Materials Accounting. From DEP TUR Plan Deficiencies: Chemicals Used

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1 Materials Accounting Jeff Bibeau, REM, TURP Associate Principal Compliance Manager Tighe & Bond Consulting Engineers Westfield, MA Toxics Use Use Reduction Institute University of of Massachusetts Lowell 1 Measure Success Implement Plan Pre-Plan Characterize Process Save Documentation of Identify TUR Actions and Options Analyses Materials Accounting Accounting Elements Threshold Determinations Production Activities Byproducts and Emissions Materials Inventories Mass Balancing Material Accounting Problems Review and Certify Plan Screen & Evaluate TUR Options Decide What, How, When to Implement From DEP TUR Plan Deficiencies: Chemicals Used PURPOSE TOTAL AMOUNTS & AMOUNTS PER UNIT OF PRODUCT used, generated as byproduct, and released BYPRODUCT FATE: amounts released on site, treated on site and off site, recycled on site and off site, reused onsite, disposed of on site and offsite EMISSIONS TO EACH MEDIA: amounts released on site, disposed on site, transferred off site, and treated, recycled and disposed of off site to air, surface water, ground water, and land 3 1

2 DEP TUR Plan Deficiencies: Chemicals Used Chemical use / byproduct / emissions per unit of product Byproduct fate details Emissions to media details What s Involved? STEP 1: PROCESS MAPPING identify processes define WHERE inputs enter define WHERE outputs leave chemical pathway analysis STEP 2: PRODUCTION UNIT INFO identify PURPOSE OF TOXIC identify PRODUCT identify PRODUCTION UNIT identify UNIT OF PRODUCT QUALITATIVE QUANTITATIVE STEP 3: MATERIALS ACCOUNTING define HOW inputs are used define HOW outputs leave define prices/volumes identify losses Definitions Materials Accounting Process Characterization Create Process Flow Diagrams Chemical Pathway Analysis ID and Locate Chemical Inputs & Outputs Materials Accounting Quantify Inputs & Outputs 6 2

3 SARA Title III, TRI Inventory of Releases to Environment TURA May require additional analyses/monitoring from Production Unit 7 TURA Plan: Material Accounting Requirements Threshold Determinations Manufactured, processed, and otherwise used Production Activities Determination of unit of product Byproducts and Emissions Definition of byproduct and emission 8 TURA Thresholds Manufactured and Processed Otherwise Used Higher Hazard Substances PBTs 25,000 lbs 10,000 lbs 1,000 lbs varies Specific Rules Mixtures Compound Categories On site Reuse/Recycle De Minimis Exemption (1.0%, or 0.1% for carcinogens) 9 3

4 Sources Of Chemical Use Data Toxic Chemical Procurement (Purchasing) Raw Material Purchasing Records Vendor Invoices Transfer Records (between facilities) Toxic Chemical as Inventory End of Year Inventory Records Storage/Warehouse Record Sources of Material Loss (leaks, evaporation, theft etc.) Production Run Data, Batch Tickets, etc. Toxic Chemical Reuse/Recycling Disposal records/recycling Logs 10 Unit of Product A measure that reflects the level of production associated with use of toxic OR generation of toxic as a byproduct Toxics use reduction must be normalized against the level of production Select a measure of facility production that closely reflects activities involving toxics REMEMBER: it s a unit of PRODUCT, not of toxics use! Determining Unit of Product Fundamental Elements In general non physical measures are less accurate than physical measures The more closely the UOP is related to chemical use/byproduct, the more accurate the measure Most firms chose UOP from available data. Not implementing complicated database systems Poorly correlated UOP is where there is random relationship between chemical use/waste and production 12 4

5 Determining Unit of Product Data Sources for Unit of Product Product Shipment Records Product Specifications Invoices to Customers (accounts receivable) Considerations Issues Complications What Correlates Best to Toxics Use? Are There Complexity Factors? 13 Determining Unit of Product Identifying a well correlated UOP will be easiest in cases where: Few uses of a chemical at the site The greater the number of uses the more difficult to find a measure of production that correlates with the waste stream containing the chemical Little variation in the product: variation in product types (surface area, geometric shapes or substrates) makes selecting a UOP more difficult Little change in the process: processes that are constantly changing make measurement from year to year more difficult Also: To find a suitable UOP (1) draw PFD w/chemical path; (2) collect time consistent data (i.e. chemical use vs. SF); (3) test relationship of inputs/variables (linear regression) 14 Determining Unit of Product : Perfect World vs. Real World Perfect World: We can measure final product as we want and we can create any new database system to measure our UOP Our process has very little change and our product has little variation (same shape, size, configuration) We use our chemical only in one process 15 5

