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Facility ID: 77032GHYDR33NSA
Facility Name and Address: HYDRIL USA DISTRIBUTION LLC - JFK 3300 N SAM HOUSTON PKWY E HOUSTON, TX 77032 Parent Company: HYDRIL CO Industry: Oil and Gas Field Machinery and Equipment Manufacturing (333132) Chemical: Ethylene glycol Reports: View TRI Facility profile report for this facility View TRI Form R submissions by this facility |
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Production Related Waste Management for Selected Chemical
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Pollution Prevention Activities for Selected Chemical
Reporting Year | Section 8.10: Newly Implemented Source Reduction Activity | Section 8.10: Methods to Identify Activity | Section 8.11: Optional Pollution Prevention Information* |
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2022 |
Source Reduction:: S34: Improved monitoring practices of potential spill or leak sources[-0-4%]
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Methods to Identify SR Opportunities: T04: Participative team management
Barriers: B3-Barriers to P2 B3 - Concern that product quality may decline as a result of source reduction. |
S34: Employee engagement Environmental Team refined. Team employees trained to perform daily walks of waterways and outfalls when HSSE is not available to verify no releases have occurred during operations. Source Reduction - Employee participation in an Environmental Team. Employees trained to act as eyes and ears to identify unauthorized releases and how to respond to those releases. Employees are trained to be aware of other locations in the facility that pose a higher risk and to perform visual inspections of those areas on a regular basis. Employees trained on proper cleanup and mitigation efforts as required. Barriers to P2: B3 - Concern that product quality may decline as a result of source reduction. - Ethylene glycol is used in combination with water at a +/- 6% concentration to perform pressure testing on our equipment. The ethylene glycol acts as a rust inhibitor inside of our equipment which is critical to safe and proper operation of our product. |
2021 |
Source Reduction:: S41: Improved scheduling, record keeping, or procedures for operations, cleaning, and maintenance[-15-24%]
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Methods to Identify SR Opportunities: T01: Internal pollution prevention opportunity audit(s)
Methods to Identify SR Opportunities: T04: Participative team management Barriers: B8-Barriers to P2 B8 - A reduction does not appear to be technically feasible Barriers: B3-Barriers to P2 B3 - Concern that product quality may decline as a result of source reduction. |
S41: Site trains employees for waste disposal practices, spill cleanup and prevention techniques, and proper chemical handling and mixing procedures in line with our permits, local, and national regulations Source Reduction - Site inspects and monitors all tanks and outfalls daily for signs of leaks or releases. Source Reduction - All Employees are trained to identify and report any potential chemical spills or other releases. Subset of Employees are trained waste handlers and spill cleanup responders. Barriers to P2: B8 - A reduction does not appear to be technically feasible - The method of testing allows us to apply the ethylene glycol during the testing process instead of filling our equipment a second time with a rust/freeze inhibitor separate of the testing process. This allows us to reduce waste and water usage by not having multiple fill and drain processes on the equipment. Barriers to P2: B3 - Concern that product quality may decline as a result of source reduction. - Ethylene glycol is used as additive to tap water at a 4-6% concentration in order to hydraulically test our equipment while simultaneously providing a layer of rust inhibitor and freeze protection to our equipment internals. |
2020 |
Barriers: B6-Barriers to P2 B6 - Pollution prevention previously implemented - additional reduction does not appear technically or economically feas
Barriers: B8-Barriers to P2 B8 - A reduction does not appear to be technically feasible Barriers: B3-Barriers to P2 B3 - Concern that product quality may decline as a result of source reduction. Barriers: B7-Barriers to P2 B7 - No known substitutes or alternative technologies. |
Barriers to P2: B8 - A reduction does not appear to be technically feasible - We are already diluting the ethylene glycol down to as little approximately 5-6% in water in order to facilitate the testing operations and still allow the chemical to perform it's intended duty. Other Environmental Practices: General Environmental Management - The site Best Management Practice is to keep all oily waste, including Ethylene Glycol, on or in secondary containment at all times. This includes virgin product, during use, and waste management. Other Environmental Practices: Recycling - The goal is to recycle as much of our waste as possible. The facility utilizes proven 3rd party waste vendors. The site has recycled or sent for alternative use 97.70% of its total generated waste. This is an important metric for us as it keeps this waste out of landfills and reduces our environmental impact. Barriers to P2: B6 - Pollution prevention previously implemented - additional reduction does not appear technically or economically feas - Mixing and production equipment are closed systems located on secondary containment and/or within a trenched floor and collection system. Waste storage tanks have secondary containment. Chemical product is stored on secondary containment pallets or in our designated chemical storage areas with secondary containment. Barriers to P2: B7 - No known substitutes or alternative technologies. - Ethylene glycol is a standard product used in pressure testing to provide a stable test medium as well as corrosion and freeze inhibitor for our products. Other Environmental Practices: Waste Treatment - 100% of our ethylene glycol waste goes to a waste water treatment place that treats and recycles our waste water. Barriers to P2: B3 - Concern that product quality may decline as a result of source reduction. - Engineering has determined the minimum required amount to be mixed with our test water to a) reduce chemical on hand which limits potential environmental exposure, b) comply with quality standards, and c) reduce overall cost of production. |
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2019 |
Barriers: B3-Barriers to P2 B3 - Concern that product quality may decline as a result of source reduction.
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Barriers to P2: B3 - Concern that product quality may decline as a result of source reduction. - Site needs to use ethylene glycol for pressure testing to ensure product quality. The amount of ethylene glycol used is dependent upon demand for customer qualification, which requires the use of ethylene glycol as an additive during pressure testing. The amount of offsite disposal, however, should be reduced in RY2020 due to the facility evaporator coming back online after being out of commission. Other Environmental Practices: General Environmental Management - As part of the facility's ISO 14001 program, it has put forth as an environmental objective to reduce the amount of ethylene glycol (oily wastewater waste stream) generated. The facility's plan to revamp the use of the on-site evaporator unforutnately did not happen in RY2019; however, it is currently under construction and should come back into commission in RY2020. The resulting reduction in the site's ethylene glycol transfers should be reflected on the RY2020 TRI submittal. |
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2018 |
Barriers: B3-Barriers to P2 B3 - Concern that product quality may decline as a result of source reduction.
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Barriers to P2: B3 - Concern that product quality may decline as a result of source reduction. - Ethylene glycol is a component in our pressure testing fluid and necessary for certification process of our products. Other Environmental Practices: General Environmental Management - As part of the facility's ISO 14001 program, it has put forth environmental objectives & targets to reduce the amount of ethylene glycol (oily wastewater waste stream) generated. This includes revamping the site evaporator to minimize off-site waste disposal transfers and determining how to make this waste stream recyclable at the TSD facility. Source Reduction: Methods for Identifying Pollution Prevention Opportunities - Site is making efforts to discuss reuse of ethylene glycol-based test fluid with Product Quality team. |
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2017 |
Other Barriers to Source Reduction - Due to market factors, our business has switched from new-make manufacturing to a more services based business, which has lead to an increase in pressure testing. The pressure testing fluids contain ethylene glycol, as it has desirable chemical properties for our products. |
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2016 |
Source Reduction:: W54: Instituted better controls on operating bulk containers to minimize discarding[-0-4%]
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Methods to Identify SR Opportunities: T11: Other
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W54: Bought materials in bulk, thus reducing the amount of polyethylene containers brought on-site. |