TRI Pollution Prevention Report for CHURCH & DWIGHT CO INC and Ammonia

Facility ID: 23834LDNCR16101

Facility Name and Address:
CHURCH & DWIGHT CO INC
1851 TOUCHSTONE RD
COLONIAL HEIGHTS, VA 23834

Parent Company: CHURCH & DWIGHT CO INC

Industry: All Other Rubber Product Manufacturing (326299)
Chemical: Ammonia

Production Related Waste Management for Selected Chemical


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    Waste Management Comparison - 2022



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*
2022 Source Reduction:: S04: Substituted manufacturing aid, processing aid, or other ancillary chemical[-50-99%]
Methods to Identify SR Opportunities: T01: Internal pollution prevention opportunity audit(s)
S04: The facility has been evaluating alternative manufacturing aids that are not SARA 313 listed chemicals. Extended trials throughout 2020 - 2022 have been conducted to eliminate the use of ammonia in the dipping process however small concentrations of ammonia will remain in the raw latex. Currently the facility is no longer using ammonia as a manufacturing aid in the dipping process though small concentrations of ammonia will remain in the raw latex used in the manufacturing of condoms.

Source Reduction - In RY2022, the facility continued practices of precision monitoring of ammonia concentration in process tanks. As of 2023, the facility no longer uses ammonia in the dipping / forming of latex condoms.

Source Reduction: Source Reduction - The facility has been evaluating alternative manufacturing aids that are not SARA 313 listed chemicals. Extended trials throughout 2020 - 2022 have been conducted to eliminate the use of ammonia in the dipping process while maintaining product integrity. Currently the facility is no longer using ammonia as a manufacturing aid in the dipping process though small concentrations of ammonia will remain as an ingredient added to the raw latex supply used in the manufacturing of condoms.

2021 Source Reduction:: S04: Substituted manufacturing aid, processing aid, or other ancillary chemical
Methods to Identify SR Opportunities: T01: Internal pollution prevention opportunity audit(s)
S04: Facility is evaluating alternative manufacturing aids that are not SARA 313 listed chemicals. Extended trials are underway to eliminate the use of ammonia.

Source Reduction - In response to a historic upward trend of ammonia usage, the Colonial Heights facility implemented a ammonia reduction initiative in 2016 focusing on precision monitoring of ammonia concentration in process tanks. As a result, ammonia usage per dipped condoms have remained constant since 2017.
2020 Source Reduction:: W13: Improved maintenance scheduling, recordkeeping, or procedures[-5-14%]
Methods to Identify SR Opportunities: T01: Internal pollution prevention opportunity audit(s)
Barriers: B3-Barriers to P2 B3 - Concern that product quality may decline as a result of source reduction.
Source Reduction - The Colonial Heights facility implemented an ammonia reduction initiative in August of 2016, focusing on precision ammonia monitoring of leach water tanks through implementation of daily titrations. This project was in response to a 6 year upward trend in ammonia consumption and an effort to reduce ammonia to Chesterfield County POTW. Ammonia consumption has been reduced 34% per production unit since the initial implementation in 2016.

Barriers to P2: B3 - Concern that product quality may decline as a result of source reduction. - Additional reduction efforts are in progress to reduce or eliminate ammonia. However, an extended evaluation is required to ensure the quality of our product remains the same or improves as a result fo the reduction measures being considered.

2019 Source Reduction:: W13: Improved maintenance scheduling, recordkeeping, or procedures
Methods to Identify SR Opportunities: T01: Internal pollution prevention opportunity audit(s)
Barriers: B3-Barriers to P2 B3 - Concern that product quality may decline as a result of source reduction.
Source Reduction - Daily audits / evaluations of production lines improved efficiency and reduced ammonia consumption per production unit.
Source Reduction - Additional efforts are underway to eliminate ammonia as a production aid



Barriers to P2: B3 - Concern that product quality may decline as a result of source reduction. - Additional reduction efforts are in progress to reduce or eliminate ammonia. However, an extended evaluation is required to ensure the quality of our product remains the same or improves as a result of the reduction measures being considered.

