and Recovery Act (RCRA), as amended by the Hazardous
and Solid Waste Amendments (HSWA) of 1984, creates a "cradle to grave" management
system to ensure that hazardous wastes are transported, treated, stored, and disposed of in
a manner that ensures the protection of human health and the environment.
Hazardous waste generators are required by RCRA to register with USEPA, to meet
certain standards for managing their hazardous waste, and to recycle, treat or dispose of
the waste only in RCRA licensed facilities (see below). While the RCRA generator
program is not typically regarded as a "permit" program, it essentially is an enforceable
permit program that sets management standards without limiting releases
Subtitle C of RCRA requires all hazardous waste treatment, storage, and disposal
facilities (TSDFs) to obtain an operating permit issued either by EPA or an authorized
state. Regulated hazardous waste management units include: container storage areas,
tanks, surface impoundments, waste piles, land treatment areas, landfills, incinerators,
boilers and industrial furnaces, thermal, chemical, physical, and biological treatment units
and underground injection wells.
HSWA further requires that owners and operators of RCRA permitted treatment, storage,
or disposal facilities certify that they have a program in place to reduce the volume and
toxicity of waste generated to the extent that is economically practicable.
HSWA also requires corrective action for all releases of hazardous waste or constituents
from any solid waste management units at TSDFs. Corrective action requirements are
imposed through a permit or an enforcement order.
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II. STATE MULTIMEDIA PERMITTING EFFORTS
Several states are working on the development of multimedia permits for issuance to specific
cooperating facilities. Most of these efforts are pilot projects which have the potential to be
expanded if initial results are positive.
It has been noted that most of the states' permits/agreements completed to date, and
discussed in this report, have a strong air focus as compared to the other media. This may be due
to the fact that there are simply more regulated air emission points at a typical facility and that there
are more facilities subject exclusively to air permitting requirements.
This section describes the efforts underway in the three primary states that are participating
in the M2P2 project: New Jersey, Arizona and Massachusetts. In addition, it briefly outlines what
several other states are doing, or planning to do, with respect to multimedia permitting.
New Jersey
New Jersey has a pilot program underway to test the feasibility of developing multimedia
permits for a wide range of industrial facilities. The State Pollution Prevention Act of 1991 (PPA)
requires the NJ Department of Environmental Protection (NJ DEP) to select 15 "priority industrial
facilities" to take part in the pilot program. Each facility is to be issued a single facility-wide permit
(FWP) covering all of its regulated emissions and discharge points. The permit application would
include the facility's multimedia pollution prevention plan, required by the PPA.
The program's four main goals are to: promote pollution prevention, increase operational
flexibility, streamline the permitting process, and identify regulatory obstacles to pollution
prevention. Emphasis is placed on encouraging reduction of nonproduct output, defined as all
hazardous material that is generated prior to storage, recycling, treatment, control or disposal, and
that is not intended to be used as intermediate or final product.
How the FWP Program Operates
The NJ DEP responded to the PPA's requirements by assigning its Office of Pollution
Prevention to coordinate the FWP program with technical support from the air, water and hazardous
waste permitting programs. The directors of the media programs jointly sign each final multimedia
permit.
The PPA sets forth a number of criteria by which facilities are selected for the program, such
as a facility's potential to serve as a model for multimedia pollution prevention, the likelihood that
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its P2 planning goals will be achieved as a result of the facility-wide permit, and others. The NJ
DEP has the authority to require participation but has chosen to leave the program wholly elective.
Of the 70 facilities approached in an initial round of contacts, 26 volunteered to join the program and
fifteen were admitted. Three others participated in a "pre-pilot" exercise.
The NJ DEP offers incentives to encourage participation, such as consolidated review of
permit applications, reduced paperwork requirements, and the elimination of the need to obtain prior
state approval of certain kinds of process changes that would otherwise require case-by-case air
program review. However, the state will not waive applicable single-medium permit limitations.
The Program's Early Accomplishments
New Jersey's FWP program has made considerable progress. In December 1994, the NJ DEP
issued its first-ever multimedia permit to a pharmaceutical manufacturing facility in Kenilworth, NJ,
owned by the Schering-Plough Corporation. Since that time, seven more facility-wide permits have
been issued, and another eight are in progress.
As of April 22, 1997, the following New Jersey facilities have been issued facility-wide
permits:
Schering-Plough (Kenilworth)
Frigidaire (Edison)
Huntsman Polypropylene (West Deptford)
Tekni-Plex (formerly Hargro) (Flemington)
Bond Adhesive (Newark)
Fisher Scientific (Bridgewater)
Fabricolor (Paterson)
Geon (Pedricktown)
How a Facility-wide Permit is Structured
Each facility-wide permit is comprised of five major sections:
> A process-level section which sets forth the enforceable limitations that apply to specific
production processes within the plant. Air emissions are controlled by setting process-level caps (in
tons/year) for particular categories of pollutants. Discharges to surface water are controlled through
tons/year limits applied to on-site wastewater pretreatment processes. This section of the permit also
includes Ibs/hour limits on air emissions from groups of sources (pieces of equipment). These limits
address "worst-case" situations.
+ A facility-level section which summarizes the permit limitations that apply to the facility as
a whole. These represent the sum of the individual process-level limits and accordingly are
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expressed in tons/year. Also in this section are a recitation of standard permit provisions and, in
some cases, a summary of water discharge limits.
4 A compliance plan which lists the regulatory requirements which constitute the legal basis
for the permit limits. In addition, the compliance plan may set forth "operational" limits, which are
sometimes used as a surrogate for emissions limits. Performance standards, applicable to specific
kinds of equipment, are the most common form of operational limit. The compliance plan also
specifies monitoring, reporting and recordkeeping requirements.
4 An administrative section which presents a description of the facility's operations, including
a process flow diagram, and a list of equipment and control devices, materials used and released, and
the locations at which emissions occur.
4 A fact sheet which summarizes basic information about the facility and its processes. Some
facility-wide permits also include a "special conditions" section.
Figure 2 illustrates how a facility-wide permit (issued to a Schering-Plough Corporation
facility) is organized by individual production processes. Figure 3 displays a flow diagram for one
of these processes. Attachment A to this report presents more extensive excerpts from a facility-
wide permit (issued to a Huntsman Polypropylene facility).
A Closer Look at Key Program Features
New Jersey's program has several distinctive features that warrant closer examination:
4 Statutory Foundation
As mentioned previously, New Jersey's FWP program was created by the state legislature
in enacting the Pollution Prevention Act of 1991. The law sets forth specific targets and deadlines
for achieving program goals. With this foundation in place, the FWP program has gained
considerable visibility and significant institutional and political backing.
4 Linkage with Pollution Prevention
The facility-wide permitting program is closely linked with broader initiatives to encourage
pollution prevention. Before a facility-wide permit can be issued, a facility must comply with the
state's pollution prevention planning regulations. These require covered manufacturing facilities to
prepare a multimedia pollution prevention plan, focusing on individual production processes, that
analyzes the facility's use of toxic materials and sets out action steps for reducing their use and
generation (as nonproduct output). If the facility is participating in the FWP program, the completed
pollution prevention plan is made part of the facility-wide permit.
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f Process-Level Focus
Facility-wide permits are structured around individual production processes, whereas single-
medium permits generally focus on controlling impacts from specific pieces of equipment.
New Jersey had several reasons for selecting a process-level focus for the program. Process-
level standards provide greater flexibility to introduce process changes that may yield better
environmental results at lower cost. In addition, it was hoped that a process-level focus would reveal
pollution prevention opportunities at critical points in a facility's manufacturing operation, and
provide a nexus between facility-level water regulations and source-level air regulations.
New Jersey's program includes the authority to set air emissions caps for individual
production processes. These caps allow a facility to make certain types of operational changes
without case-specific NJDEP approval so long as the changes do not result in higher multimedia
releases or higher nonproduct output per unit of product (or conflict with other applicable
requirements). In addition, a facility must conduct a multimedia pollution prevention assessment
if the process is not covered by the facility's pollution prevention plan.
4 The Role of Input-Output Data
The New Jersey Pollution Prevention Act requires all facilities that are subject to the law's
pollution prevention planning requirements to include, with their plans, estimates of the amount of
each hazardous substance in starting and ending inventories, and the amounts used/consumed
through chemical reactions, generated as nonproduct output, recycled out of process, transferred off
site, incorporated into product, or released to the environment. These estimates are required for each
production process and for the facility as a whole.
These quantities, often referred to as materials accounting (or input-output) data, are
integral to a facility's pollution prevention plan and play an equally important role in facility-wide
permitting. With the aid of input-output data, a facility manager can trace the path of each hazardous
substance from the point at which it is brought on site to the point at which it leaves the plant as
product or nonproduct output.
H
In addition, materials accounting enables a facility to quantify the amount of each hazardous
substance that enters via any particular pathway. This makes it possible to compare multiple sources
of data in order to gain a more complete and accurate picture of materials flow within a facility. For
example, input-output data can be compared with Toxics Release Inventory (TRI) or permit
monitoring data as a cross-check on accuracy.
Arizona
The Arizona Department of Environmental Quality (ADEQ) and U.S. EPA have signed a
final project agreement with the Intel Corporation that provides for the development of a five-year
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FIGURE 2
Schering-Plough Corporation,
Facility- Wide Permit Outline and List
Kenilworth, NJ
of Production Process
Page Number
I.
II.
III.
IV.
V.
VI.
VII.
VIII.
«
Outline
Permit Page
Fact Sheet
Facility Summary Table 1
General Conditions
List of Previous APC permits
Stormwater PPP Requirements
Process Packages:
' Process A (Tablet Manufacturing)
> Process B (Tablet Coating)
Process C (Aerosol Manufacturing)
Process D (Freon Recovery)
Process E (K2 Quality Control)
Process F (K2 LOG)
Process G (Equalization Tank)
Process H (Tube Crimping)
Process I (Carpenter Shop)
Process J (Weld Shop)
Process K (Gasoline UST)
Process L (Wastewater Air Stripper)
Process M (Paint Spray Booth)
Process N (K2 Pilot Plant)
Process O (Kll Pilot Plant)
Process P (Emergency Generators)
Process Q (Boilers)
Itoll
12
Ito6
Attachment A
Attachment B-D
Al to A97
Bl toB45
Cl to C24
Dl toD26
El to E32
Fl to F32
Gl to G29
HI to H20
11 to 11 7
Jl to J17
Kl to K16
LI to L23
Ml to M22
Nl to N44
Ol toO21
PI to P26
Ql to Q21
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FIGURE 3
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"environmental master plan" for the company's new facility in Chandler, AZ, just outside Phoenix.
The "FAB 12" facility will manufacture computer chips and ancillary semiconductors. This project
is being implemented as part of EPA's Project XL initiative, which is designed to test innovative
policy approaches that could provide greater flexibility while achieving superior environmental
results. Project XL is one of 25 projects that make up the President's Regulatory Reinvention
Initiative (see page 1).
The final project agreement consolidates all major environmental commitments being made
by the company. The agreement includes, as attachments, individual permits covering air emissions,
water use and discharge, and solid/hazardous waste generation, recycling and disposal. However,
the agreement is not structured as a single permit that encompasses all media.
Intel is developing an innovative reporting system that will allow environmental data for all
media to be made publicly available in an integrated format. This reporting system will include
information that is required by law or regulation (e.g., TRI data) together with data to be provided
voluntarily. Attachment B to this report contains a copy of the full Intel reporting format (data are
fictitious do not quote or cite).
Key features of the Intel agreement include:
+ Plant site emissions limits that will allow the company to satisfy air emissions requirements
by meeting a single, plant wide limit on particular categories of emissions. In addition, Intel will
have preapproval to make specified process and equipment changes as long as the plant site limits
are not exceeded.
4 Voluntary goals for minimizing water consumption; recycling the facility's treated
manufacturing effluent for reuse or reinjection to groundwater, and minimizing water consumption
by purchasing treated water from the city of Chandler for use in cooling towers and landscaping.
Intel is also committing to increase its recycling of solid waste, hazardous waste and non-hazardous
chemical waste.
+ An integrated emergency response plan for preventing, preparing for, and responding to
accidental spills and releases. This plan will satisfy all federal, state and local emergency response
requirements.
4 Provisions to incorporate the company's Design for the Environment Program, which
focuses on identifying process and product improvements that are beneficial to the environment.
Intel has applied this concept successfully at some of its other facilities.
* Provisions for Other Environmental Benefit Activities, such as an employee trip reduction
program, environmental education activities, and an agreement to exceed the city's minimum
setback requirement as a buffer for nearby residential property.
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Massachusetts
Massachusetts is experimenting with an innovative multimedia approach that is designed to
help small companies achieve compliance with environmental requirements. The "Printers
Partnership Program," launched in 1994 by the State Department of Environmental Protection
(DEP), allows small-to-medium size printing companies to file a multimedia self-certification
statement in order to demonstrate compliance. This single document takes the place of multiple
single-medium permits and approvals. The statement also provides information on pollution
prevention opportunities.
The DEP offers a range of incentives for printers to join the program. By self-certifying,
printers avoid the sometimes lengthy and cumbersome process of obtaining multiple permits. In
addition, participating companies are granted a "safe harbor" for past violations and a temporary
grace period for reaching full compliance. Lower application fees act as a further incentive.
The self-certification statement is designed to be comprehensive in scope yet straightforward
and easy to use. The form is structured as a series of numbered statements, organized by facility
operation, that allow the user to check "Yes," "No," or "Not applicable." Each statement relates
either to a specific compliance requirement or to a voluntary opportunity that may be of interest to
the company, such as a new technology or process change that could prevent pollution or save
money. A copy of the self-certification statement is found in Attachment C to this report.
The state expects this partnership to be far less resource-intensive than full-scale permitting.
To ensure that compliance requirements are met, the DEP each year will conduct multimedia
inspections at a certain number of facilities chosen by random selection. The DEP has released a
guidance document on the self-certification process, the "Massachusetts Printers Partnership
Workbook - a Self-Certification Guide for Commercial Printers," published Winter 1996.
Other States
There are a number of other states that have begun to explore multimedia permitting options.
This section briefly summarizes what each of these states is doing.
+ Delaware
Delaware's Department of Natural Resources and Environmental Control (DNREC) is
working with Camdel Metals, Inc., a metal fabrication company, to develop a framework for
multimedia environmental management at its facility in Camden. The framework will provide for
multimedia inspections, consolidated reporting, and pollution prevention assessments. In addition,
there are plans to develop a permit summary sheet that will present all permit limits, schedules, and
monitoring and reporting requirements in a simple and concise manner.
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The state had initially selected Camdel to take part in a pilot project to develop a model
multimedia permit. However, these plans have been deferred pending resolution of Title V issues
and development of a consolidated reporting format. The facility has recently concluded a voluntary
pollution prevention and waste reduction assessment, and hopes to use the findings in identifying
P2 measures.
+ Florida
The State of Florida, the South Florida Water Management District, and the U.S. EPA have
signed a final project agreement with the Jack M. Berry company, a citrus juice processor,
to develop a "comprehensive operating permit" that will consolidate all of the facility's operating and
regulatory permits into a single document. This project, like Arizona's, is being implemented
through EPA's Project XL (see page 9).
Under the final project agreement, Berry is committed to achieving a level of environmental
performance that exceeds regulatory requirements and to adopting specific measures to foster
pollution prevention and waste reduction. In particular, the company has agreed to begin using less
toxic solvents; make process changes to reduce VOC emissions; increase recycling of metal, paper,
glas's and plastic; and conserve water through the reuse of treated industrial wastewater. Annual
progress reports will be made available to the public.
The state is making incentives available to the company that will provide regulatory and
administrative flexibility. For example, there will be an accelerated process for permit application
and renewal, which is expected to reduce costs.
+ New York
New York has a pilot project underway to explore avenues to multimedia integration at a
major industrial facility. In September 1995, the New York State Department of Environmental
Conservation (NYSDEC) entered into a consent agreement with the General Electric Silicones
Company to develop a report to evaluate the merits and feasibility of promoting pollution
prevention through an integrated facility permit process and related ways to streamline the permitting
process. In December 1996, G.E. Silicones completed the final report which is based on the analyses
.of a variety of issues arising from an investigation into how the concepts of multimedia permitting,
facility-wide permitting and pollution prevention can or should be coordinated.
The report suggests that it may not be prudent to invest resources to develop a multimedia
permit for a large facility such as the size and complexity of G.E. Silicones because the permitting
process can be burdensome and time consuming. In the absence of true regulatory reform,
multimedia or facility-wide permits may simply be the consolidation of single individual permits,'
11
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with no other real benefits. These permits may be better suited for smaller facilities. Any
multimedia program should have well defined and measurable goals as to how the program will
improve on existing programs. NYSDEC believes that consideration for starting a new multimedia
program should be done only after a detailed review of the successes and failures of other similar
state and federal multimedia initiatives.
4 Washington
The Washington Department of Ecology has completed the final Multimedia Project report
in January 1997 as mandated by state law, to evaluate options for multimedia integration, including
the development of multimedia operating permits for regulated facilities.
In this study, the department looked at the feasibility of developing multimedia operating
permits for three industrial facilities that had volunteered for the project. The report findings
suggest that multimedia permitting faces significant barriers including restrictive federal and state
regulations, difficulty in coordinating permit issuance and renewal across media, insufficient
funding, and concern over the legality of relaxing certain permit requirements. In general, facilities
expressed greater interest in consolidating permit requirements within media than in developing a
multimedia operating agreement.
Figure 4 summarizes some of the key features of the various state approaches to multimedia
environmental permitting with a focus on pollution prevention.
12
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III. PROJECT FINDINGS
This section presents initial findings from the M2P2 Project, organized into five areas:
environmental results, benefits and costs, pollution prevention, incentives, and issues and barriers.
For each of these areas, the report lays out general conclusions and observations, followed by
information relating to individual states. These findings should be considered preliminary, as the
state pilot projects are at varying stages of completion.
Environmental Results
The initial data from the state M2P2 projects are not yet conclusive as to whether multimedia
permitting will lead to improved environmental results. This can be attributed, in part, to the fact
that state efforts are still at an early stage of development and implementation. After states have
issued a larger number of permits and examined permit monitoring data, a more definitive answer
may be possible.
There are early indications, however, that some of the multimedia permitting efforts may
have a positive effect on environmental results. In New Jersey's case, it appears that facility-wide
permitting helped ensure that facilities would perform a materials accounting (input-output) analysis,
which was instrumental in identifying opportunities for reducing emissions (see New Jersey, below)!
And in a broader sense, pollution prevention clearly benefits from the close linkage with operational
flexibility and cross-media integration which are integral features of multimedia permitting.
It is not yet clear whether the projects had a strong or direct influence on permit limits. In
some cases, the emissions limits set forth in the new multimedia permits are more stringent than the
previous single-medium permit limits, but in other cases the opposite is true. New Jersey's
experience is that large increases in allowable emissions levels tend to reflect the incorporation of
previously unpermitted or unregulated emissions into the permit limits. It is possible that emissions
per unit of product will decrease as a result of efficiencies made possible by multimedia permitting,
but it is too early to tell for certain.
A state-by-state analysis follows:
New Jersey
The focus of New Jersey's facility-wide permitting (FWP) program is on the development
of facility-level and process-level emissions limits that are designed to promote pollution prevention.
Each facility-wide permit includes emissions limits for regulated air pollutants such as volatile
organic compounds (VOCs), criteria air pollutants, and hazardous air pollutants (HAPs). Some
13
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permits also contain limits on water discharges and hazardous waste, especially in cases where the
facility had previously been issued a single-medium permit covering the relevant category of
discharges.
The new facility-level emissions limits can be compared to the corresponding "potential to
emit" levels from the single-medium permits they replaced (this involves aggregating the previous
source-level emissions limits to obtain a facility-level "potential to emit"). Looking at the first eight
facilities that received facility-wide permits, it becomes clear that many, if not most, of the facility-
level limitations showed significant change, but the direction and magnitude of change varied
widely. With respect to individual air pollutants, allowable emissions levels became more stringent
(decreased) in about as many cases as such levels were relaxed (increased).
Some of the changes were quite substantial; for example, the limit on sulfur oxide emissions
at one facility declined from about 64.2 tons/year to 0.307 tons/year while the limit on VOC
emissions at the same facility climbed from 9.73 tons/year to 59.5 tons/year. According to the NJ
DEP, increases that are especially large (in percentage terms) often resulted from the discovery of
unpermitted emissions that had to be factored into the new permit limits. Large decreases often
reflected a determination by the state that allowable emissions levels (based on "potential to emit")
had previously been much higher than the actual level of releases.
It seems premature, at this time, to draw any firm conclusions about the effect of facility-
wide permitting on permit limits or actual emissions. However, there is. evidence that the use of
materials accounting (input-output analysis) did produce improved environmental results in a
number of cases. Materials accounting is a method of estimating the quantity of a particular
chemical or substance that enters or leaves any particular pathway in a facility's manufacturing
processes.
