TRI Pollution Prevention Report for AVERY DENNISON MILL HALL and Ammonia

Facility ID: 17751VRYCHDRAKE

Facility Name and Address:
AVERY DENNISON MILL HALL
171 DRAKETOWN RD
MILL HALL, PA 17751

Parent Company: AVERY DENNISON CORP

Industry: Adhesive Manufacturing (325520)
Chemical: Ammonia

Production Related Waste Management for Selected Chemical


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    Waste Management Comparison - 2020



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*
2020 Other Barriers to Source Reduction - COVID-19 impacts

2018 Source Reduction:: W52: Modified equipment, layout, or piping[-5-14%]
Methods to Identify SR Opportunities: T11: Other
W52: Changed from totes to bulk storage, reducing fugitive emissions from packaging transfers.

Source Reduction - Process streamlining and potential cost savings.
2017 Source Reduction:: W55: Changed from small volume containers to bulk containers to minimize discarding
Methods to Identify SR Opportunities: T11: Other
W55: Implementation of bulk storage versus tote storage, minimizing fugitive losses and losses from residual in containers

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 - Switch to bulk tank vs non-bulk packaging is awaiting proper resourcing


Barriers to P2: B6 - Pollution prevention previously implemented - additional reduction does not appear technically or economically feas - finished goods require addition of ammonia; no further minimization anticipated.

2015 Barriers: B7-Barriers to P2 B7 - No known substitutes or alternative technologies.

Other Environmental Practices: Source Reduction - It is expected that new storage and inventory management processes will be implemented in 2016 that will reduce fugitive emissions

Other Environmental Practices: Waste Treatment - Currently run primary pretreatment which is not designed to treat for ammonia removal

Barriers to P2: B7 - No known substitutes or alternative technologies. - Substance is a critical raw material in production processes

2013 Source Reduction - Product quality improvement efforts result in higher consumption of water, with resultant increase in wastewater directed offsite to POTW, impacting off-site release of chemical.Finished good properties necessitate use of the chemical, preventing product substitution.


Other Barriers to Source Reduction - Ammonia is a key raw material that presents specific characteristics to finished product. Quality improvements may continue to reduce chemical emissions

2002 Source Reduction:: W55: Changed from small volume containers to bulk containers to minimize discarding

Methods to Identify SR Opportunities: T11: Other
Methods to Identify SR Opportunities: T06: Employee recommendation (under a formal company program)
*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.