Source Reduction: Source Reduction - The Colonial Heights facility implemented an ammonia reduction initiative in August of 2016, focusing on precision ammonia monitoring of leach water tanks through implementation of daily titrations. This project was implemented in response to a six year upward trend in ammonia consumption and an effort to reduce Chesterfield County POTW ammonia loading. As a result, ammonia consumption was reduced 23.18% per production unit (gross dipped condoms) in 2017 and another 34.18% per production unit from 2018 to 2019. Efforts to minimize ammonia consumption have continued through 2019. Ammonia has been reduced by 44.13% per production unit since the initial 2016 implementation. Approximately 342,700 pounds of ammonia purchases / consumption have been eliminated from our process, since implementation.

2018 Source Reduction:: W13: Improved maintenance scheduling, recordkeeping, or procedures[-25-49%]
Methods to Identify SR Opportunities: T01: Internal pollution prevention opportunity audit(s)
Barriers: B3-Barriers to P2 B3 - Concern that product quality may decline as a result of source reduction.
W13: Beginning in mid 2017, ammonia concentrations were monitored and adjusted based on specific process variables which allowed the facility to reduce ammonia use per production unit.

Source Reduction - Daily audits / evaluations of production lines improved efficiency and reduced ammonia consumption per production unit.
Source Reduction - Evaluations are currently underway to eliminate the use of ammonia as a manufacturing aid.



Source Reduction: Source Reduction - Through on-going measures to reduce ammonia consumption while maintaining a superior quality product, the facility has reduced ammonia consumption per production unit by 41.7% in 2018 compared to 2017 and has reduce ammonia consumption 55.3% in 2018 compared to 2016.

Barriers to P2: B3 - Concern that product quality may decline as a result of source reduction. - Additional reductions efforts are underway to reduce or eliminate ammonia. However, this process will take time to ensure the quality of our product remains the same or better by the reduction measure being considered and implemented.

2017 Source Reduction:: W15: Introduced an in-line product quality monitoring or other process analysis system
Methods to Identify SR Opportunities: T01: Internal pollution prevention opportunity audit(s)
W15: In 2016 the facility developed a GMP of conducting daily titrations of the process tanks to provided management with a precise ammonia concentration in each leach tank, allowing management to make the appropriate adjustment in ammonia feed rates. 2017 was the first full year in which this policy could be evaluated. The improved management and data collection of ammonia concentrations in the process tanks reduced ammonia consumption 23.17% per dipped condom in 2017 vs 2016, reversing a 6 year upward trend in ammonia consumption per dipped condom.


Other Environmental Practices: Recycling - In 2017, the facility reduced water consumption 2.21% compared to 2016. Through the years, water conservation efforts throughout the facility include, recycling of form rinses, process improvements in waste water treatment to reduce water consumption, recycling of cornstarch slurry in tumbling, best management practices in dipping to monitor and regulate high water consumption processes and increased monitoring of water consumption to identify and eliminate excess water usage. These efforts combined over a 10-year period have reduced water consumption 54.87% per gross dipped condom.

Other Environmental Practices: General Environmental Management - Daily conductivity measurements of the process tanks are being conducted and evaluated to ensure chemical dosing of ammonia remains in the optimum range, preventing over/under charging the process tanks with chemistry and ensuring quality defects are minimized.

2016 Source Reduction:: W19: Other changes in operating practices
Methods to Identify SR Opportunities: T01: Internal pollution prevention opportunity audit(s)
W19: Facility continues to meter ammonia into the process tanks in a controlled manner however, due to increased demand for bulbous tip condoms, increased amounts of ammonia is required to release the condom from the mold.


Other Environmental Practices: Recycling - Through water reduction measures implemented in 2016 and late 2015, water consumption per gross dipped condom was reduced 8.459% in 2016 vs 2015 per gross dipped condom. Facility wide, water consumption was reduced 14.455% in 2016 vs 2015.

Source Reduction: Ways P2 Was Incorporated in Original Process Design - Daily conductivity readings of the dip line leach tanks are being collected and evaluated to ensure chemical dosing of Ammonia remain in the optimum range, preventing over/under charging the process tanks with chemistry and ensuring quality defects are minimized. While ammonia consumption for 2016 vs 2015 continued on an upward trend for the year, after implementing the auto titration method to determine chemical doses in July 2016, ammonia consumption was reduced 4.05% per GDC from August - Dec 2016 when compared to Jan - July. The auto titration method to determine chemical dosing is anticipated to reverse a 5 year upward trend in ammonia consumption per GDC.