As explained previously, all facilities enrolled in the FWP program conducted a thorough
materials accounting analysis in conjunction with the development of their permit limits. Using this
analysis, some facilities were able to identify ways of achieving significant emissions reductions.
One facility, for example, identified significant unpermitted emissions, previously classified as
fugitive emissions, of the toxic chemical Trichloroethylene (TCE). The company is planning to
install an ECOVAC deoiling system which will eliminate any need to use TCE in the relevant
production process.
Most of the M2P2 facilities did not require permits to control discharges to surface water,
or needed such permits only for a few production processes. New Jersey believes that the next group
of permits under the FWP is expected to include a higher number of facilities that are subject to
water permits.
Although facility-wide permits can be applied to RCRA hazardous waste management, only
one facility (Huntsman) required a transport, storage or disposal permit, and a few were subject to
generator (non-permit) requirements.
14
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Arizona
Arizona is participating in the M2P2 Project through EPA's Project XL. The Arizona project
focuses on a new facility, owned by the Intel Corporation, that produces computer chips The final
XL project agreement provide for the consolidation of all single-medium permits previously issued
to the facility into one "environmental master plan." The agreement that governs the air permit
establishes facility-wide air emissions caps ("plant site emissions limits" or "PSELs") on emissions
of total VOCs, total organic HAPs, total inorganic HAPs, NOx, CO, PM10, SO2, phosphine and
sulfunc acid.
Intel is allowed to raise its VOC limits from 25 tons per year (the sum of the facility's source-
level VOC limits) to a facility-wide limit of 40 tons/year. HAP limits also are set at a higher level,
while limits on criteria air pollutants and particulates are tightened. The increases in VOC and HAP
limits reflect several factors: a previous overestimation of the removal efficiency of the applicable
control technology, a projected expansion of the plant's production capacity, increased use of
methanol, and a shift from regulating emissions of specific HAPs (which in the aggregate total 25
tons/year) to setting limits on total emissions of organic HAPs and total emissions of inorganic
HAPs. Actual emissions data are not available at this time, because the Intel-Chandler facility has
been in operation only one year.
Intel also has agreed to observe a voluntary cap, currently under development on the
facility's emissions per unit of product. However, in the absence of baseline emissions data, it is
unlikely that the effect of the new permit on emissions per unit of product can be determined'with
any real accuracy.
In addition, Intel will purchase treated effluent for use in cooling towers and landscapin^
from the City's wastewater treatment plant to avoid drawing from the aquifer that supplies water to
the City. Effluent from the facility will be treated to comply with drinking water standards at the
Chandler Reverse Osmosis (RO) facility. The City then has the option to reuse the wastewater or
remject it into the groundwater.
Massachusetts
The Massachusetts Department of Environmental Protection is working on a preliminary
evaluation of its Printers Partnership Program (described in Section H of this report) The evaluation
will include a comparison of facilities participating in the program with facilities not participating
using random samples of each group. Comparable data from the period before program'
implementation will also be examined. °
The evaluation will utilize information on key performance indicators (including compliance-
related items), obtained through inspections at randomly selected printing facilities, using a standard
inspection protocol. The performance indicators include measures relating to compliance pollution
prevention and recycling, best management practices, and sources of information and assistance
15
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Results of the evaluation are expected to be available later in 1997. Early indications suggest
that there may be significant differences between participating and nonparticipating printers with
respect to a number of indicators. Self-certifiers appear to have scored approximately 50% higher,
as a group, on a composite index of environmentally sound business practices. Differences may also
emerge in comparing the "pre-program" cohort with the "participants" and "nonparticipants" groups.
Other Benefits and Costs of Multimedia Permitting
All states involved in the M2P2 Project have tentatively identified a number of benefits and
costs associated with multimedia permitting. Since most of the state M2P2 efforts are at an early
stage of development, the information available on benefits and costs is largely qualitative. States
expect to have quantitative data within the next year or so.
The two benefits cited most frequently by the states are streamlining and operational
flexibility. New Jersey and Arizona envision consolidation of multiple existing permits into a single
multimedia permit. This will simplify the permitting process while making permits easier to
understand and comply with. In a similar vein, Massachusetts is planning to replace a complicated
set of permitting requirements, applicable to small printers, with a single multimedia self-
certification form.
The gains in operational flexibility result from the use of facility-wide or process-specific
emissions caps lieu of having separate air emissions limits for individual pieces of equipment or
separate water discharge limits to individual outfalls. As long as the facility stays within the overall
emissions caps, it is generally free to make minor operational changes without going through a
lengthy pre-approval process. The expected time savings are of critical importance to facilities in
advanced technology sectors, as they must respond to rapidly changing market conditions on very
short notice.
States and facilities also expect that multimedia permitting will lead to cost savings over the
long term. However, there is some concern that the high costs incurred in moving from single-
medium to multimedia permitting may discourage companies and state environmental agencies from
making the requisite administrative changes - such as restructuring programs, reonentmg budgets,
providing new training and informational materials, and merging computer databases. All of these
changes involve significant resource commitments.
New Jersey
New Jersey's pilot program on facility-wide permitting (FWP) has produced impressive
results in terms of permit consolidation and streamlining. Through the program, some facilities have
been able to replace a large number of single-medium permits with just one multimedia permit,
16
.
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thereby improving clarity and efficiency.
As an illustration, the Schering-Plough Corporation facility in Kenilworth, NJ, succeeded
in integrating nearly 100 individual permits, covering more than 800 sources of air emissions (and
two outfalls to surface water), into a single facility-wide permit. These gains in efficiency are
expected to produce significantly lower costs. Figure 5 lists all of the air permits that were replaced
by the single multimedia permit and Figure 6 further illustrates this consolidation.
New Jersey considers materials accounting to be the driving force behind many of the
program's early accomplishments. The section on Environmental Results, above, describes how
materials accounting contributed to emissions reductions. The state also believes that the use of
input-output analysis produced these additional benefits:
+ Materials accounting appears to have aided facilities in reducing emissions of hazardous
substances that are not covered by the State Pollution Prevention Act. The NJ DEP offered
incentives, through the FWP program, for including non-TRI chemicals in the input-output analysis
(such as additional time to complete the pollution prevention plan). In some cases, this revealed
opportunities for cost-effective process changes.
In addition, facilities used input-output data to cross-check the estimated quantities of
individual chemicals used by the facility with actual emissions levels, derived from permit
monitoring data. Sometimes this enabled the facility to identify unpermitted emissions that should
have been factored into its permit limits. These limits could then be adjusted to more accurately
reflect actual and potential conditions.
+ Materials accounting may help to provide a framework for development of a consolidated
multimedia reporting system, and a multimedia baseline for measuring progress toward pollution
prevention and emissions reduction goals.
+ The state found materials accounting data helpful in identifying cross-media transfers of
pollutants and in forming a more holistic view of the environmental risk and impact posed by a
facility's emissions.
New Jersey's facility-wide permitting exercise also entailed a number of costs Most
importantly, the pilot program required a substantial up-front commitment of resources by the state
and participating facilities. The materials accounting process was especially resource-intensive
requiring a careful examination of each facility's manufacturing process and use of hazardous
substances. Since most facilities had not previously completed a materials accounting analysis
(though required by state law), it often was necessary to "start from scratch" to analyze the flow of
materials at a facility.
Other constraints include the need to define and maintain controls on the release of
confidential information (discussed below under "Key Issues and Barriers"), and the need to develop
17
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incentives for companies to devote sufficient resources to facility-wide permitting (discussed below
under "Incentives to Encourage Multimedia Permitting").
Arizona
The Arizona Department of Environmental Quality (AZ DEQ) expects significant benefits
from the Intel permitting exercise:
+ The operational flexibility provided by the Intel permit will help the facility respond to short
product cycles, changing manufacturing demands, and rapid product obsolescence -- features
characteristic of high technology industries.
4 A consolidated and simplified permit is expected to save resources by reducing operating
costs, lessening liability exposure, and freeing staff time.
On the other hand, Arizona recognizes that the transition to multimedia permitting is likely
to require a substantial commitment of resources. The state may have to reallocate funds, reorganize
programs, retrain workers, develop new permitting guidelines and documents, and merge computer
databases; the company may have to make parallel administrative changes. However, the cost of
these activities is likely to taper off as experience is gained with multimedia management.
Massachusetts
As explained previously, the Massachusetts Department of Environmental Protection (DEP)
is working on a preliminary evaluation of the Printers Partnership Program (see page 10). There are
early indications that participating firms may have "outperformed" nonparticipants on certain
indicators of program or environmental performance. Final results should be available sometime
during 1997.
It is clear, even at this early stage, that the self-certification program has helped to streamline
the process that printers must go through to demonstrate that they are meeting environmental
standards. Preliminary estimates suggest that about 40% of the firms involved in the Printers.
Partnership Program had not previously registered with, or been permitted by, the MA DEP.
Multimedia Permitting and Pollution Prevention
Pollution prevention is the major focus of the New Jersey and Massachusetts M2P2 programs
and is addressed, as well, in other state projects. States are generally optimistic that multimedia
permitting can provide a boost to pollution prevention, especially if incentives for source reduction
are included. The M2P2 programs are so new, however, that it is difficult to show that multimedia
18
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FIGURES
SCHERING-PLOUGH roRPORATTrw. KFNTT WORTH FAPTT TTV
Process-
K-2 Aerosol Manufacture
K-10 Tablet Manufacture
K-2 Tablet Coating
K-2 Pilot Plant
K-ll Pilot Plant
K-2 Quality Assurance Inspection
K-2 LOG
Equalization Tank
Maintenance Spray Booth
Plastic Tube Crimping Operation
Maintenance Carpenter Shop
Maintenance Weld Shop
Gasoline Tank
KGEN-01
KGEN-07
K-6 Emergency Generator
K-ll Emergency Generator
135 KW Generator
100 KW Generator
200 KW Generator
125 KW Generator
Boiler #3
Boiler #4
Boiler #5
DDF Generator #1
DDF Generator #2
DDF Generator #3
Air Stripper
31st Street Generator
B-20 Emergency Generator
Freon Recovery System
Air Certificate (#s) Replaced hy Farilify-M/Mg._P.g.nmt:
103226, 110776, 111258, 112811, 112812
113230, 104398, 104399, 104400, 104401 104402
104403, 104409, 104410, 104411. 104412 104414'
104416, 104654. 105390. 105499. 106435. 111824! I I 1825.
104395, 104396, 104397. 104406, 104417. 104657 110779
110819, 110820.
LOG #'s 01924066, 112636,01924075. 110643. 110644
110645, 110646, 110778, 110780. 111125. 111126. 111672
107320, 110562, 110563, 110773, 110774. 110775, 088930
060773, 060774, 060775. Log # 113039. 112097
110777
063225
066765
107668
077897
062984, 077898
083584
087323
087321
099680
074235
106432
106429
105434
105436
066488
066489
066371
093110
093107
093109
114270
108382
112098
114836, 115135. 115136
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FIGURE 6
Photograph illustrating results of permit consolidation at Schering-Plough's
Kenilworth facility. Integrated permit is being held while permits it replaces
are shown in file cabinets. (Photograph courtesy of Schering-Plough
Corporation and Nat Clymer, photographer. Used by permission.)
-------
permitting has had a direct impact on pollution prevention.
New Jersey
New Jersey's facility-wide permitting program appears to have facilitated pollution
prevention by encouraging participating facilities to conduct pollution prevention planning (as
required by the State Pollution Prevention Act) in a sound and thorough manner. However, it may
not be possible to distinguish the effects of facility-wide permitting as such from those of pollution
prevention planning.
Some New Jersey facilities were particularly successful in identifying pollution prevention
measures that proved feasible and cost-effective. For example, the Schering-Plough Corporation's
Kenilworth facility was able to reduce its freon use by 140,000 pounds annually and eliminate use
of the toxic chemical 1,1,1-trichloroethane in label making. Frigidaire's Edison facility plans to
replace its trichloroethane (TCE) degreaser with a less polluting ECOVAC system, which will
reduce nonproduct output of TCE by 88,000 pounds annually. The Huntsman polypropylene plant
in Woodbury, NJ, expects to reduce its use of hazardous chemicals by 3.5 million Ibs/year as part
of a planned modernization.
According to the NJ DEP, these achievements resulted from the use of materials accounting
(input-output) analysis as an element of pollution prevention planning and facility-wide permitting.
Input-output analysis enabled the facilities to identify specific areas within their production
processes where hazardous substances were being generated and possibly released, and this, in turn,
revealed opportunities for preventing pollution. Thus, facility-wide permitting helped facilitate
pollution prevention by ensuring productive use of planning and materials accounting.
Arizona
The environmental master plan for the Intel-Chandler plant includes a number of innovative
provisions for recycling and reuse of the facility's waste material. For example, under the agreement,
the City of Chandler has the option of reusing Intel's treated wastewater or reinjecting it to
groundwater; either approach would conserve scarce water supplies. Intel will use treated effluent
from the City's wastewater treatment plant for cooling towers and landscaping, instead of purchasing
municipal water.
The agreement does not include specific measures to prevent pollution at its source.
However, Intel has agreed to incorporate its Design for the Environment Program into the
environmental management system. The company is committed to developing environmentally
sound products and processes, for each new generation of technology, through continuous
improvement approaches.
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Massachusetts
The Printers Partnership Program places a high degree of emphasis on promoting voluntary,
practical and low-cost pollution prevention measures. In addition to compliance-related material,
the self-certification form includes many suggestions on actions that printers can take to reduce their
use and release of hazardous substances (the full self-certification form is attached to this report).
The program's effect on pollution prevention will be addressed in the DEP's program evaluation,
ongoing as of this writing.
It is interesting to note that the printing industry in Massachusetts has shifted significantly
in the past decade to the use of alcohol-free fountain solution and less VOC-laden press washes. A
number of printers have indicated that they were motivated to make these changes partly as a result
of their participation in the Printers Partnership Program.
Incentives Used in M2P2 Programs/Projects
States offered a variety of incentives to encourage facilities to become involved in M2P2
efforts. The most common approach was to offer greater operational flexibility, in the form of
facility- or process-level emissions caps and pre-approval of minor process changes that would not
cause exceedances.
Other incentives used by one or more states include:
4 Safe harbor for past noncompliance (Massachusetts)
+ Limited enforcement amnesty for information voluntarily disclosed during development of
a multimedia permit (New Jersey)
+ The expectation of future cost savings (most states)
4 Consolidation of permits and permits applications (most states)
Most of these incentives appear to have been favorably received by companies interested in
the M2P2 projects. However, there is little information on the incentives' effectiveness, because the
M2P2 programs are so new. The states do have some preliminary information and observations:
New Jersey
New Jersey's experience illustrates the critical role that incentives play in pilot projects on
multimedia permitting. In developing facility-wide permits, facilities have to compile extensive data
on their inputs and outputs of potentially hazardous substances. This information is analyzed in
20
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comparison to permit limits and compliance data as part of the required materials accounting
analysis (see page 8). Given the amount of work this can involve, companies may hesitate to make
a full commitment to a pilot program unless they are assured of concrete benefits.
Recognizing this, the NJ DEP offered incentives to encourage facilities to take part in the
FWP program and observe program requirements:
+ To encourage disclosure of data, the NJ DEP granted a partial enforcement amnesty to
facilities that enrolled in the program. The state announced that, generally, it would not issue
penalties for any violations identified through voluntary disclosure of information during the
development of a FWP. The amnesty did not apply to violations discovered after issuance of a
facility-wide permit.
4 Emissions caps were applied at the production process level instead of at specific emissions
units or outfalls. This gave the facilities more latitude in selecting the approach they would take to
achieve compliance and other environmental goals.
4 Facilities were offered a consolidated permit application procedure and form, partial relief
from having to obtain pre-approval of minor plant modifications, and a single point of contact within
the NJ DEP for all permit-related matters.
Arizona
The final project agreement for the Intel XL project allows flexibility for the company to
make minor changes in its construction, equipment and production processes without a formal
permit modification, as long as the facility-wide (plant site) emissions limits are not exceeded. In
this respect, the Intel agreement parallels the flexible emissions caps developed by New Jersey.
Also, Intel's monitoring, recordkeeping and reporting burden will be eased through the
integration of most reporting requirements into annual and quarterly progress reports, covering all
media. Each quarterly report will present several types of information (at the facility level only):
4 Emissions data for specific categories of air pollutants (total VOCs, total organic HAPs, total
inorganic HAPs, NOx, CO, sulfur dioxide, PM10);
4 The percentage of the facility's waste, by category, that is recycled or reused (% of solid
waste, hazardous waste, non-hazardous chemical waste, city water, wastewater);
+ Reported permit limit exceedances for air emissions and wastewater discharges;
+ Yes/no responses to a number of specific questions (e.g., whether facility has been inspected
during the quarter, whether there were any shutdowns, whether there were any changes to emissions
21
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factors, etc.).
The annual progress report will present yearly totals for emissions and recycling/reuse data,
as well as Toxics Release Inventory (TRT) data and a description of other activities at the facility that
benefit the environment. Attachment B to this report presents excerpts from the final project
agreement that describe and illustrate the reporting format.
Massachusetts
The Printers Partnership Program is designed to function as a more efficient, "one-stop,"
alternative to conventional permitting. This, in itself, is likely to act as a strong incentive for
program enrollment, as it creates a potential opportunity to achieve long-term cost savings and
reductions in liability exposure.
In addition, Massachusetts offered several specific incentives, during the first phase of the
pilot program, to encourage companies to participate. These are outlined in the "Massachusetts
Printers Partnership Workbook," Winter 1996, pages 3-4:
+ Companies that joined the Printers Partnership received a "safe harbor" for past
noncompliance. This was particularly beneficial to small printers, which were less likely to have
obtained all required permits or followed all applicable regulations "to the letter."
The "safe harbor" incentive was coupled with a disincentive that applied to companies not
joining the program. Nonparticipating companies were placed on a priority list for inspection by the
State Department of Environmental Protection. Companies discovered to be out of compliance were
more likely to face enforcement action, which could include penalties for past, as well as current,
noncompliance.
* The state offered reduced fees as a further incentive to participate. Companies that joined
the program before June 30, 1996, paid fees ranging from 0-$500, based on the number of people
they employed. This fee replaced all DEP permits and compliance fees for the period July 1,1996
through June 30, 1997. Nonparticipants would have paid up to $1,000 for permits (not counting
consultants' fees) and up to $500 annually in compliance fees. The MA DEP reserved the option
of waiving the partnership fees for firms that would not otherwise have been required to obtain any
DEP permits or pay an annual compliance fee.
Issues/Barriers to M2P2 Permitting
There are several issues of concern to most M2P2 states: (1) the need to ensure consistency
with single-medium statutory and regulatory requirements (especially Clean Air Act Title V
requirements); (2) lack of agreement as to whether multimedia permitting will achieve superior
22
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environmental results (a matter of particular concern to Project XL states); (3) inconsistencies among
air, water, and hazardous waste permitting requirements; and (4) the resource commitments involved
in the transition to multimedia permitting. Some states have also expressed concern about issues that
reflect state-specific circumstances.
New Jersey
New Jersey has encountered a number of significant issues and barriers in developing its pilot
program on facility-wide permitting:
4 Under the NJ program, a facility-wide permit must satisfy, or provide substantial equivalency
with, the same federal permitting requirements that apply to single-medium permits. However, New
Jersey had initially experienced difficulty in gaining federal approval to "count" a facility-wide
permit as the functional equivalent of a permit issued under Title V of the Clean Air Act. Region
2 in cooperation with NJ DEP has agreed to review and comment on all remaining FWP as to their
acceptability as Title V permits.
+ Confidentiality was another significant issue. In the FWP program, a facility's pollution
prevention plan also serves as a key element of its multimedia permit. Since the public generally
has greater access to the facility-wide permit than to the pollution prevention plan, some companies
expressed concern that participation in the FWP program might lead to the disclosure of sensitive
or even proprietary information to competitors.
The state chose to address this issue by allowing each facility to decide which material it
considered confidential. Some facilities were willing to submit their entire pollution prevention plan
to the NJ DEP. Other facilities preferred to keep their plan on site. In the latter case, the NJ DEP
conducted its review of the plan at the facility.
4 Another issue was the tendency of some facilities to define their production processes in a
broad and general manner for use in materials accounting, pollution prevention planning, and
facility-wide permitting. From a facility's perspective, this practice has the advantage of minimizing
the number of production processes for which it is required to report data. On the other hand, the
materials accounting analysis could be less useful to the facility in identifying opportunities for
emissions reduction.
Arizona
During the development of the final project agreement, the Arizona DEQ identified a number
of legal and regulatory issues that need to be resolved. For example:
4 To reduce handling costs, the company wishes to send chemical wastes directly to a chemical
manufacturer for recycling, instead of shipping it first to a recycling facility. However, since federal
23
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regulations restrict the recycling of hazardous wastes without a direct piping connection, Intel may
need to have its waste reclassified.
