TRI Pollution Prevention Report for KOCH SEPARATION SOLUTIONS INC. and N-Methyl-2-pyrrolidone

Facility ID: 01887KCHMM850MA

Facility Name and Address:
KOCH SEPARATION SOLUTIONS INC.
850 MAIN ST
WILMINGTON, MA 01887

Parent Company: KOCH INDUSTRIES INC

Industry: All Other Miscellaneous Manufacturing (339999)
Chemical: N-Methyl-2-pyrrolidone

Production Related Waste Management for Selected Chemical

lchemid=0000872504

Waste Management Comparison - 2021

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*
2021	Source Reduction:: S41: Improved scheduling, record keeping, or procedures for operations, cleaning, and maintenance	Methods to Identify SR Opportunities: T11: Other	S41: Batch size has increased for several operations that allow for extended operations and less scrap due to start up and shut down procedures.
2020			Other Barriers to Source Reduction - Limited resources were available due to pandemic, resulting in technical resources being diverted to ensuring continuation of operations with highly fluid manpower.
2016		Barriers: B6-Barriers to P2 B6 - Pollution prevention previously implemented - additional reduction does not appear technically or economically feas	Barriers to P2: B6 - Pollution prevention previously implemented - additional reduction does not appear technically or economically feas - Previous membrane thickness and tank equalizations have been optimized. Identified alternative chemistry falls into the same regulatory categories.
2012	Source Reduction:: W13: Improved maintenance scheduling, recordkeeping, or procedures Source Reduction:: W58: Other process modifications	Methods to Identify SR Opportunities: T04: Participative team management Methods to Identify SR Opportunities: T04: Participative team management
2011	Source Reduction:: W13: Improved maintenance scheduling, recordkeeping, or procedures Source Reduction:: W58: Other process modifications	Methods to Identify SR Opportunities: T04: Participative team management Methods to Identify SR Opportunities: T04: Participative team management	W13: PM program has been formalized into Facilities MPET System for rescheduling PM activities. Facility has also scheduled in shut down activities to facilitate PM activities. W58: Facility is evaluating all processes to determine the potential for improvements that will optimize their operation to minimize scrap. Source Reduction - Facility participates in Massachusetts Toxic Use Reduction Act (TURA) activities that evaluate ways of reducing the use of chemicals that are TRI and TURA listed Source Reduction - This chemical was reported in prior years with our existing manufacturing processing. The increase in use in 2011 is due to the commissioning of a new membrane manufacturing facility. The facility participates in Toxic Use Reduction Act (TURA) planning that evaluation options for reducing the use of listed chemicals. Several projects were identified in this year''s TURA planning session that may help to reduce the overall use of this chemical, as well as, other chemicals used in all of our manufacturing processing. Note that the production ratio is 2 fold, but the wast and chemical use did not significanlty increase with the new process line.

*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.