TRI Pollution Prevention Report for DETREX and Hydrochloric acid (acid aerosols including mists, vapors, gas, fog, and other airborne forms of any particle size)

Facility ID: 44004DTRXC1100N

Facility Name and Address:
DETREX
1100 STATE RD
ASHTABULA, OH 44004

Parent Company: DETREX CORP

Industry: Other Basic Inorganic Chemical Manufacturing (325180)
Chemical: Hydrochloric acid (acid aerosols including mists, vapors, gas, fog, and other airborne forms of any particle size)

Production Related Waste Management for Selected Chemical

lchemid=0007647010

Waste Management Comparison - 2015

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*
2019		Barriers: B8-Barriers to P2 B8 - A reduction does not appear to be technically feasible	Barriers to P2: B8 - A reduction does not appear to be technically feasible - The HCl gas that is recycled is from fuming hydrochloric acid and the gas is treated so that it does not escape into the atmosphere.
2016	Source Reduction:: W13: Improved maintenance scheduling, recordkeeping, or procedures	Methods to Identify SR Opportunities: T04: Participative team management
2015		Barriers: B6-Barriers to P2 B6 - Pollution prevention previously implemented - additional reduction does not appear technically or economically feas	Other Environmental Practices - Waste reduction and pollution prevention activities include but are not limited to research and development efforts for process improvements and control, production planning, proper inventory management techniques, process improvement meetings with total employee involvement to eliminate manufacturing of off specification materials, and predictive maintenance along with preventive maintenance. We are also ISO 14001 and ISO 9001 certified, and have a mercury PMP program in place. Both ISO 14001 and ISO 9001 programs drive our waste reduction and pollution prevention activities. Barriers to P2: B6 - Pollution prevention previously implemented - additional reduction does not appear technically or economically feas - Best available technology to reduce emissions are currently being used.
2014			Source Reduction: Methods for Identifying Pollution Prevention Opportunities - Waste reduction and pollution prevention activities include but are not limited to research and development efforts for process improvements and control, production planning, proper inventory management techniques, process improvement meetings with total employee involvement to eliminate manufacturing of off specification materials, and predictive maintenance along with preventive maintenance. We are also ISO 14001 and ISO 9001 certified, and have a mercury PMP program in place. Both ISO 14001 and ISO 9001 drive our waste reduction and pollution prevention activities.
2013	Source Reduction:: W13: Improved maintenance scheduling, recordkeeping, or procedures Source Reduction:: W14: Changed production schedule to minimize equipment and feedstock changeovers	Methods to Identify SR Opportunities: T01: Internal pollution prevention opportunity audit(s) Methods to Identify SR Opportunities: T02: External pollution prevention opportunity audit(s) Methods to Identify SR Opportunities: T04: Participative team management Methods to Identify SR Opportunities: T01: Internal pollution prevention opportunity audit(s) Methods to Identify SR Opportunities: T02: External pollution prevention opportunity audit(s) Methods to Identify SR Opportunities: T04: Participative team management
2012	Source Reduction:: W13: Improved maintenance scheduling, recordkeeping, or procedures Source Reduction:: W14: Changed production schedule to minimize equipment and feedstock changeovers	Methods to Identify SR Opportunities: T01: Internal pollution prevention opportunity audit(s) Methods to Identify SR Opportunities: T02: External pollution prevention opportunity audit(s) Methods to Identify SR Opportunities: T04: Participative team management Methods to Identify SR Opportunities: T01: Internal pollution prevention opportunity audit(s) Methods to Identify SR Opportunities: T02: External pollution prevention opportunity audit(s) Methods to Identify SR Opportunities: T04: Participative team management	Source Reduction - Waste reduction and pollution prevention activities include but are not limited to research and development efforts for process improvements and control, improving production planning, proper inventory management techniques, process improvement meetings with all employee involvement to eliminate manufacturing of off specification materials, and preventive maintenance, and predictive maintenance. We are also ISO 14001 certified, ISO 9001 certified, and have a mercury PMP program. Both ISO 14001 and ISO 9001 drive our efforts for continuous improvements in day to day activities for waste reduction and pollution prevention.