4 The company sought approval from the City of Chandler to discharge stormwater, after
testing them, in order to facilitate reuse, but the City denied the request due to capacity constraints.
In addition, the Intel project faces many of the same issues that other M2P2 states have
grappled with, such as Clean Air Act Title V equivalency and the need for a substantial up-front
commitment of resources.
Massachusetts
The Massachusetts Printers Partnership Program focuses on small to midsize printing firms-,
which may lack sufficient resources to obtain expert advice on environmental compliance matters.
For this reason, it was essential that the self-certification process be readily accessible and
understandable to small companies, while at the same time comprehensive in scope and effective
in promoting full compliance.
The state recognized the time and resource constraints faced by this sector of the regulated
community and designed the self-certification requirements with flexibility in mind. These are some
of the approaches taken:
f The requirements for calculating and reporting VOC emissions were "tiered" according to
the volume of VOC-laden press washes that were used by the printing operation. Small printers,
those purchasing/using less than one ton/year, were made exempt. Midsize printers, those
purchasing/using 275-3000 gallons/year, were required to calculate VOCs only for press/screen
cleaning solvents. All others were required to calculate VOC emissions associated with inks,
cleaning solutions and fountain solution.
+ Small alcohol users (for fountain solution) were exempted from alcohol content limitations
and from associated recordkeeping requirements. Alcohol is a VOC precursor.
4 The state concluded that daily recordkeeping would be too time-consuming for most printers.
Accordingly, the MA DEP decided to require monthly recordkeeping for midsize and large printing
firms and to require weekly averaging for presses that use alcohol in fountain solution.
24
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IV. RECOMMENDATIONS
It is clear from this study that a number of states have made progress in testing multimedia
permitting approaches. However, the M2P2 pilot projects are still relatively young, and is difficult
to reach any conclusions about their effectiveness or their potential to be applied in other situations.
Accordingly, the recommendations outlined here focus on steps that EPA can take to support
continued research, evaluation and problem solving. These measures will lay the groundwork for
broader implementation of M2P2 approaches if states wish to move in this direction.
* EPA should work with states to see that multimedia permitting is evaluated more
fully.
EPA should work with interested states to ensure that research on multimedia permitting
continues. One appropriate task for EPA would be to update this report after states have made more
progress in evaluating the M2P2 pilot projects. Some states, such as New Jersey and Massachusetts,
already have preliminary evaluations underway.
Research on environmental results should be a high priority. As follow up to this report,
it would be useful to determine why some permit limits were made more stringent, while others were
relaxed, in writing multimedia permits, and whether such changes had any impact on pollution
prevention or on other parameters of interest, such as environmental compliance rates.
Materials accounting appears to have served as a catalyst for pollution prevention, at least
in New Jersey's case. EPA should develop case studies to illustrate the ways in which materials
accounting can facilitate multimedia permitting.
Finally, the resource implications of multimedia permitting should be explored more
thoroughly, and quantified to the extent feasible. Evidence suggests that states and industry face
high transition costs in moving to a multimedia approach, but may save time and money over the
long run. However, additional data is needed before drawing any final conclusions.
* EPA should facilitate implementation of multimedia permitting where states are ready
Some states with completed pilot projects may be ready to put M2P2 approaches on a more
permanent footing. Massachusetts, for example, has completed development of its self-certification
program for small printers and is proceeding with full-scale implementation. Project XL states will
begin their multimedia pilot projects once final project agreements have been signed.
25
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EPA has awarded grants to New Jersey, Arizona, and Massachusetts to support their
multimedia/pollution prevention projects. EPA can continue to assist these efforts by making
resources available for expanded pilot testing and long-term program development. The most
appropriate source of federal funding is through the National Environmental Performance
Partnership System, which allows states to combine their single-medium EPA categorical grants in
order to support multimedia projects.
+ EPA should help states develop integrated multimedia reporting systems
New Jersey and Arizona are planning to move ahead with the development of a consolidated
reporting format that would allow permitting and reporting to be conducted on a parallel multimedia
basis. EPA is supporting New Jersey's efforts under a cooperative agreement with the Tellus
Institute. In addition, EPA also awarded the One-Stop Reporting Demonstration Grant to New-
Jersey, along with Washington, Massachusetts, Missouri, and Utah to assist their development of
a streamlined environmental reporting and data management system. EPA plans to extend the One
Stop program to other states in the future. EPA is also working with the States of Wisconsin, Illinois
and Michigan to pilot test a consolidated reporting system. This effort is being undertaken through
the Great Printers Project- a partnership with the Council of Great Lakes Governors, the
Environmental Defense Fund and the Printing Industries of America.
EPA can provide continued support by making grants available through NEPPS, offering
technical assistance, and, in appropriate cases, helping states pursue multimedia reporting through
special- programs, such as EPA's Project XL, that are designed to encourage policy innovation.
4 EPA should create a mechanism for coordinating, monitoring and sharing information
on M2P2 efforts
As state M2P2 efforts continue and expand, EPA can play a vital role in coordinating,
monitoring and information sharing. It is particularly important that there be a focal point for
communicating with states, EPA Regions and other parties.
EPA should designate a lead office to organize this function on a long-term basis. The
function could be assigned to one of EPA's program offices or to a "lead" EPA Regional office.
i EPA should help states resolve key issues
Another role that an EPA lead office could play is that of ensuring that EPA-related issues
affecting multimedia permitting are resolved and to assist in removing barriers to the wider use of
their approach. As an example of such an issue, many states say that multimedia integration is
26
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hampered by the need to ensure consistency with existing single-medium laws and regulations.
Federal air permitting requirements present a particular challenge. Under Title V of the
Clean Air Act, states are required to obtain EPA's review and approval of their air permitting
programs and its concurrence on individual permits. In addition, states must comply with emissions
standards'and reporting requirements that are specific to the air medium. Such provisions reinforce
the conventional practice of writing permits one medium at a time.
Permitting reform is further complicated by inconsistencies between federal and state
requirements. As an illustration, facilities are required under federal rules to provide 30 days notice
before making process changes that could affect air emissions; New Jersey, on the other hand,
requires notification within 120 days after the change has been made. Many issues of this type
would need to be resolved in order for multimedia permits to be approved as meeting Title V
requirements.
Problems also arise from a lack of coordination in scheduling public participation activities.
EPA's air, water and hazardous waste programs have different requirements and time frames for
public noticing permit actions and public comment periods. For example, public notice of a draft
NPDES permit requires a 30 day public comment period. However, a 45 day comment period is
required for a draft RCRA permit. The-single-media regulations pertaining to public notice and
public comment need to be reviewed and better coordinated, using the most stringent of this single-
media requirements. Another problem with timing is with permit issuance and renewals. Although
most environmental permits cover five-year periods, a facility's single-medium permits may be
issued at different times, which makes it likely that they will also come up for renewal at different
times. Consequently, it may be difficult to identify a suitable period when a facility's single-medium
permits can be replaced, all at once, with one multimedia permit, particulary since permittees are
generally more reluctant to "open" existing permits prematurely. Perhaps some facilities would be
willing to accept modified permit terms in the interest of gaining a more integrated permitting
framework.
Finally, EPA needs to develop a more definitive policy on cross-media tradeoffs if
multimedia permitting is to achieve its fullest potential. Permits written for a single medium often
have unintended effects on releases to other media (for example, a technology used in controlling
air emissions may transfer pollution to surface water, and vice versa).
The writer of a multimedia permit has to take such cross-media transfers into account more
explicitly than the writer of a single-medium permit. Indeed, a range of possible cross-media
tradeoffs may have to be evaluated if the permitting authority wishes to set limits that will achieve
the most preferable environmental outcome. At this time, however, there is little explicit policy
guidance on which to base such a decision, and EPA's authority to issue such guidance is
constrained by applicable statutory and regulatory standards that are written for individual media.
These include ambient (e.g., state water quality) standards as well as standards that apply to
individual sources.
27
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As a long-term effort, EPA may wish to join other interested parties in exploring the
possibility of developing a legal and policy framework that would offer some flexibility to make
cross-media tradeoffs in the interest of overall risk reduction. This would require extensive
consultation with the Congress, states and many other parties.
28
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ATTACHMENT A
Facility-wide Permit
Huntsman Polypropylene
Selected Excerpts
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FACILITY-WIDE PERMIT for HUNTSMAN POLYPROPYLENE
TABLE OF CONTENTS
I. Facility-Wide Permit Cover Page
II. Fact Sheet
1
2
3
4
6.
7.
Name and Address of Applicant
Name and Address of Facility Covered by Permit Applicaf jn
Permitted Activities
Facility Description
A. Narrative description
B. General Flow Diagram
Basis for Facility Level Multimedia Releases
A. Pollution Prevention Plan
B. Facility Level Air Emissions
C. Surface Water Discharges of Stormwater Runoff
Procedures for Reaching a Final Decision on the Draft Permit
NJDEP Contact
III. Facility Release Limits
IV,
V.
General Facility Conditions
Process Packages.
Administrative Information
A. Process Description
B. Block Flow Diagrams (BFDs)
C. Equipment, Control Device,
PROCESS PACKAGES
WE....WET-END
DE DRY-END
BU....BOILER-^TILITIES
WW....WASTEWATER TRMT
and Source Sheet Information
Process Stack Sheet Information
Raw Material/Contaminant List
Technical Information
A. Release and Alteration/Amendment Limits
i. Process (Tons/Year)
ii. Worst-Case Permit Allowable Emission Limits
Additional Alteration/Amendment Release Limits
i. Process Average (Pounds/Hour)
ii. Process Worst-Case (Pounds/Product)
B
(Pounds/Hour)
3. Compliance Plan
4. Special Process Conditions
*Each of the four process packages has this general format.
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SECTION I; FACILITY WIDE PERMIT COVER PAGE
Issued To: Huntsman Polypropylene Corporation
PO Box 700
Mantua Grove Road
West Deptford Township, NJ 08906
Block 350D Lot 25.
Issuance Date:
Effective Date:
Expiration Date:
December 14, 1995
January 13, 1996
January 13, 2001
This Facility-Wide Permit is being issued in accordance with N.J.S.A.
13:10-35 fit £fig., particularly N.J.S.A. 13:lD-48, N.J.A.C. 7:1K fit seq. f
N.J.S.A. 13:1E-1 fit £££., N.J.A.C. 7:26 fit seq.. N.J.S.A. 58:10A-1 fit
SfiS-, N.J.A.C. 7:14A fit seq. , and N. J. S .'A . 26:2C-1 fit seq. . N.J.A.C.
7:27 fit fifisj. The FWP will replace the following existing
permits/certificates:
(1) Renewal of New Jersey Pollutant Discharge Elimination System
(NJPDES) Permit No. NJ0035831 for stormwater discharges;
(2) Air Pollution Control certificates listed in Appendix A;
(3) Renewal of Hazardous Waste Storage Permit, New Jersey
Hazardous Waste Facility Permit^No. 0802J1HP06, EPA ID No. »1JD 002
482 602;
(4) Compliance schedule for the wastewater treatment system
establishing case-by-case VOC RACT pursuant to N.J.A.C. 7:27-
16.17;
The FWP contains provisions to cover the following new activities:
(5) Revision to the flare permit (Certificate No.107113, Stack
No. 064) to correct VOC emissions pursuant to N.J.A.C. 7:27-16.13,
18.2(a), and 18.3(b);
(6) Operation of 62- previously permitted air sources and 23
stacks in the Dry-End Process to include VOC limits pursuant to
N.J.A.C. 7:27-16.16, 18.2(a), and!8.3(b);
(7) Operation of 23 previously grand-fathered air sources and 14
stacks in the Dry-End Process to include VOC limits pursuant to
N.J.A.C, 7:27-16.16, 18.2(a), and 18.3(b);
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(8) Operation of four new blenders, the upgrading of a blender
cycle on an existing blender, the installation of two new blowers
and a new loadout system in the Dry-End Process pursuant to
N.J.A.C. 7:27-8.2 (al 7 . 8.2(a)10, 8.2(a)ll, 8.2(a)18, and8.3(c);
(9) The operation of two boilers fitted with low NOx burners and
flue gas recycling pursuant to N.J.A.C. 7:27-8.2(a)13, 8.3(c) and
19.2(b)2;
The FWP contains provisions covering the following monitoring and
reporting requirements:
(1) Emission reporting and tracking requirements pursuant to
N.J.A.C 7:27;
(2) Submittal of New Jersey Pollution Prevention and Release
Reports pursuant to N.J.A.C. 7:IK-5.1 and 6.1;
(3) Recordkeeping and reporting of monitoring results pursuant to
N.J.A.C. 7:14A-2.9;
(4) Recordkeeping and reporting of monitoring results pursuant to
N.J.A.C. 7:26-7.4(g).
William O'Sullivan^ Administrator, Air Quality Permitting
Ken Hart, Director, Division of Solid and Hazardous Waste
as^re^Hart, Di
Director, Division of Water Quality
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SECTION II; FACT SHEET
Name and Add?ft«fl of
by Application
Huntsman Polypropylene Corporation
PO Box 700
Mantua Grove Road
West Deptford Township, NJ 08906
Block 350D Lot 35
2: Name and Address of Facility
See above
3 : Permitted Activities
A- Description of Permit: Replacement Activities
The above named applicant has applied for a Facility-Wide Permit (FWP)
pursuant to N.J.A.C. 7:iK-7.i. The FWP will replace the following
existing permits/ certificates:
(1) New Jersey Pollutant Discharge Elimination System (NJPDES) Permit
No. NJ0035831 for stormwater discharges at Discharge Serial Numbers 001,
002, 006, and 007 which discharge via four ditches to Mantua Creek, an
FW2-NT classified water, pursuant to N.J.A.C. 7 : 14A-2 . 1 (f ) (5) .
(2) NJDEP Air Pollution Control (APC) certificates listed in Appendix
A.
(3) Renewal of Hazardous Waste Storage Permit, New Jersey Hazardous
Waste Facility Permit No. 0802J1HP06, EPA ID No. NJD 002 482 602. Three
tanks (V-9102, V-9103, and T-U503B) were permitted for hazardous waste
storage.
Huntsman was previously allowed (Air Certificate No. 069063) to bum
hazardous waste in their small boiler (Boiler No.3) and was pursuing a
permit under EPA's Boiler and Industrial Furnace (BIF) regulation. Since
Huntsman is currently not pursuing this authority, the FWP prohibits the
burning of hazardous waste until BIF Closure requirements are complete.
This permit does renew Huntsman's ability to store hazardous waste
generated on-site for more than 90 days. Tanks V-9102 and V-9103 can
store up to 42,000 gallons each. Tank T-U503B is an accumulation tank
with a capacity of 1,089 gallons. Hazardous wastes stored in these three
tanks meet the federal criteria for ignitability (D001). Segregation
and permit modification must precede future burning of hazardous wastes.
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(4) Compliance schedule for the wastewater treatment system
establishing case-by-case VOC RACT pursuant to N.J.A.C. 7:27-16.17.
This schedule includes dates for interim pollution prevention measures
and dates for gradually decreasing, and eventually eliminating, the
emission of VOCs, primarily isopropyl alcohol (IPA), from the
wastewater;
B. Description of New Activities
The Department also proposes that the FWP will contain provisions to
cover the following new activities:
(5) Revision to the flare permit (Certificate No. 107113, Stack No.
064) to correct VOC emissions pursuant to^N.J.A.C. 7:27-16.13, 18.2 (a),
and 18.3(b);
(6) Operation of 62 previously permitted air sources and 23 stacks in
the Dry-End Process to include VOC limits pursuant to N.J.A.C. 7:27-
16.16, 18.2{a), and!8.3(b);,
(7) Operation of 23 previously grand-fathered air sources and 14
stacks in the Dry-End Process to include VOC limits pursuant to N.J.A.C.
7:27-16.16, 18.2(3), andl8.3(b);
(8) Operation of four new blenders^ the upgrading of a blender cycle
on an existing blender, the installation of two new blowers and a new
loadout system in the Dry-End Process pursuant to N.J.A.C. 7:27-8.2(a)7,
8.2(a)10, 8.2(a)11, 8.2(a)18, and8.3(c);
(9) The operation of two boilers fitted with low NOx burners pursuant
bo N.J.A.C. 7:27-8.2(a)13. 8.3(c) and 19.2 (b)2;
C. Basis for monitoring and reporting requirements;
(1) Emission reporting and tracking requirements pursuant to N.J.A.C
7:27-21.1, et seq. and 22.1, et seq. ;
(2) Submittal of New Jersey Pollution Prevention and Release Reports
pursuant to N.J.A.C. 7:lK-5.l and 6.1;
(3) Recordkeeping and reporting of monitoring results pursuant
N.J.A.C. 7:14A-2.9.
(4) Recordkeeping and reporting of monitoring results pursuant
N.J.A.C. 7:26-7.4(g).
to
to
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4= Facility Dearr-iyM on
A. Narrative Deseripfi nn
The applicant's activity consists of all phases of polypropylene
manufacturing and is classified under Standard Industrial Classification
(SIC) Code 2821. site operations are separated into four processes that
have the potential to release contaminants into the air, land, and
waters of tva State.
Propylene is polymerized to produce polypropylene plastic in the Wet-End
Process. The powdered plastic is conveyed to the Dry-End where it is
blended, extruded, formed into polypropylene pellets and packaged for
shipment. . The Boiler-Utility Package includes storage and handling
operations, flare gas recovery operations, the flare and the three
boilers at the facility. The wastewater treatment operations have been
analyzed from both a technical and regulatory perspective as a separate
process.
This FWP permits the release of air pollutants from over 200 air
emission sources, the discharge of stormwater from four stormwater
ditches, and the storage of hazardous waste for more than 90 days.
B. General Flow Diagram
Wet-End
Process
Boiler-
Utilities
Process
Dry-End
Process
! Wastewater
j Treatment
Process
5:
Basis for Facility-level Multimadiji Parnife Conditions
The facility-level effluent/emission limitations contained in the permit
are presented in the Table 1, Facility Release Summary. Also included is
a brief summary of the basis for each effluent/emission limitation and
other conditions in the permit:
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A.
Pollution Prevention Plan
The applicant has prepared a Pollution Prevention Plan (Plan) pursuant
to the Pollution Prevention Program Rules, N. J.A.C. 7: IK 1.1 fit_aaa.
This Plan includes a comprehensive analysis of the use and generation of
six hazardous substances in the two manufacturing processes at the
facility. The chemicals that must be included in the Plan are the same
as those publicly reported under the Federal Toxic Release Inventory
(TRI). The applicant expanded the scope of the Plan in certain areas to
include additional chemicals and changes the facility plans to make
under their "Plant Modernization" program. The expanded Plan covers an
additional 5 chemicals not covered under N.J.A.C- 7:1K «t sag. The
Plant Modernization cost will cost about $20 million, will save 220
jobs, and will keep the operations in New Jersey. The FWP is based on
the combined activities planned by the applicant in the Pollution
Prevention Plan and in the Plant Modernization Project.
Through these investigations, the applicant determined that managing
catalyst and cleaning the polypropylene plastic after it is manufactured
contribute significantly to environmental releases from the facility.
The biggest change planned for the plant involves changing the chemistry
of the process to use a new high activity catalyst. The new catalyst
will significantly reduce the use and generation of hazardous substances
in. several catalyst management and polymer cleaning steps. This
includes eliminating the use of seven chemicals at the facility. Three
chemicals (titanium tetrachloride, hydrogen chloride and cyclohexane)
are covered under TRI and four (isopropyl alcohol, isopentane, triethyl
amine, and diethyl aluminum chloride) are not covered and pollution
prevention planning for these was not required.
Huntsman's pollution prevention plan identifies significant sources of
hazardous substance non-product output (NPO) at the- plant; improving
the accuracy of data where needed and verifying previous data for
emissions and NPO. Several pollution prevention options were identified
and are being incorporated into the modernization effort. These options
include improved housekeeping measures, product transfer upgrades,
equipment replacements and the installation of an in-process recycling
system. In the last case. Huntsman's pollution prevention team found a
simple and inexpensive way to reduce the VOC emissions from the
wastewater treatment system by an estimated 43%.
Other pollution prevention activities planned by the applicant include:
eliminating equipment venting volatile organic chemicals to the flare,
in-process recycling of propylene in the polymerization step, recovery
and reuse of propylene and butane from the polymer stripping step, and
reducing the number of plant startups and shutdowns. Overall, the
facility plans to reduce its use of chemicals by over 4,300 tons per
year (TPY) . This will reduce emissions to the air by approximately 151
TPY (83 TPY of VOC and 68 TPY of NOx) , and discharges to the POTW by
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approximately 601 TPY (263 TPY of organics and 338 TPY of suspended
solids). This will also reduce the quantity of hazardous waste
generated by approximately 88 TPY.