6 Determining Unit of Product : Perfect World vs. Real World Real World: Companies chose UOP they believe to be most suitable to their production process Most suitable means not practical to measure square foot of every part produced It results in a not well correlated UOP It s easier for them to get sales dollars or labor hours Influencers such as labor rates or material costs may increase sale dollars, but disconnected from chemical use or byproducts Inconsistent quality of materials accounting data will make byproduct, emission, and UOP estimates difficult 16 Typical Units of Product Form S Cover Sheet lists these unit of product possibilities Example units of product Example toxics use per unit of product Area sq. ft., sq. yard, sq. meter lb (of toxic) per sq. ft. Labor hours Hours lb (of toxic) per hour Kilowatt - hours kwh lb (of toxic) per kwh Length ft, meters, yards, miles lb (of toxic) per ft Number number (of units) lb (of toxic) per number (of chairs, of jars, etc.) Volume gal., litre, cu. ft., board-feet lb (of toxic) per gallon Weight lb, kg, ton, (metric) tonne lb (of toxic) per ton Dollars $ [use only if nothing else works!] lb (of toxic) per $ (of revenue) Determining Unit of Product Measuring TUR in Metal Intensive Industries Hazardous Waste & Hazardous Materials vol. 11, number 2, 1994 Measuring Progress in TUR and Pollution Prevention - Mass TURI/OTA/MADEP Technical Report No Developing and Using Production Adjusted Measurements of Pollution Prevention EPA National Risk Management Research Lab September 1997, and Project Summary November

7 Refresh your memories 5 minutes for a quick quiz 19 Byproducts Non product outputs of toxic or hazardous substances generated by a production unit, before handling, transfer, treatment or release. Otherwise used substances shall be counted as byproduct when they leave a production unit. Outside production unit boundary = Byproduct 20 Emissions A release of a toxic or hazardous substance to the environment or a transfer of a toxic or hazardous substance in waste to an off site location Emissions include: Air (Point and Fugitive) Water (POTW, NPDES, Storm) Hazardous and Solid Wastes Off Site Recycling Outside facility boundary = Emission 21 7

8 Byproduct/Emissions Measurement of Byproduct and Emissions Materials as Byproduct/Emissions Waste Transport Manifests and Invoices Media specific Environmental Reports POTW, NPDES, APSR/SSEIS, Biennial Waste Report Toxics Release Inventory Reports Spill/Release Reports Be Consistent! Materials Reuse/Recycling Recycling Records: Recycler Invoices Recycling Permits Scrap Logs 22 Byproduct/Emission Measurements Use Existing Data Sources Direct Measurements continuous and non continuous (extrapolations from periodic monitoring) Engineering and Design Calculations Best Engineering Judgment Estimates Vendor specs Documentation helps justify Good Faith Effort 23 Mass Balances: Inputs = Outputs Create Production Unit "Invisible envelope" Identify and measure all materials that pass into and out of envelope Equate inputs to outputs + materials accumulated inside envelope 24 8

9 Mass Balancing Material In = Material Out + Material maintained in Production Unit Material Inputs (A) Production Unit (Retained inventory and accumulated materials ) (B) Finished Products (C) Waste Byproducts (D) A = (C + D) + B 25 Byproduct vs. Emissions A1 W1 Waste Water Treatment W2 S2 P in P inv P out Production Unit A Facility Boundary Byproducts: A1 S1 W1 Emissions: A1 S1 S2 W2 S1 26 Byproduct Generation Total byproduct is often the sum of numerous byproduct generation points: B1 B2 B3 Process 1 Process 2 Process 3 B4 B total = B 1 + B 2 + B 3 + B