2011	Source Reduction:: W13: Improved maintenance scheduling, recordkeeping, or procedures Source Reduction:: W14: Changed production schedule to minimize equipment and feedstock changeovers	Methods to Identify SR Opportunities: T01: Internal pollution prevention opportunity audit(s) Methods to Identify SR Opportunities: T02: External pollution prevention opportunity audit(s) Methods to Identify SR Opportunities: T04: Participative team management Methods to Identify SR Opportunities: T01: Internal pollution prevention opportunity audit(s) Methods to Identify SR Opportunities: T02: External pollution prevention opportunity audit(s) Methods to Identify SR Opportunities: T04: Participative team management	Source Reduction - Waste reduction and pollution prevention activities include but are not limited to research and development efforts for process improvements and control, improving production planning, proper inventory management techniques, process improvement meetings with all employee involvement to eliminate manufacturing of off specification materials, and preventive maintenance and predictive maintenance. We are also ISO 14001 certified, ISO 9001 certifed, and have a mercury PMP program. Both ISO 14001 and ISO 9001 drive our efforts for continuous imporvements in day to day activites for waste reduction and pollution prevention.
2010	Source Reduction:: W13: Improved maintenance scheduling, recordkeeping, or procedures Source Reduction:: W14: Changed production schedule to minimize equipment and feedstock changeovers	Methods to Identify SR Opportunities: T01: Internal pollution prevention opportunity audit(s) Methods to Identify SR Opportunities: T02: External pollution prevention opportunity audit(s) Methods to Identify SR Opportunities: T04: Participative team management Methods to Identify SR Opportunities: T01: Internal pollution prevention opportunity audit(s) Methods to Identify SR Opportunities: T02: External pollution prevention opportunity audit(s) Methods to Identify SR Opportunities: T04: Participative team management	Source Reduction - Waste reduction and pollution prevention activities include but are not limited to research and development efforts for process improvements and control, improving production planning, proper inventory management techniques, process improvement meetings with all employee involvement to eliminate manufacturing of off specification materials, and preventive maintenance and predictive maintenance. We are also ISO 14001 certified, ISO 9001 certified, and have a mercury PMP program. Both ISO 14001 and ISO 9001 drive our efforts for continuous improvements in day to day activities for waste reduction and pollution prevention.
2009	Source Reduction:: W13: Improved maintenance scheduling, recordkeeping, or procedures Source Reduction:: W14: Changed production schedule to minimize equipment and feedstock changeovers	Methods to Identify SR Opportunities: T01: Internal pollution prevention opportunity audit(s) Methods to Identify SR Opportunities: T02: External pollution prevention opportunity audit(s) Methods to Identify SR Opportunities: T04: Participative team management Methods to Identify SR Opportunities: T01: Internal pollution prevention opportunity audit(s) Methods to Identify SR Opportunities: T02: External pollution prevention opportunity audit(s) Methods to Identify SR Opportunities: T04: Participative team management	Source Reduction - Waste reduction and pollution prevention activities include but are not limited to research and development efforts for process improvemetns and control, improving production planning, proper inventory management techniques, process improvement meetings with all employee involvement to eliminate manufacturing of off specificatio materials, and preventive maintenance and predictive maintenance. We are also ISO 14001 certifed, ISO 9001 certified, and have a mercury PMP program. Both ISO 14001 and ISO 9001 drive our efforts for continuous improvement in day to day activities for waste reduction and pollution prevention.
2008	Source Reduction:: W13: Improved maintenance scheduling, recordkeeping, or procedures Source Reduction:: W14: Changed production schedule to minimize equipment and feedstock changeovers Source Reduction:: W19: Other changes in operating practices 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: T05: Employee recommendation (independent of a formal company program) Methods to Identify SR Opportunities: T04: Participative team management Methods to Identify SR Opportunities: T05: Employee recommendation (independent of a formal company program) Methods to Identify SR Opportunities: T04: Participative team management Methods to Identify SR Opportunities: T05: Employee recommendation (independent of a formal company program) Methods to Identify SR Opportunities: T04: Participative team management Methods to Identify SR Opportunities: T05: Employee recommendation (independent of a formal company program)	Source Reduction - Waste reduction and pollution prevention activities include but are not limited to research and development efforts for process improvements and control, improving production planning, proper inventory management techniques, process improvement meetings with all employee involvement to eliminate manufacturing of off specification materials, and preventive maintenance. We are also ISO 14001 certified, ISO 9001 certified, and have a mercury pmp program. Both ISO 14001 and ISO 9001 drive our effort for continuous improvement in day to day activities for waste reduction and pollution prevention.