The large release reductions actually understate the pollution
prevention efforts and benefits acheived for VOCs because the
destruction of VOCs in the boilers is 99.9%. The non-product output
(NPO) reductions of VOCs are almost 3500 TPY vs. 83 TPY of release
reduction.
B.
Facility-Level Air Emissions
(a) Facility-level air emissions for Volatile Organic Compounds (VOC)
are based on compliance with N.J.A.c. 7:27-18.1 "Control and Prohibition
of Air Pollution from New or Altered Sources Affecting Ambient Air
Quality," more commonly referred to as the "Emission Offset Rule." This
rule requires covered major sources to determine if proposed emission
increases are a "significant net emission increase." If so, the
facility is required to purchase offset and implement technology
representing the Lowest Achievable Emission Rate (LAER).
Huntsman conducted an emission offset analysis pursuant to N.J.A.C.
7:27-18.7 by quantifying the total facility emissions in 1979 and 1995.
This analysis included potential emissions from "grandfathered" sources
as well as uninventoried sources identified as part of Huntsman's
voluntary involvement in the facility-wide permit program. Fugitive
emissions from the plants various piping valves, flanges and equipment
were also included.
The Woodbury facility was originally constructed in 1962. All equipment
at the facility was in place at the time of the initial filing of the
Emission Offset Rule in September of 1980. Only minor changes have been
made to the facility since the original plant was built. The base'year
of 1979 was selected to document what the allowable emissions were
before the offset rule took effect. Emission for 1995 were quantified
as part of the development of the new emission limits proposed in the
facility-wide permit. The limits in the facility-wide permit will be
used as the new baseline for determining if future changes are
"significant net emission increases" under N.J.A.c. 7:27-8.7.
The offset analysis shows that emissions have decreased from 889
tons/year in 1979 to 397 tons/year in 1995. The only change to specific
equipment at the facility over this period was the installation of a new
rail car unloading facility for propylene. This change increased the
potential emissions by 0.438 tons/year. Overall, there are no
significant emission increases at the facility.
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C. Surface Water Discharges from Stormwater Runoff
(a) The facility manufactures polypropylene pellets (SIC 2821) and has
four surface water outfalls which are regulated under this permit in
accordance with N.J.A.C. 7:l4A-3.13(a) (12) (ii). These outfalls are
located at the rear of the facility and discharge via four ditches to
Mantua Creek, classified as FW2-NT waters, at maximum hydraulic design
loadings of 0.39 million gallons per day (MGD) for DSN 001; 0.37 MOD for
DSN 002; 0.08 MGD for DSN 006; and 0.42 MGD for DSN 007 based on a 25
year storm. (Design was based on 2.6" of rainfall in one hour.)
Stormwater is generated from various roof drains, fields, rail spurs,
diked areas, roadways, and other paved areas. Prior to discharge, the
Stormwater from DSN 001, 002, 006 and 007 are filtered via basket
screens (placed over various catch basins), hay filters, and/or
overflow/underflow weirs. Stormwater from the manufacturing areas of
the plant is diverted from the permitted outfalls and sent to the
wastewater treatment plant.
(b) The limitations and conditions for Flow, pH, Total Organic Carbon,
and Total Suspended Solids are based on the September 5, 1991 "EPA
Region 2 Revised Guidance for Cooling Water and Stormwater Runoff" from
John S.Kushwara, Acting Chief, Water Permits and Compliance Branch,
USEPA Region II. All limitations including Petroleum Hydrocarbons are
also carried forward from the permittee's former permit in accordance
with the anti-backsliding regulations set forth in N.J.A.C. 7:14A-
3.13(a)(12)(ii).
(c) The monitoring requirements for Petroleum Hydrocarbons are in
accordance with N.J.A.C. 7:14A-14.5 &L Sfijj., the New Jersey Oil and
Grease Effluent Limitations. The Petroleum Hydrocarbons parameter is
imposed instead of oil and grease as one would expect to find mostly
petroleum-based oil and grease in this permittee's Stormwater discharges
based upon the nature of it's operations.
(d) Permit conditions are authorized by the Federal Clean Water
Pollution Control Act (33 U.S.C. 1251 at seg.), and the Water Pollution
Control Act (N.J.S.A. 58:10A-1 et seq.). These statutes are implemented
by the National Pollutant Discharge Elimination System (NPDES) (40 CEE
Part 122) and the New Jersey Pollutant Discharge Elimination System
(NJPDES) permit programs.
6:
NJDEP Contact
Additional information concerning this permit may be obtained by
contacting Brian O'Reilly of the Office of Pollution Prevention at
(609)777-0518.
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SECTION IVi GENERAL FACILITY CONDITIONS
1. The equipment covered by this permit shall not cause any air
contaminant, including an air contaminant detectable by sense of smell,
to be present in the outdoor atmosphere in such quantity and duration
which is, or tends to be injurious to human health or welfare, animal or
plant life or property, or would unreasonably interfere with the
enjoyment of life or property, except in areas over which the owner or
operator has exclusive use or occupancy.
2. Any operation of the equipment covered by this permit which may
cause off-property effects, including odors, shall be reported by the
Permittee immediately, as required by the Air Pollution Control Act,
N.J.S.A. 26:2C-19(e). Such report shall be made by calling the
Environmental Action Hotline at (609) 292-7172.
3. The permittee shall not use the equipment covered by this permit,
unless specified in the applicable process package, in a manner which
will cause visible emissions, exclusive of water vapor to be emitted
into the outdoor atmosphere. Compliance with this requirement shall be
verified visually by use of New Jersey Test Method 2 (N.J.A.C. 7:27B-2),
or equivalent, or by opacity monitoring. This provision shall not apply
to smoke from the facility boilers which is visible for a period of not
longer than three minutes in any 30-minute period.
4. Hazardous Waste Personnel Training
A. Facility personnel shall successfully complete a program of
classroom instruction or on-the-job-training that teaches them to
perform their duties in a way that insures the facility (s
compliance with the requirements of N.J.A.C. 7:26-9.4(g). New
employees shall be trained within six months of the date of
employment.
B. The training program shall be maintained with records and
documentation describing the type and amount of both introductory
and continuing training that has been and will be given to each
person engaged in hazardous waste management at the facility.
5. The Permittee shall meet the Hazardous Waste Financial Assurance
Requirements in N.J.A.C. 7:26-9.10.
6. The permittee has informed the Department that it did not use any
corrosion inhibitors, biocides, or other cooling water additives which
contain chromium, in its non-contact cooling water at the time of permit
issuance. If the permittee decides to begin using any chromium-
containing agents in the future, the permittee must notify the
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Department at least 180 days prior to use so that the permit may be
reopened to incorporate any additional limitations deemed necessary.
7. There shall be no discharge of floating or visible foam, in other
than trace amounts, through DSNs 001, 002, 006 and 007. There shall be
no visible sheen in the discharges from DSNs 001, 002, 006 and 007.
8. Effluent Limitations and Monitoring Requirements:
Monitoring for the parameters indicated below shall be conducted during
the^ first precipitation event of the month which causes a discharge
during working hours and which is preceded by a minimum dry period of 72
hours.
Effluent Characteristic-
Flow (MGD)
pH (Standard Units)
Total Organic Carbon (mg/1)
Total Suspended Solids (mg/1)
Petroleum Hydrocarbons (mg/1)
Discharge Limitations
Daily _ Monthly Daily
Minimum Average Maximum
N/A
6.0
N/A
N/A
N/A
NL
N/A
NL
NL
NL
NL
9.0
50
50
10
All samples shall be monitored monthly with a grab sample, except for
Petroleum Hydrocarbons, wh'ch shall be impled multi-grab; i.e. the
permittee shall take samples 15, 30,^ and 45 minutes after the onset of
discharge, shall analyze each sample individually, and report the
maximum value for the samples.
Samples shall be taken at the outfalls of DSN 001, 002, 006 and 007.
(See Figure 1. Location of NJPDES/DSW Sampling Points.)
9. The permittee must also comply with all permits conditions and
reporting and monitoring requirements in Appendix B: Conditions for
NJPDES/DSW Perrmits.
10. The permittee shall be responsible for supervising and managing
the operation and maintenance of this facility and any BMPs which are
implemented by the permittee to achieve compliance with the conditions
of this permit. Proper operation and maintenance also requires the
operation of backup or auxiliary facilities or similar systems when
necessary to achieve compliance with the conditions of the permit.
11. The permittee may request a modification of their permit to
decrease monitoring frequencies for limited surface water parameters if
site specific conditions indicate applicability of such a modification.
-------
The Department will consider reducing the monitoring frequency of a
limited parameter provided that:
A. ELGs applicable to the facility do not specify the required
monitoring frequency;
B. The frequency reduction conditions are included in the public
notice of the draft permit;
C. The permittee has shown consistent compliance with all permit
conditions for the affected parameter(s) for:
a) a minimum period of. one (1) year for a monitoring
frequency of weekly;
b) a minimum period of two (2) years for a monitoring
frequency of twice per month;
c) a minimum period of three (3) years for a monitoring
frequency of monthly;
d) a minimum period of five (5) years for a monitoring
frequency of quarterly; and
e) a minimum period of four tests for Whole Effluent
Toxicity (WET) limitations.
D. A monitoring frequency can be reduced as follows:
a) from weekly to monthly;
b) from twice monthly to monthly;
c) from monthly to quarterly;
d) from quarterly to semi-annually or annually.
E. For WET limitations, monitoring frequencies can be reduced as
follows:
a) a minimum of twice per year for major dischargers,
b) a minimum of annually for minor dischargers.
Reduction of monitoring frequency is not automatic; the Department shall
determine whether or not a reduction is warranted. The Discharge
Monitoring Reports (DMRs) shall be reviewed to verify consistent
compliance with permit limitations and conditions for the affected
parameter(s). If the Department agrees to grant the request, the
Department will perform a conditional change to the permit to change the
monitoring frequency of the affected parameter(s) .
The monitoring frequency for the affected parameter(s) cannot be reduced
below annual frequency, in accordance with N.J.A.C. 7-.14A-3.13.
A request for a modification of the monitoring frequency should be sent
to the Chief of the Bureau of Permit Management, CN-029, Trenton, New
11
-------
Jersey 08625. A copy of the letter should also be sent to the Office of
Pollution Prevention, CN-423, Trenton, New Jersey 08625.
12. Modification Procedures
A. Any modification of this facility-wide permit will be limited
to the specific provisions included in the modification.
Modifications will not require that all conditions in the
facility-wide permit be reopened for each modification. All
conditions in the facility-wide permit not subject to the
modification will remain in full force and affect.
B. Modifications will be processed pursuant to N.J.A.C. 7:14A-
2.12 and 7.5; N.J.A.C. 7:26-12.6, j.2.7 and 12.8; and N.J.Vr.
7:27-8.3 and 8.27, as appropriate.
C. The Department may require the Permittee to modify the permit
to include any new applicable requirements when they are
promulgated.
13. Certification of information
(a) Except pursuant to (c) below, any person who submits an
application, report or other documrit to the Departmei shall
include, as an integral part of the application, report or other
document, the following two part certification:
l. A certification, signed by the individual or individuals
(including any consultants) with direct knowledge of and
responsibility for the information contained...- in the certified
document. The certification shall state:
"I certify under penalty of law that I believe the
information provided in this document is true, accurate and
complete. I am aware that there are signifigant civil and
criminal penalties, including the possibility of fine or
imprisonment or both, for submitting false, inaccurate or
incomplete information."
2. A certification signed by a responsible official, as defined
at N.J.A.C. 7:27rl.4, which states:
"I certify under penalty of law that I have personally
examined and am familiar with the information submitted in
this document and all attached documents and, based on my
inquiry of those individuals responsible for obtaining the
information, I believe that the information provided in this
12
-------
document is true, accurate and complete. I am aware that
there are signifigant civil and criminal penalties, including
the possibility of fine or imprisonment or both, for
submitting false, inaccurate or incomplete information."
(b) The certification at (a) 2 above shall not be required if the
individual required to sign the certification in (a)l is the same
individual required to, sign the certification in (a)2.
14. The Permittee shall report any non-compliance of operating
requirements directly related to emission limits, including but not
limited to pressure drops, changes in operating hours, flow rates or
temperature, or any non-compliance specified in the conditions for the
permit, in writing, within three working days after the event, to the
Regional Enforcement Officer, unless otherwise specified in writing by
the Regional Enforcement Office.
15. Unless otherwise specified all reports shall be submitted to the
following address:
N.J. Department of Environmental Protection
Environmental Regulation
Office of Pollution Prevention
CN 423
Trenton, NJ 08625-0423
13
-------
HUNTSMAN POT VPROPYLF.NF TORPOR ATTONf
WEST DEPTFORD TOWNSHIP WOOnmjRY PLANT
APPENDIX A
STACK
002
003
004
005
006
007
008
009
010
Oil
012
013
014
015
016
017
018
019
020
022
023
024
025
027
028
029
031
032
033
034
035
036
039
041
NUMBER
012162
030871
006130
032612
034770
023267
001291
023266
047667
007552
005120
012161
022193
022194
063232
078722
012160
031815
031509
034771
DATE
04/01/99
05/04/97
10/12/97
03/31/98
08/04/97
11/08/96
03/21/00
11/08/96
02/04/96
04/03/98
05/22/00
04/01/99
06/03/96
06/03/96
08/12/99
06/16/98
04/01/99
09/22/92
07/01/92
06/08/98
COMPANY DESIGNATION
ELUTRIATOR SOUTH BAGGER
ELUTRIATOR NORTH CARTON
ELUTRIATOR SEMIAUTO BAG
ELUTRIATOR BULK LOADER A
ELUTRIATOR V4553
TWIN CONE RECEIVER BIN
B42 SYSTEM MIXERS AREA
SPENCER VACUUM CLEANER
POLYPROP STOR BIN 9921
POLYPROP STOR BIN 9922
POLYPROP STOR BIN 9923
POLYPROP STOR BIN 9924
POLYPROP STOR BIN 9925
RUNDOWN BIN 9911
RUNDOWN BIN 9912
RUNDOWN BIN 9913
RUNDOWN BIN 9914
RUNDOWN BIN 9915
RUNDOWN BJN 9916
INTERNAL BLEND BIN 9991
INTERNAL BLEND BIN 9992
INTERNAL BLEND BIN 9952
INTERNAL BLEND BIN 9993
INTERNAL BLEND TANK 9995
INTERNAL BIN 9904
RECEIVER BIN 9901
EXTRUDER FEED VESSELS 3
PRIMARY EXTRUSION UNITS
B-3555 PELLETIZER & DRYER
AIR CLEANING SYS A B34
BLENDING BIN V9996
CONVEY AND STOR OF POLYP
SEC EXTRU 4101 4151 4201
FINISH BLD DUST CON SYS
-------
(continued)
APPENDIX A
STACK
042
043
044
048
049
050
051
052
053
054
055
056
059
061
062
063
064
065
066
067
068
069
070
071
072
073
074
075
076
Oil
079
080
081
082
NUMBER
066144
066145
069063
046752
038320
063233
043093
033590
107113
049879
051416
062989
DAIE
06/20/96
06/20/96
12/01/96
05/01/86
05/02/98
08/12/99
06/16/99
03/21/00
07/17/98
03/22/98
03/21/98
11/29/97
COMPANY nFSTGNATION
F, U201 STACK, BOILER
F, U202 STACK, BOILER
F, U203 C.B. BOILER
STORAGE TANK V9117
STORAGE TANK V9118
STORAGE TANK V9119
STORAGE TANK V9120
STORAGE TANK V9121
STORAGE TANK V9122
STORAGE TANK V9123
STORAGE TANK V9124
WASTE OIL ST. TANK V-9103
VENTILATION BLOWER B3008
B-3604
CENTRAL VAC. CLEAN. B3016
BLENDER BIN V9994
F-U503 F-U502
T-U507, SPARE WASTE WATER
T-U508 - FLARE SEPARATOR
BASIN CVR
T9101
T9002
S-2006 POLYP.ROPYLENE
CONVEYOR
#6 FUEL OIL STOR TK TU201
T9113 5% IPA
T911285% IPA
T-700 EPON 828
T-701 EPON 8280
T9111 100% IPA
VENTILATION BLOWER B-33
DP-U-106 WELLWATER PUMP
VENTILATION BLOWER B-32A
VENTILATION BLOWER B-32B
VENTILATION BLOWER B-32C
VENTILATION BLOWER B-32D
s:\hunu man,bor
-------
HUNTSMAN POLYPROPYLENE CORPORATION
WEST PFPTFORD TOWNSHIP WOODBURY PLANT
APPENDIX P. CONDITIONS FOR NJPDES/DSW COMPLIANCE
I. STANDARD CONDITIONS FOR > LL NJPDES/DSW PERMITS
The permittee shall comply with all the conditions set forth in this permit and all the
applicable requirements relevant to the permittee's discharge(s) that can be found in the
Federal Clean Water Act and the New Jersey Water Pollution Control Act (the State Act as
amended), N.J.S.A. 58:10A-1 et seq. The permittee may be subject to penalties for any
violations thereof.
The following conditions that are applicable to all NJPDES/DSW permits are incorporated
by reference. The permittee is required to comply with the regulations which were in
effect as of the effective date of the final permit.
Section A. GENERAL CONDITIONS
1. Penalties for Violations
2. Consolidation of Permit Process
3. Incorporation by Reference
4. Duty to Comply
5. Duty to Reapply
6. Continuation of Expired Permits
7. Duty to Mitigate
8. Permit Actions
9. Duration of Permits
10. Effect of Permit/other Laws
11. Inspection and Entry
12. Severability
13. Toxic Pollutants
14. Reopener Clause
N.J.A.C.
7:14-8. let seq.
7:14A-1.4
7:14A-1.10
7:14A-2.5(a)
7:14A-2.1(g)5
7.-14A-2.3
7:14A-2.1(f)
7:14A-2.5(a)8
7:14A-2.7
7:14A-2.10(a)(b)&(c)
7:14A-2.5(a)ll
7:14 A-1.5
7:14A-2.5(a)3
7:14A-3.13(a)3
SectionB. OPERATION AND MAINTENANCE N.J.A.C.
1. Proper Operation and Maintenance
2. Need to Halt or Reduce not a defense
3. Bypass of Treatment Facilities
4. Upset
7:14A-2.5(a)7
7:14A-2.5(a)5
7:14A-3.10
7:14A-3.10
-------
5. Power Failure
6. Emergency Plans
7:14A-2.5(a)5&7
7:14A-3.12(b)
Section C. MONITORING AND RECORDS
1. Representative Sampling
2. Monitoring Procedures
3. Retention of Records
4. Monitoring Records
5. Additional Voluntary Monitoring
6. Averaging of Measurements
7. Required Additional Monitoring
Section D. REPORTING REQUIREMENTS
1. Planned Changes
2. Change in Discharge
3. Anticipated Noncompliance,
4. Transfer
5. Reporting of Monitoring Results
6. Compliance Schedules
7. Twenty-four Hour Reporting
8. Duty to Provide Information
9. Signatory Requirements
10. Availability of Reports
11. Other Noncompliance
12. Other Information
13. Confidentiality
Copies of the NJPDES regulations may be obtained, for a nominal charge, by contacting:
West Publishing Company
St. Paul, Minnesota
800-328-9352
II. ADDITIONAL STANDARD CONDITIONS
N.J.A.C.
7:14A-2.5(a)12.i
7:14A-2.5(a)12.ii
7:14A-2.5(a)12.iii
7:14A-2.5(a)12.iv
7:14A-2.5(a)12.vi
7:14A-2.5(a)12.vii
7:14A-2.5(a)12.xi
-N.J.A.C.
7:14A-2.5(a)14.i
7:14A-2.5(a)14.ii
7:14A-2.5(a)14.i&v
7:14A-2.11 &7:14A-2.5(a)14.iii
7:14A-2.5(a)14
7:14A-2.8
7: 14A-2.5(a)14.vi.(2)(3)&(4)
7:14A-2.5(a)10
7:14A-2.4
7:14A-2.5(a)14.viii
7:14A-2.5(a)14.ix
Monitoring and Reporting
Monitoring results shall be summarized and reported on the appropriate Discharge
Monitoring Reports (DMRs) following the completed monitoring period. If a discharge
does not occur during a particular reporting period, the permittee should write "NODI"
across the face of the DMR. Unless otherwise specified or directed, signed copies of these
-------
DMRs shall be submitted postmarked no later than the 25th day of the calendar month
following the completed monitoring period to the address given below:
NJDEP
Bureau of Permits Management
CN 029
Trenton, New Jersey 08625-0029
Attn. Monitoring Reports
Sampling Point*-
All samples shall be taken at the monitoring points specified in this permit and, unless
otherwise specified, before the effluent joins or is diluted by any other wastestream. body
of water or substance. Monitoring points shall not be changed without notification to and
the approval of the Department.