10 Byproduct Generation Example: Vapor Degreaser Production Unit B1 B2 B3 B4 Solvent Storage Tank Degreaser B5 Byproduct Is related to B1 Losses during solvent delivery Number of Deliveries B2 Volatilization from tank vent Temperature Differences B3 Fugitive (Operating Losses) Hours of Operation B4 Fugitive (Drag-out) Number of Parts/Lots B5 Hazardous Waste Generation Soil Loading and Humidity Why Don t the Inputs = the Outputs? (sometimes, they don t) Chemical reactions Input chemical is neutralized. Chemicals IN are not the chemicals OUT. Example: Input acid neutralized by chemical reaction with a base Output acid is 0 Why Don t the Inputs = the Outputs? (sometimes, they don t) Chemical is a compound Input compounds: total weight must be reported Byproducts, emissions, chemical in product: only listed chemical weight must be reported Example: PbSO 4 (Lead Sulfate) is used in production unit Input: report weight of PbSO 4 Output: report weight of Pb (even if still contained in PbSO 4 ) 10

11 Why Don t the Inputs = the Outputs? (sometimes, they don t) Chemical is non integrally recycled Byproduct weight must be reported for each use Example: 10,000 lbs. of solvent is recycled 9 times after initial use 10,000 lbs. is used 100,000 lbs. is reported as byproduct Compare this with integrally recycled! Non Integral Recycling RECYCLED ONSITE Each time onsite recycled material is re introduced as an input to the Production Unit Adds to Production Unit level chemical use quantities Does not add to facility wide level chemical use quantities Thus, onsite recycling will result in a reduction of the facility wide total usage number RECYCLED OFFSITE Each time offsite recycled material is re introduced as an input to the Production Unit Adds to byproduct AND use Both at Production Unit level And at facility wide level Thus, offsite recycling will NOT result in a reduction of the facility wide total usage number 32 Problem 1: Byproduct Calculation Calculate the Total Byproduct and Emissions Production Unit B is a vapor degrease operation. The company purchased 4,500 lbs. of TCE to operate this production unit for one year. The fugitive emissions from the degreaser (A1) were determined to be 20% of the amount of TCE used in the degreaser. The fugitive emissions from the recycler (A2) were determined to be 5.0% of the TCE sent to the recycler. The spent TCE sent from the degreaser to the recycler was 10,000 lbs for the year. The recycling process recovered 80% of the TCE that was sent to it. A1 P Stamp Degreaser R2 A2 R1 Non Integral Recycler Finishing A1 Fugitive emissions A2 Fugitive emissions B1 Incinerated solvent R1 Spent solvent to recycler R2 Recycled solvent P Purchased solvent S Solvent used in degreaser B1 11

12 Problem 1: Byproduct Calculation Solution Given Equations Byproduct R1 = 10,000 lbs. S = P + R2 = 12,500 lbs. Byproduct = R1+ A1 A2 = R1 x 5.0% = 500 lbs. A1 = S x 20% = 2,500 lbs = 12,500 lbs R2 = R1 x 80% = 8,000 lbs. B1 = R1 R2 A2 = 1,500 lbs. Emissions P = 4,500 lbs. Emissions = A1 + A2 + B1 A1 = 4,500 lbs. P Stamp Degreaser Finishing Production Unit B boundary R2 A2 B1 R1 Non-Integral Recycler A1 Fugitive emissions A2 Fugitive emissions B1 Incinerated solvent R1 Spent solvent to recycler R2 Recycled solvent P Purchased solvent S Solvent used in degreaser Problem 2: Integral vs. Non integral Recycling A production unit uses toluene for parts degreasing. Fresh toluene is added to an open top degreaser at a rate of 8000 lb/yr. 75% of the total toluene input is lost to evaporation, the rest is sent to a non integral recycling still. 2,000 lbs./yr. of recycled toluene from the still is added back to the degreaser. The still loses 15% of its total volume to evaporation. The still bottoms are sent off site as hazardous waste. The process is operated at steady state. a. Draw a process flow diagram of this production unit. b. Calculate the total emissions and total byproducts from this production unit. c. The production unit scenario above was for In 2016 the company hard piped the still to the degreaser. What are the byproduct and emissions for 2016? 35 Problem 2: Integral vs. Non Integral Recycling Solution E D E S F Degreaser D Still R B Production unit boundary GIVEN F = 8,000 lbs. R = 2,000 lbs. E D = 0.75 * (F + R) E S = 0.15 * D NON INTEGRAL CASE Production Unit Balance: F = B + E D + E S Degreaser: D = F + R E D Still: B = D R E S 5 equations, 4 unknowns: E D = (0.75)(10,000 lbs) = 7,500 lbs D = 10,000 7,500 lbs = 2,500 lbs E S = (0.15)(2,500 lbs) = 375 lbs B = 2,500 lbs 2,000 lbs 375 lbs. = 125 lbs 12