2007	Source Reduction:: W13: Improved maintenance scheduling, recordkeeping, or procedures Source Reduction:: W14: Changed production schedule to minimize equipment and feedstock changeovers Source Reduction:: W19: Other changes in operating practices 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: T05: Employee recommendation (independent of a formal company program) Methods to Identify SR Opportunities: T04: Participative team management Methods to Identify SR Opportunities: T05: Employee recommendation (independent of a formal company program) Methods to Identify SR Opportunities: T04: Participative team management Methods to Identify SR Opportunities: T05: Employee recommendation (independent of a formal company program) Methods to Identify SR Opportunities: T04: Participative team management Methods to Identify SR Opportunities: T05: Employee recommendation (independent of a formal company program)	Source Reduction - Waste reduction and pollution prevention activities include but are not limited to research and development efforts for process improvements and control, improving production planning, proper inventory management techniques, process improvement meetings with all employee involvement to eliminate manufacturing of off specification materials, and preventive maintenance. We are also ISO 14001 certified, ISO 9001 certified, and have a mercury pmp program. Both ISO 14001 and ISO 9001 drive our effort for continuous improvement in day to day activities for waste reduction and pollution prevention.
2006	Source Reduction:: W13: Improved maintenance scheduling, recordkeeping, or procedures Source Reduction:: W14: Changed production schedule to minimize equipment and feedstock changeovers Source Reduction:: W19: Other changes in operating practices 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: T05: Employee recommendation (independent of a formal company program) Methods to Identify SR Opportunities: T04: Participative team management Methods to Identify SR Opportunities: T05: Employee recommendation (independent of a formal company program) Methods to Identify SR Opportunities: T04: Participative team management Methods to Identify SR Opportunities: T05: Employee recommendation (independent of a formal company program) Methods to Identify SR Opportunities: T04: Participative team management Methods to Identify SR Opportunities: T05: Employee recommendation (independent of a formal company program)
2005	Source Reduction:: W13: Improved maintenance scheduling, recordkeeping, or procedures Source Reduction:: W14: Changed production schedule to minimize equipment and feedstock changeovers Source Reduction:: W19: Other changes in operating practices	Methods to Identify SR Opportunities: T04: Participative team management Methods to Identify SR Opportunities: T05: Employee recommendation (independent of a formal company program) Methods to Identify SR Opportunities: T04: Participative team management Methods to Identify SR Opportunities: T05: Employee recommendation (independent of a formal company program) Methods to Identify SR Opportunities: T04: Participative team management Methods to Identify SR Opportunities: T05: Employee recommendation (independent of a formal company program)
2004	Source Reduction:: W13: Improved maintenance scheduling, recordkeeping, or procedures Source Reduction:: W14: Changed production schedule to minimize equipment and feedstock changeovers Source Reduction:: W19: Other changes in operating practices	Methods to Identify SR Opportunities: T04: Participative team management Methods to Identify SR Opportunities: T05: Employee recommendation (independent of a formal company program) Methods to Identify SR Opportunities: T04: Participative team management Methods to Identify SR Opportunities: T05: Employee recommendation (independent of a formal company program) Methods to Identify SR Opportunities: T04: Participative team management Methods to Identify SR Opportunities: T05: Employee recommendation (independent of a formal company program)
2003	Source Reduction:: W13: Improved maintenance scheduling, recordkeeping, or procedures Source Reduction:: W14: Changed production schedule to minimize equipment and feedstock changeovers Source Reduction:: W19: Other changes in operating practices	Methods to Identify SR Opportunities: T04: Participative team management Methods to Identify SR Opportunities: T05: Employee recommendation (independent of a formal company program) Methods to Identify SR Opportunities: T04: Participative team management Methods to Identify SR Opportunities: T05: Employee recommendation (independent of a formal company program) Methods to Identify SR Opportunities: T04: Participative team management Methods to Identify SR Opportunities: T05: Employee recommendation (independent of a formal company program)