Intermittent Discharges
For permitted discharges which occur on an intermittent basis, the permittee is required to
provide representative sampling of the monitored activity pursuant to N.J.A.C. 7:14A-
2.5(a)12i. Therefore, although a discharge may occur on an intermittent basis, it does not
exempt the permittee from complying with the conditions of the permit. For example, if a
permittee has a monthly monitoring and reporting requirement and the discharge occurs
three separate tim^ during the month, the permittee should obtain a sample during at least
one of the discharge events occurring during the monitoring period. The permittee should
report "NODI" on the DMR only if there are no discharge events during the entire
reporting period.
Compliance/Noncompliance
The permittee shall notify the Department of any noncompliance in accordance with
N.J.A.C. 7:14A-2.8(a)3 and N.J.A.C. 7:14A-2.5(a)14 et seq. Such a notification shall be
submitted to the appropriate Bureau of Water and Hazardous Waste Enforcement in the
Division of Enforcement Field Operations.
Schedule of Maintenance
Any maintenance of facilities, which might necessitate unavoidable interruption of
operation and degradation of effluent quality, shall be scheduled during non-critical water
quality periods and carried out in a manner approved by the Department.
-------
III. SPECIAL CONDITIONS
fieopener Clauses
1. Toxic Effluent Limitations
Notwithstanding any other condition of this permit, if any applicable toxic effluent
standard, limitation, or prohibition (including any schedule of compliance specified in such
effluent standard or prohibition) is promulgated under Sections 301(b)(2) (C) and
-------
PROCESS BU: BOILER AND UTILITIES PROCESS
TABLE OF CONTENTS
Section l. ADMINISTRATIVE INFORMATION
A. Process Description
B. Process Flow Diagrams
C. Equipment, Control Device and Source Information
D. Process Stack Sheet Information
E. Raw Material/Contaminant List
Section 2. TECHNICAL INFORMATION
A. Release & Alteration/Amendment Limits
(i) Process (Tons/Year)
(ii) Worst-Case Permit^ Allowable Emission Limits for Each
Piece of Equipment in the Process (Pounds/Hour)
B. Additional Alteration/Amendment Reli ..se Limits
(i) Process Average (Average Pounds/Hour)
(ii) Process Worst-Case (Pounds/Product)
Section 3. COMPLIANCE PLAN
A. Applicable Requirements
B. Monitoring and Recording Requirements
C. Reporting Requirements
D. Operating Conditions
Section 4. SPECIAL PROCESS CONDITIONS
Not Applicable
BU-l
-------
Section 1. ADMINISTRATIVE INFORMATION
«BU-A. BOILER AND UTILITIES PROCESS,
PROCESS DESCRIPTION
There are three types of source operations subject to environmental
permitting requirements which are covered in this process package. For
consistency of format and organization they are referred to as steps:
(1) Storage and Handling Operations
(2) Boiler Operation
(3) Flare Operation
step l. Storage and Handling Operations
No.6 fuel oil, caustic, sulfuric acid, and two epon resin tanks are
stored in conventional atmospheric API tanks. The sulfuric acid tank
(T-9005A) stores less than 10,000 gallons and does not require
permitting so it has no stack number. The Epon Resin tanks (T-700 and
T-701) are operated as part of an agreement Huntsman made with Shell
Oil Co. when they purchased'the site from Shell. The fuel oil in tank
T-U201 may be burned in any of the three boilers.
Step 2. Boiler Operation
The Woodbury Plant operates three boilers that generate the steam
required for manufacturing operations and facilty heating. These
boilers are identified as:
Boiler No. 1
Boiler No. 2
Boiler No. 3
FU-201 ... 80.1 MM BTU per hour
FU-202 ... 80.1 MM BTU per hour
FU-203 ... 28.3 MM BTU per hour
All boilers can burn No. 6 fuel oil, natural gas, and flare gases
recovered from the Wet-End Process. Boiler No. 3 previously burned a
mixture of RCRA (DOOl) and state (X-726 and X-722) hazardous waste; a
mixture primarily of fuel oil No.2, used lubricating oils, mineral oil
and isopentane. This operation has been complying with EPA's Boiler and
Industrial Furnace (BIF) regulation (40CFR266.100) under interim status.
In order to continue burning RCRA hazardous waste, EPA requested that
Huntsman demonstrate compliance with the new combustion strategy
requirements which include a risk determination and a trial burn.
Huntsman then decided to stop burning the mixture of hazardous waste on-
site. They will dispose of future waste by off-site incineration.
BU-2
-------
Boiler No. 3 will continue in operation but will no longer burn
hazardous waste. Huntsman has stopped burning any hazardous waste while
they are involved in BIF Closure procedures. Huntsman plans to
eliminate a signifigant portion of the hazardous waste generated at the
facility; but if they want to separate and burn state hazardous waste
from non-specific sources after BIF Closure is complete, they must
modify this FWP via modification to their hazardous waste permit
application and by providing appropriate air permit information
modifications to the FWP.
Step 3. Flare Operation
The flare(s) (F-0502 and F-U503) was originally installed in May of
1961. The flare consists of two stacks, one 8 inch and the other 30
inch diameter, which are connected to a common 9,850 gallon Knock-out
Pot (V-U504) at its base. (The large (30* inch diameter) flare is only
used for emergency situations.) Each stack is equipped with continuous
burning energy efficient pilots and steam sprayers. The flare gas is
primarily a propylene-butane mixture with a BTU content of approximately
1066 Btu/ft3.
BU-3
-------
BU-B: BOILER AND UTILITIES PROCESS,
BLOCK FLOW DIAGRAMS
There are four block flow diagrams in this section. The first diagram,
Figure BU-B, is a schematic representation of the process divided into
three separate steps. The raw material inputs, number of air sources
and stacks, and the wastewater output (s) are indicated.
There is a separate figure for each of the steps described in subsection
BU-A. The nomenclature for naming figures follows a simple format:
Process Abbreviation - Subsection Letter.Step Number
Figure BU-B:
Figure BU-B.l:
Figure BU-B.2:
Figure BU-B.3:
FIGURES
Simplified Overall BU Process
Storage and Handling Operations
Boiler Operation
Flare Operation
BU-4
-------
Figure BU-B
Process Flow Diagram
Boiler-Utilities Process
NPO from
Wet End
Process
(Hare gas)
Rare Gas
Recovery System
Natural Gas
Flare
F-U502
F-U503
NJ Stack
BU-301
BU-302
Boiler
Operation
Boiler #1
F-U201
NJ Stack
BU-201
Boiler
Operation
Boiler #2
F-U202
NJ Stack
BU-202
Boiler
Operation
Boiler #3
F-U203
NJ Stack
BU-203
Storage and Handling
Operations
No. 6 Fuel Oil Tank
T-U2Q1
NJ Stack
BU-101
Storage and Handling
Operations
Caustic Tank
T-9002
NJ Stack
BU-102
Storage and Handling
Operations
Epon Tank
T-700
NJ Stack
BU-103
Storage and Handling
Operations
Epon Tank
T-701
NJ Stack
BU-104
BU-5
-------
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llg>
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Is
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Q.
(0
SO w
~ ~ w
5 2 g
Y. CD fl> X
IJ « Q.2
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> ra w
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BU-6
-------
Figure BU-B.2
Process Flow Diagram
Boiler Operation Step
Boiler-Utilities Process
Exhaust Air
to Atmosphere
Containing
Participates, CO,
NOX. SO2. VOCs.
THC, and Lead
(NPO)
Exhaust Air
to Atmosphere
Containing
Particulates. CO,
NOX, SO2, VOCs,
THC, and Lead
(NPO)
Exhaust Air
to Atmosphere
Containing
Particulates, CO,
NOX, SO2, VOCs,
THC, and Lead
(NPO)
Stacks
t
NJ Stack
BU-201
Controls
(None)
Step
1
NJ Stack
BU-202
I
NJ Stack
BU-203
Boiler 1
Boiler 2
Boiler
Slowdown
to Chemical
Sewer
Boiler 3
Boiler
Slowdown
to Chemical
Sewer
Boiler
Slowdown
to Chemical
Sewer
No. 6 Fuel Oil
Natural Gas
Flare Gas
No. 6 Fuel Oil
Natural Gas
Flare Gas
No. 6 Fuel Oil
Natural Gas
Flare Gas
BU-7
-------
Figure BU-B.3
Process Flow Diagram
Flare Gas Recovery and Flare Operation Step
Boiler-Utilities Process
Exhaust Air to Atmosphere
Containing Particulates, CO,
NOX, and VOCs (NPO)
Stacks
i
NJ Stack
BU-301A
Controls
Rare
Fy-502
FU-503
Step
Rare Gas
Recovery
System
Rare Gas
to Boilers
NPO from
Wet End
Process
BU-8
-------
BU-C: BOILER AND UTILITIES PROCESS,
EQUIPMENT, CONTROL DEVICE AND SOURCE INFORMATION
There is a separate table for each of the three steps described in
Subsection BU-A. The nomenclature for naming tables follows a simple
format:
Process Abbreviation - Subsection Letter.Step Number
TABLES
Table BU-C.l Storage and Handling Operations
Table BU-C.2 Boiler Operation
Table BU-C.3 Flare Operation
BU-9
-------
Table BU-C.1
Process Equipment and Control Devices
Storage and Handling Operations Step
Boiler-Utilities Process
Old
Stack
068
070
073
074
New |
Stack Equipment Description
BU-101 Sodium Hydroxide (caustic)
Storage Tank (T-9002)
Carbon Steel
16 ft. diameter x 24 ft. high
Contains Liquid Non-VOS
Submerged Fill
Maximum Fill Rate: 50 gpm
Exposed to Sun
Uninsulated
BU-102 No. 6 Fuel Oil Storage Tank
(T-U201)
Carbon Steel
45 ft. diameter x 35.5 ft. high
Contains Liquid VOS
Submerged Fill
Maximum Fill Rate: 150 gpm
Exposed to Sun
Insulated with 1-in.
Polyisocyanurate Foam
Panels (R=7.2)
BU-103 Epon Resin Storage Tank
(T-700)
Carbon Steel
15 ft. diameter x 24 ft. high
Contains Liquid VOS
Submerged Fill
Maximum Fill Rate: 65 gpm
Exposed to Sun
Uninsulated. Internal
Heaters (70 MBTU/Hr)
BU-104 Epon Resin Storage Tank
(T-701)
Carbon Steel
15 ft. diameter x 24 ft. high
Contains Liquid VOS
Submerged Fill
Maximum Fill Rate: 65 gpm
Exposed to Sun
Uninsulated. Internal
Heaters (70 MBTU/Hr)
Processing Capacity
Tank capacity * 36.000 gal
Construction: carbon steel
Avg annual throughput =
133.000 gal
Max annual throughput =
150.000 gal
Tank capacity = 410.000 gal
Construction: carbon steel
Avg annual throughput =
1.949.500 gal
Max annual throughput =
11. 000,000 gal
Tank capacity = 30,000 gal
Construction: carbon steel
Avg annual throughput =
500,000 gal
Max annual throughput *
1,300,000 gal
Tank capacity * 30,000 gal
Construction: carbon steel
Avg annual throughput =
600,000 gal
Max annual throughput =
1,300,000 gal
Control Device Description
Tank painted white
Direct vent to atmosphere
Tank painted white
Direct vent to atmosphere -
Tank is insulated
Direct vent to atmosphere
Tank is insulated
Direct vent to atmosphere
BU-10
-------
Table BU-C.2
Process Equipment and Control Devices
Boiler Operation Step
Boiler-Utilities Process
Old
Stack
New
Stack
Equipment Description
Processing Capacity
Control Device D
042
BU-20
043
BU-202
044 BU-203
No. 1 boiler (FU-201)
Manufacturer Foster Wheeler
Date of Installation or
Alteration: July 31,1995
Boiler Type: Non-utility,
Package, Fire Tube
Maximum Gross Heat Input:
80.1 MMBTU/Hr
Primary Fuel: No. 6 fuel oil
Secondary Fuels: Natural
gas and flare gas
Firing Method: Tangential
Draft Type: Forced
No. 2 boiler (FU-202)
Manufacturer: Foster'Wheeler
Date of Installation or
Alteration: July 31,1995
Boiler Type: Non-utility,
Package, Fire Tube
Maximum Gross Heat Input:
80.1 MM BTU/Hr
Primary Fuel: No. 6 fuel oil
Secondary Fuels: Natural
gas and flare gas
Firing Method: Tangential
Draft Type: Forced
No. 3 boiler (FU-203)
Manufacturer Cleaver Brooks
Date of Installation or
Alteration: August 31, 1995
Boiler Type: Non-utility,
Package, Fire Tube
Maximum Gross Heat Input:
30 MM BTU/Hr
Primary Fuel: No. 6 fuel oil
Secondary Fuels: Natural
gas and flare gas
Firing Method: Tangential
Draft Type: Forced
Max rate = 60,000 Ib/hr
steam
Avg rate = 38,000 Ib/hr
steam
Max throughput = 505
million Ibs steam
Avg throughput = 320
million Ibs steam
Max rate = 60,000 Ib/hr
steam
Avg rate = 38,000 Ib/hr
steam
Max throughput = 505
million Ibs steam
Avg throughput = 320
million Ibs steam
Max rate = 24,000 Ib/hr
steam
Avg rate = 15,000 Ib/hr
steam
Max throughput = 73
million Ibs steam
throughput = 45
million Ibs steam
Low NOX burners (LNB)
Flue gas recirculation (FGR)
Oxygen analyzer
Low NOX burners (LNB)
Flue gas recirculation (FGR)
Oxygen analyzer
None
BU-ll
-------
Table BU-C.3
Process Equipment and Control Otvlcas
Flare Gas Recovery and Flam Operation Step
Boiler-Utilities Proctss
Old
Stack
064B
064A
New
Stack
BU-302
BU-301
Flare recovery system
Supplies flare gas (NPO
from Wet End Process)
to boilers through network
of headers and common
knockout drum
Flare recovery system
Supplies flare gas (NPO
from Wet End Process)
to boilers through network
of headers and common
knockout drum
Processing Cacacity
650.000 Ibs/hr
hydrocarbon.
When pressure in common
tare knockout drum
exceeds 30 in. H2O, seal
on 30-in. flare stack
blows and hydrocarbon
flow is initiated in the
30-in. stack.
Hydrocarbon flows
>5,400 Ibs/hr.
Control Device Descnption
30-in. flare stack (F-U502)
Manufacturer JohnZink-
STF-S-30C
Unenclosed flare system
Supplementary pilot fuel:
non-interruptible natural gas
Pilot flame monitoring:
remote
Type of pilot flame monitoring:
heat sensing thermocouples
Flare not equipped wrth
automatic gas shutoff after
loss of flame
Manual reignition required
after loss of flame
Minimum heat content at
burner tip. 1,850BTU/ft3
Flare is operated for
emergency use
8-in. flare stack (F-U503)
Manufacturer. John Zink -
STF-S-8
Unenclosed flare system
Supplementary pilot fuel:
non-interruptible natural gas
Pilot flame monitoring:
remote
Type of pilot flame monitoring:
heat sensing thermocouples
Flare not equipped wrth
automatic gas shutoff after
loss of flame
Manual reignition required
after loss of flame
Minimum heat content at
burner tip: 1,850BTU/fl3
Flare is operated for
emergency use
BU-12.
-------
BU-D: BOILER AND UTILITIES PROCESS
PROCESS STACK SHEET INFORMATION
There is a separate table for each of the three steps described in
Subsection BU-A. The nomenclature for naming tables follows a simple
format:
Process Abbreviation - Subsection Letter.Step Number
, TABLES
Table BU-D.l Storage and Handling Operations
Table BU-D.2 Boiler Operation
Table BU-D.3 Flare Operation
BU-13
-------
Table BU-D.1
Process Stick Information
Storage and Handling Operations Step
Boiler-Utilities Process
New
Stack
Number
U68
070
073
074
Old
Stack
Number
BU-101
BU-102
BU-103
BU-104
Current
Certificate
Numbers
G'fathered
G'fathered
G'fathered
G'fathered
Distance to
Nearest
Property
Line. Feet
1.3* )
657
863
625
Diameter or
Dimensions,
Inches
6
diameter
5
diameter
4
diameter
4
diameter
Discharge
Height Above
Ground,
Feet
24
36
29
29
Exit
Temp. "F
Ambient
90-110
110-150
110-150
Gas
Discharge
Rate,
ACFM
Not Applicable
Not Applicable
Not Applicable
Not Applicable
Discharge
Direction
Downward
Downward
Upward
Upward
BU-14
-------
Table BU-D.2
Process Stack Information
Boiler Operation Step
Boiler-Utilities Process
Old
Stack
Number
042
043
044
New
Stack
Number
BU-201
BU-202
BU-203
Current
Certificate
Numbers
066144
066145
069063
Distance to
Nearest
Property
Line. Feet
844
825
788
Diameter or
Dimensions,
Inches
60
diameter
60
diameter
24
diameter
Discharge
Height Above
Ground,
Feet
60
60
60
Exit'
Temp, *F
300
300
325
Gas
Discharge
Rate.
ACFM
20,000
20.000
7,500
Discharge
Direction
Upward
Upward
Upward
BU-15
-------
Table BU-O.3
Process Stack Information
Flare Gas Recovery and Flart Operation Step
Boiler-Utilities Process
Old
Suck
Number
064A
064B
New
SUck
Number
BU-301
BU-302
Current
Certificate
Numbers
107113
107113
Distance to
Nearest
Property
Line, F et
1.050
1,050
Diameter or
Dimensions.
Inches
8
diameter
30
diameter
Discharge
Height Above
Ground,
Feet
250
250
Exit
Temp, 'F
1,800
1,800
Gas
Discharge
Rate.
ACFM
1.075
12,700*
Discharge
Direction
Upward
Upward
' Gas vent rate under catastrophic worst-case operating conditions is 82,100 ACFM.
BU-16
-------
BU-E: BOILER-UTILITIES PROCESS,
RAW MATERIALS/CONTAMINANT LIST
The list of raw materials and potential air contaminants is listed by
category in Table BU-E.
BU-17
-------
Table BU-E
Raw Materials/Contaminants List
Boiler-Utilities Process
Chemical
Name
Carbon
(Combustion
Particulates)
Natural Gas
including
methane
Hydrocarbons-VOC
(as No. 6 fuel oil)
Hydrocarbons-VOC
(as flare gas)
Cartxn Monoxidi
Oxides of Nitrogen:
N2O
NO
N2O3
N2O4
NO2
N2O5
N3O4
NO3
Sulfur Dioxide
Lead
CAS
Number
7440-44-0
74-82-8
None
None
630-08-0
10024-97-2
10102-43-9
None
None
10102-44-0
10102-03-1
None
None
7446-09-5
7439-92-1
Stepl
Storage and
Handling
Operations
Raw
Matl
No
No
Yes
No
No
No
No
No
No
No
No
No
No
No
No
Release
No
No
Yes
No
No
No
No
No
No
No
No
No
No
No
No
Step 2
Boiler
Operation
Raw
Matl
No
Yes
Yes
Yes
No
No
No
No
No
No
No
No
No
No
No
Release
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes -
Yes
Yes
Yes
Yes
Yes
Yes
Step 3
Flare Recovery
and Flare
Operation
Raw
Ms*
No
Yes
No
Yes
No
No
No
No
No
No
No
No
No
No
No
Release
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
BU-18
-------
Section 2. TECHNICAL INFORMATION
Sources in Huntsman's WE Process, presently containing 187 sources (See
WE Process, Section l.C for complete list of equipment), generate NPO
which is collected by a system of headers, directed to the flare
recovery system, and burned in either one of the boilers for fuel value
(93.5% of recovered flare gas) or the flare (6.5%), resulting in the
emission of air pollutants which result from combustion.
Table 1. Ton Per Year Potential To Emit
The contribution from the storage sources was estimated and is included
in the process level estimate of PTE. The flare sytem is not enclosed
and not subject to pound per hour limits, but it's contributions to Ton
Per Year (TPY) Potential to Emit (PTE) was estimated and is included in
the process level PTE estimate. These PTEs were added to the PTE from
the individual boilers and the sums for the process are reported by
category in Table 1.
Table 2. Pound Per Hour Limits
The applicable limits for Boilers No. 1 and No. 2, coth 80.1 MM Foster-
Wheeler steam generating boilers, are identical. Since different limits
apply when burning different fuels, two sets of limits, one for natural
gas and/or flare gas and the other for No. 6 fuel oil, are listed in
Table 2.
Boiler No. 3 is much smaller, 28.3 MM Btu, and has a separate Table 2
with one set of emission limits.
The flare system and the storage tanks are not required to comply with a
pound per hour limit.
Table 3. Alteration/Amendment Limits
These limits do not apply for this process.
