TRI Pollution Prevention Report for AMERICAN SYNTHETIC RUBBER CO and Acrylic acid

Facility ID: 40216MRCNS4500C

Facility Name and Address:
AMERICAN SYNTHETIC RUBBER CO
4500 CAMPGROUND RD
LOUISVILLE, KY 40216

Parent Company: MICHELIN NORTH AMERICA INC

Industry: Synthetic Rubber Manufacturing (325212)
Chemical: Acrylic acid

Production Related Waste Management for Selected Chemical

lchemid=0000079107

Waste Management Comparison - 2017

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*
2017	Source Reduction:: W39: Other spill or leak prevention	Methods to Identify SR Opportunities: T04: Participative team management	W39: During outages, removed raw materials from equipment other than storage vessels
2016		Barriers: B6-Barriers to P2 B6 - Pollution prevention previously implemented - additional reduction does not appear technically or economically feas	Other Barriers to Source Reduction - fugitive emissions are covered under Subpart H (LDAR regulations). ASRC is conducting more frequent monitoring than required by regulations. Barriers to P2: B6 - Pollution prevention previously implemented - additional reduction does not appear technically or economically feas - Already very low emissions but Acrylic acid cannot be cost effectively vented thru vent header to control device.
2014	Source Reduction:: W58: Other process modifications	Methods to Identify SR Opportunities: T11: Other
2013	Source Reduction:: W14: Changed production schedule to minimize equipment and feedstock changeovers	Methods to Identify SR Opportunities: T04: Participative team management
2012	Source Reduction:: W14: Changed production schedule to minimize equipment and feedstock changeovers	Methods to Identify SR Opportunities: T04: Participative team management
2011	Source Reduction:: W32: Improved procedures for loading, unloading, and transfer operations	Methods to Identify SR Opportunities: T04: Participative team management Methods to Identify SR Opportunities: T10: Vendor assistance
2010	Source Reduction:: W32: Improved procedures for loading, unloading, and transfer operations	Methods to Identify SR Opportunities: T04: Participative team management Methods to Identify SR Opportunities: T10: Vendor assistance
2009	Source Reduction:: W36: Implemented inspection or monitoring program of potential spill or leak sources Source Reduction:: W52: Modified equipment, layout, or piping	Methods to Identify SR Opportunities: T04: Participative team management Methods to Identify SR Opportunities: T04: Participative team management
2008	Source Reduction:: W13: Improved maintenance scheduling, recordkeeping, or procedures Source Reduction:: W36: Implemented inspection or monitoring program of potential spill or leak sources	Methods to Identify SR Opportunities: T01: Internal pollution prevention opportunity audit(s) Methods to Identify SR Opportunities: T10: Vendor assistance Methods to Identify SR Opportunities: T11: Other
2007	Source Reduction:: W13: Improved maintenance scheduling, recordkeeping, or procedures	Methods to Identify SR Opportunities: T01: Internal pollution prevention opportunity audit(s) Methods to Identify SR Opportunities: T10: Vendor assistance
1994	Source Reduction:: W35: Installed vapor recovery systems Source Reduction:: W39: Other spill or leak prevention	Methods to Identify SR Opportunities: T11: Other Methods to Identify SR Opportunities: T01: Internal pollution prevention opportunity audit(s) Methods to Identify SR Opportunities: T04: Participative team management
1993	Source Reduction:: W35: Installed vapor recovery systems Source Reduction:: W39: Other spill or leak prevention	Methods to Identify SR Opportunities: T11: Other Methods to Identify SR Opportunities: T01: Internal pollution prevention opportunity audit(s) Methods to Identify SR Opportunities: T04: Participative team management

*Classifications of Optional Pollution Prevention Information shown in brackets are provided by EPA.

TRI Pollution Prevention Glossary

The Waste Management Hierarchy

The waste management hierarchy established by the Pollution Prevention Act (PPA) guides waste generators toward the best options for managing wastes. The preferred option is to prevent pollution at its source, but for waste that is generated, the preferred management methods are recycling, followed by burning for energy recovery, treatment and, as a last resort, disposing of the waste.

Source Reduction includes activities that eliminate or reduce the generation of chemical waste.
Recycling includes the recovery of a toxic chemical in waste for reuse.
Energy Recovery includes the combustion of toxic chemicals in waste to generate heat or electricity.
Treatment includes the destruction of a toxic chemical in waste.
Disposal or Other Releases includes toxic chemical quantities entering the environment.

The PPA requires facilities to provide the following details about each chemical they report to TRI:

A breakdown of production-related waste managed. This includes all amounts of the chemical released directly to the environment or otherwise managed as waste, other than waste generated by one-time events not associated with normal production processes (e.g., fires or remedial actions).
A production ratio or activity index to provide context for reported toxic chemical quantities. For example, if a chemical is used in the manufacture of refrigerators, the production index would track the number of refrigerators produced and could be used to help gauge how much of the chemical is being released per unit of production.
Any newly implemented source reduction activities, reported using "W-codes" (e.g., "W41: Increased purity of raw materials")

Facilities may also provide optional Pollution Prevention Information describing their source reduction, recycling, or pollution control activities.