TRI Pollution Prevention Report for 3 SIGMA LLC and Toluene

Facility ID: 4537WSGMCR1985W

Facility Name and Address:
3 SIGMA LLC
1985 W STANFIELD RD
TROY, OH 45373

Parent Company: D12 ULTIMATE HOLDINGS LLC

Industry: Paper Bag and Coated and Treated Paper Manufacturing (322220)
Chemical: Toluene

Production Related Waste Management for Selected Chemical

lchemid=0000108883

Waste Management Comparison - 2019

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:: S44: Other improvements to operating practices and training	Methods to Identify SR Opportunities: T04: Participative team management Methods to Identify SR Opportunities: T01: Internal pollution prevention opportunity audit(s)
2020	Source Reduction:: W52: Modified equipment, layout, or piping	Methods to Identify SR Opportunities: T04: Participative team management Methods to Identify SR Opportunities: T01: Internal pollution prevention opportunity audit(s)	W52: Upgraded the heat exchanger in the Thermal Oxidizer.
2019	Source Reduction:: W19: Other changes in operating practices	Methods to Identify SR Opportunities: T10: Vendor assistance Methods to Identify SR Opportunities: T01: Internal pollution prevention opportunity audit(s)	Source Reduction - Process change Source Reduction - Reduced hazardous toluene waste stream.
2018	Source Reduction:: W19: Other changes in operating practices[-15-24%]	Methods to Identify SR Opportunities: T10: Vendor assistance Methods to Identify SR Opportunities: T01: Internal pollution prevention opportunity audit(s) Methods to Identify SR Opportunities: T11: Other	W19: Changed process to reduce Toluene contaminated material.
2017	Source Reduction:: W19: Other changes in operating practices[-25-49%] Source Reduction:: W71: Other cleaning and degreasing modifications[-0-4%]	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: T10: Vendor assistance 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: T10: Vendor assistance	W19: We changed a process that created a larger amount of tolunene contaminated material. The sorting of this material greatly reduced the volume of contaminated material that had to be handled and transported from the facility. W71: Eliminated/ Reduced the use of fiber wound towels in the cleaning and manufacturing process. Source Reduction - Identifying waste streams and how they were being managed. Helped us reduce the amount of waste that was being sent off by changing manufacturing process and eliminating waste generating streams from prior activities. Source Reduction - Continuous improvement projects with Resource-One team Source Reduction - Vendor suggestion to recycle and launder cleaning rags used in manufacturing. Source Reduction - Working with the Supervisors and Production staff on waste management activities. Source Reduction - Partnership with waste reduction firm to identify and implement changes to reduce our waste that was generated. Source Reduction - Employees use the cloth rags when they are able reducing the contaminated rags that were going into the waste stream.
2016	Source Reduction:: W71: Other cleaning and degreasing modifications[-0-4%]	Methods to Identify SR Opportunities: T01: Internal pollution prevention opportunity audit(s) Methods to Identify SR Opportunities: T04: Participative team management Methods to Identify SR Opportunities: T10: Vendor assistance	W71: Reclamation of used solvents through a distilling process for reuse.

*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.