BU-19
-------
TABLE 1: PROCESS LIMITS IN TONS/YR
PROCESS: BOIliER-tTrTLTTTES PROCESS
CATEGORY
Particulates
SUB CATEGORY
Biological
Radionuclide
Hex-chrome
Metal
Asbestos
Dioxin
LOG
HAP-Particulate
Other
(Total)
1. TOTAL
TONS/ YR
0.0
0.0
0.0
0.0
0.0
0.0
0.0
O'.O
40.55
40.55
Volatile Organic
Compounds
2. TOTAL
3. TOTAL
TOTAL
Vinyl Chloride Monomer
Toxic Volatile Organics
Exempt VOS
HAP-VOC (Total)
Other
0.0
0.0
0.0
0.0
30.36
30.36
Acid Gases
HAP-Acid
Acid
0.0
0.0
0.0
Extraordinary
Toxic Gases
HAP-Gases
Other
0.0
0.0
0.0
5. Carbon Monoxide
6. NOx
7. S02
8. Base
83.3
238.63
403.2
0.0
BU-20
-------
TABLE 2: WORST-CASE PERMIT ALLOWABLE UNCONTROLLED EMISSION'
LIMITS FOR BOILER No.l AND BOILER No.2
PROCESS :
EQUIPMENT:
CATEGORY
BOILER-UTILITY PROCESS
Steam Boilers F-U201 and
SUB CATEGORY
Parciculates Biological
1. TOTAL
Volatile Organic
2. TOTAL
Acid Gases
3 . TOTAL
Extraordinary
Toxic Gases
4 . TOTAL
Radionuclide
Hex -chrome
Metal
Asbestos
Dioxin
LOC
HAP- Part icul ate (Total)
Other
Compounds
Vinyl Chloride Monomer
Toxic Volatile Organics
Exempt VOS
HAP-VOC (Total)
Other (Non-Methane VOC)
HAP-Acid
Acid
HAP-Gases
Other
5 . Carbon monoxide
6. NOx
7. S02
8 . Base
F-U202
lb/ha
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
4.2
4.2
0.0
0.0
0.0
0.0
2.4C
2.4°
0.0
0.0
0.0
0.0
0.0
0.0
6.5 c
24.03d
42.1
0.0
lb/hb
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
1.09
1.09
0.0
0.0
0.0
0.0
2.5C
2.5=
0.0
0.0
0.0
0.0
0.0
0.0
6.8=
8.01d
0.1
0.0
a Burning No.6 fuel oil
b Burning natural gas and/or flare gas
c At seven percent oxygen dry value
d NOx may not exceed 0.1 lbs/106 BTU for gas, 0.3 lbs/10s BTU for No.6
BU-21
-------
TABLE 2: WORST-CASE PERMIT ALLOWABLE UNCONTROLLED EMISSION
LIMITS FOR BOILER No.3
PROCESS: BOILER-UTILITY PROCESS
EQUIPMENT: Steam Boiler F-U203
CATEGORY
Parciculates
SUBCATEGORY
Biological
Radionuclide
Hex-chrome
Metal
Asbestos
Dioxin
LOG
HAP-Particulate
Other
(Total)
1. TOTAL
lb/ha
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
1.6
1.6
Volatile Organic Compounds
Vinyl Chloride Monomer
Toxic Volatile Organics
Exempt VOS
HAP-VOC (Total)
Other
2. TOTAL
3. TOTAL
0.0
0.0
0.0
0.0
0.64
0.84
Acid Gases
HAP-Acid
Acid
0.0
0.0
0.0
Extraordinary
Toxic Gases
HAP -Gases
Other
0.0
0.0
4. TOTAL
0.0
5. Carbon monoxide
6. NOx
7. S02
8. Base
1.0
11.0
15.76
0.0
a Burning No.6 fuel oil, natural gas and/or flare gas.
BU-22
-------
Section 3. COMPLIANCE PLAN
A- Applicable
Step 1. Storage and Handling Operations
(1) Fuel Oil No. 6 Storage Tank T-U201 is regulated under and subject
to the terms and conditions of N. J.A.C. 7: 27-5. 2 (a), 7.2, 8. 2 (a) (8),
8.3, 8.9, 9.2, 9.3(b), 9.4, 21.2(a and b)', e£ S£fl. , and N.J.S.A.
26:2C-19.
(2) Storage tanks T-9002, T-700, and T-701 {Caustic and two Epon
Resin Tanks respectively) are regulated under and subject to the terms
and conditions of N.J.A.C. 7:27-5. 2 (a), 8.2(a){8), 8.3, 8.15, 21.2(a
and b) , ejt aejj. , and N.J.S.A. 26:2C-19.
Step 2. Boiler Operation
(1) Boilers No.l and No. 2, FU-201 and FU-202, are regulated under
and subject to the terms and^ conditions of N. J.A.c. 7:27-3. 2(a, b and
c) , 3.6, 4. 2 (a) , 4.3 (a and b') , 4.4 (a, b and c) , 4. 5 (a, b and c) ,
5.2(a), 7.2, 8.2
-------
B. Monitoring and Rerordinp Requirements
The Permittee shall:
1. Maintain all records required below on-site for at least five years
after the recording date. These records must be available for
inspection by representatives of the Department.
Record the following for VOC emissions from each boiler:
(a) Date of operation
(b) Hours of operation
(c) Daily total pounds of VOC emitted.
3. Record for each boiler, the daily hours of operation burning number
6 fuel oil.
4. Obtain certification from each fuel supplier stating that for each
shipment of fuel delivered, the sulfur content of the No.6 fuel oil does
not exceed 0.5% by weight.
5. Within 180 days from the initial operation of the low NOx burners,
and every five years thereafter, conduct stack emissions performance
tests on Boilers No.l and No.2 in accordance with N.J.A.C. 7:27-8.4{c).
Stack tests shall be conducted on each boiler at plus or minus five
percent of the maximum heat input rate of each boiler as specified in
the permit for CO, NOx, SO2 and VOCs for number 6 fuel oil, and for CO,
NOx and VOCs for natural gas. The stack testing shall be conducted to
determine compliance with N.J.A.C. 7:27-9.2, 16.8 and 19.7.
6. At least 60 days prior to the stack test date, the Permittee shall
submit to the Chief, BTS, for approval, a pretest protocol. BTS may
change or require additional pollutants to be stack tested.
7. Conduct all emission performance tests using the method approved by
the Chief, BTS.
8. Contact the Chief, BTS, and the Chief, Regional Enforcement Office
upon approval of the test protocol, to schedule a mutually acceptable
test date.
Additional Monitoring Conditions for Boiler No.l and Boiler No.2
9. The permittee shall maintain an operating log book, strip chart
recorder, or electronic data storage system to track:
BU-24
-------
(a) Hourly fuel usage
(b) Flue gas recirculation damper position and ratio indicated by
damper position.
C- Reporting Reqniremenf.fi
The Permittee shall:
l. Submit to the Department every six months, beginning from the
effective date of this permit, a summary report listing the total tons
emitted for each category and subcategory of contaminants from the BU
Process and from each boiler and the total number of hours each boiler
burned number 6 fuel oil.
2. Within 60 days after completion of any stack testing, submit to the
Chief, BTS, and the Chief, Regional Enforcement Office one copy each of
the emission test report. The test results shall be certified by a
Licensed Professional Engineer or a Certified Industrial Hygenist.
3. Report any non-compliance, of operating requirements directly related
to emission limits, including but not limited to changes in operating
hours, flow rates or temperature, or any non-compliance specified in the
conditions for the permit, in writing, within three working days after
the event, to the Regional Enforcement Officer, unless otherwise
specified in writing by the Regional Enforcement Officer.
D. Operating Condif-ions
1. Except during start-up and shutdown periods, neither period to
exceed 30 minutes, the maximum emissions, from the.. boilers shall not
exceed the limits specified in conditions 2,3 and 4 below.
(a) Start-up shall be defined as the period from the beginning of
fuel ignition until the flame of the burners reaches
stabilization. The duration of the exemption from the emissions
limits specified in Table 2 shall not exceed 30 consecutive
minutes.
(b) Shutdown shall be defined as the beginning of fuel reduction
until the total shutdown of fuel to the boiler. The duration of
the exemption from the emissions limits specified in Table 2 shall
not exceed 30 consecutive minutes.
2. Continuous oxygen monitor and recorder shall be maintained and
operated at the exit of each boiler.
BU-25
-------
3. The Permittee shall operate each boiler so as not to cause it to
emit any air pollutant in amounts that exceed the pound per hour (Ib/hr)
limits specified in Table 2, Section II.
4. The boilers shall not cause any visible emissions, except during
any three minutes out of the 30 consecutive minute start-up and shut-
down period(s).
Operating Conditio' a for Boiler No.l and Boiler No.2
5 The Permittee shall adjust the combustion process of each boiler
each calendar year beginning in" 1995, in accordance with the
.requirements of N.J.A.C 7:27-19.16.
6. The low Nox burners shall be operated at all times the boilers are
operated. Flue gas recirculation shall be' used whenever the boilers are
firing No.6 fuel oil. Flue gas recirculation will not be required while
the boilers are firing natural gas/flare gas unless stack test results
require flue gas recirculation to meet emission limits.
7. Control of the flue gas recirculation system will be accomplished
by the opening and closing of the mototrized flue gas.control dampers.
The control of the damper will be through the output of fuel oil control
system which will concurrently increase or decrease the combustion air
supply. At start-up of the system on No.6 fuel oil, the flue gas
recirculation damper position will be set to minimize CO, toal non-
methane hydrocarbons and NOX emissions. The position of the damper and
the corresponding flue gas recirculation ratio will be recorded so that
the operator can identify, on an on-going basis, whether the damper is
in its proper position. The damper setting will be recalibrated on an
annual basis to ensure optimum performance.
8. By no later than May 31, 1996, the Permittee shall demonstrate
that the boilers are in compliance with the provisions of N.J.A.C. 7:27-
19.
9. The emission of carbon monoxide is not to exceed 80 ppm by volume
on a dry basis at 7V oxygen.
10. The emission of total non-methane hydrocarbons is not to exceed 50
ppm by volume on a dry basis at 7* oxygen.
BU-26
-------
Operating Conditions for Boiler No.3 (FU-203)
11. Boiler No. 3 shall be limited to the burning of number 6 fuel oil
for no greater than 4380 hours per calendar year.
12. Boiler No.3 shall be monitored continuously for flow rate and
oxygen (02) .
Operating Conditions, for the Flare
13. The owner or operator of the flare shall inspect the each year
beginning in 1995 to verify that the flare continues to be operated
-------
portion 4. SPECIAL PROCESS CONDITIONS
Not Applicable.
BU-28
-------
ATTACHMENT B
Consolidated Reporting Format
Intel Corporation
Chandler. AZ Facility
U.S. EPA - Project XL
-------
-------
EXHIBIT 1
CONSOLIDATED REPORT FORMS
INTEL CORPORATION
OCOTILLO CAMPUS
CHANDLER, ARIZONA
This Exhibit presents the proposed consolidated reporting formats fir both the quarterly
and annual reporting on Intel Corporation's progress to achieve the goals established
within our five year environmental master plan for Intel's Ocotillo campus in Chandler,
Arizona. Attached to each report is a glossary of terms to assist in the review of the
information. The data and goals established in the attached documents are.fictitious The
objective in issuing this Exhibit, as part of the Final Project Agreement (FPA), is to
.demonstrate the approach and format to be used in the consolidated reporting. This
document will also satisfy the majority of the requirements for reporting as set forth in the
air permit for the Ocotillo campus.
The Annual Rep'ort-is an expanded presentation of the Quarterly Report. Where
appropriate, the Annual Report also presents breakdowns regarding specific environmental
goals. A summary of the SARA 313 reporting is also presented as part of the Annual
Report. Intel will continue to independently submit Form R to EPA in the required format
so that it can be electronically uploaded into EPA's database.
The Quarterly Report and Annual Report will be available both in hard copy and
electronic version. Intel will operate a Home Page:
http://www.intel.com/other/ehs/projectxl/index.htm
The Quarterly Report will be issued two months after the close of the quarter in order to
allow sufficient time to review all laboratory analyses and quality control the data. The
Annual Report will be issued on or before April 1, following the close of the calendar
year.
Intel will review each Quarterly Report with our Community Advisory Panel. Twice a
year, Intel^ will hold public meetings to review our progress on the five-year environmental
master plan. One of these meetings will be concurrent with the issuance of our Annual
Report.
DO NOT CITE
DATA AND GOALS ARE FOR ILLUSTRATIVE PURPOSES ONLY
Rev. 8 10/30/96
-------
FPA REPORTING REQUIREMENTS
FAB 12/OCOTILLO SITE
Form R
Quarterly FPA
Progress Report
Annual FPA
Report
To EPA
July 1 (each year)
To Public/Agencies 2 months after
quarter close
To Public/Agencies April 1 (each year)
DO NOT CITE
DATA AND GOALS ARE FOR ILLUSTRATIVE PURPOSES O
Rev. 8 10/30/96
-------
DATA IS FICTITIOUS
QUARTERLY
FPA PROGRESS REPORT
QUARTERLY PROGRESS REPORT
DO NOT CITE
DATA AND GOALS ARE FOR ILLUSTRATIVE PURPOSES ONLY
Rev. 8 10/30/96
-------
FPA PROGRESS REPORT
INTEL CORPORATION
OCOTILLO CAMPUS
CHANDLER, ARIZONA
QUARTERLY FPA PROGRESS REPORT
REPORTING FACILITY
Intel Corporation
4500 S. Dobson Road
Chandler, Arizona 85248
Reporting period:
Report prepared by:
Telephone #:
Fax#:
SOLID WASTE RECYCLE
Reporting period: July 1 - Sept. 30, 1996
Percent recycled for quarter: 40%
Percent recycled year-to-date: 36%
SOLID WASTE RECYCLE
FINAL DRAFT - DOCUMENT
-1-
QUARTERLY PROGRESS REPORT
DO NOT CITE
DATA AND GOALS ARE FOR ILLUSTRATIVE PURPOSES ONLY
Rev. 8 10/30/96
-------
NON-HAZARDOUS CHEMTrAT.
WASTE RECYCLE
Reporting period: July 1 - Sept. 30, 1996
Percent recycled for quarter: 27%
Percent recycled year-to-date: 25%
GOAL « 35H
0196
CHEMICAL WASTE RECYCLE
HAZARDOUS WASTE RECYCLE
Reporting period: July 1 - Sept. 3Q, 1996
Percent recycled for quarter: 40%
Percent recycled year-to-date: 38%
owe
COBS
HAZARDOUS WASTE RECYCLE
WASTEWATER REUSE
Reporting period: July 1 - Sept. 30, 1996
Percent recycled for quarter: 100%
Percent recycled year-to-date: 100%
QVS6 CBSS 0395
WASTEWATER REUSE
QUARTERLY PROGRESS REPORT
-2-
DO NOT CITE
DATA AND GOALS ARE FOR ILLUSTRATIVE PURPOSES ONLY
Rev. 8 10/30/96
-------
CTTY WATER REUSE
Reporting period: July 1 - Sept. 30, 1996
Percent recycled for quarter: 57%
Percent recycled year-to-date: 54%
COAL - 55%
CITY WATER REUSE
VOLATILE ORGANIC COMPOUND
EMISSIONS
Reporting period: July 1 - Sept. 30, 1996
VOCs in tons for quarter: 2JL
VOCs in tons year-to-date: 12.4
OPHANTC HAZARDOUS AIR
POLLUTANTS fHAPs) EMISSIONS
Reporting period: July 1 - Sept. 30, 1996
Organic HAPs in tons for quarter: 2J)
Organic HAPs in tons year-to-date: 5J
Z
> 15.
10.
! f? '.<3VH
<» QUM
ax
VOC EMISSIONS
^x>
1 «
f-
< '
U «
Z
z
** Q
2 Q"«
"0,52. I:".' W*
17 QI.M
ORGANIC HAPs
-3-
QUARTERLY PROGRESS REPORT
DO NOT CITE
DATA AND GOALS ARE FOR ILLUSTRATIVE PURPOSES ONLY
Rev. 8 10/30/96
-------
INORGANIC HAZARDOUS ATP
POLLUTANTS
Reporting period: July 1 - Sept. 30, 1996
Inorganic HAPs in tons for quarter: j_9
inorganic HAPs in tons year-to-date:
) B *> *
SNOjO'dVIIDtl
z
2 >
5 o.
u
.i-::r.1.7. i;
13
w
X. 30
^
0-
7i
/. * r
B
-------
SULFUR DIQXroE EMISSIONS
Reporting period: July 1 - Sept. 30, 1996
Emissions in tons for quarter: _LO
Emissions in tons year-to-date: 3.5
5? »
fc 8
u
£ 6
x
I *
I .
SULFUR DIOXIDE EMISSIONS
PARTICULATES (PMltn EMISSIONS
Reporting period: July 1 - Sept. 30, 1996
Emissions in tons* for quarter: 0.6
Emissions in tons year-to-date: 2.5
t
2
»!
PARTICI
0
as io«~
Ismail ..;/
-------
WASTEWATER DISCHARGE MONITORING
PARAMETER
Arsenic
Biochemical
Oxvgen Demand
Boron
Cadmium
Chromium, Total
Copper
Cyanide. Total
Lead
Maneanese
Mercurv
Nickel
Phenolic
Compounds
Selenium *
Silver
Zinc
Oil & Grease
Sulfides. Dissolved
Solids, Total
Suspended
DISCHARGE
POINT IWD-1
DISCHARGE
POINT IWD-2
DISCHARGE
POINT IWD-3
CITY OF
CHANDLER
DISCHARGE
LIMIT fme/L)
0.30
300.00
2.40
0.40
4.40
330
0.40
0.50
48.00
0.30
, 3 70
177.00
1.20
0.90 1
17.00
100.00 |
0.50
350.0
TEST
METHOD
EPA 206.2
EPA 405.1
EPA 200 7
I EPA 213 2
EPA 200 7
EPA 200 7
EPA 335 3
EPA 23 9 2
EPA 200 7
EPA 245 1
EPA 200 7
EPA 420.1
EPA. 270 2
EPA 200. 7'
EPA 200 7
EPA 413. 1
EPA. 376 2
EPA 160.2
All values in milligrams per liter unless noted.
Date of sampling
Average flow rate on the date of sampling
Flow - Daily maximum
Flow - Monthly average
Date reported to City of Chandler
QUARTERLY PROGRESS REPORT
-6-
DO NOT CITE
DATA AND GOALS ARE FOR ILLUSTRATIVE PURPOSES ONLY
Rev. 8 10/30/96
-------
EXCEPTION/INSPECTION REPORTING
1. Reportable quantities released this quarter.
Yes [ ] No [ ]
If yes, date and agency reported to.
Date:
Chemical spilled:
Quantity spilled:
Agency:
2. Wastewater discharge exceedance this quarter.
Yes [ ] No [ ]
If yes, date and agency reported to.
Date:
Agency:
3. Air emissions exceedance this quarter.
Yes [ ]" No [ ]
If yes, date and agency reported to:
Date:
Agency:-
Constituent exceeded:
4. Agency inspection this quarter.
Yes [ ] No [ ]
If yes, date and agency performing the inspection:
Date:
Agency:
Type of inspection:
5. Has the Hazardous Materials Management Plan been revised or updated during this
reporting period?
Yes [ ] No [ ]
If yes, date of change and scope of change:
Date:
Scope:
-7-
QUARTERLY PROGRESS REPORT
DO NOT CITE
DATA AND GOALS ARE FOR ILLUSTRATIVE PURPOSES ONLY
Rev. 8 10/30/96
-------
8.
Has a shutdown or change in type of a pollution control device occurred this
quarter:
Yes [ ] No [ ]
If yes, provide the following information:
Date:
Pollution control device:
Nature of shutdown:
Ag' .icy notified:
Have there been any changes to criteria pollutant emissions factors?
Yes [ ] No [ ]
If yes, list changes with date and reason:
Are any new chemicals being emitted which require screen modeling?
Yes [ ] No [ ]
If yes, ppvide a description of the modeling:
OTHER ACTTVTTES THAT BENEFIT THE ENVIRONMENT
Briefly describe activities implemented this quarter on:
Environmental mentoring/education
Suppliers
Equipment donations
-8-
QUARTERLY PROGRESS REPORT
DO NOT CITE
DATA AND GOALS ARE FOR ILLUSTRATIVE PURPOSES ONLY
Rev. 8 10/30/96
-------
GLOSSARY OF TERMS
CARBON MONOXIDE (CO) - This is defined in section 302, subsection w of the
United States Clean Air Act, as CO means carbon monoxide. This is a combustion
emission produced when fossil fuel is burned (oxidized) incompletely.