2015 Source Reduction:: W19: Other changes in operating practices
Methods to Identify SR Opportunities: T01: Internal pollution prevention opportunity audit(s)
W19: Facility continues to meter ammonia into process tanks in a controlled manner however, due to increased demand for bulbous tip condoms, increased amounts of ammonia is required to release the product from the mold.


Other Environmental Practices: Recycling - Water re-use efforts in the dipping department (re-piping of form rinses to reuse a portion of the form rinse in the process) combined with increased scrutiny of daily water consumption / discharge data resulted in a reduction of 9.38% water consumption per gross dipped condom in 2015 vs 2014. Water usage per gross dipped condom has been down every year since 2011, resulting in an overall reduction of 29% /gross dipped condom in 2015 compared to 2011

2014 Source Reduction:: W19: Other changes in operating practices
Methods to Identify SR Opportunities: T01: Internal pollution prevention opportunity audit(s)
W19: W19 - Facility continues to meter ammonia into process tanks in a controlled manner however, due to increased demand for bulbous tip condoms, increased amounts of ammonia is required to release the product from the mold.

Source Reduction - Increased segregation of recyclable materials focusing heavily on corrugate and plastics resulted in a 38.48% increase in corrugate recycling per gross dipped condom in 2014. The segregation of recyclable materials resulted in 6.8% less general trash disposal per gross dipped condom, and an overall reduction in landfill disposal of general trash by 23.48 tons in 2014 vs 2013.Waste ink/alcohol was reduced 23.5% per gross dipped condom in 2014. This reduction was a secondary gain obtained from redesigning lube pump fittings and delivery systems. The modified lubricant delivery system resulted in an improved efficiency of equipment cleaning involving the use of alcohol.



Other Environmental Practices: Recycling - Water re-use efforts in the dipping department (re-piping of form rinses to reuse a portion of the form rinse in the process) combined with increased scrutiny of daily water consumption / discharge data resulted in a reduction of 9.37% water consumption per gross dipped condom in 2014 vs 2013. Overall usage was down 12.05% in 2014 compared to 2013.

2013 Source Reduction:: W19: Other changes in operating practices
Source Reduction:: W58: Other process modifications
Methods to Identify SR Opportunities: T01: Internal pollution prevention opportunity audit(s)
Methods to Identify SR Opportunities: T01: Internal pollution prevention opportunity audit(s)
Source Reduction - By continued evaluation and refining of processes that consume large volumes of water, the facility was able to reduce water consumption 2.1% per dipped condom in 2013 vs. 2012. This is in addition to the 8.97% reduction of water consumption
2012 Source Reduction:: W19: Other changes in operating practices
Methods to Identify SR Opportunities: T01: Internal pollution prevention opportunity audit(s)
Source Reduction - In 2012 the facility increased the operational speed of the manufacturing equipment. As a result the facility experienced resource reductions of 1.51% less electricity per unit, 3.83% less natural gas per unit, and 8.97% less water per unit. Concerns regarding decline in production quality were identified with some ammonia source reduction activities. Ammonia is required as a release agent for product removal from the mold. Controls have been implemented to limit ammonia consumption/emissions. However, specific production units demand higher ammonia levels for proper release, which offset any anticipated reductions
2006 Source Reduction:: W53: Use of a differant process catalyst
Source Reduction:: W74: Improved application techniques
Methods to Identify SR Opportunities: T01: Internal pollution prevention opportunity audit(s)
Methods to Identify SR Opportunities: T05: Employee recommendation (independent of a formal company program)
2003 Source Reduction:: W32: Improved procedures for loading, unloading, and transfer operations
Source Reduction:: W49: Other raw material modifications
Methods to Identify SR Opportunities: T06: Employee recommendation (under a formal company program)
Methods to Identify SR Opportunities: T06: Employee recommendation (under a formal company program)
1998 Source Reduction:: W58: Other process modifications
Methods to Identify SR Opportunities: T11: Other
*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:
Facilities may also provide optional Pollution Prevention Information describing their source reduction, recycling, or pollution control activities.