2002	Source Reduction:: W13: Improved maintenance scheduling, recordkeeping, or procedures Source Reduction:: W14: Changed production schedule to minimize equipment and feedstock changeovers Source Reduction:: W19: Other changes in operating practices	Methods to Identify SR Opportunities: T04: Participative team management Methods to Identify SR Opportunities: T05: Employee recommendation (independent of a formal company program) Methods to Identify SR Opportunities: T04: Participative team management Methods to Identify SR Opportunities: T05: Employee recommendation (independent of a formal company program) Methods to Identify SR Opportunities: T04: Participative team management Methods to Identify SR Opportunities: T05: Employee recommendation (independent of a formal company program)
2001	Source Reduction:: W13: Improved maintenance scheduling, recordkeeping, or procedures Source Reduction:: W14: Changed production schedule to minimize equipment and feedstock changeovers Source Reduction:: W19: Other changes in operating practices	Methods to Identify SR Opportunities: T04: Participative team management Methods to Identify SR Opportunities: T05: Employee recommendation (independent of a formal company program) Methods to Identify SR Opportunities: T04: Participative team management Methods to Identify SR Opportunities: T05: Employee recommendation (independent of a formal company program) Methods to Identify SR Opportunities: T04: Participative team management Methods to Identify SR Opportunities: T05: Employee recommendation (independent of a formal company program)
2000	Source Reduction:: W13: Improved maintenance scheduling, recordkeeping, or procedures Source Reduction:: W14: Changed production schedule to minimize equipment and feedstock changeovers Source Reduction:: W19: Other changes in operating practices	Methods to Identify SR Opportunities: T04: Participative team management Methods to Identify SR Opportunities: T05: Employee recommendation (independent of a formal company program) Methods to Identify SR Opportunities: T04: Participative team management Methods to Identify SR Opportunities: T05: Employee recommendation (independent of a formal company program) Methods to Identify SR Opportunities: T04: Participative team management Methods to Identify SR Opportunities: T05: Employee recommendation (independent of a formal company program)
1999	Source Reduction:: W13: Improved maintenance scheduling, recordkeeping, or procedures Source Reduction:: W19: Other changes in operating practices	Methods to Identify SR Opportunities: T04: Participative team management Methods to Identify SR Opportunities: T05: Employee recommendation (independent of a formal company program) Methods to Identify SR Opportunities: T04: Participative team management Methods to Identify SR Opportunities: T05: Employee recommendation (independent of a formal company program)
1995	Source Reduction:: W32: Improved procedures for loading, unloading, and transfer operations	Methods to Identify SR Opportunities: T05: Employee recommendation (independent of a formal company program)
1994	Source Reduction:: W32: Improved procedures for loading, unloading, and transfer operations Source Reduction:: W35: Installed vapor recovery systems Source Reduction:: W39: Other spill or leak prevention	Methods to Identify SR Opportunities: T01: Internal pollution prevention opportunity audit(s) Methods to Identify SR Opportunities: T11: Other Methods to Identify SR Opportunities: T10: Vendor assistance
1993	Source Reduction:: W32: Improved procedures for loading, unloading, and transfer operations Source Reduction:: W35: Installed vapor recovery systems Source Reduction:: W39: Other spill or leak prevention	Methods to Identify SR Opportunities: T01: Internal pollution prevention opportunity audit(s) Methods to Identify SR Opportunities: T11: Other Methods to Identify SR Opportunities: T10: Vendor assistance
1992	Source Reduction:: W32: Improved procedures for loading, unloading, and transfer operations Source Reduction:: W35: Installed vapor recovery systems Source Reduction:: W39: Other spill or leak prevention	Methods to Identify SR Opportunities: T01: Internal pollution prevention opportunity audit(s) Methods to Identify SR Opportunities: T11: Other Methods to Identify SR Opportunities: T10: Vendor assistance
1991	Source Reduction:: W32: Improved procedures for loading, unloading, and transfer operations Source Reduction:: W35: Installed vapor recovery systems Source Reduction:: W39: Other spill or leak prevention	Methods to Identify SR Opportunities: T01: Internal pollution prevention opportunity audit(s) Methods to Identify SR Opportunities: T11: Other Methods to Identify SR Opportunities: T10: Vendor assistance

*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.