CITY WATER REUSE - Effluent from Intel's manufacturing operations will be
separated into two streams (high total dissolved solids effluent and low total dissolved
solids effluent) and sent to the City of Chandler Effluent Treatment and Recharge Facility,
which uses reverse osmosis (RO) to treat the water. The percent of City water reuse is
calculated by dividing the total flow volume in gallons sent to the City of Chandler's RO
facility, divided by the quantity of fresh water purchased by Intel from the City of
Chandler. The City of Chandler can either recharge into the groundwater the treated
effluent or sell the water for reuse.
FPA ANNUAL REPORT - This is a summary of progress against the Final Project
Agreement for the previous calendar year and is published on April 1.
FINAL PROJECT AGREEMENT (FPA) - EPA's Project XL program requires that
each proponent develop a final project agreement that defines specific scope and goals to
be achieved. For Intel, t ie FPA sets forth a five-year Environmental Master Plan for
Intel's Ocotillo site, located in Chandler, Arizona.
FPA QUARTERLY PROGRESS REPORT * This is a progress report that is
published by Intel on the following schedule which documents progress against the goals
established within the FPA:
REPORTING PERIOD
January, February, March
April, May, June
July, August, September
October, November, December
By June 30
By September 30
By November 30
By February 28
HAZARDOUS AIR POLLUTANTS - Hazardous Air Pollutants (HAPs) refers to the
189 chemicals and chemical categories listed in section 112(b) of the United States Clean
Air Act. Under the Act, a major source of HAPs is defined as one that emits 10 tons/yr.
of any single chemical on the list, or 25 tons/yr. of any combination of these chemicals.
HAZARDOUS MATERIALS MANAGEMENT PLAN (HMMP) - An emergency
plan required by the City of Chandler for all operations which store hazardous materials
above a certain quantity on-site.
QUARTERLY PROGRESS REPORT
DO NOT CITE
DATA AND GOALS ARE FOR ILLUSTRATIVE PURPOSES ONLY
Rev. 8 10/30/96
-------
HAZARDOUS WASTE RECYCLE - This category includes materials that are
specifically designated as hazardous waste under EPA's Resource Conservation and
Recovery Act regulations. The percent recycled is calculated by dividing the quantity of
hazardous waste sent off for beneficial recycle and energy recovery by the total quantity of
hazardous waste generated and shipped off-site.
NITROUS OXIDES - In accordance with the definition in section 302, subsection v of
the United States Clean Air Act, NOx refers to oxides of nitrogen. The oxides of nitrogen
typically emitted from combustion processes are nitrogen monoxide (NO) and nitrogen
dioxide (N02).
NON-HAZARDOUS CHEMICAL WASTE RECYCLE - This is used chemical
materials which are collected for the purpose of returning them back into beneficial reuse.
These materials are classified as non-hazardous, based upon EPA's definition set forth
under the Resource Conservation, and Recovery Act (RCRA). The percent recycled is
calculated by dividing the material in this category sent for beneficial reuse, divided by the
total quantity of chemical waste generated.
OTHER ACTTVnTES THAT BENEFIT THE ENVIRONMENT - Intel has
committed to voluntarily engage in other activities which may connect back to programs
implemented by Intel Arizona and/or Intel's corporate programs. The items that will be
reported on include:
Environmental mentoring/education
Donation of equipment
Environmental activities with suppliers
PARTICULATE MATTER (PM) EMISSIONS - Airborne paniculate matter with an
aerodynamic diameter less than or equal to 10 microns (PMio) as defined in 40 CFR
51.100(qq).
REGULATORY AGENCIES - The following are the regulatory agencies associated
with the Intel Ocotillo site Final Project Agreement:
ADEQ - Arizona Department of Environmental Quality
City of Chandler
EPA - U.S. Environmental Protection Agency
MCES - Maricopa County Environmental Services
RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) - Refer to the
statutes and promulgated EPA regulations which address the generation, storage,
treatment and disposal of hazardous waste.
QUARTERLY PROGRESS REPORT
DO NOT CITE
DATA AND GOALS ARE FOR ILLUSTRATIVE PURPOSES ONLY
Rev. 8 10/30/96
-------
REVERSE OSMOSIS (RO) - Reverse Osmosis is a high pressure filtration process
which separates dissolved salt and minerals from water, using a membrane. Clean water .
passes through the membrane, and the salt and minerals are rejected. *
SOLD) WASTE RECYCLE - This includes materials that are designated as non-
hazardous waste, based upon EPA's definitions under the Resource Conservation and
Recovery Act, which include such materials as paper, plastics, aluminum, glass, wood,
pallets, metal, cardboard, etc. The percent recycled is calculated by dividing the quantity
of materials within this category that are sent to beneficial recycle by the total volume of
solid waste shipped off-site.
SULFUR DIOXIDE - This is a special oxide or sulfur which is emitted during the
combustion of fossil fuels.
SUPERFUND AMENDMENTS AND REAUTHORIZATION ACT (SARA) -
TITLE HI - Refers to the statutes and promulgated EPA regulations which address
Emergency Planning and Community Right-to-Know.
TOTAL DISSOLVED SOLIDS - A measurement of the salt and mineral content in
water.
VOLATILE ORGANIC COMPOUNDS - Volatile Organic Compounds (VOCs) are
any compound of carbon which participate in atmospheric photochemical reactions, except
those which are specifically excluded, as defined in 40 CFR 51.100(s). Typically, a major
source is 100 tons per year of emissions.
WASTE WATER REUSE - Intel will use effluent from the City of Chandler's Ocotillo
Wastewater Reclamation Facility (OWRF) for cooling tower make-up and landscaping.
The percentage of wastewater reuse is calculated by the quantity of OWRF effluent used
for landscaping and cooling tower make-up, divided by the total quantity of water used for
landscaping and cooling tower make-up.
QUARTERLY PROGRESS REPORT
DO NOT CITE
DATA AND GOALS ARE FOR ILLUSTRATIVE PURPOSES ONLY
Rev. 8 10/30/96
-------
DATA IS FICTITIOUS
ANNUAL
FPA REPORT
DO NOT CITE .:"- .-..' . ... ; . .
DATA AND GOALS ARE FOR ILLUSTRATIVE PURPOSES ONLY
Rev. 8 10/30/96
-------
INTEL CORPORATION
OCOTILLO CAMPUS
CHANDLER, ARIZONA
ANNUAL FPA REPORT
(ISSUED APRIL 1)
REPORTING FACILITY
Intel Corporation
4500 S. Dobson Road
Chandler, Arizona 85248
Year:
Report date:
Report prepared by:
Telephone #:
Fax#:
SOLID WASTE RECYCLE
SD%
L-EkKCOUfLJ
500 TONS TOTAL FOR 1996
SOLED WASTE RECYCLE
FINAL DRAFT - DOCUMENT
-1-
ANNUAL PROGRESS REPORT
DO NOT CITE
DATA AND GOALS ARE FOR ILLUSTRATIVE PURPOSES ONLY
Rev. 8 10/30/96
-------
NON-HAZARDOUS CHEMICAL
WASTE RECYCLE
40%
200 TONS RECYCLED IN 1996
OAL « 35%
CHEMICAL WASTE RECYCLE
HAZARDOUS WASTE RECYCLE
HAZARDOUS WASTE RECYCLE
80 TONS RECYCLED/ENERGY RECOVERY IN 1996
110 TONS TOTAL HAZARDOUS WASTE IN 1996
WASTEWATER REUSE
TDK
WASTEWATER REUSE
ANNUAL PROGRESS REPORT
-2-
DO NOT CITE
DATA AND GOALS .ARE FOR ILLUSTRATIVE PURPOSES ONLY
Rev. 8 10/30/96
-------
CITY WATER REUSE
GOAL - 55V.
CITY WATER REUSE
VOLATILE ORGANIC COMPOUND
EMISSIONS
40
<* X
z **
c. -r
u _
C ^^ "
0.
20
1
1
1
£1
(
I
t '
! .
1
1956
VOC EMISSIONS
ORGANIC HAZARDOUS AIR
POLLUTANTS fHAPs) EMISSIONS
Xy1»nt
«
2 .
ANICIUI
o » e
Z
S 0.
7.S
**
e
McQianol
7 5 TONS IN 1996
ORGANIC HAPs
Other organic HAPs:
-3-
ANNUAL PROGRESS REPORT
DO NOT CITE
DATA AND GOALS ARE FOR ILLUSTRATIVE PURPOSES ONLY
Rev. 8 10/30/96
-------
INORGANIC HAZARDOUS AIR
POLLUTANTS
Chlorin«
Ofliv
7 TONS IN 1996
Other inorganic HAPs:
£ 8
c
5 «
a
i 4
3 ?
io
&£
';.;::
'
INORGANIC HAPs EMISSIONS
NITROGEN OXIDE fNChrt
EMISSIONS
80
ao
NOx EMISSIONS
CARBON MONOXIDE (CO) r
EMISSIONS *>
--_-__ 70.
Z SO.
o
t4Q.
o "^
10
0.
z
J
106 19BB
CO EMISSIONS
-4-
ANNUAL PROGRESS REPORT
DO NOT CITE
DATA AND GOALS ARE FOR ILLUSTRATIVE PURPOSES ONLY
Rev. 8 10/30/96
-------
STTLFUR DIOXIDE (SO2) EMISSIONS
t
m
8
SO2 EMISSIONS
PARTICULATES
EMISSIONS
TM10 EMISSIONS
Annual fossil fuel usage
Natural gas:
Fuel oil*:
Low sulfur content
ANNUAL PROGRESS REPORT
million cubic feet
gallons
-5-
DO NOT CITE
DATA AND GOALS ARE FOR ILLUSTRATIVE PURPOSES ONLY
Rev. 8 10/30/96
-------
SARA TITLE m (FORM R)
RELEASES AND OFF-SITE
TREATMENT
30 TONS m 1996
CHEMICAL RELEASES
10 TONS IN 1996
OTHER ACTIVITIES THAT BENEFIT THE ENVIRONMENT
Briefly describe activities implement this past year by the Ocotillo site on:
Environmental mentoring/education
Suppliers,
Equipment donations
-6-
ANNUAL PROGRESS REPORT
DO NOT CITE
DATA AND GOALS ARE FOR ILLUSTRATIVE PURPOSES ONLY'
Rev. 8 10/30/96
-------
GLOSSARY OF TERMS
CARBON MONOXIDE (CO) - This is defined in section 302, subsection w of the
United States Clean Air Act, as CO means carbon monoxide. This is a combustion
emission produced when fossil fuel is burned (oxidized) incompletely.
CITY WATER REUSE - Effluent from Intel's manufacturing operations will be
separated into two streams (high total dissolved solids effluent and low total dissolved
solids effluent) and sent to the City of Chandler Effluent Treatment and Recharge Facility,
which uses reverse osmosis (RO) to treat the water. The percent of City water reuse is
calculated by dividing the total flow volume in gallons sent to the City of Chandler's RO
facility, divided by the quantity of fresh water purchased by Intel from the City of
Chandler. The City of Chandler can either recharge into the groundwater the treated
effluent or sell the water for reuse.
FPA ANNUAL REPORT - This is a summary of progress against the Final Project
Agreement for the previous calendar year and is published on April 1.
FINAL PROJECT AGREEMENT (FPA) - EPA's Project XL program requires that
each proponent develop a firal project agreement that defines specific scope and goals to
be achieved For Intel, the FPA sets forth a five-year Environmental Master Plan for
Intel's Ocotillo site, located in Chandler, Arizona.
FPA QUARTERLY PROGRESS REPORT - This is a progress report that is
published by Intel on the following schedule which documents progress against the goals
established within the FPA:
REPORTING PERIOD
January, February, March
April, May, June
July, August, September
October, November, December
DATE PUBLISHED
By June 30
By September 30
By November 30
By February 28
.HAZARDOUS AIR POLLUTANTS - Hazardous Air Pollutants (HAPs) refers to the
189 chemicals and chemical categories listed in section 112(b) of the United States Clean
Air Act. Under the Act, a major source of HAPs is defined as one that emits 10 tons/yr.
of any single chemical on the list, or 25 tons/yr. of any combination of these chemicals.
HAZARDOUS MATERIALS MANAGEMENT PLAN (HMMP) - An emergency
plan required by the City of Chandler for all operations which store hazardous materials
above a certain quantity on-site.
ANNUAL PROGRESS REPORT
DO NOT CITE
DATA AND GOALS ARE FOR ILLUSTRATIVE PURPOSES ONLY
Rev. 8 10/30/96
-------
HAZARDOUS WASTE RECYCLE - This category includes materials that are
specifically designated as hazardous waste under EPA's Resource Conservation and
Recovery Act regulations. The percent recycled is calculated by dividing the quantity of
hazardous waste sent off for beneficial recycle and energy recovery by the total quantity of
hazardous waste generated and shipped off-site.
NITROUS OXIDES - In accordance with the definition in section 302, subsection v of
the United States Clean Air Act, NOx refers to oxides of nitrogen. The oxides of nitrogen
typically emitted from combustion processes are nitrogen monoxide (NO) and nitrogen
dioxide (NO2).
NON-HAZARDOUS CHEMICAL WASTE RECYCLE - This is used chemical
materials which are collected for the purpose of returning them back into beneficial reuse.
These materials are classified as non-hazardous, based upon EPA's definition set forth
under the Resource Conservation and Recovery Act (RCRA). The percent recycled is
calculated by dividing the material in this category sent for beneficial reuse, divided by the
total quantity of chemical waste generated.
OTHER ACTIVITIES THAT BENEFIT THE ENVIRONMENT - Intel has
committed to voluntarily engage in other activities which may connect back to programs
implemented by Intel Arizona and/or Intel's corporate programs. The items that will be
reported on include:
Environmental mentoring/education
Donation of equipment
Environmental activities with suppliers
PARTICULATE MATTER (PM) EMISSIONS - Airborne paniculate matter with an
aerodynamic diameter less than or equal to 10 microns (PMio) as defined in 40 CFR
51.100(qq).
REGULATORY AGENCIES - The following are the regulatory agencies associated
with the Intel Ocotillo site Final Project Agreement:
ADEQ - Arizona Department of Environmental Quality
City of Chandler
EPA - U.S. Environmental Protection Agency
* MCES - Maricopa County Environmental Services
RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) - Refer to the
statutes and promulgated EPA regulations which address the generation, storage,
treatment and disposal of hazardous waste.
ANNUAL PROGRESS REPORT
DO NOT CITE
DATA AND GOALS ARE FOR ILLUSTRATIVE PURPOSES ONLY
Rev. 8 10/30/96
-------
REVERSE OSMOSIS (RO) - Reverse Osmosis is a high pressure filtration process
which separates dissolved salt and minerals from water, using a membrane. Clean water
passes through the membrane, and the salt and minerals are rejected.
SOLED WASTE RECYCLE - This includes materials that are designated as non-
hazardous waste, based upon EPA's definitions under the Resource Conservation and
Recovery Act, which include such materials as paper, plastics, aluminum, glass, wood,
pallets, metal, cardboard, etc. The percent recycled is calculated by dividing the quantity
of materials within this category that are sent to beneficial recycle by the total volume of
solid waste shipped off-site.
SULFUR DIOXIDE - This is a special oxide or sulfur which is emitted during the
combustion of fossil fuels.
SUPERFUND AMENDMENTS AND REAUTHORIZATION ACT (SARA) -
TITLE m - Refers to the statutes and promulgated EPA regulations which address
Emergency Planning and Community Right-to-Know.
TOTAL DISSOLVED SOLIDS - A measurement of the salt and mineral content in
water.
VOLATILE ORGANIC COMPOUNDS - Volatile Organic Compounds (VOCs) are
any compound of carbon which participate in atmospheric photochemical reactions, except
those which are specifically excluded, as defined in 40 CFR 51.1QO(s). Typically, a major
source is 100 tons per year of emissions.
WASTE WATER REUSE - Intel will use effluent from the City of Chandler's Ocotillo
Wastewater Reclamation Facility (OWRF) for cooling tower make-up and landscaping.
The percentage of wastewater reuse is calculated by the quantity of OWRF effluent used
for landscaping and cooling tower make-up, divided by the total quantity of water used for
landscaping and cooling tower make-up.
ANNUAL PROGRESS REPORT
DO NOT CITE
DATA AND GOALS ARE "FOR ILLUSTRATIVE PURPOSES ONLY
Rev. 8 10/30/96
-------
ATTACHMENT C
Massachusetts Department of Environmental Protection
Printers Partnership Program
Multimedia Self-Certification Form
-------
-------
ATTACHMENT Jf£
SELF-CERTIFICATION STATEMENT
MASSACHUSETTS PRINTERS PARTNERSHIP
IA/ uu ThJS ^elf-Certification Statement accompanies the
Workbook, A Self-Certification Guide for r«mm»,,..-.i p
30
'
f " *'« °" ovembr
Pr°9ram' th* Printers Partnership will be evaluating
thP ,, . < , - o ' rsp w
the use and applicability of this Self-CertificatioM for adoption as a final rule.
? be-3 p!rtner' vou must comP'V with the requirements (items in bold type face) in
?*"*"* W0rkb°°k- ln addition' you must Complete
urn .t, along with the appropriate Parsnip
I ,
below) to PEP no later than May 15. 1996:
Massachusetts Printers Partnership (MP2)
Department of Environmental Protection
P.O. Box 4062
Boston, Massachusetts 0221 1
Why You Should Join the Partnerhip
You can replace multiple PEP Permits with one Self-Certification Statement-
The Partnership self-certification statement takes the place of the following DEP permits or
reg.strat.ons from the date that you submit it to DEP through June 30, 1 997:
Sewer discharge permit
Class A recycling permit (for free-standing "batch" silver recovery systems)
Air source registration
Air emissions plan approvals
Note: There are certain circumstances in which you may still need an air plan approval in
order to join the Partnership. Page 5 of the workbook describes four situations when you
must contact DEP for a decision as to whether you need a plan approval.
If you don't join, you may have to obtain these permits or registrations, and pay the fees
associated with them.
Safe Harbor:
By joining the Partnership, you get a "safe harbor" for past non-compliance. Except for
certain circumstances described on page 5 of the workbook, this means that DEP will not
enforce against you for past non-compliance (i.e., for not having a sewer discharge permit)
if you join the Partnership. If you don't join, you will be placed on a "priority" list for DEP
inspection. If you are not in compliance when you are inspected, you will be subject to an
enforcement action, which may include penalties for being out of compliance in the past.
-------
Reduced Fees:
When you submit your Self-Certification Statement and join the Partnership, you must pay
a fee (which covers the cost of targeted technical assistance being provided by DEP to
printers). However, the Partnership fees are much less than the fees you may have to pay
if you don't join. Currently, printers may be paying DEP up to $1,000 for permits (not
including consultant fees) and up to $500 each year for compliance fees. The Partnership
fees range from 0-$500 depending on the number of employees. This fee, which may be
waived for companies who would not be otherwise required to obtain a permit or pay an
annual compliance fee, replaces all DEP permits and compliance fees (except for certain air
permit fees, see page 5 of the workbook for situations requiring special review) through
June 30. 1997.
Increased Profits:
By helping develop more environmentally-sound practices, the Partnership intends to
reduce pollution, enhance public health, and increase compliance with environmental
regulations. The Partnership will reduce costs and liability associated with the use,
management, and disposal of polluting substances, thereby making participants more
profitable and competitive.
For information about eligibility, review pages 5 and 6 of the workbook. You may also call
DEP for assistance (617-292-5838.)
Partnership Fee
When you submit your Self-Certification Statement, you must pay the appropriate
partnership fee, unless you are fee-exempt. This fee will cover the cost of targeted
technical assistance and replace certain permit and annual compliance fees wh.ch might
apply in 1996.
You are "fee-exempt" if you satisfy ALL of the following:
you are a Very Small Quantity Generator of hazardous waste, and,
you are a "Small" printer for air pollutants (see p. 21 and p. 26 of the workbook),
and
you DO NOT discharge wastewater to either a sewer or septic system.
If your company is not fee-exempt, you will submit a check, based on your total number of
employees, payable to: Commonwealth of Massachusetts
1-20 employees: $1OO
21-69: $300
70 or more: $500
-------
Completing the Self-Certification Statement:
.Read the workbook through once to find the items which are easily answered then
'fc h°S*WhiCh Wi" require more at
-------
Federal Taxpayer Identification Number:
Number of Full-time Employees: _
Number of Part-time Employees:
Type of Printing Operation (list number of presses for all that are applicable):
Non Heatset Offset Lithography Heatset Offset Lithography ,
Sheetfed Webfed Other Heatset
Letterpress Prepress Bookbinding
Screen Printing Flexography Gravure
Coating Platemaking Silver Recovery Unit
Wastewater Information (refer to Appendix B in the Workbook and check the one that
applies)
sewer discharge in MWRA sewer district
sewer discharge in non-MWRA district
discharge to septic system/cesspool
Do you discharge less than 25,000 gallons of combined industrial and sanitary waste per
day?
If. you have a sewer use permit from the MWRA or another sewer authority, complete the
following:
Date. Permit Obtained:,
Permit Expiration Date:
Indicate how much fountain solution you discharge (check the one that applies):
less than or equal to 55 gals/month
more than 55 gals/month
What is your hazardous waste generator status? (Refer to p. 14 of the workbook.)
Hazardous Waste: VSQG SQG LOG
Waste Oil: VSQG SQG
What is your generator identification number?
Based on your press or screen cleaning solvent usage, as a lithographer or screen printer,
your size category is: (See p. 21 of the workbook.)
Remember that if you do both nonheatset offset lithographic/screen printing and. water-based
flexograph,c/gravure priming, you must call DEP (617-292-5838) for a determinate of your eligibility to
participate in the Partnership.
Small:
less than or equal to 275 gals/yr
-------
Midsize: greater than 275 gals/yr & less than or equal to 3000 gals/yr
[Attach copy of p. 36 of the Workbook, or comparable VOC calculation information, for
each press/screen cleaning product, except for incidential materials of which you use less
than 12 gals, per product per year.)
Large: greater than 3000 gals/yr [Attach copies of pp. 45-46 of the Workbook or
comparable VOC calculation information, for each VOC-containing product, except for
incidental materials.]
Based on your water-based ink usaga, as a flexographic or rotogravure operation, your size
category is: (See p. 25 of the Workbook.)
Small: less than 20,000 pounds during past 12 months
Midslze: greater than 20,000 pounds but less than 150,000 pounds during the past
12 months [Attach documentation of your calculation.!
Lar9e: greater than 150,000 pounds during the past 12 months [Attach
documentation of your calculation.]
If you have an air permit, complete the following:
Date Permit Obtained: _
Permit Expiration Date:
_ Date Permit Obtained:
Permit Expiration Date:
DESCRIPTION OF ACTIVITIES BY OPERATION
Note: The items in bold are required; they are conditions you must meet to participate in
the Partnership. The italicized items are optional; they are pollution prevention
opportunities or recommendations for other environmentally sound practices that DEP
encourages you to adopt. Other items are provided as information for you and do not
require you to act. Each numbered question in the Self-Certification Statement
corresponds to the same numbered question in the workbook. Answer each question by
checking the box for Yes, No, or N/A (not applicable).
PREPRESS OPERATIONS
1. Facilities on sewer.
1 A. Our facility is on a sewer system, and we do not discharge untreated silver-bearing
photoprocessing wastes to the sewer.
Yes D No D N\A D
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18. Our facility is on a sewer system, and we discharge to the sewer only treated silver-
bearing photoprocessing wastes that meet the 2 ppm discharge limit for silver.
Yes G No D N\A G
2. Facilities on septic systems or cesspools.
You may check both 2A and 2B.
2A. Our facility is on a septic system or cesspool, and we do not discharge any industrial
waste or process chemicals to the system.
Yes D No D N\A D
2B. Our facility is on a septic system or cesspool, and we have our fixer, developer, and
rinsewater hauled by a licensed hazardous waste transporter or permitted precious
metal transporter, or by septage hauler (if the waste in not hazardous), or we are a
VSQG and self-transport to another hazardous waste generator.
Yes G No D N\A D
3. Disposal at sinks.
We have placed a sign prohibiting disposal of hazardous waste and waste ink at our
sinks.
Yes G No D- N\A ;_j
4. Silver recovery systems and t: insporters.
4A We have a properly engineered and maintained silver recovery system which
discharges only treated silver-bearing wastes to the sewer system. We test our
wastewater annually and keep records of such testing to ensure that we do not exceed
the 2 ppm silver discharge limit. We also train our employees in proper operation and
maintenance of silver recovery equipment and in spill procedures.
Yes D No D N\A G
For free-standing batch recovery systems only, the volume of silver-bearing waste we
treated during the past calendar year: _ __ - (See p. 27 of the
workbook.)
4B We use a MA DEP licensed hazardous waste hauler or permitted precious metal
transporter to remove §H silver-bearing wastes [i.e., fixer solutipn] and we retain the
manifest paperwork related to such waste removal for a minimum three-year penod.
Yes D No D N\A D
4C. We do not use a licensed hauler. We are a registered VSQG and we self-transport our
waste to: Name: _______ _ - - - -
Location: _
Yes G
No G
N\A LJ
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4D. We have a septic system or cesspool, we have a silver recovery unit, and we do not
discharge the treated silver-bearing waste to the septic system or cesspool.
Yes Z No 3 N\A Z
5. Platemaking operations.
5A. We do not engage in any platemaking operations.
Yes Z No D N\A G
58. We have platemaking operations and we use only, non-hazardous aqueous-based
platemaking chemistry.
Yes a
No D
N\A G
5C. We have an acid-based platemaking process for engraving plates and we either ship all
platemaking wastes off -site as hazardous waste fir we are a VSQG and we self -
transport our hazardous waste, or we have an appropriate pre-treatment system.
Yes Z' No G. N\A D
50. We have platemaking operations which utilize a solvent-based system and we have the
wastes removed by a licensed hazardous waste hauler, or we are a VSQG and we self-
transport our hazardous waste.
Yes 2 No D N\A G
Pollution prevention opportunities in prepress operations
6. Floating lids.
If applicable, we use floating lids on our mixed photochemical reservoirs to maximize
solution life by reducing air exposure to the chemistry.
Yes Z No Z N\A Z
7. Tray processing.
We do tray processing of film.
Yes Z No D
N\A G
7A. When we leave the chemistry in the trays overnight, we cover the trays to
minimize evaporation. Remember, untreated silver-bearing waste from tray processing
may not be disposed of down the drain.
Yes G No G N\A G
8. Digital technologies.
We have investigated the use of direct-to-film/plate digitalpre-press equipment.
Yes G No G N\A G
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9. Photographic film recycling.
We recycle all of our waste photographic film.
Yes Z No D N\A Z
10. Rinsewater flow.
We regularly monitor the flow rate, or if applicable, the recirculation rate, of rinsewater
in film and plate processing equipment to ensure it complies with manufacturer's
specifications and minimizes water usage.
Yes D No D N\A D
11. Financial analysis of rinsewater circulation systems.
We have conducted a financial analysis to determine if fixer, developer, or rinsewater
recirculation systems are appropriate for our facility.
Yes D No d N\A D
12. Venting fumes.
We vent fumes from photoprocessing equipment to the exterior of our building if the
equipment was originally designed to be vented.
Yes D No d N\A D
13. tazardous waste requirements.
We have reviewed the hazardous waste requirements on pp. 12-18 in the workbook,
and we maintain compliance with them.
Yes Z No D N\A Z
PRESSROOM OPERATIONS ^
14. Container covers. / *"
Both 14A and 14B are requirements.
14A. We keep containers of hazardous waste covered, except when adding waste.
Yes D No D N\A D
14B. We keep containers of new and used solvent closed/covered when they are not in
use.
Yes D No D N\A D
14C. We have a parts cleaner which uses solvents, and we keep it covered when it is not
in use. Write N/A if you do not have a parts cleaner or if your parts cleaner has a
remote solvent reservoir.
Yes D No D N\A 3
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1 5. Waste presswash and liquid waste ink disposal.
We do not discard waste presswash or liquid waste ink in the trash
Yes _ No G N\A G
16. Waste discharge to sewer or septic system.
16A. We do not discharge any warte ink, petroleum products, or regulated solvents to the
sewer.
Yes G No D N\A G
168. We do not discharge any process chemicals to our septic system.
Yes D No G N\A D
17. Solid and liquid waste ink.
17A. We have evaluated our waste inks and determined they are hazardous, we manage
them as a hazardous waste and we have them hauled away as hazardous wastes by a
licensed hauler.
Yes G No G N\A G
17B. We have not evaluated our waste inks to determine if they are hazardous, so we
assume they are hazardous, we manage them as a hazardous waste, and we have
them hauled away as hazardous-wastes by a licensed hauler.
Yes _ No G N\A G
17C. We have evaluated our waste inks and determined they are i it hazardous.
Yes _ No _ N\A G
18. Waste ink cans.
We do not place waste ink cans in the trash until we have removed sufficient amounts
of residual ink to_render them "empty" (as defined on p. 31 of the Workbook).
Yes u_ No G N\A G
19. Presswash disposal.
We do not dump waste presswash into our container(s) of used industrial wipers (rags).
Yes D No D N\A D
20. Precleaning.
20A. We do not wash printing equipment in our sinks without precleaning, since the
equipment may^contain residual inks or solvents.
Yes G No G N\A G
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205. We wash printing equipment in our sinks, but we preclean items with industrial
wipers.
Yes - No u N\A D
21. Rags and wipers.
21 A. We use wipers in such a manner that they do not become "saturated" and we return
our used wipers to an industrial laundry.
Yes D No D N\A D
21B. We produce saturated wipers, but we do not send them back to our industrial laundry
until we have removed th« free liquid, and we manage the removed liquid as a
hazardous waste.
Yes D No D N\A u
21C. We produce saturated or disposable wipers and we manage them as a hazardous
waste.
Yes D No D N\A D
22. Contaminated rag storage.
We store all of our ink-contaminated rags and other solvent-contaminated cleaning
materials in closed metal containers.
Yes 2 No D N\A D
23. Spill cleanup materials.
We manage miscellaneous contaminated absorbents and spill clean-up materials such as
"speedy-dri." absorbent "socks," and "pigs" as hazardous wastes, if applicable. We
manage oily debris in accordance with DEP's requirements on p. 32 of the workbook
(Question 23).
Yes a No D N\A H
Pollution prevention opportunities in the pressroom
24. Alternative inks.
We have tried soy-based or other non-petroleum-based inks, and we use them when
feasible.
Yes D No D N\A D
We have tried UV curable or water-based inks, and we use them when feasible.
Yes D No D N\A D
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We have tried near zero VOC ink/presswash systems for our nonheatset lithographic
operations, and we use them when feasible.
Yes H No D N\A G
25. Ink conservation/reuse.
We have evaluated ink conservation/reuse options including:
Yes G No a N\A C
(check all that apply)
9 Installation of automatic ink levelers at fountains (applicable to web presses)
* - Software programs designed to promote the reuse of inks through custom mixing
_ Managing inventories on a first-in, first-out basis
_ Use of spray preservatives to prevent ink from drying in fountains overnight
_ Ink recycling systems
_ Job scheduling procedures designed to minimize the need to change ink in
fountains
_ Enclosing or covering ink 'fountains or trays on our presses
_ Avoidance of letting ink "skim over" in cans and replacement of covers when ink
is not in use
26. Solvent reduction, (check those which apply)
To minimize so/vent use and waste we are:
_ Using pumps on solvent containers with a proper fit to minimize spills and
evaporation
Monitoring solvent quantity use by different press operators to insure the lowest
quantity is.being used per wash-up
Inspecting our wash-up blade to insure it is in good condition and has the proper
angle against rollers
Developing ways to reuse used solvent for gross cleaning
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Pollution prevention opportunities for screen printing operations
As a screen printer we are (check those which apply):
Using spray bottles to apply ink removal product
Using plunger type solvent dispensers to minimize use
Reusing shop towels to reduce ink remover use
Avoiding delays in removing the ink from the screen once the print run is
completed
Using a manual spot application of chemicals and alternative rinses where
possible
Keeping chemicals in safety cans or covered containers between uses to
minimize chemical losses from evaporation and/or spills
Recovering solvent from rags for reuse (be cautious of solvents: do not choose
this option if the solvents have a flash point of less than 100° F)
Recovering used cleaning product and chemical overspray for reuse
We have evaluated low VOC, low vapor pressure, and water miscible
presswash products as part of an effort to reduce VOC emissions associated with
press/screen cleaning operations.
Items 27-30 relate to clean air requirements.
27. VOC printer category for nonheatset offset lithographic and screen printing.
If you do only water-based flexographic/gravure printing, enter N/A here and skip to
question number 33.
Yes G No D N\A G
27A. Small Printer Category.
We have reviewed our purchase orders and determined that, except for.incidental
materials of which we used less than 12 gallons per product per year, we have not
purchased and/or used more than 275 gallons of press and/or screen cleaning solvents
and not more than 55 gallons of alcohol during the past 12 months. We comply with
the record-keeping requirements on p. 21 of the workbook.
Note: If you use more than 55 gallons of alcohol per year, you are categorized as a
Midsize Printer.
Yes D No D N\A D
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27B. Midsize Printer Category.
We purchased and/or used more than 275 gallons but have determined that we used
less than 3,000 gallons of any press and/or screen cleaning solvents.
Yes C No D N\A G
We used less than 275 gallons of press and/or screen cleaning solvents but more than
55 gallons of alcohol, during the past 12 months (except incidental materials of which
we use less than 12 gallons per product per year). We comply with the record-keeping
requirements for midsize printers on p. 22 of the workbook.
Yes D No D N\A Hi
Based on just our VOC-containinq press/screen cleaning solvent, our VOC emissions
are tons per year.
27C. Large Printer Category.
We used more than 3,000 gallons of VOC-containing press/screen cleaning solvents
during the past 12 months (except incidental materials of which we use less than 12
gallons per product per year) and have made the calculations necessary to determine our
actual emissions of VOC's from our inks, cleaning solutions and fountain solution. We
comply with the record-keeping requirements for large printers on p. 23 of the
workbook.
Yes G No D N\A G
Our actual t lissions were tons, during the past twelve months.
28. Non-heatset lithographic printers (midsize and large only).
For non-heatset lithographic printers, one or both of the following best describes our
operation:
28A. We have evaluated low VOC, low vapor pressure, and water miscible press wash
products as part of an effort to reduce VOC emissions associated with press cleaning
operations.
Yes D - No D N\A D
28B. We use only presswash, blankatwash, rollerwash and solvent products which arc 30
% or less VOC by weight, or which have a composite vapor pressure of less than or
equal to 10 mm Hg at 68° F. (Incidental materials are not subject to this requirement.}
Yes D No D N\A D
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29. Lithographic fountain solutions for non-heatset offset sheet-fed presses (midsize and
large only).
For non-heatset offset sheet-fed presses, one of the following three describes our
fountain solutions:
29A. We use fountain solution mixtures which do not contain alcohol and are now using
only alcohol substitutes.
Yes D No D N\A G
255. Our total facility-wide use of alcohol is less than 5 gal/ons per month (approximately
I drum per year).
Yes G No D N\A G
29C. If our fountain solution contains alcohol, the total concentration of alcohol does
not exceed 5 percent by volume unrefrigerated, or 8 percent by volume refrigerated
(60° F). or we use alcohol in combination with VOC-containing alcohol substitutes in
concentrations not exceeding the 5% or 8% VOC content limit.
Yes D No D N\A D
30. Web-fed presses, including newspapers (midsize and large only).
One of the following describes our fountain solutions:
3OA. We use only alcohol substitutes in our fountain solutions.
Yes G No G N\A G
30B .We are a newspaper, and we do not use alcohol in fountain solution.
Yes G No G N\A G
30C. If our fountain solution contains alcohol, the total concentration of alcohol does not
exceed 1.6% unrefrigerated or 3% refrigerated by volume (60° F.).
Yes G No G N\A G
31. Fountain solution and cleanup solution.
31 A. We do not discharge any waste fountain solution to the sewer system.
Yes G No G N\A G
31B. Our facility discharges less than 55 gallons per month of fountain solution to the
sewer.
Yes D No G N\A G
31C. Our facility is in the MWRA district (see Appendix B in the workbook), discharges
more than 55 gallons per month of fountain solution, and we are aware that we need
MWRA approval to discharge our fountain solution to the sewer.
Yes G No G N\A G
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31D. Our facility is not in the MWRA district, we discharge to a sewer, and we are aware
that discharge of fountain solution could be regulated by our sewer authority.
Yes G No D N\A G
31E. Our facility is on a septic system and we do not discharge any waste fountain
solution.
Yes D No D N\A D
31F. Our facility generates waste fountain solution, has determined it is hazardous, and
manages it as a hazardous waste.
Yes D N- D N\A D
32. Pollution prevention opportunities for fountain solutions and press cleaning
32A. We have conducted a financial analysis to determine the economic feasibility of
installing fountain solution chilling equipment to reduce evaporation of VOC-containing
materials.
Yes D No a N\A D
328. We have conducted a financial analysis to determine the economic feasibility of
installing a centralized fountain solution dispensing unit that will minimize VOC
emissions and material use.
Yes D No D N\A G
32C. We have conducted a financial analysis ft 'determine if the installation of automatic
blanket washers is technically and economically feasible.
Yes D No G N\A G
33. Water-based flexographic and rotogravure operations.
If we use an evaporator to reduce the volume of unusable water-based inks at our
facility, we have determined whether the residual ink sludge is non-hazardous or
hazardous. If it is hazardous, we manage it as a hazardous waste.
Yes G No D N\A G
33A. Small printer category
We have reviewed our purchase orders and determined that we have not purchased
and/or used more than 20,000 pounds of water-based inks during the past 12 months.
We keep records supporting this determination for at least three years.
Yes G No D N\A D
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33B. Midsize printer category
We have reviewed our purchase orders and determined that we have used more than
20.000 pounds but less than 150,000 pounds of water-based inks during the past 12
months. We keep records supporting this determination for at least three years.
Yes C No D N\A G
Based on a calculation of just our inks, we believe that our actual VOC emissions are
tons per year.
33C. Large printer category
We used more than 150,000 pounds of water-based inks during the past 1 2 months
and have made the calculations necessary to determine our actual emissions of VOCs
from our inks, ink additives, and cleaning solutions. We keep records supporting this
determination for at least three years.
Yes D No G N\A G
Our actual emissions were tons during the past 1 2 months.
Pollution prevention opportunities for flexographic aad rotogravure operations
We use water-based inks with less than 10% VOC content as applied on the
press.
We minimize the addition of alcohol or other solvents to our inks as used on the
press.
We reclaim our waste ink onsite or send it off site for reclamation.
We work out our leftover inks using computer software or by following supplier
instructions.
We use an evaporator in our facility to reduce the volume of our waste ink.
We have conducted an energy analysis to determine if the evaporator is more
economical than other offsite disposal alternatives without volume reduction.
34. Coating operations.
34A. We have reviewed the MSDS for our coating products and have determined based on
the VOC content of these products that we emit less than 15 pounds of VOC per
coating line per day.
Yes D No D N\A G
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34B. We have reviewed the MSDS for our coating products and have determined based on
the VOC content of these products that we emit greater than 15 pounds of VOCs per
coatinq line per day, and, for each coating line that emits more than 15 pounds of
VOCs per day, our emissions do not exceed 4.8 pounds of VOCs per gallon of solids
applied.
Yes D No D N\A G
34C. Our priming operations include solvent-based paper surface coating operations, and
we have evaluated ways in which we could reduce our VOC emissions.
Yes D No D N\A D
34D. We have changed our coatings (both in-line and off-line) and we use only aqueous-
based coatings.
Yes D No D N\A D
34E. We have moved to UV curing of our coatings.
Yes D No G N\A G
POSTPRESS OPERATIONS
35. Bindery practices.
We practice the following in our bindery:
35A. We usually use only water-based or animal-based adhesives, and we try to avoid
using bindery adhesives containing chlorinated solvents.
Yes G No G N\A G
35B. We use bindery adhesives containing chlorinated solvents, and we manage the
waste adhesives as hazardous waste.
Yes D No G N\A D
35C. We do not use chlorinated solvents to clean residual adhesives from our equipment.
Yes G No G N\A G
36. Disposal at sinks.
We have placed a sign prohibiting disposal of hazardous waste and waste ink at our
sinks.
Yes G No G N\A D
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Opportunities for cost savings in m»n»ging your solid waste
_ We recycle our waste aluminum printing plates.
_ AS P*1* of an effort to minimize waste packaging materials we try to
purchase products in as large a container as possible without purchasing in
quantities which promote waste due to spoilage.
___ We recycle waste paper.
_ We recycle waste corrugated.
.. We ask our materials vendors to take back waste containers/packaging
when possible.
_ ,__ We recycle used or broken shipping pallets.
* _ We have produced Written information about f/?e e
printing and we make this information available to our customers.
impsct of
. _ We post a list of the "greener" products we are using so that our
customers know that we are making an effort to be environmentally responsible.
Certification
» » * Based on my discussion with individuals responsible for obtaining the information
set forth in this document, I certify that the information is true, accurate, and complete. I
also certify that I have reviewed this Self-Certification Statement and the Massachusetts
Printers Partnership Workbook dated Winter 1996, and will maintain my facility in
compliance with the requirements in those documents. I am aware that there may be
significant penalties, including, but not limited to possible fines, for willfully submitting
false, inaccurate, or incomplete information.
Signature of Owner, General Partner or Officer of the Corporation:
Print Name:
Title.
Date
U.S. Government Printing Office: 1997 - 514-003/60601
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